Five Minutes: Who Decides?
This "development" is an attack by private, monopoly right on public right
By TONY SEED
Western Region Community Council
Public Hearing, Black Point Fire Hall, 28 November 2005
Case 00640: 7790 St Margarets Bay Road development agreement
(Editor's Note: Due to the five-minute restriction, only the bolded portion of this submission was presented orally. The Western Region Community Council did not ask for a written copy. Revised for publication.)
I am editor and publishing of shunpiking magazine, president of New Media Services Inc., and a longtime resident of Spryfield. St. Margarets Bay is a strong base of our readers and contributors whom are deeply concerned about this project. As a socially responsible publication, it behooves us to respond to the concerns of our readers, which are our concerns. This issue of "development" in Ingramport affects all of us, the people of the entire Halifax Regional Municipality and the entire province. In fact two of the three members of the Western Region Community Council who are deciding the fate of Case 00640 do not represent this area. This "development" is an attack by private interest on public right. It is thus being confronted and opposed by the broad public, as the hundreds of people gathered here tonight demonstrate. Not only are there serious flaws in the environmental reports from the Department of Fisheries and Oceans and Jacques Whitford, there are fundamental flaws in the political process. It is this question I will address.
1. The 7790 St Margarets Bay Road development agreement (Case 00640) embodies a social and political vision of development. The implementation of this gated community with its 31-slip marina, 370-foot artificial breakwater on crown land breaking up the estuary and bay, former restaurant-lounge and 17 condos (in the $400,000-$600,000 price range according to one estimate) not only will degrade the entire bay, watershed and environment, it will displace one class of people who use St Margaret's Bay, the residents, the families, the producing, professional and recreational fishermen, the recreational scuba divers, and the public, with another, smaller and wealthy class of people who will control access. Displacement of traditional residents and their families is a trend throughout the HRM.
What is being proposed is not development but wrecking, not progress but retrogression, not community but smashing the fabric of community, not providing "summer jobs" at a marina but destroying what little remains of a productive fishery and the value created by the fishermen. This is an irrevocable loss to the social economy and cultural and natural environment. Wrecking of this size and style will eventually drag down the South Shore and its islands, and replace it with Florida-style condo clavens and ocean infrastructure to the mid- and inter-tidal line, with potentially severe consequences to inter-related coastal erosion, the ecologically-sensitive estauaries and water tables, all of which assist in providing protection from such natural disasters as hurricanes. The gentrification of Rte. 3 based on the outmoded car culture is a serious concern. It gives new meaning to the HRM slogan, "Love the way we live", and HRM policy regarding "urban sprawl". It is not fortuitous that the development plan provides for leasing the marina to "non-resident" users. This is the Province's term for absentee landlords and foreign property owners who are permitted to buy up prime coastal property throughout Nova Scotia, drive up the price of land and taxes, and in many bays make it impossible for the next generation to continue living on land which has been in their families for generations. Out-migration, the growth of rural slums and the urban-rural split is a serious concern. Currently, this is occurring in Lunenburg and Inverness counties, amongst others, where indigenous coastal residents now must move inland, in order to purchase a home or property.
2. Breakwaters are at best an endless screw in the ocean, and one never knows when you are done with it. Whether it is the lesson of Hurricane Katrina or the Canso Causeway, by protecting one region of the coast, you directly or indirectly hurt all others, and have therefore to protect them too. By so doing you again damage the area you first protected, and have to compensate it; but this compensation reacts, on all other regions and modes of settlement and livelihood, and entitles them to redress, and so on in infinitum.
The HRM-Destiny/Terrain Development Agreement is silent on this question: who will be held accountable? The developer makes his profit, and moves on, leaving a condominium corporation in their wake. There is no provision by the federal, provincial or muncipal jurisdictions that they have to be bonded to provide for accidents, bankruptcy or future reclamation and environmental mediation. The developer is granted impunity. Citizens refuse this bogus and backward views that developers by property right can act with impunity and that the public should make lasting concessions of public land and services in the name of making their projects viable. The Sobeys monopoly "develop" Westhills but Nova Scotians pay for twinning the 103 Highway. It is the people who will pay the bill for 7990 St Margarets Bay Road. The agreement must be rejected on this basis alone. The "right" of the developer should be restricted.
