u/Status-Lime3469

I’ve been asked to provide additional documents related to the Spruce Lake Industrial Park expansion and proposed data centre in Lorneville. Sharing the technical materials here so everyone has access to the same source information.

EIA review can be located under project number: 1635 

Record of EIA registrations and determinations 1623 - 1641 - gnb.ca

Map of coastline, tidal inlets bordering proposed project.

Lorneville Saint John, NB

45.184529, -66.156012

I’ve been reviewing the full EIA package alongside several residents and families in Lorneville who are directly affected by the proposed expansion. Together, we documented 53 technical concerns related to hydrology, ecological baselines, air‑quality methodology, governance conflicts, cumulative impact assessment, and UNESCO Geopark obligations.

These concerns have already been formally submitted to Minister Gilles LePage (Environment & Climate Change).
I received a form‑letter response that did not acknowledge a single one of the documented issues — not the hydrology omissions, not the ecological baseline gaps, not the UNESCO obligations, and not the cumulative impact warnings from federal experts.

I’m sharing the documents here so anyone discussing the project can review the same source material directly.

Dear Minister LePage,

I am writing to formally request an immediate halt and comprehensive re‑evaluation of the Environmental Impact Assessment (EIA) registration for the Spruce Lake Industrial Park expansion and associated data centre project in Lorneville. The deficiencies in the current EIA are not isolated consultant errors; they represent systemic failures across municipal governance, environmental assessment methodology, public communication, and provincial oversight.

Proceeding on the basis of this incomplete and improperly scoped assessment poses direct and irreversible risks to local ecosystems, private wells, and the downstream watershed. Under the Clean Environment Act, these failures warrant ministerial intervention.

I. Governance Failures and Structural Conflict of Interest

The municipal review process lacked the independence required for a neutral regulatory evaluation. The City of Saint John acted simultaneously as:

• project proponent (owner of the industrial park land),
• applicant (submitting its own rezoning amendments), and
• regulator (conducting the public hearing and approving the project).

This structure created a profound conflict of interest:

1. The City evaluated its own application. No independent municipal body existed to critically assess the proposal.
2. Councillors sat on the development board promoting the project while also voting on it. This blurred the line between advocacy and regulation.
3. Institutional bias toward approval. Planning staff appeared under internal pressure to facilitate the expansion, contributing to residents’ perception that the outcome was predetermined.
4. Deflection of responsibility. When residents raised concerns about groundwater, wetlands, and ecological damage, City staff repeatedly stated these were “provincial responsibilities,” despite the City being the proponent.
5. Lack of Indigenous consultation. The Wolastoqey Nation was not consulted, contrary to FPIC, UNDRIP, and UNESCO Geopark guidelines.

These governance failures alone justify a ministerial review of the EIA registration.

II. Contradictions Between Municipal Claims and EIA Evidence

The City’s public communications contain multiple contradictions that misrepresent the environmental realities of the project:

1. “Clean, non‑emitting industries” vs. natural gas plant in the EIA. The EIA includes a large‑scale fossil‑fuel generator plant incompatible with the City’s claims.
2. “Enhanced wetland protections” vs. 1.5–1.75 km of unmapped brooks and streams. These omitted watercourses feed wetlands and drain into the Bay of Fundy.
3. “Significant preservation of natural areas” vs. 83% unprotected. Only 17% of the rezoned land is preserved; 83% is open for industrial development.
4. Trees and wetlands may be removed “if there is a business case.” This places ecological protection secondary to industrial interests.
5. “Unprecedented engagement” vs. no Indigenous consultation. The City did not consult the Wolastoqey Nation.
6. The City admits the land is “very rare… in the entire world,” yet proposes industrial clearing.
7. Companies require 40‑hectare footprints, contradicting claims of “clean industry.”
8. “One of the biggest economic projects in a generation” signals massive industrial intensification.
9. UNESCO Geopark guidelines ignored. Indigenous involvement, geological heritage protection, and sustainable development requirements were not met.

These contradictions demonstrate that the public was not provided with accurate information about environmental risks.

