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Comment on Canada’s Trans Mountain Pipeline Expansion project by November 20th!

by Friends of the San Juans on November 15, 2018 No comments

Since 2014, we have been sending letters to Canada’s National Energy Board (NEB) to protect our shorelines and the Southern Resident Killer Whales from the Trans Mountain Pipeline Expansion project. The increased risk of diluted bitumen (dilbit) Alberta Tar Sands crude oil spills in our waters and the Southern Residents’ critical habitat is not justified by this project’s profit margin.

Please ask the NEB to address the full costs of this project’s risks and impacts.

Submit your comment letter directly to the NEB by November 20th. See below for a suggested comment letter by Friends of the San Juans.

You can also send (and customize) this form letter provided on STAND.earth’s website.

Electronic filing portalhttps://apps.neb-one.gc.ca/efile/ElectronicDocumentSubmission.aspx

Fax (plan for possible last-minute submissions to tie up the phone line): 403-292-5503 (or toll-free at 1-877-288-8803)

If you are unable to send a fax, we’ll send it for you. Please send your document by email to katie@sanjuans.org or drop a paper copy by our office (650 Mullis Street, Suite 201, Friday Harbor) by noon on Monday, November 19 if you would like us to fax your document.

Please include personal details following, “I would be negatively impacted by project-related marine shipping.” Note that the NEB states that comment letters should include name, mailing address, and phone number.

Ms. Sheri Young
Secretary of the Board
National Energy Board
Suite 210, 517 Tenth Avenue SW
Calgary, AB T2R 0A8
CANADA

RE: Hearing Order MH-052-2018 and File OF-Fac-Oil-T260-2013-03 59

Dear Ms. Young,

I am writing in opposition to the Trans Mountain Pipeline Expansion project. I would be negatively impacted by project-related marine shipping.

The NEB has recognized that the project will have significant adverse effects, including:

  • Adverse impacts to our climate and air quality from increased greenhouse gas emissions.
  • Adverse impacts to the critically endangered Southern Resident Killer Whales from the project’s vessel traffic noise, presence, and increased oil spill risk.
  • Adverse impacts from the increased risk of a large or credible worst-case spill to our environment, economy, and our cultural, socio-economic and natural resources. The Southern Resident Killer Whales could become extinct if they are in the vicinity of a project-related vessel’s large or credible worst case oil spill.
  • Adverse impacts to traditional Indigenous use associated with Southern resident killer whale.

If the NEB approves the project, please require the following mitigation measures:

  • To reduce greenhouse gas emissions, require hybrid propulsion systems on all project-related tankers.
  • To reduce vessel noise impacts to Southern Resident Killer Whales, require all project-related tankers to be accredited as quiet by ship-classification societies.
  • Prohibit project-related tankers from bunkering and/or anchoring in the waters of Washington State.
  • To prevent oil spills that could result from another vessel in distress colliding with a project-related tanker, require Emergency Response Towing Vessels to be stationed along the vessel traffic route.
  • To address the potential effects of a large or credible worst-case spill, require changes to Canadian law regarding compensation for a tanker spill to ensure compensation for the full costs of a project-related tanker spill. Total spill costs could exceed available compensation by over $2.9 billion (CAD) not including the full costs of cultural and ecological values, ecosystem services losses and psychological damages (e.g., stress and dislocation) which could bring the total cost of a project-related tanker oil spill to $25.5 billion CAD.

I support the First Nations and Tribes with Treaty Rights who do not give their consent to the pipeline expansion and project-related marine shipping.

The comment letter from Friends of the San Juans and the evidence submitted by US and Canadian environmental organizations and the Washington State Department of Ecology supports my comments.

Thank you for considering this comment letter.

Your name, mailing address, and phone number

More Information:

In November 2016, after 2 years of flawed review of Kinder Morgan’s Trans Mountain Pipeline Expansion project’s application, and in spite of overwhelming opposition by British Columbia, First Nations and Tribes with Treaty Rights, and the cities of Vancouver and Burnaby, the NEB approved the Trans Mountain expansion project.

