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Prioritize Reduction of GHG Emissions in Canada

Posted by Winnipeg Chapter on June 8, 2018 at 10:05 PM Comments comments (0)

UPDATE: NEB hearing for the MMTP


The Council of Canadians Winnipeg Chapter continues to participate in the NEB hearing for the Manitoba-Minnesota Transmission Project. At the time of our last blog, we had completed several steps in the process.


  1. We submitted an Information Request to Manitoba Hydro.

  2. MH replied that our concerns are not relevant.

  3. We submitted a detailed explanation of why our concerns are entirely relevant.

  4. MH replied that our concerns are outside the scope of the NEB hearing and that they do not have access to the third party information that would be required to do the analyses requested.


The third item on the list is also known as a Motion to Compel Full and Adequate Response.


When Intervenors make Motions to Compel, the NEB must consider each submission and make a decision to either deny the motion or to compel Manitoba Hydro to provide a full and adequate response to the initial Information Request. The Board denied all the Motions to Compel, giving various reasons for the denial. In our case, they said that the questions were outside the scope or beyond the Board’s mandate.


Deny – Motion sought information on matters outside the scope of the proceeding, or that is beyond the Board’s mandate.


(See our previous blog on our questions about Manitoba Hydro’s ability to both export electricity and provide enough power to electrify transportation as part of Manitoba’s commitments under the Paris Accord.)


Manitoba Hydro also maintained its position that Manitoba’s electricity need in the context of climate change mitigation measures is irrelevant to their MMTP export plans.


The Chapter contends that our concerns are very relevant. The corporation cannot responsibly commit to exporting electricity over several decades when that electricity is going to be necessary to power the transition here in Manitoba.


We initially intended to submit a final reply and to file evidence supporting our argument. However, we found that other Intervenors were making the arguments very well, and we decided that our energy would be more effective elsewhere in the process. We focused on the draft conditions that will apply to the MMTP if Hydro gains NEB approval for the project.


You can read the draft conditions apps.neb-one.gc.ca/REGDOCS/Item/Filing/A90002 and our complete comments apps.neb-one.gc.ca/REGDOCS/Item/View/3573437 in the Regulatory Documents section of the NEB website.


For a brief overview of our argument, we’ve included the introduction and our recommendations here.



Introduction


The Manitoba-Minnesota Transmission Project (MMTP or the Project) is intended to increase grid interconnection capacity between Manitoba and Minnesota, mainly to export electricity.


However, there are potential uses of this electricity and hydroelectric storage capacity within Manitoba and within Canada. These in-Canada uses may be more economically feasible and have better environmental and socio-economic outcomes than the Project as currently proposed. Manitoba Wildlands’ evidence report, The Manitoba Minnesota Transmission Project is Not Needed, outlines this case admirably under more or less status quo conditions regarding climate action.


Thus, it seems appropriate that the NEB conditions for the operation of the Project ensure that adequate electricity is available for use in Manitoba and elsewhere in Canada. In addition, on May 18, 2018, the NEB specifically invited comment on the relevance of the Manitoba Clean Environment Commission (CEC) report to MMTP conditions.



Recommendations


On the Manitoba Clean Environment Commission Report


Background


“The Board invites Participants to comment as to which, if any, Report recommendations the Board ought to consider adopting as conditions on a Certificate of Public Convenience and Necessity, should one be issued. Participants’ comments should include a justification as to why the Board ought to adopt a particular recommendation, including an explanation of how the recommendation relates to matters which must be decided by the Board.”


The CEC report provides important context for their recommendations. It points out that the purposes of The Manitoba Hydro Act include providing “for the continuance of a supply of power adequate for the needs of the province.” In keeping with domestic GHG reduction obligations and plans, it would seem that Manitoba Hydro is obligated to evaluate the provincial supply of power in the context of the amount of power needed to adequately supply future domestic electrification.


Recommendation

We recommend the inclusion of these CEC conditions by the NEB. We believe that the NEB should extend these conditions to include the development of a monitoring plan to verify and monitor all GHG reduction claims over a period of at least 10 years.


One of the stated justifications for the Project is to reduce GHG emissions from coal-fired plants in Minnesota.


It is inconceivable that there is no consideration of the potential GHG reductions that would be achieved in Manitoba and other parts of Canada by powering domestic electrification instead of exporting power.


Based on this consideration we recommend that long-term export contracts outside Canada via MMTP be restricted to ensure adequate electricity is available for use in Manitoba and other areas of Canada.


On the Canadian Public Interest in Reducing GHG Emissions


Background


The National Energy Board must determine


“whether or not these projects are in the ‘present or future public convenience and necessity.’ In other words, are these projects in the Canadian public interest?”


“The Canadian public interest includes all Canadians and refers to a balance of environmental, economic, and social interests that changes as society’s values and preferences evolve over time. . . Simply put, we need to answer the fundamental question: Would Canada be better or worse off if a particular project were to go ahead?”


Therefore, it seems that information about the environmental, economic, and social impacts of differing courses of action regarding GHG emissions, including if the Project should be built and operating conditions for the Project, should be crucial considerations for the NEB.


Recommendation


The Board should impose Certificate Conditions concerning export contracts to include the flexibility to reduce exported power to provide for domestic electrification over time.



Photo by Ken Harasym


Next Steps


The final stage is the Oral Cross Examination and Final Argument. Intervenors and the Applicant can choose to cross examine other participants in the hearing. Following the period for cross examination, Intervenors and the Applicant can present an oral final argument or submit a written final argument. The Chapter is submitting a written final argument.


The hearings take place June 18-21, 8:30 a.m. to 4:30 p.m., and anyone can attend. The environment and rules are very similar to a courtroom. While it can be interesting to observe in person, it is a very formal atmosphere. We ask all our supporters to respect the hearing protocol and remember that the hearing is an important time for Intervenors to address concerns and ask questions.


You can find detailed information about public access to NEB hearings on the NEB website. www.neb-one.gc.ca/prtcptn/hrng/plcynpblcndmdccss-eng.html



Contributor: Mary Robinson - Council of Canadians Winnipeg Chapter Chair

Can Manitoba Hydro support our Low-Carbon Future?

Posted by Winnipeg Chapter on April 23, 2018 at 10:35 PM Comments comments (0)

About the NEB MMTP Hearings and Chapter


The Council of Canadians - Winnipeg Chapter is an Intervenor in the National Energy Board hearings on Manitoba Hydro’s proposed Manitoba-Minnesota Transmission Project.



Photo by Ken Harasym


The MMTP would be “500 kV alternating current international power line (IPL) extending from Manitoba Hydro’s Dorsey Converter Station in Manitoba to the international boundary between Manitoba and Minnesota (Dorsey IPL). The Dorsey IPL will connect with the Great Northern Transmission Line, a new 500 kV transmission line in the United States.” NEB Project Description


The Chapter is concerned about many issues when it comes to Manitoba Hydro, including hydro justice for northern communities, the environmental devastation resulting from Hydro’s control of waterways in Manitoba, and the urgent need to transition away from fossil fuels.


As Intervenors in the MMTP hearings, we chose to focus on two specific problems that are relevant to the proposal: 1) Cathodic protection and 2) Transition.


