Letter of Comment British Columbia Sustainable …...In April this year, Michael Liebreich of Bloomberg New Energy Finance told the audience at the Future of Energy Summit, that in

In the matter of the National Energy Board review of: Trans Mountain Pipeline ULC

Trans Mountain Expansion Project

National Energy Board File Number OF-Fac-Oil-T260-2 013-03 02

Hearing Order OH-001-2014

Letter of Comment by the

British Columbia Sustainable Energy Association,

Kamloops Chapter

~~ 24 July ‘15 ~~

Submitted to: Secretary of the Board National Energy Board

444 Seventh Avenue SW Calgary, AB T2P 0X8 Fax: 403-292-5503

Submitted by: Cheryl Kabloona

On behalf of BC Sustainable Energy Association, Kamloops Chapter

(250) 372-0277 c/o 1120 Hugh Allan Drive, Apt 412

Kamloops, BC V1S 1T4

BCSEA Kamloops Letter of Comment re Trans Mountain Expansion July 24, 2015 Page 2

Executive Summary The British Columbia Sustainable Energy Association, Kamloops Chapter (BCSEA Kamloops) respectfully asks the National Energy Board to reject the Trans Mountain Expansion Project, on the grounds that the project is not needed, and it is not in the public interest when potential environmental and socio-economic impacts are taken into account. We discuss here two of the twelve issues being considered by the Board, as experts in sustainable energy and as residents of Kamloops who are directly affected by the project. Looking at the Board’s issue number one, the need for the proposed project, we maintain that the Trans Mountain Expansion Project isn’t needed because humanity, including Canada, is in the beginning stages of an energy transformation. The world is turning to renewable energy. Renewable energy, especially solar, is cheaper than ever before and has become the cost-effective choice for electricity generation in many jurisdictions. Renewable energy has the advantage of very low operating costs once installed: the sun and the wind are free. Low-cost solar and wind power, electric vehicles, distributed generation and smart grids will all play a part in reducing demand for oil. At the same time, capital and production costs for unconventional oil grow ever more expensive as easy-to-get resources have been depleted. It should not be assumed that oil sands growth is inevitable or that the second pipeline, if built, would be used to capacity. Canada’s reliance on oil has brought us economic uncertainty. Many of the expensive oil sands projects are unprofitable under current low oil prices, and layoffs and project cancellations are commonplace. We would be better off with a diversified economy having greater emphasis on renewable energy. Canada has an educated and skilled workforce, and we have the means to shift our output away from natural resource extraction into a breadth of intellectual, sustainable business ventures. Investing in these ventures will moderate the economic risks we face with oil export. Looking at the Board’s issue number four, potential environmental and socio-economic effects of the proposed project, we point to the threats to our natural environment and the economy that it supports. Kamloops, and every other region along the proposed expansion route, would be at increased risk of oil spills. Here in Kamloops, wild salmon and clean rivers are of great value to local residents and the tourism industry. An oil spill into the Thompson and Fraser rivers presents a direct threat to already fragile


populations of salmon, including the world-famous Adam’s River sockeye salmon. Construction of the second pipeline would inflict intrusive and long-lasting damage on the Kamloops region’s semi-arid terrain of hills, forests, small lakes and streams. There are serious risks resulting from the proposed pipeline being in such close proximity to the proposed Ajax mine. Both of these are located within the Peterson Creek watershed that drains through the Kamloops downtown. This and other cumulative impacts need to be understood better, in a region that is experiencing significant industrial and urban growth. The very few jobs and economic benefits offered by Kinder Morgan are inadequate in comparison to our beautiful landscape and the vibrant local economy that will suffer in the case of an oil spill. Market forces and potential oil spill disasters are not alone in propelling us toward low-carbon energy. Many governments are taking the first steps to put a price on carbon emissions, and the demand for fossil fuels is changing, as governments, organizations, businesses and individuals take action to reduce emissions. Here in Canada, the public's willingness to accept projects such as the oil sands and pipelines will certainly continue to abate. Other trends that will limit oil sands expansion include the growing divestment campaigns to "leave it in the ground"; the need for a national energy strategy that balances traditional energy sources with renewables; and the employment benefits of a more diversified economy. All of these trends point to a transition away from fossil fuels that will accelerate as the years go by. While outside the scope of the Trans Mountain expansion review, it is climate change that is driving much of the energy revolution, plus technological advances. We are feeling the effects of climate change already, in droughts, forest fires, floods, and ecological disasters. This will only worsen as the years go by and will spur an accelerating shift to low-carbon energy. The transition away from fossil fuels is inevitable and it is doable. Expensive and risky infrastructure projects like pipelines, in support of the oil industry, are coming at the wrong time. They’re simply not needed, and on balance they do not deliver benefits to Canadians. It is unreasonable to move ahead with this pipeline expansion and expect communities along its path to bear the risks to their lands, water and livelihoods. In all, we feel strongly that Kinder Morgan's application to expand the Trans Mountain pipeline should not be approved.


