Submission to the BC Environmental Assessment Office
Georgia Strait Alliance
October 22, 2002
Georgia Strait Alliance (GSA) is a nonprofit organization working to protect and restore the marine environment and promote the sustainability of Georgia Strait, its adjoining waters and communities. GSA seeks solutions to prevent environmental degradation of the Georgia Basin, in order to ensure healthy communities in our region. GSA has 205 members in the Nanaimo area and 600 members in the Georgia Basin who would be affected by the proposed natural gas plant, and we therefore have many concerns about the proposed project.
1) Concerns regarding overall context and process:
This EAO review is premature. The National Energy Board (NEB) review of the proposed Georgia Strait Crossing Pipeline (GSX) is not yet complete, and therefore the VIGP proponent hasn’t ensured that the resource necessary for transport of the gas to the plant is in place. Nor have the results of BC’s Energy Task Force Review been released yet, so decisions about this plant are being made without the benefit of the task force’s recommendations on provincial energy directions.
The proponent has requested to be exempted from a BC Utilities Commission (BCUC) review. The BCUC would examine the broader issues of the need for electrical power and the alternatives, as well as allow for a public hearing. Nanaimo City Council has written to the Minister of Energy and Mines to request that the project not be exempted from the BCUC review and MLA Mike Hunter has written to say that his constituents want a BCUC review. As well, 39 local businesses, community groups and organizations have requested this review in addition to many individual citizens.
The VIGP should also be required to be assessed under the Canadian Environmental Assessment Act (CEAA). There are two possible triggers for the federal review, both of which appear to apply here: (1) Section 47 of the CEAA calls for a review if effects are transboundary in nature. Atmospheric pollutants are shown to be deposited in Washington state as a result of the project (see figures 10.3-25, 10.3-26, 10.3-28, 10.3-30 of the application); (2) Section 48 of the CEAA relates to a significant impact on a First Nations Reserve. Given the proximity of the plant to the Snuneymuxw First Nation Reserve significant impact can be shown.
BC Hydro is proposing to make a massive investment in fossil fuel burning technology and its associated environmental and economic costs, at a time when there is considerable doubt about the long term reliability of gas supply at an affordable cost. There are several viable alternatives to the VIGP plan that would reduce electricity demand and provide renewable, environmentally sound electrical power.
BC Hydro has only responded within the last 48 hours to questions raised by the public at its so-called “Roundtable” meetings last April. The EAO timeline was extended to allow for proper “consultation” by the project proponents. However, Hydro appears to have waited until the last possible moment to provide the answers to questions raised by the public, and has thereby circumvented any possibility of dialogue and has short-circuited the public’s ability to analyze the information it has provided.
People in the Nanaimo area are concerned about the plant. In fact, 3,375 local citizens signed a petition saying: “We the undersigned are opposed to the building of a gas-fired power plant at Duke Point, Nanaimo and demand a public hearing on this issue. We are very concerned about the environmental effects and public health hazards of emissions from such a plant”.
The provincial Environmental Assessment doesn’t consider alternative energy sources and their impacts in order to evaluate the comparative impacts of the plant – i.e., the plant is considered in and of itself. However, the Assessment does consider alternative energy sources in order to allow for greenhouse gas (GHG) offsets. Thus, under the EAO process, project alternatives are considered in an unbalanced manner, by allowing the benefits of alternatives to the proponent without an adequate assessment of the full impacts of the project to local residents and the environment.
We question the assertion of BC Hydro that the project, along with the associated GSX pipeline, is necessary to make Vancouver Island energy self-sufficient. A pipeline does not make us more self-sufficient or secure than do undersea cables. Nor does it provide any sort of ‘bridge’ to renewable energy. Rather, it provides the infrastructure to keep us dependent on non-renewable natural gas for many years to come.
2) Vancouver Island Energy Corporation
The project applicant is Vancouver Island Energy Corporation (VIEC). Yet it is impossible to find information about VIEC. They state that they’re a wholly owned subsidiary of BC Hydro. However, their name isn’t on the BC Hydro web site. There is no published list of officers of the corporation, no apparent financial statements or audit, so as a result there appears to be no accountability for a corporation that is owned by the taxpayers of BC and has spent approximately $25 million of public money to date.
