Does this look like a safe route for LNG tanker exports?

Send your comment to the BC Environmental Assessment Office about the Tilbury LNG Phase 2 Expansion Project

Deadline for Submission is July 16, 2020

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14 Issues of Concern About This Project

1. LNG tankers in the narrow, busy Fraser River?
Bad idea.

Tankers and barges loading LNG at the jetty would have to be custom-built to pass over the 11.5m draught limitation of the Massey tunnel. Those 300-meter long tankers, with 60,000 tonnes of highly-flammable LNG aboard, would have to sail past highly-populated areas of Richmond, Delta and Steveston. The risks and consequences of collisions, groundings and release of cargo are significant, as are the risks of turning 300-meter long laden tankers around in the narrow, fast-flowing river channel at Tilbury. SIGTTO, the Society of International Gas Terminal and Tanker Operations, recommends a turning radius of 2-3 times the ship’s length (600-900m.) – impossible at Tilbury.

2. LNG is methane, a powerful greenhouse gas.

Fracking, pipelining and liquefying methane gas into LNG results in
Greenhouse Gas (GHG) emissions at least on par with coal and oil. The climate disruption effects of fossil fuels – sea-level rise (crucial for Delta and Richmond), ocean acidification and increases in floods, wildfires and violent storms – are hugely concerning to residents of the Lower Mainland. Fortis’ Tilbury expansion would be incompatible with BC’s climate action plan (CleanBC) and with Canada’s international commitments to reduce GHG emissions 80% by 2050. 

3. Economic benefits are overstated, few new jobs created.

The social and economic benefits of the project for Delta/Richmond, Metro Vancouver and BC are generally small and are poorly outlined in the proposal. The project would employ only 110 people when in full operation and “as these positions will be filled by existing employees at the Tilbury LNG Plant, the Project will not create new employment opportunities and therefore not affect labour market balance.” Tilbury LNG’s business purpose is vague – it suggests that the LNG product could be sold as bunker fuel to unnamed major ports along the West Coast or exported to unknown Asian markets or even sold to “other potential customers.” It uses the BC Input-Output Model (BCIOM) to analyze and predict project-related effects on direct, as well as indirect employment, labour income and government taxation revenues. That model was discredited after it predicted, in 2013, a BC LNG industry employing 100,000 people, generating $100 billion in LNG revenues to Government and resulting in a “debt-free BC,” none of which have actually transpired.

4. Plant location and safety concerns

Both industry-group SIGTTO (Society of International Gas Tanker and Terminal Operators) and U.S. DHS Regulations strongly argue against locating LNG plants near human populations and/or in narrow inland waterways with significant aircraft, ferry, freighter and recreational traffic.  This is a good description of the Tilbury site.

LNG is classified as a HNS (Hazardous and Noxious substance) cargo rated second only to explosives as a shipping risk by the International Maritime organization (IMO). How does Fortis propose to reduce the risk from accident and terrorist actions?

Fighting a fire at a LNG facility on a waterway (opposite a jet-fuel terminal and near fire-prone Burns Bog, where a fire in 2017 triggered the complete evacuation of Tilbury Island) requires special equipment, such as foam retardant and fire-boats, of which Richmond and Delta have neither. Will Fortis be compensating these cities for the expense of providing publicly-funded emergency response and security capabilities? 

5. The public should not subsidize fossil fuel exports.

Successive provincial and Federal Governments have showered the well-heeled, foreign-owned LNG industry with taxpayer-funded subsidies. These include cheap electricity, exemption from carbon tax increases on GHG emissions, PST and GST exemptions and zero LNG taxes. Using taxpayer’s money for these subsidies is grossly unfair to citizens struggling to cope with housing, food and transportation cost increases.

6. Salish Sea orcas don’t need the stress of added boat traffic.

The population of Southern Resident Killer Whales in the Salish Sea is already at near-extinction levels. Adding LNG tanker, tug and barge traffic will only add to the stresses on the remaining orca pods.

7. Fortis BC should focus on serving the BC public, not foreign markets.

FortisBC is a regulated utility whose charges to Customers are based on recovering its expenses for service. Building a 5 megatonne LNG plant will cost in excess of $5 Billion. Will financing for this come out of BC customers’ pockets and raise our heating and food preparation costs through the roof (as happened with Australian LNG developments, which tripled gas bills for locals)?

Share your concerns with the BC Government about the Tilbury Phase 2 expansion project 

8. Canada lacks world class LNG safety regulations.

The proposed location is in Canada’s most important salmon river, opposite a storage terminal for flammable jet fuel, in BC’s prime earthquake-liquefaction zone, and in the path of a narrow commercial and recreational shipping lane of freighters, tugs, barges and aircraft. The Society of International Gas Terminal and Tanker Operations, strongly recommends against locating LNG facilities in such narrow, crowded waterways. Because of such risks, U.S. regulations prevent LNG plants and shipping routes from locating within 3.5 km. of populated areas. In 2016, a fire in nearby Burns bog caused the evacuation of the Tilbury LNG plant. Fighting an LNG fire requires responders equipped with special foam retardant and a well-practiced emergency response plan to evacuate local residents and businesses in the event of a fire. Just such an event happened in 2014 at an LNG plant in Oregon.

