March 21, 2014. Kinder Morgan Canada 2844 Bainbridge Avenue P.O. Box 84028 Burnaby, BC, V5A 4T9 Attention: Michael Davies, Director, Marine Development Dear Mr. Davies, Re: Mutual Interests for the Protection of Central Burrard Inlet Thank you for your letter of March 15 th (attached) wherein you confirm some of our mutual interests in the development of Kinder Morgan Canada’s (KMC) Westridge Marine Terminal (WMT) and protection of the sensitive marine habitat of Burrard Inlet. Minimizing Impacts To Neighbours We are pleased to see that KMC acknowledges Belcarra’s concerns regarding increased noise and light pollution associated with an expanded WMT tanker loading facility and increase in tanker shipments that would negatively impact the quality of life for Belcarra residents. Can you provide details on how KMC intends to utilize 'environmental design' measures for the new WMT facility to minimize and/or mitigate the bright lights and noise from both the WMT facility itself and the vessels loading at dockside? We would expect that KMC will require all client vessels –– some of which will be owned or chartered by KMC or its parent company –– to implement measures to mitigate noise and light pollution while waiting to be loaded at the WMT. Can you also provide details regarding KMC’s vessel acceptance criteria that will require commitment from vessels calling at WMT to make efforts to reduce noise and light disturbances, as well as details about the Port Metro Vancouver (PMV) program for vessels at anchor off the WMT loading facility? WMT Oil Containment Booms While KMC’s TMEP application makes a brief mention of oil containment booms around oil tankers berthed at the WMT facility, there is no mention as to the design technology and efficacy of the oil containment booms proposed for the expanded WMT tanker loading facility. Belcarra seeks assurance that KMC will utilize ‘best available technology’ appropriate for the water conditions encountered in Central Burrard Inlet. Will KMC utilize appropriate open-water oil spill containment booms around all tankers berthed at the WMT that will be capable of effectively performing in at least 5-foot waves due to the wind, current, wave and vessel wake conditions known to occur on Central Burrard Inlet waters? …page two
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March 21, 2014. Kinder Morgan Canada 2844 Bainbridge Avenue
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March 21, 2014. Kinder Morgan Canada 2844 Bainbridge Avenue P.O. Box 84028 Burnaby, BC, V5A 4T9 Attention: Michael Davies, Director, Marine Development Dear Mr. Davies,
Re: Mutual Interests for the Protection of Central Burrard Inlet Thank you for your letter of March 15th (attached) wherein you confirm some of our mutual interests in the development of Kinder Morgan Canada’s (KMC) Westridge Marine Terminal (WMT) and protection of the sensitive marine habitat of Burrard Inlet. Minimizing Impacts To Neighbours
We are pleased to see that KMC acknowledges Belcarra’s concerns regarding increased noise and light pollution associated with an expanded WMT tanker loading facility and increase in tanker shipments that would negatively impact the quality of life for Belcarra residents. Can you provide details on how KMC intends to utilize 'environmental design' measures for the new WMT facility to minimize and/or mitigate the bright lights and noise from both the WMT facility itself and the vessels loading at dockside?
We would expect that KMC will require all client vessels –– some of which will be owned or chartered by KMC or its parent company –– to implement measures to mitigate noise and light pollution while waiting to be loaded at the WMT. Can you also provide details regarding KMC’s vessel acceptance criteria that will require commitment from vessels calling at WMT to make efforts to reduce noise and light disturbances, as well as details about the Port Metro Vancouver (PMV) program for vessels at anchor off the WMT loading facility? WMT Oil Containment Booms
While KMC’s TMEP application makes a brief mention of oil containment booms around oil tankers berthed at the WMT facility, there is no mention as to the design technology and efficacy of the oil containment booms proposed for the expanded WMT tanker loading facility.
Belcarra seeks assurance that KMC will utilize ‘best available technology’ appropriate for the water conditions encountered in Central Burrard Inlet. Will KMC utilize appropriate open-water oil spill containment booms around all tankers berthed at the WMT that will be capable of effectively performing in at least 5-foot waves due to the wind, current, wave and vessel wake conditions known to occur on Central Burrard Inlet waters?
