Deadline midnight 15th October, 2015
Earlier this year, you helped us submit the most public comments for any Environmental Assessment, ever! We need your help to do that again. FortisBC has provided an alternative pipeline route and relocated the compressor station to just behind Valleycliffe that threatens our air quality, our health, and our trails.
Your input is critical! It can be as simple as stating your concerns and WHY you are opposed to the project, however, specific questions related to FortisBC's addenda have more weight. This is one of your only opportunities to hold FortisBC accountable and stop this project!
Submit your comments here by October 15th, 2015
Say why you are opposed to FortisBC's pipeline and compressor station
Check out the key concerns with this alternate route below
Share this with your friends via email and social media
List of key concerns with FortisBC's addenda
We have compiled a list of our key concerns with FortisBC's addenda below. Please feel free to cut and paste as many of these as you'd like to include. You can submit comments as many times as you like. If you have the time to submit your own comments in your own words that is even more powerful as FortisBC needs to respond to each and every comment and requests for additional information and studies.
SOCIAL LICENSE: There is no social license for this project
Communities and Regional Districts around Howe Sound have signaled strong opposition to the proposed Woodfibre LNG project by voting to ban tankers in Howe Sound and Georgia Strait, deny permits for FortisBC to drill test boreholes in the Squamish estuary, or state that the project is unsupportable as it stands. Hundreds of Howe Sound citizens have participated in rallies and events over the last 18 months to protest this unsustainable project. My Sea to Sky partnered with Concerned Citizens Bowen to deliver the Howe Sound Declaration to MLA Jordan Sturdy with over 4,330 signatures, in conjunction with Propeller Strategy who delivered their declaration with over 2,300 signatures. This project does not have the social license to proceed.
Summary of community opposition with links to municipal resolutions
Howe Sound Declaration
Propeller Strategy's declaration
GOVERNMENT REGULATION: Inability of government to monitor, enforce, and respond to issues
The Canadian Standards Association provides standards for the operation, maintenance, and decommissioning of all pipelines and compressor stations through CSA standard Z-662. These standards are regulated by the BC Oil & Gas Commission who has set up a Self-Assessment Protocol, which essentially means that industry will be monitoring their own pipelines and compressor stations. Self-monitoring industries have created several examples of accidents with resulting environmental destruction in recent years, including the Lac Megantic rail disaster and the Mt Polley tailing pond spill. There is little trust that FortisBC will monitor and maintain this pipeline and compressor station to a standard that will prevent future accidents. The risk of accidents due to poor self-regulation and government enforcement is unacceptable.
CSA standard Z-662
BC Oil & Gas Commission Self Assessment Protocol
OVERTURNING LEGISLATION: Gas pipelines can become oil pipelines
The concern that gas pipelines can become oil pipelines has been raised a lot in the last year. The BC Liberals have responded by saying that a new regulation prohibits proposed natural gas pipelines from transporting oil or diluted bitumen. The problem is that this government keeps changing their own legislation. They've already rebranded natural gas as a clean energy resource, a reversal of its earlier policy which recognized the need to shift our dependency away from ALL fossil fuels. They're also proposing to repeal the Greenhouse Gas Reduction Targets Act and replace it with a watered down Greenhouse Gas Industrial Reporting & Control Act. There is absolutely no assurance that this gas pipeline won't be used to transport tar sands oil in future. That possibility is an unacceptable risk for Squamish and Howe Sound.
HUMAN HEALTH: Air pollution from sulphur dioxide and nitrogen dioxide
The alternative compressor station proposed for Mount Mulligan will be powered by three natural gas turbines, which will create air pollution emissions of nitrogen dioxide (NO2) and sulfur dioxide (SO2), in addition to the considerable increase in these emissions proposed by the proposed Woodfibre LNG project. Emissions of NO2 and SO2 interact with other compounds to form fine particles, which can affect both the lungs and the heart. Exposure to these particles is linked to increased risk of respiratory symptoms, such as irritation of the airways, coughing, or difficulty breathing; decreased lung function; aggravated asthma; onset of chronic bronchitis; irregular heartbeat; nonfatal heart attacks; and premature death in people with heart or lung disease.
Why is this compressor station being powered by natural gas rather than electricity to minimize air pollution and ensure the health of Squamish and Howe Sound residents? I request that additional studies be conducted showing the wind and weather patterns in Squamish and Howe Sound to evaluate the potential health impact of this additional air pollution in our air shed, looking at the cumulative impact of this project, the proposed Woodfibre LNG project, and all existing and proposed sources of air pollution in our air shed.
