To Jonathan Wilkinson, Minister of Fisheries and Oceans; Iain Rankin, Nova Scotia Minister of Environment; Catherine McKenna, Minister of Environment and Climate Change; Premier Stephen McNeil of Nova Scotia; Premier Wade MacLaughlan of PEI
Honorable ministers,
I have a hard time understanding how there is any confusion regarding how an effluent pipe, with a volume of this magnitude, directly to the Northumberland Strait, won’t cause any negative effects to the marine environment and the existing fishery.
Basically, Northern Pulp wants to redirect the majority of the flow from the Middle River – between 62 and 90 million liters per day, heat it up to 37 degrees Celsius, add one ton of what is technically toxic waste solids, then direct that to the mouth of Caribou Harbour.
This effluent will kill lobster larvae; it’s inevitable and would directly breach section 36 of the Federal Fisheries Act. The mill then states, ‘it’s unlikely there will be any harm to lobster,’ in their environmental assessment. It is virtually impossible that there will not be adverse effects from this dramatic redirection of the Middle River, to the mouth of Caribou Harbour.
For our Provincial government to have not immediately sent this to the Federal government for environmental assessment is outrageous. To suggest, ‘this is not a new facility, just replacement of an existing one’, as the reason for a provincial assessment, is not reasonable or realistic. To completely redirect the flow of a major river to the mouth of Caribou Harbour, miles from where it’s been flowing, into the very heart of the most lucrative lobster and herring grounds in the Northumberland Strait, a provincially shared Federal Fishing zone, this goes beyond responsible, honest government, with regards to the environmental assessment applied.
Our government is in an obvious conflict of interest. The Supreme Court of Canada agrees, according to the ruling of Justice Timothy Gabriel last fall, with regards to Pictou Landing First Nations and the Provincial Government with respect to the government funding of a replacement facility and the relationship with Northern Pulp. Justice Gabriel stated, “… it would essentially boil down to the Crown (wearing one hat) being called upon to determine whether a project which the Crown (wearing another hat) has funded passes muster. This will do nothing to assuage whatever cynicism has been engendered in the past.”
I believe the working group of fishermen’s organizations, together with Pictou Landing First Nations, should be taking the Province and Northern Pulp to Supreme Court on this basis; in the event the Federal Government does not step in and take control of this environmental assessment. I believe we, as fishermen and First Nations, have a legal right to protect our industry – and Justice Gabriel has set the precedent.
We undoubtedly will lose our Marine Stewardship Certification, (a major marketing tool), for both our herring and lobster fisheries as a result of this new effluent pipeline, as part of the criteria is the species are harvested from a healthy environment, in a sustainable fashion. It’s already affecting the existing fishery and not just here, in P.E.I as well. Fishermen are anticipating the value of their enterprises to be less than half what there are now, as soon as there is real indication of construction of this effluent pipe; and some have literally already sold out on this realistic assumption.
In Northern Pulps submitted proposal, the pipe is required to be set at a depth below the seabed of three meters due to potential from ice damage. To accomplish this, they submit the trench would have to be 9 meters across, for the entire length of 4.1 kilometers from where it enters the harbour adjacent to the ferry dock, to the mouth of the harbour, the proposed discharge location. The sediment alone from this construction would destroy the local fishery and directly breaches section 35 of the Federal Fisheries Act as it will destroy marine habitat, eelgrass beds, etc., killing juvenile fish, lobster and crab. The sediment dispersed will cause havoc with the marine environment for miles and for how long, is anyone’s guess.
There came a point in time when the environment outweighed the economy, it has passed. In this day and age, to even consider directing this massive flow of ‘treated’, poisonous effluent directly to the Northumberland Strait, is not reasonable.
There is an alternative, yet the mill will not consider it, as it would mean less profits – converting the mill to a mechanical process that separates the pulp, no effluent discharge required and less air emissions – this actual possibility could be discussed at length. The mill simply will not consider it, as it is less profitable and there would be ‘downtime’ at their expense while converting.
Our government is closing Boat Harbour in January 2020, ten years premature of the lease agreement, but actually 25 years late, from what was originally promised to Pictou Landing First Nations (PLFN). To continue using Boat Harbour, is to continue with the current environmental racism that PLFN have been enduring for 52 years and are currently, on a daily basis, contending with. To ask for an extension, is simply ignorant. Because the closure of Boat Harbour is premature of this lease agreement that the Province agreed to without PLFN consent, Premier McNeil has been quoted saying that the monies our government will be giving Northern Pulp are not to directly pay for the estimated $130 million 15.5 km pipe and new treatment facility, but in lieu of the lease agreements early closure….
Obviously, this $130 million could be better spent on converting the mill to a mechanical, closed loop system. The mill has no interest and has continually stated, no pipe = no mill. If all you are thinking about is profits, you can’t blame them. This company, Asia Pulp and Paper, subsidiary, Paper Excellence, buys up mothballed pulp mills for peanuts in comparison to today’s cost, (that would be upwards of 2 billion dollars), spends next to nothing on upgrades, rakes in government subsidies and hand-outs… and in the case of our mill, is not responsible for any environmental damage. What a deal! The mill with one of the worst environmental records in the country, suffers no consequences for environmental damage – a coincidence? Think about that, why would you improve your discharges, (air and water), if there are no consequences?
No, you can’t blame them for not wanting to convert the mill. There would be downtime and they couldn’t sue our government for it – and they will be suing for any ‘downtime’ when Boat Harbour closes, you can count on that.
They have a sweetest of deals right now and the fishing and forestry industries are both paying for it! The thing is, our government, (the people), have allowed this to happen. The question is, will we continue to?
This mill is not worried about our marine environment and really, other than from a profits perspective, they are not worried about the longevity of our forest industry either.
I don’t suspect anyone in the forest industry would want any harm to the fishing industry and I know the reverse is the same; we in the fishing industry want the forest industry to thrive, but simply not at our expense. There is a solution and the extension of Boat Harbour is not the solution. The solution is to convert the mill; this is what the forest industry should be promoting to Northern Pulp.
Thanks,
John Collins Alma Road,
Loch Broom, N.S.
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