3. This contempt for public right emanates from the form and content of the political process. "Who Controls the Political Process?" is one of the serious issues being raised by the residents of the Bay. The democratic will of the people, the majority, are not represented in the day to day decisions which affect our lives. A minority seems to decide a process which is carried out behind our backs, behind not only our view but also our control. This has caused great community anxiety and uncertainty for the past 24 months and more.
4. The development plan for 7990 St Margarets Bay Road approved by the HRM does not disclose that both the Terrain Group Inc., which represents Destiny Developments, and Jacques Whitford Environment Ltd., which carried out the questionable "environmental screening assessment" under commission by Destiny for the federal Department of Fisheries and Oceans (DFO) in June 2004, are both part of the Greater Halifax Partnership of the HRM. Terrain Group Inc. is one of just 51 Partners (down payment of $10,000 or more). Jacques Whitford is one of 125 investors (down payment of $5,000 or more). (1) The saying, "He who pays the piper, calls the tune", comes to mind. These insiders in this "public-private model" are given preferred vendor status on projects and advance knowledge of tenders. Then this is called "partnership in action". They actively seek out possible HRM contracts using such contacts to get an inside track. (2)
All the political and business parties involved in this development seem to be involved in a position of significant conflict of interest and their wrecking project must be understood in this context. This should be investigated in depth.
The development agreement also does not disclose that Councillor Reg Rankin is on the Board of Directors of the Greater Halifax Partnership, yet is one of just three councillors of the Western Region Community Council of the Halifax Regional Municipality who decide on the application by Terrain Group Inc., representing Destiny Developments. (3) All three councillors -- Reg Rankin, Gary Meade and Stephen Adams -- are members of HRM committees in whose jurisdiction the Terrain Group Inc. has received contracts, such as solid waste and water. The Terrain Group Inc. website lists the HRM, HRM Planning and the Halifax Regional Water Commission as major clients. It reveals that the Terrain Group Inc. even goes so far as to prepare municipal by-laws. (4) Its corporate logo, "Discover The Terrain Advantage", is suggestive. The Terrain Group lists more than 70 projects on its website, including the Tantallon Market Superstore for Loblaws (one of 12 contracts), the 1,800-acre Westwood Hills development of the Sobeys monopoly (Atlantic Shopping Centres) and the Exit 3 Otter Lake Waste Management Facility in this region alone. (5) Terrain is the funnel.
The common mutual use of such consulting corporations by both developers and the HRM Planning Department, the Halifax Regional Water Commission and other government bodies is a major source of legitimate distrust and non-confidence on the part of the public in environmental assessment justifying HRM development agreements. The objectivity and, indeed, the qualifications of consultants who are equally available to the two primary parties to environmental assessment according to the contract has already been questioned in detail by residents, as may HRM Planning Department's own objectivity in dealing with information and recommendations provided by such corporations.
There is also the suggestion of more conflicts of interest with Jacques Whitford, the multinational engineering end environmental services corporation. (5) Hector Whitford is a HRM Economic Strategy Committee Member and made a presentation to Council 20 September 2005 on the Economic Development Strategy. The HRM stated, in a 17 November 2005 press release: "The Economic Strategy complements (sic) both the proposed Regional Plan and the proposed Cultural Plan, and provides the guidebook for HRM to meet the 'smart growth' criteria of economic growth, environmental sustainability, cultural priorities and social objectives." The Greater Halifax Partnership is a "public-private partnership" that participates in the destructive global competition between cities over corporate relocation, resources and places to exploit. The HRM places the resources of the taxpayers at the disposal of these incoming monopolies to whom such consulting corporations sell their services. Enter Terrain-Whitford-Destiny. Rather than being in contradiction with HRM plans, such a private, high-priced, waterfront development -- the gated community in the rural retreat -- seems to epitomize "smart growth", providing "quality of life" for incoming executives of corporations lured here by our taxdollars, tax writeoffs, subsidized municipal services and job training programs, etc. (6)
Are all these "conflicts of interests" of the business and political insiders what has driven the Terrain-Destiny-Whitford-DFO fraud from the beginning and what is behind the widespread rumours of a secret agenda?
The HRM has no business determining our fate, especially in a process which is carried out behind the backs of the people, beyond not only their view but also their own control. The process of drafting an agreement before public opinion is offered gives the developer an extreme advantage and staff who have invested time preparing the document see the public process only as an opportunity to meet the MGA requirements for a public process and not for true public input.
