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Kimberly D. Bose,Secretary
Re: docket CP07-52 , this comment is sent in support of the request to motion for an expanded public comment period on behalf of Nulankeyetomonen Nkihtahkomikumon, Save Passamaquoddy Bay – Canada, and SPB – USA.
I contend that the Downeast LNG EIS is incomplete and lacks critical information. The extension will allow time to compile and submit new data and analyses, without which FERC does not have the foundational information needed to make a rational decision and judgement.
My name is Arthur MacKay. I am a biologist and have worked professionally in the Gulf of Maine area since 1961. I have been the principal investigator for numerous studies, including a detail resource inventory for the entire coast of the NB side of the Bay of Fundy and the adjacent Maine shore, the area currently in question. My resume is extensive and can be reviewed online. I am not a member of Save Passamaquoddy Bay – Canada, nor a member of their Board of Directors and all submissions made by me are as a private citizen.
I have been involved in preparing and contributing to many environmental assessments including the Point Lepreau Nuclear Power Plant, the Coleson Cove Generating Station, the proposed Pittston Refinery at Moose Island, the Q&M Pipeline proposed Sable gas pipeline route, and many aquaculture applications in Maine and New Brunswick. My clients have included provincial and state governments, federal governments in Canada and the United States, and individuals and private organizations in these countries as well as abroad. The scope of my work has included alternate energy, aquaculture, fisheries development, community development, and marine assessments including invertebrates, fishes, birds, marine mammals and plants. Currently, I am retired but actively involved in several research projects. I also maintain several websites including www.bayoffundy.ca, ilovequoddywild.blogspot.com, and fundywhale.blogspot.com.
I recognize that Downeast LNG has spent many months and substantial monies preparing their Draft EIS. I have reviewed this document and find, among other things, that it is lacking in many areas including:
*an understanding of the basic operation of the Quoddy Ecosystem, its components and interactions,
* the constituent species that occur in the Region and their importance to the ecosystem and the resource industries that draw upon them,
* the local benthic nutrient pump that is so vital to the Northern Gulf of Maine,
* the occurrence of important plankton,
* the true impacts that industrial water use will have on vital biota, and
* the socio-economic impacts of this development on the existing resource-based industries.
Firstly, the scope of the document does not follow currently acceptable ecosystem focus now promoted by both American and Canadian professionals including the Gulf of Maine Council. In some cases, the status of a plant, animal, or social element is underestimated because the study focus is restricted to the immediate area surrounding the proposed development. In other instances, it appears that the references are so broad that they do not apply well to the reality of this region. The Quoddy/Cobscook Region is widely recognized as a vital ecosystem that is known to have the highest biodiversity of any area of similar size on the entire Canadian coast and is home to approximately 3,000 marine species as well as many listed and endangered species. It is unique as outlined in the online slideshow at: http://www.bayoffundy.ca/LNG/slideshow .
However, there is no “dotted line” or border - the ecosystem occurs in our two countries with over 3/4 of the productive environment occurring in Canada, creating the apparent disparity that motivates Maine-shore support of this and other local LNG proposals; unfortunately while ignoring the well developed “eco-economy” in Canada.
It is my considered opinion that the consultants were not familiar with the area in question and, moreover, that they relied on selected and questionable sources for much of their information; particularly endangered and listed species, fisheries activities throughout the ecosystem, plankton distribution and impacts of waters used for various activities, etc. But particularly, there is a lack of credible information on the vital planktonic resources, marine fishes, marine birds, and marine mammals of this area, the species composition, distribution and potential impacts relative to proposed tanker and tug activities, as well as impacts from construction and operational activities and designated “significant places”. We are attempting to provide professional information on this topic for FERC in response to the EIA, but it is proving difficult within the available time frame.
The absence of important whale records from Head Harbour Passage, West Isles, and the adjacent areas where LNG traffic will pass, is a glaring omission. Since the announcement of the EIA, we have been scrambling to gather together data on marine mammal occurrences through recent years to the present. This was part of our activities in any event, but the time frame allowed is just not adequate to properly assemble a professional document. We are attempting to provide professional information on this topic for FERC in response to the EIA, but it is proving difficult within the available time frame.
It is my sincere wish to provide FERC with the detailed and supportable data and information that it will require to make a proper and professional judgement of the Downeast LNG EIA. What can be gathered will be sent within the existing time frame, but I believe that FERC wishes the best and most professional documentation available and I respectfully request that you consider the motion for extension of the date for submission so that such information can be made available to you.