In May 2018, the Canadian government announced its decision to purchase the Trans Mountain Pipeline and the proposed expansion project from Kinder Morgan. Three months later, the Canadian Federal Court of Appeals overturned the NEB approval of the pipeline for two reasons: the Canadian government failed to consider the impacts of increased tanker traffic on the marine environment, especially on the endangered Southern Resident Killer Whales; and, Canada’s consultation with Indigenous Peoples was woefully inadequate.

An oil spill risk analysis commissioned by the Tsleil-Waututh Nation found that in a 50-year time period there is a 37% likelihood of a project tanker-related large spill (>10,000 barrels) and a 29% chance of a “worst case” spill (103,782 barrels) along the project’s vessel traffic route from Burrard Inlet to Georgia Strait, though Boundary Pass and Haro Strait, and the Strait of Juan de Fuca.

For any questions about submitting comments to the NEB, contact a Process Advisor in Canada at 1-800-899-1265 (toll-free) or by email at TMX.ProcessHelp@neb-one.gc.ca (questions only, no comments will be accepted by email).

Greenpeace. 2018. Tar Sands Tanker Superhighway Threatens Pacific Coast Waters. 

Gunton & Broadbent. 2015. An Assessment of Spill Risk for the Trans Mountain Expansion Project.

Financial Post: “Canada buys Kinder Morgan’s Trans Mountain pipeline for $4.5 billion — but can we sell it?” 

The Guardian: “Did Canada buy an oil pipeline in fear of being sued by China?” 

CBC News: “Ottawa gives pipeline regulator 22 weeks to review Trans Mountain expansion project”

Financial Post: “Timeline: Key dates in the history of the Trans Mountain pipeline”

National Energy Board – Trans Mountain Expansion-Reconsideration-Decisions following comment periods – Hearing Order MH-052-2018 – Explanatory Note to OIC PC 2018-1177 – Filing Requirements for Trans Mountain – Request to Federal Authorities https://apps.neb-one.gc.ca/REGDOCS/Item/View/3620050

The NEB is considering:

  1. The environmental effects of Project-related marine shipping, and the significance of these effects.
  2. Measures that are technically and economically feasible, and that would mitigate any significant adverse environmental effects of Project-related marine shipping.

Given that the Board found four significant adverse effects related to Project-related marine shipping in its previous assessment (i.e., greenhouse gas emissions, Southern resident killer whale, traditional Indigenous use associated with Southern resident killer whale, and the potential effects of a large or credible worst-case spill), the consideration of mitigation measures will include these four matters. This issue will also include consideration of whether the mitigation measures will change the Board’s previous significance findings.

  1. Alternative means of carrying out Project-related marine shipping that are technically and economically feasible, and the environmental effects of such alternative means.
  2. Requirements of any follow-up program in respect of Project-related marine shipping.
  3. Measures to avoid or lessen the adverse effects of Project-related marine shipping on SARA-listed wildlife species and their critical habitat, monitoring of the measures, and consideration of how to ensure the measures and monitoring are undertaken.

The Board’s previous assessment identified the SARA-listed marine fish, marine mammal, and marine bird species that could be found in the area of, or affected by, Project-related marine shipping. Consideration will also be given to any species that have been newly listed or have seen a change to their designation since the issuance of the Board’s Report and that could be affected by Project-related marine shipping.

  1. The potential impacts of Project-related marine shipping on Indigenous interests.
  2. Whether there should be any changes or additions to the Board’s recommendations set out in its Report, or to the recommended terms or conditions, including Conditions 91, 131 to 134, 144, and 151.

Image above courtesy of San Juan Islanders for Safe Shipping.

Friends of the San JuansComment on Canada’s Trans Mountain Pipeline Expansion project by November 20th!