5. The different levels of government involved in this project make a big show that their approach to development is "rules-based" and that they consult communities about the plans they are to make. This is a charade.
Let us look at that again: "Public involvement in a screening is at the discretion of the responsible authority." Authority triumphs over human rights. The citizens of the Bay including eminent marine scientists submitted their own detailed environmental critique to no avail whatsoever.
6. It is outrageous that the development plan provides for consultation with the community only when recommended. It is outrageous that when a "public hearing" is then actually recommended, residents are not only not provided with the reports justifying the development, but are then limited to a five minute intervention in the "public hearing". Furthermore, according to the city clerk, even this five minute submission can then be interrupted by questions from the HRM Council. We are then told by way of explanation that the five minutes has been upheld by the Nova Scotia Supreme Court. I ask you: how can any serious issue be sorted out in five minutes? This is a travesty. A democratic councillor would say: "you are my constituents, let us sit together until we can thrash this out, no matter how long it takes." Is this form not reminiscent of the Middle Ages, when the peasants went deferentially cap in hand to the feudal lords and masters to plead their grievances? What equality before the law, dignity and humanity does the citizen as a human being have?
7. Citizens come to this "public hearing" with the expectation that the responsibility of both councillors and government is to "serve the social good" and to represent their interests. In exchange for social peace they will be taken care of, the environment will be protected (also known as the precautionary principle), essential services will be provided, and development will be regulated. Now they find that the table has been turned and they have absolutely no say in the matter. They remain deprived of any means of exercising direct control over their government and therefore over the policies and administrative decisions that affect their lives. If people are not sovereign in our society, then the Western Region Community Council, HRM Planing staff, DFO and other agencies of the government are not actually accountable.
Historically, the civic polity was divided between the individual property holder (who came to be known as a ratepayer) and the rest. Those citizens who owned property were defined as the electorate while the majority without property were denied the right to vote. Today, the division is between the monopoly property owner and everyone else.
This "Community Council" can be described as the gatekeeper on a toll highway. It protects the private land developer by law and subordinates the interest of the small property owner to monopoly property owners. It prevents the citizenry from enforcing any authority over public land and such a project. Whether it is through taxes, tolls or imposing "user pay" fees, it profits the developer through providing public land and services gratis. It recognizes only the claims of the developers and their financial bankers on society. It is composed and structured in a way that prevent it from effectively carrying out a mandate of public overview of "development" for the social good. The reason:
(a) that mandate has not come from the people; and
(b) there is no mechanism for the public to hold the private developer accountable and even consider amending or restricting developer right.
The developer holds all the trump cards. The mandate of the WRCC and even of the HRM has been drawn up elsewhere. Only if the Bay residents are directly involved in discussing the mandate of the Western Region Community Council and deciding themselves what type of development they need, and who should decide, can this problem be resolved successfully. Until this is dealt with, the credibility of the HRM will continue to decline, and collusion and lack of accountability will continue to increase. This has serious consequences for the people of Halifax now and for the future. This is the affair of all of us. The problems must be squarely met, discussed and an alternative to wrecking must be found. Let us reverse the trend, towards direct democracy. Such development would be an honourable decision.
8. To advance the situation, I propose a specific, six-point agenda:
A. Since the spring the Bay residents have convened weeky meetings, providing residents with a regular forum though which they are informed about the developments and can discuss what is at stake. They have demonstrated that they are the responsible authority. These should become permanent institutions with the perspective of becoming the sovereign authority.
B. We must act to renew the HRM so that it becomes an instrument of accountability in the service of all the people of Halifax. The role of the Western Region Community Council should be subordinate to the will of the residents expressed through such democratic forums. There is a need to review current MPS (Municipal Planning Strategy) policies to ensure that the policies for public input are being met, staff are not adverse omitting policies , catch me if you can.
C. Citizens should have the right to recall councillors who defy or do not represent the interests of the majority.
D. The impunity the HRM grants private developers must be ended.
E. No concessions to Case 00640: Development Agreement - 7990 St. Margarets Bay Road. Any future development agreement should be negotiated directly with the community.
F. A commission of inquiry be established to investigate the way in which science is being produced and manipulated by these so-called environmental corporations.
Since these views, information and proposals are presented simply in point form, I am at your disposal to expand on them.
