Stop Woodfibre LNG from harming seals and sea lions

Dear Minister Guilbeault,

I am writing to express my significant concern about the proposed changes to conditions for the Woodfibre LNG export facility. As the final decision maker, I urge you not to approve these proposed changes, which I believe will increase the adverse effects of the project.

Particularly I’d like you to consider that the decibel scale for sound levels in air doesn’t mean the same thing in an underwater context: animals underwater are vulnerable to damage from sound travelling through their bodies in a way that terrestrial species are not.

The use of single figure dB values for underwater acoustic measures is only ever telling part of the story, and it is possible to make errors in judgement which could have severe negative consequences for the wildlife in the sound.

In addition to this, recommended sound exposure levels are normally quoted for continuous noise levels, and are less well defined for short impulsive sounds such as pile driving.

This paper outlines some of the wrong assumptions people make when applying a naive conversion factor for underwater sound:
https://www.sciencedirect.com/science/article/abs/pii/S0003682X07000977?via%3Dihub

Because of the differences between underwater and overwater acoustic measures, and the many possibilities for misinterpretation and misrepresentation, I believe the most precautionary approach possible should be taken when deciding on a safe operating distance for the project.

I believe it is wrong to put sea lions and seals through the intense disturbance and stress the noise pollution would cause them at this reduced operating distance. There is also the matter of other fish and crustacean species who will be damaged by the planned work- but this letter is about the exclusion zone for marine mammals.

The proponent has requested that the monitoring area for underwater noise impacts to seals and sea lions be reduced from 7,322 metres to just 125 metres during construction.

However, Woodfibre LNG is located in the Átl’?a7tsem / Howe Sound UNESCO Biosphere Region, which is recognized internationally as "a cultural and ecological treasure." Steller sea lions are listed as a species of "Special Concern" under the Species at Risk Act, and have only recently returned to Átl’?a7tsem / Howe Sound.

Woodfibre LNG must be held to the highest standards, and must employ the precautionary principle to minimize impacts to wildlife and ecosystems.

Please reject these proposed changes.

Sincerely,

Sincerely,
Michael Gallimore

<personal information removed>
Squamish BC
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