Lastly, there does not appear to be a definitive statement anywhere in the submitted document that avoidance of the wetland and watercourse features in the northeast portion of the project, and their respective buffer zones, would absolutely render this proposal unfeasible. Since this was not clearly stated / identified at the outset, there should be little rational for permitting / preferring habitat destruction and compensation over simple avoidance.
Date Posted: January 15, 2019 1:45 PM
Imposing a 30 m buffer from WC1 and WL3 would reduce the operational width of the quarry in this area from approximately 435 m to 315 m, or a corresponding 30% reduction in surface area. The shape of the resource also thickens toward the northeast corner of the Project site. Imposing a 30 m wetland and watercourse buffer, in conjunction with sloping and benching requirements prescribed by WorkSafe NB, would prematurely pinch out the floor of the quarry above a significant portion of the resource. thus making the Project economically unfeasible.
Question: The proponent's operational plan, as illustrated in Fig. 2.3.1. indicates that WC I, approx. 100 meters of WC 3, and a portion of a wetland (WL 3) will be destroyed by quarry operations. During the initial public meeting, I discussed the necessity of this destruction with the EIA's signatory, Mr. Denis Marquis. My stated concern was regarding the necessity of destroying the above mentioned features, when avoidance would likely only reduce the operational area by approx. 4 ha. The response I received was that, even with the maintenance of a 60 meter buffer along these features, given the nature of the operation, they would ultimately be destroyed anyway. The proponent has not offered any specific geotechnical information in the EIA, such as detailed contours, soil profiles, core sample results, etc., which would technically support this "assumption of destruction", even if standard setbacks were adhered to. I see no direct statement or indication in the EIA document itself which delineates the area or zone of inevitable destruction of wetland / watercourse features. It should be noted that all field identified wetland drainage connections identified within the PDA flow towards the eastern boundary (WC3 / WL 3) as opposed to toward the intended pit. It should be further noted that in SEC. 18.104.22.168., the proponent states that "no regulated wetlands are located within the PDA, nor is it expected that they will be directly affected by the project". Given that the regulated wetland identified on the northeast boundary (Fig. 2.3.1.) is immediately adjacent to the proposed pit boundary (well within 60 m), this would absolutely contradict the proponent's logic that WL 1, WL 3, and WC 3 would be destroyed by quarry activities outside of the 60 m. buffer. One or the other of these assumptions must therefore be incorrect....
Date Posted: January 15, 2019 1:42 PM
Thank you for pointing out this potential for misunderstanding in the EIA Registration; the statements appearing in the document in this regard are factually correct. Below are the facts for clarification:
- There are no regulated (i.e., mapped) wetlands on the Project site—only 13 unregulated (unmapped) wetlands.
- There is a regulated (mapped) wetland on the neighbouring property to the northeast of the Project site.
- The 13 unmapped wetlands located on the Project site were field delineated and their functions evaluated in 2018 for the purpose of the EIA Registration since most of them (11 of 13) will be directly lost to make way for the Project components (i.e., they will be disturbed by earth moving and operational activities on the site, and their footprint will be covered by Project components such as the open pit, the storage pad, and other facilities).
- Wetlands WL8 and WL9 on the Project site will not be lost due to the Project since the Project components in those areas can be sited to avoid their disturbance.
- Wetland WL3, located on the northeast corner of the Project site, is hydraulically connected (via watercourse WC1) to the mapped wetland located on the neighbouring property to the northeast of the Project site, but WL3 is not a mapped wetland. WL3 will be directly lost due to development of the open pit over this wetland.
- The mapped wetland located on the neighbouring property to the northeast of the Project site will not be directly lost to Project facilities (i.e., its footprint will not be lost to Project components). However, it is highly likely that this mapped wetland will experience indirect loss of wetland function due to seepage of the water it contains into the open pit (i.e., an excavation below surrounding ground elevation that effectively acts as a groundwater “sink”). This assumption has not yet been substantiated and the only way to confirm or refute it is through monitoring and adaptive management during operation of the Project, but assuming that it will be lost is a conservative assumption that is relatively standard in Project EIA.
Hammond River Holdings will monitor, and attempt to mitigate, the indirect loss of wetland function to the mapped wetland on the neighbouring property to the northeast of the Project site to the extent possible through adaptive management. Mitigation measures may include the construction of a small berm in an attempt to preserve flow in watercourse WC1.
Finally, it should be noted that, for the purposes of the EIA Registration, only the 13 unmapped wetlands located on the Project site were field delineated in 2018. It was not possible to delineate the mapped wetland on the neighbouring property to the northeast of the Project site since it is located on a private property that is not owned by Hammond River Holdings, and to do so would have resulted in illegal trespassing on private land. Should the landowner of that property provide permission to access the property for this purpose in the future, Hammond River Holdings will delineate and evaluate the function of this wetland prior to construction so as to serve as a baseline for monitoring future indirect effects on this wetland.
