Northern Gateway Response to CPE Op-ed
26 Apr 2014, The Vancouver Sun
SPECIAL TO THE SUN, John Carruthers, President of Northern Gateway Pipeline
Experts back Northern Gateway plan 9
Pipeline: Critics are off base in attack on findings of professionals and Joint Review Panel
With many years’ experience in business development I always ensure the details of any project I am working on have been developed by professionals and reviewed by experts. The Northern Gateway Pipeline is an ideal example of this approach. From the very beginning we have assembled some of the most respected engineers, scientists and naval architects from B. C. and around the globe to ensure that ours is a safer, better project.
On many occasions we sought out a second or even third analysis to ensure our project meets the high standards that British Columbians and Canadians rightly expect.
Once our initial submission was complete, the independent Joint Review Panel conducted the most comprehensive review of its kind in Canadian history to determine that our project should be approved, subject to 209 important conditions.
I am proud of that work, and proud of the rigour that has been applied at every turn. That is why I am disappointed that a few individuals have formed a small group to attack the work of our experts, and to try to discredit the objective sciencebased findings of the Joint Review Panel.
This group has made claims about our project that ignore the facts and proven science.
Among the errors made by this group is the assertion that Northern Gateway did not account in its planning for future LNG related vessel traffic on B. C.’ s north coast. This is simply not true. Our risk analysis looked specifically at this issue and found that, even with the proposed LNG projects, traffic on B. C.’ s north coast would not come close to what is safely managed every day on B. C.’ s south coast, and at oil terminals worldwide in similar environments.
This group also asserts that Northern Gateway underestimates the probability of an oil spill. But on the day that members of this group asked their questions at the JRP hearings, our experts explained why Northern Gateway’s marine risk analysis is based on conservative estimates.
The group also points to the Exxon Valdez oil spill to oppose Northern Gateway. However, they fail to acknowledge that the Exxon Valdez spill was a catalyst for drastic and lasting changes in tanker regulations, design, construction, maintenance and operation. These changes include the adoption of double hulls, tug escorts, advanced navigation aids and oil spill preparedness planning — independently audited. Taken together, these changes mean a spill like the one 25 years ago simply could not happen today.
It is important to note that members of this group brought all of their concerns before the JRP in the form of written evidence, letters of comment, oral statements and final arguments. This group also took the opportunity to cross examine Northern Gateway’s experts in front of the Joint Review Panel over a number of days in 2012 and 2013. And the Joint Review Panel responded to these concerns, formally asking Northern Gateway on two occasions to answer, in writing, to issues raised by this group.
Throughout this process, Northern Gateway and our team of leading experts ensured the JRP had all the information and science necessary to assess the validity of the group’s criticisms. After its comprehensive review of the evidence, the JRP recommended that Northern Gateway be approved, subject to 209 conditions.
Northern Gateway is committed to several industry leading measures for marine safety, including: reduced vessel speeds; escort tugs; stringent tanker acceptance criteria and oil spill preparedness measures unparalleled in Canada. The Joint Review Panel has agreed these safety measures are important and has made them a condition of project approval and operation. We are proud of these measures and know they will help make our project, and B. C.’ s north coast, safer.
This group has chosen to disagree with the findings of the most exhaustive regulatory approval process ever completed in Canada, the conclusions of master mariners, BC Coast Pilots, and dozens of professional engineers, scientists and naval architects. I hope that by writing this it will help shed light on their inaccurate campaign materials that are being used to second guess the JRP process and to attack the experts and professional engineers who work tirelessly on our project to make it a model of safety for B. C.
Our Response to Enbridge
This article was never published by the Vancouver Sun.
On April 26, John Carruthers, president of Northern Gateway, wrote an editorial in the Vancouver Sun (see above) stating that “a few individuals have formed a small group to attack the work of our experts, and to try to discredit the objective science based findings of the Joint Review Panel.”
As a group of five professional engineers, critical of the risk analysis presented by Northern Gateway and of the review of these risks by the Joint Review Panel, we can only assume we are the group to whom Mr Carruthers is referring.
Mr Carruthers states that we have ignored the facts and the proven science. This is, plainly, not true. We reviewed in detail the risk analysis presented by Northern Gateway on the basis of which they got conditional project approval from the Joint Review Panel of the National Energy Board. We just looked at the evidence presented, found it flawed and raised the following points during our participation in the Joint Review Panel hearings. These points are stated in detail on in our white papers http://icareconsulting.com/~concernedengine/reports-and-white-papers/ .
