BC launching major study of Kitimat River, Kitimat Arm water quality

The Environmental Protection Division of BC’s Ministry of Environment is launching a major study of the water quality in the Kitimat valley, first on the Kitimat River and some of its tributaries and later on the Kitimat Arm of Douglas Channel.

There has been no regular sampling by the province in Kitimat since 1995 (while other organizations such as the District of Kitimat have been sampling).

Jessica Penno, from the regional operations branch in Smithers, held a meeting for stakeholders at Riverlodge on Monday night. Among those attending the meeting were representatives of the District of Kitimat, the Haisla Nation Council, LNG Canada, Kitimat LNG, Rio Tinto BC Operations, Douglas Channel Watch, Kitimat Valley Naturalists and the Steelhead Society.

As the project ramps up during the spring and summer, the ministry will be looking for volunteers to take water samples to assist the study. The volunteers will be trained to take the samples and monitored to insure “sample integrity.” Penno also asked the District, the Haisla and the industries in the valley to collect extra samples for the provincial study and to  consider sharing historical data for the study.

With the growing possibility of new industrial development in the Kitimat valley, monitoring water quality is a “high priority” for the province, Penno told the meeting. However, so far, there is no money targeted specifically for the project, she said.

Fishing and camping on the Kitimat River
Camping and fishing on the Kitimat River. (Robin Rowland/Northwest Coast Energy News)

The purpose of the study is to make sure water in the Kitimat valley meet the provinces water quality objectives, which have the aim of watching for degradation of water quality, upgrade existing water quality or protect for designated uses such as drinking water, wildlife use, recreational use and industrial water supplies as well as protecting the most sensitive areas. It also provides a baseline for current and future environmental assessment. (In most cases, testing water quality for drinking water is the responsibility of the municipalities, Penno said.  The province may warn a municipality if it detects potential problems, for example if a landslide increases metal content in a stream).

Under the BC Environment system, “water quality guidelines” are generic, while “water quality objectives” are site specific.

One of the aims is to compile all the studies done of the Kitimat River estuary by the various environmental impact studies done by industrial proponents.

The ministry would then create a monitoring program that could be effectively shared with all stakeholders.

At one point one member of the audience said he was “somewhat mystified” at the role of Fisheries and Oceans in any monitoring, noting that “when you phone them, nobody answers.”

“You mean, you too?” one of the BC officials quipped as the room laughed.

Water quality objectives

The last time water quality objectives were identified for the Kitimat River and arm were in the late 1980s, Penno told the meeting. The objectives were developed by the British Columbia government because of potential conflict between fisheries and industry at that time. The objectives were developed for the last ten kilometres of the Kitimat River and the immediate area around the estuary and the Kitimat Arm. “The Kitimat is one of the most heavily sport fished rivers in Canada,” she said.

However, the work at that time was only provisional and there was not enough water quality monitoring to create objectives that could be approved by the assistant deputy minister.

There has been no monitoring of the Kitimat River by BC Environment since 1995. “We’ve had a lot of changes in the Kitimat region, with the closure of Methanex and Eurocan, the modernization of Rio Tinto and potential LNG facilities.”

The main designated uses for the Kitimat River at that time were aquatic life, wildlife with secondary use for fishing and recreation.

She said she wants the stakeholders to identify areas that should be monitored at first on the river and the tributaries. Later in the summer, Environment BC will ask for suggestions for the estuaries of the Upper Kitimat Arm.

Participants expressed concern that the water supply to Kitamaat Village and the Kitimat LNG site at Bish Cove as well as Hirsch Creek and other tributaries should be included in the study. Penno replied that the purpose of the meeting was to identify “intimate local knowledge” to help the study proceed.

After a decade so of cuts, the government has “only so much capacity,” Penno said, which is why the study needs the help of both Kitimat residents and industry to both design the study and to do some of the sampling.

The original sampling station in the 1980s was at the Haisla Boulevard Bridge in Kitimat. A new sampling station has been added at the “orange” Kitimat River bridge on Highway 37. There is also regular sampling and monitoring at Hirsch Creek. The aim is to add new sampling points at both upstream and downstream from discharge points on the river.

The people at the meeting emphasized the program should take into consideration the Kitimat River and all its tributaries—if budget permits.

