Kinder Morgan Realignment IR#1

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Kinder Morgan has applied for a small route change in Chilliwack to their Trans Mountain Expansion Project. The route change, if approved, would move the pipeline out of a BC Hydro right-of-way to instead cross Watson Elementary School and run through back yards of residential neighbourhoods. The change would also move the pipeline closer to City of Chilliwack drinking water wells.

WaterWealth is an intervenor in the NEB hearing for the route change. We oppose the route change, primarily for the added risk to children attending Watson Elementary School and to our community's drinking water supply.

What follows is our Information Request #1 to Trans Mountain on the proposed route change. (Formatted to appear similar to the original document)

[Update: The City did a very thorough information request. It is not available on the NEB website yet, but a pdf copy is here. One note, there is mention in it of "two pipeline leaks in 2013 in the Sardis-Vedder Aquifer area." That is in error. The 2013 leaks were near the Coquihalla Summit (one at the summit and one about 40 km east). An easy error to make as the document referred to in that part of the City's IR is largely about the aquifer and the context of the mention of the two spills is not immediately apparent if one does not know what "Kingsvale North and KP966" refer to.]

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Anti-Spawning Affront Post 3

So this happened: "Hiccup clears for Canada's TransMountain pipeline. Regulator declares a challenge moot after pipeline planners pulled a request for relief."
(United Press International, Home/Energy News)

However Trans Mountain's withdrawal of their request for relief from NEB Act section 31 does nothing to allay concerns about the impact of their unproven and unauthorized use of snow fence as an anti-spawning measure for already at risk trout and salmon populations. On the contrary, this move by the NEB heightens concerns that harm to fish eggs and young may occur.

What follows is WaterWealth's letter in response to the NEB. (Formatted as the original document)

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Anti-Spawning Affront Post 2

Having been caught doing construction on the Trans Mountain Expansion Project prior to fulfilling pre-construction conditions and achieving NEB approval of the detailed route of the project, Kinder Morgan first requested permission to continue and then withdrew that request. The construction work involved placing snow fence into streams to prevent trout and salmon from spawning where Kinder Morgan plan to install the new pipeline. Kinder Morgan's withdrawal of the request to continue installing anti-spawning measures came with a claim that to remove the ones already installed would risk serious harm to fish.

What follows is WaterWealth's response to Kinder Morgan's withdrawal of their request for relief.
(Formatted as the original document)

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Kinder Morgan's Anti-Spawning Affront

Kinder Morgan was caught doing construction on the Trans Mountain Expansion Project prior to fulfilling pre-construction conditions and achieving NEB approval of the detailed route of the project. This violates both the NEB Certificate and the BC Environmental Assessment Certificate for the project. The construction work involved placing snow fence into streams to prevent trout and salmon from spawning where Kinder Morgan plan to install the new pipeline. Fish populations affected include a red-listed Chinook run. After the work was brought to the attention of the NEB by a private citizen, the NEB ordered the work to stop. Kinder Morgan responded by applying for "relief" from section 31 of the National Energy Board Act so as to be allowed to continue installing these unproven spawning deterrents in streams along the proposed pipeline route.

What follows is WaterWealth's response to Kinder Morgan's request for relief.
(Formatted as the original document)

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Kinder Morgan's 3-Ring Circus

If you're feeling confused about the pipeline processes in Chilliwack don't worry,
so is everyone else!

Think of it as a 3-ring circus...

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An Ounce of Prevention

Donate-to-Redcross-to-help-with-the-Fort-McMurray-wildfires.jpgCanadians are generous in disaster response. Domestically an outstanding example is the $189-million in private donations to the Canadian Red Cross for Fort McMurray wildfire relief. Along with $104-million from the federal government and $30-million from the Alberta government, Fort McMurray wildfire relief was the largest response to a disaster in Canadian history. It is interesting to note that the greatest contribution came from private sources rather than from government.

Of course the first principle of risk control is to eliminate the risk if possible. What if we could support disaster prevention instead of disaster response?

