Contributed by Robert Lyman © 2018
Robert Lyman is an Ottawa energy policy consultant and former public servant of 27 years, prior to that he was a diplomat for 10 years. He is a frequent contributor to the Friends of Science blog.
Every major new oil pipeline project proposed in Canada over the last decade has encountered significant opposition from environmentalist and aboriginal groups, with many of them parading signs declaring that “Water is Life”. These groups have claimed incessantly that the construction and operation of pipelines creates unacceptable risks for rivers, lakes, wetlands and underground aquifers. Seldom, if ever, does the mainstream news media ever examine the facts behind these claims or dare to challenge them. Thus is born a whole new set of myths, destined to be repeated at each new demonstration.
This note will examine the general background to these claims and then the specific issues that were raised during the National Energy Board’s three-year review of the planned Trans Mountain Expansion Project (TMPL).
Oil Pipelines in the United States and Canada
If one were completely unaware of the energy infrastructure in North America and listened only to the protests being made, one might suppose that there are very few oil pipelines now operating and that the technology for building and operating them safely was in its infancy.
In fact, oil pipelines have been operating in North America since the 1870’s, for almost 150 years. There was a significant expansion of the existing systems in the early part of the 20th century, then again after the Second World War, and most recently in the last decade. In fact, in the United States, the crude oil pipeline system expanded from about 51,000 miles in 2008 to 75,700 miles in 2016, a 48% increase in less than a decade. In addition, 62,400 miles of pipelines transport refined petroleum products.
In Canada, there were 48,500 kilometres of oil pipelines operating in 2016, 27,600 km of them gathering lines and 20,900 km of trunk lines.
Virtually every one of the trunk lines in both countries crosses dozens, if not hundreds, of waterways and areas where there are underground aquifers. For its entire history, the pipeline industry has been coping with the engineering problems of how to build and operate pipelines so as to minimize the potential adverse effects on waterways.
The Canadian Oil Pipeline Industry’s Safety Record
The Transportation Safety Board of Canada (TSB) is responsible for maintaining statistics on the operation of oil and natural gas pipelines in Canada, including records of any “accidents” or “incidents” that occur, and for preparing in-depth reports on major accidents, especially where these involve a release into the environment. According to TSB data, in 2016 federally regulated oil pipelines in Canada (i.e. those that cross interprovincial or international boundaries) transported 1.2 billion barrels to market. 1.2 billion (i.e. 1,200,000,000) is a very large number. To get some sense of what that means, a barrel is almost a yard high, so 1.2 billion barrels laid end-to-end would be close to 680,000 miles, or almost three times the distance from the earth to the moon.
The TSB counts as an accident any event that results in a severe injury or loss of life, or a rupture, explosion or other event that causes a pipeline to be inoperative.
It counts as an incident any event that is a reportable occurrence, ranging from minor threats to the operation of the pipeline to an unintended or uncontrolled release of a product. In 2016, the number of accidents involving federally regulated pipelines was a nice round number – zero, exactly the same as the number of accidents in 2015. In fact, the number of accidents on oil and natural gas pipelines combined has averaged only four per year over the last five years. The number of incidents involving oil and gas pipelines in 2016 was about 100, half of which occurred on transmission lines. Fifty-seven of these involved no release of product. One incident involved the release of one to 25 cubic meters of petroleum. That’s one.
The Canadian Energy Pipeline Association (CEPA) often publicizes the fact that 99.999% of the petroleum transported arrives safety with no incident. That is an exaggeration. It is more like 99.99999 % arrives safely with no incident. The spill avoidance issue, about which so much news is made, is all about avoiding that last 0.00001%.
The Trans Mountain Expansion Project – Basic Facts
The project involves the expansion of an existing oil pipeline system that runs from Edmonton, Alberta to Burnaby, British Columbia, at which point some of the crude oil would be loaded onto tankers at the Westridge Marine Terminal, where it would be delivered to markets throughout the west coast of North America and the Pacific Rim. This pipeline system has operated for 65 years, since 1953.
The expansion project would result in the looping (or twinning) of the existing 1,147 km Trans Mountain Pipeline (TMPL) system with about 987 km of new buried pipeline. The older pipeline would be designated Line 1. The proposed new pipeline segments, along with two currently active segments, would become Line 2.
Most of the expansion would occur along existing rights of way that have been used since 1953 – the same watersheds, rivers and wetlands that have been close to the pipeline for 65 years!
The existing pipeline now transports both crude oil and refined petroleum products to British Columbia and export markets in the Puget Sound area as well as California. Today, British Columbia receives over half of its motor gasoline supplies from Alberta via TMPL; the dedication of Line 1 exclusively to refined oil products would increase the security and flexibility of refined oil product supply to British Columbia consumers. In total, the project would increase the capacity of the TMPL system from 300,000 barrels per day to 890,000 barrels per day of crude oil and refined products.