The reasons for citizens to make sound decisions in regards to personal, business, and political motivations where ecological impacts exist have never been more defined, compelling, and available than they are right now in mainstream modern society. Corporations and Elected Governments are at a moment in time where even the most recent understandings, assertions, and policies need to be challenged as possibly out of date in the context of rapidly increasing depth of knowledge, social interest, and awareness of importance of intact ecosystems. As a citizen do you really feel that the development of the Gypsum mine within the bounds of a sensitive watershed where Alantic Salmon spawn is a good idea? At what point does your organization do the right thing environmentally? How are the importance of the ecological systems you effect categorized, weighted, and represented within the fundamental cost framework of your project development strategy?
Date Posted: January 15, 2019 1:41 PM
We are committed to responsible operations, including this new project. The EIA process provides a complete and rigorous review of impacts on air, land and water. In this effort we are engaging third party experts and welcome feedback. If there is research or data you believe would be helpful in this process, please forward it via this email address. With regard to Atlantic Salmon, JDI has been a longstanding supporter and voluntary investor in research, conservation and is one of a few in the country with a full time wildlife biologist and naturalist. The work of CAST (www.castforsalmon.com) is a most recent example of our efforts to help restore wild Atlantic salmon populations.
My family own's 40 plus acres on route 111, we have concerns about an early 1800's graveyard that is fairly close to the road . Can you assure us that no road widening will accure? We understand the Government owns a certain amount of set back on the sides of the roads, if they were to widen the road would they not claim additional set back ie. Landowners current property? Would hydro lines also need to be set back & at who's expense? So far this project seems to costly to our way of life and our wallets, rural peace & quiet traded for higher traffic volume & higher taxes. Not fair to locals who will gain nothing! Currently Irving trucks gypsum from Nova Scotia to St. John wallboard plant ,what happens to those truck drivers? Are those jobs lost? Or will some or all of those drivers be employed here on this project? Meaning no real jobs created?
Date Posted: January 15, 2019 1:40 PM
No widening of Route 111 or Route 820, or hydro line movement, is anticipated as part of this project.
Currently, the rock used at the wallboard plant is brought in by rail from Nova Scotia. It runs on rail routes that are heavily used by other industries and therefore, is not anticipated to reduce the jobs of anyone working on either the CN or NBSR rail lines. All estimates of increased jobs due to the project are new positions in New Brunswick, not the shifting of resources. Securing a domestic supply of gypsum for our plant also removes external risk to the supply chain and helps protect over 100 jobs in the region.
Route 111 just had substantial & costly work done this summer ($millions?), yet there is now talk of possible upgrades being required to allow for these bigger (B-Train double dump style ) trucks HRH wishes to use to transport their gypsum . The Minister of Natural Resouces says no royalties will be charged for such a common mineral as gypsum .With no compensation being sought,who will pay for the road upgrades & the upkeep over the next decade of wear & tear from truck traffic? Irving, HRH, or local NB. tax payers?
When you say somewhere between 30&40 truck per day traveling routes 111 & 865, carrying gypsum ,does that mean in total or 30-40 coming in empty & 30-40 going out full for a total of 70-80 trucks in a 12 hour period? Either way , I would like to know if this extra truck traffic has been considered from a tourism point of views? Billions $$$ have already been spent on Fundy Trail Parkway & more to complete it . Route 111 is the St. Martin's highway, how can blasting & high transport truck traffic & a gypsum guarry be considered part of a relaxing rural drive?
Tourism & the employment & monies generated from it, are much more important to this riding than a guarry that pays no royalties & instead cost taxpayer money we don't have to waste.
Date Posted: January 15, 2019 1:37 PM
At this time, it is unknown if the trucking route will need to be upgraded. An application has been made to the Department of Transportation to uprate the route from the proposed gypsum site to the wallboard plant in Saint John, NB. This is a common process throughout the province and requires engineers from the Department of Transportation to evaluate the route in its entirety to determine if heavy traffic can be permitted. The Department of Transportation will remain responsible for the maintenance of all public roads within the province.
When we say 30-40 trucks/day carrying gypsum, we mean return loads (from the wallboard plant to Upham and then back). This is based on 12 hours/day, 5 days per week.
Tourism is represented on the TRC and it is our understanding that its effects will be evaluated through that process.
The watercourse fish survey was done in August, in the midst of a drought and low water levels. Salmon, who prefer cold water, would have avoided entering the watercourses on the site at that time. Could the watercourse fish survey be done again during normal conditions- unless the survey was done in an unfavorable time on purpose to ensure no salmon would be present?
Date Posted: November 16, 2018 3:36 PM
The watercourse survey at the site was conducted on August 29-30, 2018, and while water levels were seasonally low (as is typical at this time of year), there is no scientific indication of “a drought”. The conditions of the scientific collection permit issued by Fisheries and Oceans Canada (DFO) for conducting aquatic surveys allow such surveys to be conducted at any time between June 1 and September 30 when water temperatures are below 22°C. The water temperature of the two watercourses that had flowing water within them at the time of the survey was 17°C for Watercourse 1 (WC1) and 18°C for Watercourse 3 (WC3) (Table 5.4.2 of the EIA Registration document), which is within the acceptable range for cold water species (13-18°C for salmon and below 20°C for brook trout). As such, the sampling was conducted during normal conditions representative of the allowable timeframe.
