GIC One More Time

As part of restarting regulatory processes for the Trans Mountain Expansion Project the National Energy Board is submitting for re-approval by the Governor in Council (federal Cabinet) all seven routing variances that occurred after the original project approval.

In Chilliwack, where the project is proposed to follow a route no entirely new pipeline project would even contemplate, the federal government had three opportunities to make a correction for public safety;

  • when they approved the project the first time;
  • when they approved a realignment of project segment 6.3 in Chilliwack, and;
  • when they approved the project the second time.

At the time of the first approval, WaterWealth letters to the federal government urging a correction here, by simply moving the project a short distance to the north to follow Highway 1, were responded to by directing us to the NEB detailed route hearings.

Route hearings are an adversarial process against the multi-billion dollar company's team of management, engineers, consultants and lawyers, played out before a panel of a regulator widely viewed as industry-captured. Of 94 detailed route hearings concluded prior to the original project approval being tossed out by the federal court, the NEB had ruled against the company exactly 0 times. The Trans Mountain project will in all likelihood be the last heard by the NEB. The federal government are in the process of replacing them with a new Canadian Energy Regulator.

At the time of the second approval, with the company now a federal Crown corporation, our letter was ignored with no reply from federal Ministers.

Canadians have heard the Trudeau government talk of listening to communities. We have heard them say that projects will only proceed if they can be built safely. The Expansion Project's segment 6.3 realignment in Chilliwack going to the Governor in Council for re-approval gives the federal government one more opportunity to walk their talk.

The following letter was sent to federal representatives on August 5, 2019. We urge Chilliwack residents to send their own letters. We should not have to fight a Crown corporation through an adversarial route hearing process to defend the drinking water source our community depends on -- though if it comes to that, we'll be in it to win it.

The list of email addresses we used for this letter is:

[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected],
[email protected]


"Our Wealth is in Our Water – Let’s Protect It"


5 August 2019

The Right Honourable Justin Trudeau, P.C., M.P., Prime Minister of Canada
The Honourable Amarjeet Sohi, P.C., Minister of Natural Resources
The Honourable Catherine McKenna, P.C., Minister of Environment and Climate Change
The Honourable Jonathan Wilkinson, P.C., Minister of Fisheries, Oceans and the Canadian Coast Guard
The Honourable Marc Garneau, P.C., Minister of Transport
The Honourable Carolyn Bennett, P.C., Minister of Crown-Indigenous Relations
The Honourable Ralph Goodale, P.C., Minister of Public Safety and Emergency Preparedness
The Honourable Navdeep Singh Bains, P.C., Minister of Innovation, Science and Economic Development
The Honourable William Francis Morneau, P.C., Minister of Finance
The Honourable François-Philippe Champagne, P.C., Minister of Infrastructure and Communities
Mr. Mark Strahl, M.P. for Chilliwack-Hope

Re: opportunity for Governor in Council to improve public safety on the portion of the Trans Mountain Expansion Project crossing Chilliwack, B.C.

On 19 July 2019 in decisions on resuming the Trans Mountain Expansion Project (TMEP) regulatory processes the National Energy Board said that it would seek Governor in Council (GIC) approval to re-issue the necessary orders to amend Certificate OC-065 for routing variances. I write to bring your attention to one of those routing variances, in TMEP segment 6.3 in Chilliwack, B.C., where the GIC has an opportunity to make a correction for public safety.

When the TMEP was first approved the route of segment 6.3 was in a BC Hydro right-of-way on an alignment between 500 KV electrical distribution circuits. That alignment proved impossible to construct. Rather than change the alignment to the south side of the BC Hydro right-of-way alongside a 2.3 KV circuit that BC Hydro said would be acceptable, Kinder Morgan chose to move the TMEP route to the old Trans Mountain pipeline right-of-way. That put the TMEP across an elementary school, through residential neighbourhoods where the pipeline would be less than 10 metres from homes, and closer to already at risk city drinking water wells.

That the pipelines pose a risk to these neighbourhoods is made abundantly clear by Trans Mountain’s emergency information. Pipeline Emergency Response Guidelines for Schools1 provided by Trans Mountain to the Chilliwack Board of Education advises such things as “Do not turn any machinery on or off or use a cellular phone near a suspected release site.” It is hard to imagine were a significant release to occur at the elementary school or nearby middle school that students would not reach for their cell phones to share the event on social media. A Trans Mountain web page titled “What You Need to Know in the Event of an Emergency2” includes advice “DO NOT ring doorbells to notify others of the release. Knock with your hand to avoid a potential spark from metal knockers.” Where the TMEP proposes to run through residential neighbourhoods there are many potential sources of ignition beyond metal door knockers, such as appliance pilot lights, barbeques, fireplaces, vehicles, residents’ power tools, lawn mowers, hot tub motors, people smoking, or candles or sparklers at special family occasions.



"Our Wealth is in Our Water – Let’s Protect It"



The Governor in Council reconsideration of approval of the routing variance in TMEP Segment 6.3 provides an opportunity to eliminate the risks from these Chilliwack neighbourhoods. The TMEP arrives at Chilliwack from the east following Highway 1. It returns to Highway 1 just west of Chilliwack at Trans Mountain’s Sumas pump station. Were the TMEP to simply follow Highway 1 between those points where it is already at the highway a route could be selected that would include no schools, no residential neighbourhoods, and no city drinking water wells. There would also be access advantages for construction, maintenance, and emergency response. Several areas of exceptional recreational and ecological value, including salmon spawning habitats, would be avoided.

Citizens have heard the Liberal government promise change, and promise to listen to communities. We have heard that projects will not proceed unless they can be done safely. This is a time to put those words into action.

Please do not approve the TMEP Segment 6.3 realignment without the option of the safer route across Chilliwack alongside Highway 1 being thoroughly examined as an alternative to the proposed route across our community.

Ian Stephen
Program Director,
The WaterWealth Project


Our Wealth is in Our Water, Let's Protect It!


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