World Wildlife Fund Canada
Atlantic Regional Office
Suite 1202, Duke Tower, 5251 Duke St. Halifax, NS B3J 1P3
Steve Chapman
Canadian Environmental Assessment Agency
200 Sacré-Coeur Boulevard, 13th Floor
Gatineau QC K1A 0H3
Environmental Assessment Administrator
Nova Scotia Environment and Labour
5151 Terminal Road, 5th Floor
P.O. Box 697
Halifax NS B3J 2T8
21 January 2005
Re: Draft Guidelines for the Preparation of the Environmental Impact Statement for the Whites Point Quarry and Marine Terminal Project.
WWF Canada is concerned about the scale of the work proposed for the quarry at Whites Point on Digby Neck, Nova Scotia, its potential impact on adjacent ecosystems, and the cumulative contribution it may make to the full range of impacts from human activity in the area. Consideration of this project or any similar large-scale industrial development should not be undertaken in isolation from the potential impacts of additional development over time.
We are encouraged to note that the draft guidelines require the proponent to elaborate on “alternatives to the Project” which must include the option of not conducting project, if they cannot demonstrate that the proposed activity will not harm the Bay of Fundy ecosystem.
The Bay of Fundy is a unique and sensitive ecosystem, and major industrial activity there should not proceed prior to an effective assessment of special or sensitive ecological areas. Large-scale development, like that proposed for Whites Point, has the potential to destroy or degrade sensitive marine areas before we fully know what merits protection.
Every time a development project is proposed in a natural region that is not yet adequately represented by protected areas, we erode the options to establish natural and cultural safeguards. WWF believes that there should be no new or expanded large-scale industrial development in Canada until a network of protected areas is reserved which adequately represents the natural region(s) affected by that development. The Provincial and Federal governments should take the lead, working with regional partners, to develop comprehensive coastal management plans that incorporate biodiversity and habitat conservation with reasonable, sustainable resource development.
In addition, as a member of the North Atlantic Right whale Recovery implementation Team, we strongly support and reiterate the comments and recommendations made in a letter from the North Atlantic Right Whale Recovery Implementation Team about the draft EIS guidelines for this project.
WWF recognizes that there are uncertainties about the potential impacts of industrial activities on many elements of the marine ecosystem adjacent to the proposed quarry. For this reason, it is crucial that the proponents and decision-makers take a precautionary approach when considering the potential impacts, short- and long-term, of proposed large-scale industrial activity in the Bay of Fundy. WWF Canada urges the Joint Review Panel to carefully consider the full range and cumulative nature of the effects of this proposed development on the marine environment adjacent to Digby Neck.
WWF will not support the advancement of the quarry project on Digby Neck if these requirements of the EIS are not thoroughly and adequately met.