SSCAS COMMENTS FOR WLNG EA CERTIFICATE

Below is the Sea to Sky Clean Air Society’s submission to the Environmental Assessment Office regarding Woodfibre LNG’s application for an environmental assessment certificate. Leading up to this comment period, were a couple of meetings held with WLNG during which time a number of questions were asked and comments made, which having been answered do not appear in the submission (but which are referenced). Please see the attached documents for details. The submission to the EAO (March 23rd, 2015) is below.

140822 Sea to Sky Clean Air Society Responses

WLNG Meeting Minutes-Feb. 25 2015

 

March 23, 2015

RE: Woodfibre LNG Project Application for Environmental Assessment Certificate

To: BC Environmental Assessment Office,

The Sea-to-Sky Clean Air Society (SSCAS) is a charitable society committed to improving air quality within the Howe Sound and Sea-to-Sky airshed. Where possible, we seek to work collaboratively with airshed stakeholders on air quality and climate change initiatives that fit with our charitable purposes of: 1) organizing and participating in programs that are designed to improve air quality in the Sea to Sky / Howe Sound airshed; 2) identifying, communicating and supporting initiatives that have both air quality and GHG reduction co-benefits, and building awareness of such in the public, and; 3) conducting research related to air quality and climate change, and disseminating the results through a variety of mediums.

We are a small community-based organization that relies on the technical expertise of advisors, mainly advisors who work for the Ministry of Environment (MoE), to analyze air quality monitoring data and infer impacts to the airshed. Our role as per our mandate and the Air Quality Management Plan (AQMP) that directs our work is to disseminate their results through our communications channels and act upon their conclusions through the programs we develop and implement. As such, the extent to which we can directly interpret and verify the technical analysis of potential emissions and their impacts contained in Woodfibre LNG’s (WLNG’s) project description is limited, and quite honestly, outside of our purview. That being said, we have broad questions and concerns about the project that are high-level in nature. In some instances, they are aimed at the LNG industry as a whole, which nonetheless we feel are germane to this specific Project.

Our submission is based on a review of the project description components related to air quality and green house gas emissions, as well as the attenuating appended files compiled by WLNG for its application for an Environmental Assessment Certificate. Additionally, we met with WLNG on July 27, 2014 to have our initial questions answered and received written responses available on our website. We also met with WLNG on February 25th, 2015 to have some additional questions answered. This meeting was followed by an email exchange of the meeting minutes and written answers to those questions that WLNG could not answer at the time of our meeting due to timing constraints. The questions and minutes from these meetings can be found on our website (www.seatoskyairquality.com) and in the Appendix below. We appreciate the time WLNG afforded us in responding to our questions, and appreciate their willingness to collaborate on meeting the objectives of our Air Quality Management Plan (AQMP).

Based on our focused literature review and other communications exchanges, we have the following comments that we hope will be taken into consideration in reviewing the Project application. We have divided our comments into two parts; the first related to potential criteria air contaminants (CACs), and the second pertaining to potential green house gas (GHG) emissions.

  1. Criteria Air Contaminants (CACs)

1.1 As our mandate is focused on improving air quality in the region, our primary concern is with the addition of a new point source of criteria air contaminants (CAC) in our airshed. CACs are those contaminants that have the greatest propensity to affect human health and / or key valued components such as visibility and odour. CACs include Nitrogen Oxides (NOx), Particulate Matter (PM2.5 and PM10), Volatile Organic Compounds (VOC), Carbon Monoxide (CO) and Sulphur Dioxides (SO2). The aforementioned CACs are measured variously throughout the airshed and additional monitoring may be needed to fully capture potential emissions. It is our understanding that such a determination is undertaken through consultation with the Ministry of Environment (MoE) and through this Environmental Assessment (EA) certification process, and that a third party may be brought in to support objective monitoring and reporting. SSCAS is a strong advocate of monitoring and would welcome opportunities to share results with the broader public.

1.2 According to our technical advisors, it appears that the dispersion modelling selected (CALPUFF) and other airshed modelling conducted was appropriate. Of concern to one stakeholder that contacted SSCAS via email, was the apparent lack of a wind analysis, however, our advisors note that an appropriate wind analysis was conducted that consisted of 3-D wind fields being generated for CALMET input using a MM5 meteorological model. Details of how this model was validated through comparison to measured data at several meteorological stations operated by MoE and Environment Canada within the model domain can be found in the Project Appendices. It appears that the modeling accords with requisite MoE guidelines and has a considerable amount of conservatism built-in. The assessment of the project location, according to complex terrain and meteorology analysis, is also appropriate. All in all, this means that the potential CACs of this Project in and of themselves are likely negligible as described.

1.3 It is however worth noting that even if emissions fall below the regulated standards, for some air contaminants, such as particulate matter (PM10) and fine particulate matter (PM2.5), “no safe thresholds have been identified below which no damage to health is observed” (World Health Organization, http://www.who.int/mediacentre/factsheets/fs313/en/). This means that efforts to reduce and mitigate, which are incumbent upon WLNG to do, can never fully eliminate the threat posed to the health of some individuals.

