I'm not so sure anybody has a full take on this deal. The numbers are funky and most likely Ms Zahn was inaccurate, however I believe I read where we are talking 1.3 million cubic meters of salt to be "gradually" dumped into the environment. That means either a very long process OR a great deal of dilution.
DFO's, " SCIENTIFIC REVIEW OF THE ENVIRONMENTAL REGISTRATION DOCUMENT FOR THE PROPOSED ALTON NATURAL GAS STORAGE PROJECT " (http://publications....007-013-eng.pdf )
addresses this very issue under "Exposure"
It is doubtful that any information concerning the effects of exposure to brine (at varying
concentrations) is available for any or most of the diadromous species present within the
Shubenacadie River Estuary. However, the infrastructure and expertise to assess the effects of
exposure to brine on juvenile diadromous fish is available at a local university. The need to look
at exposure effects would be contingent upon the relative difference between the chemical
composition of the brine and seawater occurring naturally in the river. If the proponent cannot
produce information that shows the chemical properties of the brine at the point of discharge:
a) does not differ from that of seawater, and
b ) would not harm fish at the proposed dilution, upon release into the river,
then it is recommended that studies be scheduled to assess both the lethal and sub-lethal
effects of exposure, minimally on juvenile striped bass.
The "Conclusion" to this 2007 document is interesting as well.
The Shubenacadie River Estuary at the proposed location of water withdrawal and discharge for
the Alton Salt Dome project is a dynamic receiving environment possessing a high level of
natural variability, which has not been fully characterized within the Environmental Registration
document. Existing uncertainties associated with natural variability in the underlying physical
and climatological dynamics of, and their interaction within, the receiving environment
complicate the task of prediction of potential environmental effects on aquatic ecosystem
components. Both the design and implementation of measures to mitigate the impacts to
aquatic ecosystem components, such as the timing of brine discharge, may be therefore equally
Given the presence of a species listed as endangered species under the Species at Risk Act
(inner Bay of Fundy salmon) and other regionally rare and sensitive species (striped bass and
Atlantic sturgeon), it is expected that a lower than average level of risk tolerance may be applied
to projects proposed for this environment. At present, the Environmental Registration document
contains insufficient information to enable full evaluation and risk assessment of the potential
impacts to aquatic ecosystem components, including species at risk.
Given that advice has not been provided by DFO Maritimes Science on this type of project in
the past, and given that this is only a preliminary evaluation of the information contained within
the Environmental Registration, it is recommended that a DFO-led scientific peer review
meeting be conducted to more fully evaluate the scientific and technical information available for
this project, to discuss additional mitigation and monitoring options, to determine what
information may be required (if any) to address outstanding knowledge gaps.
Have looked but haven't been able to find if those "knowledge gaps" have been filled.
I am also curious if there might be a loophole in the law that is somehow being utilized here?
Let's see if I can make some sense of my thinking.
Under the Fisheries Act, Section 35: " No person shall carry on any work, undertaking or activity that results in serious harm to fish that are part of a commercial, recreational or Aboriginal fishery, or to fish that support such a fishery".
“Serious Harm” is defined as the death of fish or any permanent alteration to, or destruction of, fish habitat (e.g., infilling, dredging, blasting, etc.) but does not cover impacts related to changes in water chemistry.
Salt and salinity would be considered a "change in water chemistry" and therefore could be considered a "deleterious substance".
Impacts related to the deposit of a deleterious substance is addressed in Section 36(3) of the Fisheries Act which states, “no person shall deposit or permit the deposit of a deleterious substance of any type in water frequented by fish or in any place under any conditions where the deleterious substance or any other deleterious substance that results from the deposit of the deleterious substance may enter any such water.”
This Section of the Act is administered by Environment Canada. And weren't Environmental Assessments neutered by one of the Omnibus Bills? (See: Bill C-38: the Environmental Destruction Act http://thetyee.ca/Op...05/10/Bill-C38/ ) Yet even under the new regulations, this project would seem to raise some flags.
So who is being tasked to address this issue? DFO? Environment Canada? Both?
Let's see the science. As you stated, "I would like to see numbers and figures put forward by scientists which are based in fact, and which can be peer reviewed."
I continue to search for answers to questions that should easily be found in Public Record, yet seem to be more elusive than one would hope. Projects, such as this, should have ALL materials compiled under one file name (such as Alton Brine Project: Shubinacadie River) and be available on a Government Database for the public's access.
However, that may lead to more "problems" for those making the decisions.
To put it simply Ian, there is a **** pile of salt about to be dumped into a river and the Government doesn't seem to have a handle on the details. Even a politician, who should have access to the info, seems to be "confused".
My hope is that, when all is said and done, we don't look back on this and wish more questions were properly answered before going ahead with the project.
Here's hoping for "no regrets".
Take care, my friend,