We are opposed to this "development" and we should carry this opposition to the end.
Thank you for listening.
1 Investor Directory, http://www.greaterhalifax.com
2 Tenders or RFPs [Requests for Proposals], to wit: "preferred status in requests for proposals for Greater Halifax Partnership projects" and to "participate in the decision making process of initiatives." Investor Benefits, http://www.greaterhalifax.com Private-sector investors are estimated to contribute $1.6 million to the partnership this year alone), a minority of the 2005 budget of $4.57 million. The HRM provides $900,000 annually or 20 per cent. (Back)
3 Councillor Reg Rankin contest this assertion later, saying merely that he had been appointed by the HRM to the Greater Halifax Partnership. After the public hearing concluded, according to a resident, he departed in a car belonging to the Terrain Group Inc. (Back)
4 HRM contracts by the Terrain Group Inc. have included: Bedford Highway Trunk Sanitary Sewer "in conjunction with HRM engineering staff"; Bedford/Sackville Trunk Sewer Study; Burnside Industrial Park Phase 11-1; Camden Street Storm Sewer, Bedford ("Terrain Group planning staff worked with HRM staff to develop a draft development agreement ... and Halifax Regional Water Commission [HRWC] staff'); Cole Harbour Storm Drainage Study; Hammonds Plains Water Booster Station (retained by the Halifax Regional Water Commission); Infrastructure Mapping Projects (HRM and Halifax Regional Water Commission); Lot Grading and Drainage Report ("Terrain Group played a significant role in the preparation of the by-law..."); and Timberlea West Collector, to link Highway No. 3 to Highway 103. (Combined List of Projects, http://www.terraingroup.com/s_ourprojects_combinedlist.html) (Back)
Councillors Reg Rankin and Gary Meade are both members of the HRM Solid Waste Resource Advisory Committee. Terrain Group Inc. has received contracts in this sphere as well. As noted above, Terrain contracted with the HRM for the "Timberlea West Collector, to link Highway No. 3 to Highway 103. According to the company's website, "The creation of the Highway 103 interchange to serve the Otter Lake solid waste facility provided the necessary access to the 100 series highway. A route was selected from the new interchange to Highway No. 3 across a large parcel of land proposed for residential development."
Councillor Stephen Adams is a member of the Halifax Regional Water Commission, from which the Terrain Group has received several contracts, as noted above. (Back)
In her submission "Phenomenal number of conflicts of interest" resident Anne Dunsworth underlines the cosy relationship between HRM and the Terrain Group: "Even the HRM planning department is engaged -- Terrain Group and HRM were even two sponsors for Atlantic Planners Institute's 2003 Conference with thanks to Barry Zwicker, who happens to be treasurer of Terrain Group and is well-known to HRM.'
According to an Industry Canada website, the Terrain Group Inc. (Alternate Name: Paragon Land Sciences Group Inc.), an engineering, surveying, and planning related firm with a staff of 80, has annual sales of $1,000,000 to $4,999,999, which is hard to believe. It was founded through a merger of Wallace Macdonald and Lively, Ltd. of Bedford and Key Surveys & Engineering Limited of Moncton. (Back)
4 The development agreement does not disclose that Terrain Group Inc. provided services to the fiercely-contested (for eight years, 1998-2005) 350-acre, 870-home, three-apartment builing Governor's Brook on an environmentally sensitive ecoystem between Colpitt Lake and the McIntosh Run in Spryfield by the Armoyan Group (Kimberley Lloyd) and Terrain Group Inc. (Armoyan was also involved in the development of two P3 schools in the Western region, amongst others.) The area had been reviewed as a potential candidate for protection under Nova Scotia's Special Places Act. This is the constituency of HRM Councillor Stephen Adams (Spryfield-Herring Cove), also a member of the Western Region Community Council and chairman of the public hearing. Adams facilitated this development as a member of the Chebucto Community Council which approved it January 2005 despite it being under appeal. One of the central issues which arose during the course of the "public hearing" which led the Williams Lake Conservancy Company to challenge it was that citizens had not received a fair hearing, including the restriction of submissions to five minutes, lack of adequate notice, etc.