Contents Executive Summary 1.0 Introducing BCSEA Kamloops 2.0 Visions of Canada’s Energy Future

2.1 We CAN Power Civilization with Renewables 2.2 Our Vision: Lasting Prosperity with a Diversified Economy 2.3 National Energy Strategy 2.4 A Great National Opportunity 2.5 A Young Person’s View 2.6 Questionable Assumptions about Need for the Project 2.7 The Third Option: Leave it in the Ground

3.0 Fossil Fuels under Threat 3.1 Divestment Campaign: Leave it in the Ground 3.2 Climate Action on the Global Scale 3.3 Market Forces

4.0 Local Impacts 4.1 Oil Spills and the Importance of Healthy Rivers and Salmon 4.2 Oil Spill Risks and Responses 4.3 Jobs and Tourism 4.4 Parks 4.5 Cumulative Impacts

Closing Bibliography Appendix 1: Don’t be Fossil Fooled - It’s Time to Say Good-bye Appendix 2: Big Oil Is About to Lose Control of the Auto Industry


1.0 Introducing BCSEA Kamloops This is the submission of the commenter, the British Columbia Sustainable Energy Association, Kamloops Chapter (BCSEA Kamloops) regarding the application by Trans Mountain Pipeline ULC, a Kinder Morgan subsidiary, to construct the Trans Mountain Expansion Project. BCSEA is a non-profit association of citizens, professionals and practitioners committed to promoting the understanding, development and adoption of sustainable energy, energy efficiency and energy conservation in British Columbia. BCSEA has five chapters across B.C., including the Kamloops Chapter, and approximately five hundred individual and corporate members. The BCSEA Kamloops Chapter has approximately 1500 supporters and followers in the Kamloops region. BCSEA Kamloops represents the public interest, as well as the interests of its own members and BCSEA members across British Columbia. 2.0 Visions of Canada’s Energy Future This section describes our vision of Canada’s future with a low-carbon, diversified economy and other views of our energy future. While not directly related to the Trans Mountain pipeline expansion project, it provides context to our later discussion of threats to fossil fuels and need for the proposed project. 2.1 We CAN Power Civilization with Renewables In the last decade, renewable energy has seen tremendous expansion: solar, wind, biomass, geothermal, tide and hydro. Many of these have become technically robust and have experienced dramatic reductions in price. Along with grid improvements, electric vehicles, energy storage solutions and energy conservation and efficiency, renewable technologies are at a point where it’s entirely feasible to shift to a low-carbon economy in a few decades. Renewable sources of energy really are good enough. Earlier this year, more than 70 Canadian scientists, engineers and economists had this to say: “Because renewable energy resources are plentiful, we believe that Canada could reach 100% reliance on low-carbon electricity by 2035. This makes it possible, in turn, to adopt a long-term target of at least an 80% reduction in emissions by mid-century, consistent with


Canada’s international climate mitigation responsibility” (Sustainable Canada Dialogues, 2015, p. 6). Similar conclusions on a global scale have been published by various research teams. The barrier is not technical or economic, it’s the lack of political will. In April this year, Michael Liebreich of Bloomberg New Energy Finance told the audience at the Future of Energy Summit, that in 2013 the world had added 143 gigawatts of new renewables capacity, compared to 141 gigawatts of capacity in coal, natural gas and oil combined. For a given capacity, renewables produce less energy than fossil fuels, but this still shows how rapid the growth of renewables has been and is forecast to be.

(Bloomberg New Energy Finance, 2015, p. 34) 2.2 Our Vision: Lasting Prosperity with a Diversifi ed Economy The federal government would have us believe that development of the oil sands will bring us economic prosperity. That may have sounded good when oil prices were high, but it's been a fallacy all along. It's distracted us from developing our economy toward low-carbon industry based on renewable energy. It has turned northern Alberta into a wasteland. We've allowed private interests to extract our oil resources at royalty and taxation rates that benefit them, not the Canadian public (Anderson, 2015). The lure of easy money in the oil sands has taken young people away from their home


communities and deluded politicians and voters into thinking that the boom would last forever. Investing so heavily in the oil sands has put our economy at risk when conditions change. We’ve always known that oil prices are volatile, so the current downturn should not be a surprise. We’d be better off to encourage diversification, including low-impact renewable energy. It makes no sense to put all of our eggs in one basket. Now we have a weak economy with fears of recession, unemployment, and government budget deficits. Any investment advisor tells a client to use diversification as a tool to spread risk among different sectors. Unfortunately our leaders have ignored that principle. Canadians are looking for a better answer. We want a diversified economy that is not based on one boom-and-bust resource. We want jobs in our communities and we want to feel good about what we do for a living. We want sustainable industries that are good stewards of the environment. Renewable energy and the green jobs sector can do a lot of that. Imagine a community like Kamloops having local sources of energy: a community-owned solar farm, solar panels on residences and commercial buildings, a wind farm in the mountains nearby, and all the trades jobs installing and maintaining those. Energy doesn't have to come to us by pipeline and rail! Imagine also all the jobs involved with improving the energy efficiency of our homes and other buildings: energy audits, better insulation, high-efficiency furnaces, new roofs and windows. Large facilities need monitoring equipment and energy managers. Investment in transit and light-rail in our cities, including electrification of these systems, generates many thousands of new jobs across Canada. Locally owned value-added industry and food production are other sources of good jobs. Tourism is a thriving industry in a community where the air, water and landscape are healthy. The new sustainable economy includes jobs in forest rehabilitation, design of resource-efficient cities, and management of healthy ecosystems. Canada needs to provide better support for research and development and manufacturing in the cleantech sector. We could provide investment stimulus to companies like Electrovaya who develop and build innovative power storage solutions for automotive and wind/solar farms (Electrovaya). “The global market for advanced batteries is expected to be worth over $55 billion by the year 2020” (Taiyou Research, 2015). Rather than continuing to rely on natural resource export and auto manufacturing, Canada needs more focus on the vast array of industries that fall under the green movement. We can export cleantech goods and services and also put people


