To the editor;
The Concerned Professional Engineers (CPE) are a group of registered Professional Engineers with significant experience in the design, construction, and operation of bulk export marine terminals in Canada and around the world.
As professional engineers, we understand that Canada’s oil industry requires an export route through Canada’s Pacific Coast in order to transport its valuable product to global markets. However, we also understand that these megaprojects – pipelines, terminals, and tanker shipping routes – pose significant risks to the safety of Canadians and to our natural environment. In our opinion, a strong, independent, science-based review and oversight process is required to ensure the success of these projects while risks are kept at a minimum.
We believe that the National Energy Board (NEB) has failed in its responsibility to implement such a process, particularly for the Enbridge Northern Gateway and Kinder Morgan Transmountain projects. As intervenors in the review of the first project and as commenters for the second, we witnessed firsthand the flaws in the NEB’s process. We are alarmed at the number of critical issues still left unaddressed.
Below is a brief summary of our concerns:
The proponents’ own risk analyses state that there is a 10 per cent probability in the 50-year lifetime of either project, of a marine spill greater than 5,000 cubic meters (for Northern Gateway) or 8,250 cubic meters (for Transmountain). As a comparison, the April 2015 MV Marathassa spill into Vancouver’s English Bay was estimated to be 2.7 cubic meters.
The product that will be transported, diluted bitumen, is substantially different from crude oil. Very little is known about how it will behave when spilled into a marine environment. Environment Canada’s own scientists have repeatedly questioned whether it can be cleaned up effectively at all.
Finally, we are concerned that the funding structure currently in place to pay for a spill is woefully inadequate and Canadian taxpayers are exposed to these risky projects. In contrast, the marine shipping industry is structured to limit its liability to the greatest possible extent.
Our recommendations are that alternate locations for the marine terminals must be seriously considered for both Northern Gateway and Transmountain.
For Northern Gateway, moving the terminal from Kitimat to Prince Rupert or preferably to Port Simpson would eliminate the need for supertankers to navigate 220 km of narrow fjords in the pristine Great Bear Rainforest, a waterway that will be shared every year by several hundred liquefied natural gas tankers.
For Transmountain, moving the terminal from the confined Burrard inlet to Roberts Bank, where there is already a coal superport and a container terminal, would provide a clearer route to the open ocean and allow for larger vessels to be used, significantly cutting the number of vessels travelling.
These alternatives have been proposed to the NEB, Enbridge, and Kinder Morgan many times, and each time have been disregarded without a thorough review or response. We recently put in a request to Prime Minister Trudeau to take a look at how the NEB reviews these megaprojects in hopes that information can be made available to the public.
Canada is uniquely situated to take advantage of its tremendous endowment of petroleum resources while ensuring the preservation of its environment for all Canadians, now and in the future. We hope that the new government will consider our proposals.
Brian Gunn
Concerned Professional Engineers
