Letter to NEB re Maintenance Concerns on Trans Mountain Old Line


1 Dec 2016

Danielle Prevost,
Engagement Specialist
National Energy Board

Ms Prevost

I am writing for the WaterWealth Project. WaterWealth is a community group working for protection of freshwater in BC and was an intervenor in the recent hearing on the proposed Trans Mountain Expansion Project. Information acquired during that process very much heightened our concern about the ageing Trans Mountain pipeline that is in operation now.

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Federal Letter re Pipeline & Aquifer

(The letter below also sent separately to Prime Minister Trudeau. James Carr as Minister of Natural Resources. and local MP Mark Strahl. Interestingly, no acknowledgement or reply was received from the Prime Minister or Environment Minister until a comment referring to the letter was made on an opinion piece on the pipeline by Federal Liberal MPs several weeks later. An acknowledgement from the Prime Minister's Office was received hours after that comment was posted. Coincidence?

Regrettably, that acknowledgement, like the reply from MP Strahl, merely said that the matter was being referred to the Minister of Natural Resources. No response has been received from the Minister of Natural Resources or any member of the Cabinet Climate and Energy Committee.

The letters were sent 28 November, 2016 and later posted here to add to the record on our blog of events related to the project and the aquifer.)

Climate and Energy Committee

Honourable Melanie Joly, Chair
Honourable Kristy Duncan, Vice Chair

Committee Members,
Honourable James Carr,
Honourable Carolyn Bennett
Honourable Dominic LeBlanc
Honourable Catherine McKenna
Honourable Amarjeet Sohi

Re: The Trans Mountain Pipeline Expansion Project and City of Chilliwack water source

You may not be aware that the pipeline runs right across the Sardis-Vedder Aquifer that is the sole water supply for the rapidly growing city of Chilliwack, BC, my home and the home of the WaterWealth Project which I represent.

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Needed Repairs Left Waiting?

Has Kinder Morgan been delaying needed pipeline repairs over the Sardis Vedder Aquifer for a year or more?

And has the National Energy Board let them?

On 16 March 2012 the National Energy Board (NEB) issued a letter directing Kinder Morgan Canada to complete baseline assessments of the Trans Mountain pipeline for cracking features that may lead to leaks. Over a year later, in June 2013, two spills were discovered by crews on the ground near the Coquihalla Summit and about 40 km east. Those spills had been missed by inline inspection tools.

p8240152sm.jpgA group of Chilliwack residents went to see the spill sites. The expectation was two spill sites, two excavations for repairs. In fact many excavations were found and extensive repairs to the ageing pipeline were apparent. A large pile of oil-contaminated soil was seen, part of hundreds of dump truck loads of contaminated soil that were removed from the Coquihalla Canyon that summer.

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Pipeline Risks

chilliwackmapedit3-page-001_8.25_300w.jpgA comment we often hear in our work regarding Kinder Morgan's Trans Mountain Expansion Project is that the old pipeline has operated safely for many years. The implication being that allowing a second pipeline to be built over the aquifer that supplies Chilliwack and Yarrow with water would also be safe.

Here are some facts to consider in deciding:

Are the Pipelines Really A Risk?

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Hope for Hope Slough

hopeslough_500w.jpgLocal Chilliwack residents cherish Hope Slough. Walkers, joggers, and cyclists can be found enjoying the roads, paths and parks along the slough any day of the week. Leisurely paddles are taken by canoe or kayak. Somehow "progress" seems to have relegated swimming in Hope Slough to the memories of only older residents, but fishing is popular for old and young alike. It doesn't take much luck to spot otters, mink or beaver along the slough, while herons and kingfishers are a daily sight. A viewing platform overlooks spawning salmon in season.

Sunday morning July 24 people out to enjoy the slough were shocked to get a little too close a view of the variety of fish species found in this much loved place.