1.4 This concern could be further compounded by the fact that the ambient concentrations of PM predicted in Table 5.2-17 were likely underestimated due to the use of pre-2014 values in developing the baseline for PM2.5, The reason for this is that prior to 2014, tapered element oscillating microbalance (TEOM) equipment was predominantly used at air quality monitoring stations throughout the region (and Province), which was less accurate in capturing PM emissions’ values than the Beta Attenuation Monitors (BAM) that have since replaced them. While the PM10 and PM2.5 levels associated with this Project alone are low, when combined with the (underestimated) baseline they could constitute 60% of the criteria.

1.5 Additionally, when upset conditions are in effect compared against this too-low baseline there is a predicted near exceedance of PM2.5 in the short-term criteria.

1.6 Nitrogen Dioxide (No2) levels are also worthy of note. When the Project emissions are added to the baseline, two times the current amount of N02 is released in the short-term, and the annual amount is three times above the current baseline. This poses a concern for Ozone (O3) and (PM2.5) production.

1.7 We also note that Hydrogen Sulphide (H2S) is mentioned several times as a contaminant, but does not seem to be assessed in terms of its potential for air quality impacts – its association with Hazardous Air Pollutants (HAPs) seems to indicate that it will be assessed as part of the human health risk assessment, but this ignores the role it plays in odour-impacts.

1.8 Providing an airshed-specific context for emissions in Section 5.2.3.2, by utilizing the Sea to Sky Emissions Inventory (though dated, it is still reflective of the current realty) instead of the federal emissions inventory would have lent additional accuracy to the modelling.

1.9 We are concerned that the proposed Project represents yet another emissions source, which considered cumulatively with a host of other emissions sources, will indeed negatively impact our airshed. The cumulative effects analysis provided is in our opinion flawed, as some of the other emissions sources are not being considered at their maximum output. For instance, only the emissions from the construction of housing developments (Table 5.2-21 mentions Box Canyon Hydro, South Britannia, and Britannia Beach McDonald Development) are being considered, rather than the use of said developments (which would include home heating and energy-related emissions for instance), which could result in emissions that far exceed those rendered during construction. The assumption that the construction stage is the time of greatest emissions for these types of projects underestimates the magnitude and duration of PM emissions and eliminates other contaminant emissions (NOx, CO, SO2) from the assessment entirely.  Similarly, it appears that only the build-out of Highway 99-“the Highway 99 Improvement Project”- is considered in the cumulative effects analysis, not the continual use of that piece of infrastructure, which is likely to increase with anticipated population growth and increases in tourism in the region. This, in our opinion, is not representative of some of the key current and future emissions sources in our airshed and thus vastly underestimates the potential for cumulative negative impacts on our regional air quality.

1.10 There also appears to be an assumption that it is only the WLNG project that might overlap with each of the individual projects identified, but no acknowledgement is offered that all of these projects might overlap each other at the same timeframe.

1.11 There is also no assessment of secondary pollutant (O3 & PM2.5) production, which could be influenced by the combined emissions of precursor pollutants (NOx, SO2) from all project sources.

1.12 We recognize there are difficulties in fully accounting for all of the emissions sources in an airshed (especially non-point sources such as mobile and area-based sources)- it is a problem that is faced by all cumulative assessments. The only way for these cumulative impacts to be assessed effectively is through a regional scale dispersion modelling assessment (including photochemistry)- and we appreciate that it is perhaps unfair to expect one project proponent to foot the bill for it. Nonetheless, we would like to see WLNG recognize the importance of accurately accounting and mitigating for cumulative effects. One way that WLNG could demonstrate this is to actively support the Howe Sound Forum and its regional Cumulative Effects Planning Framework. This framework supports a Cumulative Effects Assessment, and is presently being discussed with the provincial government. We strongly recommend that WLNG become an active partner in these Framework and Assessment initiatives, and be prepared to assist in data collection toward Cumulative Effects Assessment.

1.13 Another area with which we take issue is the fact that in the case of flaring, incineration and energy recovery have been discounted as either too expensive or not warranted. The use of flaring was explained as being for emergency and maintenance conditions. The BC Oil and Gas Commission 2013 Guidelines (http://www.bcogc.ca/node/5916/download) point to a decision tree for reductions in flaring and venting. The first objective is reduction, but clearly the priority sequence for necessary decompression and/or system maintenance is incineration with energy capture, flaring, and then venting. Given the highly visible proposed location of WLNG and periodic poor air quality, we think the decision regarding energy recovery should be revisited.

1.14 This project should be held to a high standard, and we wonder if all avenues for avoiding flaring (and its visual and air quality impacts) have been exhausted.

1.15 Contingency plans should be developed in the case that the described mitigation practices do not adequately minimize noise, dust, and emissions – such that additional measures and solutions can be easily put into practice if required.

