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Environmental Assessment Office
PO Box 9426 Stn Prov Govt
Victoria BC V8W 9V1
March 23, 2015
RE: Woodfibre LNG project
To whom it may concern:
Thank you the opportunity to comment on Woodfibre LNG’s proposed liquefied natural gas
terminal in Squamish, B.C. If approved the Woodfibre terminal would produce roughly 2.1
million metric tonnes of liquefied natural gas (LNG), fracked gas that has been turned into liquid
by cooling the gas to -163C. The LNG would then be shipped on tankers through Howe Sound
for export.
The Council of Canadians is extremely concerned about the Woodfibre LNG terminal as well as
the other 17 proposals for LNG terminals along the Pacific Coast. We are concerned because of
the threat to public safety, water and health impacts of fracking and climate change risks. Free,
prior and informed consent of Indigenous peoples must be obtained. We also have concerns
about B.C. weakened regulatory system and its ability to adequately assess risky projects. For
these reasons we oppose the project and urge the B.C. government to reject Woodfibre’s
application in order to protect water sources, ensure public safety and curb climate change.
Public safety risks
Retired KPMG consultant Eoin Finn has pointed to the heightened risk of LNG tankers. They are
categorized under Class 2 under the Maritime Dangerous Good Code for Shipping (1 being most
dangerous, 9 being least dangerous). LNG tankers are massive vessels at 300 metres long (the
equivalent to three football fields), 40 metres wide and 30 metres tall. LNG tankers are typically
150,000 tonnes DWT (deadweight tonnage) with a capacity to carry 60,000 tonnes of LNG. They
are twice as big in width and height as a B.C. ferry and pose a unique threat to coastal
communities if there were to ever be an explosion or accident. Will the B.C. government be
conducting a study on the potential scenarios of a LNG tanker accident and of risks to nearby
populations of Squamish, Bowen/Bower Island, West Vancouver and other nearby
communities?
The Society of International Gas Tanker and Terminal Operators (SIGTTO) have advised against
locating LNG plants on long, narrow inland waterways to avoid greater navigation risk. Howe
Sound could constitute a narrow inland waterway. Why is the B.C. government considering
going against the advice of SIGTTO, which is based on decades of engagement in the LNG
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industry and involves major LNG players, by siting an LNG terminal and having tankers run
through in Howe Sound?
Water and health impacts of fracking
To cool some of the LNG liquefaction plants, seawater will be used which will have a significant
impact on the surrounding coastal waters. The Squamish Woodfibre LNG plant will be cooled
by sea-water from Howe Sound and every hour will discharge 17,000 tonnes of water - enough
to fill seven Olympic-sized swimming pools - back into the Sound at 10°C above that of the
intake. Hypochlorite will be added to the discharge to reduce growth of marine fouling
organisms such as mollusks and oysters. This mixture will be discharged into Howe Sound 24
hours per day year round.
Will the B.C. government undertake any studies on the impacts of adding a chlorinated product
into the water and the increased in temperature to the marine ecosystem of Howe Sound? Will
the B.C. government also be conducting any studies on the sound and vibrational pollution
impacts on herrings, porpoises, whales and other marine life?
The gas needed for only five LNG terminals would require an estimated 582 billion litres of
water from B.C.'s rivers, lakes and streams, the amount of water that would supply the
population of Greater Vancouver for two years.
Fracking has devastating impacts on local watersheds and ecosystems. More than 600
chemicals have been used in fracking, and many of these chemicals have been linked to cancer,
mutations, and impacts to the nervous, immune, and cardiovascular systems. The boom in
proposed Liquefied Natural Gas (LNG) developments could result in a 600% increase in fracking
on the Fort Nelson First Nation’s already heavily impacted territory. Concerns over water
withdrawals and cumulative impacts on Treaty 8 territory have been ignored by the BC
government, which continues to approve fracking projects at a breakneck pace.
Climate change risks
B.C.’s LNG ambitions would require 50,000 new fracked wells by 2040 – twice as many gas wells
as have been drilled in the entire 60 year history of the B.C. gas industry. Clark’s promise of
"150 years" of prosperity will come at the expense of our climate, watersheds and public safety.