There is a very specific process that must be followed for Intervenors and the Applicant (in this case, Manitoba Hydro) during an NEB hearing. The Information Request is the primary method for expressing concerns and asking questions about a project.


Once Manitoba Hydro replies to the Information Request, the Intervenor can either accept Hydro’s response or can take the next step by filing a Motion to Compel Full and Adequate Response.


Motions are formal requests that require the Board to make a decision or an order.


The Motion to Compel gives the reasons why the Intervenor is not satisfied with Hydro’s answers and asks the NEB to compel Hydro to take action.


The detailed and fully referenced Information Requests and all responses are part of the public record on the NEB Regulatory Documents website.



Information Request Overview


In our first Information Request, we asked Manitoba Hydro to clarify what they are doing to maintain cathodic protection for nearby pipelines, railways, and other infrastructure. We were satisfied with Hydro’s response and are not taking any further action.


Our second Information Request addressed Manitoba Hydro’s role in helping the province meet our obligations under the Paris Climate Accord.


We took the position that using surplus hydroelectricity to facilitate transition could be more economically feasible and have better environmental and socio-economic outcomes than using it to raise revenue through locked-in export sales.


This is a time of rapid and disruptive change in energy technology and economics. Electric vehicles, solar power, wind power, and storage batteries are becoming more accessible and affordable every day, at a pace far beyond expectations. It doesn’t make sense to plan within the limitations of an older framework that is quickly disappearing.




Manitoba’s Green Plan, Canada’s Framework on Climate Change, and the MMTP


In the 2017 Made-in- Manitoba Climate and Green Plan, Manitoba laid out its commitment to decarbonization through electrification. This strategy is an effective way to reduce emissions and meet climate change targets while strengthening and diversifying our economy. Under the Pan‑Canadian Framework on Clean Growth and Climate Change, all provinces are obligated to work cooperatively towards climate solutions. The Framework commits provinces and the federal government to direct more funding towards increasing the mode share of public transit and other energy efficient modes of transportation.


Advances in battery storage technology and the concurrent drop in prices will make electric cars, trucks, and public transit buses viable much sooner than could have been predicted only a few years ago. If the province follows through on its Green Plan and Framework commitments, there would be a market here in Manitoba and in the rest of Canada for all the “surplus” hydroelectricity produced. Under those circumstances, the MMTP export line could become no longer economically viable.




Facilitating decarbonisation through electrification within Canada


“The Canadian Energy Strategy is intended to strengthen the collaboration of provinces and territories in the transition to a low-carbon economy. It proposes ‘pan-Canadian, regional, and bilateral agreements’ on electricity transmission. It is likely that Manitoba would benefit in multiple ways from the success of such agreements.”




Our specific Requests to Manitoba Hydro


1) Estimate and explain how much increased electricity would be required for decarbonization through electrification for each of the following:

a. Electrifying all urban transit buses in Manitoba assuming presently planned fleet growth and replacement by purchasing only electric buses starting in 2020.

b. Electrifying all urban transit buses in Manitoba assuming greatly accelerated fleet growth to meet climate emissions targets (purchasing only electric buses starting in 2020).

c. Electrifying other buses and heavy trucks, with 100% of new vehicles sold being electric or plug in hybrid by 2025.

d. Electrifying other buses and heavy trucks, with 100% of new vehicles sold being electric or plug in hybrid by 2030.

e. Electrifying cars and light trucks, with 100% of new vehicles sold being electric or plug in hybrid by 2025.

f. Electrifying cars and light trucks, with 100% of new vehicles sold being electric or plug in hybrid by 2030.

g. Electrifying the main rail lines through Manitoba for both passenger and freight transportation by 2025.

2) Estimate and explain how much less electricity would be required for decarbonization through electrification if 90% of federal and provincial urban road expansion budgets were re-allocated to public transit and other forms of active transportation beginning in 2018.

3) Estimate and explain how much increased electricity would be required for decarbonization through electrification for each of the following:

a. Cancelling all planned expansions of the Manitoba natural gas distribution system, to be replaced with programs to decarbonize these areas through electrification and energy efficiency.

b. Eliminating fossil fuel burning for water and space heating (except emergency back up) in new buildings starting in 2020.

c. Retrofitting 5% of all existing publicly owned buildings per year that burn fossil fuels for water and space heating to electric space and water heat (except emergency back up) starting in 2019.

d. Retrofitting 2% of all existing privately owned buildings per year that burn fossil fuels for water and space heating to electric space and water heat (except emergency back up) starting in 2019.

4) Estimate and explain how much increased electricity would be required for both moderately aggressive and very aggressive programs of decarbonization through electrification in the commercial / industrial sectors in Manitoba.

5) Explain the results of efforts to negotiate bilateral, regional and/or pan-Canadian agreements on electricity transmission in the context of Canadian and provincial commitments to reduce greenhouse gas pollution. For example, is increased electricity transmission and trade with Ontario a near term possibility?




Manitoba Hydro’s response


“Manitoba Hydro stands by its answers to this IR.


The questions ask for information on various alternative scenarios which are not within the scope of the NEB hearing. These scenarios are not “alternatives” to meeting the needs of the project that are explained in Section 3.1.3 of the Application. They are also not “alternatives” as defined in Section 4.5 of the NEB Electricity Filing Manual - “functionally different ways of meeting the need and purpose of the project, or are other technically, economically, socially and environmentally feasible means of fulfilling the project”.


Further, and in the alternative, Manitoba Hydro does not have access to the third party information that would be required to do the analyses requested.”




Next Steps?


The Chapter can either accept Manitoba Hydro’s inadequate and dismissive reply, or it can reply for a final time. We are preparing our reply now. After that process is complete, we have a brief window to present written evidence, followed by the oral portion of the hearing where (if we choose) a Chapter representative can briefly speak and ask and answer questions.


Are you interested in transit, transition, and climate solutions? Please complete a brief survey to let us know where you stand.


Contributor: Mary Robinson - Council of Canadians Winnipeg Chapter Chair

Want to Make A Difference? Read On!

Posted by Winnipeg Chapter on February 28, 2018 at 5:45 PM Comments comments (0)


Welcome to our online, always ready newsletter!


In this issue:

  • Justice for Tina Fontaine
  • Functional Transit in Winnipeg
  • The Manitoba-Minnesota Transmission Project
  • Pharmacare: A Plan for Everyone


  

Justice for Tina Fontaine

 
Please show your #LoveForTina and support the call for justice for Tina Fontaine.

 
Visit the Soaring Eagle camp on the grounds of the Manitoba Legislature, donate requested items, donate to the fund to assist Tina's Aunt Thelma who attended court every day during the trial; there are many ways to help.

If you can't donate or come in person, please share with friends and on social media and speak up about the tragedy and travesty of our justice system.
 


You can find more information about Tina Fontaine at Groundwork for Change, a website dedicated to helping non-indigenous people begin learning  “to build just relationships between non-Indigenous and Indigenous peoples; to learn about historical and contemporary issues related to Indigenous peoples and relationships with non-Indigenous governments and peoples in the Canadian state; to gain understandings of colonialism, racism, privilege and other related concepts and topics.


 
 
From our friends at Functional Transit


Winnipeggers deserve accessible, affordable, frequent transit service!


