DEADLINE 11:59pm, Sunday 15th December 2019
Woodfibre LNG has proposed a "floatel" comprised of a barge and ATCO trailers to house up to 600 fly-in, fly-out construction workers at the Woodfibre site. The general public can comment on this proposed amendment until midnight on Sunday 15th December. Woodfibre LNG has mobilized their supporters to submit positive comments, so we need your help to demonstrate that there is still no social license for Woodfibre LNG in Howe Sound, and to share your concerns about the social, economic, environmental, health, and safety impacts of a floatel.
Your input is critical! It can be as simple as stating that you do not support Woodfibre LNG, however specific comments on the floatel will have more weight. We have compiled a list of our key concerns for you to use as inspiration, or feel free to copy and paste. This is one of your only opportunities to hold Woodfibre LNG accountable!
Submit your comments here by Sunday 15th December 2019. Click the "Submit Comment" button.
Say why you are opposed to Woodfibre LNG, and your concerns about the floatel
Copy or adapt the example statement and/or key concerns below
Share this with your friends via email and social media
We do want to acknowledge that the floatel is likely the best possible solution to house Woodfibre LNG's construction workers. But this is making the best of a bad deal for Howe Sound. We need to make sure that we are holding Woodfibre LNG to the very highest standards. It's also an opportunity to highlight the broken environmental assessment process, and to raise our voices in continued opposition to Woodfibre LNG. Share why you are opposed to Woodfibre LNG, and then copy or adapt the issues below to include in your submission:
I am opposed to Woodfibre LNG as it will increase fracking, worsen climate change, and put the health and safety of Howe Sound communities at risk. Woodfibre LNG also threatens the recovery of our precious Howe Sound ecosystem with direct impacts to herring, salmon, and whales. None of these impacts have been adequately assessed through the provincial environmental assessment process for Woodfibre LNG.
I have completely lost trust in the integrity of the provincial environmental assessment process. This latest floatel amendment for Woodfibre LNG demonstrates that the process is broken and public engagement is meaningless. Woodfibre LNG and their consultants knew in 2014 that Squamish had a near-zero vacancy rate, yet BC EAO staff failed to hold them accountable and failed to incorporate appropriate mitigation measures such as building legacy housing as a condition of their environmental assessment.
Now Woodfibre LNG's consultants have determined that the floatel will not cause any significant adverse effects on our communities or our environment. But science that is bought and paid for by the proponent has an inherent conflict of interest. This undermines the integrity of the process and results in a loss of public confidence and trust in the decision. Decisions that relate to projects that pose a significant risk to the environment and/or human health like Woodfibre LNG must be assessed independently.
I call for an independent assessment to be conducted by the BC EAO (and paid for by Woodfibre LNG) to determine the possible adverse effects of a floatel in Howe Sound. Only then will public trust in this process be restored.
List of key concerns with Woodfibre LNG's floatel amendment
SOCIAL: Impact of temporary construction workers on community structure and safety
An influx of mostly male, temporary workers that don't have a connection to the community where they are working is typically associated with an increase in crime, drug use and misabuse, and increased demand for sex workers. These impacts often disproportionately affect the most vulnerable people in the community.
Studies during construction of similar industrial projects with large numbers of temporary workers have resulted in:
- increased number of workplace accidents.
- increased substance abuse and misuse.
- increased traffic accidents and collisions.
- increased rate of violent crime, including sexual assault and sexualized violence, and increased domestic violence.
- increased violence against Indigenous women and children.
- increased rates of prostitution.
- increased demands on hospitals, counseling, police, and ambulance services, which results in reduced service capacity for residents.
- waste disposal issues.
The recent report from the National Inquiry into Missing and Murdered Indigenous Women and Girls highlights “substantial evidence of a serious problem that requires focused attention on the relationship between resource extraction projects and violence against Indigenous women.”
While locating workers at the Woodfibre site on the floatel may eliminate concerns about traffic accidents, the other impacts are still very concerning to me, particularly if the workers are allowed to access Howe Sound communities when they are not working.