to work, whether that be as an assembler for Electrovaya or an installer upgrading a bank of cells in a power storage substation in Iron Bridge, Ontario. We have a well-educated workforce and abundant natural resources. We'll do just fine making the transition away from fossil fuels but it will happen faster if our government provides a regulatory framework in support of the low-carbon economy. It is time to stop focussing on oil and invest in our people. 2.3 National Energy Strategy We don’t ask to shut down all oil sands production right now, but surely it would be possible to keep production level while we take the time for a national conversation about energy. Canada should not be pushing ahead with major energy infrastructure projects in the absence of a national energy strategy. What’s the big rush to extract and sell our oil so fast? Not only that, why should we sell it at such low prices to overseas interests? Why not keep the pace of production slower so there’s some left for our grandchildren? We desperately need to develop a national energy strategy that balances both the economy and also protection for communities, health and environment. We need a level playing field and long-term development plans for both renewable energy sources and the traditional oil and gas sector. Decisions that perpetuate vested interests in oil and gas make the investment climate for newer industries much more difficult. Our government has not done enough to pursue reductions in carbon emissions and invest in renewables, energy efficiency and other clean-tech solutions. Not only are we being seen internationally as obstructing climate progress, we’re falling behind as the rest of the world moves to low-carbon energy. Let’s take the time to have that conversation and find the right path for Canada. We have gone too fast and made some mistakes. Let’s get it right and avoid this frantic race to extract and sell our resources. The existing Trans Mountain pipeline is good enough for now. Expansion isn’t inevitable: oil sands production doesn’t have to grow. 2.4 A Great National Opportunity While oil prices are low and the world’s attention turns to the United Nations Climate Change Conference in Paris this winter, we have a great opportunity to shift Canada’s


path by expanding our renewable energy sector. It’s of vital importance to our economy that we as a society give better opportunities to clean energy, efficiency and low-carbon solutions. We need to be competitive in the world of the future, and continued pursuit of fossil fuels won’t do that for us. Canada has abundant renewable energy resources: rivers, sunshine, wind, tide and wave, and geothermal hot spots. We also have a well-educated workforce with the skills needed to develop these resources. Our building trades already have the skills to help us transform our homes and other buildings towards energy efficiency. We have a good high-tech sector that already contributes to low-carbon solutions. Our young people understand that the world is changing. They know the future lies in finding sustainable ways to live and prosper. They want to be able to stay in their home communities, make them a better place, and feel good about what they do for a living. “By addressing climate disruption and investing in renewable energy and low carbon solutions, Canada can provide opportunities for young people who understand sustainability is the key issue of our time and want to be part of the solution. As countries move away from reliance on fossil fuels around the world, the next generations of Canadians will be in an excellent position to compete” (Pike, 2014, p. 18). 2.5 A Young Person’s View One of our young BCSEA members, a university student, has this to say about Canada’s future:

How putting our foot down in Kamloops can help Canada

From the perspective of British Columbia, and Kamloops, there is very little gain to be had, on an economic level, by having new or beefed-up pipelines carve up our natural landscape. From a local and provincial level, these schemes provide little to no employment. As such, we have little to gain, and everything to lose, by having pipes buried in our back yard.

Wild fluctuations around the long-time average $50/barrel have had major short-term impacts on the economies of oil-producing provinces such as Alberta, Saskatchewan, and Newfoundland - leading to only little spurts of growth (and losses) in the long run. There has been shown to be little positive, and even negative, effect on the other provinces that must acquiesce to pipeline plans, past and present (Stanford, 2015).


Time to shake-off our Petrodollar status!

Canada is a place full of educated people, with enviable human capital, and we are in a position to lead the world in alternative energies. It is time to shake off our "hewers of wood, drawers of water" status. Our persistence in delivering raw and unrefined crude and other products out of our borders helps shore up this ridiculous status. We are actually shipping more and more raw resources every day.

Canada must move more toward determining its own fortunes and destiny. It can do this by ridding itself of the whims of OPEC and oil market speculators.

We need to remove the uncertainties of oil and move into more intellectual, sustainable productivity and development. People are our greatest resource, not oil!

