6 Critical Things to Consider

Reference Number
21
Text

1) Current regulations require both; the Proponent expects both: Under current assessment legislation, this project meets the criteria for assessment by both IAAC and its provincial counterpart, the BC Environmental Assessment Authority. As the IAAC legislation is new, we think it unwise to miss this opportunity to test its validity and public acceptance. We note that the proponent acknowledges that the project qualifies for a IAAC assessment. On P. 1 of the project description, the Proponent notes that: “It is expected that the Project will require an environmental assessment (“EA”) under both the British Columbia Environmental Assessment Act (BIAAC) and the federal Impact Assessment Act (IAA) as the Project”.

2) Marine impacts are a Federal- not Provincial- responsibility:  The Cedar LNG project description shows, at full buildout, one floating liquefaction and storage barge moored near the shore of the North end of Douglas Channel, between the Bish Cove (Kitimat LNG) and Kitimat (LNG Canada) project sites. According to the project description (P.4): “Construction activities will include site preparation, as well as the construction and installation of Project components. Construction activities will be refined as design progresses, but are currently anticipated to consist of the following: Potential localized removal and disposal of marine sediments to accommodate marine terminals and the nearshore LNG production unit ….. “.  As Provincial Governments have no constitutional authority over marine areas below tidewater, and this authority cannot be assigned, a Federal assessment of the impacts on marine areas and marine life and habitat, is therefore required. 

The project will impact marine life, both in the Douglas Channel and on the West Coast of BC. This includes near-shore noise and water quality effects on cetaceans and local herring-spawn and salmonid spawning areas, along with effects of noise and tanker traffic on endangered Northern Resident and Transient orca populations. This is acknowledged in the project description (P.66) as: “Douglas Channel is highly productive, supporting many species of marine fish and invertebrates. Upwellings of nutrient-rich waters from the Juan de Fuca Plate and subsequent mixing with less saline and warmer surface waters support a diversity of marine life, from microscopic primary producers (i.e., phytoplankton) through apex predators such as killer whales (Orcinus orca)”. 

LNG is classified as a Hazardous and Noxious substance (HNS) whose floating storage and ocean transport is regulated under the (Federal) Canada Shipping Act and Dangerous Goods Act. BC’s Oil & Gas Commission has no jurisdiction (or expertise) in these areas. Indeed, the Commission‘s regulatory independence has recently attracted severe criticism for its repeated failure to regulate the construction of large dams supporting gas fracking operations in N.E. BC. As there is not now, nor has there ever been, an active LNG export facility on BC’s coast, the Commission’s (and EAO’s) expertise in this area is demonstrably inadequate. The conflict of interest in having the BC Government’s Deputy Minister of Energy, Mines and Petroleum Resources also be the current Chair of BCOGC, is further reason to require a separate Federal assessment lest public trust in BC’s much-maligned EA process be further eroded.

The Provincial Government lacks both the expertise and the authority to assess marine impacts. Section 5 of IAAC 2012 is specific to the need for IAAC to assess marine effects. Its dependence on “professional reliance” is what has hugely diminished public trust in the independence and quality of BC’s EA process.

3) The GHG emissions effects of this project are of national significance: P. 6 of the Cedar project description states: “If the full amount of power required by the Project is available from the provincial grid, the Project is expected to produce approximately 168,000 tonnes of CO2 equivalent (CO2e) per year. If Cedar is required to self-generate 100% of its power, the Project is expected to produce approximately 840,000 tonnes of CO2e per year”. 

This suggests that the GHG emissions intensity (tonnes CO2e emitted per tonne of LNG produced) of this plant would be far below industry norms (i.e. in the range of 21% v. industry-standard intensity measures of 27%-30% for gas-powered liquefaction; roughly 4% if grid-powered v. at least 17% predicted. Grid-powered Woodfibre LNG is suggesting at least 7% direct-emissions intensity). How Cedar’s exceptional level would be achieved in either power option is not explained and is, frankly, highly improbable. The project description also lacks any estimate of the upstream emissions resulting from fracking, venting and flaring and fugitive emissions from pipeline transmission of the gas generated to supply this project.

Both BC and Canada have committed to large reductions in GHG emissions to meet its provincial and international obligations, so the addition of this plant’s emissions to the GHG tally is indeed a matter of national importance. Current measurement indicate that GHG levels are rising- not falling – and that both Governments are failing to make progress on meeting those commitments. The air quality and ocean acidification of the Douglas Channel are also of intense local concern. In respect of the greenhouse gases and climate effects of this project, this statement of emissions effects understates the damaging effects of wildfires, tornadoes, floods and pestilences that are the consequences of climate changes induced by anthropogenic emissions, such as from this project. As the recent IPCC report warns, Governments worldwide have little less than a decade to transition away from fossil fuel dependencies. It is inconceivable that this project is in any way consistent with heeding that warning, living up to Canada’s COP-21 Paris commitments, or with meeting either Federal or Provincial (“CleanBC”) emissions targets. 

4) Where’s the pipeline piece?: The current proposal omits from its scope the pipeline required to feed gas to the Cedar plant. Without it, the project is impossible, as there is no local supply of gas. The Project Description describes the pipeline thus: “Subject to the negotiation of certain agreements, Cedar intends to receive feed gas from the Coastal GasLink pipeline at a meter station within the vicinity of Kitimat. Natural gas will be delivered to the Cedar LNG Project Area by a 20-inch diameter, approximately 8 km long pipeline”.  As the pipeline is a necessary and intrinsic part of the project, and, along with possible grid power infrastructure, contributes to the project’s cumulative environmental impacts, it should be included in a single, comprehensive assessment rather than in this fragmented, piecemeal approach. That the pipeline component has being supplied by an unrelated entity is entirely irrelevant to the environmental assessment of the project.

5) Where’s the BC Hydro line piece?: The current proposal omits details of the impact of adding a high-voltage electricity supply from the sub-station to the Cedar plant. The proposal states that it will require a 200MW service from BC Hydro (if available). As high-voltage lines require 32-64m. clear-cut setbacks from large pylons, the visual, vegetation and wildlife habitat impacts should be included in the assessment. Also, the effects of this large increase in electrical demand in the Kitimat area – already taxed by the RTZ, LNG Canada and Kitimat LNG proposals - should be known prior to any approvals of this project. 

6) What are the upstream impacts (fracking, fugitive emissions, water use/contamination etc.)?: The project description is largely silent on the sources of its feed gas, which will necessarily require a large increase in fracking operations in N.E. BC. The adverse environmental impacts of fracking (earthquakes, forest destruction, use and contamination of ground water and water tables, health and social impacts on residents, infringement on First Nations hunting and fishing rights, effects on wildlife, especially caribou, to name but a few) are well known. Less well known and largely-unmeasured also are the fugitive emissions from cracked well-casings, poorly-completed well bores and pipeline compressor stations, all of which are significant unrecognized point sources of climate-warming methane emissions. 

 

 

Submitted by
Melyssa Desilles
Phase
Planning
Public Notice
N/A
Attachment(s)
N/A
Date Submitted
2019-10-21 - 1:23 AM
Date modified: