Sackville announces plans to scrap its heritage bylaw, but what will replace it?


Megan Mitton

Sackville Councillor Megan Mitton caught many observers by surprise last week when she announced that the town plans to repeal the heritage bylaw it first passed in 2010.

Scrapping the bylaw would mean dissolving the Heritage Board and eliminating two designated conservation areas in parts of downtown. It means that property owners in those areas on Bridge Street, Main Street and York Street would no longer have to apply for a heritage permit if they want to alter the appearance of their properties or demolish a building.

Mitton read a report signed by town manager Jamie Burke. It said the decision came after a comprehensive five month review during which council concluded the bylaw wasn’t working.

“The point has been raised that the bylaw is achieving very little in terms of heritage conservation and preservation,” Mitton said, “the bylaw focuses more on the appearance of the streetscape as opposed to traditional heritage regulation.”

She said that over the last year, there have been no heritage permits issued and only one $5,000 heritage grant was awarded in the last two years.

Mitton also said it has been difficult recruiting volunteers to serve on the Heritage Board, an indirect reference to the turmoil that began after JN Lafford Realty Inc. applied for a permit to demolish the Sackville United Church in August 2014.

Several members of the Heritage Board resigned in the following months citing town interference in its decisions while council later fired Louis Béliveau, another member who challenged his dismissal in costly court fights that went all the way to the Supreme Court of Canada before a settlement was finally reached.

Mitton’s report vaguely suggested the town focus instead on assisting the redevelopment, appearance and maintenance of heritage properties while continuing to support the Tantramar Heritage Trust.

Council passed a resolution setting June 11th as the date for a public hearing on the matter.

Dismay

Warktimes reached out to several prominent townsfolk, some of whom, such as former Councillor Merrill Fullerton were involved in crafting, passing and implementing the bylaw in 2010. Their general reaction could be summed up as one of concern and even dismay.

Fullerton wondered if scrapping the bylaw means a return to the “wild, wild west” of development with no heritage guidelines.

“The bylaw wasn’t perfect,” he said, “but it was a good starting point.”

He added that the Heritage Board provided useful guidelines for property owners and that the original intent was to demonstrate the bylaw’s worth in preserving the town’s character and then later, apply it to the historic buildings at Mount Allison.

“The bylaw wasn’t working because they didn’t make it work,” former councillor Virgil Hammock said bluntly during an interview.

Another prominent citizen said, “I’m very sorry to see it (the bylaw) go. My hope would be that they would introduce a new bylaw, one with more teeth in it.”

Others also said the bylaw, which was amended in 2016, was weak and even meaningless.

For his part, Mayor Higham gave this elliptical answer when asked why council wants to scrap the heritage bylaw and all that goes with it:

“I think that there’s been frustration with how it’s been operationalized for quite some time,” Higham said. “And when we started to look at the review in the last five, six months, we were finding out that there had actually been no permits issued at all and that, in essence, when we really drilled into it, the intent of the original bylaw was simply one of an appearance as opposed to a true heritage bylaw that would dive into more than just a streetscape appearance. So, we were frustrated over the history of how it had been done, but also understanding that it was actually achieving its original objective, which was a simply very shallow heritage interpretation. So, it didn’t seem to us that this was doing much good, quite frankly and we looked at what some of the other options would be at this point and suggest that the town’s better off if we were to take an opportunity, actually we heard today one of the speakers in the presentations said that we don’t invest in heritage. They’re right, we didn’t give out very many grants, so we’re now thinking that maybe that’s a more appropriate way for the town to support the type of heritage that we’ve been talking about at this point.”

Posted in Sackville United Church, Town of Sackville | Tagged , , , | 3 Comments

Sackville councillors hear passionate debate on pros and cons of luxury apartments

Erna Duchemin spoke against rezoning the property

Sackville Town Council heard a sometimes-passionate, 54-minute debate last night on the pros and cons of building 36 luxury, seniors’ apartments on part of the former United Church property in the heart of the downtown business district.

After nine citizens had spoken against the proposed three-storey building and five, including developer John Lafford, had spoken in favour, council gave preliminary approval to a bylaw change that would make the project possible.

However, construction cannot go ahead until council gives its final approval in two more votes expected next month. Deputy Mayor Ron Aiken and Councillor Allison Butcher said they needed time to consider the comments they heard during last night’s public hearing. Councillor Bruce Phinney, who has said previously he would vote against the new apartment building, was not present at the public hearing.