9. An expanded LNG terminal will need electricity, meaning transmission lines on farm land.

Liquefying and storing LNG requires huge amounts of electrical power. An expanded Tilbury plant would need electricity supply from two sub-stations and require building unsightly power lines and pylons across ALR farmlands in Richmond and Delta.

10. BC’s environmental assessment process is seriously flawed.

The BC Environmental Assessment Process is seriously flawed and in the pocket of industry. Its starting assumption is that each project proposal will be approved subject to actions that could mitigate the worst of the environmental effects. It provides no means of challenging, via cross-examination, proponent-supplied “science” , instead relying almost exclusively and unquestioningly on the findings of proponent-paid professionals. “Open Houses” in affected communities are poorly advertised and provide no opportunity to question proponents. Comment periods are far too short to allow the public time to examine the thousands of pages of boiler-plate proponent submissions. The process largely ignores the cumulative effects of multiple projects in the same area, and, unlike its U.S. counterpart, does not factor the social and economic disruptions the project will cause in local communities. Community and provincial benefits assessments focus almost exclusively on short-term employment, based on an economic model that wildly overestimates the effects of resource-based projects. The ability to assess this risky project will be hampered by the serious flaws in the BC EA process.

11. GHCs and other air pollutants

Fortis estimates the plant’s annual direct emissions will be over 226,500 tonnes go greenhouse gases. That’s equivalent to adding almost 60,000 cars to Delta’s roads.

12. Noise

Cooling equipment for air-cooled LNG plants (to draw away the heat released in the liquefaction process) require many large, noisy fans and/or large releases of steam emissions. What are the noise and steam vapour characteristics of the proposal?

13. Seismic risk

This facility would be located in the area of the Lower Mainland most at risk during an earthquake.  Japanese LNG import facilities, post-Fukishima, are required to sink their storage tanks so their tops are at ground level – why are Tilbury’s overground and lacking any secondary containment?

14. Upstream impacts of fracked gas production

Producing millions of tonnes of methane gas via fracking produces significant upstream impacts like freshwater pollution, methane leakage, etc. Destroying indigenous territories and leaving behind a toxic legacy of leaky, abandoned wells is entirely unacceptable.

I’m Ready to Send My Comments

I Want to Learn More About This Project

1. LNG tankers in the narrow, busy Fraser River? Bad idea.

Tankers and barges loading LNG at the jetty would have to be custom-built to pass over the 11.5m draught limitation of the Massey tunnel. Those 300-meter long tankers, with 60,000 tonnes of highly-flammable LNG aboard, would have to sail past highly-populated areas of Richmond, Delta and Steveston. The risks and consequences of collisions, groundings and release of cargo are significant, as are the risks of turning 300-meter long laden tankers around in the narrow, fast-flowing river channel at Tilbury. SIGTTO, the Society of International Gas Terminal and Tanker Operations, recommends a turning radius of 2-3 times the ship’s length (600-900m.) – impossible at Tilbury.

2. LNG is methane, a powerful greenhouse gas.

Fracking, pipelining and liquefying methane gas into LNG results in Greenhouse Gas (GHG) emissions at least on par with coal and oil. The climate disruption effects of fossil fuels – sea-level rise (crucial for Delta and Richmond), ocean acidification and increases in floods, wildfires and violent storms – are hugely concerning to residents of the Lower Mainland. Fortis’ Tilbury expansion would be incompatible with BC’s climate action plan (CleanBC) and with Canada’s international commitments to reduce GHG emissions 80% by 2050.

3. Economic benefits are overstated, no new jobs created.

The social and economic benefits of the project for Delta/Richmond, Metro Vancouver and BC are generally small and are poorly outlined in the proposal. The project would employ only 110 people when in full operation and “as these positions will be filled by existing employees at the Tilbury LNG Plant, the Project will not create new employment opportunities and therefore not affect labour market balance.” Tilbury LNG’s business purpose is vague – it suggests that the LNG product could be sold as bunker fuel to unnamed major ports along the West Coast or exported to unknown Asian markets or even sold to “other potential customers.” It uses the BC Input-Output Model (BCIOM) to analyze and predict project-related effects on direct, as well as indirect employment, labour income and government taxation revenues. That model was discredited after it predicted, in 2013, a BC LNG industry employing 100,000 people, generating $100 billion in LNG revenues to Government and resulting in a “debt-free BC,” none of which have actually transpired.

4. Plant location and safety concerns

Both industry-group SIGTTO (Society of International Gas Tanker and Terminal Operators) and U.S. DHS Regulations strongly argue against locating LNG plants near human populations and/or in narrow inland waterways with significant aircraft, ferry, freighter and recreational traffic.  This is a good description of the Tilbury site. How does Fortis propose to reduce the risk from accident and terrorist actions?

