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Comments on the draft EIS guidelines submitted to the Panel Review Return to the Submission List | HOME PAGE Written comments to the Draft EIS Guidelines for the Whites Point Quarry and Marine Terminal Project, November 2004 Prepared by Kemp L. Stanton, Whale Cove, Digby Neck, NS I am submitting some of my concerns for your consideration although some of these may have been dealt with already or later in the process. I am hoping you can find a way to see that they are addressed adequately somewhere in the proceedings. 1. Night operations – I believe the Project is supposed to be an 18-hour-a-day operation. The installed lights are likely to be left on at night, causing concerns for bird migration and for fish feeding and migrating through the area. Also ship-loading operations will have to take place at night many times because of weather. The concerns for safety and security translate into many 24-hour-a-day operations. 2. Security – The Proponent and F.B.I. get to dictate who has access to the site and area making public monitoring not only unlikely, but illegal in most cases. Bad weather (fog, temperature inversions, whales in the area, etc.) can delay blasting operations on short notice, necessitating storage of explosives on site; and this fact will cause even greater security to be needed. NAFTA is already being used to facilitate the use of an American mine manager. So, with homeland security laws and NAFTA rules applying, will Canada’s weak laws and regulations be set aside in favour of keeping the U.S. laws and regulations? In other words, in a dispute, whose laws are likely to be enforced? If U.S. laws are enforced, why are the hearings being held here and not in the U.S. where enforcement will emanate from. 3. Regulations, laws, guidelines, voluntary guidelines, all must be enforced to prevent and not react to violations. For example: Fox Harbour was blasted for months and the ledges removed before enforcement got involved (fines the cost of doing business). There is no system for reporting violations that ensures this report end up in the official record. How many environmental and blasting accidents in the last 10 years? The Government doesn’t even know how many quarries there are. 4. Who owns the adjacent properties and can these be used to expand operations or restrict observation and monitoring of the project? 5. There seem to be no reliable records of the quality, quantity, or availability of fresh water over a period of time. There is no benchmark for the condition of the salt water either. These things take years or decades to identify and record properly. 6. Having personally asked the NSDEL and NSDNR to analyze samples of material from test holes at the site, and being told the material was basalt and they did not care what else may be in the samples, I believe we should have a responsible, trusted expert examine what materials besides basalt may be in the area. What is the chemical formula for basalt? (Copper has been mined on the Islands, and what about radon gas?) 7. Alterations to any rules or regulations, or restrictions introduced in the future, are not likely to undergo anywhere near as rigorous assessment. Small changes can and will be made to any regulatory regime and eventually the project will dominate the area and the environment. Lobbyists are good at getting things in the back door. (For example: basalt used to have royalties imposed on it.) 8. Hazardous Materials and Dangerous Materials storage, disposal, monitoring, and isolating from the environment. The wash water will contain blast residue, acid, petroleum products, and other unknowns. 9. Since no one seems concerned about the fishing families who lived, died and are buried in Whites Cove, maybe someone could investigate the close connection of Whites Cove to Harvey Denton and the Pugwash Conference. Also to Julia L. Sauer’s famous children’s book, Fog Magic. I do not know in which specific part of the Guidelines these matters could be best dealt with, but I believe they should be addressed. |