Emotional debate

Erna Duchemin led off the debate saying that even though the new apartment building would generate tax revenues for the town and the province, it would also destroy the beauty and serenity of the green space near the Centennial Monuments and Swan Pond off East Main Street.

“We need to look ahead and think of the worries this building will cause such as accidents and problems with traffic flow and how it will affect the beauty that our tourists and we enjoy now,” she said. “Why lose this green space and the grove of birch trees for a huge structure that destroys the view for us all?”

Meredith Fisher

Meredith Fisher, who campaigned along with Erna Duchemin to save the United Church, recalled the bitter divisions that occurred before the church was demolished in September 2015.

“Those feelings still linger on. We don’t want our town to be divisive,” she said.

She argued that it’s important to preserve the sweep of green space that was designed and paid for by Sackville’s forefathers and that still makes the town special.

“This is what attracts people to want to live here, to visit here, to want to stay here, to work here or to send their children to school and study here,” Fisher said. “I just can’t imagine how a community would support the decimation of this beautiful, iconic, signature space in our town.”

 Change happens

Eric Tusz-King told the hearing that as a member of the United Church congregation, he negotiated with the Laffords when they bought the church property in 2012.

Eric Tusz-King

“We went through a lot of grief and there was a lot of emotion in our congregation on that issue,” he said. “But we realized that nothing stays the same and we needed to move on and I think that’s a little bit of what needs to happen in this conversation as well.”

Tusz-King added that while he has a strong attachment to the birch trees that would be destroyed if the new apartments are built, he also realizes they will die naturally within the next 15 years and besides, the land is going to be developed anyway.

“The zoning is only for a portion of that land that’s going to be used,” he said. “They [the Laffords] can still use the other part of the land for another…building and the birches would be gone…so, again that’s not a particularly good argument.”

Tusz-King said he uses the Lafford parking lot at Main and York Streets every day and while he acknowledged it’s busy, he doesn’t mind that.

“I like people, I don’t like living in isolation, I don’t get worried by that,” he said adding that the area is not nearly as dense as it is in larger cities such as Halifax or Toronto.

“So I would recommend personally that council go ahead with this approval,” Tusz-King concluded. “There’s not enough justifiable reasons not to go ahead.”

Tenants and landlords

Ardyth Rose identified herself as a tenant in a Lafford building on Waterfowl Lane and called the Laffords wonderful landlords. She supported the new building saying that the more seniors’ apartments Sackville has, the better.

John Lafford

Wayne Harper told the hearing that he wants to rent one of the luxury apartments adding that it would provide beautiful views for its tenants, attract more people to Sackville and add to the town’s tax base.

When his turn came, John Lafford said he’s been hearing from a lot of people who are excited about the new building and although a few are opposed to it, there are many in favour.

“What we say, we’ll do,” Lafford said. “Yes, we’re going to cut those trees, a good portion, yes. But we will replant as many as are cut and that is a pledge,” he added telling council, “And if that site can’t fit all those trees that we take down, then we will plant them at other locations designated by you people.”

Lost beauty

Tim Reiffenstein, a geography professor at Mount Allison, questioned the planning department’s reliance on figures more than a decade old when it says the town needs more density in downtown residential neighbourhoods. He also said he’s concerned that the new building would add more traffic to the downtown area.

Susan Dales

“When I’m downtown, I’m mainly on foot and the only places I’ve ever been in fear for my life, the only place I’ve ever been hit is walking by the exit of that parking lot on York Street,” Reiffenstein said.

Susan Dales, who said she moved to Sackville from Mississauga, Ontario, estimated that the new building would probably have about 65 people living in it.

“To provide housing for these 65 individuals,” she said, “is it worth losing all the surrounding beauty and putting it at risk? I don’t think so, beauty is so hard to find and beauty is what makes Sackville, Sackville.”

After the public hearing, Councillor Bill Evans moved first reading to send the requested bylaw change to the next stage. He said it didn’t necessarily mean he would vote for the project on second and third readings, but he also made it clear that council should not be passing judgment on the new apartment building itself only on whether it conforms to the town’s existing bylaws.

“When people buy private property, it’s their property and they get to make decisions,” Evans said. “All they have to do is follow the rules,” he added.

