EAO - Islands Trust

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Mar 23, 2015 - Concerns about the completeness of the EAO process re vessel traffic ... consequence events such as a vap
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File No.: 0420-20 March 23, 2015 Via online comment form: http://www.eao.gov.bc.ca/pcp/forms/Woodfibre_LNG_form.html Michael Shepard, Project Assessment Manager Environmental Assessment Office (EAO) PO Box 9426 Stn Prov Govt Victoria BC V8W 9V1 Dear Michael Shepard: Re: Woodfibre LNG Limited’s application On behalf of the Islands Trust Council, I am writing to comment on the marine shipping aspects of Woodfibre LNG Limited’s application to develop and operate a liquefied natural gas (LNG) production facility and floating LNG storage at the former Woodfibre Pulp and Paper Mill site near Squamish, B.C. We appreciate that the EAO invited Islands Trust and Bowen Island Municipality staff to participate in the Advisory Working Group. We also appreciate that the EAO held information sessions in Squamish, West Vancouver, and Bowen Island, and extended the public comment period from 46 days to 60 days in consideration of the high level of public interest in the proposed Project. We also recognize that Woodfibre LNG Limited, in cooperation with the Sunshine Coast Regional District and Gambier Island Local Trust Committee, hosted a Roundtable Discussion on March 21st on Gambier Island to provide information on the Project and to give community members an opportunity to ask questions and provide feedback. We have heard from constituents that they would still appreciate more time to comment on this complex application that could have lasting implications for the culture, environment, and economy of Howe Sound communities. I understand that the EAO’s intention when seeking public comments is to ensure that all potential environmental, social, heritage and health effects that might result from the proposed Project are identified for consideration as part of the assessment process. Before providing comment on the application, I believe it is important for the EAO to be aware that in 2008 the Islands Trust Council voted to support a ban on the passage of LNG tankers in the waters of the Malaspina, Georgia, Juan de Fuca and Haro Straits, and Boundary Pass. The Islands Trust’s position on the subject has not changed since the 2008 position. …/2

Bowen Denman Hornby Gabriola Galiano Gambier Lasqueti Mayne North Pender Salt Spring Saturna South Pender Thetis

Environmental Assessment Office March 23, 2015 Page 2 With regard to the Woodfibre LNG Limited’s application itself, we have heard strong concerns in our communities on the following topics: 

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Concerns about the completeness of the EAO process re vessel traffic risks/mitigation. Woodfibre LNG has stated numerous times in its application that marine shipping risks will be mitigated by implementing the recommendations of Transport Canada’s TERMPOL Review Committee. But the public will have no opportunity to comment on the adequacy or environmental and socio-economic consequences of these future mitigation measures. We understand that Woodfibre will provide its submission to the TERMPOL Review Committee in late August and the Review Committee is unlikely to release recommendations before December 2015, while the EAO public comment period closes today, March 23, 2015. This creates a situation where our communities, and indeed the EAO, are hindered in their ability to comment knowledgeably on the marine shipping impacts of the Project and the social acceptability of future mitigation measures. For example, if a moving exclusion zone was to be required around each transiting vessel, this could have negative consequences for the marine users of Howe Sound, including BC Ferries. In this recreational boating hub, there also remain unanswered questions about whether LNG tankers could stop in time to avoid a small vessel in distress and/or with an inexperienced boater at the helm. It is also unclear to us whether the EAO has sufficient information about vessel traffic risk without the benefit of the documents that will be submitted to the TERMPOL Review Committee. Concerns about possible shoreline erosion, damage to docks and danger for people in small recreational vessels, such as canoes, from vessel wakes from LNG vessels and tugboats-our communities still remember the damage done by the BC fast ferries. Concerns about a lack of information on the impact of the presence of LNG tankers in Howe Sound on the newly emerging Howe Sound tourism brand. This brand relies on the majestic, wild beauty of the region. Will future eco-tourism jobs be compromised? Concerns about a lack of information about the consequences of low probability/high consequence events such as a vapour cloud explosion or oil spill following a serious tanker accident.

The Islands Trust Policy Statement, a statutory document founded in extensive community consultation and approved in 1994 by the then Minister of Municipal Affairs, encourages provincial and federal agencies to ensure safe shipment of materials hazardous to the environment. The Salish Sea is a special place and a unique part of the world. Our waters are home to some of the most productive and biologically-diverse ecosystems on earth. In our Policy Statement the Islands Trust Council holds that economic opportunities should be compatible with the conservation of resources and protection of community character. There are strong concerns that LNG tankers do not fit with the current community character of Howe Sound. We hear a desire for governments at all levels to support Howe Sound’s ongoing transition from a polluted industrial zone to a thriving environment that supports sustainable businesses, including a world-class tourism industry. In light of the Islands Trust’s mandate and the concerns from community members on both the content of the application and the lack of public participation in the process of approval, we hope the EAO will carefully consider all aspects of environmental, economic, social and cultural impacts on the Howe Sound communities throughout the process. …/3

Environmental Assessment Office March 23, 2015 Page 3 The Islands Trust Council is a federation of local government bodies representing 25,000 people living within the Islands Trust Area and about 10,000 non-resident property owners. The Islands Trust is responsible for preserving and protecting the unique environment and amenities of the Islands Trust Area through planning and regulating land use, development management, education, cooperation with other agencies, and land conservation. The area covers the islands and waters between the British Columbia mainland and southern Vancouver Island. It includes 13 major and more than 450 smaller islands covering 5200 square kilometres. Thank you for your consideration. Yours sincerely,

Peter Luckham Chair, Islands Trust Council cc: Islands Trust Council Bowen Island Municipal Council Gambier Island Local Trust Committee Nicholas Simons, MLA, Powell River – Sunshine Coast Jordan Sturdy, MLA, West Vancouver – Sea to Sky John Weston, MP, West Vancouver/Sunshine Coast Islands Trust Area First Nations San Juan County Council Lisa Gordon, Director, Trust Area Services Islands Trust website