Mills et al (2009) Adverse cardiovascular effects of air pollution. Nature Clinical Practice Cardiovascular Medicine 6: 36-44
ENVIRONMENT: Greenhouse gas emissions
The alternative compressor station proposed for Mount Mulligan will be powered by three natural gas turbines, which will create an additional 27,000 tonnes of greenhouse gases. These annual emissions of CO2 equivalent from the proposed Mount Mulligan compressor station is equal to adding over 3,500 cars to the highway, driving to Vancouver and back, every day.
Why is this compressor station being powered by natural gas rather than electricity to minimize greenhouse gas emissions? When combined with the estimated greenhouse gas emissions from Woodfibre LNG (= 142 thousand tonnes of CO2 equivalent every year), cumulative annual emissions are equal to adding over 21,500 cars to the highway, driving to Vancouver and back, every day. It is irresponsible to approve this kind of polluting industry at a time when we need to transition away from fossil fuels to mitigate the risks associated with climate change, and to reduce the economic and health impacts of air pollution in general. This is of critical importance, and neglecting to reduce greenhouse gas emissions will have extensive health and economic costs to citizens and to communities around Howe Sound.
SAFETY: Location of this high-pressure natural gas pipeline and compressor station threatens the safety of Squamish residents
While accidents are fairly rare, they do happen and when they do the results can be catastrophic causing loss of life, injuries, property damage, and environmental damage. Why is this alternative compressor station site still being proposed so close to homes and schools in the Valleycliffe neighbourhood? The pipeline route still passes through populated areas close to businesses, homes, a daycare, a playground, and our emergency response centre. The proposed siting of both the high pressure natural gas pipeline and compressor station poses an unacceptable risk to safety of people in nearby homes and businesses along the pipeline route or within 1 km of the compressor station. This risk to human life is unacceptable. We again request FortisBC to provide another alternative for both the pipeline route and the compressor station.
NOISE: Noise levels from the Mount Mulligan compressor station are unacceptable in such close proximity to residential neighbourhoods
The Mount Mulligan compressor station is proposed roughly 1.8 km from Ravens Plateau, Crumpit Woods, and Valleycliffe, in a direct line-of-sight approximately 400 metres above these neighbourhoods. FortisBC says it has modeled the noise from the three-compressor combo at Mount Mulligan and predicts it will be “less than 40 decibels” under normal conditions at a point 1.5km away from the compressors. However, these gas-turbine compressors are very similar to jet engines (GE makes them both), and have similar high-pitched whines. With the mountains and rock walls surrounding the site, noise from the compressor station is likely to impact all nearby homeowners, particularly at night when other ambient noise levels are reduced. This has been well documented for the existing Eagle Mountain compressor station in Coquitlam. The proposed location of this noisy compressor station so close to private dwellings in Squamish is unacceptable.
I request the EAO to require FortisBC to research additional options for locating this compressor station away from any residences and businesses to minimize noise pollution in Squamish. I also request additional studies to determine the impacts of noise pollution from the gas-powered compressor station on nearby residential homes and schools, which are not solely reliant on modelling.
NOISE: Squamish's Noise Bylaws must be respected
Squamish's noise regulation bylaw states that "No owner or occupier of real property shall use or permit such property to be used so that noise, sound, or vibration emanating from the property disturbs or tends to disturb the quiet, peace, rest, enjoyment, comfort, or convenience of any person or persons in the neighbourhood or vicinity." The noise levels from the proposed compressor station do not comply with this bylaw. I insist that this noise regulation bylaw be respected and upheld.
Source: Squamish Noise Regulation Bylaw No. 2312,2014
ECONOMIC: Impacts to viewscapes, wildlife, and trails from 35m - 100m wide deforestation corridor
The proposed compressor station on Mount Mulligan and the 35m - 100m wide deforestation corridor for the "Pipeline Construction Footprint" will be visible from locations throughout Squamish, and will destroy or damage significant biking and hiking trails that are regularly used by residents and visitors to Squamish for recreation. Our extensive trail network is the key reason why many people live in Squamish, and has significant recreational, cultural, and economic value both for residents and visitors. Damage to viewscapes, impacts to wildlife, and damage to our trail network will have potential impacts on Squamish’s tourism and outdoor recreation economy, and is not acceptable. I request the EAO to require FortisBC to research possible mitigation schemes, and to research alternative locations for this compressor station and pipeline out of key sightlines. I also request studies to determine the potential impact of this 47km long deforestation corridor on wildlife. I also request further studies to determine the economic impacts from the loss of trails, key wildlife habitat, and viewscapes as a result of this proposed project.
ENVIRONMENT: Disposal of tunneling debris
Boring a 4-6km long, 4.2m wide tunnel under the Squamish Estuary and through the mountain on the far side would require disposal of up to 250,000 tonnes of rock debris. The FortisBC proposal is silent on where this would be disposed of, what contaminants it contains, and how those would be handled. Where will this debris be put? How will contaminants be dealt with and contained?
