June 15, RE: WesPac LNG Project. To whom it may concern:

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1 June 15, 2015 WesPac Tilbury Marine Jetty Project Canadian Environmental Assessment Agency West Georgia Street Vancouver, BC V7Y 1C6 Fax: RE: WesPac LNG Project To whom it may concern: The Council of Canadians is writing to urge the Canadian Environmental Assessment Agency (CEAA) to commit to a federal review of WesPac Midstream s plan to build a Liquefied Natural Gas (LNG) terminal on the Fraser River in Delta, B.C. The Council is concerned that the terminal would serve as an export facility for fracking operations in northeastern B.C. and would result in up to 120 LNG tankers and 90 LNG barges on the Fraser River annually. The company has not adequately addressed concerns about the project s climate change impacts, how tankers will navigate a narrow and busy passageway, or the potential ecological impacts on the Fraser River. The B.C. government has suggested that a provincial environmental assessment would be adequate. However, the federal government has the responsibility to review this project under the Canadian Environmental Assessment Act, the Navigation Protection Act, the Canada Shipping Act, the Fisheries Act and other federal legislation. Based on the UN Declaration on the Rights of Indigenous Peoples, free, prior and informed consent of Indigenous peoples must also be obtained. The Council of Canadians is concerned about the proposed terminal as well as the other 17 proposals for LNG terminals along the Pacific Coast. We urge the CEAA to review this proposal in light of the public safety, water, health and climate impacts of fracking. We also have concerns about B.C. s weakened regulatory system and its ability to adequately assess this risky project. Indigenous communities and municipalities in B.C. need a federal review of this project that considers the location of the facility, the tanker routes on the Fraser River and safety concerns as well as watershed and climate change implications resulting from the extraction, shipment and consumption of shale gas.

2 2 Public safety risks Retired KPMG consultant Eoin Finn has pointed to the heightened risk of LNG tankers. They are categorized as Class 2 under the Maritime Dangerous Good Code for Shipping (1 being the most dangerous, 9 being the least dangerous). LNG tankers are 300 metres long (equivalent to three football fields), 40 metres wide and 30 metres tall. LNG tankers are typically 150,000 tonnes DWT (deadweight tonnage) with a capacity to carry 60,000 tonnes of LNG. They are twice as big in width and height as a B.C. ferry and pose a unique threat to the Lower Mainland if there were ever to be an explosion or accident. The Society of International Gas Tanker and Terminal Operators (SIGTTO) has advised against locating LNG plants on long, narrow inland waterways to avoid greater navigation risk. The Fraser River at Tilbury Island could constitute a narrow inland waterway. Why are WesPac Midstream and the B.C. government considering going against the advice of SIGTTO, which is based on decades of engagement in the LNG industry and involves major LNG players, by siting an LNG terminal on and having tankers run through southern arm of the Fraser River? Under the Canada Shipping Act, the Minister of Transport is required to prohibit the operation of vessels for the purpose of protecting persons, vessels, artificial islands, installations, structures, works, shore areas, or environmentally sensitive areas. Water and health impacts of fracking To cool some of the LNG liquefaction plants, seawater will be used, which will have a significant impact on the surrounding coastal waters. WesPac Midstream s project description notes noise emissions from loading operations, marine vessel traffic and other activities. The CEAA should conduct studies on the sound and vibrational pollution impacts on herrings, porpoises, whales and other marine life. The project description also lists that the lower section of the Fraser River supports at least 37 native fish species and that all five Pacific salmon species spend at least part of their life in the area. A federal environmental review is needed to assess the long-term impacts on fisheries and marine life. The gas needed for only five LNG terminals would require an estimated 582 billion litres of water from rivers, lakes and streams in B.C., an amount of water that would supply the population of the Greater Vancouver Area for two years. The federal government has yet to intervene and regulate fracking for water use, wastewater impacts on fisheries, toxic chemical impacts on public health and climate impacts, and should do so with the LNG terminal proposals.