Since oil prices dropped, Clark has backpeddled on her promotion of LNG. However, companies
and the province are still pursing LNG terminal agreements.
The combined impacts from fracking, fracked gas pipeline construction, gas liquefaction and
export make LNG a major contributor to global climate change. The gas boom in British
Columbia could result in an additional 73 million tons of greenhouse gas emissions per year,
which would amount to about the same as Alberta’s tar sands as early as 2020.
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According to retired KPMG consultant Eoin Finn, if the LNG terminai is powered by gas (10% of
supply), the terminal would release 735,000 T/a CO2 which is the equivalent to the emissions of
137,000 vehicles. If terminal is powered by electricity (140MW), it would release 147,000 T/a
CO2 which is the equivalent to the emissions of 31,000 vehicles.
Five LNG terminals alone would more than double BC’s current climate footprint. The emissions
from the 12 LNG terminals proposed for Prince Rupert and Kitimat would bring acid rain and
serious air pollution to the region and impact the health of residents and surrounding ecology.
A few of these LNG plants will produce the same amount of emissions as the entire city of
Vancouver.
Free, prior and informed consent of Indigenous peoples
Some members of Squamish Nation are opposed to the Woodfibre LNG terminal as well as its
associated FortisBC pipeline.
Fracking projects are happening on Indigenous lands without respect for First Nations Treaty
Rights and Title. As noted in the Assembly of First Nations resolution on a Moratorium on
Hydraulic Fracturing, the UN Declaration of the Rights of Indigenous People states:
“States shall consult and cooperate in good faith with the indigenous peoples concerned
through their own representative institutions in order to obtain their free and informed
consent prior to the approval of any project affecting their lands or territories and other
resources, particularly in connection with the development, utilization or exploitation of
mineral, water or other resources.” (Article 32 – 2)
Fracking projects are taking place in Indigenous communities, some of which are already
struggling to have access to clean and safe drinking water. Governments must obtain free, prior
and informed consent before proceeding with fracking and related projects.
The promise of jobs
Prior to the drop in oil prices Premier Christy Clark boasted that the LNG industry would bring
100,000 jobs to the province. However, jobs in the oil and gas sector still only account for under
1% (0.64%) of jobs in British Columbia.
Woodfibre LNG states that its project will create “direct employment for 102 full-time
equivalents.” However, local Squamish resident Tracey Saxby has noted that only 4.3 per cent
of jobs will be for locals in the Squamish/Whistler region. Saxby has highlighted that this only
equals 38.5 jobs for locals each year during the two-year construction period.
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B.C.’s weakened regulatory framework
The B.C. government has dismantled key pieces of legislation and protections in B.C., such as
overhauling the Agricultural Land Reserve and passing Bill 4, the Park Amendment Act, that
opens up protected land to industrial development. The Council of Canadians is deeply
concerned that the scaling back of environmental and other safeguards will allow the B.C.
government to rubber stamp and fast-track LNG projects and fracked gas pipelines.
Community concerns and resistance
Hundreds of residents attended public forums on LNG in Vancouver, Victoria, Powell River,
Squamish, Delta and Comox Valley. Community opposition to the LNG terminals is building in
the province. Several municipalities have passed resolutions calling for a ban on LNG tankers
along the Pacific Coast.
The province needs a long-term energy plan that does not put public safety and water sources
at risk. B.C. needs to be a leader in curbing climate change and it can do so by rejecting
Woodfibre LNG terminal. The province must foster renewable energy and sustainable green
jobs and paving the way for a clean energy future that protects water sources and respects
Indigenous rights.
Thank you for the opportunity to comment on this important issue.
Sincerely,
Emma Lui
Water Campaigner
Council of Canadians
The Council of Canadians is Canada’s leading social action organization, mobilizing a network of
60 chapters across the country, a third of which are located in British Columbia. Through our
campaigns we advocate for clean water, fair trade, green energy, public health care, and a
vibrant democracy. We educate and empower people to hold our governments and
corporations accountable.
300-251 rue Bank St., Ottawa, ON K2P 1X3
Tel: (613) 233-2773, Fax/Téléc: (613) 233-6776
www.canadians.org [email protected]