Attn: DFO Minister, Bernadette Jordan
Department of Fisheries, Oceans and Coast Guard
November 22th. 2019
Dear Minister Jordan,
First, please let me congratulate you on your appointment as Minister of Fisheries and Oceans. We are very proud to have a Nova Scotian working on this portfolio.
Over the past two decades, I’ve chaired a citizen group in the Annapolis Valley whose concern is to create proper fish passage for the conservation of Endangered Wild Atlantic Salmon, American Eel and other species at the Windsor Causeway in Nova Scotia. Today we are more concerned than ever because the latest plan for twinning this particular section of Hwy 101 will, if approved, significantly restrict safe and easy migration for many of these species.
The Department of Transportation and Infrastructure and the Department of Agriculture are currently designing an aboiteau across the Avon River channel, with the intent of maintaining ‘lake levels’ on the upstream side, while meeting the requirements for fish passage under the Fisheries Act. Not withstanding the years of experimentation and precedent for free tidal flow on the Petitcodiac River in New Brunswick which in 2010 called for a partial opening, not an aboiteau, as the sole solution to the causeway damage – the proponents here in Nova Scotia for the Avon River Causeway are promising that this latest experimental aboiteau will succeed where New Brunswick failed.
In a real cost benefit analysis the Petitcodiac model wins, to such a degree that they’ve now gone on to widen the opening by removing the entire causeway on their river. The Avon River project EA Study does not take the same approach as the Petitcodiac EA, and carefully sidesteps many aspects of the picture in order to make their plan appear sensible.
If such an aboiteau proposal were approved, it would then have to be followed up by careful monitoring for years to determine the efficacy of its ability to allow fish passage, to maintain a healthy river ecosystem, and to successfully flush any accumulating overload of silt in ‘Lake Pesiquid’ – which lessons from the Petitcodiac tell us is a big waste of time and resources in these micro-tidal rivers. Free tidal flow is the only way to go.
If such an aboiteau proposal were approved, the performance of the fish passage, habitat quality, and silt balance the performance of this test aboiteau is unproven at this time; yet numerous studies suggest that any restriction to these inner river tidal flows results in negative impacts in all these areas. Monitoring will soon show if this was a bad gamble, or did they really do the science? If monitoring proves they’ve failed, the proponents could be subject to fines and civil suits, and would have to fix up the mess, much like the Petitcodiac.
Even more distressingly, the latest plans call for doors and gates to be attached on the fish passage openings, so that blockages can be arbitrarily imposed to an unspecified degree, for whatever reason. This is a design option that no science supports; it guarantees added environmental impacts. Adding doors and gates will exacerbate the fish passage problems, water quality and siltation. The remaining endangered Wild Atlantic Salmon of the Avon River cannot endure this test. More tidal flow is much better than less tidal flow.
Please find attached a slightly abridged (just the ‘text’) copy of Lisa Isaacmans critical study for the Avon River Causeway, transcribed by us, which the author has given permission to distribute. I’ve also attached a PDF for the Petitcodiac EA Study, although getting ones hands on the transcripts from the Peticodiac Open House Meeting, and iBoF Recovery Team Meetings would lend to a better understanding of the picture, where most of the scientific consensus rests.
After 50 years, we finally have the chance to fix the causeway mistake and we can begin to recover the Wild Atlantic Salmon and the health of the Avon River. May I ask you to find some time in the near future to meet with me so we can discuss this further? Thank you; I look forward to hearing from you soon.
Sonja E. Wood (FAR Chair)
Friends of the Avon River
127 Blue Beach Rd.,
Hantsport, Nova Scotia
B0P 1P0, Canada
Save the Avon River!
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