“I’m not making a statement about what I like or don’t like, I’m doing my job.”

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More pavement, fewer trees around luxury downtown apartments

Information compiled by Sackville resident Sharon Hicks and confirmed by town planner Lori Bickford shows the proposed luxury apartment building in the heart of downtown would have fewer trees around it and more above-ground parking behind it than I have previously reported.

The V-shaped building would be constructed in an area that now has a number of birch trees on it and it appears from the site plan that there would not be much space to plant replacements.

As the diagram below shows, the land that would need to be rezoned to permit the high-density residential development is large enough to contain about half of the new building overlooking Main Street plus a fairly large area around it. Previous reporting indicated that rezoning would be required on a much smaller parcel.

Rezoning area outlined in red includes at least half of the proposed new V-shaped apartment building next to the Monuments area. Additional above-ground parking is proposed in the yellowed area behind the building. Entrance to the underground parking is indicated by arrows at the top centre — diagram courtesy of Sharon Hicks. (click to enlarge)

According to Lori Bickford, JN Lafford Realty Inc. is now proposing to construct a three-storey, peaked-roof building with up to 36, two-bedroom apartments. She says plans call for six, 960-square foot units with the remainder between 1100 and 1300 square feet. The building would cater to well-off tenants over 55. The number of apartments will depend on how much underground parking the Laffords can build on the site, which is part of the former Sackville United Church property.

The building would border on the Monuments property leased to the town by the Laffords. It would also be closer to Main Street than previously reported with one end of it approximately 33 feet from the paved part of the street. Bickford explained that town bylaws require downtown buildings to be fairly close to the street.

Current plans call for the building to be 30 feet from the property line of the old Methodist cemetery and about 55 feet from the nearest grave.

Approval process

In April, Sackville Town Council approved a resolution calling for a public hearing on the proposal. That hearing is set for tomorrow, Tuesday, May 15 at 7 p.m.

In order for the rezoning to be approved, it would need to pass three readings during at least two separate council meetings.

It remains to be seen whether council will consider first reading after tomorrow’s public hearing or whether the rezoning application will be put off until later.

Diagram showing traffic flows in the parking lots off York and Main Streets — courtesy Sharon Hicks

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Town Council to hear about luxury apartments and quarry park when it meets Tuesday

Artist’s conception of the proposed Lafford apartment building on the hill overlooking Main St.

Sackville Town Council will hear about two controversial issues at its next meeting on Tuesday, May 15th.

Council has scheduled a formal public hearing on the proposal from local developer JN Lafford Reality Inc. to build a $6 million luxury apartment building on the former United Church property at Main and York Streets.

And, corporate manager Jamie Burke is expected to brief councillors on why the town failed to get a $1 million grant to create a much sought-after wilderness park in Sackville’s old Pickard quarry.

Old church, fresh wounds

The historic Sackville United Church was demolished in September 2015 in spite of persistent efforts by a community group to save it. In a last ditch effort to rescue at least some of the building, the group says it offered JN Lafford Realty Inc. $175,000 to leave the outer walls standing with their four-metre stained glass windows intact. The idea was to preserve the overall appearance and streetscape in the heart of downtown Sackville while leaving the Laffords free to build inside the old church.

The new apartment building would be about the same size as the one at 23 York St.

But the Laffords said that by then, the building was too far-gone to save.

Today, the property where the church stood has two new commercial/ residential buildings, one at 112 Main Street which houses Service New Brunswick and another, larger building at 23 York Street.

Government records show that the property is assessed at more than $5.3 million with municipal taxes this year amounting to $168,386.65.

Rooms with a view

Now, the Laffords are proposing to build a four-storey seniors’ apartment building with up to 36, two-bedroom units on the part of the property that overlooks the Mount Allison campus, the swan pond and the Sackville Waterfowl Park.

John Lafford says the apartments would be at least 1,250 square feet with monthly rents ranging between $1,450 and $1,700.

During an interview in March, he pointed to the benefits from an upscale building that would attract well-heeled, older people to Sackville.

“I think that’s a win-win for myself as a developer…I think for the town it’s wonderful, it gives them a tax base…and I think the provincial government also gets a nice chunk of the success of my buildings.”