“The provincial budget will be released in several weeks, and we are reminding provincial MLAs of the importance of funding public transit. I encourage you to send an email to your MLA reminding them how important transit is. Please also consider passing the message along to other transit supporters.


 
You can find a form email available on our website, FunctionalTransit.com. There is also a link to help you find your MLA if you don't know their name.”


 
 
The Manitoba-Minnesota Hydro Transmission Project (MMTP)


The Winnipeg Chapter is an Intervenor in the NEB hearings for the MMTP.


We are very concerned about Manitoba Hydro investing heavily in long-term plans that require years of electricity export sales to make the investment financially worthwhile. If Manitoba is to meet its commitments to the Paris Accord, the province needs all the hydro it can produce, along with wind and solar.


Background information


Map of the proposed route


List of affected communities:


Winnipeg, Rosser, Headingley, Oak Bluff, Grande Pointe, Prairie Grove, Dugald,  Glass, Anola, Dufresne, Ste. Anne, La Coulee, Richer, La Broquerie, Marchand, Sandilands, Sundown, Piney 


 
Do you live anywhere along the line?  Please let us know. We'd love to hear what you think of this project, and we’re ready to answer your questions. 


 
There is no need for you to participate directly in the process; the Chapter will represent you and give voice to your concerns in the hearing. Your identity will remain confidential unless you choose otherwise.



Pharmacare: A Plan for Everyone

From our friends at the Canadians Labour Congress

"Join us on March 12, for a "Pharmacare: A Plan for Everyone

"Town Hall meeting in Winnipeg!


This important meeting will feature Canada's foremost pharmacare experts and advocates, and these important discussions will address why we need a universal prescription drug plan that covers all Canadians, regardless of their age, income, or where they work or live.


When: Monday, March 12, 2018

Time: 6:30 -- 8:30 P.M.

Venue: Crossways in Common, 222 Furby Street (at Broadway), Winnipeg, MB  R3C 2A7

Register today and share with friends and family

CALL TO ACTION - Participate in Manitoba Hydro NEB Hearings

Posted by Winnipeg Chapter on February 5, 2018 at 4:55 PM Comments comments (0)

"Hydro costs have risen, while other sources have dropped. And the politics of energy are increasingly linked to local investment over imports." 


Apply to be an Intervenor in the NEB Public Hearings for the Manitoba Hydro's Manitoba-Minnesota Transmission Project  Council of Canadians-Winnipeg Chapter particularly questions whether the line is and will be required by the present and future public convenience and necessity.


In 2016, Will Braun of the InterChurch Council on Hydropowerwrote about some of the problems with Manitoba Hydro’s export plans. He concluded :

"[We should consider] a fundamental shift away from an old-school hydro company to a nimble new energy solutions innovator…We need a utility that helps create a vibrant future rather than trying recreate the past."


The Public Utilities Board was similarly unimpressed:


“As a result of its review, the Panel rejects Manitoba Hydro’s Preferred Development Plan, as well as Manitoba Hydro’s suggestion to consider pathways that map out a 78- year future, as the Panel sees Manitoba Hydro’s long-term future projections as highly speculative and too uncertain.” From the Public Utilities Board Needs For and Alternatives To (NFAT) Review of Manitoba Hydro’s Preferred Development Plan,  Page 18. 



NEB Press Release


Quick Facts.

 

Manitoba Hydro is applying for authorization under the NEB Act to construct and operate a 500 kV international power line extending from the Winnipeg area to the U.S. border in southeastern Manitoba as well as upgrades to three existing electrical stations in southern Manitoba.


There are 84 international power lines between Canada and the United States. In 2015, these power lines transmitted $3.4 billion dollars in electricity.

 

CALGARY, Jan. 17, 2018 /CNW/ - The National Energy Board (NEB) will conduct a public hearing for Manitoba Hydro's Manitoba-Minnesota Transmission Project. Indigenous peoples, members of the public and other stakeholders who may be impacted by the project must apply to participate by 7 February 2018.


Participant funding is available to cover expenses such as legal or expert fees and travel expenses. The NEB's hearing and environmental assessment will consider a broad range of topics, including the need for the project and its economic viability, as well as the potential impacts on landowners and Indigenous peoples.


To reduce duplication, the NEB requested that Manitoba Hydro file all documents from the provincial Clean Environment Commission public hearing on the NEB's record. Also, when contemplating participation in the NEB hearing, people who took part in the provincial process are encouraged to only consider what new information they may be able to bring forward.

 

Today's announcement follows an NEB recommendation to the Minister of Natural Resources that this project be subject to a hearing. This will allow the NEB to ensure Indigenous considerations are fully taken into account.


The NEB regulates the construction and operation of international power lines, such as the proposed Manitoba-Minnesota Transmission Project, so that approved projects can be built and operated safely for people and the environment.

 

Safe and Warm in the Winter

Posted by Winnipeg Chapter on January 3, 2018 at 10:15 PM Comments comments (1)

For many people, it’s easy to make good choices and take extra steps to stay safe and warm in the winter. For instance:


Wear good wool clothing for all your outdoor winter activities. Wool will retain most of its insulating value even when wet, it will also breath better than other fabrics, allowing for activity without becoming saturated with sweat. Ear muffs and a hooded coat can make a big difference.


Layered synthetic fabrics also help keep you warm. Some are specifically made to stop the wet from getting through to your inner layers, while others allow sweat to escape more easily. Layer t-shirts and light jumpers/sweaters, so that you can easily adjust the amount you are wearing at any given point in the day.


Use hand-warming packs. These small packs use chemicals to create a continuous heat for several hours, a bit like having small hot water bottles in your pockets. (Warning: this is a common tip, but the packs are a poor environmental choice. They’re best used in emergencies only.)


Stay hydrated


Keeping food in your stomach will give you energy to keep you warm.


But if you don’t have a home, it’s not so easy. www.engageandchange.org Toronto’s Engage and Change runs Project Winter Survival, an “initiative dedicated to providing homeless and less fortunate with winter survival kits, which help provide warmth and essential supplies needed for survival on the streets during the winter.”


The kits contain sleeping bags, winter clothing, and hand warmers along with some things that might not come to mind.


Reusable water bottles can make a huge difference for someone struggling to stay hydrated. It’s tough to drink enough water when there are so few public drinking fountains and you can’t stop in to a café for a warm up and a hot drink.


For a homeless person, owning an insulated cup means that when someone offers a coffee, you have a way to keep it hot while you drink it.


Backpacks help keep belongings together and can be used as a pillow, and small things like lip balm and moisturizer can prevent painful chapped lips and skin.



Photo by: Ken Harasym


Here in Winnipeg, helping someone else survive in the extreme cold can be as simple as donating some common household items or winter clothing to a shelter or support location like Siloam Mission, the Main Street Project, Just a Warm Sleep, the Fountain Street cupboard, Got Bannock, or Koats for Kids (the United Way).


Contributor: Mary Robinson - Council of Canadians Winnipeg Chapter Chair

Public Transit Action Alert

Posted by Winnipeg Chapter on December 6, 2017 at 7:40 PM Comments comments (3)

After Manitoba’s provincial government decided to end their funding guarantee for public transit, the City of Winnipeg was faced with a huge budget shortfall for public transit service.




