On December 21, 2021, The Government of Nova Scotia released Draft Terms of Reference for Northern Pulp’s mill transformation project.

The Terms of Reference set out the rules and expectations for Northern Pulp to complete their Environmental Assessment Report and submit it for approval to the NS Department of Environment and Climate Change.

The Draft Terms of Reference can be found here: Class-II-EA-Draft-TOR-NP-Dec-21-2021.pdf (novascotia.ca)

The 50-page draft Terms of Reference is available for public and stakeholder input until the end of January.  The province will review all feedback received and use it to determine the final Terms of Reference which will be released in March 2022.

The Friends of New Northern Pulp have reviewed the draft Terms of Reference and will be making the following observations in our feedback to the NS Department of Environment and Climate Change.

• We are pleased to see the draft Terms of Reference are more thorough than the previous set. It will be important for Final Terms of Reference to be even more comprehensive and not subject to change during the Environmental Assessment process. There can be no moving goalposts during the process.
• The prescribed timelines detailed in the review overview are important and must be followed. There should be no changes or extensions to the timelines.
• The inclusion of a review panel to assess the EA Report is vital to an objective outcome. To be effective, such a panel must be independent from the Department of Environment and composed of subject matter experts who know about pulp mills and their impacts on receiving environments.
• The decision to not include any specific provincial emission standards is disappointing. Potentially, this lack of clarity allows the Department to move the goal posts during the process which would be unfair. The Friends of a New Northern Pulp believe that Canada’s national standards for treated Pulp and Paper Effluent Regulations (PPER) and existing Canadian Ambient Air Quality Standards (CAAQS) should be used as the guiding standards to assess the New Northern Pulp Plan.
• The Friends of a New Northern Pulp believe the impacted communities should be broader than the immediate area as Nova Scotia’s entire forestry sector (including private landowners) and communities throughout NS are impacted by having a market for low grade fiber and as such their social and economic welfare is also at stake in this EA process.
• The Friends of a Northern Pulp also believe that consideration needs to be given to the vital importance of having a market for low grade fiber provided by a centrally located pulp mill to the broader provincial environmental goal of practicing ecological forestry as recommended in the Lahey Report and recently enshrined in provincial law.

 If you agree, please tell the Department any or all these points:

• I work in forestry and want to be able to continue to make a livelihood from forestry in Nova Scotia. The uncertainty created by the sudden closure of Northern Pulp has been very damaging for our sector. (Or I support the forestry sector in our province, or I support the transformation of Northern Pulp.)
• The Environmental Assessment Process must be fair and clear. It must be thorough and based on science and national standards. There are 88 other pulp mills in Canada and hundreds around the world that operate in a manner that is healthy for their economy and safe for the environment.
• Subject Northern Pulp’s Plan to a rigorous assessment in the prescribed timelines. Don’t change the rules during the process or move the goal posts.
• Canada’s national standards for air and water emissions should be the guiding standards for this project.
• An expert, independent review panel should be created as soon as possible. 
• I live outside of Pictou County. My livelihood depends on the mill operating. My voice should matter.
• The natural resource sectors of farming, fishing and forestry are vital to our province. They provide jobs and keep our rural economies going. Please prove that natural resource sectors can still provide jobs and livelihoods in rural Nova Scotia by conducting a fair, and objective process.

FROM NOVA SCOTIAN WORKING IN FORESTRY SECTOR

To: Environmental Assessment Branch, NS Dept of Env. and Climate Change

I am writing to you today to provide comments on the draft Terms of Reference for the Class II Environmental Assessment for the Northern Pulp Mill Transformation project.
I live in _________ county, Nova Scotia. I work in forestry and want to be able to continue to make a livelihood from forestry in Nova Scotia. The uncertainty created by the sudden closure of Northern Pulp has been very damaging for our sector. My livelihood depends on the mill operating. My voice should matter.

The Environmental Assessment Process must be fair and clear. It must be thorough and based on science and national standards. There are 88 other pulp mills in Canada and hundreds around the world that operate in a way that is healthy for their economy and safe for the environment.

I think it is important to subject Northern Pulp’s Plan to a rigorous assessment in the timelines that have been prescribed. The Department should not be permitted to change the rules or move the goal posts during this process.

I also think that Canada’s national standards for treated effluent should be the guiding standards for this project and that fair and just air emissions standards should be set for the mill to meet. These standards should be based on those set by other Canadian Provinces with operating mills.

Finally, I believe an independent expert review panel be created as soon as possible. There is neither the expertise nor independence within the NS Department of Environment and Climate Change to do this job objectively.

