Honourable Christy Clark, Premier, email@example.com
Honourable Rich Coleman, Deputy Premier & Minister of Natural Gas Development & Minister Responsible for Housing, firstname.lastname@example.org
Honourable Mary Polak, Minister of Environment, email@example.com
Laurie Throness, MLA Chilliwack-Hope, firstname.lastname@example.org
John Martin, MLA Chilliwack, email@example.com
I am writing on behalf of the WaterWealth Project regarding the imminent Province of BC decision on Kinder Morgan's proposed Trans Mountain Pipeline Expansion Project. WaterWealth does not support building new oil pipelines generally, such multi-generation infrastructure being contrary to our responsibilities to our children and future generations.
However regarding the Trans Mountain Expansion Project in particular we would bring your attention to a local concern in our home city of Chilliwack that remains unaddressed throughout the project approval processes to date, and which we believe makes it impossible for the project to meet the minimum conditions set out by your government to consider approval of heavy oil pipeline projects.
In the technical analysis document "Requirements for British Columbia to Consider Support for Heavy Oil Pipelines" we find:
"Our government has identified five areas of significant concern for British Columbia and our citizens. These five areas must be addressed by our partner governments and Enbridge before British Columbia would consider supporting the Project."
Listed below that paragraph of the document are those five areas of significant concern, the third being:
"World-leading practices for land oil spill prevention, response and recovery systems to manage
and mitigate the risks and costs of heavy oil pipelines;"
Further, under the heading "Terrestrial Protection and Spill Prevention" we find the objective:
"Objective: Canada becomes a world leader in terrestrial spill prevention, preparedness and response for pipelines transporting heavy oil or bitumen."
The first step in world leading spill prevention and preparedness is of course selection of a pipeline route that minimizes the risk of pipeline spill and minimizes risks in the event of pipeline spill. In Chilliwack the route currently planned for the Trans Mountain Expansion Project does the opposite.
Risk of pipeline spill is maximized by the presence of the Vedder Mountain Fault near where the pipeline route crosses the Vedder River, which in a zone of highest liquefaction potential according to Kinder Morgan's documents submitted in the National Energy Board (NEB) hearing. The Vedder Mountain Fault is one of four faults on the Trans Mountain route that was identified by Natural Resources Canada during the NEB hearing as being of specific concern. Compounding that concern is the proximity of the Sumas Fault to the Vedder Mountain Fault and the unknown risks of interaction between those two faults.
Risk in the event of pipeline spill is maximized by the Trans Mountain route crossing directly over the Sardis-Vedder Aquifer that is the City of Chilliwack's sole source of drinking water. The pipeline lies over the aquifer for approximately 13.5 kilometres. It passes within capture zones of city wells. Still over the aquifer and adjacent to the Vedder River the Trans Mountain route crosses two salmon enhancement areas--Peach Creek and Browne Creek Wetlands--that are of exceptional value to the community as places of recreation and to the local ecology and economy through their invaluable salmon habitat and its contribution to recreational and food fisheries. The salmon enhancement areas parallel the river on either side and are wooded areas that would make spill response access difficult. The pipeline route crosses the Vedder River a short distance up-river of Yarrow Waterworks wells and another jewel of the community, the Great Blue Heron Reserve.
Clearly, compounding the risks in this area of the Trans Mountain system by adding another pipeline and tripling the amount of oil passing through these vulnerable areas would not meet any standard of "world leading spill prevention and preparedness".
There are of course also concerns about the existing Trans Mountain pipeline through this area. In 2012 the NEB ordered Kinder Morgan to conduct inline inspections (ILI) of the Trans Mountain Mainline. That work was under way when two leaks on the pipeline were discovered in June of 2013, near the Coquihalla Summit and about 40 kilometres east. ILI tools had missed those leaks. They were discovered by people on the ground. Following the discovery of the leaks the NEB ordered Kinder Morgan to reduce the operating pressure of the Trans Mountain system.
In a document EA-TM-2014-004 dated 14 March 2014 Kinder Morgan sought to lift the pressure restriction on the Hargreaves to Darfield section of the system, a section 274 kilometres long. On the sixth page of that document Kinder Morgan state that the ILI assessment of the Mainline will be “completed by the end of 2014”. Kinder Morgan also stated that following the discovery of the two 2013 leaks they asked their ILI vendors to re-analyze all of their data. As shown on a table on that page, the ILI analysis identified 119 features that met Kinder Morgan’s dig criteria in that Darfield to Hargreaves section. Averaged over those 274 km that gives one feature requiring excavation every 2.3 km.
This writer was among a group of Chilliwack residents who went to see the spill sites in 2013. We went expecting to see two spill sites, two excavations for repairs. To our surprise, but similar to the Hargreaves to Darfield section, we found many excavations and repairs to the pipeline in roughly seven km of the Coquihalla Canyon that we hiked. Since then excavations on the pipeline have been observed to approximately 5 kilometres east of Bridal Falls, but none have been seen in Chilliwack.
If the Hargreaves to Darfield section was typical that would suggest that six features meeting Kinder Morgan’s dig criteria could be expected to be present now over the Sardis-Vedder Aquifer that is the sole source of water for the City of Chilliwack and for Yarrow Waterworks.
In response to a question in WaterWealth’s information request #2 in the NEB hearing on the expansion project Kinder Morgan said that the ILI work on the old line had been delayed by unavailability of one of the tools and that the inspections would be completed and a final report submitted to the NEB “by the end of 2015.” It is concerning, given the density of features meeting Kinder Morgan's dig criteria that we know of, that ILI work could be delayed by a full year. It is further concerning that no excavations have been done in Chilliwack and very few west of Chilliwack in the year, approximately, since the ILI work was to have been completed and report submitted to the NEB.
It seems unlikely that the pipeline would be in better condition across Chilliwack to the degree that no digs would be required here. But then how to explain the absence of excavations? WaterWealth has written to the NEB requesting a copy of that 2015 ILI report so that Chilliwack and Yarrow residents can assure themselves of the security of the water supply they drink from daily. The NEB acknowledged receipt of that request. We await a response that we hope will include a copy of the report.
In conclusion, while WaterWealth does not believe that the Trans Mountain Expansion Project should proceed, and posit that it cannot meet the province's conditions for consideration on the current risk-maximizing route, we anticipate that the Clark government favour the project going ahead and will work to make that happen. If this is so then you must change the route at least in the section crossing Chilliwack to move the pipeline off of the Sardis-Vedder Aquifer and away from the other risks and highly vulnerable areas in the vicinity of the Vedder River crossing. In doing so it would be irresponsible not to also take the opportunity to decommission the section of 63 year old pipeline that lies over the aquifer now and move that portion of the original line to the new route across Chilliwack as well.
We look forward to your response regarding these concerns.
Ian Stephen, Program Director
The WaterWealth Project
"Our Wealth is in Our Water"