ENVIRONMENT: Current regulations require FortisBC to clear a "right of way" through the estuary
FortisBC says they will apply for a “right of way” over the pipeline route. Current regulations require them to clear a right of way. FortisBC claimed at the open house that they would tell the governing body that they don’t need to clear above where they have a 30m deep tunnel, but FortisBC needs to make this assessment and assertion to the governing body. At this point, there is no promise that they won’t clear in the estuary above the pipeline. Our estuary is highly valued by our community, and hundreds of people have attended council meetings to speak in opposition to test drilling proposed by FortisBC in our estuary. I ask the EAO to require FortisBC to legally ascertain whether they can, in fact, place a pipeline underneath our estuary without clearing a right of way above it and once this is clarified to go through another round of public input.
ECONOMIC: Property values along pipeline and tanker routes can decrease by 10-40%
Resource development projects, such as pipelines or transiting tankers, have the potential to impact property values. Both direct impacts (following an accident with tankers or pipelines) or the perception of impacts (the possibility that an accident may happen) were clearly linked to reduced property values. Directly impacted properties can devalue by 10-40%, while properties nearby can also see a 5-8% reduction in value. The EA for this project ignores this economic impact, which would adversely affect homeowners and business owners in Valleycliffe, along Finch Drive, and in the Industrial Park, which ultimately impacts DoS finances. I request a full socio-economic impact study that includes the potential devaluation of property as a cost to Squamish homeowners and business owners. What reduction in property values/ compensation for the loss of property value along the pipeline’s path will be offered to affected owners? How will this compensation be determined?
Source: CRED BC
ECONOMIC: Limited benefits for Squamish
Compressor stations are automated, as are pipeline inspections. FortisBC’s proposal offers Squamish no long-term jobs, nor any more property taxes than it now pays. Instead, this project and the associated Woodfibre LNG project is likely to depress residential development, and decrease property values (and hence, DoS property taxes), especially in Ravens Plateau, Crumpit Woods, Valleycliffe neighbourhoods and all along Finch/Industrial Way, where there would be two high-pressure (2160psi) natural gas pipelines. Other than dubious short-term construction jobs, why would Squamish want such a project at such high risk?
ECONOMIC: No socio-economic impact study has been provided (still!)
There is still no socio-economic study provided that details the costs and benefits of this pipeline and compressor station project for Squamish. What are the benefits to Squamish? What are the costs? How will this project impact existing small businesses and existing industries in Howe Sound? How will it impact our tourism and outdoor recreation economy? I request an independent cost-benefit analysis and socio-economic study to answer these questions.
- the cost of devalued property to landowners and business owners along the pipeline route and surrounding the compressor station
- the cost of damaged viewscapes, and damaged trail networks due to the pipeline construction footprint
- impact of industrial noise from the compressor station on the value of nearby homes and businesses.
FUTURE CONCERNS: The "bigger" factor
Pipelines and compressor stations almost always tend to be expanded over time (as this one has already). What is to prevent this pipeline and compressor station from being much bigger, and even more polluting and intrusive, in future?
CONCERNS WITH EA PROCESS: FortisBC can "choose" the final route with no further public input
Despite the focus on a second specific route, this is just one alternate suggestion. FortisBC has asked for a much wider application corridor and can put a pipeline anywhere within this corridor (unless the EAO imposes conditions). They are not restricted to either specific route proposed so far, they’d just be restricted to the corridor highlighted in their application. FortisBC states that they "will take into consideration the results of technical and economic feasibility studies" before selecting the final pipeline route, and it is unlikely that their client, Woodfibre LNG, will be willing to pay for the more expensive option given the plummeting prices of LNG. Given the large number of impacts that this project will create, our community deserves to have input on the final chosen pipeline route, and the final location of the compressor station and whether it is powered by electricity or natural gas. I ask that the EAO require FortisBC to complete their technical and economic feasibility studies and submit the final chosen pipeline route and compressor station option for public review.
CONCERNS WITH EA PROCESS: Inadequate time to respond to public comment periods
A recent review of the Environmental Assessment process stated that "a process that limits the time for government and stakeholders to scrutinize applications is unfair given that proponents are typically far less restricted in how long they have to assemble their applications." This public comment period has been no exception given a very short timeframe (3 weeks) with only one week to respond to the addenda following the BC EAO open house. This has severely limited meaningful participation in this process by the general public.
Source: Chris Joseph, Thomas Gunton & Murray Rutherford (2015): Good practices for environmental assessment, Impact Assessment and Project Appraisal
Summary of key changes with FortisBC's pipeline application
We have compiled a summary of changes with FortisBC's addenda below.