The City’s budget will be voted on at the December 12 council meeting, and if the current proposals are approved, the result will be far fewer buses, longer waits, and higher bus fares.


If you’d like to know more, Functional Transit Winnipeg has detailed information on the problems and solutions facing our public transit system.


Right now, we have to take action and let city council know that a good public transit system is vital to our city.


Buses are:

  • better for our infrastructure (they create far less wear-and-tear on the roads than cars do),

  • better for the environment (lower emissions), safer (accident rates plummet when there are fewer cars on the road), and

  • better for the economy (more people can get to work, shopping, and life events).

It’s time to take public transit seriously in Winnipeg and make our city a truly livable city for everyone.


Here are some actions to take now
• URGENT - the timeline is short •

  • Functional Transit Winnipeg is organizing handing out leaflets downtown on Friday Dec 8 and Monday Dec 11 from 4 PM to 6 PM. We would like volunteers to assist with this if possible. [CONTACT: Joseph Kornelsen 204-232-2023 | joseph.kornelsen@functionaltransit.com

  • Call or email your city councillor to voice your opposition to raised fares and schedule cutbacks.

  • Call or email your city councillor to voice your support for a suspension of the council meeting rule that limits delegations for and against an agenda item to two. The suspension would apply to the Dec 12 Council meeting, and would allow many more concerned citizens to speak on this vital issue.

Direct action suggestions

  • always ask for a transfer. If you don't use it, offer the transfer to someone at the bus stop when you are done your trip.

  • Participate in the Sardines Award. The winner will receive a free January bus pass. Post about your crowded bus on Twitter and Facebook, use the hashtag #sardinelife and tag @mayor_bowman for a chance to win a January bus pass.


NEB Energy East hearing process survey

Posted by Winnipeg Chapter on July 24, 2017 at 8:30 PM Comments comments (0)

The National Energy Board is asking for public feedback on their Energy East hearing process. Anyone can submit answers to the survey questions after completing a simple and quick registration.


Here is the survey website


This is a great opportunity to once again tell the NEB how dangerous the pipeline will be. Here in Winnipeg, we are still deeply concerned about the contamination risk to the aqueduct and to the many other rural drinking water supplies.


According to the NEB website, the results will be used to help the Board design a better hearing process.


“A team of four Board Members, who are independent from the Hearing Panel, will gather the comments into a report. This report will be filed on the official record for the Hearing Panel to consider as they design the hearing process.”


Here we have listed the questions and some suggested answers. Feel free to address your own concerns in your own words too!


QUESTION 1. Are there any local values, perspectives or concerns that the NEB should be aware of to design the hearing process?


Suggested Answers:


Much of the length of the Winnipeg aqueduct and many other rural drinking water supplies are in danger of contamination from an oil spill from the Energy East pipeline. The direction of groundwater flow adds to the always-present concern about leaks. Much of the area crossed by the pipeline is swampy.


QUESTION 2. Do you have any comments regarding the NEB hearing process and/or matters of particular interest within the Board’s mandate of the Energy East and Eastern Mainline hearing that you think the Panel should consider?


Suggested Answers:


The Board should consider…


... the domino effect that could occur if a natural gas line in the same corridor as the conversion portion of the Energy East line explodes. A gas line explosion could potentially rupture and ignite the oil line.


...measures to investigate and mitigate riverbank instability such as the situation which caused the Husky Oil spill in 2016.


...complete acknowledgement and discussion of systemic problems: sulfur management of bitumen and sour oil, emissions from hydrocarbon processing plants, and upstream and downstream greenhouse gas emissions.

 

....upgrading current Commenters to Intervenors if they originally applied to be Intervenors because of climate concerns


QUESTION 3. What are the barriers (if any) that currently impact your ability to participate in the hearing process?


Suggested Answers:


I applied to be an official participant (Intervenor or Commenter), but I wasn’t accepted because of the restrictions. I think all Canadians are directly affected by increased fossil fuel and pipeline development. All Canadians should be able to participate in the hearing.


I wanted to apply to be an official participant, but the application process was too intimidating and complicated.


Finding up-to-date information on pipelines is difficult, and too much of it is never made public. For instance, I recently heard that the NEB is allowing pipeline companies to keep repair locations secret.


I would like to see frequent plain-english communication from the NEB about pipeline projects and current issues.


QUESTION 4. If the NEB offered issue-specific workshops, what issue(s) would you most like to explore?


Suggested Answers:


I’d like to find out details of plans to protect water and water crossings.


I’d like to find out details of emergency response plans for measuring toxic fumes and protecting first responders and citizens when toxic fumes are present.


QUESTION 5. How could Expanded Engagement Board Members best engage Canadians regarding the Energy East project? (e.g., organization of regional meetings or online engagement activities)


Suggested Answers:

 

I would like the NEB to provide…


... public online access to complete responses to Information Requests, press releases, and news. as well as an easy front page index to find the information.  

...ongoing collation of Information Requests and responses into plain english explanations


...regular interactive webinars to help citizens fully understand issues and technical information


Some helpful resources:

Energy East Pipeline in Manitoba: Avenues for Action

Potential Impacts of the Energy East Pipeline On the City of Winnipeg

canadians.org/energyeast

NEB  Energy East Process Survey

Drill for Heat not Oil

Posted by Winnipeg Chapter on January 15, 2017 at 11:30 PM Comments comments (2)

The fossil fuel industry has left behind thousands of abandoned wells in Alberta. The wells have the potential to produce enormous amounts of geothermal energy that is clean, green, and sustainable. Using abandoned oil wells to reach some of Canada’s abundant geothermal energy means producers wouldn’t have to pay for expensive drilling: the wells are already there. They’re a nearly perfect transition tool, a made-to-order piece of the reject, reduce, reuse, recycle puzzle that clean energy advocates are assembling from the wreckage of fossil fuel use.


Chapter member and scientist Dennis LeNeveu explains the basics of geothermal energy and how it could work here in Canada.


Glossary of terms:


Enhanced Geothermal System (EGS) is a man-made reservoir, created where there is hot rock but insufficient or little natural permeability or fluid saturation. In an EGS, fluid is injected into the subsurface under carefully controlled conditions, which cause pre-existing fractures to re-open, creating permeability.”


Capacity factor of a power plant is the ratio of its actual output over a period of time, to its potential output if it were possible for it to operate at full nameplate capacity continuously over the same period of time.


___________________________________________________________________

Dennis LeNeveu, a retired biophysicist who is deeply concerned about tar sands and pipeline expansion, is an active member of the Council of Canadians Winnipeg Chapter. This is the second in a series of blogs by Dennis addressing various issues that are too often overlooked in media coverage of pipelines.

___________________________________________________________________


D.M. LeNeveu - 16 December 2016

Imagine an affordable, inexhaustible electrical power source with an over 90% capacity factor, minimal environmental impact and a tiny surface footprint. This source is geological heat reservoirs, something Canada has in abundance. In 2011, Natural Resources Canada (NRCAN) released a Geological Survey of Canada report that looked at geothermal potential in Canada. The report is clear: despite obstacles to developing many of the sources, deep geothermal power is available and would offer a significant benefit for Canada’s transition to clean energy.

  • “Canada's [deep] geothermal power exceeds one million times Canada's current electrical consumption, although only a fraction of this can likely be produced.”