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Protect Chilliwack/Yarrow drinking Water

If you could take a few minutes and remove a major threat from Chilliwack and Yarrow’s water supplies, would you? We have such an opportunity now. At the bottom of this blog post we'll tell you how, but first some background info.

The National Energy Board (NEB) has recommended that the federal government approve Kinder Morgan’s Trans Mountain pipeline expansion project that will triple the volume of the Trans Mountain system by adding a second, larger pipe to the system. While generally the new pipe would lie next to the old one, in its report the NEB stated “The Board is of the view that the opportunity exists for detailed route alignments that may further minimize impacts to those directly affected.

chilliwackmapedit3_300_quote.jpgOne of those detailed route alignments must be to remove this pipeline from the water source we in Chilliwack and Yarrow use every day! The existing pipe lies over, and at its average depth of five feet even in, the Sardis/Vedder Aquifer (also known as the Vedder River Fan Aquifer) that residents of Chilliwack and Yarrow rely on for our tap water. Even Kinder Morgan described the aquifer in the NEB hearings as "high demand, productivity and vulnerability" (p 4-15). Kinder Morgan also admitted that "City of Chilliwack community wells are located within this aquifer and the mapped well capture zones cross the proposed pipeline corridor" (p 4-35).

Regarding the risk of pipeline spill the City of Chilliwack stated in their letter of comment to the NEB Once contaminated, it is unlikely that the aquifer could be remediated adequately to use for drinking water purposes again.”

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Citizen Science in a Warming World

Water is arguably the most significant way that climate change is making itself felt here and around the globe, with changes in timing, quantity and quality of water in all its forms.

Climate_Fig2.jpg2oC is often talked about as the danger threshold of global average warming, a threshold discussed as early as this 1975 paper by economist and Yale professor William Nordhaus. At the recent Paris Conference, Canada helped to set 1.5oC as an aspirational target. However the BC Ministry of Forests, Lands, and Natural Resource Operations states that "BC will have greater warming and changes in its precipitation regime than the global average" and that even with "emission scenarios with significant reduction in emissions, the warming is 2 to 3oC by the 2080s". This puts BC beyond the oft-cited danger threshold well within the lifetime of today's toddlers, a sobering thought given that any emission reductions still seem a long way off as federal and provincial governments plan for new oil pipelines and LNG projects.

In 2015 BC had very little snow, followed by a summer with many rivers, lakes and streams too low and too hot for fish. Despite average and even above average snow levels in the province this past winter, it's looking like fish are going to be in hot water again. A record hot April dropped snow levels dramatically. Looking at the graphs one wonders whether we'll be any better off in terms of snow-fed flows than last year. (Click images for larger versions)



We have two tools to help give salmon and other fish a fighting chance against warming waters:

- maximize groundwater baseflows in surface waters by not drawing down the water table with our own groundwater use (hence the vital task of convincing the BC government not to hand out 30-year groundwater licences that fail to consider environmental flows), and;

- provide shade by preserving or restoring riparian vegetation.

wolf_salmon_raincoast.jpgWild salmon are an important food source from the marine environment to the tops of west coast watersheds; sharks, orcas, seals, people, invertebrates, fish, bears, wolves, herons, eagles, the list of species that rely on wild salmon goes on and on...even the forests themselves, the trees and plants in salmon-bearing watersheds are fertilized by the migrations of salmon back from the sea. Not to mention the economic importance of food, recreational, and commercial fishing in BC.

With the salmon foremost in mind, WaterWealth will be doing water quality monitoring throughout the summer. We will be gathering data on temperatures, oxygen levels and other metrics that we hope will help us help the salmon have a fighting chance.

If this aspect of our work appeals to you, we are always looking for volunteers to get involved! Or if volunteering isn't in the cards for you this summer, we're always looking for donations too! Together we can take care of our shared home waters.

BC Climate maps image: Ministry of Forests, Lands and Natural Resource Operations, accessed 26 May 2016

Wolf with Salmon image: Raincoast Conservation Foundation, accessed 26 May 2016

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Bridges and Troubled Waters

Update: Environmental flows exemption amended! Jump straight to the update, or read the original post from here.