3) Omissions and inconsistencies in application
There appear to be significant omissions and inconsistent information in the application to the EAO, e.g.:
Local ambient air quality figures given for particulate matter (PM10 and PM2.5) do not correspond to those provided by Environment Canada’s National Air Pollution Surveillance (NAPS) annual report. The numbers given by the proponent in the application are much lower than those from NAPS.
Although there are a number of similar-sized plants operating in the US (a number of them in Washington state), using GE7FA turbines in a combined cycle generating plant, the proposed plant hasn’t been compared in any way to another plant with the same rating and equipment. This seems to be a huge oversight, as comparable figures and permits for similar plants will give a far better picture of the actual impacts of this plant.
In Chapter 16 on socio-economic impacts, there are income statistics given for the Cowichan Valley Regional District (CVRD), yet none for Gabriola Island. Not only would Gabriola Island be significantly more impacted by the gas plant than the CVRD, it has a larger population base (3600) than Lake Cowichan (3200). Yet the latter is included in the analysis and Gabriola is omitted.
Also in Chapter 16 on Socio-Economic impact, NRD is used in the same table as RDN. We assume that the former means Nanaimo Regional District and the latter means the correctly-named Regional District of Nanaimo. However, such sloppiness does not inspire confidence in the rest of the proposal.
Given adequate time and resources, we expect that additional examples of such oversights and errors would be found in other parts of the application.
4) Air quality impacts
a) Greenhouse Gas (GHG) Emissions
It is projected that 925,000 tonnes of greenhouse gases will be released yearly from the VIGP. Both the federal and provincial governments share a concern about greenhouse gas emissions and their contribution to climate change, and under the soon-to-be ratified Kyoto Protocol, the federal government will be adopting a national plan to reduce greenhouse gases.The project proposal refers to GHG offsets as “impact mitigation” and says that GHGs will be offset by 50%, from future projects that could be located anywhere in the world. It is BC Hydro and not the project proponent, VIEC, who will carry out these offsets.There is a lack of accountability in this proposal. Proposed future developments by an entity other than the project proponent do not constitute acceptable or reliable impact mitigation. There is no way to ensure that these impacts will be adequately or speedily mitigated. The onus should fall on VIEC to assess the major potential environmental, socio-economic and human health impacts associated with GHG emissions and to offer concrete methods of offsetting those impacts within a local context, from the outset of the project.
b) Combined effect of Harmac Mill and proposed VIGP
The Sierra Legal Defense Fund commissioned SENES Consultants Limited to prepare an independent scientific review of the VIGP project application. This review has been submitted to Environmental Assessment Office. The review drew a number of conclusions about the air quality assessment submitted by the proponent, i.e. that it contained:• unreliable air modeling results due to omissions and errors in the meteorological data;
• an underestimate of predicated impacts outside of the project site due to a coarse modeling domain;
• a substantial underestimate of direct emission and secondary formation of PM10 from VIGP;
• a substantial underestimate of existing air quality impacts of the Harmac mill;
• a failure to take into account, in its analysis of cumulative effects, other significant point sources and background pollutant levels; and
• exceedence by existing emissions of Provincial and Federal Air Quality Guidelines for PM10/2.5 and SO2, even before emissions from the VIGP are factored in.The SENES report indicates that there are already currently significant public health impacts from Harmac emissions, which will be worsened by emissions from VIGP. Maximum predicted off-site concentrations for PM10 and PM2.5 54.5 µg/m3 and 48.5 µg/m3 respectively. These maximum off-site concentrations exceed the BC Maximum Acceptable Guideline for PM10 of 50 µg/m3 and the Canada Wide Standard for PM2.5 of 30 µg/m3. As well, the report found a maximum predicted 1-hour average SO2 off-site concentration of 1,495 µg/m3, more than three times the desirable air quality objective of 450 µg/m3.
SENES found the following omissions and errors in the proponent’s consideration of impacts:• The emission rate for total particulate matter that is reported by the turbine’s manufacturer is 4.5 times higher than the emission rates for PM2.5 and PM10 modeled for the proposed VIGP facility.
• Cooling tower operations will result in a source of PM10 emissions, and this source was not considered in the original application. These emissions could be up to 3.5 times higher than emissions from the combustion stack.