Spring freshette

Last year, the team collected five samples in thirty days in during four weeks in May and the first week in June, “catching the rising river quite perfectly” at previously established locations, at the Haisla Bridge and upstream and downstream from the old Eurocan site as well as the new “orange bridge” on the Kitimat River.

The plan calls for five samples in thirty days during the spring freshette and the fall rain and monthly sampling in between.

The stakeholders in the meeting told the enviroment staff that the Kitimat Valley has two spring freshettes, the first in March during the valley melt and later in May during the high mountain melt.

The plan calls for continued discussions with the industry stakeholders, Kitimat residents and the Haisla Nation.

The staff also wants the industrial stakeholders to provide data to the province, some of it going back to the founding of Kitimat if a way can be found to make sure all the data is compatible. One of the industry representatives pointed out, however, that sometimes data is the hands of contractors and the hiring company may not have full control over that data.

There will be another public meeting in the summer, once plans for sampling in the Kitimat Arm are ready.

Dilbit dangerous to young fish, laboratory study shows

Diluted bitumen, also known as dilbit, a mixture of oil sands bitumen and natural gas dilutants can seriously harm fish populations, according to research study at Queen’s University and the Royal Military College of Canada published this week.

At toxic concentrations, effects of dilbit on exposed fish included deformities and clear signs of genetic and physiological stress at hatch, plus abnormal or uninflated swim bladders, an internal gas-filled organ that allows fish to control their buoyancy. Exposure to dilbit reduces their rate of survival by impairing their ability to feed and to avoid predators.

Post-doctoral fellow Barry Madison works with the fish in Valerie Langlois' lab. (Queen's University)
Post-doctoral fellow Barry Madison works with the fish in Valerie Langlois’ lab. (Queen’s University)

Among the other findings from the study were

    • Embryo toxicity of dilbit was comparable to that of conventional oils.
    • Developmental malformations increased with increasing dilbit concentrations.
    • Chemical dispersion broadened the genotoxic effects of dilbit

“This new study provides a clearer perspective on the potential risks to Canada’s aquatic resources of dilbit spills, and a technical basis for decisions on dilbit transportation within Canada,” says Peter Hodson Environment Studies, Biology at Queens. “It reduces some of the uncertainty and unknowns about the hazards of dilbit.”

This study characterized the toxicity and physiological effects of unweathered diluted bitumen (Access Western Blend dilbit; AWB) to a fish used for laboratory studies. Embryos of Japanese medaka (Oryzias latipes) were exposed for 17 days to dilutions of dilbit physically-dispersed by water and chemically-dispersed by dispersants

AWB dilbit exposure was not lethal to medaka, but resulted in a high prevalence of blue sac disease (BSD), impaired development, and abnormal or un-inflated swim bladders. Blue sac is a disease of young trout and other salmonid species; usually caused by unsuitable hatchery water. It turns the yolk sac bluish and is thought to be caused by a lack of oxygen.

The research was funded by Fisheries and Oceans Canada’s National Contaminants Advisory Group and the next stage will determine whether fish species native to Canada will be affected by dilbit exposure. The work also includes the development of genetic markers of exposure to dilbit and toxicity that could be used to assess whether wild fish that survive a spill are still affected.

The research team includes Dr. Valérie Langlois (Environmental Studies, Royal Military College of Canada) and Dr. Barry Madison (Royal Military College of Canada).

Dr. Hodson is also a member of a Queen’s research team tasked to determine whether dilbit spilled into rivers would contaminate bed sediments, specifically areas where fish such as salmon, trout, chars, whitefish and graylings spawn, to the extent that the survival of their embryos would be affected.

The research was published in ScienceDirect and is one of the first studies of dilbit on young fish.

The finding could be significant because both the proposed Northern Gateway pipeline and the proposed Kinder Morgan expansion will cross areas near spawning streams.

Sending the Northern Gateway Pipeline to Prince Rupert: A dumb, dumb, dumb idea—and here are the photos to prove it.

There’s a dumb, dumb, really dumb idea that just won’t go away—that Enbridge could solve all its problems if only, if only, it would send the Northern Gateway Pipeline to Prince Rupert.

Enbridge long ago rejected the idea. Before Enbridge updated its website to make  Gateway Facts, to make it slick and more attractive, the old website had an FAQ where Enbridge explained why it wasn’t going to Prince Rupert.