Rezoning needed

To make their plans work, however, the Laffords need the rezoning of a small parcel of land behind the old Methodist cemetery to permit construction of a high-density residential building with underground parking. Without the rezoning, they say they could still put up a cheaper building for student tenants with above-ground parking.

Lafford says the rezoning would allow them to position the building in a way that would make it more attractive.

Joe (L) and John Lafford on the site of the proposed apartment building

“The reason why we’re asking for a little piece that is already [zoned] institutional is just to make our development look more complete and be able to keep a little more greenery, more trees,” he says.

He acknowledges that birch trees would need to be removed during construction, but says the company intends to replace them because upscale tenants want greenery.

“It’s not to our advantage to have a bunch of pavement around the building,” he says.

Support from council

When the rezoning request first came before town council last month, Councillors Bill Evans, Megan Mitton and Joyce O’Neil spoke in favour of the new building. Evans pointed out that when the Laffords bought the United Church land in 2012, town council decided then to rezone most of it as mixed use, but wasn’t sure of the boundaries, so it was just a “fluke” that a small part remained institutional.

Councillor Bruce Phinney voted against the new luxury apartments

Council decided to set May 15th as the date for a public hearing on the rezoning request with only Councillor Bruce Phinney voting against. He said the new building would add to traffic congestion in the parking lot that has entrances and exits off Main and York Streets.

Under the Lafford proposal, tenants in the new building would travel through the lot to get to their underground parking spots.

“I go there quite often,” Phinney said. “I have people telling me they won’t drive to go to Service New Brunswick because there’s no place to park down that way,” he added.

“I look at the fact, actually even myself going in and out of there, it’s dangerous.”

Heated public hearing?

Meantime, Warktimes has been hearing from people echoing Phinney’s worries about traffic congestion and safety.

In addition, some are expressing concern about the loss of more green space and trees in the heart of downtown.

It appears too that the demolition of the old church still rankles while some have commented that the town should worry more about the housing needs of the local elderly with limited means rather than about catering to well-off seniors from out of town.

If those opposed to the new apartment building participate in Tuesday’s public hearing, things could get hot, but at this point, there’s no way of knowing.

Quarry issue

For awhile last week, it looked like councillors would also be hearing from fervent supporters of a new park in Sackville’s old Pickard quarry, now that the town’s application for a $1 million grant to build it has fallen through.

Old Pickard quarry near the Mt. A. campus

The Tantramar Outdoor Club e-mailed members urging them to attend the council meeting to show their continuing support for a wilderness park at the end of Quarry Lane.

But the club rescinded the call after learning that councillors aren’t likely to discuss the matter until a later date. However, council is expected to hear from manager Jamie Burke about why the Federation of Canadian Municipalities (FCM) denied the grant.

The FCM administers the money on behalf of the federal government under a municipal Climate Innovation Fund.

Sackville pitched the park project along with a proposal to build a water retention system in the quarry to restrict the flow of storm water down to Lorne Street during heavy rains.

The town had allocated capital spending of $200,000 this year to go with the anticipated million dollar FCM grant.

Meanwhile, the outdoor club is offering to lend the town one dollar to purchase the quarry from Mount Allison so that it can begin working on park trails.

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Sackville’s former Moloney plant officially re-opens under new Ontario-based owner Cam Tran

 

Cam Tran President Kyle Campbell (Centre) prepares to cut ceremonial red ribbon with Sackville Mayor John Higham (L) and MLA Bernard LeBlanc

Sackville’s Cam Tran electrical transformer plant officially opened today as company president Kyle Campbell cut the ceremonial red ribbon assisted by Mayor John Higham and MLA Bernard LeBlanc.

“This shop is already going,” Campbell told reporters pointing to big spools of gold-coloured, wire coils being manufactured for Hydro One, the Ontario electrical utility that sustained extensive damage to its transformers during a recent ice and wind storm.

“They’ve already shipped 300 coils,” Campbell added, “so, this plant is up and running.”

He noted earlier during a speech that while the plant wasn’t operating during the official opening ceremonies, it would be back to business first thing next week.

“Monday, we get at it,” he said drawing laughter when he added, “Everybody’s on profit sharing, so they’re quite excited to get at it.”

More jobs?

Campbell said that so far, Cam Tran has hired 17 skilled employees all of whom worked at the former Moloney plant. When the plant closed in 2016, 60 Moloney workers lost their jobs.