  • “As few as 100 projects could meet a significant fraction of Canada’s base load energy needs.” 1

Deep geothermal power is not to be confused with shallow geothermal heat systems. Shallow systems use heat pumps to take advantage of constant shallow subsurface temperature. Deep geothermal power uses boreholes to extract heat from hot brine reservoirs found at a depth of from 700 to 4000 m in many areas of Canada. In a few locations, primarily in BC, shallow hot springs could be used. 2


Geothermal power is a developed technology that is used worldwide. 3 Most would think of Iceland, a country that uses abundant near-surface volcanic heat for power generation and heat. Other power plants include the over fifty-year-old 835 MW Geyser power plant in California that uses steam from 350 wells to turn turbines. Withdrawn water is recharged by injecting wastewater from regional wastewater treatment plants.4


Binary Cycle Power Plant (Figure 1)


More advanced “binary cycle systems” use a closed loop. Heat from hot brine in turn heats a second liquid (an organic fluid) to turn it to steam. The steam is used to drive turbines to produce power. Both the brine and the second liquid remain in their own closed loops and are reused. (Figure 1). 5


  • The hot brine is pumped to the surface and circulated through a heat exchanger to vaporize the organic fluid,

  • The organic fluid) is used to drive a power turbine,

  • The brine is reinjected to the reservoir,

  • The organic vapour is liquefied in cooling towers or in heat exchangers cooled with surface water,

  • The organic fluid returns to the brine heat exchanger to be re-vaporized and continue the cycle,

  • The boiling point of the organic fluid can be much lower than that of water, allowing for the use of reservoirs with temperatures less than 100 °C, 6

Alternatively, the organic fluid can be pumped through a borehole to the deep, hot reservoir. Heat can be withdrawn from the reservoir from a heat pipe that vaporizes the organic fluid at depth. The hot vapour is returned to the surface to turn turbines, liquefied in a heat exchanger, and pumped through the closed loop back to the heat pipe to continue the cycle. 7


Image: U.S. Department of Energy (Figure 2)


In the binary method, potential contaminants from the deep reservoirs (such as brine and heavy metals) are returned to the deep reservoir; with the heat pipe method, contaminants remain in place. There is a very small potential for environmental detriment from contaminants in the brine from a leak in the primary loop.



Distribution of geothermalpotential in Canada based on end use. (Figure 3)


As shown in Figure 3, significant deep geothermal resources occur in B.C. Alberta, the Yukon, southwestern N.W.T, Saskatchewan, southwest Manitoba, the Gaspe peninsula, and New Brunswick.1  These resources are virtually ignored and remain undeveloped in Canada.

 

B.C., which has the highest grade potential geothermal power, already has abundant hydroelectric power. The recent investment in the site C dam leaves little opportunity for exploitation of geothermal power. Some studies have shown the equivalent power from geothermal could have been done more cheaply with far less environmental impact. 8


Impediments to large scale geothermal exploitation in Canada include: 9


  • Geothermal reservoirs in the Yukon and N.W.T. are remote from power infrastructures.

  • Geothermal reservoirs in the Western Canadian Sedimentary Basin coexist with substantial oil and gas deposits that have a higher energy density and a greater short term return on investment. Oil companies with the technology to drill deep are invested in and have the expertise for the fossil fuel extraction, not geothermal.

  • Geothermal reservoir development has significant up front costs and risk with a long payback period.

  • Hot brine could be lost through leakage into formations disabling the resource.

  • Similar to new promising oil and gas reservoirs, geothermal reservoirs can prove to be inadequate.

  • Government support comparable to the fossil fuel industry is usually unavailable, and regulatory and permitting impediments exist.

The current tiny geothermal investment in Canada includes a 15 MW plant to be constructed in 2017 at Laytong hot springs about 10 km south of Terrace B.C. A consortium of Kitselas First Nation and Borealis Geopower has purchased for $100,000 the subsurface rights to develop the geothermal power. 10, 11


In 2010 Saskatchewan a start up company, DEEP, received a $2 million funding commitment from NRCAN and the government of Saskatchewan to develop geothermal power from a vast three kilometre hot deep aquifer near Estevan. 12 The first well, to be drilled in 2017, is expected to produce 5 MW of power with further development expected. 13


This can be compared to the 1.4 billion in government funding swallowed up by 110 MW coal fired carbon capture boundary dam power plant in Saskatchewan. This plant is billed as clean coal even though the captured carbon dioxide is to be sold for enhanced oil recovery that will generate more carbon dioxide through the burning of the recovered oil. 14 The waste streams from the toxic amines used in the process and the recovered sulphur from the coal are conveniently ignored.


Similar chemicals used in removing carbon dioxide and hydrogen sulphide from natural gas have already poisoned drinking water in Alberta and elsewhere. 15, 16 It is claimed that the sulphur recovered from the coal will be sold to generate a profit. 17 This is hard to imagine given the massive mountains of sulphur already stockpiled from the Athabasca bitumen sands and from sour oil and gas processing plants all over Western Canada. 18

 

Many oil and gas wells over the Western Canadian Sedimentary Basin, including the Bakken, inject huge amounts of hot produced wastewater into deep reservoirs. 19 These hot fluids could be potentially used to generate electricity in coproduction with the oil and gas. This is undeveloped technology that is viewed as having uncertain and comparatively small returns on investment so remains moribund.



Abandoned Oil and Gas Wells


Similarly, some of the thousands of abandoned oil and gas wells that are now a significant liability could be used for geothermal power. The high cost of drilling could be avoided by developing these wells. 20, 21


To realize the full potential of deep geothermal power would require initiatives by both the public and government. If the full environmental costs of fossil fuels were born by the industry, and global emissions curtailed to combat climate change, market forces could drive an explosion of geothermal power.


Measures to enable this transition would include a price on carbon, polluter funded fossil fuel waste treatment and disposal, double walling of pipelines and hard caps on emissions. Waste treatment would include industry funded treatment and isolation from the environment of the huge volume of toxins in the bitumen waste impoundments in the Athabasca sands.


The injection of sulphur waste in the form of acid gas containing deadly toxic hydrogen sulphide gas into oil and gas fields that will eventually leak should be stopped. 22 Alternatives include dissolution of the acid gas in produced waste water and stabilization of the sulphur in the form of sulphur salts such as calcium sulphate. 23, 24


Governments often react and follow rather than lead. Public awareness and advocacy for this valuable and environmentally benign resource might help to get the ball rolling. The most feasible economically viable option for large scale uninterruptible low carbon power is geothermal power. Geothermal power can be introduced incrementally well by well each having a relatively low cost and low environmental impact compared to large scale hydro, nuclear power or carbon capture. 25


What are we waiting for Canada? Get on board and be a world leader in geothermal power. Make us proud to be Canadians once more rather than shameful purveyors of climate, clean air and fresh water destroying, oil, natural gas and bitumen.