Did you consider running the pipeline to Prince Rupert where a major port already exists?

We considered Prince Rupert and Kitimat as possible locations. We carried out a feasibility study that took into account a number of considerations. The study found that the routes to Prince Rupert were too steep to safely run the pipeline, and that Kitimat was the best and safest option available.

Current proposed route for the Northern Gateway pipeline. (Enbridge)
Current proposed route for the Northern Gateway pipeline. (Enbridge)

Here in the northwest even the supporters of the Northern Gateway roll their eyes when they hear the old Prince Rupert story come up again and again – and it’s not just because these people support the Kitimat plans for Northern Gateway, it’s because those supporters (not to mention the opponents) have driven along the Skeena from Terrace to Prince Rupert.

There just isn’t any room for a pipeline. It’s a game of centimetres.

A rainbow hugs the mountains near the Telegraph Point rest area on the Skeena River between Terrace and Prince Rupert, Sept. 29, 2014.  Traffic is seen on the narrow corridor between the mountains and the river (Robin Rowland/Northwest Coast Energy News)
A rainbow hugs the mountains near the Telegraph Point rest area on the Skeena River between Terrace and Prince Rupert, Sept. 29, 2014. Traffic is seen on the narrow corridor between the mountains and the river (Robin Rowland/Northwest Coast Energy News)

Alternatives to Kitimat?

Now the new premier of Alberta, Jim Prentice, who should know better if he’s going to lead that province, is hinting that Kitimat isn’t the only possible solution for the Northern Gateway.

Without specifying Prince Rupert, according to Gary Mason reporting in The Globe and Mail, Prentice was speculating about an alternative to Kitimat.

Asked whether he believes the Gateway terminus should be relocated to Prince Rupert or another destination, Mr. Prentice said, “Everything I’ve heard from the Haisla who live there is they don’t agree with the terminal being in Kitimat.” Is it possible to get First Nations approval if there is no support at the planned terminus site? “It’s pretty tough,” the Premier said.

A couple of days ago, the Prince Rupert’s Mayor Jack Mussallem told The Globe and Mail in Mayor, port authority say no room for Northern Gateway pipeline in Prince Rupert

Prince Rupert has a thriving local fishing industry that employs hundreds of people and is critically important to the local First Nations. He is convinced the community would not be willing to put that at risk.
“Overwhelmingly people in my community are much more comfortable with liquefied natural gas, with wood pellets, with coal, than any oil product,” he said.

The Prince Rupert Port Authority also rejected the idea

A spokesman for the Prince Rupert Port Authority said Wednesday there is currently no room for Enbridge to build at the port even if it wanted to. “We are fully subscribed,” Michael Gurney said. There are two large vacant lots within the port authority’s jurisdiction, but both are locked by other energy companies, earmarked for LNG projects.

So not only is there no room on the road to Prince Rupert, there is no room in Prince Rupert.

Shovel-ready?

Let’s just consider for a moment that if Prince Rupert was the ideal location for the Northern Gateway terminal (which it is not), what would be needed to get the project going today.

The Northern Gateway Joint Review Panel would have be reconstituted or a new JRP created by the National Energy Board. That’s because the bitumen comes from Bruderheim, Alberta, crossing provincial boundaries and thus it’s in federal jurisdiction.

Even under the fast track rules imposed on the NEB by Stephen Harper’s Conservative government, new environmental and social impact studies would be required, starting from scratch. So add another five years of paperwork before a single shovel goes into the ground.

The pipeline would have to cross the traditional territory of First Nations that, so far, have not been part of the negotiations, mostly the Tsimshian First Nation as well as the Nisga’a First Nation which has a treaty establishing local rule over their territory.

Traditional leaders of the Gitga'at First Nation lead a protest march through the streets of Prince Rupert, February 4, 2012. (Robin Rowland/Northwest Coast Energy News)
Traditional leaders of the Gitga’at First Nation lead a protest march through the streets of Prince Rupert, February 4, 2012. (Robin Rowland/Northwest Coast Energy News)

In February 2012, the largest anti-Enbridge demonstration outside of the Lower Mainland took place in Prince Rupert, with the elders of the Tsimshian First Nation welcoming the elders and members of the Gitga’at First Nation, at Hartley Bay, which had organized the protest.

