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The Government of B.C. has requested substitution of the Environmental Assessment process regarding the proposed LNG business for Howe Sound, B.C. The proposed LNG vessel transit route would require LNG tankers to enter Howe Sound running past busy Horseshoe Bay.

    This proposal shows an ocean going vessel, around the size of an aircraft carrier, 295 m long, 47m wide with a draught depth of 12m, having capacity to carry up to 180,000m3 of LNG with a dead weight tonnage of 85,000 tonnes, running through our marine highway, in the path of B.C. Ferries. This will seriously disrupt the 64 plus daily BC Ferry sailings, and our way of life. This is not acceptable.

    Woodfiber Natural Gas Ltd Project (WNGL) states, “Shipping activities associated with the Woodfibre project include transit of LNG carriers, with up to 40 vessel calls per year or three to four calls per month for two LNG trains.” These vessels will be accompanied by two or more tugs. Reports propose safety exclusion zone for LNG tankers is two miles ahead and one mile astern while a fully loaded vessel is en route to and from the LNG terminal. This moving safety exclusion zone will affect the travel of commercial maritime traffic, B.C. Ferries, and recreational boat traffic.

    Communities around Howe Sound will be negatively impacted by such huge tanker traffic. In addition to the potential risks to the safety and welfare of those living and working near the LNG vessel transit route, there are also potential economic impacts.

    For example, LNG vessel traffic is likely to impose a serious impact on commercial fishing, aquaculture facilities, tourism, including whale watching, and eco-tourism. Many citizens depend on the resources in this area for their livelihoods.

    The ministry asks for public comments on the proposal by Woodfiber Natural Gas Ltd Project, however I find the WNGL document lacking information and clairity..........therefore somewhat challenging to know what exactly is being proposed. Example: no assessment of the cumulative impact of the marine activity, or impact on the travel of B.C. Ferries, nothing on a terrorist attack or earthquake.

    The WNGL document states that “WNGL does not intend to own or operate LNG carrears, barges, tugs or water taxis. WNGL intends to contract all vessels under WNGL terms and conditons, as required on a short, medium, and long-term charter. If Free on Board (FOB) is used, WNGL will transfer ownership of the LNG product as it leaves the Woodfibre LNG marine terminal. In this circumstance, WNGL would transfer care, safety and control to the buyer/shipper, which may or may not include the provision of LNG shipping. This would be subject to the specific terms of LNG sale and Canadian and international regulatory standards and practices for shipping.”

    This indicates to me that WNGL transfers liability to off shore contracts, and or interests, is this correct? This is worrysome, as there is potential for horrific consequences in the event of an LNG spill either on water or land, so how would compensation occur, say from offshore interests?

    The Sandia study dramatically increased the predicted impact of a possible worst case failure over scenarios released in 2004. Using an average wind speed of 9 mph, Sandia estimates that a catastrophic failure of two storage tanks onboard the vessel would spread LNG and methane out in a circular pattern 7 miles from the permanently anchored ship before it would mix with enough oxygen to ignite in a fireball (providing there is a source of ignition). This scenario could be disasterous for Squamish, and Lions Bay. Imagine the wicked forest fire that would engulf the mountain side. How many people would die?

    WNGL states, “Storage of LNG will be provided within the FLNG, along with dedicated storage that may be provided on one or more permanently moored FSUs. Storage capacity between 170,000 and 250,000 m3 will be provided and determined based on the selected off-take LNG carrier size. The exact storage configuration will be determined during the FEED phase of the project; however, floating LNG storage will be common for both the preferred FLNG configuration and alternative land-based configuration”

    Hazards assessments is needed for all LNG facilities to identify both shipping-related and land-based risks

    WNGL states,”Any pre-fabricated modules associated with construction of the LNG facility will be transported from Asia for direct offload at the project site using specialised transportation vessels contracted by WNGL under WNGL terms and conditions, pursuant to which WNGL will require the contracted transportation vessels to comply with all applicable national and international shipping and safety requirements. The number of specialised vessel movements for construction will be confirmed during the FEED design phase of the project.”

    “Woodfibre LNG will purchase prefabricated modules for gas pre-treatment, LNG production,and the FSU. These construction activities will take place in shipyards and or conversion yards qualified to undertake this type of work, most likely in Asia. For the preferred configuration,individual modules will be assembled on the hull and the FLNG will be transported to site. The alternative land-based configuration will also include construction of individual modules inconversion yards in Asia. The individual gas pre-treatment and liquefaction train modules will be transported to site, before connection and assembly to the land-based infrastructure in accordance with the FEED specific layout.”

    The document does not state how many FLNG and FSU facilities will be on site. What is the process for inspection of these pre-fabricated modules from Asia? Why is this work (jobs) not staying here in B.C.?

    “Approximately 40 LNG carriers will be loaded per year for either the preferred or alternative LN processing configurations based on the planned 2.1 MMTPA LNG production rate. There may be some variation to the number of vessels loaded each month due to available carriers and vessel capacity. LNG will be pumped from the FSU through a cryogenic pipeline to the loading platform at the dedicated jetty head. The nature of the cargo arms, loading systems, and vapour recovery systems will be determined during the FEED phase of the project. It is anticipated that the LNG carriers would be loaded within 14 to 29 hours and any vapour generated as part of loading activities will be collected and returned to the facility through a separate pipeline.”

    What are the consequences of a potential fire or of thermal radiation extending beyond the limits of the LNG processing facility, and what resources are available to control the impact and to protect lives and property?

    Other public concerns -

    - the foul-smelling and highly flammable odorizing chemical to be used on board the ship could be spilled, dousing the coast with a concentrated dose of odorant that could travel miles on the wind.

