The Right Honourable Stephen Harper
Prime Minister of Canada

Monsieur Philippe Couillard
Premier ministre du Québec

The Honourable Gail Shea
Minister of Fisheries and Oceans

Monsieur Laurent Lessard
Ministre des Forêts, de la Faune et des Parcs

Monsieur David Heurtel
Ministre du Développement durable, de l’Environnement et de la Lutte contre les changements climatiques

Dear Sirs and Madame:

The Society for Marine Mammalogy is the world’s largest professional group dedicated to the study of marine mammals, with a membership of approximately 2,000 scientists from 60 countries. Its goal is to facilitate the understanding and conservation of marine mammals and the ecosystems that support them.

The Society is very concerned about the proposed Cacouna Harbour terminal project which involves construction of facilities for the export of crude oil in tankers that would travel into and out of the St. Lawrence River estuary. Cacouna Harbour is near the center of what government scientists have defined as “critical habitat” for a beluga whale population that is listed as Threatened under the Species at Risk Act (Department of Fisheries and Oceans 2012). To be more exact, the site is within one of the few well-defined areas of high residency of female belugas and their young (Lemieux Lefèbvre et al. 2012).

St. Lawrence belugas are the most southerly population in the circumpolar range of this iconic species, which is of particular symbolic and economic importance to Quebec and to Canada. This population has been studied by researchers from Canadian universities, government agencies, and environmental organizations over a longer period of time than any other beluga population in the world. All of this is to Canada’s credit, as is the fact that the St. Lawrence beluga population, which had declined to only a few hundred animals in the 1970s as a result of hunting and environmental degradation, recovered to around 1,000 by the late 1990s.

Unfortunately, it seems that this encouraging example of environmental stewardship is now in jeopardy. Recent research by Department of Fisheries and Oceans (DFO) scientists indicates that the beluga population has been declining slowly since the early 2000s (Department of Fisheries and Oceans 2014). Although the reasons for this change in trend are uncertain, the recent DFO Science Advisory Report (Department of Fisheries and Oceans 2014) notes that it occurred during a period coinciding with increased noise and marine traffic, and also that these animals continue to suffer from high levels of contaminants. The DFO report draws attention to the need to reduce anthropogenic stressors such as disturbance in sensitive areas and during critical periods for female belugas and their calves.

Members of our Society with extensive experience in beluga biology and conservation consider that construction and operation of a tanker terminal in the critical habitat of a small and declining beluga population is incompatible with the aims of the Beluga Recovery Strategy (DFO 2012). Such a project is bound to have serious impacts on the suitability of the area for use by female belugas and their calves. It will further degrade the physical and acoustic environment, increase the risk of ship strikes on belugas, and possibly also reduce the availability of beluga prey; the possibility of a catastrophic oil spill is ever-present. These stresses may well prove to be too much for a population already considered threatened with extinction under Canadian law.

Given the strong scientific capacity at DFO and elsewhere in Canada, I encourage you to take full advantage of these enviable resources as you make decisions concerning this high-risk, controversial proposal. As with any such major project, scientific advice from relevant specialists should be obtained at every stage as part of a transparent consultation process. This advice should apply equally to preparatory work such as geophysical seismic and geotechnical drilling surveys that could have deleterious impacts on the beluga population, as well as to the overall assessment of potential impacts and consideration of alternative sites and mitigation measures.

Please do not hesitate to contact me if you would like further advice from Society members with appropriate technical expertise.

Sincerely,

Helene Marsh
President

Read acknowledgement of receipt and response on behalf of the Premier of Québec received 23 June 2014

Read acknowledgement of receipt and response on behalf of the Office of the Prime Minister of Ottawa received July 11, 2014