Nov 11, 2012

British Columbia, CANADA & beyond: Please take action & OBJECT VOCIFEROUSLY! Tidal Turbines in Whale Epicentre? Hell No!

From: The Marine Detective <>
Date: Sun, Nov 11, 2012 at 10:12 AM
Subject: [New post] RESEND: Tidal Turbines in Whale Epicentre? Hell No!

The Marine Detective posted: "Apologies dear subscribers. I am resending this as there was an error in one of the links for commenting to government + a few fabulous typos! Corrected below and at this link"
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RESEND: Tidal Turbines in Whale Epicentre? Hell No!

by The Marine Detective
Apologies dear subscribers. I am resending this as there was an error in one of the links for commenting to government + a few fabulous typos! Corrected below and at this link
Very best wishes, Jackie
There are times when explicatives like "Hell No!" are justified and I am sure you will agree this is one of those very unfortunate times and - your action is needed.
Blackney Pass off Johnstone Strait is an epicentre of whale activity and there is an application for an "Investigative License of Occupation - Ocean Power " for this very area. Yep, that's right . . . an application for "actual installment of technical investigative and monitoring equipment" that could lead to turbines being in critical whale habitat. The proponent is SRM Projects Ltd of Nanaimo, B.C.
While I of course support initiatives to reduce the use of climate-changing fossil fuels, to have turbines in critical whale habitat would be pure, simple, total, utter insanity. No matter how advanced the turbine technology, no amount of mitigation could compensate for the noise, prey reduction, and other disturbance to the whales.
The first deadline for your comment on this application is November 14th. Below, I have strived to make commenting very expeditious for you, but first, a bit more on how preposterous the application is, jut to fuel you up for those comments.
Here is the map showing the area for the "license of occupation".

Source: Application by for OCEAN ENERGY/INVESTIGATIVE AND MONITORING by SRM Projects Ltd of Nanaimo, B.C.  Click image to enlarge.
Here is the map showing the application site relative to the critical habitat map for northern resident killer whales from the Final Amended Recovery Strategy for Northern and Southern Resident Killer Whales in Canada. [Why was it amended you might ask? Because the federal government had to be taken to court TWICE to enforce their legal obligation to protect killer whale habitat (first ruling December 7, 2010; appeal ruling February 9th, 2012).]

Proposed site (red) relative to acknowledged northern resident killer whale critical habitat (cross hatched area). Source Amended Recovery Strategy for Northern and Southern Resident Killer Whales in Canada. Click image to enlarge.
The very ocean current that makes this area of interest for staking a claim for ocean energy is what makes this such a rich area for marine life. Multiple currents collide causing a merry-go-round in which plankton and fish are concentrated. The threatened northern resident killer whales feed here with great regularity as do members of the threatened population of humpback whales, Steller sea lions, Dalls porpoise, etc.
The importance of this area for killer whales can be supported by almost 4 decades of data collected by Department of Fisheries and Oceans and the OrcaLab. More recently, with regard to the humpbacks, I and my fellow researchers from the Marine Education and Research Society can testify to how often these giants are in this area.
But it is the whales that speak with the most convincing voices of all. Here is the OrcaLab's September 16th, 2012 visual and acoustic recording of the I15 and A30 matrilines of northern resident killer whales in the very area "in question".
For researchers, whale watchers and on-line followers of the OrcaLab's monitoring of whales, we all know that this kind of activity is not exceptional in this area and we know what is at stake.
As final telling testimony to how often there are whales in this area, note where, of all the places the OrcaLab could have put their whale-monitoring cameras and hydrophones, they are positioned. Then again, note the location of the proposed ocean power project.

Proposed site (red) relative to positions of the OrcaLab, and their hydrophones and cameras. Testimony to just how often there are whales here. Click image to enlarge.
One would hope that government agencies would surely deny this application but  . . . we have so many recent examples of this being tragically misplaced faith and we cannot count on there being any legislation in place for sound environmental assessment that would confirm environmental impacts. May I point out again that the government had to be taken to court TWICE to be order to acknowledge and protect killer whale critical habitat?!
Therefore, we collectively need to make our "Hell No!" heard now.
Action needed:
  1. Essential: By November 14th, click this link, go to the bottom of the page, and comment on the project. Sample text below in green.
  2. Essential: By December 2nd, click this link and email your comment to Forests, Lands and Natural Resources Operations. You could use the same text as you did for the above. 
  3. If you can, come to the Port McNeill "community information session" given by the proponent, SRM Projects Ltd of Nanaimo, on November 20th in the Image Room of the Chilton Arena from 6:30 to 7:30 PM. There will also be an information session in Campbell River on November 22nd but this will focus on SRM's proposals for the Discovery Passage and Seymour Narrows. It will be in the Rivercorp Boardroom, 900 Alder Street from 7:00 to 8:30 PM.
  • Sample text for both of the above. "With regard to Land File Number 1412946, the application for SRM Project Ltd's "Investigative License of Occupation - Ocean Power" in the Blackney Passage / Johnstone Strait area, I write you to express that this application must not be granted. This is scientifically confirmed critical habitat for northern resident killer whales and it has been legally ruled that this must be protected as per Canada's Species at Risk Act. In addition, the area is of great importance to humpback whales and many other marine species. No matter how advanced the turbine technology, no amount of mitigation could compensate for the noise, prey reduction, and other disturbance to the whales."  You may even want to reference this blog and provide the link e.g. "For further details of the reasons for my great objection to this application see the rationale and resources provided at"
With this application being so ludicrous, I can't help but wonder if I am missing something. Is this just part of a staking frenzy or is it some sort of distractor so that attention is taken away from something else?
SRM LTD's projects are listed here. Again, reductions to our voracious fossil fuel consumption are very much needed but, at the cost of having turbines in whale critical habitat? Unequivocally - no. 
So much insanity  . . . so little time.  Sigh.
Huge gratitude and respect to Angela Smith for being the one to take note of the notification of this application and to Leah Robinson for ensuring I had many of the details I needed for this blog. 
Includes the following on Investigative Licences (Section 6.1.2)
"A Land Act Section 11 investigative licence of occupation is the form of tenure provided to authorize initial investigation to determine site placement of ocean energy device(s). Investigative licences will be issued for areas not exceeding 50 ha for straits or narrows less than 5 km in width and up to a maximum of 500 ha for offshore areas. Requests for larger areas are at the discretion of the Authorizing Agency. The term for an investigative licence is up to five (5) years at the discretion of the Decision Maker with the possibility of a one-time replacement.
A licence of occupation may be issued to allow monitoring equipment and measuring devices (i.e. buoys, sensors, satellite communication and/or appropriate technology) to evaluate ocean energy resources and to determine site suitability. Multiple devices may be included in a single licence of occupation. For management purposes, the Regional Executive Director may require more than one licence of occupation (e.g. where a significant number of devices are proposed for the same licence area).
A licence of occupation may be issued to a single proponent to install multiple monitoring devices and equipment. A licence of occupation may also be issued to a single entity comprised of one or more developers where multiple users occupy a single investigative area for the purpose of monitoring and gathering wave, tidal and current data.
The Investigative Plan that must accompany application(s) for testing equipment should specify the locations and construction schedules for equipment as well as timing for the collection of monitoring data, and other information reasonably required by the Authorizing Agency. If the equipment is not used diligently, (see Diligent Use requirements in Section 9.6.2) a subsequent tenure will not be granted."
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