The role of such "planning" companies in undermining the political proces is completely overlooked. They manipulate democracy in the direction of the developer's interests, and are quietly but deeply involved in essentially every aspect of preparing development agreements with the HRM, especially "refining" unfavourable communities. They are described throughout much of the HRM as either helpful, meddlesome, or downright subversive, depending on who you ask. The Terrain Group website frankly speaks of its astroturf role, known as greenwashing, as follows: "Concept plans were developed in consultation with the client and HRM staff. Meetings were held with resident groups and the general public to gather public input in refining the concepts.' (McIntosh Run Development, htttp://www.terraingroup.com/s_projects_mcintoshrun.html) That is to say, Terrain specializes in grooming the public for developers in league with HRM staff, and considers the role of the public simply to "refine (the developer's) concepts". An analogy is the role big public relations firms play with focus groups and creating front groups, advance polling and exit polling for elections, etc. In this case, the Armoyan Group ultimately advanced $50,000 to the environmental group which then withdrew a legal challenge to the Nova Scotia Supreme Court. In other words, Armoyan has come full circle from simply cutting down the trees regardless of community opinion and consequences to becoming actively engaged in cultivating non-government organizations, something called the astroturf strategy. A similar approach was taken regarding environmental opposition to a Hemlock Ravine development. (Back)
5 The website of the Greater Halifax Partnership extols: "Many Atlantic Canadians can work in an urban environment yet live in a rural area, resulting in an enhancement in the quality of life." This is quoted from a full-page article entitled "N.S.'s urban-rural connection," sponsored by the Parternship and published on 10 May 2004 by the Chronicle Herald. The Halifax Herald Ltd. -- along with other major media such as Global TV, CTV, Toronto Globe and Mail, Progress Magazine, Atlantic Business, The CCL Group,and Metro Radio Group -- is an investor in the Greater Halifax Partnership. Neville Gilfoy, President and Publisher, Progress Corp., was chairman (as of year-end, 2004). (Back)
5 Additional Whitford conflict of interest. The Environmental Screening Assessment was commissioned by Destiny Developments from Jacques Whitford Environment Ltd. for the federal Department of Fisheries and Oceans (DFO), specifically to address the HADD (harmful alteration, disruption or destruction of fish habitat) which was to result from the construction of the marina and housing complex, which Destiny wants to build at the mouth of St. Margarets Bay's Ingram River estuary. The authors of a detailed review of the document entitled "Environmental Screening Assessment: June 2004 by Jacques Whitford for Destiny" state:
"The ESA purports to be objective and scientific though it appears often to be more of a promotional tool for the unproven proprietary technology developed by its authors. In reference to the damage to lobster habitat in the estuary, for example, the ESA states, 'A new concept in lobster shelters has been developed by Jacques Whitford to imitate this habitat.' In documents just recently secured by residents after considerable effort through the Freedom of Information Act, details of the HADD compensation approved by the DFO have now come to light. The approved compensation relies totally on the installation of the Jacques Whitford shelters. As stated above, both the scientific credibility of the ESA and the ethics of the regulatory body, the DFO, which based its decision on the report could be called into question." (Review of Environmental Screening Assessment: June 2004 by Jacques Whitford for Destiny Developments, Michelle Adams, Dr. Paul F. Brodie, Dr. Sue Douglas, James Fryday, Dr. Phil Warman. Available on this website)
Based on the ESA, the DFO approved the Destiny/Jacques Whitford HADD compensation proposal.
The record of Jacques Whitford Ltd. is hardly green. In very brief:
A. It fronted the notorious plan of Bennett Environmental Inc. for a toxic soil incinerator from US military sites in Belledune, NB, providing a private impact assessment in lieu of a provincial Environmental Impact Assessment in 2003. ("Turning an Incinerator into a Teddy Bear", Asaf Rashid, June 2004)
B. Jacques Whitford is also implicated in a $759 million class action suit by Port Colborne, ON residents in 2001 against Inco based in large part due to exposure to nickel oxide, a high risk Group One carcinogen. Residents alleged that INCO and its consultants such as Jacques Whitford suppressed knowledge of the carcinogen. INCO (along with Falconbridge) is a founding patron ($25,000+) of the Assoc of Professional Geoscientists of Ontario Start-Up Fund; Whitford is also a contributor. That year (2001) Whitford, though based in Halifax, made three contributions to the governing Ontario Conservative Party.