Woodfibre LNG gets to choose either route
The original proposal (compressor station on Finch Avenue, new 24”-diameter pipeline path horizontally-drilled under the estuary and through the Wildlife Management Area) is still in play. Woodfibre LNG will choose which alternative it will proceed with, if both are approved by the BC Environmental Assessment Office (BC EAO).
Compressor station close to Valleycliffe
In this additional alternative, FortisBC will build (i) the same 24” pipeline 47km to Woodfibre from North of Coquitlam Lake and; (ii) a new (“Mount Mulligan”) compressor station located at ~400m. altitude on Mount Mulligan behind the Stawamus Chief about 1,800m SouthEast of Valleycliffe homes.
Less taxes for Squamish
The “Mount Mulligan” compressor station would be sited on crown land outside the District of Squamish (see detailed map), which will need rezoning by SLRD to an industrial designation. FortisBC’s Squamish property taxes are estimated at $107,000 (versus $322,050 in the original proposal).
Gas powered compressor station
The station would be powered by burning part of its own gas supply – not by electricity, as in the original proposal (though a 500kva BCHydro power line runs right by it). It would have a “nitrogen gas & water” fire suppression system.
Increased pressure in the pipeline
The “Mount Mulligan” compressor station would boost the pressure (to 2160psi) on the current 10” pipeline serving Squamish, Whistler, the Sunshine Coast and Vancouver Island. The new 24” pipeline - paralleling the existing 10” one and serving Woodfibre only - would be pressurized by existing compressors at an expanded Eagle Mountain (Coquitlam) compressor station.
Greenhouse gases and other pollutants could have human health impacts
The three “Mount Mulligan” 4,700hp gas-turbine compressors would together emit some 27,000 tonnes of GHG’s (equivalent to the exhausts of about 6,000 automobiles) per annum, along with significant amounts of carbon monoxide and nitrogen and sulphur oxides. These pollutants could have severe human health impacts, and studies need to be completed to determine wind flow patterns and whether these pollutants will impact nearby residential areas and schools.
Squamish's Noise Bylaws must be respected
FortisBC says that the noise from the compressors would be less than 40 decibels at a point 1.5km from the site and would be compliant with BC’s guidelines for industrial areas (BC’s test: less than 75% of local receptors are “highly-annoyed”). There are several residential neighbourhoods located in close proximity to the proposed compressor station. Noise from the compressor station could impact all nearby homeowners, particularly at night when other ambient noise levels are reduced. This has been well documented for the existing Eagle Mountain compressor station in Coquitlam. The proposed location of this noisy compressor station so close to private dwellings in Squamish is unacceptable. Squamish's noise regulation bylaw states that "No owner or occupier of real property shall use or permit such property to be used so that noise, sound, or vibration emanating from the property disturbs or tends to disturb the quiet, peace, rest, enjoyment, comfort, or convenience of any person or persons in the neighbourhood or vicinity." The noise levels from the proposed compressor station do not comply with this bylaw. I insist that this noise regulation bylaw be respected and upheld.
Source: Squamish Noise Regulation Bylaw No. 2312,2014
High pressure natural gas pipeline through Squamish
The routing of the 24” pipeline through Squamish is to be the same in both alternatives - skirting Valleycliffe and proceeding via Finch Avenue/Industrial Way.
250,000 tonnes of rock???
From a vertical shaft drilled at FortisBC’s “Sabre” site on Industrial Way, the 24” pipeline would proceed underneath the estuary and through the mountains on the West side of the Sound in a 4.2m (14’) wide, 3.5 - 6km long tunnel toward Woodfibre. Some 130,000- 250,000 tonnes of rock would be excavated in this tunnel by tunnel-boring machines. FortisBC has not decided where to dispose of this, nor has it ascertained what contaminants may be present in the rock.
Tunnel under the Wildlife Management Area
The tunnel would go completely under the Wildlife Management Area (WMA), and the barge landing sites on the estuary would not be needed. To accommodate the tunnel work crews, FortisBC would set up either a floating or an on-land construction camp somewhere on the West side of the Sound between the estuary and Woodfibre. Piping would be stockpiled at the “Sabre” site.
With only a few weeks to respond, we're scrambling to pull together a list of our key concerns to help you respond, but it's in the works! Our concerns include health impacts, increased greenhouse gas emissions, and the fact that they can choose either route if this proposal is approved.
If you have any questions, contact Michael Shepard, the Project Assessment Manager for both the Woodfibre LNG project, and the Fortis BC pipeline from Eagle Mountain to Coquitlam.
Project Assessment Manager
Environmental Assessment Office