Information Requests from the Board of Friends of Ecological Reserves submitted to Kinder Morgan on Jan 15

On January 15, 2014, The Board of Friends of Ecological reserves submitted the round 2 set of Information Requests to Kinder Morgan /TMX project . Since it has some questions related to local sensitive marine ecological areas, It is posted here:

C33-4-1_-_Information_Request_No._2_-_A4G5Q9

Other posts on our concerns about the risk of oil spills on Metchosin’s Coastline may be found here:

50 other intervenors in the NEB hearings also submitted questions.. The link to these will be added here when the National Energy Board puts up a link.

 

 

 

Trans Mountain Analysis of Tanker /Tugs

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Trans mountain projection of Vessel traffic lanes in the Strait of Georgia and Strait of Juan de Fuca.

Recently, Trans Mountain released a Response to the National Energy Board  Information Request , TERMPOL Report and Outstanding Filings from the National Energy Board:

(Def: TRC= TERMPOL Review Committee )

 

Below are some notes on this document:

 

tanker-scenario

This scenario was modelled to show the results of no tug escort of tankers coming out from the Westridge Terminal in Burnaby

tanker scenario2

14 minutes after a Blackout of a tanker’s control systems, without s tug escort, it hits the Coast.

Page 4 of 26
Recommendation 8: Trans Mountain should develop a tug matrix identifying appropriate tug specifications for untethered tug escort of Project tankers for the Strait of Georgia in consultation with the Pacific Pilotage Authority, BC Coast Pilots, and Transport Canada.

As described in response to NEB IR No. 1.59a (A3W9H8), Trans Mountain will make it a requirement of acceptance for tankers nominated to load at Westridge to have a suitable arrangement for the proposed enhanced tug escort. Trans Mountain will develop a tug matrix for inclusion as part of its Tanker Acceptance Standard to prescribe minimum tug capabilities required upon departure of the tanker. The tug matrix will define the capabilities and number of tugs required for foreseeable meteorological and ocean conditions and based on tanker and cargo size. The tug matrix will be developed by a qualified third-party consultant, in conjunction with the tug operators and regulatory authorities.

Page 5 of 26 Recommendation 9: Trans Mountain should implement extended untethered escort for outbound laden Project tankers through the Juan de Fuca Strait. (3.2.4 Proposed Risk Mitigation Measures)

TM Remarks,Comments, Actions:
As described in response to NEB IR No. 1.59a (A3W9H8), Trans Mountain will make it a requirement of acceptance for tankers nominated to load at the Westridge Marine Terminal to have a suitable arrangement for the proposed enhanced tug escort during its outbound transit through the Juan de Fuca Strait in accordance with the tug matrix developed in Recommendation 8. Tankers that do not commit to tug escort in the Juan de Fuca Strait during their laden passage shall be denied their approval to load at the Westridge Marine Terminal.

Recommendation 10: Should Trans Mountain revise its tanker acceptance process to require untethered tug escort of Project tankers through the Juan de Fuca Strait, it should develop a tug matrix identifying appropriate tug specifications in consultation with the Pacific Pilotage Authority and Transport Canada.
Response:Agreed. Please see comments above regarding Recommendation 8
Page 10 of 26

Finding 18: The TRC supports extending the pilot disembarkation zone and tethered tug escort requirements for Project tankers to an area in the vicinity of Race Rocks, weather permitting and subject to the requirements identified in a Pacific Pilotage Authority ‘Notice to Industry’. (3.2.4 Proposed Risk Mitigation Measures)
Accepted.

Trans Mountain is pleased with the TRC’s support for extending the pilot disembarkation zone and tethered tug escort requirements for Project tankers to an area in the vicinity of Race Rocks, weather permitting and subject to the requirements identified in a future Pacific Pilotage Authority ‘Notice to Industry’.

Page 16 of 26
c) TERMPOL Submission

In its Application Trans Mountain had included information from the quantitative risk assessment carried out by DNV, which was also submitted to TERMPOL for the committee’s review. Volume 8C, TERMPOL 3.15 (General Risk Analysis and Intended Methods of Reducing Risks, Trans Mountain Expansion Project, A3S5F4, A3S5F6, A3S5F8).

While the TERMPOL submission had proposed a number of enhanced laden tanker risk reduction measures for consideration (TERMPOL 3.15, Chapter 7), only two in-transit measures were included in the detailed quantification of probabilities (TERMPOL 3.15, Chapter 10), these were: · Extending tug escort for the laden tanker to areas of the route that currently do not require such escort (TERMPOL 3.15, Chapter 7.3.1); · Implementing a laden tanker Moving Exclusion Zone (MEZ) (TERMPOL 3.15, Chapter 7.3.2). Comparison of oil spill probabilities utilized a comparison of three primary scenarios of traffic and enhanced risk reduction measures. These were:  Case 0: Forecast traffic in 2018 without TMEP (60 Trans Mountain tankers)

Case 1: Forecast traffic in 2018 with TMEP (408 Trans Mountain tankers)
Case 1b: Same as Case 1 but with expanded tug escort and moving exclusion zone for loaded Trans Mountain tankers.

