Stop Woodfibre LNG from harming seals and sea lions!!!

• 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 adverse effects of the project.
• I am concerned that IAAC's Draft Analysis of proposed changes to the Woodfibre LNG Project Decision Statement Conditions indicates approval of these changes. This could set a dangerous precedent for any project that finds itself looking to cut costs at the expense of the environment.
• Woodfibre LNG's rationale for amending the condition statements is that they are not "technically or economically feasible." What is at stake is whether it’s acceptable to put the environment in jeopardy because safeguarding conditions are not easy for a project to comply with. But if a 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 has not provided evidence to support assertions that the proposed changes to conditions 3.8 and 6.4 will not result in increased adverse effects.
• Woodfibre LNG is located in the Átl’?a7tsem / Howe Sound UNESCO Biosphere Region, which is recognized internationally as "a cultural and ecological treasure."
• Woodfibre LNG must be held to the highest standards, and must employ the precautionary principle to minimize impacts to wildlife and ecosystems.
• I am concerned that ECCC flagged several errors and misrepresentations in IAAC's draft analysis, and it appears from their submission that the proposed changes to conditions could increase the adverse effects of the project. What other errors has the draft IAAC report included in its analysis and recommendations? This significantly undermines public trust in both the agency and the process.

Example comments for condition 3.8

• Changing 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.
• 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.
• Human-caused underwater noise is a critically important component of water quality, and one that we have a responsibility to manage. Everything that lives underwater relies on sound to communicate, to find food, to escape predators, and to survive.
• The science about underwater noise impacts is rapidly evolving. Woodfibre LNG appears to rely on outdated science to inform its rationale for changing condition 3.8.
• Preventing injury should not be used to define noise limits. Noise higher than 160 decibels could still cause serious stress or long-term damage.

Example comments for 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 decommisioning.
• 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.