CAS Feedback on Environmental Assessment
Certification Application – for the Westcoast
Connector Gas Transmission Project- April 2014
Regarding GHG Emissions
1.5.3 Predicted Environmental Benefits of the Proposed Project
Please eliminate the following statement:
“BC LNG to Asia could reduce GHG emissions in China alone by up to 93 Mt CO2e per year. The export of
natural gas could lead to the reduction of global GHG emissions more than if every GHG emitter in BC
(including every home, car and industrial facility) stopped operating. The increased export of natural gas
could amount to GHG savings of more than 20 times total emissions from the WCGT project even when
fully built with two lines and operating at full capacity (World Resource Institute 2013).”
Pipelines are net contributors to GHG emissions in BC. Exports of LNG cannot be accounted to assess
environmental benefits of this project. Also, according to carbon accounting rules, emission reductions
are "owned" by the country in which they occur rather than any other country or jurisdiction that may
facilitate the emission reduction.
1. P.405, 4.1.4 Greenhouse Gases > 4.1.4.1 Background and Setting > [Paragraph 2]
Please eliminate or modifying the following statement:
“It is also widely acknowledged … no individual activity is responsible for global effects on climate due
to GHG emissions. Instead, it is the multitude of … that have rendered the current climate circumstances
faced today”,
It is misleading to state that no individual activity is responsible for global effects on climate change, the
sum of individual activities create a multitude.
Page A2-12 TABLE A.2-1. “WCGT conducted an assessment of GHGs consistent with the Canadian
Environmental Assessment (CEA) Agency guidance (CEAA 2003). WCGTs consideration of the GHG
reduction targets contained in the Greenhouse Gas Reduction Targets Act includes compliance with the
Act, as well as other BC Legislation and Regulations aimed at reducing GHG emissions”
Please ensure and state that the GHG assessment is conducted according with the guidelines provided
by the BC Reporting Regulation. This assessment could be compared with the guidelines provided by the
CEAA (2003) guidance, but CEEA (2003) cannot substitute guidelines provided by the BC Reporting
Regulation.
Page A2-12 TABLE A.2-1. “The carbon emitted during the construction phase through burning of
biomass is resequestered in biomass when the pipeline right-of-way reverts back to its original state”
CAS Feedback on Environmental Assessment
Certification Application – for the Westcoast
Connector Gas Transmission Project- April 2014
Please delete or modify this statement. Pipelines need to account for all deforestation annual emissions
when they are changing the land-use of an area. It is not acceptable to state that there is no carbon loss
because some carbon may be regained when the pipeline is decommissioned.
Page A2-12 TABLE A.2-1: “The Application describes and characterizes WCGTs carbon management
initiatives and discusses GHG emissions consistent with applicable guidance (CEAA 2003). The CEAA
(2003) provides guidance to project proponents to compare Project-related GHG emissions against
national and provincial GHG emission totals”.
Please ensure and state that the GHG assessment is conducted according with the guidelines provided
by the BC Reporting Regulation. This assessment could be compared with the guidelines provided by the
CEAA (2003) guidance, but CEAA (2203) cannot substitute guidelines provided by the BC Reporting
Regulation.
4.1.4.3 Potential Effects “The direct GHG emissions associated with the construction and operations of
the proposed Project were considered in this assessment. The CEAA method for incorporating GHG
considerations in environmental assessments (CEAA 2003) and the accounting and reporting principles
of the WRI GHG Protocol were applied to this assessment (WRI 2004)”.
Please ensure and state that the GHG assessment is conducted according with the guidelines provided
by the BC Reporting Regulation. This assessment could be compared with the guidelines provided by the
CEAA (2003) guidance, but CEAA (2203) cannot substitute guidelines provided by the BC Reporting
Regulation.
P.409, 4.1.4.5 Residual Effects, Cumulative Effects and Their Significance > Potential Residual Effects >
Key assessment findings are as follows: “The quantities of project …. to be 2.13 Mt CO2e during
construction”
The application should disaggregate construction emissions per source and per year for both, the first
and second pipelines.
Also, please validate data and provide an explanation of why construction of the second pipeline would
release considerable lower emissions (0.23 Mt CO2e).
15.1 Key Findings on Environmental VCs
We disagree with the proponent’s assessment of the Project's GHG effects and magnitude. In order to
be consistent with other environmental assessments where significance and magnitude were
determined by how the proposed facility compared with BC's current emissions, it is more appropriate
that the greenhouse gases have a "significant adverse effect" and "high" magnitude.
CAS Feedback on Environmental Assessment
Certification Application – for the Westcoast
Connector Gas Transmission Project- April 2014
Also, the proponent must not consider exports of LNG to assess that the pipeline construction will
displace GHG emissions. According to carbon accounting rules, emission reductions are "owned" by the
country in which they occur rather than any other country that may facilitate the emission reduction.
Regarding Climate Change Adaptation
Section 10.3
The Proponent does a good job of assessing climate change's effect on the project in terms of extreme
weather but not of sea level rise. This is material for the project due to the fact that the pipeline will be
submerged underwater for part of the route.