2.6 Questionable Assumptions about Need for the Pro ject In the Trans Mountain expansion application, the proponent has included a report by consultant IHS Global Canada Limited titled “Trans Mountain Expansion Project, Direct Written Evidence of Steven J. Kelly” (Kelly, 2013). One of the objectives of the report is to address the question “If the TMEP is constructed as planned, is it reasonable to expect that the facilities will be highly utilized?” The writer concludes yes, “that the facilities will be utilized at a high rate.” He anticipates “total crude production growing at a 3.0 percent compound annual average growth from 2013 to 2037.” Kelly expects that, with crude production growing steadily, the proponent can be confident that the pipeline expansion would be used over twenty years of operation. With recent drops in oil prices, that forecast looks optimistic at least in the short term. But more than that, there’s a fundamental flaw in the report’s assumptions: it presents an insider’s view of the oil industry and doesn’t consider uncertainties from outside. Forecasts are made within a business-as-usual world view without any acknowledgement of possible disruptive change in energy markets. The report makes no mention of renewable energy as competition to oil-based energy; in fact, the term “renewable energy” is not used even once in the sixty-four page report. There is no mention of carbon pricing or regulation affecting economic outlook. There is no mention of changing consumer behaviour or investor sentiment. These are all significant risk factors to the economic case underlying pipeline expansion.


We understand that Kinder Morgan has firm service contracts in place with shippers, giving the appearance of guaranteed revenues. But in reality, when disruptive change happens there are no real guarantees. Project delays and added costs can invalidate the firm service contracts, and a changing regulatory environment and shipper default are possible too. The shift to renewables, regulatory changes governing greenhouse gas emissions, carbon pricing and changing attitudes will all play a part in reducing the volume of oil requiring transport. In other words, the project's business model is flawed in being blind to the likelihood of disruptive change and it should not be assumed that the additional pipeline capacity is needed. The oil and gas industry has been phenomenally successful and expects to conduct business in the same manner as in the past, with rising demand and production continuing to increase. This is simply not credible today, and the National Energy Board should reject the proponent’s conclusions on this point. Rather, the Board should conclude that the demand for oil faces great uncertainties over the lifetime of the proposed project, and that there is a high likelihood that alternative, non-fossil-fuel energy sources will increasingly compete with and displace fossil fuels. These factors have not been credibly addressed in the evidence. and accordingly, the Board should conclude that it has not been established that the second pipeline would be fully utilized. 2.7 The Third Option: Leave it in the Ground The pipeline vs. rail discussion is another example of a business-as-usual world view. The oil industry has marketed the idea that pipelines are needed because they’re less dangerous than rail transport of oil and bitumen. The discussion has been framed as if there are only those two choices. They’ve completely ignored the third option: leave it in the ground by levelling off and gradually reducing production. They assume that oil sands growth is inevitable, leaving only the decision on how to transport the ever-increasing volumes of petroleum products. We suggest that seeing only pipeline vs. rail is a false dichotomy. As discussed already, society is changing rapidly and the transition to a low-carbon economy is well underway and accelerating. The oil industry is under threat in a number of ways that we’ll review below.


3.0 Fossil Fuels under Threat Having set the framework for our vision of Canada having a low-carbon, diversified economy, now in this section we discuss the multiple forces and trends that are propelling our society away from fossil fuels, towards renewable energy sources. Climate change is the underlying driver for much of the energy transition, in concert with technological advances. People everywhere are feeling the effects of climate change, in droughts, forest fires, floods, and ecological disasters. These effects will only worsen as the years go by and bring a real sense of urgency to the energy transition. Bold new developments in the energy transition are coming at an astounding pace. Writing this section has been a very time-sensitive exercise: as soon as a portion of the text is drafted, another dramatic news story comes along illustrating how fast things are changing. Pope Francis’s groundbreaking encyclical letter of June 18, 2015 is a case in point. Francis has used his moral authority to urge faster action on climate change, and he proposes an intriguing coalition between faith and science to bring about the political and structural transformations needed for lasting change (Yardley and Goodstein, 2015). Paul Gilding writes about the energy transformation in a compelling way (Gilding, 2015). See Appendix 1 for his blog “Don’t Be Fossil Fooled - It’s Time to Say Goodbye.” In this section we address the first issue being considered by the National Energy Board, the need for the proposed project. We speak from the perspective of being experts in sustainable energy. We conclude that the Trans Mountain expansion is not needed and the second pipeline would not necessarily be used to capacity. 3.1 Divestment Campaign: Leave it in the Ground The fossil fuel divestment campaign is a growing threat to investment in oil, gas and coal. The campaign is partly based on ethics: many of us feel that it is unethical to invest in companies that are doing profound harm to the world, now and in the future. Pope Francis and many faith groups come to climate action and divestment from that perspective. There’s also a strong case that investment in fossil fuels is risky. This is based on an analysis by the Carbon Tracker Institute and others: given the commitment to hold the increase in global temperature to no more than two degrees Celsius, the world can afford to add roughly 565 more gigatons of carbon dioxide into the atmosphere by midcentury. But as of 2011, there are 2,795 gigatons in proven coal, oil and gas


reserves (Carbon Tracker, 2011). One has to conclude that the majority of proven reserves can’t be used if we’re to succeed in limiting global warming to 2 degrees. Those reserves that can’t be used are called “stranded assets,” and the companies that own them are currently overvalued.