3 3 Fracking has devastating impacts on local watersheds and ecosystems. More than 600 chemicals have been used in fracking, and many of these chemicals have been linked to cancer, mutations, and impacts on the nervous, immune, and cardiovascular systems. The boom in proposed LNG developments could result in a 600 per cent increase in fracking on the Fort Nelson First Nation s already heavily impacted territory. Concerns over water withdrawals and cumulative impacts on Treaty 8 territory have been ignored by the B.C. government, which continues to approve fracking projects at a breakneck pace. Climate change risks B.C. s LNG ambitions would require 50,000 new fracked wells by 2040 twice as many gas wells as have been drilled in the entire 60-year history of the B.C. gas industry. Premier Christy Clark s promise of 150 years of prosperity will come at the expense of our climate, watersheds and public safety. Since oil prices have dropped, Clark has backpedalled on her promotion of LNG. However, companies and the province are still pursuing LNG terminal agreements. The combined impacts from fracking, fracked gas pipeline construction, gas liquefaction and export make LNG a major contributor to global climate change. The gas boom in British Columbia could result in an additional 73 million tons of greenhouse gas emissions per year as early as 2020, which would be about the same as Alberta s tar sands. According to retired KPMG consultant Eoin Finn, if the LNG terminai is powered by gas (10 per cent of supply), it would release 735,000 tonnes per year of carbon dioxide, equivalent to the emissions of 137,000 vehicles. If terminal is powered by electricity (140 megawatts), it would release 147,000 tonnes per year of carbon dioxide, equivalent to the emissions of 31,000 vehicles. Five LNG terminals alone would more than double B.C. s current climate footprint. The emissions from the 12 LNG terminals proposed for Prince Rupert and Kitimat would bring acid rain and serious air pollution to the region and impact the health of residents and surrounding ecosystems. A few of these LNG plants will produce the same amount of emissions as the entire City of Vancouver. Free, prior and informed consent of Indigenous peoples This project would operate on the traditional territories of the Musqueam Indian Band, Tsawwassen First Nation, Cowichan Tribes, Halalt First Nation, Lake Cowichan First Nation, Lyackson First Nation, Penelakut Tribe, Stz uminus First Nation, Tsleil-Waututh Nation, Semiahmoo First Nation, Katzie First Nation, Squamish Nation and First Nations of the Stó:lō Nation.

4 4 Overall, fracking projects are happening on Indigenous lands without respect for First Nations treaty rights and title. As noted in the Assembly of First Nations resolution on a moratorium on hydraulic fracturing, the UN Declaration of the Rights of Indigenous People states: States shall consult and cooperate in good faith with the indigenous peoples concerned through their own representative institutions in order to obtain their free and informed consent prior to the approval of any project affecting their lands or territories and other resources, particularly in connection with the development, utilization or exploitation of mineral, water or other resources. (Article 32(2)) Fracking projects are taking place in Indigenous communities, some of which are already struggling with access to clean and safe drinking water. Governments must obtain free, prior and informed consent before proceeding with fracking and related projects. B.C. s weakened regulatory framework The B.C. government has dismantled key pieces of legislation and protections in B.C., such as overhauling the Agricultural Land Reserve and passing Bill 4, the Park Amendment Act, that opens up protected land to industrial development. The Council of Canadians is deeply concerned that the scaling back of environmental and other safeguards will allow the B.C. government to rubber-stamp and fast-track LNG projects and fracked gas pipelines. The Council of Canadians has also expressed concerns about the amendments to the Canadian Environmental Assessment Act that resulted in the cancellation of 3,000 environmental assessments. Given the risks that LNG terminals pose to coastal communities, however, it is imperative that the CEAA carefully review WesPac Midstream s proposal. Despite the delisting of 99 per cent of lakes and rivers in Canada from the Navigation Protection Act, the Fraser River is one of the remaining rivers protected under the act. Community concerns and resistance Hundreds of residents attended public forums on LNG in Vancouver, Victoria, Powell River, Squamish, Delta and Comox Valley. Community opposition to the LNG terminals is building in the province. Several municipalities have passed resolutions calling for a ban on LNG tankers along the Pacific Coast. The province and country need a long-term energy plan that does not put public safety and water sources at risk. Seventy per cent of people in Canada and 75 per cent of people in B.C. support a national moratorium on fracking. The Council of Canadians calls for a ban on fracking in order to foster renewable energy and sustainable green jobs, and pave the way for a clean energy future that protects water sources and respects Indigenous rights. At the very least, we urge the CEAA to commit to a federal review to assess tanker safety, impacts on fisheries and marine life, and impacts on the Fraser River and other waterways.

5 5 Thank you for the opportunity to comment on this important issue. Sincerely, Emma Lui Water Campaigner The Council of Canadians The Council of Canadians is Canada s leading social action organization, mobilizing a network of 60 chapters across the country, a third of which are located in British Columbia. Through our campaigns we advocate for clean water, fair trade, green energy, public health care, and a vibrant democracy.