1.16 The public should be informed of how complaints can be made- avenues like the Report All Poachers and Polluters (RAPP) hotline- regarding any of WLNG’s activities that result in emissions, noise, dust, odours, etc. This should be made clear on the WLNG website.

1.17 Adhering to the letter and spirit of all local and provincial bylaws and regulations, including the District of Squamish’s idling bylaw that restricts vehicle idling to 2 minutes, should be a priority of WLNG and would demonstrate WLNG’s commitment to being a good member of the community. We recommend adopting Metro Vancouver standards for operating off road diesel powered equipment when at all possible.

1.18 If this project is approved, SSCAS feels there is an opportunity for WLNG to demonstrate a strong commitment to monitoring and protecting health, as well as to evince corporate social responsibility by providing additional monitoring equipment and personnel where needed as determined by MoE, and providing routine air quality monitoring onsite.

1.19 Contributing funds to an emissions inventory to identify all emissions sources in the airshed would demonstrate shared values where protecting air quality is concerned. An emissions inventory for instance could contribute to a larger study on cumulative effects, which would be a useful asset in considering future development proposals with potential air quality impacts.

1.20 If this project goes ahead, we are also in support of the on site restoration work (i.e. greening of the waterfront) being carried out that was mentioned in our February 25th meeting.

1.21 Finally, should the Project be approved, we would hope to work collaboratively with WLNG to ensure the air quality indicators and recommended actions in our AQMP are meaningfully implemented. WLNG is now the owner of an industrial property zoned (in the District of Squamish Zoning Bylaw) for a large industrial power boiler. Whether or not the LNG facility proposal is approved, we wish to strongly encourage WLNG to consider itself a Sea to Sky Air Quality Management Plan stakeholder, and become an active supporter and partner in realizing our goals of continuous improvement in air quality throughout the Sea to Sky airshed.

 

  1. Greenhouse Gas Emissions (GHG):

2.1 The other area of concern for us is the potential for greenhouse gas emissions (GHGs), which contribute to climate change, having both regional and global impacts. BC has committed to reducing its greenhouse gas emissions by a third, by 2020, from its 2007 rates. The District of Squamish has also made commitments in its Official Community Plan to reduce carbon emissions, stating: “The District of Squamish will strive to meet and ideally exceed Kyoto Protocol targets and timelines for reducing global warming pollution. (https://squamish.civicweb.net/document/52607/OCP%20Part%206_%20Appendix.pdf?handle=E299F6FA4E1744F48FB03FBC09F29065 ). The projected emissions from this project will make it difficult to achieve those targets.

2.2 Moreover, full accounting of the emissions- which would consider emissions all the way along the value chain- is not required of the Proponent and has not been provided, which means the projections are considerably lower than actual. We feel full GHG accounting and reporting should be a requirement of all LNG projects and should conform to the highest standards and protocols, measuring Scope 1, 2 and where possible 3 emissions, and ideally speak to the life cycle of the natural gas product.

2.3 We would also like to see reduction and mitigation efforts that manage these upstream and downstream emissions, which may include carbon offsets and carbon sequestration.

2.4 In an effort to be transparent and accountable for its emissions, we would like to see WLNG communicate total emissions (rather than just an emissions intensity, which is a less understood metric) to the public in a clear and comprehensible fashion.

2.5 WLNG used both FPTCCCEA and PCIC modelling to predict GHG impacts. One of the problems with the scope of analysis is the limitation of both the temporal and spatial boundaries provided by WLNG. Nowhere is a calculation of cumulative effects provided other than in regard to other projects in the region- yet cumulative GHG impacts are global in scale and scope. By WLNG’s own reckoning, most of the activities anticipated will have the potential to increase GHG impacts.

2.6 While outside the scope of WLNG’s proposed project, it is our opinion that a greater exploration of alternate natural gas uses, and a stronger rationale for LNG export are needed at the Provincial and National level.

2.7 We would like to see the Province invest in and meaningfully commit to growing the renewable energy sector with desired outcomes aimed at directly benefiting a greater proportion of Canadians, rather than foreign investors or markets. Perhaps natural gas could play a role as a transitional fuel in shifting our dependence on fossil fuels to renewables. SSCAS recommends WLNG continue to explore opportunities for supporting the development of a local renewable energy sector through its business model and through its dealings with the Province. Advocating for a green technology fund to be set up using tax revenues derived from the LNG industry, carbon offsetting, sequestration, and expansion of carbon markets are all possible actions that WLNG could consider. Such steps would have a positive impact on the regional and provincial economy, and would support WLNG’s social license to operate.

2.8 If WLNG is indeed planning on being a world class LNG facility, we would expect to see hyper vigilance in all regards, with reduction and mitigation efforts that reflect and go beyond best management practices, and a strong commitment to transparency and accountability.

Thank you for taking our comments, concerns and suggestions into account. Please feel free to contact me with any questions or requests for additional information.

Respectfully,

Sea-to-Sky Clean Air Society