…page two
Michael Davies, Director, Marine Development March 21st, 2014. Page two, continued Burrard Inlet A Special Place
We certainly agree that Burrard Inlet is a special place that is home to high-value public assets that include recreation, tourism, fisheries, and sensitive marine habitats. As such, emergency response plans (ERPs) for Central Burrard Inlet need to include strategies for both rapid response and containment of an oil spill, and concurrent habitat protection measures. This ‘dual approach’ is required because fugitive oil always escapes from primary containment booms, which necessitates deployment of secondary booms to protect sensitive marine habitat areas. This was one of the ‘lessons learned’ from the 2007 oil spill event at WMT. Emergency Response Time Is Critical
We absolutely agree with KMC that the initial response time to an oil spill is critical, particularly when operating within a confined area such as Central Burrard Inlet that is surrounded by sensitive marine habitat that requires protection. However, we must re-emphasise that emergency response times that exceed one hour within Burrard Inlet are not acceptable.
In our letter of December 2nd, 2013 (attached) we expressed concern regarding KMC’s inadequate emergency response plan for dealing with potential oil spills in Burrard Inlet. Part of the problem is that the regulatory planning standards are minimum generic criteria that do not reflect the specific requirements of specific locales. The characteristics of Central Burrard Inlet, with its high-value public assets, necessitates the development of higher standards for emergency response plans in keeping with public expectations.
KMC’s proposal to increase oil tanker traffic at KMC’s Westridge Marine Terminal from one tanker per week to one tanker per day — a seven-fold increase in frequency and risk — warrants a proportional increase in WCMRC’s emergency response planning, equipment and personnel resources. WCMRC On-Water Home Base
We were pleased to see that KMC recognises the importance of assured access by WCMRC personnel to Burrard Inlet and WCMRC’s response vessels. Such ready access to WCMRC vessels is essential for the rapid deployment of personnel and equipment in the event of an oil spill emergency. Does the planning for WCMRC moorage space at WMT also include road access from the neighbouring Shell Oil property to facilitate vehicle access between the dock and WCMRC warehouse facilities? WCMRC Under Resourced
Although WCMRC has a dedicated and professional staff, at present WCMRC is seriously under-resourced for its mandate to protect Burrard Inlet’s public assets that have significant socio-economic and environmental values. WCMRC has a number of response vessels staged around Burrard Inlet, but under ideal conditions WCMRC is only able to muster two or three three-person response crews. A minimum of four three-person response crews are needed to ensure protection of Burrard Inlet’s public assets: two crews to deploy primary containment booms around the spilled oil, and two crews to simultaneously deploy secondary protective booms around sensitive marine habitat areas. As a consequence, WCMRC’s current personnel resources are insufficient for the existing level of shipping activity in Burrard Inlet, let alone the anticipated increase in WMT tanker shipments. KMC needs to ensure that WCMRC has sufficient in-house personnel to ensure a comprehensive response for the proper protection of Central Burrard Inlet’s sensitive marine habitat and wildlife resources.