Almost a month ago we posted the blog "Sustaining the Goal of Water Sustainability" which laid out a number of shortcomings in the process of developing the Water Sustainability Act to date. What prompted that post was this piece:

What they said on Environmental Flow Needs (EFNs): “It is proposed that under the WSA, decision-makers … would be required to consider EFNs when adjudicating most new water licence or short-term use approval applications for both ground and surface water…”
-- A Water Sustainability Act for B.C. Legislative Proposal, page 19

water_drop_sad_50w.jpgWhat they did: In regulations released February 29, 2016, exempted the approximately 20,000 existing non-domestic groundwater users from environmental flow considerations on water licences that won’t come up for discretionary review before the year 2046. This effectively locks in avoidable and costly future community and neighbour-to-neighbour water conflicts.
-- Water Sustainability Regulation Section 55 (4)

wsa_secret.pngWe were surprised when after all of the years of work and all of the public interest, such as the over-225,000 signature petition last year, the government did not issue a press release when the Water Sustainability Act was finally put into effect February 29. Incredibly the ministry responsible for putting the WSA into effect, Forests, Lands, and Natural Resource Operations, did issue a press release that day for a new snowmobile bridge on a trail in the Cariboo. Perhaps bridges are a greater priority for the BC government than the water that flows under them. In any case, the lack of press release got us started looking for why. Why after everything did they want the WSA to slip in unnoticed? And we thought we may have found why with that environmental flows exemption.

Some good news on that particular concern today, however, as Dan Fumano at the Province newspaper reports that the provincial government "acknowledges that there is currently a lack of clarity" and "are reviewing the Act and regulations to ensure that decision makers have the discretion to consider environmental flow needs when making water authorization decisions."

We can only surmise that the lack of clarity is within the Ministry of Environment itself, as the words of the exemption - "Applications under subsection (1) are exempt from section 15 [environmental flow needs] of the Act." - seem as clear as they could be. So whether the lack of clarity represents a difference of views from the staff level to the political level, or infighting between factions within the ruling party, or something else, who knows.

What we do know is that they appear to be fixing it.

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Our Shared Water Stories

"Our home, within the Fraser Valley, is one of the last remaining developed places on earth where natural systems are still relatively intact. We have wildlife, clean air, land, water and food."
-- "What is the WaterWealth Project", January, 2013

kayak_whtbk.jpgWe who call the Fraser Valley home have a lot to be grateful for. Natural abundance supports an enviable quality of life. A common thread flowing through it all is water. For number crunchers, there are statistics such as the Fraser River Trade Area's $3-billion contribution to BC GDP (2012). Statistics don't begin to tell the story though. You can't number-crunch the feeling of being on the water with friends and family, the joy of seeing the salmon return, sunrise views over snow-capped peaks, streamside hikes to lakes below those peaks, and sunset views on the Vedder or the Fraser. To capture how our home waters really make life good here takes stories, not statistics.

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We have good reasons to celebrate in BC on World Water Day 2016.

water_life_waterday.jpgOn February 29 the new Water Sustainability Act came into effect, bringing BC water law a big step toward the 21st century with long overdue recognition that groundwater and surface water are one system.

March 21st the BC Supreme Court sided with residents and local government around Shawnigan Lake who have been struggling, and even facing arrest, to protect their drinking water.

Also March 21, after years of foot dragging, the province finally seems to be taking steps to address contamination concerns on the Hullcar aquifer that supplies the Steele Springs Waterworks District in Spallumcheen.

And broadly speaking we still enjoy among the most beautiful and pristine streams, rivers, lakes, and aquifers in the world right here in BC.

World Water Day is a good opportunity to reflect on what brought these successes and how we can continue to protect the freshwater that is so precious, and the physical, spiritual, cultural and ecological prosperity that water makes possible.

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