...and Parry
Reply from J.W. Bourque, Deputy
Minister
15 December 1989
Mr. Gerry De Sorcy
Chairman
Alberta Pacific Impact Assessment
Environmental Review Board
Standard Life Building
1540, 10405 Jasper Avenue
Edmonton, Alberta
TSJ 3N4
Dear Sir:
I regret the developments which have led me to write this letter. However, I feel that we must outline our reaction to these events while at the same time reaffirming our government's commitment to the review process for which you and the Board are responsible.
Recent events have inclined the Government of the Northwest Territories to the view that the integrity of the environmental review process constituted by the Alberta and Federal govemments has been undermined by the activities of the proponent, AlPac, outside the hearing room. We wish to formally register our objection to the criticisms being made of our position through AlPac's recent press releases.
As the Deputy Minister of the Department of Renewable Resources for the Government of the Northwest Territories, it was my responsibility to assemble the technical teams which developed and presented our Government's position to your Board in Forth Smith. Our position throughout these hearings has been that current levels of chlorinated organic compounds being found in fish in the Peace, Athabasca and Slave Rivers provide cause for concern. Given the possible magnitude of the effluent loading of these substances to be generated by AlPac's proposed mill, our position has been that no new sources should be licensed until we are sure that these additional loadings can be accommodated by the system. We, therefore, called for zero discharge from the AlPac mill. I point out to the Board that the furore in the press, resulting from different ways of calculating total dioxin and furan loading is thus irrelevant to our basic position.
Unfortunately the proponent's activities have also raised procedural concerns which we are compelled to draw to the Board's attention. At the end of our presentation in Fort Smith, AlPac requested through the Board, that the Government of the Northwest Territories reappear to give further detail on our technical position. We agreed and at considerable expense to our government, the team reappeared in Edmonton. We brought in additional expertise and revised information to this technical session. The latter was provided to the proponent several days in advance. After our presentation, AlPac raised the issue of estimated levels of dioxin and furan loading, referring to a comment made by Dr Hallett and one paragraph in Annex 3 of our overall Position Statement. Dr Hallett briefly responded to this discrepancy between loading estimates. AlPac asked no other questions of him. In fact, they have posed no questions on any other pan of our Position Statement or the four annexes. Mr. Chairman, what was AlPac's point in requesting our return to the public forum when they did not even undertake a meaningful technical discussion? Subsequent to ourpresentation, however, AlPac has raised their criticisms through the press, in a manner which has given us little opportunity to rebut their position.
As a result, I have instructed my technical team to respond to the Board immediately and advise you on how our dioxin and furan loading numbers were generated and what they mean. If we have made an error we will identify it and indicate whether it affects our position. We expect that this submission will form a part of the hearings record. We will also be responding in detail to the Board on the issues that have been raised in material tabled by AlPac on December 4th.
We wish to repeat to your Board that it always was and remains the intention of the Government of the Northwest Territories to participate in your review process through the public hearings and not via the media. We feel that the proponent's use of the media to voice their concerns is unwarranted, unfair and counterproductive to the overall review process. I would like to take the opportunity to list, for your consideration, several of our concerns with the public relations/media approach upon which AlPac has embarked:
1) We are concerned that AlPac's tactics may be adversely affecting public perception of the overall review process. We also point out that we are not the only intervenors to have been singled out for these kinds of intimidation tactics.
2) AlPac's press release of December 7, 1989 was factually inaccurate and misrepresented our position before the Board. In our view, this was aimed at tarnishing the credibility of our efforts before your Board and may also have caused damages to the personal reputations of our expert witnesses; and
3) Other public intervenors may have modified their positions due to these intimidation tactics and for fear of reprisal in the media, outside your forum.
We understand the nature of your mandate and the limitations which characterize your Board's powers. We request that the Board respond publicly to these intimidation tactics by making it clear that the contents of these press releases do not form a part of the hearings record and will not influence the Board's decision. Decisive action by the Board will reaffirm to the public that the discussions and technical information which are part of the environmental assessment and review process must be presented and evaluated within the hearing sessions and not outside them.
Yours sincerely,
J.W. Bourque
Deputy Minister