The natural resource sectors of farming, fishing and forestry are vital to our province. They provide jobs and keep our rural economies going. Please prove that natural resource sectors can still provide jobs and livelihoods in rural Nova Scotia by conducting a fair, grounded and objective process.

Thank you,

FROM NOVA SCOTIAN OUTSIDE THE FORESTRY SECTOR

To: Environmental Assessment Branch, NS Dept of Env. and Climate Change

I am writing to you today to provide comments on the draft Terms of Reference for the Class II Environmental Assessment for the Northern Pulp Mill Transformation project.

I live in _________ county, Nova Scotia. I believe this project is important to the economy of Nova Scotia. I believe The Environmental Assessment Process must be fair and clear. It must be thorough and based on science and national standards. There are 88 other pulp mills in Canada and hundreds around the world that operate in a way that is healthy for their economy and the environment.

I think it is important to subject Northern Pulp’s Plan to a rigorous assessment in the timelines that have been prescribed. I feel it is very important that the rules are set and are not changed through the process.
It makes sense for the Canada’s national standards for effluent be used as the guiding standards for this project. I also believe that fair and just air emissions standards should be set for the company to meet. These should be based on those set in other Canadian Provinces with operating mills.

Finally, I feel it is very important that an independent expert review panel be created as soon as possible. The NS Dept of Environment and Climate Change does not have the expertise or the independence to do this job objectively.

The natural resource sectors of farming, fishing and forestry are vital to our province. They provide jobs and keep our rural economies going. Please prove that natural resource sectors can still provide jobs and livelihoods in rural Nova Scotia by conducting a fair, grounded and objective process.

Thank you,

To: Environmental Assessment Branch, NS Dept of Env. and Climate Change

I am writing to you today to provide comments on the draft Terms of Reference for the Class II Environmental Assessment for the Northern Pulp Mill Transformation project.

I live in _________ county, Nova Scotia. My family owns a woodlot and like many Nova Scotia woodlot owners, I want to improve its condition for the next generation. To be able to do this depends on having viable markets for all forest products. The uncertainty for low valued forest products created by the sudden closure of Northern Pulp has been a setback to our ability to tending our family’s forest.

We do our best to manage our woodlot sustainably and follow best practices. A reality of managing a woodlot is removing lower quality trees to provide room for more desirable ones to grow. Having a steady and active market like Northern Pulp provided, affords private woodlot owners such as myself, the opportunity to practise ecological forestry. Even if my woodlot didn’t sell directly to Northern Pulp, many others do and that affects economics of the overall fiber market in Nova Scotia.

Although my woodlot is located outside of Pictou County, my family’s views should matter and be considered in the process. I urge you to expand the scope of the study area to consider the socio-economic impacts of a central pulp mill beyond the immediate area.

I think it is important to subject Northern Pulp’s Plan to a rigorous assessment in the timelines that have been prescribed. The Department should not be permitted to change the rules or move the goal posts during this process.

I also think that Canada’s national standards      for treated Pulp and Paper Effluent Regulations (PPER) and existing Canadian Ambient Air Quality Standards (CAAQS) should be used as the guiding standards to assess this project. 

Finally, I believe an independent expert review panel be created as soon as possible. There is neither the expertise nor independence within the NS Department of Environment and Climate Change to do this job objectively.

The natural resource sectors of farming, fishing and forestry are vital to our province. They provide jobs and keep our rural economies going. Please prove that natural resource sectors can still provide jobs and livelihoods in rural Nova Scotia by conducting a fair, grounded and objective process.

Thank you,

To: Environmental Assessment Branch, NS Dept of Env. and Climate Change

I am writing to you today to provide comments on the draft Terms of Reference for the Class II environmental assessment for the Northern Pulp Mill Transformation project.

I live in _________ (Province), Canada. I care about the Forestry sector in Canada, and I would like my voice to be heard on this matter.

The Environmental Assessment Process must be fair and clear. It must be thorough and based on science and national standards. There are 88 other pulp mills in Canada and hundreds around the world that operate in a way that is healthy for their economy and the environment.

I think it is important to subject Northern Pulp’s Plan to a rigorous assessment. I also think that Canada’s national standards for effluent should be the guiding standards for this project and that fair and just air emissions standards should be set for the mill to meet. These standards should be based on those set by other Canadian Provinces with operating mills.

Finally, I feel it is very important that an independent expert review panel be created as soon as possible to oversee and evaluate this plan.

The Forestry sector is important to Canada and the proposed transformation plan for the Northern Pulp Mill should be given a fair chance.

Thank you,