While Kitimat Council long stood neutral on the issue, the councils at Prince Rupert, Terrace, Smithers as well as the Kitimat Stikine Regional District and the Skeena Queen Charlotte Regional District had voted to oppose the Northern Gateway.

Audio Slideshow; No to Tankers Rally, Prince Rupert, February 4, 2012

The Skeena Route

The Skeena is one of the greatest salmon rivers on the planet. The Petronas LNG project has already run into problems because its planned terminal at Lelu Island would also impact the crucial eel-grass which is the nursery for young salmon leaving the Skeena and preparing to enter the ocean. Note that northern BC is generally in favour of LNG terminals, if the terminals are in the right place, so expect huge protests against any bitumen terminal at the mouth of the Skeena.

When I say there isn’t room for a pipeline along the Skeena, it also means that there isn’t any room for the pipeline corridor right-of-way. Enbridge, in its submissions to the Joint Review Panel, said it requires a 25 metre wide right of way for the pipeline corridor. (For the record that’s just over 82 feet).

Along that highway, as you will see, there’s barely enough room for the CN mainline and Highway 16 (also known as the Yellowhead Highway) and on a lot of places both the highway and the railway roadbed are built on fill along the side of a cliff.

Now I’ve said this all before, two years ago, in a piece for the Huffington Post, Get Over it! A Pipeline to Prince Rupert Is Bust

Albertans’ desperate desire to see the Northern Gateway go to anywhere to what they call “tide water” keeps coming up like the proverbial bad penny. The latest came when Jim Prentice speculated about a new route for the Northern Gateway.

I knew I had an appointment coming up in Prince Rupert on Monday, September 29. So I decided that only way to prove to people sitting in Calgary, Edmonton and Fort McMurray playing with Google Maps that the pipeline to Prince Rupert was a really dumb idea was to shoot photographs to show just why the Northern Gateway will never go to Prince Rupert—at least along the Skeena.

As you drive out of Terrace, you pass two large swing gates (also called by some “Checkpoint Charlie” gates after the Cold War era crossing in Berlin.) At the first rest stop west of Terrace, there are another set of gates at the Exstew. There’s a third set of gates just outside Prince Rupert.

A logging truck passes the avalanche gates at Exstew on Highway 16, Sept. 29, 2014.  (Robin Rowland)
A logging truck passes the avalanche gates at Exstew on Highway 16, Sept. 29, 2014. (Robin Rowland)

The swing gates are avalanche gates and, in the winter, Highway 16 can be shut down if an avalanche closes the highway or the danger from avalanche is too great to allow motorists to proceed. When you drive the highway from Terrace to Prince Rupert in the winter (the signs were covered up when I drove Monday) you are warned “Avalanche danger Next 13 kilometres. No stopping.”

The Exstew avalanche gates, (Robin Rowland/Northwest Coast Energy News)
The Exstew avalanche gates, (Robin Rowland/Northwest Coast Energy News)

The drive along the Skeena from just west of Exchamsiks River Provincial Park all the way to Tyee where the highway turns inland to reach northwest to Prince Rupert on Kaien Island is one of the most spectacular drives on this planet. The highway snakes along a narrow strip of land with steep mountain cliffs on one side and the vast river on the other.

The problem is that apart from locals and tourists, none of the “experts” whether journalist, think tanker, bureaucrat or politician have, apparently ever driven from Prince Rupert to Terrace.

When both Opposition Leader Tom Mulcair and Liberal Leader Justin Trudeau were in the northwest earlier this summer to “engage” with the local people, apart from short boat trips down Douglas Channel, they flew everywhere. Scheduling you know. Stephen Harper has never visited northwest BC and probably never intends to. His cabinet members fly in for photo ops and then are on the next plane out of town.

Of all the visiting journalists who have come to the northwest only a couple have bothered to drive around the region. Most fly-in fly-out. These days, most often budget-strapped reporters never leave their offices, interviewing the same usual suspects by phone on every story.

On Monday, I took most of the photographs on my way back from Prince Rupert to Terrace after my appointment, so the sequence is from west to east. There are also very few places along the river where you can safely stop. There are concrete barricades on both sides of the highway to prevent vehicles either going into the river or onto the narrow CN right-of-way.