 

References

1. ftp.maps.canada.ca/pub/nrcan_rncan/publications/ess_sst/291/291488/of_6914.pdf

2. pubs.geothermal-library.org/lib/grc/1030313.pdf

3. www.energybc.ca/cache/hightempgeo/hightempgeo2/www.bcsea.org/learn/get-the-facts/renewable-energy-technologies/geothermal-power.html

4. www.energy.ca.gov/tour/geysers/

5. sistem-tenaga-listrik.blogspot.ca/2011/05/geothermal-energy-plt-panas-bumi.html

6. large.stanford.edu/courses/2011/ph240/yan2/

7. www.geothermal-energy.org/pdf/IGAstandard/WGC/2000/R0427.PDF

8. www.ecowatch.com/david-suzuki-tapping-earths-abundant-geothermal-energy-1882200232.html

9. www.desmog.ca/2014/02/26/top-5-reasons-why-geothermal-power-nowhere-canada

10. www.terracestandard.com/news/249147481.html

11. borealisgeopower.com/projects/lakelse-geothermal-kitselas-borealis-geopower/

12. www.theglobeandmail.com/report-on-business/breakthrough/can-geothermal-industry-gather-steam/article15134237/

13. www.thinkgeoenergy.com/saskatchewan-geothermal-project-to-start-drilling-in-february-2017/

14. reneweconomy.com.au/is-the-boundary-dam-ccs-plant-in-canada-really-a-success-story-32486/

15. www.esaa.org/wp-content/uploads/2015/01/WaterTech2008-Presentation26.pdf

16. www.cbc.ca/news/canada/edmonton/alberta-government-admits-it-knew-of-earlier-sulfolane-leak-1.2633095

17. www.sulphuric-acid.com/sulphuric-acid-on-the-web/Acid%20Plants/SaskPower.htm

18. www.businessinsider.com/there-are-mountains-of-sulfur-growing-in-the-oil-sands-just-waiting-for-demand-to-increase-2012-4

19. www.bloomberg.com/news/articles/2015-04-22/turning-bakken-oil-well-waste-water-into-clean-geothermal-power

20. www.albertaoilmagazine.com/2016/04/alberta-site-canadas-first-abandoned-oil-well-geothermal-conversion/

21. www.sciencedirect.com/science/article/pii/S096014811100574X

22. onlinelibrary.wiley.com/doi/10.1002/ghg.1271/abstract

23. www.ogj.com/articles/print/volume-96/issue-31/in-this-issue/production/injecting-acid-gas-with-water-creates-new-disposal-option.html

24. www.sciencedirect.com/science/article/pii/S0360544209005118

25. www.theguardian.com/environment/damian-carrington-blog/2011/jan/18/geothermal-energy-nuclear

 


Pipeline Problems: The Husky Oil Spill Investigation

Posted by Winnipeg Chapter on November 29, 2016 at 1:40 PM Comments comments (1)

___________________________________________________________________

Dennis LeNeveu, a retired biophysicist who is deeply concerned about tar sands and pipeline expansion, is an active member of the Council of Canadians Winnipeg Chapter. This is the first in a series of blogs by Dennis addressing various issues that are too often overlooked in media coverage of pipelines.

___________________________________________________________________

 

D.M. LeNeveu - 28 November 2106

 

The Husky Oil accident report of November 17, 2016, attributed the oil spill on the North Saskatchewan River to ground movement following heavy rains. The National Observer reports that the pipeline was built on unstable ground.


The failure was likely due to gradual creep rather than a one time, rare, event as the report claims. It appears that faulty trench infill allowed water to flow down the pipeline trench. Water flowing in the pipeline trench likely contributed to instability, failure and spill movement to the river. Proper maintenance should have prevented water from channelling down the trench and detected the slope movement that led to failure1


The Saskatchewan Ministry of Economy plans to a release its own report on the spill of the provincially regulated Husky oil pipeline. 2


Failure in the thousands of pipelines in Saskatchewan is common.

● In 2011 there were 2,062 oil and gas pipelines and 68,000 flow lines in the province. ( Flow lines are narrow lines which are used to transport oil and gas from the wellhead to storage or other facility.) 3

● There have been 8,360 spills in Saskatchewan since 2006, of which Husky is responsible for 1,463.

● In Alberta, there have been 28,666 crude oil spills in the last 37 years. Cumulative effects from all these pipeline spills would be expected but have not been investigated. 4

 

Typically, the Saskatchewan provincial government allows the industry to investigate its own spills. The government conducted only 78 provincial investigations in 2015. 5 It is unknown if the provincial government employed independent geotechnical experts to investigate the spill site or if it is primarily relying on information supplied by Husky Oil.


A 2012 report from Saskatchewan's auditor found that while the Ministry of the Economy regulated the construction of new pipelines, it had "no documented processes to regulate existing pipelines." 6


Why was the North Saskatchewan spill not investigated by the NEB and the Transportation Safety Board (TSB)?

 

The NEB’s main purpose is “to promote safety and security, environmental protection and efficient infrastructure and markets in the Canadian public interest for pipelines that cross international borders or provincial and territorial boundaries.” 7 The TSB is an independent agency that advances transportation safety by investigating occurrences in the marine, pipeline, rail and air modes of transportation. 8

 

The NEB Act defines a pipeline as:

 

“a line that is used or to be used for the transmission of oil, gas or any other commodity and that connects a province with any other province or provinces or extends beyond the limits of a province or the offshore area as defined in section 123, and includes all branches, extensions, tanks, reservoirs, storage facilities, pumps, racks, compressors, loading facilities, interstation systems of communication by telephone, telegraph or radio and real and personal property, or immovable and movable, and works connected to them.” 9

 

The failed Husky Oil line (and other pipelines in the Saskatchewan gathering system) deliver oil to Albertan terminals that supply export pipelines like the proposed Energy East pipeline. The Energy East pipeline will originate from a terminal in Hardisty, Alberta.

 

The 1.3 km replacement lateral line connecting the Husky Hardisty terminal to the Express Pipelines Hardisty terminal is completely with the province of Alberta. In 2010, Express Pipelines applied for NEB construction approval of the replacement lateral after the previous lateral was abandoned due to severe internal corrosion over the majority of the pipeline's length. 10

 

Why do not all pipelines that are wholly within provincial boundaries, and that connect to export pipelines (like the Husky lateral connecting to Express) require NEB approval, regulation, hearings, and EA according to the NEB Act?


The Husky heavy oil that spilled into the North Saskatchewan contains up to 5000 ppm deadly toxic and corrosive H2S. 11

 

Could it be that the original Express Pipeline lateral succumbed to internal corrosion due to the H2S content from the same heavy oil? Would not all export pipelines that carry sour crude oil containing H2S and other corrosive substances be subject to the same risk of internal corrosion and public exposure to deadly toxic fumes upon spillage? The Enbridge mainline and the proposed Energy East would carry these products.

 

Was the late deployment of booms in the North Saskatchewan oil spill due in part to the toxic H2S content? 12 During the Husky oil spill, there is no indication that toxic fume concentrations such as H2S and benzene were measured near river bank occupation and necessity of evacuation determined. Why not?

 

River bank instability, a common problem in rivers across the country, has been the cause of numerous pipeline accidents. The 2016 North Saskatchewan spill, the 2015 Yellowstone River spill, 13 the 2012 the Red Deer River spill in Alberta, 14 and the 1996 natural gas explosion on the La Salle River in Manitoba were all caused by river bank instability or river scour. 15

 

In the Energy East application, monitoring and assessment of bank stability has been documented but no extensive bank stability measures or maintenance have been definitely planned or executed. 16 For instance, riprap laid on the La Salle and Red Rivers in past years is no longer evident.

