Botwood ASARCO Wharf Rehabilitation Response

This submission is such an obvious attempt at project splitting, it is unbelievable that it would be attempted by the proponent.  The ASARCO (American Smelting and Refining Company) wharf upgrading is clearly a side project directly related to the EVREC (Exploits Valley Renewable Energy Corporation) Windfarm development in Botwood.  The refurbished ASARCO Wharf will undoubtably be utilized for the berthing of large, 35 to 50 DWT (Deadweight Tonnage), ammonia carrier ships.  A massive health and safety concern for the residents of Botwood.  There is no demand in the Exploits Valley for the docking of any other type vessel in the future.  This is a campaign by the proponent to obscure the totality of what they want to do with both the WindFarm, Ammonia Plant, Irving Jetty and ASARCO Wharf.

 
A thorough review of the wharf proposal and the reasoning indicated in the document for not including the Irving Jetty in the environmental assessment, clearly demonstrates the proponents and EVREC’s actual need for the Wharf refurbishment.  Proponent is attempting to separate the Irving Jetty from the berthing wharf by constructive use of the physical activities regulations and by applying for environmental assessment under two different entities, EVPC (Exploits Valley Port Corporation) and EVREC.  Both of which share a common link with respect to their agendas; the chairperson of EVPC is also a key shareholder with the main investor within EVREC.  A clear conflict of interest and link between the two projects.

My review has concluded that the ASARCO Wharf project is required by EVPC, through their joint venture, as EVREC does not desire that the Irving Jetty be subject to Federal environmental assessment.  The Irving Jetty, a fuel loading jetty situated in the middle of a residential area of Botwood, had historically been used to load small (5000 DWT) coastal fuel carriers.  EVREC, is requesting approval provincially to use this old infrastructure to load liquid ammonia onto much larger, up to 50000 DWT carrier ships.  The change in size of vessel and type (liquid ammonia vs fuel) docking at the Jetty should have triggered Federal assessment, however EVREC has indicated that if the Jetty is only used for loading and not berthing of the ships then no federal assessment is required.  This is where ASARCO Wharf comes in to the plan; if they only load at Irving Jetty and then berth at ASARCO Wharf, only the wharf requires assessment and similar can be avoided at the much more contentious Jetty site.  The chairperson of EVPC actually took part in a CBC news story claiming the wharf project is for the support of future cruise ships to Botwood Harbour, clearly a disinformation campaign to gain local support and distract from the real intent.

 
The fact that the entities are intertwined, both through their management and processes, I implore the minister to intervene and require both EVPC and EVREC to submit to a regional environmental assessment of these dealings.  All of the following projects are intrinsically linked as a functionally interdependent industrial process, neither is viable on their own and should be evaluated together; EVREC Windfarm/Ammonia Plant, Irving Jetty and ASARCO Wharf.  If this plan goes through without a regional review, local concerns will not become apparent until after construction begins.  EVREC attempted a similar piecemeal approach with their provincial environmental assessment by attempting to exclude the Irving Jetty from the Ammonia Plant/Windfarm assessments.  ASARCO Wharf and the Irving Jetty situation is no different.  Divide and conquer.

Looking at this from a regional perspective; the EVPC and EVREC plans will substantially change the socio-economic, health and safety, traditional use, recreational and flora/fauna of the area all without residents having heard of the total plan and the direct impacts they will experience if it proceeds.  I can’t imagine that neither the Federal or Provincial governments would not look extremely closely at the possible risks of shipping and storing hundreds of thousands of cubic meters of liquid ammonia in such close proximity to communities of over 2700 people.  According to documents from proponents; there may be at any given time 200,000 cubic meters of liquid ammonia surrounding Botwood (150,000 EVREC, 50,000 EVPC) which would amount to 170,000,000 cubic meters of toxic/explosive gas if released.  In my and a substantial number of other informed residents opinion, there is no way to make this process completely safe.  Performing some desktop exercises, without all factors included due to my lack of knowledge in this field, shows that just the explosive power of a 50,000 DWT ship filled with ammonia could create an explosion with a danger radius of close to half a kilometer.  This is one of the key aspects that neither EVPC or EVREC are describing in the statements due to the partitioning of the project.

None of the public consultation sessions or information from the Town of Botwood, to date, have explained to the local public exactly what this project in its entirety is about.  All of it engineered to deliberately divide resident opinion and negate individual concerns.  Even the timing of the submission of the federal ASARCO Wharf project and that of the Provincial EVREC environmental assessment both coincide such that residents would be distracted by one or the other and not have time to respond to both.  A very tactical move by the proponent, along with the misleading cruise ship spin.  