There are, however, two rest stops and a number of small turnoffs on the highway, the turnoffs mainly intended for use by BC Highways, but which are also used by tourists, fishers and photographers.

aberdeencreek1

The first image was taken at one of those highway turnoffs just east of Aberdeen Creek. This is what the highway and rail corridor are like all along the Skeena, the highway, bounded by concrete barricades, the CN rail line and then the towering mountains. Note where the telegraph and telephone lines are—further up the cliffside.

aberdeencreek4

A closer view of the highway and rail corridor just east of Aberdeen Creek.

aberdeencreek3

Here is the view of the Skeena River from the Aberdeen Creek turnoff. You can see to the east, a mountain and the narrow strip of fill land that supports the highway and the rail line.

 

aberdeencreek2
You see the broad width of the mighty Skeena, the Misty River, as it is called by the Tsimshian First Nation and by everyone else who lives in the northwest and on the right side of the image, the highway and rail corridor built on fill.

Any room for a pipeline?

aberdeencreek5

There’s another turnoff on the other side of the headland east of Aberdeen Creek, looking back the way we came.

khyex1

The final small turnoff is just by the Kylex River. Again you can see how narrow the highway and rail corridor are.

basalt

A few kilometres further along—as I said the highway snakes and curves its way along the riverbank–  you come to the Basalt Creek rest area. So this telephoto image shows a logging truck heading west,   taken from Basalt Creek, looking back at the highway.

Again you can see both the highway and CN line are built on fill. Is there any room for a pipeline?

Any room for a 25 metre pipeline right-of-way?

Between Basalt Creek and Telegraph Point, a few kilometres to the east, again the highway and rail line hug the narrow strip between the river and mountains.

Rowland_CN_container_Skeena

This shot, taken from Telegraph Point, in October 2013, shows a CN intermodal container train heading to Prince Rupert. The container trains and the coal trains usually have between 150 and 180 cars. If a winter avalanche took out a train, there would be environmental damage, but that damage would be insignificant from coal or containers compared to a train of railbit tankers carrying diluted bitumen.

At Telegraph Point, the second of the three rest stops between Prince Rupert and Terrace, again there is just a narrow strip between the mountain, the highway and the river.

telegraph1

telegraph2

Across the highway from the rest stop, you can again see the narrow corridor, the first shot looking west the rail line close to the cliff face, the second, east, with the waterfall, which you don’t see during the rest of the year, fed by the fall monsoon.

 

telegraphmarch2013Two shots from the same location, Telegraph Point, taken in March, 2013, of a CN locomotive hauling empty coal cars back to the fields around Tumbler Ridge. (No waterfall in March)

telegraphmarch2013_1

 

Alternative routes

Everyone has assumed that if Northern Gateway changed its route, the most likely choice given the configuration of the pipeline at the moment is to follow the Skeena.

There are alternatives. The Petronas LNG project and its partner TransCanada Pipelines have proposed a more northern cross-country route, which would go north from the Hazeltons, avoiding the Skeena 

Proposed natural gas pipeline. (TransCanada)
Proposed natural gas pipeline. (TransCanada)

The BG Group and Spectra Energy are also contemplating a pipeline…although details on the website are rather sparse.

If Enbridge wanted to try a northern route, similar to the one TransCanada contemplates for Petronas, Northern Gateway would again run into trouble.

It would require reopening or creating a new Joint Review Panel, many more years of environmental and social impact studies of the route, even under Stephen Harper’s fast track system. The TransCanada/Petronas pipeline would also cross the traditional territory of the Gitxsan First Nation and if Enbridge tried that the company would have to deal with the fact that it signed a controversial agreement with Elmer Derrick that was immediately repudiated by most members of the Gitxsan First Nation and eventually dropped by Enbridge.

So why does this idea of a pipeline to Prince Rupert keep coming up?

In most cases, the idea of the pipeline to Prince Rupert is always proposed by Albertans, not from any credible source in British Columbia, or the suggestions come from desk bound analysts in Toronto and Ottawa both in think tanks and in the newsrooms of dying newspapers who have never seen the Skeena River apart from a tiny handful who have looked at Google Street View

(Yes you can Google Street View Highway 16 along the Skeena, I recommend it if you can’t do the drive)

Perhaps the worst example of this failure of both analysis and journalism came in the Edmonton Journal on July 7,2014, when it published a piece by Bob Russell, entitled Opinion: Make Prince Rupert the terminus, which went over the same old inaccurate arguments.