The Water-Related Issues Considered During National Energy Board Review
There were three main onshore water-related issues addressed during the environmental review of the TMPL project. These concerned the anticipated effects of the construction and operation of the project, and the potential for mitigation, in three specific aspects:
- Surface water quality and quantity
- Groundwater quality and quantity
It is well known, and was acknowledged by Trans Mountain during the NEB review, that pipeline construction can have a number of potential residual effects on surface water quality and quantity, primarily due to reduced water quality (i.e. suspended sediments) during construction activities. Trans Mountain identified a number of watersheds crossed by the proposed pipeline corridor, including the Sturgeon River, Lower and Upper North Saskatchewan River, Lower MacLeod River, Athabaska River, Lower North Thompson River, Thompson River, South Thompson River, Lower Nicola River and Similkameen watersheds.
It committed, however, to implement both general and site-specific mitigation, monitoring and reclamation measures either to reduce any adverse effects or avoid them altogether.
A key concern raised by some participants in the review was the potential alteration or loss of riparian habitat resulting from construction or operation of the pipeline. Riparian habitat is the soil and vegetation along river margins and banks. There could be a temporary effect, but Trans Mountain pointed out that maximum riparian area that might be disturbed was 334.6 hectares, or 0.05% of the total riparian habitat within the Regional Study Area.
Trans Mountain committed to:
- Limit riparian vegetation clearing to trench areas and any required workspace within the pipeline corridor;
- Adhere to the Forest Practice Code and the Riparian Management Area Guidebook in B.C. during clearing activities;
- Adopt riparian buffer setbacks to temporary workspaces based on provincial and federal guidelines;
- Revegitate any disturbed riparian habitat; and
- Monitor these areas upon completion of construction to ensure that they return to similar pre-construction condition.
The NEB considered that the Environmental Protection Plans Trans Mountain submitted would effectively reduce the extent of any effects on surface water quality and quantity. The Board, however, imposed four conditions as part of the pipeline certificate (Conditions 72, 78, 151 and 154) requiring Trans Mountain to submit additional plans and to commit to additional management of riparian habitat.
Trans Mountain conducted extensive studies of the proposed pipeline corridor to identify the aquifers along the proposed route, the facilities overlying mapped aquifers, and potential groundwater quality effects. It established groundwater monitoring programs at selected facilities, including the Burnaby Terminal, to identify impacts on groundwater. It testified that, should a release from the pipeline or related facilities occur and groundwater impacts be suspected, it would undertake a hydrogeological investigation to assess site conditions and the magnitude and extent of any impacts.
Trans Mountain proposed mitigation measures to address the Project’s potential effects on groundwater quality and quantity. It followed recommendations from several industry and federal and provincial regulatory guidelines in designing construction activities to avoid diversion and unnatural retention of water along the right-of-way.
The NEB accepted Trans Mountain’s commitments to identify areas of high risk and to implement additional risk mitigation measures where needed. However, it added certificate condition 130 requiring Trans Mountain to develop a groundwater monitoring program for any vulnerable aquifers that may be present along the pipeline route.
Overall, given these commitments and conditions, the Board concluded that the construction and operation of the pipeline was “not likely to cause significant adverse environmental effects.”
Trans Mountain testified that 538 wetlands would potentially be crossed by the proposed pipeline corridor. Not all of these wetlands would be disturbed because the pipeline right-of-way would be routed within the corridor to avoid wetlands to the extent practical.
Trans Mountain reviewed aerial surveys and satellite imagery of the wetlands encountered by the Project, and during the pre-construction field program ground surveyed 413 of the 538 wetlands crossed. It committed to ground survey all the remaining wetlands before construction began. The pipeline will follow existing linear infrastructure where feasible.
Past studies of other projects indicate that, with the mitigation measures proposed, along with supplemental remediation measures where warranted and the passage of time, wetlands habitat function generally returns successfully within two to three years following construction. The adverse effects, if any, are temporary. Trans Mountain stated that its goal was to return all wetlands to the same “functional condition category” post-construction.
Trans Mountain further committed that, at the last year of post-construction monitoring (i.e. year five after construction), if any wetland is not on the way to recovering its pre-construction functional condition, and additional remedial measures are not enough, it would provide financial compensation, and provided a Preliminary Wetland Compensation Plan.
The NEB found these commitments acceptable.
The risks of oil pipeline spills in Canada are already extremely low. If they do occur, the pipeline company is required by law to pay the costs of clean-up, and it must have services available that ensure that clean-up will be rapid and effective.
There are potentially some temporary adverse effects of pipeline construction on surface water, groundwater and wetlands during and immediately after construction. These are generally small and temporary. In Trans Mountain’s case, the company has gone to extraordinary lengths to anticipate, prepare for and mitigate any adverse effects that might occur. These actions have been reviewed by the pipeline engineers, biologists and other professional staff of the National Energy Board and been subject to lengthy public regulatory review and approval by experts.
It is fair to say that the Trans Mountain Project has been subjected to an unprecedented level of regulatory and scientific scrutiny on all aspects of its construction and operation, including perhaps especially its potential impact on water. If this level of review and requirements for mitigation and remediation were imposed on any other transportation infrastructure, we would never build another highway, port, rail line or electricity transmission line in Canada.
Demanding that no infrastructure project or building proceed unless there is zero risk of even the smallest environmental impact would mean that modern economies would cease to function because there it would not be possible to build and operate the businesses that serve society’s needs.
Those who shout slogans and carry posters saying, “Water is Life” are proclaiming a truth, but a half truth. By opposing beneficial infrastructure, they are denying the possibility of prosperous life in the modern world.