 

It is difficult to believe that across the 4600 km length of the Energy East pipeline with hundreds of river crossings that major bank reconstruction and stability measures would not be required or already in place, maintained and independently inspected.

 

Would not the Husky oil spill experience demonstrate utter failure on the part of the pipeline industry and the regulators to maintain environmental protection and to safeguard drinking water supplies? After completion of the quickly forgotten Husky appeasement report will anything change?

 

I will discuss the sulphur and H2S problem in sour crude oil carried in pipelines, river bank stability and other aspects of pipeline safety in more detail in future blogs.

 

Stay tuned.

 

References

 

1. www.nationalobserver.com/2016/11/22/news/exclusive-new-photos-show-husky-likely-could-have-prevented-oil-spill-say-experts

2. www.theglobeandmail.com/news/national/husky-oil-spill-has-critics-questioning-independence-of-saskatchewans-regulatorysystem/article31585612/

3. ca.news.yahoo.com/husky-oil-spill-more-2-211610946.html

4. leaderpost.com/opinion/columnists/saskatchewan-oil-spill-shows-need-for-better-regulation-move-away-from-oil

5. www.cbc.ca/news/canada/saskatoon/university-of-saskatchewan-engineer-husky-oil-spill-instability-1.3858200

6. www.bnn.ca/saskatchewan-has-never-physically-inspected-husky-pipeline-report-1.537286

7. www.neb.gc.ca/nrg/ntgrtd/trnsprttn/2016/ppln-cpcty-eng.html

8. www.tsb.gc.ca/eng/

9. laws-lois.justice.gc.ca/eng/acts/N-7/page-1.html?txthl=definitions+pipelines+pipeline#s-2

10.docs.neb-one.gc.ca/ll-eng/llisapi.dll/fetch/2000/90464/90552/92264/644016/643871/A1V4J0_-_Application_s__58_1_Husky_Lateral_Oct__21_2010.pdf?nodeid=643878&vernum=1

11. huskyenergy.msdsbinders.com/CustomBinder/ViewMsds/2e12540d-7507-44cd-96fc-96d9fe74464b/20457/HLU%20Blended%20LLB%20Heavy%20Crude%20Oil%20-%20Husky%20Oil%20Operations
%20Limited%20(Husky%20Oil%20Marketing%20Company

12. www.standard.net/Business/2016/07/23/Husky-hits-snag-in-efforts-to-contain-Saskatchewan-oil-spill

13. insideclimatenews.org/news/06022015/yellowstone-oil-spills-expose-threat-pipelines-under-rivers-nationwide

14. www.huffingtonpost.ca/2012/06/08/alberta-oil-spill-red-deer-river_n_1581008.html

15. tsb.gc.ca/eng/rapports-reports/pipeline/1996/p96h0012/p96h0012.asp

16. docs.neb-one.gc.ca/ll-eng/llisapi.dll/fetch/2000/90464/90552/2432218/2540913/2543426/2858155/A74256-4_NEB_5.20-1_Part3of8_-_A4V8G9.pdf?nodeid=2858636&vernum=-2


Photo by: Paul S. Graham

 

Environmental Assessment Review Panel in Winnipeg

Posted by Winnipeg Chapter on November 17, 2016 at 5:00 PM Comments comments (0)

The Minister of Environment and Climate Change has established an Expert Panel to review federal environmental assessment processes under the current Canadian Environmental Assessment Act (CEAA). The Environmental Assessment review panel is traveling to centres across Canada to listen to members of the public present their concerns and information.




Each event includes an afternoon of short citizen presentations to the panel and an evening of less formal engagement. The Winnipeg sessions took place on Wednesday, November 15, and members of the Council of Canadians - Winnipeg Chapter (Doug Tingey and Dennis LeNeveu) participated in both the panel presentations and the evening dialogue.

  

Many of the presenters chose to include a written submission of their comments to the panel. Dennis LeNeveu’s complete presentation (see below) is available on the panel website along with submissions from a wide variety of citizens, government departments, and NGO’s from across the country.

 

Of special interest, Council of Canadians Water Campaigner Emma Lui and former ELA advocate Diane Orihel submitted their presentation "Environmental Assessment and Water Protection" to the Edmonton session of the panel.


We’ve included here a quick overview of the main points of Dennis’ message, in which he raises questions about the current environmental protection process in Canada and provides recommendations for improvement.

  • The proponent (TransCanada, in the case of Energy East) supplies the information for the EIS that focuses on new pipeline construction.
  • There is constant repetition of the false claim that oil spills are local, short term, low magnitude, reversible and easily remediated.
  • Suitability of Natural Gas pipeline and current route for oil (much of which will be sour and contain deadly toxic and corrosive H2S) is not considered.
  • Those accepted as “directly affected” Intervenors in the National Energy Board (NEB) review process often do not have the knowledge to analyze the complex processes involved, but are underfunded, and unable to access expert help.
  • The scope of assessment is too restricted, and excludes many carbon emitting and toxic processes connected with the project.
  • Toxic legacies (tailing impoundments and processing plants, abandoned oil and gas wells, mine tailings) are allowed to increase and accumulate with no remediation.
  • Sulphur stockpiles and wells are left to leak H2S, SO2, and acid, poisoning both air and water.
  • Captured regulator allows gas contamination of private landowners’ well water, leaving individuals with no recourse but to further deplete their personal assets fighting in the courts in pursuit of justice.
  • Researchers across the United States and Canada are repeatedly finding high levels of neonics and other residues from farm chemicals and pesticides, levels that exceed vital standards set to protect aquatic life.
  • Decisions are not made according to a national carbon budget consistent with global commitments to address climate change.

 

The  Council of Canadians Winnipeg Chapter will continue to advocate for excellent environmental regulations and open, transparent, public processes for establishing those regulations. We are currently preparing a letter of comment to submit to the NEB modernization review. This separate will "examine issues that are specific to the NEB"  and will focus on regulatory processes of the NEB. Please check back here for updates.


Contributor: Mary Robinson - Council of Canadians Winnipeg Chapter Chair


________________________________________________


Presentation to the Expert Panel:
Review of CEAA Winnipeg, 16 November 2016 by D.M. LeNeveu


My experience includes participation in the 1996 national EA of the Canadian Concept for Nuclear Fuel Waste Disposal under the Seaborn panel. The Environmental Impact Statement ( EIS) was prepared by Atomic Energy of Canada at arms length from the proponent, Ontario Hydro. The multi year independent supporting research underwent rigorous peer review including an international technical review panel. I am now an Intervenor for the Energy East pipeline project whose EA conducted by the NEB pales in comparison. I will raise questions about the current environmental protection process in Canada and provide recommendations for improvement.


In the Energy East project, the proponent supplies the information for the EIS that focuses on new pipeline construction. A mantra that oil spills are local, short term, low magnitude, reversible and easily remediated is repeated as has been done in previous pipeline assessments. Evidence to the contrary, such as from the National Academy of Sciences study on dilbit, and from the Kalamazoo River oil spill is omitted.1

 

The route for conversion, determined in 1958 for gas, is not considered for suitability to oil much of which will be sour and contain deadly toxic and corrosive H2S. The risk to the over forty year old converted oil line from explosion of the adjacent natural gas lines is not considered. A double walled pipeline with leak detection at designated collection points, as is required for underground refined petroleum piping is not considered.

