Read 'em and weep!
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Canadian Environmental Assessment Agency
MILITARY FLYING ACTIVITIES IN LABRADOR AND QUEBEC Report of the
Environmental Assessment Panel February 1995
SUMMARY
This report conveys the findings of a seven-person environmental assessment
panel appointed to review military flying activities in Labrador and Quebec
as proposed by the Department of National Defence (DND).
Approximately 6000-7000 low level training flights are currently being
conducted out of Canadian Forces Base (CFB) Goose Bay, over designated
areas of Labrador and Quebec that total about 100 000 km2. This training is
being carried out under a Multinational Memorandum of Understanding (MMOU),
signed by Canada and NATO Allies, that expires in 1996. DND proposes to
negotiate a new MMOU that would provide for an in crease in the number of
aircraft, an increase in training flights to a maximum of 18 000, an
extension of the flying season, an additional practice target area of 300
km' and a change to the designated flying areas. Of the 18 000 proposed
flights, a maximum of 15 000 would be at low level, below 1000 feet. DND
estimates that 90% of those would likely be at 500 feet or below, and
approximately 15% would operate as low as 100 feet above ground level.
DND has put forth two mitigative options. Option "A" involves the
continuation of flight training within the two existing training areas of
100 000 km2, with reduced avoidance for both humans and sensitive wildlife
species. Option B modifies and adds to the current training areas to
provide 130 000 km2, of which no more than 100 000 km2 would be used for
training at any one time, while maintaining the current avoidance criteria.
DND prefers Option B, as it feels that this option will provide a higher
level of environmental protection while at the same time ensuring the
viability of the training program.
The environmental assessment panel was given the mandate to examine the
environmental, social and economic effects of the existing and proposed
training activities and to make recommendations accordingly. Following its
appointment in 1986, the panel held many public consultations at various
stages of the review and received considerable information from DND and
review participants. The public hearings held in 14 communities in Labrador
and Quebec in September and October 1994 were the most recent
consultations. All written and oral information received by the panel since
its appointment was considered in the preparation of this report.
This has been a special kind of environmental assessment, in that the
Project has been ongoing for many years and impacts more than 100 000 km2
of land in Labrador and Quebec that, until recently, had been used mainly
by aboriginal people. The Project entails no extraction of products from
the land and little alteration of the physical landscape. Impacts on the
land are mainly from noise and associated startle effects from low-flying
aircraft. This is not a hypothetical project. It is a real industry with
real employees and dependents.
The Project and the review have been the source of controversy, division
and social tension. This is the aspect of the Project that is best known
across Canada. Groups and individuals who benefit either directly or
indirectly from the Project hold views on the future of the Project that
are greatly divergent from those of people who do not benefit. The panel
was struck by the difference in evidence between those who benefit from the
Project, both aboriginal and non-aboriginal, who harvest from the land and
who said that the Project had little adverse effect on them: and those who
do not benefit from it and who claim that the overflights have significant
adverse effects. The Project is critically important to the livelihood of
some, yet it is a source of disruption and annoyance for others. Since the
completion of the public hearings, the panel has carefully weighed the
benefits of the Project against its adverse impacts. In doing so, the panel
has considered the need to make recommendations that not only will ensure
minimal Impact to the human and natural environment, but also might help
bridge the social and cultural polarization that now exist In the region.
The panel also examined the issue of aboriginal land claims. The panel
believes that settlement of land claims in the Project area will constitute
significant bridge building. The failure to settle land claims affects the
attitude of some aboriginal groups towards the Project. The panel has
recommended that, given the perception of the aboriginal groups that the
Project negatively influences their land claims negotiations, the federal
and provincial governments settle aboriginal land claims in the Project
area quickly.
The benefits of the Project were made clear to the Panel. The Project
supports the town of Happy Valley-Goose Bay. with a population of about
8600 people, and central Labrador in general. The Panel was told that Happy
Valley-Goose Bay is a one-industry town for which no viable economic
alternative currently exists and that the end of low-level flying would
result in the closure of CFB Goose Bay and an economic disaster for the
town. Many people told the panel that the continuation of low-level flying
was vital to the economic and social health of the town of Happy
Valley-Goose Bay and to the region. Hundreds of families and businesses
have built a prosperous and satisfying lifestyle over the years, based on
employment and income from military flying activities. Although widespread
support for the Project was evident in Happy Valley-Goose Bay and some
other communities, many people gave their sup port on the condition that
the natural environment of the region remain healthy, productive and
protected.
