Reducing distance amounts to animal cruelty not only to seals and sea lions but all sea creatures in the water of Howe Sound.

I am writing to state that I DO NOT SUPPORT  the proposed changes to conditions 3.8 and 6.4, and call on Minister Guilbeault NOT to approve these changes, which I believe will increase the risk of this project to the pristine environment of the Howe Sound.

Our voluntary community group, Sunshine Coast Streamkeepers Society work very hard to monitor and rehabilitate salmon habitat where needed. This area is inhabited by many species of salmon and other species of fish. I feel their voice needs to be heard in the decision process to make sure they are protected. Salmon are already at risk with so many other challenges.

It seems the LNG Woodfibre don't want to pay the monetary cost of protecting the ocean life by requesting these monumental changes to the original agreement of how the work would be done safely for underwater creatures. 

Woodfibre LNG's rationale for amending the conditions by their statements is that they are not "technically or economically feasible." In other words, they don’t want to take the care and attention that is needed to make sure the environment in jeopardy because safeguarding conditions are not easy for a project to comply with. Basically money and bottom line trumps the quality of life of creatures with no voice. If this project is not able to comply with its conditions, then it should not be able to continue; we should not be relaxing those conditions. We cannot sacrifice species at risk so a fossil fuel project can make more money.

Woodfibre LNG is in the Átl’?a7tsem / Howe Sound UNESCO Biosphere Region, which is recognized internationally as "a cultural and ecological treasure."  This area is a gift to us who live beside it, we value this and do not take Howe Sound for granted. We must speak up to protect the beauty and the bio-diversity of our ocean.

Woodfibre LNG must be held to the highest standards and must employ the precautionary principle to minimize impacts to wildlife and ecosystems and be held responsible for their actions. 

Condition 3.8

My comment on this proposed change amounts to animal cruelty! To reduce the exclusion zone for sea lions and seals from 7,322 m to just 125 m would allow Woodfibre LNG to expose wildlife to noise as loud as a repeated shot-gun blasts for five to six months during construction.  This is totally unacceptable.

A very important fact is Steller Sea Lions have only recently returned to Átl’?a7tsem / Howe Sound, and are listed as a species of special concern under the Federal Species at Risk Act (SARA). The federal government has a responsibility to protect this species and their habitat. This responsibility also falls on LNG Woodfibre.

This extreme noise affects in a huge negative way to the water quality of the whole Átl’?a7tsem / Howe Sound. At this time in human history, we need to make sure the water quality a priority in all projects. Everything that lives underwater relies on sound to communicate, to find food, to escape predators, and to survive.

I am concerned that Woodfibre LNG appears to rely on outdated science to inform its rationale for changing condition 3.8. The most up-to-date science needs to be included in this decision.

Condition 6.4

Woodfibre LNG wants to amend condition 6.4 so that it is only responsible for water quality and sediment during operation and construction. This is problematic given the history of industrial pollution and corporate failure to clean up industrial projects in Howe Sound. Woodfibre LNG must be responsible during all phases of the project, including decommissioning.

Woodfibre LNG also wants to limit its responsibility for contaminants attributable to the project. This is also problematic due to the site's history as a pulp mill, and it is likely that construction activities will release and remobilize pollutants, despite remediation efforts. Woodfibre LNG chose the site for its project knowing it had historic contamination. The Impact Assessment Agency should not limit the company’s requirements to report and remedy any spills or sediment to that caused by the project itself.

Woodfibre LNG wants to limit mitigation measures to only those that reduce associated risk to human health. Environment and Climate Change Canada (ECCC) has warned that this change "could allow the proponent to use administrative controls to prevent human exposure to contamination instead of preventing contaminants from entering the environment. For example, the proponent could prohibit the consumption of contaminated fish instead of mitigating the source of contamination." Water quality is important for all aquatic life. Only requiring Woodfibre to take action to protect human health when pollutants exceed guidelines risks exposing aquatic life to contaminants.

Sincerely,

Shirley Samples, President

#WaterIsLife