<<your name>>
<<today’s date, deadline is December 18, 2013>>
Prince Rupert Gas Transmission Project
Attn: Nathan Braun
Nathan.Braun@gov.bc.ca
<<upload using this link:
http://www.eao.gov.bc.ca/pcp/forms/prince_rupert_gas_form.html
General Comments
The project route is not finalized, and the comment period will close before it is finalized.
How can the public fully comment on a proposed project if its description is not
complete? This seems to be a manifestation of the government’s rush to see the proposed
LNG industry proceed, and does not augur well for careful assessment.
The proponent should be required to post a restoration bond for clean-up and
decommissioning of the project at the end of its serviceable life, or if abandoned. This
bond must be transferred to, and binding upon, any assignee of the proponent.
The proponent must be required to state, by contract, that its pipeline would never be
converted for use to transport bitumen, diluted bitumen, toxic chemicals, or freshwater.
The proponent’s pledge in this regard must be binding on others to whom the
proponent might sell controlling interest in the proposed pipeline.
The proponent and the BC government must assure residents of northern BC than the
pipeline would never be used to enable, via feeder pipelines constructed by third parties,
fracking of the Bowser Basin or other midstream resource. This assurance must be
binding on any assignee of the proposed pipeline.
Traditional access must be maintained to areas that would now involve crossing the
route of the proposed pipeline.
From conversations at its open house in New Hazelton on December 4, 2013, it was clear
that the proponent’s representatives had not read the project description for the
proposed Pacific Northwest LNG, the facility that this proposed pipeline would feed. If
the proponent has not done this as a minimum, it cannot possibly have any grasp, at the
corporate level, of the potential cumulative effects of its proposal.
Specific Comments
1.2 Proposed Project Description
General descriptions of project components will not be sufficient. For example,
compressor station operations must be included in detail, with specific descriptions of
blowdowns, fugitive emissions, turbine emissions, and the potential effects on residents
and the environment.
The project description for Pacific Northwest LNG describes gas treatment for the
removal of contaminants and mercury, yet the proponent stated, at its open house in
New Hazelton, that its pipeline gas would be “totally clean”. The spectrum of potential
contaminants in the pipeline gas, including toxins from the fracking process, needs to be
listed, with values expressed as a percentage of gas volume. These contaminants would
escape into air and water in the event of a pipeline rupture.
1.5 Alternate Means of Undertaking the Proposed Project
The proponent must be prepared to acknowledge a lack of social licence along portions
of its proposed route.
1.6 Project Benefits
“Temporary foreign workers” must be excluded from the employment pool.
The proponent must be required to have a “local purchasing strategy” in order for the
proposed project to have any local economic benefit along most of its route.
3.2.1 Spatial Boundaries
Spatial boundaries for Valued Components should not be reduced after the public has
commented on the draft document.
3.5 Mitigation Measures
Paying cash to residents and First Nations to buy acceptance of this proposed project
should not be reported as a “consultation” strategy of the proponent.
3.8 Determination of Significance of Residual Effects
Social standards must be considered as part of the criteria in assessing all potential
effects. If people who would have to live with the proposed pipeline do not want to
have it in their landscape, those reasons and the effects that those people identify, are
significant.
If residual effects are many in number, they become a significant cumulative effect,
especially if the same is true for multiple, concurrent projects in the proposed LNG
industry.
3.10 Assessment of Cumulative Effects
With more than 60 industrial developments presently proposed for northwestern BC,
the proponent must carefully assess the ability of the region’s infrastructure and social
services to handle this project. The carrying capacity of infrastructure should be viewed
by the BCEAO as a cap on proposed development, including this pipeline.
4.1.2 Existing Conditions for Air Quality
The baseline air study must be regional in scope, with multiple stations sampled for a
period of at least one year continuous. High relative humidity is prevalent along
western portions of the route, with condensing mists common. Methane emissions in
such conditions would produce ground-level methane smog, posing tremendous risk to
human health and environmental health. It is not likely that sporadic air quality
monitoring in advance of the project would capture these conditions at any given
location.