Outside of the ammonia health and safety aspect of this comment; want to outline other environmental concerns regarding the refurbishment of the ASARCO Wharf project:

 
- No statement from the proponent on the types of ships that will be docking there; along with the ammonia carrier possibility, will there be other toxic/dangerous cargos arriving there?  In very close proximity to homes and businesses.  
- Will the ships be of foreign origin and if so, what controls will be in place to ensure these ships meet Canadian safety standards for maintenance, operation and construction.
- Lack of public consultation and transparency of information provided lacking.
- Resistance of local council to holding a plebiscite on the port development and/or EVREC project.
- How will the noise of construction be mitigated for homes and business in very close proximity, ie pile driving.
- The remnants of the old A&D railbed, adjacent to wharf site, has become a piece of recreational infrastructure since it was abandoned around 2010.  A shared use trail since then for ATV/Snowmobile/Walking use.  This public infrastructure should be preserved for the good of existing residents of Botwood.  In fact, portions of the trail were upgraded by the Town of Botwood through the provincial Active NL Fund. 
- Proponent is missing necessary emergency response plans related to berthing of ships carrying toxic/dangerous cargos.  Would local volunteer fire depts be responsible for any industrial response or would an EVREC ERT team be required for this purpose?  Another possible link.
- Despite what proponent has indicated; existing infrastructure such as town roads and water mains are not in good condition and will be further deteriorated by additional industrial use.  Ship berthing requires water, electricity and road network access.  Is there a plan to provide upgrades to these items as a part of the project?  Water in Botwood is well know for being full of particulates and rust due to deteriorating piping.  Existing use of the water main to supply Coast Guard ships already causes water quality issues for local residents during high demand, expansion will exacerbate this issue.  The Town of Botwood has already had water conservation orders in past; ie Aug 2018 and July 2025. If the current water supply cannot handle existing demands, how can the system supply additional water to large vessels.  Additional domestic water sources will be required. However, EVREC has targeted Peters River as its supply of hydrogen production fuel which is the Town of Botwood previous domestic water source.  
- Will there be regulations regarding types of fuels that ships are permitted to use within Botwood Harbour to reduce impacts of air pollution?  Operationally, are there limits of how long ships can run engines or auxiliary power?  Botwood has already permitted an asphalt plant to be constructed in the same area as the wharf project; which during operations releases fumes into the air and are clearly detectible to local residents.  To this day we do not know what is in these gases as no information was provided by the Town or operator.
- Proponents IAAC summary document omits mention of the Irving Jetty entirely and is the document most reviewers will read.  Residents should have all information available so can make informed comments.
- Data the proponent has provided regarding sea floor sediments clearly demonstrates there is significant contamination with toxic substances present.  It is doubtful that this could be disturbed without releasing this contamination into the water column without constructing a cofferdam to excavate the soil and wharf remnants (creosote) before construction or pile driving.  The initial tests were very limited, few samples, and should be required to expand significantly on the testing of these soils to confirm the extent and severity of contamination.
- Local residents regularly fish trout and other fish species all long the Botwood waterfront, particularly near the ASARCO Wharf site, paper shed and Irving Jetty.  This activity will be impacted by both the loss of these locations through construction and perhaps by water contamination by disturbance of the soils/creosote mentioned above.  How will this project mitigate these issues?
- The proponent has described conflicting information regarding dredging; they indicate that none is required however elude to limited dredging in other sections of their documents.  Actual dredging should not be permitted due to the reasons outline in points above regarding sea floor and creosote water contamination.  Proponent should be required to outline the exact construction, operation and maintenance plans for the wharf.  Transparency with locals.
- Botwood Harbour is the confluence of (5) scheduled salmon rivers; Exploits, Northern Arm Brook, Peters River, Charles Brook and Rattling Brook.  Contamination of the water column in the harbour will affect the health of these salmon populations and that of those whom consume them.  Do not believe that this aspect has been brought to the attention of local residents, sport fishers and indigenous peoples in the area who use this resource.  At minimum, a detailed study of possible effects is required.  
- The harbour in general is a stopover for numerous migratory birds, particularly Peters Arm and Northern Arm estuaries.  In spring, summer and fall these areas are abundant with various ducks, geese, raptors, etc.  Will there be any effects on these migrations or populations due to construction or operation of this port, EVREC plant or the Windfarm?  Migratory birds are the responsibility of the Federal government and thorough evaluation should be required.
- Historical lack of local environmental regulation of industry by municipal governments has occurred in Botwood.  Massive Ultramar diesel oil spill, Abitibi machine shop soil contamination, ASARCO Wharf site, etc.  Providing permits to EVREC without any conditions or restrictions to protect local residents interests.  It is apparent that this region requires close oversight of any local environmental decisions by higher governments to ensure proper engagement, transparency and adherence to standards.
- Soil contamination on land adjacent to the ASARCO Wharf site, this was the previous location of the “Ore Shed” and loading dock.  This entire area may be contaminated by toxic substances, on or below the surface.  Disturbing this soil may lead to toxic dust being spread in the environment toward homes and the Botwood downtown core.  This site requires significant testing and remediation to be a suitable location for development, similar to the underwater site.  What is proponent doing to mitigate this concern?
- Increased strain on existing medical facilities, which are already overloaded.
- Loss of tourism due to the destruction of the current water front appearance, walking/ATV trail loss, wind turbine visibility, ammonia carrier visibility and industrialization of the community in general.

In summary, there is a lack of transparency with respect to all the developments proposed for the Bay of Exploits area.  A federal regional review is required so that the true scope and impacts are explained to residents who live, work and pay taxes in the area.  Bait and switch, divide and conquer, project splitting tactics cannot be tolerated by Governments in good conscience.  Respectfully request the Federal Minister intervene to deny this assessment in its current form and that of the EVREC project; so that the health, safety and enjoyment of the people of the area is protected.  Thanks.