    - air pollution increase that would be caused by the LNG ship's boilers to be highly significant

    - terminal's gas-fired boilers, used to bring the liquefied gas temperature up from -260 degrees, will be loud enough to make conversation difficult outside the closed zone, and this is a 24-hour operation and will be heard ashore on calm nights, just as the engines of passing cargo ships can be heard on quiet, windless nights.

    - LNG is a polluting, climate-changing foreign fossil fuel. The additional lifecycle stages of liquefaction, transportation, and gasification emit harmful greenhouse gases (GHG) above and beyond the GHG levels produced by using domestic “conventional” natural gas; indeed, LNG produces 20%-40% more greenhouse gases (GHG) than domestic natural gas; the ever-increasing amounts of GHG from burning fossil fuels is changing the chemistry of the sea by increasing its acidity, and thereby diminishing the ocean’s ability to serve the free and vital role as the Earth’s largest and most effective absorber of climate fluxes, as well as making the sea itself harmful to marine life;

    - Cargo ships cause oceanic pollution and degrade the marine environment therefore impacts on marine life-cycles

    - The transfer of LNG is very intense and incorporates many pressure changes, valve operations and refrigerant processes one of which causes the greatest problem – propane. In cases where ignition has occurred, the attributed cause has been individual oversight or failure of equipment. In all instances, the outcome was massive reduction of the facility. NFPA requires the calculation of fire radiation based on the assumption of zero wind speed. With wind factors, a vapor cloud may travel great distances before finding an acceptable ignition source. Once ignition is found, the burn flame will continue to the source of vapor point (fireball) with catastrophic results,

    - The LNG, which arrives as a minus-260-degree liquid, must be heated up and turned back into a gas before it can be injected into the natural gas pipeline network. How many million gallons of water will be required to heat up the superchilled LNG cargo? Federal scientists say, everything sucked up in the water will be killed, millions fish eggs and larvae representing the microscopic young of almost every creature that swimsin the area.

    - The proposed LNG project will have a detrimental impact on public travel, our way of life, the enviroment, tourism and businesses. LNG projects will permanently exclude the public from portions of the ocean, a publicly-held resource.

    - The LNG terminal and its attending fleet of ships would be visible at elevations all along the coast

    - Along with LNG tankers, BC Ferries (64 plus daily runs), barging material from Vancouver to Howe Sound Pulp and Paper, proposed barging of gravel, log barging, fishing, recreational boat traffic, boat tours, water events, water sports, plus more, we see that WNGL proposes approximately one barge movement per month to transport chemicals, cement, fuel, and refrigerant to the site at Woodfiber. In addition, two ferry trips per day will occur to take site personnel and food supplies for these personnel to and from the site during construction, operation, and closure. Additional water taxis may be used each day.

    The dilemma we are facing here in the beautiful area of Howe Sound, B.C, is the madness to industrialize Howe Sound. As Howe Sound is still in the healing process, after numerous years of commercial impact and total disregard for the environment, why would government consider disrupting that fragile balance?

    Another major concern is that the public is totally unaware of this business ......nothing in our two weekly local print newspapers here on the Sunshine Coast.  No open house to inform the residents......but here we are, being asked to comment.  All this over the holiday period.

    In December, we were asked to comment on the Woodfiber LNG Pipeline by Dec 16th., 2013 ......again no information provided to the public by the proponent or the government.

    There is legitimate concern around just the Provincial EAO dealing with this business, especially since we know that the B.C. government is sitting on a report commissioned by its climate-action secretariat that measures the greenhouse-gas emissions associated with developing a liquefied natural-gas industry. Emissions report This report is not being released to the public. Why is the public is not allowed this information?

    These types of tankers require careful and delicate handling owing to the precariousness of the material they carry, and will have acute (immediate) and chronic (months to years) effects on the health of wildlife, fish and humans and reduce habitat quality, and under the Canadian law vessel transportation and related activities in Canadian waters fall within the exclusive jurisdiction of the federal government, therefore a need for the Transport Canada technical review process for marine terminal systems and transshipment sites (TERMPOL) study is in order to fully examine the hazards associated with LNG vessels operating in our waters. Such a study is required in Canada with respect to LNG vessel traffic to a Canadian regasification terminal, and should be required for all LNG vessel traffic through Canadian waters.

    The Federal Environmental Assessment is absolutely necessary. The Environmental Assessment Act (CEAA) states;
    It is also anticipated that the Woodfibre LNG project will be subject to the federal environmental assessment process under the Canadian Environmental Assessment Act, 2012 (CEAA 2012)  travelling in and out of Horseshoe Bay because the project includes the construction of:
    “13(d) a facility for the liquefaction,storage or regasification of liqueied natural gas, with a liquefied natural gas processing capacity of more than 3000 t/d [tonnes per day] or a liquefied natural gas storage capacity of more than 50 000 t [tonnes] (Regulations Designating Physical Activities, SOR/2012-147, s.13(d) of the Schedule)”.

The Woodfibre LNG project is expected to have a liquefied natural gas process capacity of 1.5 to 2.1 MMTPA (4,110 – 5,753 t/d), and a storage capacity of 170,000 – 250,000 m3(78,200 – 115,000 t) which exceeds the thresholds set out in the regulation above. Therefore, the project would be considered a physical activity pursuant to the Regulations Designating Physical Activities, and thereby reviewable.

    This LNG business must be subject to serious scrutiny by all relevant Federal and Provincial departments. In all fairness, the public must be allowed information.

    In conclusion, may I suggest, by focusing efforts on efficiency, conservation, and renewables, our province/Canada can create a win-win situation of reduced GHG emissions and long-term, stable, job creation.

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