Campbell said that over the next five years, Cam Tran hopes to increase the plant’s workforce to between 50 and 65 workers manufacturing, repairing and renewing energy-efficient transformers for electrical utilities in the Caribbean and Atlantic Canada.

“We’re already starting to build those for Jamaica,” he said, “and then, the hope is eventually that the local utilities will give us a shot to earn their orders and business.”

He added that the work his company is already doing for Newfoundland and Labrador Hydro will be moved here from its Ontario plant near Peterborough. Cam Tran (an abbreviation of Campbell and Transformer) is a family-owned company that also has plants in British Columbia and Alberta.

“This [Sackville] plant will build any pole-mount transformers that go into this market and into the Caribbean,” he said adding that the 36,000 sq. ft. plant will also be used to manufacture replacement equipment for utilities facing emergencies.

Cam Tran workers listen as Kyle Campbell speaks

NB chips in 

Liberal MLA Bernard LeBlanc announced that Opportunities New Brunswick is contributing up to $115,000 to help Cam Tran renovate the plant and purchase equipment. The Crown Corporation’s contribution is contingent on the company investing $575,000 on eligible capital expenditures, including equipment, land and renovations.

Meantime, Mayor Higham said the plant re-opening means a lot to him because it was his highest priority after being elected almost two years ago.

“It’s taken longer than I’d hoped,” he said. “The beauty of this location was the people who were working here, extremely skilled individuals that had the skills to bring this back to life.”

Higham added there were many barriers, including legal complications, that he and town staff had to help the company overcome.

“[It was] long, arduous, we had a couple of really bad days when we thought we’d lost it,” he said, adding that while it wasn’t legal for the town to contribute financially, “we did all we could in the communication, lobbying and advocacy areas.”

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Town Engineer: Sackville ‘lucky’ to avoid spring flooding

Town Engineer Dwayne Acton

Town Engineer Dwayne Acton says that although the new storm drainage system installed under Lorne Street worked well during heavy rains this spring, Sackville was still lucky to escape flooding.

“We were a bit nervous because some of the rains we had, the water was right at the top of those ditches,” Acton said referring to ditches on the east side of Lorne Street.

During an interview after last night’s Town Council meeting, Acton said about 50 to 75 millimetres of rain fell in town during recent downpours.

“When we get over 100 millimetres of rain in a short period of time, we would be in trouble down on Lorne Street,” he said.

“The (new) system did work well, it got the water through Lorne to the major drainage ditch on the back side of Lorne, but we really need to push through with Phase II so that we have more area to store the volume of water…and then get it out to a new constructed aboiteau.”

Phase I of the flood control project, which cost $5.9 million, included the reconstruction of Lorne Street as well as replacement of water, sewer lines and storm drainage systems.

Phase II, which will cost $2.9 million, involves building two large ponds to receive water that runs down to Lorne Street from the old quarry and other elevated areas during heavy rains.

One pond will be built south of St. James Street and another larger one will be constructed behind the community gardens. The project will also involve building a new aboiteau that would discharge the water from pond number two to the Tantramar River as the tide recedes.

Sign for Phase II of the Lorne St. flood control project

As they did for Phase I, the federal and provincial governments will pay 75 per cent of the cost of Phase II.

Acton says the town received environmental approval for Phase II last week, but will have to delay working on the project until after the bird nesting season ends around September 1.

He says the project should be fully completed by next spring or early summer.

“Phase II is a must to be able to give us areas to store the capacity of water that we need,” he said.

Town audit

At its meeting last night, Sackville Town Council heard that the town ended 2017 with a $51,291 surplus in its General Operating Fund and a $9,330 surplus in its Water and Sewer Utilities Fund.

Auditor Andrew Boudreau also highlighted a significant reduction in debt. He said long-term debt fell by just over a million dollars last year from $14,777,000 in 2016 to $13,750,000 in 2017.

“It’s going in the right direction,” he said. “You did a lot of capital projects this year, there was a lot of money spent, but the debt didn’t go up, it actually went down.”

Treasurer Michael Beal explained that every department exceeded its revenue projections while ending the year either on or under budget. He said this enabled the town to complete its share of Phase I of the Lorne Street project without any borrowing.

Infrastructure funds from the federal and provincial governments also enabled the town to increase the value of its capital assets by more than $4.5 million from $49,142,859 in 2016 to $53,707,666 in 2017.

