— Photo courtesy Trans Mountain
Preparation for the Trans Mountain Expansion Project (TMEP) commenced in 2012, including an intensive examination of marine issues, risks and impacts relating to expanded tanker traffic in the Salish Sea, including potential marine mammal impacts and mitigation.
As part of the Facilities Application to the National Energy Board (NEB), Trans Mountain proposed additional marine safety measures for tankers. Regulators accepted Trans Mountain’s proposals, such as expanding tug escorts for laden tankers.
The current, advanced state of Trans Mountain’s preparations reflects extensive consultation and engagement with federal agencies and departments, stakeholders and Indigenous groups about safely and responsibly moving oil tankers in the Salish Sea.
Trans Mountain participated in a ‘TERMPOL’ (Technical Review Process of Marine Terminal Systems and Transshipment Sites) review of the Expansion Project. TERMPOL is a voluntary Transport Canada-led process focusing on vessel safety and operation in Canadian waters along shipping routes. Federal agencies participating in the review include Transport Canada, Canadian Coast Guard, Fisheries and Oceans Canada, Environment and Climate Change Canada, Pacific Pilotage Authority and the Vancouver Fraser Port Authority.
The TERMPOL Review Committee made 17 individual recommendations to further ensure safe and responsible tanker movement in the Salish Sea. Trans Mountain committed to all recommendations. The Committee indicated it did not consider increased tanker traffic from the expansion to be an issue, based on Trans Mountain’s tanker safety proposals.
Read TERMPOL recommendation updates
Stakeholder feedback contributed to Trans Mountain’s proactive decision to expand the marine regional study area for the Project to include the entire marine shipping route through the Salish Sea.
Volume 8 of Trans Mountain’s 15,000-page Facilities Application to the National Energy Board comprehensively describes environmental and socio-economic impacts of Project-related marine transportation issues. Topics covered in Volume 8 include:
- Risk assessment of tanker traffic and the Westridge Marine Terminal
- Spill response and liability
- Nine technical reports on the marine environment including impact of tankers on Southern Resident Killer Whales
- Sixteen TERMPOL study reports covering such diverse topics as:
- Fisheries resources survey
- Shipping route analysis
- Oil-handling facilities requirements
- General risk analysis
- Specifications for tankers calling on Burrard Marine Terminal
- A study of the fate and behaviour of diluted bitumen oils in marine waters. Results of this meso-scale study have subsequently been confirmed by federal researchers.
The spill risks associated with increased marine traffic were assessed by a global consultancy, DNV, which has been assessing risks in the merchant marine sector since its founding in Norway in 1864. The assessment considers the effect on incident risk of traffic growth from Trans Mountain tanker traffic as well as from overall traffic growth in the study area. The increase in traffic resulting from the Project (going from 60 to 408 tankers per year) is found to have a negligible effect on the total incident frequency for the region. With or without the Project, tanker traffic remains a small part of total traffic in the region. With effective implementation of risk-reducing measures, most of the incremental risk resulting from the Project can be eliminated. DNV said implementing extra risk controls (as is being proposed by the Project) raises the level of care and safety in the study area to well above globally-accepted shipping standards.
Six of 157 NEB conditions issued in 2016 for TMEP relate specifically to marine transportation, including one on mitigation of impacts on SRKW population. This is in addition to conditions applied to the construction of an expanded Westridge Marine Terminal.
- Condition 91 – Plan for implementing marine shipping-related commitments
- Condition 131 – Marine Public Outreach Program
- Condition 132 – Marine Mammal Protection Program
Condition 133 – Marine shipping-related commitments including:
- Enhanced tug escort – Prescribed minimum tug capabilities required to escort outbound laden tankers between the Westridge Marine Terminal and Buoy Juliet
- Enhanced marine oil spill response regime capable of delivering 20,000 tonnes of capacity within 36 hours of notification, with dedicated resources staged within the study area
- Condition 134 – Updated Tanker Acceptance Standard
- Condition 144 – Ongoing implementation of marine shipping-related commitments
In addition to NEB conditions, Trans Mountain has committed to meeting a wide range of specific commitments associated with construction of TMEP including marine commitments.