> I ask for Woodfibre LNG's construction workers to be restricted to the floatel and the Woodfibre site. I do not believe that the economic benefits of allowing workers to visit Howe Sound communities is worth putting our communities at risk.
ENVIRONMENT: Greenhouse gas emissions have not been reassessed and cumulative impacts continue to be ignored
The Intergovernmental Panel on Climate Change (IPCC) has warned that we have until 2030 to avoid catastrophic climate change. The report states that we need to immediately reduce greenhouse-gas emissions to limit warming to 1.5 degrees, with a 45% reduction below 2010 levels by 2030, and a 100% reduction (or net zero) by 2050.
Woodfibre LNG argues that the reduction in vehicle and ferry traffic will result in an environmental benefit, and as a result greenhouse gas emissions have not been assessed as part of this amendment. However, Woodfibre LNG is ignoring the increased emissions from fly-in/fly-out temporary workers, which will add significant greenhouse gas emissions to this project.
The cumulative greenhouse gas emissions for Woodfibre LNG have never been assessed, and the environmental assessment process has ignored both the upstream emissions from fracking and transporting the natural gas to the site, the downstream emissions of shipping the LNG to Asia, the emissions at the point of final combustion, and the cumulative emissions from the FortisBC pipeline and compressor station, and BC Hydro. Woodfibre LNG estimates the project will produce 142,000 tonnes of CO2 pollution every year during operations, while the associated FortisBC compressor station will produce an additional 27,000 tonnes of CO2 pollution, creating combined emissions of 169,000 tonnes of CO2 pollution per year. For comparison, that is more than double the greenhouse gas emissions for the entire community of Squamish which is estimated to produce 88,000 tonnes of CO2 pollution per year.
> I ask for greenhouse gas emissions to be assessed for the floatel as part of this amendment. This should include the greenhouse gas emissions of fly-in/fly-out temporary workers, as well as emissions from the floatel itself and associated worker transportation.
> I ask for a cumulative assessment of greenhouse gas emissions that will evaluate the entire life cycle emissions of Woodfibre LNG, including upstream and downstream emissions.
ENVIRONMENT/HEALTH + SAFETY: The Woodfibre site is not a safe location for a floatel (or a hazardous LNG facility)
On February 15th, 2015, a 3.4 magnitude earthquake hit Vancouver's coast that was felt throughout Howe Sound. Experts widely acknowledge that a 9.0 magnitude earthquake, also known as "the big one," is only a matter of time in the Pacific Northwest. The Woodfibre LNG proposal is located within this zone of moderate to high earthquake risk, on two known thrust faults.
The Woodfibre site also has a history of slope failure. In 1955 a wharf and three warehouses collapsed into Howe Sound at the Woodfibre site, causing $500,000 – $750,000 in damages. A geotechnical study by Knight Piesold identifies that approximately 46% of the Woodfibre site was mapped as having rapid mass movement. This means landslides and slope slumpage, including existing natural landslide hazards as well as terrain where construction activity may increase landslide initiation.
We've already raised our concerns about locating a hazardous LNG facility on such an unstable site, and the potential risks to our communities. The proposed location of the floatel will put an additional 600 workers at direct risk, however Woodfibre LNG has not assessed "Geotechnical and natural hazards" as part of this amendment.
> I ask for "Geotechnical and natural hazards" to be assessed for the floatel as part of this amendment.
> I ask for additional studies to be conducted to determine the safety of housing 600 construction workers at a site that is known to be susceptible to rapid mass movement.
ECONOMY: The requested socio-economic study has still not been provided
During construction, Woodfibre LNG estimated that only 4.3% of jobs (=38.5 out of 895) will be for locals living in the Squamish/Whistler corridor. However, the Vice President of Woodfibre LNG recently acknowledged at a DoS council meeting on 12th November 2019 that there is a labour shortage in BC. It is highly likely that the percentage of jobs for locals will be even lower than estimated.
