Letter to CEAA
Canadian Environmental Assessment Agency
200 Sacré-Coeur Blvd
Hull, Qc, K1A OH3
Further to your public notice on the above I enclose my comments on the
above report. Also enclosed is a photocopy of a news paper article indicating
public response to the project.
I have not yet received a reply to my fax dated March 9th. Your answers
would undoubtedly have been pertinent to the issue.
As you are already aware, your announcements of March 4th in the Sherbrooke
Record and the Stanstead Journal indicated the deadline for public comments as
March 16th instead of March 18th. A telephone call to these newspapers informed
me that they had not had any instructions from the CEAA to rectify. I sincerely
hope that these will be the only errors in this file.
You will undoubtedly notice that my comments are similar in tone to the
general public response in that they show lack of confidence in TQM Pipeline
and in the government agencies. The reason can be easily explained. The BAPE
respected the laws governing it and produced a report worthy of it's reputation
of impartiality. The BAPE report accurately shows what was revealed during
their hearings. It should be noted that there was little proof of an alternate
route through Highwater, and TQM constantly denied it's existence. The CPTAQ
and the National Energy Board on the other hand issued reports failed to
mention TQM's inability to reply to input from the public. We had expected
these government agencies to protect the public, but their reports are
misleading and seem to have been written under pressure from higher up to
approve the project at all costs, political or otherwise, hence the feeling
that our input was wasted.
This is my first involvement with this type of project, and I may be missing
some of the finer subtleties in the proceedings which should give me hope.
Nevertheless, I have written my comments under the impression that the
Canadian Environmental Assessment Agency is no different than the National
Energy Board, and that it has already written it's report.
(signed) Norman Benoit
Comprensive Study Report
Tqm Pipeline Lachanie to East Hereford
This report prepared by the National Energy Board
accurately reports the information submitted by Gazoduc TQM in it's application
for a permit. That information, however, is full of misinformation as a result
of errors, inaccuracies, and omissions.
- Chapter 2
- Page 5 - Fails to mention that the lease with Montreal Pipeline has been extended and that there are no penalties for not meeting the deadline of November 1st. As presented by NEB in it's report, we are lead to believe that there could be urgency to approve the project to meet the deadline.
- Page 6 2.4 For your information, the CPTAQ decision is under appeal because of administrative vices and conflict of interest. NEB fails to mention the results of the BAPE report which is critical towards TQM Pipeline. The Bureau des Audiences Publique Sur l'Environnement is renown for it's impartiality. If the CAEE does not consider BAPE findings, this whole exercise was just a waste of time and money.
- Page 8 2.6 - NEB now confirms the necessity to meet the November 1st start up date.
- Page 9 2.7.1 The 1980 Quebec Interdepartmental Committee principles were unavailable during NEB Hearings. We asked many times that they be deposited but the civil servants were unable to find this document. They now seem to have been found. Would the directive to minimize corridor length prove too embarrassing to the project if had been made public at the hearings?
- Page 12 2.7.2 The pumping station in East Hereford was originally to be located in a marsh to be drained out. How TQM could have asked for this and the Quebec Ministry of Environment approve it is beyond me. This error was easily identifiable by the public and was corrected under public pressure. How many more similar crimes against the environment and not identified by the public could there be in this project? I thought that NEB was supposed to protect us. Is the CEAA a rubber stamp or does it have a mission to protect the environment?
- Sectioning Valves should be placed in greater frequency in rural areas than in urban areas. Emergency protection is much less adequate in rural areas. Furthermore, wooded areas present greater risk for uncontrollable forest fires.
- Page 16 2.9 During the NEB Hearings, the commissioners seemed very interested in the Highwater entry into the United States. This route had only advantages for the promoter, the utilisers of the pipeline, the environment and the public. It was amply demonstrated that the change in route was solely at the request of PNGTS, the American counterpart Unfortunately NEB has done a turn around and is not considering any alternative. If you read the final arguments of all the intervenors, you to will be puzzled by NEB's turn around.
- Chapter 3
- Throughout the public information process it was demonstrated that TQM continually withheld information which was unfavorable to them, presented incomplete information and did word games to improve their image. Although they were continually embarrassed at every hearing when presented with proof of their shortcomings, they have not done anything to improve their conduct. It was amply shown that TQM was giving misleading information and insinuations at the early notification meeting they held in Orford for the alternative route during NEB hearings. While I'm writing this report, TQM representatives are visiting property owners and telling them that they have one week to accept their offer, otherwise their case will be sent to arbitration or expropriation and that the property owner will lose.
- I had deposited a complaint with NEB, copy of which is attached, about TQM not following NEB directives for early notification meetings. NEB has done nothing about this. Where is our protection? I feel sorry for the commissioners who were probably forced to sign a report which concludes that the consultation process was effective? Unless something is done to prove me wrong, I can only conclude that the Maritimes Pipeline Property Owners Association did the right thing by boycotting GH 2-97 hearings.
- During the public consultation process ( read promotional process), TQM representatives met with the UPA, municipalities, MRC's etc. to explain the project. The representatives were Sophie Brochu, vice-president Gazouc Gas Metropolitain, Urgel Delisle and Jean Claude Veilleux of Urgel Delisles & Associes (preparers of the impact study) Stephane Bertrand of Forum Communications. G Barbeau (project manager of Janin-PNGTS, the general contractor), Andre Poisson ( Poisson, Bazinets et Associes, evaluators and negotiators for the project) Sadly missing was anyone for TQM Pipeline who could speak with responsibility in the name of the promoter. In all fairness, Michel Turgeon, President of TQM Pipeline and his Vice-President, Robert Heider, did make a few cameo appearances. You now have a supposedly well informed public reassured by representatives who could say anything with impunity and will no longer be there when the project is finished. So much for public consultation.
- Chapter 4
- Because we were refused sufficient time, all I can say, is that if you read the legal transcripts of NEB hearings, you will note there TQM's answers were very generalized and did not hold up to scrutiny. For example, did you know that according the impact study, there are only two deer yards between Lachanie and East Hereford. From personal knowledge, there are that many on the alternate route (where no studies have been made) in the Municipality of Ste Catherine de Hatley alone.
- In wooded areas, TQM will not, according to their explanations, be replacing the top soil. CPTAQ does not seem concerned about this illegal activity. Is the CEAA concerned about the higher rate of erosion where there is no topsoil?
- Page 63 and 65 Which is it going to be, several days construction at the most in any locality or careful archaeological surveillance? My bet is on the first one.
- Page 1 refers to the socio-economic impacts of the project, but the information is given in the report is vague. The response by NEB to the points raised by the Memphremagog MRC is to me an indication of NEB partiality towards TQM Pipeline.
Sustainable development is what we have now. A corridor going through our
country side where houses will not be built and trees not allowed to grow is
not sustainable development. Emergency measures are not sustainable
development, and neither are mitigations which don't always work. The risks
which will be imposed on the environment and the public are not sustainable
It seems that someone (probably the contractors and sub-contractors for the
project) is determined that the best route is the longest and most expensive
one. If this is to be forced down the population's throat, then the most
obvious has been missed. The pipeline should be installed in the center of the
autoroutes, where all the environmental damage has already been done. This
would add the least possible stress to the environment.