"Other methods are available for removal of suspended sediments in the water are technically feasible (filtration, centrifuging, decantation, or other methods)" (2.8.4 36-37)- yet they are not being implemented. I argue that given J.D. Irving Ltd's current court case of discharging effluent into the Saint John River, and being put on the Environmental Offender's Registry, that ALL methods should be applied to ensure minimum sediment discharge. How expensive are these alternate methods? Why are they not being pursued as contingency or supplemental to the gravity-based sedimentation process? I argue that water quality trumps any price tag.

Potential effects at other types of industrial facilities in the province of New Brunswick or elsewhere are not relevant to the Project under consideration.  However, this link does provide more information regarding the Saint John pulp mill.  https://jdirving.com/BlogPage.aspx?id=5302&blogid=74

Discharge water at the proposed quarry will be subject to strict discharge standards that will be defined in the facility’s Approval to Operate, regardless of method by which those standards are achieved.  In this regard, Hammond River Holdings has suggested a total suspended sediment concentration, but the Province will determine what it considers appropriate for complying with environmental legislation. 

Gravity sedimentation (i.e., settling) is a well-established and effective method of removing suspended sediments from water, provided that the sediments can settle for a suitable period of time.  Typically, 24 hours within a settling pond or sump is more than sufficient to settle suspended sediments from water.  In addition, gypsum and related compounds are often used as flocculants in industrial wastewater treatment processes to assist suspended sediments to precipitate out of water. The composition of the material for this Project inherently aids in the effective settling of solids.  It should be noted that gravity sedimentation is used extensively at quarries throughout the Province and has been proven effective at controlling sedimentation from surface runoff in a variety of locations. 

Hammond River Holdings is confident that gravity sedimentation will be successful at meeting discharge requirements. Additionally, there is operational flexibility within the project that would allow the water to settle for a longer period, if required, to meet the discharge requirements as laid out by the Department of Environment. Other methods for solids removal remain technically feasible and will be explored as a contingency in the unlikely event that gravity sedimentation does not meet discharge standards.