LNG is classified as a HNS (Hazardous and Noxious substance) cargo rated second only to explosives as a shipping risk by the International Maritime organization (IMO). Prone to equipment malfunction and human caused accidents and terrorist actions, how does FortisBC plan to eliminate such risks with this project?

Fighting a fire at a LNG facility on a waterway (opposite a jet-fuel terminal and near fire-prone Burns Bog, where a fire in 2017 triggered the complete evacuation of Tilbury Island) requires special equipment, such as foam retardant and fire-boats, of which Richmond and Delta have neither. Will Fortis be compensating these cities for the expense of providing publicly-funded emergency response and security capabilities? 

Deadline for Submission is July 16, 2020

Day(s)

:

Hour(s)

:

Minute(s)

:

Second(s)

5. The public should not subsidize fossil fuel exports.

Successive provincial and Federal Governments have showered the well-heeled, foreign-owned LNG industry with taxpayer-funded subsidies. These include cheap electricity, exemption from carbon tax increases on GHG emissions, PST and GST exemptions and zero LNG taxes. Using taxpayer’s money for these subsidies is grossly unfair to citizens struggling to cope with housing, food and transportation cost increases.

6. Salish Sea orcas don’t need the stress of added of boat traffic.

The population of Southern Resident Killer Whales in the Salish Sea is already at near-extinction levels. Adding LNG tanker, tug and barge traffic will only add to the stresses on the remaining orca pods.

7. Fortis BC should focus on serving the BC public, not foreign markets.

FortisBC is a regulated utility whose charges to Customers are based on recovering its expenses for service. Building a 5 megatonne LNG plant will cost in excess of $5 Billion. Will financing for this come out of BC customers’ pockets and raise our heating and food preparation costs through the roof (as happened with Australian LNG developments, which tripled gas bills for locals)?

8. Canada lacks world class LNG safety regulations.

The proposed location is in Canada’s most important salmon river, opposite a storage terminal for flammable jet fuel, in BC’s prime earthquake-liquefaction zone, and in the path of a narrow commercial and recreational shipping lane of freighters, tugs, barges and aircraft. The Society of International Gas Terminal and Tanker Operations, strongly recommends against locating LNG facilities in such narrow, crowded waterways. Because of such risks, U.S. regulations prevent LNG plants and shipping routes from locating within 3.5 km. of populated areas. In 2016, a fire in nearby Burns bog caused the evacuation of the Tilbury LNG plant. Fighting an LNG fire requires responders equipped with special foam retardant and a well-practiced emergency response plan to evacuate local residents and businesses in the event of a fire. Just such an event happened in 2014 at an LNG plant in Oregon.

Deadline for Submission is July 16, 2020

Day(s)

:

Hour(s)

:

Minute(s)

:

Second(s)

9. An expanded LNG terminal will need electricity, meaning transmission lines on farm land.

Liquefying and storing LNG requires huge amounts of electrical power. An expanded Tilbury plant would need electricity supply from two sub-stations and require building unsightly power lines and pylons across ALR farmlands in Richmond and Delta.

10. BC’s environmental assessment process is seriously flawed.

The BC Environmental Assessment Process is seriously flawed and in the pocket of industry. Its starting assumption is that each project proposal will be approved subject to actions that could mitigate the worst of the environmental effects. It provides no means of challenging, via cross-examination, proponent-supplied “science” , instead relying almost exclusively and unquestioningly on the findings of proponent-paid professionals. “Open Houses” in affected communities are poorly advertised and provide no opportunity to question proponents. Comment periods are far too short to allow the public time to examine the thousands of pages of boiler-plate proponent submissions. The process largely ignores the cumulative effects of multiple projects in the same area, and, unlike its U.S. counterpart, does not factor the social and economic disruptions the project will cause in local communities. Community and provincial benefits assessments focus almost exclusively on short-term employment, based on an economic model that wildly overestimates the effects of resource-based projects. The ability to assess this risky project will be hampered by the serious flaws in the BC EA process.

11. GHCs and other air pollutants

Fortis estimates the plant’s annual direct emissions will be over 226,500 tonnes go greenhouse gases. That’s equivalent to adding almost 60,000 cars to Delta’s roads.

12. Noise

Cooling equipment for air-cooled LNG plants (to draw away the heat released in the liquefaction process) require many large, noisy fans and/or large releases of steam emissions. What are the noise and steam vapour characteristics of the proposal?

Deadline for Submission is July 16, 2020

Day(s)

:

Hour(s)

:

Minute(s)

:

Second(s)

15. Seismic risk

This facility would be located in the area of the Lower Mainland most at risk during an earthquake. Japanese LNG import facilities, post-Fukishima, are required to sink their storage tanks so their tops are at ground level – why are Tilbury’s overground and lacking any secondary containment?

16. Upstream impacts of fracked gas production

Producing millions of tonnes of methane gas via fracking produces significant upstream impacts like freshwater pollution, methane leakage, etc. Destroying indigenous territories and leaving behind a toxic legacy of leaky, abandoned wells is entirely unacceptable.

Share your concerns with the BC Government about the Tilbury Phase 2 expansion project