TERMPOL Review Committee Report

The MEZ was intended as a means to further reduce collision probability through enhanced situational awareness of both the tanker and surrounding vessels. The TRC did not endorse the MEZ concept in the manner proposed in the TERMPOL submission because the TRC has determined that current regulations including ColRegs, Pilotage, and VTS are adequate and no further regulatory change was necessary to accommodate the Project.

In its report the TERMPOL Review Committee endorsed the following enhanced risk control recommendations for in-transit laden tankers:  Extended use of tethered and untethered tug escort; as shown in figures 1 and 2 below.

(Recommendations 8, 9, 10 and Finding 17); · Extension of the pilot disembarkation zone (Finding 18);

 

Page 17 of 26

Refinements from First Round IRs
In response to intervenor requests in the first round of IRs, further assessment of risk and risk controls was conducted resulting in the refinement of the values presented in the TERMPOL submission. Specifically these IR responses were:  Research by DNV into the area VTS (Evaluation of VTS Capabilities for TERMPOL 3.15,

Trans Mountain Pipeline ULC, 15 August 2014) determined that VTS capability was far more than what had been modeled. (A4A2Z7, A4A2Z8)

· Fast time simulation study of tanker drift in Juan de Fuca Strait (Maneuvering Assessment – Juan de Fuca Strait Proposed Tug Escort). (A4A7R1)
Strait of Georgia proposed tug escort simulation study (Lantec, 2014). This and the previous study were carried out and provided to the TRC upon their request.

· Detailed assessment of collision risk in Segment 2 (Burrard Inlet); see response to PMV IR No. 1.8.1 (A3X6V4).

· Upgraded the bollard pull of tugs used in the model (40 tonnes to 70 tonnes), which better reflects the tugs available in the region for escorting laden tankers as shown in Page 19 of 26:

Thus the fundamental conclusion submitted in the Application does not change; that is, that the existing marine network is well managed and safe and has the capacity to safely accommodate Project tankers with application of agreed risk mitigation measures and that oil cargo spill risk in the region will remain similar and comparable with current conditions.

Page 22 of 26

statement after the two pink maps:

References:
The Effect of Enhanced Situational Awareness on Collision Risk, Technical Note, November 2014 (DNV GL).
Strait of Georgia Proposed Tug Escort Simulation Study (Lantec, 2014)

How Trans Mountain Project Will Pump Profits to Its Texas Owners Charting the Houston-driven inner workings of Kinder Morgan.

While doing work as an Intervenor for the Board of Friends of Ecological Reserves in the National Energy Board hearings on the Kinder Morgan Trans-Mountain Pipeline Expansion proposal , we have received notice throughout the past few months of the posting of many motions and questions to the Board from Intervenor Robyn Allan. The incredible amount of research she has done may be accessed on the NEB website:  https://docs.neb-one.gc.ca/ll-eng/llisapi.dll/Open/2451015

By Robyn Allan, Monday, January 10– TheTyee.ca

U.S.-based Kinder Morgan says its Trans Mountain expansion project represents financial and economic benefit to the Canadian economy, and our federal and provincial public treasuries.
Who would spend a year investigating such claims, rooted as they are in complex tax law, regulations and corporate structure? I did.
What I found made me conclude the opposite — Kinder Morgan drains financial wealth from our economy and does not pay its fair share of taxes.
I have written about the project’s complicated design to yield meagre tax revenues for Canadians in a previous Tyee article.
Now let me examine just how Canadian Kinder Morgan Canada Inc. is. The answer: hardly at all.
Pop the hood and take a look at Kinder Morgan’s inner workings and the idea that this is a Canadian company operating for the good of Canadians is dispelled quicker than Kinder Morgan can say injunction.
If you are bored by arcane discussions of corporate structure and governance, that may be just what Kinder Morgan is hoping. Please bear with me. It’s critical we know who really runs, and benefits from, Kinder Morgan Canada Inc.  —From the boys who brought us Enron

continued at: http://thetyee.ca/Opinion/2015/01/12/Trans-Mountain-Texas-Profits/

CHART.KMStructure_page_thumb

Click to enlarge (some browsers may require a second click to further enlarge image). Kinder Morgan corporate chart prepared by Robyn Allan. Graphic design by Karl Jensen.