• The proponent did not include the potential for formation of secondary fine particulate matter (PM2.5) due to synergistic effects of ammonia emissions from VIGP and SO2 emission from the Harmac mill.
• Unburned hydrocarbon emissions (as VOC) were underestimated by a factor of 3.3 when compared to values reported by the turbine manufacturer.SENES also found that there was substantial uncertainty about actual emissions from the Harmac mill, and that the cumulative effects analysis was flawed. In the project application, air quality was modeled on an emission rate for Harmac that is substantially lower than the emission rate on the Ministry of Water, Land & Air Protection’s emission inventory database. According to this database, the actual numbers for particulates from Harmac are more than four times higher than the numbers used by the proponent in its modeling.Background pollutant levels also were not adequately considered. Other PM sources in the area should be considered, since the Harmac-Cedar-Woodbank monitoring station, while not substantially influenced by Harmac’s emissions, shows levels of PM coming from other sources. These must be factored into the air quality assessment.Impact of Particulate Matter (PM) on Human Health
Over the past year it has become generally accepted that there is no known “safe” level of PM less than or equal to PM10. The Canadian Council of Ministers on the Environment (CCME) implementation guidelines for PM2.5 emissions, for the attainment of Canada-Wide Standards, take steps to ensure the continued reduction of PM2.5 , even in areas where PM2.5 concentrations are already below standard. The Science Assessment Document of the Federal-Provincial Working Group on Air Quality Objectives and Guidelines points out that regulatory jurisdictions have a responsibility to ensure air quality management strategies are developed and implemented that reduce emission of PM2.5 from both existing and proposed facilities.Emissions in the form of particulate matter are of particular concern from the VIGP. The CCME has identified the reduction of particulate matter as a priority, and the Federal Provincial Working Group on Air Quality Objectives and Guidelines has significantly reduced its current targets for particulates due to increased knowledge about their risks to human health. Due to their effect on cardio-respiratory health, there are no known safe levels of fine particulates.The application states that an additional 13 tons per year of PM2.5 or less will be added to our local area from VIGP. This is likely an underestimate, given the flaws in the air quality analysis (see above). The impact of this significant increase in PM will mean that the levels of particulates in the Nanaimo area will exceed provincial guidelines and as such can be expected to result in significant impacts in terms of health care costs and quality of life. Thirty-six local physicians have voiced their concerns in a letter submitted to the EAO about the health impacts of increased toxic particulate matter.Information on the ambient levels of particulate matter in Nanaimo is available through National Air Pollution Surveillance (NAPS). The 2000 Annual Report shows levels of PM2.5 that are very different from the numbers given in the proponent’s application. The three-year average of the 98th percentile 24-hour mean for PM2.5 is 17 µg/m3. The current reference level for PM2.5 is 15 µg/m3. Yet the proponent’s application cites an ambient level of PM2.5 to be only .11 µg/m3.The April 1999 Addendum To The Science Assessment Document of the Federal Provincial Working Group on Air Quality Objectives and Guidelines on “National Ambient Air Quality Objectives for Particulate Matter” looks at the issue of identifying protective ranges of particulates. The document recommends, since there is no safe known level of particulates, that the LOAEL (“lowest observed adverse effect level”) be set at PM10 12.5 µg/m3 and PM2.5 7.5 µg/m3 (averaged over 24 hours).Furthermore, it is likely that the full contribution of particulate matter from VIGP has been vastly underestimated by the proponent. US studies show that secondary particulates from gas turbines are about equal to primary particulates, and impurities from cooling tower emissions add another 15%, so that the total particulates could be 215% of the amount accounted for by the proponent. Given that particulate levels are so much higher than current targets, it would seem foolhardy to the health of local residents to allow a facility that would produce so much PM.Acidic Deposition
The proponent has not accounted for the effects that the 12 tonnes of sulphuric acid mist will have on acidic deposition from VIGP, or the interaction with acidic emissions from Harmac from their use of HCl, chlorine and H2S.
4) Water quality impacts
VIEC intends to obtain their water from Pope & Talbot’s Harmac Mill. It appears that they are seeking an authorization from the Water Comptroller, under section 34 of the Water Act, allowing Harmac to supply water to VIGP under existing licences.