4.2.1 Acoustic Environment, Introduction
The proponent must describe the use of helicopters during the construction phases and
during lifetime operations of the pipeline. The effects of helicopter traffic transcend all of
the spatial boundaries described. A regional assessment area of 5 km from compressor
station fencelines is not large enough to address the adverse effects of the introduction
of industrial noise into rural and wilderness settings.
Table 4-4: Potential Project Effects on the Acoustic Environment
The proponent should be aware that the introduction of any industrial noise caused by
the proposed project is a key aspect of loss of social licence. Sound mitigation measures
for compressor stations must be clearly described. Restrictions to time-of-day for
helicopter use must be stated and enforced.
4.3.3 Freshwater Aquatic Resources, Potential Effects, Table 4-6
The Skeena River is the second-most productive salmon bearing river in BC. Alteration
or destruction of fish habitat, and harm to fish species cannot be accepted. Any proposed
mitigation must be considered in relation to the multiple disturbances of habitat that
would result from other pipeline projects and industrial developments in the region.
4.4 Marine Resources
The proponent’s material does not include a detailed map of its proposed marine
routing to Lelu Island. This is required as, in conjunction with the proposed construction
of Pacific Northwest LNG, Spectra Energy’s proposed pipeline, and Prince Rupert LNG,
the pipeline would be an element of multiple disturbances to Flora Bank, existing sea
bottom industrial contaminants, and salmon habitat elsewhere in the Skeena estuary.
The proponent’s possible marine routing may have effects of marine traffic that are
nowhere described in the proposal.
4.4.3, Table 4-8, Potential Project Effects on Marine Resources
Alteration or destruction of fish habitat and marine species habitiat, and harm to fish
and marine species cannot be accepted.
Wildlife and Wildlife Habitat
4.5.2 Existing Conditions
4.5.3 Potential Effects
Four of the woodland caribou herds (Moberly, Burnt Pine, Scott, Kennedy Siding) that
would be affected by this proposed pipeline are blue-listed as species of concern in BC.
Any impingement on habitat would be counter to the BC government’s 2012
commitment to protect >90 percent of critical habitat for these herds, and to increase
population.
The linear disturbance of the pipeline will facilitate predation by wolves, and will enable
vehicle access (by ATVs) by hunters. Moose populations are already crashing along
Highway 37N due to hunting from the new access provided by the NTL right-of-way.
This has potential to become a regional effect of significance.
4.5.4 Wildlife and Wildlife Habitat, Cumulative Effects and Their Significance
Caribou, grizzly bears, wolverines, and wolves are sensitive to human disturbance of
habitat. Spectra Energy’s proposed twinned pipeline (Westcoast Connector Gas
Transmission Project) would occupy some of the same area as this proposal. The
cumulative effects of all these projects are bound to be significant and negative, are
unlikely to be predictable, and will be difficult to mitigate for these wide-ranging
species.
4.8.3 Greenhouse Gas, Residual Effects and Significance
Despite its assertion otherwise, the proponent should be readily able to estimate the
GHG emissions of its proposed project, and state what percentage of GHG emissions
those would represent for both the province of BC and for Canada. The data sets for
comparison are available – third parties are already making those calculations and
distributing them. What does the proponent mean by “small in the global context” with
regard to GHG emissions? Is it not true that, given the present climate change scenario,
any GHG emissions are significant, especially those of a new, large-scale, fossil-fuel
industry? Eight percent of the gas transported in this proposed pipeline would be
burned at the Pacific Northwest LNG facility, which would emit 19 million tonnes of
GHG emissions each year. LNG plant emissions, and upstream emissions from
wellheads and gathering systems, must be included as cumulative effects in this section
of the assessment.
4.8.4 Greenhouse Gas, Conclusion
The proponent must state how its proposed project would enable BC to meet its legally
mandated targets for greenhouse gas emissions reduction.
4.9.3 Water Quality, Potential Effects
Water quantity must also be included. This project would rely on fracking in
northeastern BC, and could enable fracking of the Bowser Basin. Fracking cannot be
pigeon-holed out of consideration for a pipeline that would transport fracked gas.
Pacific Northwest LNG would require vast quantities of freshwater to cool its processes.