Commitments are reported to the NEB on a regular basis each year.
Eight federal departments and agencies in 2014 signed an agreement to participate in the NEB’s review of the Project — notably, an Environmental Assessment. The agreement was coordinated by the federal government’s Major Project Management Office. Although the NEB was lead agency, it is obliged to ensure the Project complies with federal statutes such as the Fisheries Act, the Canada National Parks Act, the Indian Act and the Canadian Environmental Protection Act.
The Vancouver Fraser Port Authority, which operates the largest port in Canada, third largest in North America by cargo throughput, was one of the signatories.
The NEB and Fisheries and Oceans Canada have a Memorandum of Understanding (MOU) regarding fish and fish habitat. The MOU makes the Board responsible for assessing impacts to fisheries from projects such as Trans Mountain Expansion Project, and for determining impacts on aquatic species at risk. This reduces duplication of reviews.
Trans Mountain has done substantial work to study potential environmental impacts and mitigation methods to reduce the impact of the Project. Trans Mountain acknowledges the impacts of vessels and human activity on marine wildlife and how that might change or be impacted as a result of growing marine trade. It is for this reason, from the beginning, Trans Mountain acknowledged its responsibility to mitigate Project effects on Southern Resident Killer Whales and work with industry and stakeholders to apply mitigation to the extent possible.
Financial support has been provided to the Vancouver Fraser Port Authority-led Enhancing Cetacean Habitat and Observation (ECHO) Program. The ECHO Program aims to better understand and manage the impact of shipping activities on at-risk whales throughout the southern coast of BC. In 2015, we committed $1.6 million over three years to ECHO. This funding was not contingent on the Project proceeding. Financial support up to $3 million is also committed towards multi-year programs to protect wild Pacific salmon. Significant improvements to marine spill response in the region are being undertaken by Western Canada Marine Response Corporation as part of the NEB’s conditions on TMEP.
Trans Mountain responded to numerous Information Requests (IRs) from the National Energy Board regarding the Project’s potential impact on marine mammals, specifically Southern Resident Killer Whales. Here is an example of our responses: "Trans Mountain believes there is merit in developing a Marine Mammal Protection Program that addresses both potential Project-specific effects on marine mammals and combined stressors on the endangered southern resident killer whale population." (Trans Mountain Response to NEB IR No. 1 – page 322 of 421.)
In our Final Argument to the NEB, Trans Mountain stated: "It is forecasted that Project tankers in the future will comprise only about 6.6 per cent of all large commercial vessels trading in the Project area. As such, rather than Project-specific efforts, industry-wide efforts are necessary to mitigate the effects of maritime commerce and other activities on marine mammals in the region. . . (T)he impacts on the southern resident killer whale population assessed as part of the Application are occurring regardless of whether the Project is approved and is an issue that must be addressed by all users.” (Trans Mountain Final Argument, August 20 2015, See pages 59-60.)
Extensive records of Trans Mountain’s engagement with Indigenous and other communities and stakeholders are available. Engagement is detailed in regular consultation summary reports filed with the NEB throughout the review process for the Project. Marine-based communities were targeted for engagement and subsequent reporting. Approximately 10 Indigenous groups along the marine corridor have signed Mutual Benefit Agreements with Trans Mountain as a result of the engagement efforts.
In June 2018, the Scia’new First Nation, centred at Beecher Bay on Vancouver Island, released a statement in support of Trans Mountain Expansion Project. The Scia’new said $150 million of marine spill response enhancements, which would be implemented along the southern BC shipping route if TMEP is approved, are an “ambulance of the sea.” They also said “We are satisfied that the conditions put on the project and the management of the project will be of world-class standards.”