The Nanaimo River is already considered to be short of water and has been closed to further water licencing (except domestic licences), since 1980. VIGP could not obtain its own licence on the Nanaimo River for the proposed plant due to a shortage of water. As well, other licence applicants have been denied water licences on the Nanaimo River, so the fairness of allowing VIGP to take water is questionable.
We are concerned about the volume of water that will be taken from the Nanaimo River and its effect on aquatic life in the river and estuary. Of particular concern are water levels during the summer months. Harmac has three licenses to take water from the Nanaimo River, which together total 3.54 m3/sec. Other non-related licences allow for the diversion of over 37,000 cubic metres per year, mostly during the low flow summer months for irrigation. The lowest recorded low flow last summer at the Environment Canada’s Cassidy monitoring station was 1.22 m3/sec. Harmac’s actual maximum use of water during 2001-2002 was 1.65 m3/sec (1.252 m3/sec for their pulp mill and the rest to other users).
The Nanaimo River may not be able to support the additional proposed VIGP use. Minimizing the impacts on the Nanaimo River depends on the management and use of the water reservoir. However, the application contains no discussion on protocol around the water reservoir, making it impossible to determine the potential impacts to the river.
The environmental assessment presented in the application is seriously lacking in its scope. The environmental effects of the VIGP cannot be assessed by simply measuring the combined water use of VIGP and Harmac against legal water allocation. Additional information that is required to properly assess potential impacts are:
historic, average flows of the River (prior to diversions);
current average and maximum water usage for all water users on the Nanaimo River, particularly during low flow periods;
existence of, or analysis of the need for, minimum flow protections for the Nanaimo River;
amount of water supplied to other water users by Harmac (especially during low flow periods);
current environmental health of the Nanaimo River and estuary (water flow, estuary wetted area, estuary salinity); and
an analysis of how the river and estuary, and the aquatic life within them, would be affected by additional diversions and cumulative effects with the addition of the VIGP plant (particularly since the estuary ecosystem depends on adequate co-mingling of fresh and salt water).
We question the legality and efficacy of VIEC and Harmac making an agreement that would allow VIEC to use water from Harmac and send their effluent to Harmac’s waste water treatment system.
The Water Act specifies that a licensee must make “beneficial use of the water for the purpose and manner authorized in the license”. In Harmac’s case, the stated beneficial use is “pulp mills”. Under the regulations, Harmac could be asked to complete a statement of beneficial use, declaring that they are using the permitted water solely for its stated beneficial use, and uses other than those permitted could result in the license being revoked.
VIEC should apply for both a separate water license as well as separate discharge permits for their facility. Harmac should not be allowed to absorb the activity of power generation under their licenses and permits, as this goes far beyond both the letter and spirit of these. If Harmac has excess water in their license, the license should be revised to reflect what they truly require. VIEC should not get special consideration ahead of other water users in the area who have applied for water licenses.
5) Socio-Ecomonic Impacts
The VIGP will result in additional pollution, particularly fine particulate matter, which has already been identified as a significant public health concern. The socio-economic impact of poor public health in the area has not been evaluated in terms other than acceptable risk. If an analysis were to be generated that showed the true costs to the health care system, quality of life, ability to work and mortality from cumulative air quality impacts, we believe that the costs to the community of the plant would far outweigh the expected benefit from the additional tax dollars it will provide.
The economies of Nanaimo and its surrounding communities are dependent on both tourism and the retirement community. Both of these will suffer if the VIGP contributes to poor air quality, as tourists won’t want to stay and explore the area and retirees will be attracted to a locale with more breathable air. As well, the water vapour plumes from VIGP will increase the industrial look of Nanaimo and will be quite evident from downtown Nanaimo and its approaches via BC ferries and Nanaimo harbour. This could be very damaging to tourism, including recreational boating-based tourism, which is very important to Nanaimo’s economy. Nanaimo markets itself as the “Harbour City” for good reason, as it serves as an important hub and supply center for Canadian and US boaters headed to and from Desolation Sound and other points northward. Many of these boaters stay several days in Nanaimo and inject important dollars into the local economy. If the area has an industrial look and poor air quality, this income could be severely reduced.
No analysis was done on the local effects of water vapour emitted from the gas plant, and a number of related questions remain unanswered, e.g.:
Will the water vapour have an effect on local air movement and conditions?