Town Council is expected to formally approve the audit at its meeting next week. Until then, the full audit will not be made public. To read a summary of highlights compiled by the Treasurer, click here.

Boxing Club

Boxing Club at 203 York Street

Town Planner Lori Bickford told council that the Bob Edgett Memorial Boxing Club has requested the rezoning of its property at 203 York Street near Crossman Road so that it can build a new club that would be slightly larger than its present one which, after more than a half century of use, is beyond repair.

Bickford said the Club lacks bathrooms and storage areas. It can connect to town water lines, but would need to rely on a private sewer system.

The area is currently zoned urban residential and in order for the Club to be rebuilt, the property would need to be rezoned for institutional use.

Bickford said she will be bringing a resolution forward to allow for consideration of the rezoning application at next week’s council meeting.

If council votes to consider the rezoning, the town will schedule a public hearing on the matter.

To read Bob Edgett’s obituary, click here.

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Tidal industry warned to improve monitoring for effects on sea creatures

Darren Porter as seen in a recent Facebook video

A spokesman for the Fundy United Federation fishermen’s group says he’s pleased that government regulators have issued a stern warning to both Cape Sharp Tidal Inc. and the Fundy Ocean Research Centre for Energy (FORCE).

“This warning was needed,” Darren Porter said today during a telephone interview. “I don’t think it’s enough,” he added, “but it’s a start.”

Porter was referring to documents released yesterday from the federal Department of Fisheries and Oceans (DFO) and the Nova Scotia Department of the Environment (NSE) imposing new requirements for environmental monitoring at the FORCE tidal test site near Parrsboro. The monitoring is needed to try to gauge the effects of turbines on fish, marine mammals, lobsters and other sea creatures.

Among other things, government regulators say monitoring devices must be field-tested before another Cape Sharp turbine is deployed at the site, there must be back-up systems in place in case monitoring equipment fails to work properly and monitoring results must be compared with predictions that tidal turbines would have minimal effects when environmental approvals were granted in 2009.

Faulty equipment

The regulators were reacting to Cape Sharp’s acknowledgement that some of its fish and marine mammal monitoring devices did not work properly and others failed to work at all from the date of deployment on November 7, 2016 until April 21, 2017 when the turbine was disconnected from its data cables in preparation for retrieval.

It took the company eight weeks to raise the turbine and during that period, there was no monitoring of its effects on sea creatures.

Government officials and scientists are also requiring FORCE, which oversees the test site, to take responsibility for environmental monitoring near the turbine rather than leaving it up to the company.

While Darren Porter is pleased that government regulators are requiring more reliable and consistent monitoring, he says there are still big gaps because FORCE and Cape Sharp are not being required to measure direct effects on fish and marine mammals.

“They still don’t have to look for collisions,” he says, “they still don’t have to look for mortality (deaths) and they still have no way to determine environmental effects by direct impact of that machine.”

Problems and failures

In its annual report on environmental monitoring during turbine deployment, Cape Sharp includes the following:

  • four hydrophones (underwater microphones) are located on the turbine to detect vocal sounds from marine mammals such as harbour porpoises and whales. Only one of the devices worked properly.
  • acoustic devices called imaging sonars were pointed at the sea floor instead of capturing fish and marine mammal movements in the mid-water column; electrical interference caused interruptions in data transmission to shore-based computers interfering with analysis of the data.
  • a video camera mounted on the turbine was damaged shortly after deployment and failed to record any footage.
  • Two Autonomous Multichannel Acoustic Recorders (AMARs) were mounted on the sea floor to measure noise from the turbine. One AMAR was deployed approximately 100 metres from the turbine and a second AMAR, a control unit, was deployed approximately 680 metres away. So far, the company has been unable to recover the second control unit because of obstacles posed by underwater boulders.

Cape Sharp and FORCE

Both Cape Sharp Tidal Inc. and FORCE say they will comply with the regulators’ requirements.

Cape Sharp says it expects to deploy a second turbine sometime this summer.

I e-mailed both the company and FORCE with a list of questions.

To read Cape Sharp’s response, click here. To read FORCE’s response, click here.

To read the documents from NSE and DFO posted on the FORCE website, click here.

Posted in Tidal Power | Tagged | 2 Comments