Officials with five federal government departments say Northern Pulp's proposed new effluent treatment site and pipeline lacks necessary details and sometimes uses outdated or inaccurate information.
The Pictou County-based paper mill is hoping to get approval from the province to build a new treatment site ahead of a legislated closure date of Jan. 31, 2020 for its current treatment site at Boat Harbour.
Public comment on the project closed on Nov. 8 and among the groups to make submissions were Environment and Climate Change Canada, Fisheries and Oceans Canada, Transport Canada, Health Canada and Public Services and Procurement Canada.
CBC News has obtained those submissions, which include concerns about the limited time the province's Class 1 environmental assessment process allows for public consideration.
'Cumbersome to navigate'
Four of the five submissions make direct reference to what department officials view as too narrow a timeframe to adequately evaluate the focus report, a document of about 2.500 pages.
"The report was, overall, found to be cumbersome to navigate and incomplete in some areas," according to the submission from Public Services and Procurement Canada (PSPC).
"Additionally, several review participants noted that the volume of information was such that a 30-day review period was insufficient to complete an in-depth review of related material."
The public comment period was actually open for 36 days, but the other departments also said the timeframe limited their ability assess the proposal.
PSPC officials called for analysis of the bedrock in the area where the pipeline would go underwater and raised concerns about there being no mention of leak detection for the portions of the pipe buried underwater.
The agency also pointed to what it views as insufficient information related to archeological assessments and a lack of "detailed habitat information in large sections of the proposed pipeline route as well as the entire diffuser footprint."
'There remains a high level of uncertainty'
Environment Canada took issue with the way background water samples were collected and identified and, along with Fisheries and Oceans scientists, with the use of two-dimensional modelling rather than 3D modelling to estimate dilution of treated effluent.
"The choice [of] a 2D approach is not appropriate for far-field modelling in the Northumberland Strait," officials wrote.
The agencies said the 2D approach doesn't sufficiently account for "circulation patterns resulting from wind forcing and/or tide/topography interactions and local buoyancy effects of freshwater release at the bottom."
They said "there remains a high level of uncertainty regarding the fate of effluent particles and their potential impacts on the receiving environment."
Fisheries and Oceans noted the project area includes herring spawning and larval distribution.
According to the submission, there is insufficient information to determine the potential effects to marine life or the validity of the proposed mitigation.
The review of literature describing the aquatic community is deficient, overlooking a wealth of information that is more contemporary and thorough, according to the government submission.
"The report largely relies on a desktop review of sparse published materials (some outdated) or uses fisheries information as a proxy for species distribution. The two are not equivalent and in some cases the fisheries information is erroneous."
Health Canada unable to assess risks
It says little consideration has been given to the effects discharge would have on different stages of aquatic organisms and it notes an absence of information about marine mammals, leatherback sea turtles and sharks and it also refers to the species that's drawn the most concern from the public — lobster.
Scientists believe there is inadequate information provided in capturing baseline details about lobster and rock crab populations, making it "impossible to assess any changes in chemical loading of American lobster and rock crab resulting from the effluent treatment facility."
Health Canada's submission says it does not have adequate information to assess whether the project may pose "unacceptable or unmitigatable risks/adverse effects to human health."
The agency said the fishery information in the focus report doesn't represent the full scale of things such as food, social and ceremonial fisheries, all of which is required for a complete assessment of exposure and toxicity risks to human health.
It says air dispersion modelling was not done to consider maximum output of a new treatment facility and contaminants of potential concern in the proposed discharge were not screened based on guidance from Health Canada.
Decision due by Dec. 17
The submission from Transport Canada said that although the focus report has further information about the pipeline location, the department is still awaiting specific details necessary before a lease could be issued for use of government land at the Caribou ferry terminal, where the 15-km pipeline would enter the Northumberland Strait.
Several of the departments note that even if the project is approved by the province, the company still has work to do before it would meet federal requirements for various aspects of the work.
Nova Scotia Environment Minister Gordon Wilson is expected to make his decision by Dec. 17.