Our Proposed Program of Investigation:

We anticipate investigating the extent to which piped natural gas will have an effect on those with environmentally induced illness/chemical sensitivity, on those who may have a tendency to develop it, on those who have allergies and asthma, and on all others; and on the health, social, financial and general well-being impacts of such effects. We expect to evaluate specifically in which situations natural gas would tend to show a high risk-to-benefit ratio and would thus tend to be ill-advised. We also wish to evaluate in which particular situations natural gas may tend to have less risk and more benefit and thus might tend to be more useful.

Some basic studies have already been conducted. We need to evaluate what studies remain to be done and how they would need to be configured in order to be useful. We are eager to discuss with all parties the appropriate ways that our needs can be fully and appropriately realized.

We propose five studies, done on a team based approach:

(2) Evaluation of the Economic Implications of the Proposed Sable Gas Project from the Perspective of Environmentally Induced Illness/Chemical Sensitivity, Asthma and Allergy - [Economic Study].

(3) Review of Provincial and Federal Legislation Regarding Potential Effects of the Proposed Sable Gas Project from the Perspective of Environmentally Induced Illness/Chemical Sensitivity, Asthma and Allergy - [Legal Study].

(4) Review and Evaluation of Alternatives To and Within the Proposed Sable Gas Project from the Perspective of Environmentally Induced Illness/Chemical Sensitivity, Asthma and Allergy - [Alternatives Study].

(5) Conclusions and Recommendations Regarding the Proposed Sable Gas Project from the Perspective of Environmentally Induced Illness/Chemical Sensitivity, Asthma and Allergy, An Executive Summary [Conclusions & Recommendations Report].

The specifics of our five proposed studies are:

(1) Medical-Environmental Study

Our report will also examine the environmentally induced illness, asthma and allergy impact upon animals and plants, both domestic and in "wildlands" arising from pipeline construction and operation, and from interactions with other projects and factors. To our knowledge these have not been considered in the environmental impact assessment report. Basic cost-benefit analyses may be prepared for alternate pipeline routes that minimize potential effects. Attention will be paid to the latest research in hormone disruption effects as well as mutagenic, synergistic and trans-generational effects.

This will include a review of the adequacy of protection, if any, for persons with environmentally induced illness/chemical sensitivity, asthma and allergies in Environmental Management Plans prepared by project proponents for this and other gas pipeline projects. We have requested detailed provisions for those with environmentally induced illness/chemical sensitivity be included within an Environmental Management [protection] Plan (EMP) to be completed prior to the Panel's decision, with adequate time for public scrutiny.

Individuals can be readily tested for hypersensitivity to natural gas. Some AEHA-NS members have undergone this test and have determined they are extremely hypersensitive to natural gas. The intradermal titration neutralization method is used. The Nova Scotia Environmental Health Clinic- Dalhousie at the Victoria General Hospital and Dalhousie University in Halifax presently has the capacity to perform and evaluate the results of such testing. Physicians and patients will be surveyed for relevant information.

(2) Economic Study

(a) direct economic effects;

(b) indirect economic effects;

(c) how various government and non-government organizations (NGOs) have approached the compensation issue for this type of project and related projects that cascade from it;

(d) consequences of end uses of piped natural gas, especially to avoid unfunded liabilities due to unanticipated consequences and inadequacy of contingency funding bonded toward such public protection;

(e) economic valuation of the status quo; and

(f) recommendations to the proponents and the NEB.

(3) Legal Study

The current Nova Scotia legislation, an Act Respecting The Transmission of Oil and Gas, and an Act Respecting Gas Utilities, were passed a decade ago and were intended in light of the Venture Gas Project of Mobil Oil for a pipeline to the US. This project was never approved and never even reached public hearings. In New Brunswick, the project went a bit further before dying. None of the Provincial legislation was ever used, and needs updating. Nova Scotia has been reconsidering its legislation.

Our report will assess the existing Provincial legislation and related federal acts in terms of their suitability for:

(a) the adequacy of protection, specifically from the perspective of environmentally induced illness/chemical sensitivity, asthma and allergy;

(b) the adequacy of environmental protection, specifically dealing with gas pipelines during construction, operations and abandonment;

(c) preparation for provincial government personnel to monitor and to regulate gas pipelines in the long-term after commencement of operations;

(d) the accountability and investigative procedures in the case of accidents; and

(e) the adequacy of present and proposed legislation to protect the public interest in the case of the issuance and renewal of gas distribution licences, most specifically from the perspective of environmentally induced illness/chemical sensitivity, asthma and allergy.

(4) Alternatives Study

This review will examine the various potential uses for the natural gas and its by-products and the variable consequences of the alternatives. This review should include products manufactured from natural gas and gas by-products in all stages of their life-cycle, including;

(a) production,

(b) transportation,

(c) uses, and

(d) disposal.

Some potential natural gas products include, but are not limited to:

(a) fertilizers,

(b) propane, butane and other fuels,

(c) sulphur and/or other minerals,

(d) "natural gas liquids",

(e) pesticides,

(f) plastics, and

(g) other synthetic organic chemicals.

(5) Conclusions & Recommendations Report

This will include a review and evaluation of areas needing further study to fully answer questions that have emerged in this relatively new area of investigation. Consideration will be given to the ways these studies should be configured and undertaken. Areas needing change or further development in order to allow proper protection from the perspective of environmentally induced illness/chemical sensitivity, asthma and allergy will be given close attention.

This publication will constitute an executive summary suitable for wider distribution.

Our proposed activities fit the Terms of Reference of the Panel as set out in the Agreement for a Joint Public Review of the Proposed Sable Gas Project, Schedule I, Appendix I. Our reports and presentations will assist the Panel in its understanding of the factors relating to environmentally induced illness/chemical sensitivity, asthma and allergy. This is an emerging field in which our membership is uniquely able to contribute by virtue of our experience and expertise in the area. In addition, the potential exists for us to be so strongly affected by the outcome of this project that we have a vital stake in ensuring that it be fully and reliably assessed.