Submissions > The Requirement to be Informed by Michael McKinley with Notre Environnement, Notre Choix

The Requirement to be Informed by Michael McKinley with Notre Environnement, Notre Choix

The Requirement to be Informed

November 20, 2015

Dear Commissioners,

I’m concerned and deeply troubled by the potential for negative impacts that the shale gas industry could have for New Brunswick. One concern is the fact that the NB environmental assessment (EA) process doesn’t have a meaningful strategic study or comprehensive environmental review component. The newly revised and adopted ‘phased’ EA approach effectively removes that provision from the initiating stage of the EA process. The Minister can now make a determination for or against initiating a comprehensive EA at his discretion.

In the case of shale gas development, there has yet to be a comprehensive EA triggered. Since each and every license to frack is granted separately and therefore lacking of any notion relating to cumulative impacts, there is absolutely no environmental consideration granted to full-blown shale gas development from that perspective. Doesn’t the immense ecological and socio-economic footprint of shale gas warrant such a review?

I was surprised to read that BC opponents of shale gas knew about a similar lack of analysis back in 1986 as Mr.Will Koop of the BC Tap Water Alliance points out in his submission (attached1) to the Supreme Court of Canada in the case of Jessica Ernst vs Alberta Energy Regulator (AER). Contained in there is proof that the BC Ministry of the Environment urged the BC government to implement studies relating to cumulative impacts in 1986 and again in 1991. I would encourage you to read Mr. Koop’s submission in its entirety as it provides an instructive snapshot into the concerns people had when unconventional oil and gas development arrived in BC. Their concerns are now our concerns and development continues there and in Alberta despite an ever growing list of problems. Is that what we want for New Brunswick?

Closely related to the cumulative impacts issue is my second concern - the health risks associated with shale gas development. In a 2012 Health Canada report entitled Potential Health Hazards from Shale Gas Exploration and Exploitation – Drinking Water and Ambient Air (attached2) professional toxicologists outlined the risks and health hazards associated with shale gas development. Yet Industry and NB government spokespeople and the like maintained that there were no “concerns whatsoever” relating to health impacts. Apparently Health Canada had concerns in 2012. Why had we not been made aware of those potential health hazards from the outset?

My last reference is included to counter industry and any government claims that unconventional oil and gas development has been done safely for 60 years without problems. A Brief Review of Threats to Canada’s Groundwater from the Oil and Gas Industry’s Methane Migration and Hydraulic Fracturing by Ernst Environmental Services (attached3) provides a very comprehensive list of facts, reports, and studies and comments outlining the many number of instances where unconventional oil and gas development was implicated for having adverse effects. Do we really need further study to determine whether unconventional oil and gas development can be done safely with “world class” regulations when there is a sufficient body of evidence already in existence strongly suggesting that it cannot? “If you were looking for a way to poison the drinking water supply…you couldn't find a more chillingly effective and thorough method of doing so than with hydraulic Fracturing” - Dr. Paul Hetzler

Thank you, Michael McKinley, Notre Environnement, Notre Choix, Kent Co., NB