This situation is called “the carbon bubble” and many financial organizations are taking it seriously. The Bank of England, World Bank, International Energy Association, International Monetary Fund, PricewaterhouseCoopers, and Goldman Sachs are among many institutions concerned about systemic risks in valuations of oil, gas and coal companies. The fossil fuel divestment campaign is the now fastest-growing divestment campaign in history. One of its big successes was the announcement that Norway's $900 billion sovereign wealth fund, the richest such fund on earth, will divest from the coal industry. Others that have committed to divesting are the Rockefeller Brothers Fund, World Council of Churches, Guardian Media Group, Church of England, and a long and growing list of universities, cities and religious institutions (Fossil Free, 2015). Interestingly, the Guardian Media Group has reported that a number of investment categories without fossil fuels have outperformed those that are exposed to coal or oil (Berkett, 2015). That will certainly help the divestment campaign.

Oxford researchers found that the capital being divested is small but the results could be significant, as the companies lose social license. "The outcome of the stigmatisation process, which the fossil fuel divestment campaign has now triggered, poses the most far-reaching threat to fossil fuel companies and the vast energy value chain" (Ansarr, Caldecott and Tilbury, 2013).

3.2 Climate Action on the Global Scale

Regulation and carbon pricing are another threat to fossil fuels. While action on the international stage has been slow and tentative, many national and subnational governments are making significant progress at reducing greenhouse gases.

The deal announced last year between China and the United States is momentous. China is using pilot cap-and-trade programs in seven test regions, intending to roll out a national program next year. The Chinese have already slowed down the construction of coal-fired power plants, and are the biggest and growing market for power plants based on solar photovoltaic. The U.S.-China deal shows that these two superpowers, the world’s biggest economies and also biggest emitters of greenhouse gases, are falling into alignment in taking serious steps to curb emissions.


Here in Canada, Ontario has announced plans for a cap-and-trade program, joining Quebec with a similar program and British Columbia where we’ve had a carbon tax since 2008. When Ontario’s program is in operation, three-quarters of Canadians will live under some sort of carbon pricing regime. Even Alberta recently announced increases to its carbon levy and higher efficiency targets that large polluters must meet. California, the world’s seventh largest economy, is on target to reduce GHG to 1990 levels by 2020, and recently announced that they will go further by 2030 with a 40% reduction below 1990. Barry Saxifrage writes about commitments to climate action:

Today, heading into the next major climate conference, Paris 2015, more than two-thirds of the world's emissions are covered by public commitments to peak and lower emissions. Over two-thirds of the global economy is signed up. For the first time, many major developing nations are committed. Joining these major nation-states is a rapidly growing list of global financial, religious and civil society groups. Even the US military is increasingly engaged. While the most critical requirement – a reduction in global climate pollution – hasn't happened yet, the underlying commitment to find a solution has grown dramatically. The global trend-line is towards ever greater engagement and commitment. (Saxifrage, 2015)

Of the developed nations, the United States and the European Union are on track to achieve their Copenhagen commitments. China leads the developing world in its pledge to peak emissions by 2030 or earlier. The progress may seem slow, but in reality, it’s happening very fast. Transformative change is difficult to grasp when you’re living through it, but in hindsight it will be clear that an energy transition is underway right now. 3.3 Market Forces The last few years have seen dramatic reductions in renewable energy costs. This is especially true for solar photovoltaic. Deutsche Bank released a report in February this year saying that in over half of the 60 countries that they follow, solar is likely at grid parity today (Shah and Booream-Phelps, 2015). This means in those jurisdictions, solar


competes as a lowest-cost choice for power generation, and it beats the traditional coal. Seen on a lifetime basis, renewables have a distinct advantage in having extremely low operating costs: the sun and the wind are free. Production and capital costs of oil, on the other hand, are on an upward trend as the easily-extracted resources are depleted.

(Randall, 2014)

The transition to renewables is happening first in the realm of electricity generation. The IEA expects that solar energy could be the world’s largest source of electricity by 2050, ahead of fossil fuels, wind, hydro and nuclear (IEA, 2014). But with the Trans Mountain application, we’re looking at oil, which is not normally used for electricity generation. As we all know, oil is mainly a transportation fuel. We want to show that it’s possible to level out and reduce the demand for transportation fuels. That’s where electric vehicles come in: so far, sales of EVs are a tiny but fast-growing portion of the overall vehicle market. A Bloomberg story points out that global electric vehicle sales have quintupled in four years. “Costs are plunging in the electric car business as quickly as they did in the solar industry in the last decade. The price of lithium-ion batteries that power most electric cars has fallen 60 percent from 2010 and will keep declining at the same pace, BNEF estimates. That will bring the price of no-pollution cars within striking distance of ones that require gasoline within a decade” (Landberg, 2015). See the full Landberg story in Appendix 2.


