NEB submission

joseph's picture

Here is my submission to the farcical NEB "TMX re-consideration".

 

I am a 4th generation BC native, and am writing to express my absolute opposition to the  TMX pipeline expansion project.   My family's livelihood and lifestyle is seriously threatened from the catastrophic economic, social, and ecological consequences that will follow from the accident that will inevitably* spill Diluted Bitumen into the Salish Sea.   But even if you believe this risk is worth trading away for a short-term boom in construction jobs, there is mounting evidence that the project itself is a fiscal loser.

1) Tanker traffic through the narrow and extremely busy port and Lions Gate, and out through the tricky "Turn Point",  is projected to increase by a full order of magnitude - from approx. 40 per year to 400 per year.   With a tanker making this hazardous transit more than once per day, it is inconceivable that there would not be a serious marine incident with a large-scale Diluted Bitumen spill.

2) My family, and BC in general, depends deeply on our natural environment for economic activity generated by tourism.  Tourists come to see unspoiled coast lines, to go fishing in pristine waters, and to see whales and dolphins in their natural environment.  There is more than enough evidence to categorically state that even current levels of marine traffic are having a negative impact on marine mammals in the area -- we need to mitigate marine traffic in this area, not increase it by an order of magnitude.

3) The economic case for the project, originally made by Kinder Morgan to the NEB, is based on a deeply-flawed analysis that counts ALL economic activity as a "benefit", and excludes any analysis of competing economic, social, or environmental costs.  For example, in this analysis, an oil spill ADDS value to the project because of the jobs and economic activity it generates, yet it does NOT deduct a cent for lost revenues from fishing, shellfish, whale watching, tourism, etc.  Studies have shown that the costs of just one major spill on land or at sea “will exceed, or greatly exceed, the benefits [of the entire project] for BC and Metro Vancouver.”

 - http://www.policynote.ca/pipeline-sales-pitch/

4) Demand for dirty fossil fuel is falling.  China, our hypothetical Bitumen "market", is moving sharply towards renewable energy, and is estimated to reach renewable "grid parity" within 5 years.   Investments in pipelines and other large-scale fossil fuel infrastructure are likely to wind up as "stranded assets" (i.e., a big waste of money).

Your duty as a panelist entrusted in re-assessing this project is to weigh the potential costs and benefits of this project, not to make a politically expedient recommendation.  This project is a lemon, now officially a poster-child for "Lemon Socialism" - once the potential cost to coastal residents from a spill is accounted for, there can be no economic or social net benefit from this project.

(https://en.wikipedia.org/wiki/Lemon_socialism)

* "For tanker spills, the probability of a spill is a 58% to 98% likelihood over the lifetime of the project."
http://rem-main.rem.sfu.ca/papers/gunton/km_tig_spill_risk_final_report_Upper_Nicola_Band_Expert_Report.__An_Assessment_of_Spill_Risk_for_the_TMEP_(00250905xC6E53)_-_A4Q1T7.pdf

 - https://thetyee.ca/Opinion/2018/04/17/Why-Kinder-Morgan-Pipeline-DOA/
 - http://www.bbc.com/news/business-31689722
 - http://www.cbc.ca/news/business/fossil-fuel-investment-capital-stranded-...

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