Why Plan B shouldn’t proceed

Letters to the Editor (The Guardian)
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By Gary Schneider

Commentary

 

For over six years, I co-chaired the environmental planning and assessment caucus of the Canadian Environmental Network. I also served on the federal Regulatory Advisory Committee, which advised the minister of environment on issues related to environmental assessment. As part of this work, I helped draft the Canadian Environmental Assessment Agency’s Ministerial Guideline on Assessing the Need for and Level of Public Participation in Screenings under the Canadian Environmental Assessment Act and other guidance material.

One of the basic tenets of good environmental assessment is that meaningful public participation only occurs when the public is actually able to influence thefinal decision. This doesn’t mean that the public always gets its way.  But it certainly means that final decisions cannot be made before members of the public have a chance to present their views. In the case of the Trans-Canada Highway Realignment (Plan B), this essential condition of meaningful public participation does not appear to have been met.

The letting of tenders, the threat of expropriation and the general attitude of the politicians and civil servants have left most participants feeling as though this project is a done deal and that their interventions will be a waste oftime.

The environmental assessment documents are also just too huge to expect most people to have a thorough understanding of the material within such a short time frame. I did take the time to read all the EIS documents, and I am more convinced than ever that this major project will have serious impacts on our Island environment.

The overriding justification for any public project should always be community need. If Plan B was something that the Island really needed, there might besome justification for destroying habitat and expropriating people’s properties. But this clearly is not the case. If it were not for the federal money attached to this project, it would never take place. To ruin these rare habitats simply to take advantage of federal funding is indefensible from an ecological perspective.  

Throughout the Environmental Impact Statement, there are far too many qualifiers, such as “where possible” and “where feasible” throughout the report. Statements such as “Native species will be used, where possible, for revegetation efforts. Where not possible, species used will be non-invasive” or “Avoid known locations of plant and wildlife SAR and SOCC, where feasible” offer no firm assurance that the work will be carried out in a way that protects or even enhances the environment. Some contractors might just do whatever is cheapest and let these qualifiers take them off the hook. I would suggest removing such qualifiers so that the public knows exactly what willtake place and that contractors, if the project does go ahead, have clear rules that they will have to follow.

As the manager of the Macphail Woods Ecological Forestry Project looking after 2,000 acres of provincial forest land, I find that the report gives little weight to the fact that most of P.E.I.’s woodlands are already disturbed or degraded. If we had large areas of relatively healthy forest ecosystems, perhaps you could justify losing some. But that is not the situation we find ourselves in here. Most forests that can be seen from any roadway are seriously degraded, generallyhaving been farmland at some point in recent history. Far too much of the rest of our woodland has been clearcut and/or is some kind of conifer plantation, lacking diversity and ecological integrity.

If you don’t recognize how rare healthy forests are in the province, you don’t know what you are losing. It somehow has become acceptable to lose part of Bonshaw’s beautiful hemlock stand and leave the rest chopped in two. The ecological integrity of that stand will certainly be destroyed. We know a hemlock stand is more than one tree,more than five trees, but exactly how big an area of hemlock do we need in order to have it functioning as a viable ecological community? We don’t really have a good answer for that, and I think we should have before we begin to even think about fragmenting our few remnants of old growth forest.

The report also pays little attention given to the mixed hardwood stand on the steep slope that is part of the Crawford property. It is an ecological jewel, a forest habitat that I rarely if ever see in the province and I am fortunate in having seen a great deal of Island forests. The steepness of the slope, the height of some of the trees, the seep and small stream, all make it a unique area. This is another unique and precious habitat, one that again everyone should have a hard time seeing destroyed. It is a property that I would love to spend more time in and look at what is really living there throughout the year, both flora and fauna. And I hope that future generations of Islanders will also have that chance.

Regarding invasive species, the report recommends that “All construction equipment and vehicles (trucks and heavy machinery) will be visually inspected for vegetation each day by the Responsible Person, or designate, prior to engaging in any construction activities. Particular care must be paid to the undercarriage of vehicles and machinery.” Again, it is hard to believe that this could ever take place. Will the province really inspect the undercarriage of every truck delivering gravel or shale, or every piece of heavy equipment? The cost alone would be astronomical.

The report outlines some problems quite well, such as: “Mature forests often contain rich communities of plants and animals. Certain species depend on unique environmental conditions created by these forests.Large diameter trees, snags and fallen tree parts and root systems in various stages of decomposition provide the structure needed for life for many species of the forest. Mature forests serve as a reservoir for species which cannotthrive or easily regenerate in younger forests, and so can be used as a baseline for research. These forests serve as natural reservoirs of geneticdiversity and reproductive fitness, store large amounts of carbon above andbelow ground, and serve other ecological functions.”

But then the authors fail to adequately address those concerns.

Given all these environmental concerns, and the many others raised by Island residents regarding the cost to taxpayers, the lack of significant benefits and the availability of clear alternatives, the realignment should not be allowed to go ahead. To do so would be to give credence to those who say that Prince Edward Island’s environmental assessment process is just a rubber stamp for the whims of government.

 

Gary Schneider is co-chair of the Environmental Coalition of Prince Edward Island.

 

Organizations: Environmental Network, Regulatory Advisory Committee, Canadian Environmental Assessment Agency Trans-Canada Highway Realignment Islanders Environmental Coalition of Prince Edward Island

Geographic location: Prince Edward Island, Screenings

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