RE: Glenburnie Drydock (Reg. 1962) - Proponent: 3 T s Limited

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1 43 Tableland Drive Glenburnie, NL A0K 1K0 June 6, 2018 Environmental Assessment Division Department of Municipal Affairs and Environment West Block, Confederation Building P.O. Box 8700 St. John's, NL A1B 4J6 RE: Glenburnie Drydock (Reg. 1962) - Proponent: 3 T s Limited Environmental Assessment Division: It is with great concern that I write the Environmental Assessment Division of the Department of Municipal Affairs and Environment concerning the proposal being brought forward by 3 T s Limited to construct a 2090 M 2 (22,496 square feet) drydock on the beautiful community beach in Glenburnie, Bonne Bay, NL. I take great exception this proposal for many reasons which are noted below. It would seem that the proponent, 3 T s Limited, may have missed the most obvious reason for this proposal to be rejected, that the proposed drydock and beach which would be destroyed by the development, sits in the middle of Gros Morne National Park, a park renowned for its pristine scenery and its strength in protecting the environment for generations into the future. I therefore request that the project be disqualified for environmental assessment due to the incongruent nature of the development with the community and natural area (National Park) values. Below are the concerns and comments I have related to the proposal and proponents of the development: 1. The rationale provided by the proponent for this development is for: Servicing company fishing vessel more quickly and cost effectively as nearest drydock is Nova Scotia for a vessel of its size and The drydock is expected to be operated 2 times over a 5 year period - during spring to fall. This drydock, as proposed, is being developed to service a single vessel twice over a 5 year period. This would obviously benefit the proponent by avoiding the inconvenience and cost of the trip to Nova Scotia twice every 5 years. Although the cost/benefit ratio and business case of the proposed development to the proponent would normally be of little concern to myself, it is hard to ignore the cost of the project, it s long-term impact on a local recreation and environmentally significant space (the beach) within the confines of a National Park, and the rather limited value 1

2 it provides to the proponent given its cost. It seems obvious to the casual observer that if the drydock is approved and built, it will quickly be used as a commercial drydock facility servicing the fishing industry along the whole west coast of Newfoundland. I suggest that this may be the ultimate goal of the proponent. If this project development transpires, Glenburnie beach will become, over time, a marine junkyard and oil spill site. It will also be an eyesore, incongruent with the values upheld by Gros Morne National Park. 2. Although the proponent owns the property above the high water mark, the beach and the ocean bottom extending 250 ft into Bonne Bay is not owned by the proponent. Rather, it is owned by the people of this province and the community members of Glenburnie-Birchy Head-Shoal Brook who use it for recreation and sight-seeing. This fact alone should make the facility ineligible to receive environmental approval. The local residents of Glenburnie, especially those situated along the beach front will be subjected to the visual eyesore, and their property will devalue significantly. 3. The proposal does not estimate the amount (M 3 ) of beach material that would be removed from the site. The location of the material disposal site in essentially in the middle of the community of Glenburnie, which is already a virtual dumpsite for waste material belonging to the proponent. There is also no indication of the depth to which the beach material will be excavated. 4. The proposal indicates that an environmental spill kit will be located onsite. This seems to be a very modest environmental protection expectation for a 22,000 sq. ft. industrial development on the shoreline of a sensitive Park area. 5. The proposal does not provide any estimates of the sea-life (clams, crabs, mussels, snails, copapods etc.) that would be affected by the development, nor does it provide any evidence of the potential effects to the tidal zone birds (shorebirds and raptors) that use the beach area for food forage, mating and nesting. 6. The proposal indicates that no additional jobs will be created by this development. Although not a necessary aspect of environmental assessment, it is again mindnumbing to see this proposal being brought forward with such potential negative community and environmental impact, with no community benefits derived whatsoever. 7. Based on community evidence and opinion, the proponent does not have a history of maintaining its work sites in a tidy fashion. It is common knowledge that often when the proponent develops a work site, it becomes a site for refuse, inoperable heavy equipment and, sometimes poorly maintained buildings. There is no reason to believe that the drydock site, if developed, will be kept in any better condition. 8. Proposed cost estimate appears to be a low-ball estimate. 2

3 9. No artist rendering of the site is provided. Community members have no idea what the proposed drydock will look like and the visual impact it may have. The Environmental Protection Act notes that environmental assessment is to "protect the environment and quality of life of the people of the province; and facilitate the wise management of the natural resources of the province". It requires anyone who plans a project that could have a significant effect on the natural, social or economic environment to present the project for examination. Given that this proposed development has been brought forward and registered with the Department of Municipal Affairs and Environment, I am compelled to response by requesting the proposal be ineligible for consideration and the proponent be requested to withdraw the proposal due to the environmental sensitivity of the site, it s close approximation to residential housing in a community (Glenburnie-Birchy Head-Shoal Brook), and its location inside a National Park. If this is not considered an option, I request standing to the Environmental Assessment process and hearings on the project. Sincerely, Gregory Wood Tel: (709) gregwood33@gmail.com cc: Mr. Geoff Hancock, Superintendent, Gros Morne National Park Hon. Dwight Ball, MHA (Humber Gros Morne) and Premier Hon. Gudie Hutchings, MP (Long Range Mountains) Town Council, Glenburnie-Birchy Head-Shoal Brook Enclosed Appendix 1: Project Proposal Registration Information Appendix 2: Information Regarding Environmental Assessment Appendix 3: Images of Proposed Development Site 3

4 Appendix 1: Project Proposal Registration Information Registration: Glenburnie Drydock (Reg. 1962) Proponent: 3 T s Limited The proponent proposes to construct a 2,090 square metre dry dock at Glenburnie in Bonne Bay, Western Newfoundland. The dry dock will extend 76.2 metres out from the highwater mark and will be 27.4 metres wide. The structure will consist of a 15.2 metre wide concrete slipway bordered by two piers each with a 0.3 metre wide inner wall and a 5.8 metre band of armour stone. The undertaking was registered on May 28, 2018; the deadline for public comments is July 2, 2018; and the minister s decision is due by July 12, The undertaking was registered on May 24, 2018; the deadline for public comments is July 2, 2018; and the minister s decision is due by July 8, Contact: Environmental Assessment Division - toll-free at or by mail: Department of Municipal Affairs and Environment West Block, Confederation Building P.O. Box 8700, St. John's, NL A1B 4J6 Public comments may be forwarded to: EAprojectcomments@gov.nl.ca Environmental assessment information: Follow us on Media contact: Lynn Robinson Municipal Affairs and Environment , lynnrobinson@gov.nl.ca 4

5 Appendix 2: Information Regarding Environmental Assessment The Environmental Protection Act states that the purpose of environmental assessment is to "protect the environment and quality of life of the people of the province; and facilitate the wise management of the natural resources of the province". It requires anyone who plans a project that could have a significant effect on the natural, social or economic environment to present the project for examination. The environmental assessment process ensures that projects proceed in an environmentally acceptable manner. When the potential environmental effects of projects are of concern, the process generates real benefits by: (i) providing for comprehensive project planning and design, (ii) maximizing environmental protection, (iii) enhancing government coordination, accountability and information exchange, and (iv) facilitating permitting and regulatory approval of projects. The Environmental Assessment Division of the Department of Municipal Affairs and Environment administers the process including: i. consulting at every stage with interested government departments and the public ii. evaluating submissions by proponents and reviewers iii. advising the Minister on potential environmental effects prior to decisions iv. monitoring released projects to ensure compliance and effectiveness of mitigation 5

6 Appendix 3: Images of Proposed Development Site 6

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