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Partnership For The Sustainable Development of Digby Neck and Islands Society Comments on the draft EIS guidelines submitted to the Panel Review
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The Digby Neck Community Development Association
Comments on Draft Guidelines for the Preparation of the Environmental Impact Statement for the Whites point Quarry and Marine Terminal Project
The Digby Neck Community Development Association (DNCDA) is submitting these written comments on the draft guidelines, in addition to the spoken comments that were presented on January 6, 2005, at the Digby Neck Consolidated School.
DNCDA was formed ten years ago with a mission to work for the health of the communities and environment of Digby Neck. Since that time we have undertaken a wide range of community economic development, environmental, adult education and community capacity building initiatives. We publish a monthly newsletter that goes to every household on Digby Neck, and our board is constituted to represent all villages and sectors of Digby Neck.
These comments are the result of intensive consultations with Digby Neck community members, both individually and in a series of “kitchen table” meetings.
3.0 Consideration of Traditional Knowledge
The category of traditional knowledge must be expanded to recognize the traditional knowledge, and in particular traditional ecological knowledge, of the population of Digby Neck, the fishers of Digby Neck and of the wider region. Recognition of traditional local ecological knowledge has long been accepted as part of fisheries research, especially for inshore fisheries.
5.3 The Proponent
The EIS should provide evidence that the proponent and all its associated interests have a track record as a good corporate citizen, in Canada and internationally. This should include affiliates and backers, including Clayton Concrete and the various company names it may have used for its international operations. Without this evidence, the EIS will lack the credibility necessary to effectively inform the decision-making process related to this project.
9.0 Effects Prediction, Mitigation and Significance of Residual Effects
We feel that it is essential that the Precautionary Principle be added, either to this section or to another section. The precautionary Principle is a keystone of Canada’s Oceans Policy and to exclude it would considerably weaken the guidelines.
9.2.3 Commercial and Recreational Fisheries
General
For all fish species the EIS
• should have a geographical scope that takes into account the speed and range of tides and currents of the Bay of Fundy, Petite Passage and St. Mary’s Bay
• should describe the effect of the quarry on each species ability to reproduce, including spawning, juvenile and ability to reproduce
• should take into account the effect of the quarry on the habitat for all species, including plant species, e.g. rockweed, kelp
• should recognize the Precautionary Principle throughout
• Should groundtruth all its findings with evidence based on local fishermen’s traditional ecological knowledge
Species
The EIS should specifically include
• all commercially harvested species, including, but not limited to cod, haddock, pollock, dogfish, scallop, lobster, crab sea urchin, sea cucumber
• should include all species in the food chains, on which the commercially harvested species depend, directly or indirectly
• all species which have the potential for future commercial fisheries Invasive Species The EIS should give evidence that the ballast water from carrier vessels will not introduce invasive species than could harm the fisheries
Safety of Persons and Property
The EIS should specifically include
• evidence that blasting will not have a deleterious effect on fishermen who work in the vicinity of White’s Cove
• evidence that the carrier vessels will not destroy fishing gear, including in unpredictable weather circumstances, where they have to leave the usual shipping lanes
On-Land Fish Processing
The EIS should give evidence that the quarry will not have a negative economic effect on the water table, e.g. salination, reduction, that will adversely effect the local fish processing plants, which require large quantities of fresh water.
Economic
The EIS should include evidence that the fisheries of the Bay of Fundy and St. Mary’s Bay will not be harmed by the project
9.2.6 Recreation and Tourism
Whales
The EIS should include evidence
• that the quarry will not result in whales moving away from Digby Neck, affecting the local whale-watching industry, and all the tourism-related businesses that depend on it;
• that the quarry will not harm any species of whales
Tourism Potential
The EIS should include evidence that the quarry will not harm the future potential of tourism and ecotourism on Digby Neck and The Islands, including trails, heritage, sailing, diving, camping or any other potential development Birds The EIS should include evidence that the quarry will not have an adverse effect on migratory birds, e.g. habitat, nesting, migratory patterns, in such a way that harms the local tourism businesses dependent on birdwatching
Marketing
The EIS should include evidence that the quarry will not harm the image of Digby Neck and Islands as an ecotourism destination.
Economic
The EIS should include evidence that the activities associated with the quarry, including but nor restricted to blasting, trucking, shipping grinding rock, will not have an adverse economic effect on the present or potential tourism industry of Digby Neck and the Islands.
9.2.7 Human Health
Participation in Decision-Making
In considering the mental and cultural health of the communities of Digby Neck, and in particular Little River, the EIS should include evidence that a majority of residents are in favour of the project. The recent literature of indicators of community health, including the United Nations Development Program, has clearly identified participation in decision-making that is important to the community’s future, as a key determinant of community health. Thus, if the quarry goes ahead against the strong wishes of a large majority of the residents of Digby Neck, the community’s mental and cultural well-being will be seriously undermined. The loss of control about the community’s future must be taken into account in the EIS, if it is to fully assess the effect on the health of the community.
Combined Effects
The EIS should also factor in the combined effects on some of the residents of Little River. For example, some fishermen may experience a negative impact from the project, both in terms of their livelihoods, i.e. when they are fishing in the Bay of Fundy, and on their home lives, i.e. when they return to their families in the evening. The totality of all the effects- stress about children’s health, devaluation of property values, undermining of community morale, impact on local fishers livelihoods and many more- must be dealt with in combination, not just one at a time. The potential harm that this project will do will not be experienced in neat packages, but rather as a cumulative whole. This reality should be reflected in the EIS.
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