…page three
Michael Davies, Director, Marine Development March 21st, 2014. Page three, continued Unanticipated Risks
In considering the risk of oil spills at WMT, it appears that KMC is overly focussed on the risks associated with the movement of oil tankers, and hasn’t given adequate consideration to risks due to ‘unanticipated events’ ― most of which are the result of ‘human error’ ― the definition of an ‘accident’. There is a much greater likelihood of an oil barge being towed from Imperial Oil Company at Ioco breaking its towline and colliding with a tanker being loaded at the WMT facility. Or a freighter coming from Pacific Coast Terminals in Port Moody losing power and colliding with the WMT facility. Or a vessel at anchor in Central Burrard Inlet breaking-free of its mooring due to high winds down Indian Arm during an Arctic-outflow event and crashing into the WMT facility. Or an earthquake that causes one of the Burnaby Mountain geologic faults to rupture Trans Mountain’s pipeline resulting in oil flowing into Central Burrard Inlet. Or, as was the case in the 2007 oil spill incident, a third-party contractor damaging Trans Mountain’s pipeline resulting in oil being spilled into Central Burrard Inlet. It most likely will be the ‘unanticipated event’, with an unquantifiable risk, that will result in an oil spill in Central Burrard Inlet. It is the ‘unanticipated event’ that underscores the importance of having an emergency response plan prepared and operationally ready for the protection of the environmental and socio-economic values of Central Burrard Inlet. Kinder Morgan’s fullsome response to the foregoing questions would be appreciated by all of the communities located around Burrard Inlet. Sincerely,
Ralph Drew, Mayor Village of Belcarra RED/ cc: Hon. Lisa Raitt, Minister, Transport Canada Hon. James Moore, MP, Port Moody–Westwood–Port Coquitlam Hon. Fin Donnelly, MP, New Westminster–Coquitlam & Port Moody Hon. Mary Polak, Minister, BC Ministry of Environment Hon. Linda Reimer, MLA, Port Moody–Coquitlam Ian Anderson, President, Kinder Morgan Canada Greg Toth, Senior Project Director, TMEP, Kinder Morgan Canada Lexa Hobenshield, Manager, External Relations, Kinder Morgan Canada Kevin Gardner, President, WCMRC Robin Silvester, President and CEO, Port Metro Vancouver
Carrie Brown, Acting Director, Sustainable Development, Port Metro Vancouver Naomi Horsford, Manager, Community Affairs, Port Metro Vancouver Environment and Parks Committee, Metro Vancouver
Burrard Inlet Mayors and Councils
Trans Mountain Expansion Project
Page 1 of 5
March 15, 2014
Ralph Drew
Mayor, Village of Belcarra
4084 Bedwell Bay Road
Belcarra, BC V3H 4P8
Dear Mayor Drew,
As you are aware, on December 16, 2013 Trans Mountain Pipeline ULC submitted an application
to the National Energy Board (NEB) seeking authorization to build and operate the Trans
Mountain Expansion Project.
The Facilities Application includes environmental and socio-economic assessments, engineering
studies and field studies. It also includes feedback attained from diverse groups of people
interested in the project; presenting the ideas, observations and concerns of First Nations,
stakeholders and government representatives who engaged with us.
Our work will continue, and we look forward to the opportunities for continued dialogue as the
project moves through the NEB process. The NEB will conduct a regulatory review of the project,
including a public hearing on the Application before it makes a decision on the proposed project.
The hearing will allow people or groups who have been granted permission to participate by the
NEB a chance to raise issues, present evidence, test evidence, and provide their input.
Information how to participate in this process is available on the NEB website www.neb-
one.gc.ca.
The purpose of this letter is to confirm some of our mutual interests in developing our proposed
expansion project, and specifically as it relates to our Westridge Marine Terminal and Burrard
December 2, 2013. Kinder Morgan Canada 2844 Bainbridge Avenue P.O. Box 84028 Burnaby, BC, V5A 4T9 Attention: Ian Anderson, President Dear Mr. Anderson,
Re: Kinder Morgan’s Emergency Response Plan for Oil Spills in Central Burrard Inlet We write to again express concern about Kinder Morgan Canada’s (KMC) inadequate emergency response plan for dealing with potential oil spills in Burrard Inlet, and KMC’s unsatisfactory response to the previous questions raised regarding the 2007 oil spill. Specifically, KMC’s contract with Western Canada Marine Response Corporation (WCMRC) should ensure a timely response to potential oil spills, and also ensure effective containment strategies for the protection of the sensitive marine habitat of Central Burrard Inlet. During the 2007 oil spill in the vicinity of KMC’s Westridge Marine Terminal (WMT), WCMRC did not respond in a timely manner, notwithstanding that WCMRC facilities were located immediately adjacent to the location of the spill. WCMRC response vessels took considerably more than an hour to arrive onsite and initiate oil spill containment measures. WCMRC will only commit to a maximum response time of six hours for oil spills within the Burrard Inlet — the duration of a full tidal cycle — which is an unacceptably long response time. KMC’s current emergency response plan is seriously deficient by not requiring response by WCMRC vessels to oil spills in Burrard Inlet within one hour of a spill being reported. The 2007 oil spill also demonstrated that the containment booms used by WCMRC did not fully contain the spilled oil and also were inadequate in sealing spills on the rocky tidal shore, another issue that has been previously raised that neither KMC nor WCMRC have acknowledged or addressed. The summer weather, daylight conditions and proximity to WCMRC response vessels during the 2007 oil spill incident could not have been any better for an oil spill response, yet there was a considerable amount of unrecovered fugitive oil that contaminated the beaches around Burrard Inlet. Pre-Staged Oil Spill Booms Other jurisdictions in the world often address the issue of ‘timely response’ through the use of oil spill equipment caches coupled with pre-staging of oil spill booms for quick deployment in the event of an accident. Such pre-staging of emergency oil spill equipment significantly reduces the response time needed to deploy oil spill containment booms utilizing other procedures.
