July 15, 2016 - An Open Letter to Minister Catherine McKenna re: Her Letter to OPG Requesting Further Information on the DGR and OPG's Inadequate Response

July 15, 2016
The Honourable Catherine McKenna,
Minister of Environment and Climate Change,
Environment Canada,
Minister’s Office
200 Sacre-Coeur Blvd., 2nd Floor,
Gatineau, QC, K1A 0H3

AN OPEN LETTER TO THE MINISTER RE 1) HER FEBRUARY 18, 2016 LETTER TO OPG REQUESTING FURTHER INFORMATION RE THE PROPOSED KINCARDINE DGR, AND 2) OPG’S RESPONSE OF APRIL 15, 2016 SENT TO RON HALLMAN, PRESIDENT OF THE CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY (CEAA), DODGING 2 OF THE MINISTER’S 3 QUESTIONS

Dear Minister:

Please note our new name, SOS GREAT LAKES. This reflects the rapidly growing concern about a Kincardine DGR shared by Canadians and Americans, especially the 40 million people who receive their drinking water from the Great Lakes. SOS began as a local citizens’ group, Save Our Saugeen Shores, dedicated to keeping buried nuclear waste out of the Great Lakes Basin. From 2012 to 2014, we fought to stop the proposed DGR for high level nuclear waste in Saugeen Shores, a few kilometres north of Kincardine. That battle was won. Now, as explained at http://www.sosgreatlakes.org, we are working to bring to your attention the voices of thousands of Canadians and Americans throughout the Great Lakes Basin and beyond who are appalled at the notion of nuclear waste being buried so close to the world’s largest supply of fresh drinking water.

We urge you to instruct Mr. Hallman to reject OPG’s April 15 letter as completely inadequate. You made specific requests relating to:

a) “alternate locations…”, - that is, specific locations when you noted “...with specificreference to actual locations...”, and;

b) “…cumulative environmental effects of the Project in light of the results of the Phase 1 of the Preliminary Assessments undertaken by the Nuclear Waste Management Organization, which identified three potential host communities that fall within the traditional territory of the Saugeen Ojibway Nation.”

You and Mr. Hallman received answers to neither.

Instead of following your instructions regarding “alternate locations”, OPG misinterprets by stating OPG will look at “geologic regions”, - granite in the north and sedimentary rock in the south. This replicates OPG’s performance before the Joint Review Panel (JRP) when it routinely promised to answer the JRP’s questions but always seemed to manage to duck or dodge.

OPG should be instructed to follow the directions given.

Similarly, with respect to your question about “cumulative effects”, instead of following yourinstructions, OPG stated it will look at the cumulative effects of a hypothetical used fuel repository on its Project in two of the three communities. It not only arbitrarily reduced the number of communities from three to two but twists the requests from ‘cumulative environmental effects of two repositories on the communities’ to the ‘effect of a DGR2 on its DGR1’.

Again, OPG should be instructed to follow the directions given.

With respect to the scope of your February 18 letter, we would respectfully point out you could have requested more information, consistent with the Act’s requirements, about alternative means of storage in addition to alternative locations. OPG’s material and the JRP report are both as deficient in their analysis of alternate means as they were about alternate locations.

In November 2015 we sent you a detailed Briefing Document on 8 major public policy errors that we believe are present in this OPG proposal for a Kincardine Nuclear Waste Repository and the JRP Report approving it. Your February 18 letter seeks more information on a major part, but not all, of 1 of those 8 errors. The remaining 7 may have been acceptable to the Harper Government. However, all 7 of these errors appear to be inconsistent with your Government’s election platform and post-election policy statements. This leads us to believe that in the unlikely event that OPG is able to satisfy you on the February 18 questions, you would have multiple other reasons to reject the JRP Report.

To date, you have declined our request for a meeting, presumably on the advice of counsel, because we have applied for Judicial Review of the JRP decision by the Federal Court and Environment Canada is a respondent. We respect that advice, but want you to know we have confidence that, after thorough review of our information, your Government will share our view that the issues we raised in the detailed Briefing Document call for a Public Policy decision rejecting this OPG proposal.

Respectfully,

Jill Taylor, President
SOS Great Lakes
On behalf of the Board of Directors

 

With copies to:
The Right Honourable Justin Trudeau, Prime Minister of Canada
The Honourable Kathleen Wynne, Premier of Ontario
The Honourable James Carr, Minister of Natural Resources
The Honourable Stephane Dion, Minister of Foreign Affairs
The Honourable Kirsty Duncan, Minister of Science
The Honourable Ralph Goodale, Minister of Public Safety and Emergency Preparedness
The Honourable Dominic LeBlanc, Minister of Fisheries, Oceans and the Canadian Coast Guard
The Honourable Jane Philpott, Minister of Health
The Honourable Glenn Thibeault, Minister of Energy
The Honourable Eric Hoskins, Minister of Health and Long Term Care
The Honourable David Orazietti, Minister of Community Safety and Correctional Services
The Honourable Glen R. Murray, Minister of the Environment and Climate Change
The Honourable Kathryn McGarry, Minister of Natural Resources and Forestry
Marlo Raynolds, Chief of Staff, Environment and Climate Change Canada
Ron Hallman, President, Canadian Environmental Assessment Agency

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