That freshwater demand must also be included as a cumulative effect of this project.
4.10.2 Hydrology, Existing Conditions
If “No Project-specific flow data will be collected for individual watercourses crosses
[sic] by the Project,” then how can the potential adverse effects of a reduction in flow for
any particular stream be assessed? With 1300 stream crossings involved, how can such a
blanket approach be acceptable?
5.2.3 Employment, Potential Effects
The effect of “out-migration” of workers from small communities causes harm to the
social structure of those communities, especially with regard to functions and services
that are volunteer-driven. Communities in northern BC are already suffering from this
depletion of the volunteer pool. BC Ambulance staffing and volunteer fire departments,
for example, have been stripped out.
6.2.2 Infrastructure and Services, Existing Conditions
Access to temporary accommodation (hotels, motels) has already been compromised by
the industrial boom in northern BC. Out-migration of workers has already depleted
volunteer community staffing. In-migrating workers will not be able to access family
physicians or dentists, as these professions are already over capacity in northern BC.
6.3.2 Transportation and Access, Existing Conditions
It is inconceivable to think of the road network of northwestern BC sustaining the kinds
and volumes of traffic associated with building three pipelines through the area. This
would be utterly transformational to this infrastructure and to the rural way of life. That
said, if the proponent was required to upgrade road surfaces, the proponent should
have to pay for it, not the taxpayers of BC.
6.4.2 Visual Quality, Existing Conditions
All “traditional knowledge” (opinion) regarding viewscapes along the proposed
pipeline route should be considered as relevant. Everyone who might be subject to
having a pipeline near their backyard or out their window in the view should be
consulted – this would be truly meaningful public consultation. The proponent should
be required to go door-to-door with a notebook computer that displays modeling of the
project’s route, and listen to what people say.
6.5.3 Land Resource Use, Potential Effects
Tree- clearing for the proposed pipeline would probably be the largest forestry
operation of its time in the province. The proponent must ensure that the commercially
viable trees would be used to support local and regional industries. Burning of trees
because they were cut in remote areas should not be allowed. Natural gas pipelines were
never considered in Local Resource Management Plans for northwestern BC. These
plans should be revisited before any proposed pipeline goes ahead.
8.2.3 Human Health, Potential Effects
Changes to water quality must be added, as the project would rely on fracking and
would enable fracking of new areas.
As a resident of an area that would be affected, it is offensive to see a proposed negative
change to air quality measured by an incremental lifetime cancer risk associated with
that change. This chunk by chunk approach to project assessment – soil, rock, water,
trees, wildlife, aquatic species, birds, employment – falls apart when applied to the
health of people. People do not want to see their well-being analyzed in terms of relative
risk so that a large corporation can carry out an environmentally destructive project in
order to make money on a product that is entirely for export. Residents of northern BC
do not want their health to be compromised by this proposed project.
9.0 Accidents or Malfunctions
The industry standard for a pipeline of this proposed length is one operational failure
per year, and one catastrophic failure every seven years (National Energy Board
statistics.) The proponent must post a bond to serve as a security for residents who
might suffer injury, or damage to property or livelihood as a result of the project. The
proponent should be required to pay for well testing (by a third party) of all those on
well water who live within a prescribed distance of the proposed pipeline and
compressor stations, to serve as benchmark data against which any subsequent changes
to water quality can be assessed.
11 Aboriginal Consultation
The proponent should respect the traditional governance of First Nations, and should
negotiate only with those who have title to make decisions for their territories, not pay
money to anyone who would take it, and then say than “consultation” has been carried
out.
15 Follow-up Programs
Any follow-up monitoring must be clearly described and valid for the lifetime of the
proposed project, with terms binding on any assignee of the proponent under the laws
of BC and Canada.
Thank you for considering these comments.
<<your name>>
<<your e-mail address>>
Submitted by e-mail
cc:
Premier Christy Clark, Premier@gov.bc.ca
Minister Rich Coleman, MNGD.minister@gov.bc.ca
<<your MLA, find here: http://www.leg.bc.ca/mla/3-1-1.htm >>