…page two
Ian Anderson, President, Kinder Morgan Canada December 2nd, 2013. Page two, continued KMC should also employ a pre-staging strategy for the protection of the sensitive marine habitat of Central Burrard Inlet east of the second narrows; namely, protection of those sensitive marine habitat areas surrounding KMC’s Westridge Marine Terminal. In this regard, three pre-staged oil booms would be the obvious strategy to implement (see attached graphic): 1. Port Moody Arm – An oil boom pre-staged at the west boundary of Barnet Marine Park
could be quickly deployed across the entrance to Port Moody Arm and tethered to a pre-installed anchor at Admiralty Point to isolate the east arm of Burrard Inlet;
2. Indian Arm – An oil boom pre-staged at Roche Point could be quickly deployed across the entrance to Indian Arm and tethered to a pre-installed anchor at Admiralty Point to isolate the north arm of Burrard Inlet which includes Cates Park and Belcarra Regional Park;
3. Maplewood Flats – An oil boom pre-staged at Roche Point could be quickly deployed in an east-to-west alignment to protect the Maplewood Flats Conservation Area utilizing three or four pre-installed anchor buoys as tether points to hold the oil spill containment boom in position.
In keeping with the objective of ‘World Class’ standards for oil spill emergency response measures, we strongly recommend that Kinder Morgan Canada give serious consideration to the foregoing strategy of pre-positioned and deployment-ready (cached and pre-staged) oil containment booms that can be quickly deployed by KMC to isolate and protect the sensitive marine habitat areas of Central Burrard Inlet in the event of an oil spill. In addition, we also recommend that KMC’s contract with WCMRC specify a maximum response time of one hour for oil spills within Burrard Inlet, and also specify that WCMRC commit to utilizing ‘best available technology’ for oil spill containment and cleanup. KMC’s proposal to increase oil tanker traffic at KMC’s Westridge Marine Terminal from one tanker per week to one tanker per day — a seven-fold increase in frequency and risk — warrants a proportional increase in KMC’s emergency response planning and infrastructure. Kinder Morgan’s fullsome response to the foregoing would be appreciated by all of the communities located around Burrard Inlet. Sincerely,
Ralph Drew, Mayor Village of Belcarra RED/ cc: Hon. Lisa Raitt, Minister, Transport Canada Hon. James Moore, MP, Port Moody–Westwood–Port Coquitlam Gaétan Caron, Chair and CEO, National Energy Board of Canada Greg Toth, Senior Project Director, TMEP, Kinder Morgan Canada Michael Davies, Director, Marine Development, Kinder Morgan Canada Lexa Hobenshield, Manager, External Relations, Kinder Morgan Canada Kevin Gardner, President, WCMRC Robin Silvester, President and CEO, Port Metro Vancouver
Darrell Desjardin, Director, Sustainable Development, Port Metro Vancouver Laura Strand, Manager, Aboriginal Affairs, Port Metro Vancouver Naomi Horsford, Manager, Community Affairs, Port Metro Vancouver Environment and Parks Committee, Metro Vancouver
Burrard Inlet Mayors and Councils
Aerial view of Central Burrard Inlet showing proposal for pre-staged isolation booms to protect sensitive habitat areas.