(Landberg, 2015) China is already leading the world in solar power generation, and it may soon lead in growth of EVs too. Approximately 100 manufacturers in China are offering low-cost EVs that provide affordable transportation at low speeds and limited range. In 2014, 400,000 of these so-called “low-speed EVs” were sold in China. The market is huge: only one in ten Chinese has a vehicle now, and many people simply want an affordable car that can be used to get around town, or perhaps as a second car. Long range and high speeds are not needed. “Chinese companies are expanding aggressively to fill the growing demand. There are already at least one million low-speed EVs in use in China, and companies in the industry expect sales to increase by at least 50 percent and top 600,000 units in 2015, and to reach at least one million units [per year] by 2020. In fact, some industry observers believe that the one million mark could be achieved within a year or two, and that as many as three million low-speed EVs will be sold in 2020, generating revenue of RMB 100 billion ($16.1 billion)” (Perkowski, 2015). The low-speed EVs address consumer demand without contributing to air pollution, a major problem in China. The Chinese are serious about reducing air pollution.


Development of smart grids will become the next big thing in many of the more developed countries. Rather than having long transmission lines crisscrossing the landscape from nuclear plants and hydro dams, we will have localized power sources, from people’s rooftops and small solar/wind farms on the outskirts of towns. Advanced energy storage technologies, for instance Tesla’s new Powerwall home battery, along with smart grid and power sharing, will make owning and operating EVs that much easier, increasing EV sales and reducing demand for oil further. Low-cost solar and wind power, electric vehicles, distributed generation and smart grids will all play a part in reducing demand for oil as a transportation fuel. This may very well take place during the projected lifespan of an expanded Trans Mountain pipeline. 4.0 Local Impacts The existing Trans Mountain pipeline already goes right through our city and under the Thompson River. It’s 60 years old, in operation since 1953 according to the Kinder Morgan website. We’re concerned about oil spills with the old pipeline, and we’re also concerned that the construction and operation of an expanded pipeline would bring more risk of harm to our community and environment. Here we address the fourth issue under consideration by the National Energy Board, the potential environmental and socio-economic effects of the proposed project, and speak from the perspective of Kamloops residents who are directly affected by the project.


(Wilderness Committee, 2014) 4.1 Oil Spills and the Importance of Healthy Rivers and Salmon Our city’s name "Kamloops" comes from the Shuswap word "Tk'əmlúps", meaning 'meeting of the waters,' and our university recognizes the importance of our rivers in its name “Thompson Rivers University.” We are at the confluence of the North Thompson and South Thompson, and these two rivers become the Thompson River that flows westward to the Fraser. The current pipeline already exposes our rivers and watersheds to the risk of oil spills and contamination. An expanded pipeline would increase the risk to the North Thompson River, the pipeline crossing at the Thompson River and downstream from there, and the Peterson Creek watershed. If the pipeline expansion were to be built, the new, larger pipeline would carry mainly heavy oils, in particular, diluted bitumen (“dilbit”). Bitumen is quite thick, so it’s diluted with lighter petroleum products called “diluents” so that it will flow through the pipeline. Diluents are usually natural gas condensate, naphtha or a mix of other light hydrocarbons. Diluted bitumen is the same product that was spilled at Kalamazoo, Michigan, in July 2010. The Enbridge Line 6B pipeline burst there, spilling 843,000


gallons of diluted bitumen into a tributary of the Kalamazoo River. It took 18 hours for Enbridge to recognize that there was a spill. The six-foot break in the pipeline resulted in the largest inland oil spill in U.S. history, and one of the most expensive.

Photo: A worker lifts oil-covered debris from the Kalamazoo River in Battle Creek [July 27, 2010]. A pungent odor is hanging over the Battle Creek area and the Kalamazoo River valley a day after 840,000 gallons of oil leaked into a creek that feeds into the river. The Associated Press. Clean-up at Kalamazoo has been a long and difficult process. When the diluted bitumen spilled into the river, the volatile diluents evaporated quickly, releasing toxic chemicals like benzene which have short and long-term risks to human health (Cenovus Energy Inc., 2013). This left the heavier bitumen to sink. Thirty-five miles of the Kalamazoo River were closed for two years while clean-up was in progress. The Environmental Protection Agency (EPA) later ordered Enbridge to return to dredge portions of the river to remove submerged oil and oil-contaminated sediment (Living on Earth, 2012). Enbridge has spent over a billion dollars in cleanup, but much of the


bitumen has mixed into sediments at the bottom of the river and can’t be recovered without causing greater damage. The US Office of Response and Restoration writes that “the early hours and days of a dilbit spill are extremely important, and there is only a short window of time before the oil becomes heavier and may become harder to clean up as it sinks below the water surface” (NOAA, 2014). So of course, we’re very concerned at the thought of a second pipeline that would carry large volumes of diluted bitumen along and under our rivers. We enjoy the beauty of the rivers, and we swim, boat and fish in them. Kamloops has a very strong tourism industry that would suffer from a pipeline spill. Communities to the west of Kamloops take their drinking water from the Thompson River downstream from the pipeline. We have a special concern for the salmon and their habitat. Kokanee, chinook and sockeye salmon spawn in the Thompson region. A pipeline spill affecting the North Thompson or Thompson Rivers would be disastrous to the salmon regardless of the time of year, since bitumen sinks and is so difficult to remove. Such a spill would contaminate the salmon habitat and decimate already vulnerable salmon populations. The commercial value of the salmon includes a vibrant sports fishery and a small First Nations-owned commercial fishery at Kamloops Lake (Fortems, 2014). The sockeye salmon run at the Adams River just east of Kamloops attracts up to 250,000 people from all over the world. They come to see millions of salmon spawning there every four years, in the dominant years (Tourism Kamloops, 2014). This brings big economic benefits to the region. The potential for an oil spill into local rivers is a direct threat to the salmon and the tourism sector that relies on them.