The social, health and environmental impacts of the Project are not as
clear to the panel as the economic impacts. The panel found that the
scientific basis for predicting the effects of the Project on wildlife,
natural systems and human health is weak in many areas. De spite more than
14 years of military low-level flying, there are few sound data on the
effects of low-level flying on human health. on wildlife or on the
environment in general. That state of ignorance should not be allowed to
continue..
With respect to the social impacts of the Project, the panel examined both
in-town impacts and those occur ring on the land. In terms of the former,
the panel concluded that those impacts related to infrastructure and
services, housing, base-region relations and general social problems can be
addressed as outlined in the panel's recommendations In this report.
Impacts on land use are an issue of critical importance, but the panel did
not receive conclusive evidence with respect to the magnitude of the
impacts. In light of the non-participation of some of the aboriginal groups
during the hearings, the panel was forced to rely on written information
provided by those groups prior to the hearings. That information indicated
that adverse impacts on aboriginal use of the land have been caused by low
level flying. This Information was useful; however, the panel was not able
to explore this issue with those groups to the extent it would have
desired. AI the hearings, the panel was told that aircraft noise might
discourage aboriginal peoples from using the landQa very important
consideration, for harvest is vital for many economic, social and cultural
reasons. However, the panel received no evidence that hunting, fishing or
trapping has decreased by reason of low-level flying. Indeed, some
participants indicated that these activities seem to have increased in the
past few years.
The panel also heard from both aboriginal and non aboriginal people who
harvest from the land and who indicated that they saw no adverse effects
from low level flying. The panel has concluded that there i8 a need for
further studies to determine the actual levels of resource harvesting on
the land and the impacts of low level flying on that harvesting.
The panel examined a number of potential impacts of low-level flying on
human health, including those related to fuel management, air quality and
hazardous waste management, the panel believes that measures being
undertaken by DND, in addition to the recommendations in this report,
satisfactorily address these issues.
The panel received considerable input from experts who raised largely
hypothetical and often contradictory concerns about the possible health
impacts of aircraft noise. Much testimony was received from residents who
said that they were not bothered by noise in the vicinity of the airport.
Nevertheless, the panel has identified a number of issues and made
recommendations concerning the effects of noise in the school environment
in Spruce Park, the disruption of activities such as sleeping and the
overall annoyance effects of noise. With much contradictory evidence at
hand, uncertainty re mains, and further monitoring and study are needed.
With respect to environmental issues, it became very clear to the panel
during the review that the principal environmental issue associated with
the Project was aircraft noise. The panel looked at the effects of noise
from aircraft on wildlife, the effects of night flying, the effects of
flying in river valleys and the effects of pollution from the flights. In
general, the panel was not presented with information that pointed towards
significant adverse impacts in any of these areas. In many areas, however,
the panel has concluded that baseline studies are required to allow for
constructive monitoring.
The panel also paid special attention to the effect of the Project on
caribou, which are one of the areaUs most important resources. The panel
has made several recommendations on this topic, the most significant of
which is for a joint Canada/Quebec/Labrador caribou management board for
the George River caribou herd.
DND's proposed mitigation to lessen or reduce impacts is through an
avoidance program. Avoidance refers to the closure of parts of the training
area to low-level flying to protect wildlife and people from low-level
overflight and startle. Despite an obvious dedication of money and effort
by DND to the avoidance program, the panel concluded that there are many
uncertainties regarding its effectiveness. With the exception of quite good
data on caribou, there is little information on the natural systems or
wildlife in the training areas. In addition, there are almost no cause-
and-effect research studies on the impacts of low-level flying in the
region. So little is known about much of the wildlife in the training areas
and the effects of overflights on them over the longer term that much
uncertainty, and hence concern, remains. As a result, the panel could not
draw conclusions on the longer-term effects of low-level flying on the
natural systems. The panel is not convinced that the avoidance program at
present is successful in meeting is objectives.