We requested a comprehensive socio-economic study in 2014 and again in 2015, to highlight the possible costs and benefits of the Woodfibre LNG project. This has never been provided.
> I ask for an updated Labour Market assessment to be conducted to reflect the current labour shortage in BC.
> I ask for a comprehensive cost/benefit analysis to be conducted to determine the social and economic implications for Howe Sound communities, particularly given that the proclaimed benefits are likely evaporating.
ENVIRONMENT: Herring assessment is based on old and incomplete data setsForage fish such as herring are a critical link in Howe Sound's food web. In this amendment, Woodfibre LNG's consultants are still referring to the old and incomplete data sets for herring spawn that were used in the original environmental assessment application in 2014. This fails to take into account the extensive herring spawn data that has been compiled from 2011-2019 by local citizen scientist, John Buchanan. It also fails to take into account the data sets from Woodfibre LNG's own consultants, Hemmera, who conducted herring spawn surveys over the 2015 herring spawning season. Hemmera recommended that additional herring spawn surveys should be conducted in 2016 to establish a baseline - we don't believe this has been completed. Squamish Nation highlighted how poor the provincial environmental assessment was by forcing Woodfibre LNG to switch from seawater cooling to air cooling due to concern about impacts to herring.
Why is Woodfibre LNG again ignoring all available data to assess the impact to herring for this amendment?
> I ask for the impacts to Forage Fish such as herring to be re-assessed using all known and current available data, including citizen scientist data provided by John Buchanan.
> I ask for a baseline assessment of herring to be conducted before construction begins to ensure that appropriate mitigation measures can be taken.
ECONOMY/HERITAGE: Loss of access to Darrell Bay
Darrell Bay is a publicly-owned community resource currently assigned as an emergency ferry route to/from the Lower Mainland in the event the Sea to Sky Highway becomes impassible. Woodfibre LNG is proposing to build a dock at Darrell Bay to transport temporary construction workers to/from the Woodfibre site.
Darrell Bay is frequently used for overflow parking for Shannon Falls Provincial Park and the Sea to Sky Gondola, however Woodfibre LNG has asked for exclusive use of Darrell Bay. The impacts of the loss of this overflow parking for both BC Parks and the Sea to Sky Gondola has never been assessed as part of Woodfibre LNG's environmental assessment, and neither has the impacts of the proposed Darrell Bay dock.
> I ask for the impacts of the proposed dock at Darrell Bay to be assessed, with particular attention to potential impacts on the Sustainable Economy, and Infrastructure and Community Services.
> I ask that the BC EAO require Woodfibre LNG to build a legacy project for Squamish in the form of a public boat launch and kayak/paddle board launch at Darrell Bay as part of the conditions for this amendment.
POOR STAKEHOLDER ENGAGEMENT: Woodfibre LNG has failed to fulfill condition #24 to engage the publicWoodfibre LNG has only been engaging in an exclusive way with select community stakeholders behind closed doors, many of whom have received funding from the proponent in the last five years. As a member of the general public I do not feel informed, and I have not been meaningfully engaged by Woodfibre LNG on the floatel amendment or the current status of the project. It has been more than two years since Woodfibre LNG appeared before the District of Squamish council with an update before the update to council on 12th November 2019.
Woodfibre LNG is failing to fulfill condition number 24 of its environmental assessment certificate "to engage the public for the life of the project. Consultation and engagement must include information sharing and discussion of site-specific mitigation measures, including the development and implementation of plans and the conditions of this Certificate."
> I ask for an open community town hall hosted by the BC EAO (with representatives from Woodfibre LNG, FortisBC, and the BC Oil + Gas Commission in attendance) that is open to the general public, and where the general public can ask questions of the proponents about the projects and the process.
If you have any questions, contact Michael Shepard, the Project Lead for both the Woodfibre LNG project, and the Fortis BC pipeline from Eagle Mountain to Coquitlam.
BC Environmental Assessment Office
1 (778) 698-9294