C. On Jacques Whitford`s role in Newfoundland and Labrador - "the Voisey's Bay mine/mill panel review; the industry road show set in motion as part of the comprehensive study process for the Argentia smelter and refinery; and the clean-up of the Long Harbour phosphorous plant (preparatory to its projected use as an incinerator site to burn municipal waste imported from the U.S.)" see: http:/www.ceaa-acee.gc.ca/013/001/0002/0004/0001/whalen_e.htm (Back)
Councillor Stone referred to the two Public Information Meetings held and asked if staff had considered the concerns from the public and addressed them. In reply, Mr. Porter advised most of them were addressed in the Staff Report and the Information Report which included detail with regard to the Rotary and school overcrowding. He understood there was a commitment to have students from the new Beechville development bused to Mainland South. This particular development would probably develop at the rate of 50 homes per year.
9. PUBLIC HEARING
9.1 Case 7556 - Rezoning of Approximately 156 Acres of Land Owned by Midyat Investments Limited between McIntosh Run and Colpitt Lake in the Mainland South Area of Halifax
A Staff Report dated February 11, 1998 was before Community Council together with an Information Report dated February 27, 1998.
9. PUBLIC HEARING
9.1 Case 7556 - Rezoning of Approximately 156 Acres of Land Owned by Midyat Investments Limited between McIntosh Run and Colpitt Lake in the Mainland South Area of Halifax
A Staff Report dated February 11, 1998 was before Community Council together with an Information Report dated February 27, 1998.
Presentation by Applicant
Mr. Barry Zwicker, Wallace Macdonald & Lively, on behalf of the applicant, advised that since Spring, 1996 they had met and talked with people and interest groups in the area to determine if there were specific concerns that should be addressed in the early stages of the development. From those meetings and from input from the Public Information Meetings, it was felt that the majority of the concerns had been incorporated into the design of the project. The project occupies 156 acres, 80 acres for residential purposes, 53 acres for park and open space and 23 acres for roads. Whereas the requirement for parkland was normally 5%, it was actually 66% of the land being utilized for residential development, without the area utilized by streets. If the entire area was used as a percentage, then 34% of the total area was being dedicated as parkland. There would be 509 single family homes, ranging in lot sizes from 32' in width to excess of 50', 58 lots for semi-detached, 74 townhouse units in two clusters and three apartment buildings, for a total of 843 units. It could take, in an optimistic market, 15-20 years for the project to be fully built.
The ESA purports to be objective and scientific though it appears often to be more of a promotional tool for the unproven proprietary technology developed by its authors.
In reference to the damage to lobster habitat in the estuary, for example, the ESA states, "A new concept in lobster shelters has been developed by Jacques Whitford to imitate this habitat." In documents just recently secured by residents after considerable effort through the Freedom of Information Act, details of the HADD compensation approved by the DFO have now come to light. The approved compensation relies totally on the installation of the Jacques Whitford shelters. As stated above, both the scientific credibility of the ESA and the ethics of the regulatory body, the DFO, which based its decision on the report could be called into question.
The proposed compensation is still experimental. The report states "718.5 m2 must be compensated." If that is the case, how can 40 lobster houses that have an approximate surface area of 1sq metre compensate for 720 m2 of lost habitat?
In addition, if it is going to take three years to determine if the habitat compensation is actually going to work, then the project should be trialed elsewhere until the success of these lobster houses has been demonstrated. If the compensation plan fails, the decision to permit the breakwater cannot be reversed if it has already been constructed.
The proposal demands either scientific demonstration of the success of this plan, or the project waits for three years of monitoring before re-evaluating. The lobster habitat near Wallace, Nova Scotia has already experienced loss through infill with great expense and a diversion of DFO field effort to experiment with a habitat rebuild (Chronicle Herald, June 11/05). depletion, habitat destruction, and pollution, no matter what the management framework.
Attached please find a detailed review of a document entitled "Environmental Screening Assessment: June 2004 by Jacques Whitford for Destiny Developments" (the ESA). The ESA was commissioned by Destiny from Jacques Whitford Environment Ltd. for the federal Department of Fisheries and Oceans (DFO), the responsible authority, specifically to address the HADD (harmful alteration, disruption or destruction of fish habitat) which was to result from the construction of a marina and housing complex, which Destiny wants to build at the mouth of St. Margarets Bay's Ingram River estuary. Based on the ESA, the DFO eventually approved the Destiny/Jacques Whitford HADD compensation proposal.
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