The panel heard some groups indicate that, despite DND's best efforts, it
was difficult for them to have full trust In the avoidance program, given
that DND was also running the flying program. In consideration of the
questionable success and credibility of the avoidance program, the case for
a different approach became clear. The need for independent co-ordination
of monitoring and research to feed into the avoidance program also became
evident
The panel acknowledges that, considering the apparent scientific
uncertainty with respect to the environmental and health effects of the
Project, the uncertainties associated with the avoidance program, the
social tension and polarization caused by the Project and the strong
opposition to the Project by important aboriginal groups, a first reaction
might be that the Project should not proceed.
The panel has assessed the benefits of the Project against the above
factors. The panel has concluded that, in the short term, severe negative
economic effects would result from Project termination, and there is little
evidence at this time to suggest that the Project will cause significant
negative environmental, social or health impacts. The panel also
believes-that, in the short term, Project termination might create more
social tension, rather than lessen it.
However, the panel has also concluded that there is still a high level of
uncertainty with respect to the effects of low-level flying, and that, in
the longer term, an Independent organization is needed to co-ordinate
monitoring and research efforts aimed at resolving some of this
uncertainty. The panel believes that the best course of action is to
proceed with the Project while taking all steps necessary to ensure
protection of the environment and human health and to build bridges of
equal participation and trust in an effort to reduce existing social
tension.
The panel therefore recommends that the Project be approved, subject to the
recommendations in this report. An absolute condition is the establishment
of the Labrador Institute for Environmental Monitoring and Research, whose
function would be to advise on the terms and conditions governing low-level
flying with respect to avoidance criteria, mitigation measures, research,
effects monitoring, compliance auditing, boundaries of the low-level
training area and project-related land uses in the training area. The
Institute must be established prior to the signing of a new MMOU.
Affected aboriginal groups in Labrador and Quebec must be equal partners in
the Institute. This will remove DND from Its dominant role with respect to
the management of monitoring, mitigation and research. The creation of the
Institute will leave the bulk of the responsibility for these important
areas to other, more appropriate interested users and government agencies.
DND should not carry the full load for the financing of the Institute. The
panel recognizes that DND and NATO Allies have set aside substantial funds
for monitoring, mitigation and research. The panel believes that these
existing funds should be targeted for the Institute and that other federal
and provincial agencies should re-direct some of their present research and
resource management funds to the work of the Institute. These redirected
funds should at least match contributions made by the Allied countries.
With skillful financing, there need be no additional cost to government. It
is expected that the Institute will also seek funds from research granting
agencies. foundations and other private sources.
It would be unacceptable to approve the Project without a sound supporting
program of monitoring and research. The proponent and many participants
called for that. However, it would be equally unacceptable, even foolish,
not to design and manage that monitoring and research program in a way that
takes full advantage of all available experience and insights and that at
the same time builds trust, credibility and acceptance for the Project. In
brief, it would be wrong to approve the Project without the institution
that will help make it viable. The panel is convinced that the minimum
price to pay for project approval is a package of mutually supporting
measures aimed at reconciling two objectivesQprotecting the environment and
human land use, and maintaining a viable flight training programQwhile, at
the same time, reducing the alienation of many aboriginal people from the
Project and the conflict between groups in the region. The package consists
of:
* a commitment to early settlement of native land claims;
* the establishment of the Labrador Institute for Environmental Monitoring
and Research;
* and the setting up of a joint caribou management board for the George
River caribou herd.
With respect to the recommended option for training areas, the panel
believes that a flexible approach must be adopted. The panel has
recommended that the Option B configuration with flexible boundaries be
accepted as the preferred option for re-negotiation of the MMOU in 1996.
The panel believes that what Is essential in adopting a flexible approach
to airspace allocation is public input into and understanding of the
rationale behind airspace management decisions that are taken on a
month-by-month or seasonal basis. The panel has recommended that this is a
task for the proposed Institute.
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The panel has made 58 specific recommendations throughout the report -
sorry, they didn't come out well enough on the fax to scan in.