Is it possible that it could cause increased disruptions to air traffic at Cassidy airport, which is often foggy in the winter?
Could acid rain deposition affect forests, soil, water and shellfish, crops or even local petroglyphs?
Was the impact of pollutants settling into our soils and going into our local water evaluated, particularly with respect to how this could impact local economic activities such as organic farming and the shellfish industry?
Another social cost of the proposed project relates to public anger and attitude if the project is built, despite the fact that there has been no demonstrated need for the project (BC Hydro’s numbers and projections of power demand have been questioned by a number of outside sources). In three Vancouver Island communities to date, the public has spoken out loudly to question the overall wisdom of this project. Many citizens are advocating other power generation options, such as wind power, Independent Power Producers using more benign generating methods, an aggressive conservation program, and replacing the existing cable. The cost could be great if the provincial government is seen as ignoring a public willingness and desire create a different kind of energy future than the one proposed by VIEC.
The application says that an Emergency Response Plan will be developed for storage of hazardous materials and for accidents. The proponent will need to develop an Emergency Response Team, as the Nanaimo Fire Department doesn’t have a full hazardous materials response team. It would be worthwhile to know what kind investment in terms of equipment and training that the proponent will make towards an Emergency Response Team in the Nanaimo area.
Liquid ammonia, one of the more dangerous chemicals used at the plant, will be transported from Abbotsford to the Seaspan terminal in downtown Nanaimo, and then trucked to the plant. Risks associated with this chemical will be both on water, during storage in downtown Nanaimo, and through residential areas to the plant. These are not trivial concerns. For example, a barge regularly used for transport of hazardous materials to Nanaimo went aground last winter off Gabriola Island, losing virtually all of its cargo overboard. Fortunately the barge was on its return trip to the mainland when this happened, so was carrying empty hazardous materials containers. Had the storm occurred a day earlier, it could have been disastrous for residents of Gabriola Island and for the marine ecosystem of the area (which was in a marine protected area pilot project).
Light and noise pollution are another area of concern. The application states that noise won’t be an issue, given that the levels are lower than standard noise irritants. However, testimony from Bob Delise, who used to live a mile away from a power plant in Burrillville, Rhode Island, paints a different picture. Even though the noise was low level, the fact that it was constant was highly disturbing. Steam blows (shorts bursts of very load noise lasting less than a minute in duration) were also extremely disturbing. As well, the plant lighted up the sky at night and the vapour cloud blocked out both the sun and night sky. (http://members.shaw.ca/NCOC/Frameset1/Health/experience.html)
The economic benefits stated by the proponent are not likely to go far. The natural gas strategy does not use locally-available materials such as woodwaste or other biomass fuels that would keep revenues on Vancouver Island. Some local contractors may benefit from an infusion of capital during construction, but actual construction jobs are likely to be low and short-term. There are minimal job opportunities to operate the plant. Nor does it use local labour in the way that other fuel sources might, or create the same number of jobs: for example, for the same investment, we could create 1,200 jobs (at $75,000/annum) in renewable energy, versus just 100 jobs in gas generation. (Source: Jobs Not Pollution: A Comparison of a BC Renewable Energy Industry &the Gas Turbine Power Industry, by Ralph Keller & Delores Broten, for Adriane Carr, Leader of the BC Green Party, published in the Campbell River Courier, March 6th, 2002).
The current cost to build the plant is $370 million and this figure is likely to rise. The initially-cited cost of the associated GSX pipeline has already been revised to a much higher figure than previously stated, and we expect the same pattern will hold true with the gas plant. The Canadian subsidiary of US-owned Calpine Corporation has pulled out of the project, leaving costs to be borne solely by BC taxpayers.
In summary, we would urge you to take a precautionary approach by rejecting the application. There are too many unanswered questions, and too many potential environmental, health, social and environmental impacts. Public policy in BC on energy currently lags behind the public’s awareness of and desire for sustainable, renewable energy alternatives, and the VIGP would only result in institutionalizing and thereby widening this gap. By rejecting this proposal, the EAO will have done a considerable public service in that you will have helped to create the situational context for a thorough public dialogue and policy review, one that will otherwise be foreclosed by BC Hydro’s rush to tie us to a gas-generation energy future.