The salmon also have huge ecosystem and cultural value. The salmon are a food source for bears, ospreys and bald eagles, and they replenish soil productivity, nourishing the trees and insects. First Nations communities rely on the salmon fishery for their traditional food. The salmon are givers of life, bringing nutrients from the ocean to the inland ecosystems, and they are priceless. We urge the Board to conclude that the pipeline expansion poses an unacceptable risk of harm to our rivers and salmon, and to therefore reject the application.


4.2 Oil Spill Risks and Responses Many people take the existing pipeline for granted and figure that it’s been fine so far, so why would another pipeline be a problem? We have two responses to that. First, “since 1961, Trans Mountain has reported approximately 82 spills to the NEB” (Trans Mountain, 2014). Lucky for us, the spills in Kamloops have been relatively small and not in the river. But there are no guarantees. A Kalamazoo-type spill can happen in Kamloops too. With two pipelines involved and a tripling of volume, the risk of a rupture is both more likely and more severe. And second, the pipeline contents would change, bringing far more diluted bitumen through Kamloops than ever before. The existing pipeline now transports a variety of light and heavy crude oils and refined products in sequential batches. If the expansion goes ahead, the old Line 1 would carry mainly refined products and light crude oils in batches. The proposed Line 2 would normally carry heavy crude oils (generally diluted bitumen, “dilbit”) in batches. That means up to 590,000 barrels of diluted bitumen would flow through Kamloops each day. As mentioned above, diluted bitumen is very difficult to clean up when spilled in water and the evaporating diluents release toxic elements into the air.

On January 15, 2015, the City of Kamloops, as an intervenor, requested information: “What resources will Trans Mountain allocate to the Kamloops area to ensure a timely and adequate response to any pipeline accident, malfunction and/or spill? How will this be determined to be sufficient?” (City of Kamloops, 2015, p.4). Kinder Morgan responded saying the Emergency Management Plan (EMP) for the proposed expanded pipeline hasn’t been developed yet. They have provided a redacted copy of the EMP that concerns the existing pipeline and authorities can get an un-redacted copy if they meet certain conditions. The EMP that will apply to the new pipeline will be developed in consultation with affected parties and consistent with the National Energy Board’s requirements (Trans Mountain Pipeline ULC, 2015, pp. 30-33). They have responded the same way to similar requests from the City of Vancouver and the Province of British Columbia. So we see that Kinder Morgan is unwilling to tell the City of Kamloops how they would handle a pipeline spill. How irresponsible is that? Is there a reason why the public should trust that this big company will do the right thing, or that they even have the capacity to do so, when they can’t tell us now what that will be? Hardly. Given recent federal and provincial budget cuts and regulatory changes, our protections


have been degraded. Those levels of government are not safeguarding our communities and environment the way they should be, and we can’t rely on them to fix things that go wrong: look at the recent oil spill in Burrard Inlet and the Mount Polley disaster. We ask the Board to require Kinder Morgan to file its Emergency Management Programs (EMP) for review and to extend timeframes to provide opportunities to the intervenors to submit questions and receive responses. Failing that, the Board should find the application is deficient and reject it. 4.3 Jobs and Tourism Venture Kamloops has this to say about our city:

The City of Kamloops’ economy is strong and diverse. Forestry, mining, retail and agriculture have always anchored the economy of Kamloops as core, or driver, industries and now the emerging areas of technology, bioenergy, sustainable industry and tourism are strengthening our economic base and contributing to the city’s dynamic growth. The City of Kamloops has long recognized Sport Tourism as an economic generator for the city and to that end made becoming Canada’s Tournament Capital one of its top goals in City Council’s Strategic Plan. In March of 2002, the City officially registered its trademark as “The Tournament Capital of Canada”. With close to $50 million invested in new and renovated sports facilities, Kamloops is a proven location for hosting tournaments and events. (Venture Kamloops, 2015)

With tourism, and sports tourism in particular, as major contributors to our economy, we require a healthy natural environment. A serious pipeline spill in the region would be disastrous. Compare that picture to what Kinder Morgan offers: “Approximately 90 direct new full-time positions will be created during the operations phase of the Project. Of these positions, 40 are anticipated to be in Alberta and 50 are anticipated to be in BC” (Trans Mountain Pipeline ULC, 2013, p. 182). So of the 50 new direct jobs in BC during the operational phase, Kamloops might expect a handful, maybe five? And along with those very few new jobs comes the risk of an oil spill contaminating our land and water. Granted, there would be spin-off jobs and increased municipal tax revenues, but it still seems a bad deal to us.