1. Northern Gateway states that, including all the mitigation measures like using tugs, double hulled tankers and navigational aids, the return period for an oil spill greater than 5,000 m3 (or 31,500 barrels) is 550 years. A return period is the expected or average time between occurrence of such spills and, when thus reported, it sounds long and of somewhat little concern. What they failed to say is that the 550 years are exactly equivalent to a probability of 9% that a spill of 5,000 m3 (or 31,500 barrels) would occur during the 50 years of planned activities for the project. We did not invent these numbers using our own model or calculations, we just evaluated what was presented in Northern Gateway’s analysis. We believe that, given the major consequences of just one such spill in northern B.C’s coastline, a 9% probability is just not acceptable.
2. We asked directly to the authors of the analysis, during the Joint Review Panel hearings, whether the 550 years (and the corresponding 9% probability) they advanced was, in their view, acceptable. They answered that their contract was limited to a calculation of the return period and did not include the question of acceptability. This was, we thought, a very honest and revealing answer. Northern Gateway reinforces the acceptance of their results by stating that, as Mr. Carruthers says in his letter, there are many factors that would make their projections conservative. This, however, is just talk which is not quantified in the submitted analysis.
3. Northern Gateway also submitted navigational simulation results done by another of their consultants. We said during the hearings that, while this employed a very sophisticated software tool, it was not fully utilized (the number of simulation runs was too small) and could not be used to estimate risks or the safety of the project. These simulations only showed that, for a limited number of situations over a restricted area of the passage, the captain of the vessel could negotiate the challenges, apparently, without a problem. Again, given the large uncertainty in the many factors involved, these limited simulations, while useful for captain’s training, did not add much to the study of project safety.
4. We argued that the large traffic increase due to LNG developments was not properly taken into account. This is undeniable, and Mr. Carruthers statement in this regard does not conform to what was actually done. Their risk analysis includes a factor to account for collisions. They re-calculated the risk (expressed as the return period) when that factor was artificially increased by 25% to 50%, depending on the location along the channel. As Mr. Carruthers says, they saw an increase in risk that “would not come close to what is safely managed every day on B.C’s south coast or at oil terminals worldwide in similar environments”. Again, this is unquantifiable talk. What does it mean? We asked during the hearings whether the increase in the number of tankers per year, from 220 for bitumen to 652 for bitumen plus NLG, was equivalent to a 20-50% increase in the collision factors, and the answer was evasive or non-informative, and the fact remains that this issue has not been studied properly.
5. We argued, along with many other interveners, that the consequences of a spill could not be properly evaluated, given that the behavior of Dilbit after a spill into the sea could not be or was difficult to be predicted. In fact, at the same time of the hearings, Environment Canada was still conducting experiments on the matter. If Dilbit would even partially sink it would be difficult to clean up, and this uncertainty makes it very difficult to forecast consequences, formulate plans for cleanup response or anticipate economic losses. Talk about a “world class” response system obviously appears to be premature.
6. Apart from the above more technical concerns, we asked the following question. Given that the probability of a damaging spill is unacceptably high, and the consequences of a spill are hard to predict, the total cost of a spill is equally uncertain and would probably be very high, who will be responsible? the operator of the pipeline? the tanker company? The Federal Government? Or the people of BC? The truth of the matter is that tanker accidents, especially ones that result in the spillage of large amounts of cargo or fuel oil, are, thankfully, very rare. However, this does not mean that they cannot and will not happen. For Mr. Carruthers to state that a “spill like [the Exxon Valdez] simply could not happen today” is complete hubris. Does this mean that accidents simply cannot happen? Of course not.
Since the beginning we have based our criticisms of this project on Northern Gateway’s own risk analysis. For the past two years we have been trying to get further information from Northern Gateway to justify their assumptions. We submitted a Letter of Comment and we questioned their experts at the Joint Review Panel hearings. At every point we have been denied or offered arguments about their conservatism and wishful thinking about a world class project. Our concerns are not complex. For the most part, we have simply delved into the details of their analysis and asked that they justify the assumptions at the core of their claims. We feel that the Joint Review Panel Report to the Federal Government, even with its 209 conditions, fell short of raising the fundamental questions that were asked during the hearings.
Far from being economic obstructionists, we feel that it is our professional responsibility to raise questions about the evidence presented before going ahead with such a major project.
Brian Gunn Professional Engineer of BC.
Spokesperson for Concerned Professioanl Engineers