The overland route currently proposed by Enbridge is fraught with environmental issues because it goes over coastal mountains and streams before entering Kitimat’s port. This port will also be the base of perhaps as many as four liquefied natural gas terminals, which will result in the channel always busy with LNG ships outbound and returning from many Asian ports.

There are existing rights of way for the major highway, the Yellowhead, and CN Rail line from Edmonton to the Port of Prince Rupert, so this eliminates the issue of transgressing First Nations lands. The technical issues of narrow passages can be overcome with engineering. In fact, the pipeline can be buried in the roadway at some restricted locations if absolutely necessary, but two different engineers have assured me that for the most part, the right of way should be able to handle the pipeline. A vital factor, of course, is to reduce the impact by eliminating the need for two pipelines.

The clue is how the Edmonton Journal describes Russell;

Bob Russell has an extensive background in planning and was a member of the Edmonton Metro Regional Planning Commission. He has flown the Douglas Channel, visited Kitimat and toured the Port of Prince Rupert.

This is so typical of the Albertan attitude toward northwest British Columbia,  people fly in for a couple of days, make a quick observation, and fly out again and present themselves as experts on the region. (Some “experts” on Kitimat, very active on Twitter have apparently never left Calgary).

It obvious that the “two engineers” who assured him “the right-of-way could handle of pipeline” have no idea what they’re talking about. As the photos show there is barely enough room for a highway and a rail line much less a 25 metre wide pipeline corridor.

If the pipeline was to be built as Russell proposed, the only highway between Prince Rupert and the rest of Canada would have to be closed for years, there are no detours.  All so a pipeline can be buried under the asphalt not in solid ground, but in the fill on the side of a riverbank in an avalanche zone?

Of course, closing a highway up here won’t inconvenience anyone in Edmonton or Calgary, will it?

Would CN be happy with years of disruption of their lucrative traffic to Prince Rupert with grain and coal outbound to Asia and all those containers coming in to feed Chinese products to the North American market? (you can be sure Walmart wouldn’t be happy about that, not to mention prairie farmers including those from Alberta)

Russell’s statement

There are existing rights of way for the major highway, the Yellowhead, and CN Rail line from Edmonton to the Port of Prince Rupert, so this eliminates the issue of transgressing First Nations lands.

Is also inaccurate.

I was told by First Nations leaders during the Idle No More demonstrations in the winter of 2013, that, a century ago, when the Grand Trunk built the railway along the Skeena , they did just that, built it without consulting the First Nations along the route, sometime digging up native cemeteries and sacred spots.

While apparently CN has worked in recent years to improve relations with the First Nations along the rail line, according to those leaders some issues of right-of-way remain to be resolved.

If there were any plans to build a diluted bitumen pipeline along that route, that would likely mean another court battle adding to those already before the Federal Court, a court battle that would cost Enbridge, CN, the federal government, environmental NGOs and the First Nations more millions in lawyers’ fees.

It’s doubtful if in the long gone (and perhaps mythical) days of “get it right” journalism that the Russell opinion piece would have passed the scrutiny of an old fashioned copy editor and fact checker.

In 2012, the Edmonton Journal (in a story no longer available on their website) also cited former Alberta Premier Peter Lougheed and former Bank of Canada governor David Dodge, as also favouring Prince Rupert.

Dodge, who was in Edmonton Tuesday to deliver a speech on the global economic outlook at MacEwan University, said Enbridge’s proposed Northern Gateway pipeline to Kitimat looks like even more of a long shot.
“I think the project to Kitimat looks, objectively, more risky. So why hasn’t much greater effort gone into looking at Prince Rupert and taking (bitumen) out that way? My guess is, the easiest place to get B.C. to buy into the project would be to go to Rupert.”
Dodge’s views echo those of former Alberta Premier Peter Lougheed, who also favours looking at an alternate pipeline route to Prince Rupert, where ocean-going supertankers can navigate more easily.

Back in 2012, I finished my piece for the Huffington Post by saying:

So why do people insist, despite the evidence, that the Northern Gateway go to Prince Rupert? It’s no longer an pipeline; it’s emotion and ideology. Ideology in that opposition to the Northern Gateway is seen by conservatives as heretical opposition to free enterprise itself. Emotion among those who see promoting the oil patch as an issue of “Alberta pride” and even Canadian patriotism.
For the promoters of the pipeline to Prince Rupert, ignoring the science of geology and the study of geography across all of northwestern B.C. is no different than repeatedly knocking your head against the Paleozoic metamorphic greenstone of the mountain cliffs along the Skeena. It only gives you a headache.