Please note, the survey was conducted by independent professional biologists with multiple years of experience in carrying out scientifically-defensible aquatic habitat surveys, the work was conducted under the supervision of an experienced project manager and the results will be heavily scrutinized by government scientists in their review of the EIA registration.
Blasting. Over the summer, residents heard and felt a series of blasts coming from the general area of the project site. This turned out to be a prank- a group of individuals were using tannerite to get a reaction from the community. These blasts could be heard and felt through the entire community of Upham, as well as Upperton, Titusville, and Barnsville. These blasts had ample tree-buffering, yet their effects were still greatly felt and heard through a large area. I would argue these blasts, (not done by professionals), would be at a much lesser extent than quarry blasting- how effective will your tree buffer actually be, if we've already experienced, heard, and felt, blasting, on a smaller scale, with a very large tree buffer?
Date Posted: November 16, 2018 3:36 PM
Hammond River Holdings is unaware of the conditions surrounding any blasting activity in the area over the summer of 2018, and as such we are unable to comment specifically on the impact of those blasts. Modern blasting techniques used by licensed explosives contractors (as will be used for this Project) do not typically result in off-site impacts. A direct comparison of impacts from unqualified individuals in uncontrolled conditions is challenging, if not impossible. As outlined in the EIA Registration, pre-blast surveys will be conducted prior to quarrying gypsum, residents will be notified of the blasting schedule, and blasts will be monitored with seismographs to ensure that noise and vibration levels do not exceed the safe limits established for those levels.
It is also important to remember that, in addition to the tree buffer that currently exists between the Project site and neighbouring residents, blasting activities will be carried out within the open pit, at depth, and the pit walls will provide some buffering of noise (as compared to activities on the ground surface at the same elevation as receptors).
If the results from the Spiranthes prove that it is indeed that plant, can the plant be successfully transplanted, or will it be anhiliated?
Date Posted: November 16, 2018 3:35 PM
Unfortunately, as indicated in the EIA document, due to the timing of the surveys we were unable to confirm the identification of the sample. Identification will occur this spring. There are six species of Ladies tresses (Spiranthes sp.) in New Brunswick; none of these are listed as species at risk provincially or federally. There would be no requirement to transplant samples, although avoidance will be explored if feasible.
What are the "suitable adaptive measures" that will be implemented when residents' property values decrease? Please elaborate.
Date Posted: November 16, 2018 3:35 PM
The suitable adaptive measures that would be appropriate are unique and are determined on a case-by-case basis considering the conditions observed at the time. It should be noted that Hammond River Holdings has taken the same approach on the real estate values portion of the EIA as similar projects across the province. Property values can be influenced by multiple market forces that may be at play at any given time, and it is difficult to attribute a specific cause to such changes. Also, as stated in the EIA Registration, the body of evidence relating to whether property values are generally positively or negatively affected by the presence of a nearby industrial operation is highly uncertain.
In the unlikely event that property values in the area experience significant change during the life of the Project, the root cause of those changes would be determined, and actions would then be defined if the Project is determined to be responsible for a change. In such a case, it is likely that a market study would need to be conducted by a qualified real estate professional to determine a cause-and-effect, and to define appropriate response mechanisms and adaptive measures to be considered. Residents would need to be consulted directly to determine their needs and desires, since individuals may have different wishes. For example, one may want assistance in selling their home whereas another may simply enjoy lower property taxes. Such issues are individual concerns that are best addressed on a case-by-case basis.
"The effects on the socio-economic environment during all phases of the Project are rated not significant, with a high level of confidence" (22.214.171.124 147)- a group of 1.1k people opposing this project is not significant? The community outcry against this Project IS significant- how are you able to say otherwise, especially with a high level of confidence?
Date Posted: November 16, 2018 3:34 PM
Neither Hammond River Holdings or its consultant, Dillon, mean to imply by this statement that some people in the area or elsewhere may not be concerned about the Project. “Significance” determination is made based on comparing the anticipated effects of the Project to the defined thresholds for the socioeconomic environment (Section 126.96.36.199). This is standard EIA practice, and is consistent with the following methodological steps of EIA practice (Section 4.2.4):
- define boundaries and significance threshold (i.e., threshold of acceptability),
- establish baseline conditions,
- identify effects that would occur without mitigation,
- identify mitigation to reduce effects,
- and compare the residual effect (i.e., effects that remain after mitigation has been applied) to the significance threshold to determine if the effect remains within the defined threshold of acceptability.
If a level of confidence is less than high, it does not mean that the effects are unacceptable, but rather that a follow-up measure needs to be defined to verify the effects prediction or the effectiveness of mitigation.
Individual perceptions of the presence of an industrial operation in a community are unique from one person to another and should be considered as such. The “significance determination” presented in the EIA Registration relates to meeting the requirements of the legislation and accepted EIA practice. We encourage those concerned to fully understand the issues and how they will be managed and/or mitigated and communicate concerns through the formal channels provided.