 

Who pays for the real costs of the Oil Industry

We often hear that we need to extract oil and ship it overseas in order to support “Canadian jobs and the Economy”  I thought I would provide in this post a few links here to some references worth noting on the subsidization of the fossil fuel industry in Canada . GF

1. In July 2014, The Pembina Institute published a report titled: Fossil Fuel Subsidies: An analysis of federal financial support to Canada’s oil sector.
Published July 10, 2014 by Sarah Dobson, Amin Asadollahi

“The oil industry provides economic benefits in the short and medium term, but more permanent external benefits are less certain and are countered by the sector’s environmental impacts. This paper provides an analysis of federal financial support for the oil sector as well as recommendations on policy options. It recognizes progress made by Canada in phasing out certain subsidies, while noting that remaining federal direct and indirect support measures are largely inefficient and unnecessary.”

2. Fossil Fuels – At What Cost? Government Support for Upstream Oil Activities in Three Canadian Provinces: Alberta, Saskatchewan and Newfoundland & Labrador

Abstract:    Continue reading

Economic Impacts of an Oil Spill

This  recent cover story by Lovel Pratt in the Whatcom Watch Onlinehttp://www.whatcomwatch.org/php/WW_open.php?id=1795 is well worth reading for Metchosin residents .
Examples it has stated:

  • “The consequences are huge: The Department of Ecology(Washington State)  estimates that a major oil spill in the state would cost 165,000 jobs and $10.8 billion in annual economic activity.
  • However, these figures are undervalued because, in addition to being two years outdated, this estimate does not include any costs associated with the impacts of oil spills to privately owned shoreline and water-view properties.”
  • “Property owners may be required to evacuate if faced with fire danger and/or air pollution from emissions of benzene and other volatile organic compounds. If evacuation is not required, shoreline and water access could be cut back or prohibited. Water views would be spoiled by oil slicks and noisy cleanup operations, and oiled shorelines would likely be mechanically cleaned by pressure washing and bulldozing.–Property owners also face losses to assessed values. A study conducted in British Columbia revealed that privately owned properties can lose from 10-40 percent in value, and even properties near spills that are not directly affected can lose value by association.”
  • “Typical homeowner’s insurance would not provide compensation in the event of an oil spill. Pollutants are excluded in property policies unless the coverage is specifically defined to include the pollutant. According to my local insurance agent, unless a homeowner’s policy specifically covers oil spills, there would be no compensation for loss of use or loss of value resulting directly or indirectly from an oil spill. Further, it would be both difficult and most likely quite expensive to find such coverage.
  • “The Exxon Valdez oil spill, which hasn’t been completely cleaned up after 25 years, still has continuous and compounding environmental and economic impacts.8 Washington State can’t afford that tragedy. The 165,000 jobs and $10.8 billion in annual economic activity don’t accurately estimate the costs that such a catastrophe would have on the state.”
  • See the well-referenced article here: http://www.whatcomwatch.org/php/WW_open.php?id=1795
  • Thanks to Andy MacKinnon for pointing to this.

Sediments record tidal and storm levels.

2015-01-08 strata-ginger

Ginger “studying” the high tide level beach deposits.

 

Last week we had a very high tide, and storms from the north-east which had temporarily blocked  the exit to Gooch Creek on Taylor Beach. The water in Gooch creek swamp rose over a metre before breaking through and washing out on the beach. As the beach has eroded down, the record of the previous weeks of tide levels and storm surges is exposed in this eroding bank where the water exits on the beach.

Lost and Found on Taylor Beach

2015-01-08cupsonbeach2

Tim Hortons coffee cups, complete with non-biodegradable plastic lids . Neatly stashed in the logs.

In the past few weeks a few objects have been “mistakenly” left by visitors  to Taylor Beach. There are several local residents who always help to keep the beach clean but regularly encounter these possessions.  We do hope that future visitors aren’t so forgetful.

2014-12-06dogbag2

Non-biodegradable plastic bag , neatly tied, complete with dog excrement inside.

 

Cliff failure on Taylor Beach

In the last 24 hours, a large slump has occurred on the Taylor Beach cliff. This is located just at the north end of the beach component. The properties along the top of the cliff have for several years experienced various human impacts which have likely contributed to this erosion.

  • Disposal of yard waste over the bank.
  • Removal of trees on properties to create better viewscapes
  • Building too close to an erosional bank feature
  • Topping of trees on the cliff face to improve views
2015-01-08taylorslump

Taylor Beach slump. G. Fletcher photo.

This Cliff is all included in the Hazard lands DPA, and it is also a naturally occurring geological erosional feature which, unfortunately poor enforcement over the years has contributed to this problem.

There remains further evidence of slipping in the separated section showing a grey clay bank along a wider stretch of this bank so we can anticipate more similar events.

Currently a large deposit of soil, broken mature alders and debris remains on the beach. The next big storm from the East at a high tide will clear this out causing increased sedimentation along the inter and sub-tidal areas off shore.  There us a thriving community of organisms on this shore so an impact on those populations is predicted. .

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Taylor Beach erosion- G. Fletcher photo.

2015-01-07 cliffslide

Taylor Beach erosion with tangle of alders. G. Fletcher photo.