III. Technical Deficiencies in the EIA Registration

The EIA contains multiple scientific and methodological failures:

Hydrological Failures

1. 1.5–1.75 km of active watercourses omitted, eliminating required 15‑m buffers.
2. Headwater streams feeding wetlands and the Bay of Fundy not mapped.
3. No hydrological impact plan for altered watercourses or blasting.

Ecological Baseline Failures

1. Single‑season ecological surveys — no multi‑season baseline.
2. Migratory bird patterns not assessed.
3. Seasonal wildlife movements not assessed.
4. At‑risk plant cycles not assessed.
5. Old‑growth forest impacts not assessed.
6. Peatland ecosystem impacts not assessed.

Air Quality & Climate Failures

1. Air sensors placed beside a highway, inflating baseline pollution.
2. Localized residential air impacts not assessed.
3. Greenhouse gas emissions underestimated despite a 190‑MW gas‑fueled generator plant.
4. Climate impacts ignored, despite an estimated 6.6% increase in provincial emissions.

Groundwater & Well Safety Failures

1. No groundwater impact plan for blasting, infilling, or altered hydrology.
2. Risk of acid rock drainage not assessed.
3. Risk of heavy‑metal contamination not assessed.
4. Risk of permanent water‑table alteration not assessed.
5. Risk of increased flooding not assessed.

UNESCO Geopark Failures

1. Geological heritage impacts not assessed.
2. Underground estuaries not assessed.
3. UNESCO compliance obligations not addressed.
4. Indigenous cultural heritage and rights not addressed in the EIA materials.
5. No clear evidence of Indigenous consultation, despite UNESCO Geopark requirements.
6. Potential impacts to Indigenous cultural landscapes not assessed.
7. Lack of coordination with Stonehammer UNESCO Global Geopark regarding hydrology, ecological connectivity, and cultural heritage obligations.
8. Upcoming UNESCO inspection not acknowledged in the EIA process, despite potential implications for Geopark standing.

IV. Cumulative Impact Failures

1. Only 25% of the rezoned land was assessed, fragmenting the project.
2. Project splitting prevented a cumulative impact analysis.
3. Previous Spruce Lake expansions (2024) not included.
4. Long‑term ecological footprint not assessed.
5. Long‑term industrial emissions not assessed.
6. Long‑term land conversion impacts not assessed.
7. Federal Expert Warnings Ignored; The Technical Review Committee’s Comment 93, citing Environment and Climate Change Canada, explicitly warns that cumulative wetland loss from nearby projects—including Spruce Lake, Burchill Wind Farm, the 138 kV Corridor, and Coleson Cove—has reached critical levels. ECCC recommends avoiding any further wetland destruction and exploring restoration or compensation within the same watershed. The proponent’s response (“Wetland compensation will be addressed as part of the Watercourse and Wetland Alteration Permitting process”) defers responsibility and fails to meet federal expectations. Proceeding despite this warning would contravene the precautionary principle and undermine Canada’s commitments under the Clean Environment Act and federal biodiversity policy.

V. Public Trust and Transparency Failures

1. Voltagrid communications implied EIA approval was expected, undermining trust.
2. Residents perceived the decision as predetermined due to the City’s dual role.
3. Public information contained omissions and contradictions.
4. Residents’ concerns were dismissed or deflected.
5. The public was not informed of UNESCO obligations.

Formal Request for Action

Under the Clean Environment Act, I respectfully request that you:

1. Withhold or pause approval on the active Lorneville Data Centre EIA registration until a comprehensive, independent cumulative impact study is conducted.
2. Order a comprehensive re‑evaluation of the EIA registration.
3. Mandate an independent, multi‑season ground‑truthing study to accurately map all hydrological features and wildlife before any permits are issued.
4. Require a full cumulative environmental impact assessment covering 100% of the rezoned footprint, without segmentation.

Thank you for your attention to this urgent matter and for your continued commitment to protecting New Brunswick’s environment and communities.

Sincerely,

Marnie Mercier