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Pipeline vs Drinking Water - Update

What follows is an update after Kinder Morgan’s response to the most recent communications from the City of Chilliwack, WaterWealth and Chilliwack-Hope MP Mark Strahl regarding the route of the Trans Mountain Expansion Project. Before diving into those details however, it is important to note that almost nowhere in these discussions is there anything that would improve the safety of Yarrow Waterworks wells, even though Yarrow's drinking water wells were listed in Kinder Morgan’s inventory of drinking water sources at risk from the project while Chilliwack's wells were not.

yarrow_wells_pipeline_fault.jpgThe only potential pipeline route that would remove the risk from Yarrow’s wells is the route proposed by WaterWealth, to follow the Trans Canada Highway. The recent communications are about a minor route deviation from Watson Elementary School to just past Deerfield Crescent where the company has actually applied to move the new pipeline closer to City wells. Neither route choice in that area would make any difference to Yarrow’s wells. To truly protect City wells and to protect Yarrow wells we need the City to insist on the route change to alongside Highway 1, the only route that would move the pipelines off of the aquifer and away from all of our community drinking water wells. You can contact the Mayor and Councilors with one message at http://bit.ly/yarrowwater. (The problem with the city's contact form is fixed.)

With that in mind, here is the current state of the project in Chilliwack as of July 31, 2017.

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The Route of the Problem

To protect the source of our drinking water, many in Chilliwack have been working to have the Trans Mountain pipelines moved to a new route away from City wells and off of the aquifer. Meanwhile, pipeline owner Kinder Morgan has also been seeking route changes. They have applied to the NEB for seven route changes including one in Chilliwack that would move the new pipeline closer to City wells. In Chilliwack the three routes in play are as follows.

The BC Hydro right-of-way.
(Click the map for a larger view in a new window.)

On this map the Vedder River Fan Aquifer that is the source of Chilliwack's drinking water is shaded blue. (Also known as the Sardis-Vedder Aquifer.) The pipeline route is shown in red. The BC Hydro right-of-way option is shown in purple, going from Watson Elementary School west about 1.8 km and south to near the end of Deerfield Crescent. This was the route Kinder Morgan planned to use but they say they could not resolve technical difficulties with BC Hydro. Running a steel pipe parallel to 230 kV and 500 kV powerlines has its challenges.

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Chilliwack Wells Missing

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This image is taken from a map in the City of Chilliwack's Groundwater Protection Plan. Well 1 and Well 2 are city drinking water wells. The pipeline marked "Gas Pipeline" is the Kinder Morgan pipeline. Published in 1997, the red, orange and blue lines on the map represent the projected areas those wells would draw water from as the city grew. In the 20 years since, we have certainly grown. New mapping of these zones is being done now. (Lines represent time of travel to wells.)

Recent filings by Kinder Morgan have particular relevance to drinking water in Chilliwack.

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route_variances

Bit of an update on the route change process (Kinder Morgan's changes)

Kinder Morgan asked the NEB to consider the PPBoR on route variances at the same time as the variances themselves. NEB refused because after they approve a variance it has to be approved by the Governor in Council and only then can PPBoR be considered.

So:
- people have till July 17 to comment on the variances - route & process;
- the board will consider the variances and if they approve them;
- they go to Governor in Council for approval;
- then there will be a detailed route process on the route segments the variances are in.

In June 26 letters to Kinder Morgan, which Kinder Morgan sent out to process participants July 4, for each variance the Board provides links to their information requests on the variances and KM's responses. They invite comment until July 17 on impacts and effects of the realignment, and process steps the Board should take in assessing the variance applications.

Excerpts:

"At this time, the Board invites all interested persons of the Chilliwack Realignment to provide written submissions to the Board in relation to the proposed Chilliwack Realignment. Such submissions may only include comments and concerns about the impacts and effects of the proposed Chilliwack Realignment, and/or additional process steps, if any, that the Board should establish as part of its assessment process for this application under section 21 of the NEB Act."

"Comments about the Board’s original recommendation on the TMEP will not be considered. Further, comments about the detailed route approval process will not be considered at this time. The Board will establish a process for the detailed route in future, and communicate publicly at a later date. For the purposes of this letter, comments must be specific to the Chilliwack Realignment."

Documents on the realignments can be found here.
https://apps.neb-one.gc.ca/REGDOCS/Item/View/3279648

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