RESPONSE TO DRAFT GUIDELINES FOR AN ENVIRONMENTAL IMPACT ASSESSMENT FOR THE CONSTRUCTION AND OPERATION OF AN INDUSTRIAL LANDFILL AND RELATED FACILITIES AND INFRASTRUCTURE

1) In regard to the chemistry of the leachate prior to treatment, it is our position that this information must be available from the beginning. Possibly it will be discussed under section 3.1 "Project Description".

2) The community wishes to engage its own independent consultant to collect and analyze the waste stream from its point of origin. The cost of this independent consultant should be the responsibility of the proponent.

3) As part of section 4.6, Effects on Groundwater Resources, it is our expectation that base line data on existing well water be established. This baseline should include samples from communities surrounding the proposed landfill site as well as communities around Grand Lake. It is also the community's request that an accredited lab, acceptable to both the proponent and the community, perform collection and analysis.

4) Regarding compensation, section 2.5, specific mention should be made regarding compensation plans in the event of project-related decreased property values. Likewise, in regard to project-related contamination of groundwater wells.

5) Property owners are requesting a referenced position statement be made regarding how saleable their property will be if, after landfill construction, their well water should become contaminated. Will CMHC approve mortgages to purchase properties or homes dependent on bottled or tanked water due to contamination?

6) The proponent's Terms of Reference needs to clearly state who will pay legal and associated costs for those individuals trying to prove that ground water contamination is the direct result of proposed landfill.

7) Section 4.11 regarding "other social and economic effects" mentions the effect of the proposed project on existing "tourism and recreational activities" Prediction should also be made re: the effect of the proposed project on future tourism and recreational activities.

8) Coal Creek has suffered from previous industrial (mining) operations. However, local reports indicate Coal Creek is making a gradual environmental recovery. Therefore, predicted project-related environmental impact must not only be measured against Coal Creek as it is today, but also against Coal Creek as it is reasonable to predict it will be in the future if allowed to continue recovery without further industrial insult.

9) Section 2.7 concerns Consultation. The scope and timing of consultation is critical to the Grand Lake community.

a: Timing - The timing of consultation must be such that it include that time when the thousands of cottage owners are in the area and available to attend.

b: Scope - The consultation process must recognize that a number of communities surround Grand Lake and that all communities from Jemseg to Chipman be conveniently included at all levels of consultation.

10) Again, in reference to consultation. During the initial EIA which was conducted by AMEC, the Opponents Committee secured the opinion of various experts within the field of geology, hydrology, chemistry, physics, and so on. This was done at the personal expense of the Committee. It was the committee's need to understand and interpret the data, which prompted securing such consultation. During the Comprehensive EIA process it is the committee's expectation that financing such third party consultative expenses will be the responsibility of the proponent.

11) The committee wishes their position on the use of Crown Lands for Phase II and III of the project to be perfectly clear. We feel use of Crown Lands for a Chemical Industrial Waste Landfill unacceptable.

12) The Opponents Committee urges the NBDELG and the appropriate Technical Review Committee to scrutinize the work of Rowe, Sangam and Lake in their research entitled "Evaluation of an HDPE geomembrane". This research can be secured on the goggle search engine using "Evaluation of an HDPE geomembrane" Their findings are clear in regard to the failure rate of such liners. The search must include the quotation marks.

13) The community is concerned about the possible risks to human health either by water, air or transportation. What are the cumulative projected risks to human health? A recent survey by the River Valley Health Authority has the population of Chipman and Minto above the provincial norm in several forms of cancer. Will the installation of such a landfill not put this population at even greater risk?

14) Lined landfills that have been researched and found to leak, are prone to do so from specific sights, resulting in a narrow plume which may pass by monitoring wells undetected. Leak detection systems involving sensors installed at the time of construction have been developed for use along with monitoring wells. They can sometimes pinpoint the location of a leak as well as detect the presence of one. Will such a back-up leak detection system be required in regard to the proposed project?

15) The last line of section 2.6 speaks of "appropriate corrective actions". It should be made clear that no actions short of actually stopping a detected leak are "appropriate".

16) The first line of section 2.5 speaks of measures that are "technically and economically feasible for the proponent". The word "economically" needs to be clarified, as no project should be pursued if the proponent is not financially prepared to guarantee the future preservation of the environment through all available means. Lack of funds is not sufficient reason to pursue the project without plans for a back-up leak detection system.

17) How long is the proponent committed to monitoring and following-up regarding impact of the proposed project? Will funds be set aside to deal with problems detected perhaps one hundred years or more from now? Nothing that is being built today will last forever. That pile of chemical industrial waste will be there forever should this proposal move forward.

18) In the spirit of transparency, and it is evident that the NBDELG is committed to moving in this direction, the Opponents Committee requests they be included in receiving the Terms of Reference as they become available.

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