We think it makes more sense to protect our quality of life so we can attract and grow the clean industries that will provide jobs and be good stewards of the environment. We’re in it for the long haul and want to take care of what we have. We want jobs in which we can contribute to something meaningful and important. And we want our water, air and land to be healthy now and for generations to come. 4.4 Parks Two important local parks and natural areas are in the path of the expanded pipeline, if approved. One is the Lac du Bois Grasslands Protected Area, a significant grassland habitat. It appears that Kinder Morgan wants to route the new pipeline through this protected area rather than through residential areas in the Kamloops neighbourhood of Westsyde, where the existing pipeline is located. The Grasslands Conservation Council of BC has made a submission to the National Energy Board in which they describe the significance of protected grasslands areas.

Natural grasslands in British Columbia represent important ecological, social and economic values. Should this project proceed these values will be impacted in a substantive, long term and in some case irreparable way…

… As the application has been submitted, it fails to address the many land use issues noted. It is therefore not acceptable, and does not honour the tone and direction of the initial public consultation phase of the environmental assessment process.

Until the above noted concerns are effectively addressed, the Grasslands Conservation Council of British Columbia firmly opposes the approval of the Trans Mountain application, as submitted, for the additional pipeline through the grasslands of British Columbia.

(Grasslands Conservation Council of BC, 2015)

The pipeline expansion would also disturb Kenna Cartwright Nature Park, the largest municipal park in the province. The park offers an extensive network of nature trails for hiking or cycling with panoramic views of the city, the Thompson Valley, Kamloops Lake and the convergence of the North and South Thompson Rivers. This is a well-loved park. We are opposed to the use of parks and protected areas for industrial purposes.


4.5 Cumulative Impacts One matter of particular concern in our area is the proximity of the Trans Mountain pipeline and the proposed Ajax Mine, an open-pit copper-gold mine located near and partly within Kamloops city limits. The Ajax project is currently in the pre-submission phase of a joint provincial and federal environmental assessment process. The proposed mine overlies the existing Trans Mountain pipeline. Kinder Morgan has suggested moving the current pipeline and proposed second pipeline to skirt around the proposed mine. If both projects were to go ahead, there would be a major crude oil pipeline (two lines) and an open pit mine very close together and within the Peterson Creek watershed that flows right through the Kamloops downtown. This is a BIG concern. In addition, it is important for the Board to acknowledge the environmental impacts and risks likely to be experienced in the Kamloops area from the proposed Trans Mountain expansion project, and their relationship to the significant environmental and socio-economic impacts currently being experienced by existing industrial activity in the Kamloops region. In sum, the cumulative impacts associated with industrial development in Kamloops are cause for concern and warrant further (and comprehensive) analysis. Therefore, we expect the Board to consider in its decision the additional and cumulative impacts of the proposed pipeline and mine, and their respective relationship to the two large operating mines (New Afton and Highland Valley), the large industrial pulp and paper mill, diverse forestry extraction activities, urban footprint of the City of Kamloops and many other heavy industrial facilities currently operating in the region. Additionally, it is important to note that there are a number of other industrial facilities proposed in Kamloops and regionally. Given the high likelihood that these activities all proceed there is significant cause for concern with respect to Valued Components and the overall carrying capacity of the local environment and community well-being (i.e. socio-economic impacts). We are therefore of the opinion that the cumulative impact assessment methodology used by the Proponent is insufficient to adequately understand and respond to the diverse cumulative impacts, current and future, in a region that is experiencing significant industrial and urban growth. Further study is required to ensure that the carrying capacity of the local environment and acknowledged Valued Components (in particular local air quality, sensitive terrestrial ecosystems and fisheries habitat) are adequately protected to ensure the public’s interest is respected prior to project authorizations.


Closing In closing, we ask the National Energy Board to reject the Trans Mountain Expansion Project, on the grounds that the project is not needed, and it is not in the public interest when potential environmental and socio-economic impacts are taken into consideration. Beyond that, it’s time for Canada to have a nationwide discussion on our energy strategy and find a balance that includes planning for traditional energy sources, energy conservation and renewable energy. We see many forces pushing fossil fuels into decline. The process is not very far along but it’s accelerating dramatically. We submit that Kinder Morgan’s assumption of business-as-usual oil sands growth is unwise and financially risky, and that their forecasts concerning the need for pipeline expansion are unrealistic. It would be very short-sighted to think that the status quo will continue much longer. We ask the Board to recognize that we’re in the early stages of a global transformation in energy and realize that an expanded pipeline only perpetuates the old business model. The transition away from fossil fuels is necessary, doable and inevitable. It will happen through market forces, regulation and divestment. Canada ignores this at our peril. If we want long-term prosperity, we need to realize that the current situation with respect to fossil fuels will change rapidly and prepare for a different future. As for our hometown, Kamloops, we see serious risks to our environment, tourism industry, quality of life and ability to attract skilled people. We feel that these far outweigh the few benefits of an expanded pipeline. We do not believe that communities along the pipeline’s path should bear the risks of oil spills while those who would benefit are far-away Kinder Morgan shareholders.


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Documents

Letter of Comment British Columbia Sustainable …...In April this year, Michael Liebreich of Bloomberg New Energy Finance told the audience at the Future of Energy Summit, that in