 

Intervention in the Energy East Project rests mainly on those directly affected who do not normally have the knowledge to analyze the complex processes involved. Funding, coordination and expertise is inadequate to conduct proper studies. Scope and interpretation of the evidence presented is at the mercy of an NEB panel that has already been forced to resign for apprehension of bias. The entire process could be disregarded in final government approval.


Only the upstream process of marine shipping is assessed. Why are gathering pipelines necessary to deliver oil to the mainlines not assessed such as the Husky sour oil line containing up to 5000 ppm deadly toxic H2S gas? 2 The Husky oil spill contaminated about 500 kilometres of the North Saskatchewan River and incapacitated major drinking water supplies.



Why are other processes connected with the project such as extraction of oil and bitumen by fracking, strip mining, and thermal processes not assessed? Why is produced water injection, flaring of sour solution gas, field spreading of drill mud and disposal of waste from crude oil and bitumen extraction not assessed? Why are emissions from processors, upgraders, and refineries that have been implicated in heavy metal contamination, respiratory illness, cancer and foetal feminization not assessed? 3,4,5

 

Why did industry monitoring of the massive bitumen tailing impoundments in the Athabasca sands report that environmental releases were no more that naturally occurring? Independent studies by Schindler and others 6 have clearly shown toxic releases far above background can be traced directly to tailing impoundments and processing plants. Studies by Stephane McLachlan 7 from the University of Manitoba have shown these toxins are accumulating in the food chain.


Why are the toxic impoundments allowed to increase when no effective remediation has been demonstrated? The impoundments will likely be left as a massive toxic legacy to the taxpayers of Canada. Other toxic legacies allowed to accumulate include thousands of abandoned oil and gas wells and mine tailings such as from the abandoned Giant Mine in the Yukon.

 

Sulphur extracted from sour gas, sour oil and bitumen all over western Canada is accumulating in massive stockpiles or injected in the form of H2S gas often into old oil and gas wells with no EA.8, 9 Why should these stockpiles and wells be left to leak H2S, SO2, and acid, poisoning both air and water?


In 2008, an Alberta Environment survey found 17% of the water wells in the area of shallow coal bed methane extraction were contaminated with gas.10 Why was the gas deemed as naturally occurring, despite isotopic signatures consistent with coal bed methane and the presence of nitrogen gas compressed to fracture coal seams? One landowner, Jessica Ernst, whose well was gas free prior to coal bed methane is suing the gas operators and the Alberta regulator for well water contamination.11 Why should her personal assets be depleted by court costs through interminable hearings? No individual can stand against this conspiracy by industry, captured government regulators and courts to protect and encourage the oil and gas industry.


Why, according to the World Health Organization, is carcinogenic benzene from petroleum detected in 50–60% of potable water samples taken at 30 treatment facilities across Canada? 12


Why are farm chemicals and pesticides that are carcinogenic and hormone and endocrine disruptors allowed? Researchers across the United States and Canada are repeatedly finding high levels of neonics and other residues that exceed vital standards set to protect aquatic life.13


The EIS for the BC LNG project, prepared by the proponent, Pacific NorthWest owned by Malaysian Petronas, focussed only on the LNG plants. One condition of approval was a plant emission cap of 4.3 million annual tonnes of greenhouse gas. Upstream fugitive emissions from fracked wells, compressors, pipelines, sour gas plants, and CO2 in raw natural gas have been estimated to be up to 155 million annual tonnes of greenhouse gas by 2020, far more than the LNG plant emissions.14 Why were the adverse environmental effects of upstream processes not assessed?


A climate impact analysis by Environment and Climate Change Canada for the upstream emissions for the Enbridge line 3 replacement,15 was based on NEB forecasts of increasing global demand for oil. Why was the climate analysis not based on a national carbon budget consistent with global commitments? The combined upstream emissions from all the proposed pipeline expansion projects and the BC LNG project could not possibly meet a national carbon budget.


EA in Canada is clearly broken and biased toward industry.


Recommendations

Context and Conduct of Environmental Assessment

A permanent independent Federal Environmental Assessment Agency funded by proponents should be formed that conducts the EA based on cumulative effects of the entire project from extraction to usage and determines limiting terms and conditions. EA must be done by independent unbiased experts selected and managed by the federal assessment agency. Legacy projects approved by provincial licensing that were not subject to EA’s should be reviewed by the agency. The amendments passed by the Harper government should be repealed.

 

Public Involvement

Public input should be an integral part of the process.

  

Coordination

Levels of government and government agencies such as NRCan, the NEB and the Canadian Nuclear Safety Commission should provide technical input where relevant.

  

Climate Change and International Obligations

A climate test should be completed first based on a national carbon budget consistent with international commitments. International trade agreements and economic effects should be considered but environmental protection should take precedent using the precautionary principle and the principle of as low as reasonably achievable.


Overarching Indigenous Considerations

Full and complete indigenous consultation and assessment of effects on traditional lands and the food chain, respecting all treaty rights should be completed under the direction of the agency.


Decision and Follow up

Final decision should rest with the Federal Government respecting all terms and conditions determined by the agency. Ongoing environmental monitoring of project effects should be conducted based on the recommendations from the agency.


Legal Challenges

Environmental lawsuits having merit as determined by the agency should proceed expeditiously with legal cost borne solely by the defendant.


References

1) www.nap.edu/21834

2) huskyenergy.msdsbinders.com/CustomBinder/ViewMsds/2e12540d-7507-44cd-

96fc-96d9fe74464b/20457/HLU%20Blended%20LLB%20Heavy%20Crude%20Oil%20-

%20Husky%20Oil%20Operations%20Limited%20(Husky%20Oil%20Marketing%20Co

mpany)

3) www.thelancet.com/journals/lancet/article/PIIS0140673606681610/fulltext

4) thetyee.ca/News/2013/10/24/Alberta-Bad-Air/

5) www.nrdc.org/experts/danielle-droitsch/mounting-evidence-tar-sands-activitycausing-

health-problems

6) www.pnas.org/content/107/37/16178.long

7) onerivernews.ca/health-study-press-release-2014/

8 - onlinelibrary.wiley.com/doi/10.1002/ghg.1271/full

9) www.businessinsider.com/there-are-mountains-of-sulfur-growing-in-the-oil-sandsjust-waiting-for-demand-to-increase-2012-4

10) aep.alberta.ca/water/inspections-and-compliance/baseline-water-well-testing-for-coalbed-methane-development/documents/CoalbedMethanePanelReview-Report.pdf

11) s3.documentcloud.org/documents/279821/ernst-well-complaint-review.pdf

12) www.who.int/water_sanitation_health/dwq/benzene.pdf

13) www.centerforfoodsafety.org/files/neonic-water-report-final-9152015_web_50152.pdf

14) www.desmog.ca/2013/05/09/bc-lng-exports-blow-climate-targets-way-way-out-water

15) www.ceaa-acee.gc.ca/050/documents/p80091/114134E.pdf

 

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