Things haven’t gotten much better in the past two years. In fact they’re getting worse as opposition to pipelines mounts.

It seems that in 2014  the Alberta and the federal government policy in promoting pipelines Northern Gateway, KinderMorgan’s TransMountain, Keystone XL, Line 9 Reversal and Energy East (slick PR and smiling representatives at open houses, politicians at strictly controlled photo ops) is to ignore facts on the ground and to refuse to deal with the concerns of local people from coast to coast.

There could, perhaps, be a more inclusive and truly science-based pipeline planning process that could see pipelines go on optimum routes but that isn’t happening.

The policy  for the oil patch and its politician supporters when it comes to pipelines is facts and geology don’t really matter. So they put on ruby slippers, knock their heels together three times and send pipelines down a yellow brick road to an Emerald City (while telling the locals to ignore the man behind the curtain)

Related links

The Save Our Salmon website has a different view, arguing that federal government and the energy companies have a plan to create an energy corridor for bitumen pipelines to Prince Rupert.

Genetics show stronger pine beetle evolving; stream flow increases in infected forests: studies

A new study, based at the University of Alberta, released this week, indicates that natural selection may be making the mountain pine beetle more tolerant of colder temperatures and that the beetle may be evolving the ability to fly longer distances.

A second study, from the Colorado School of Mines, also released this week, is tracking how the extent of pine beetle infected or killed trees in forests is changing ground water and stream flows.

The mountain pine beetle infestation has wreaked havoc in North America, across forests from the American Southwest to British Columbia and Alberta. Millions of hectares of forest have been lost, with severe economic and ecological impacts from a beetle outbreak ten times larger than previous ones.

Dust from beetle killed wood is believed partially responsible for the explosions at the Lakeland Mill in Prince George and the Babine Forest Products mill in Burns Lake. The explosion in early 2012 at the Babine Forest Products mill killed two workers and injured another twenty. The Lakeland Mill explosion killed two workers and injured twenty four others.

As part of the fight to contain the mountain pine beetle, scientists recently sequenced the pine beetle genome.

Using that genome, Jasmine Janes and colleagues at the University of Alberta, with assistance from the University of British Columbia and the University of Northern British Columbia, used genetics to track how the pine beetle was able to expand its range so rapidly. The study was published in Molecular Biology and Evolution.

Studied at molecular level

While teams of researchers have tracked the path of the pine beetle across BC on the ground, how the beetle spread so easily “is only beginning to be understood at the molecular level,” the study says.

Pine beetles were collected from 27 sites in Alberta and British Columbia. The University of Alberta scientists were especially interested in how the pine beetle was able to jump across the Rockies, something that earlier researchers believed would not happen.

By looking at the genetic markers, the team concluded that the pine beetle may have been able to spread by adjusting its cellular and metabolic functions to better withstand cooler climates and facilitate a larger geographic dispersal area.

In an e-mail to Northwest Coast Energy News, Janes said the research looked at genomic signatures to find out how the beetle had been able to spread into Alberta – where did it come from, what route did it take and how did it overcome the physical and climatic barriers that we had always assumed?

The research discovered that there are two genetically different populations of pine beetles, one from the south of British Columbia and Alberta and one in the north. Another group of pine beetles, found near Valemount, “were harder to classify as being from either north or south genetically. The beetles in this area were showing higher genetic diversity.”

The pine beetle has always been around and killed older trees (called “low quality hosts”), helping to renew the ecosystem. There were also larger five-year infestations that occurred on a 20 to 40 year cycle. The current pine beetle “epidemic” in BC has gone on now for more than 20 years, with the pine beetle “observed in previously unrecorded numbers” over a much wider area

It is generally believed that climate change has help the pine beetle survive milder winters.

The study notes:

Successful establishment of mountain pine beetle on pure jack pine in northern Alberta has raised concerns that the mountain pine beetle will continue to expand its range into the vast boreal forest of jack pine that extends across North America from the Northwest Territories to the Atlantic Coast.

The teams concludes that one group of the beetles originated in southwestern BC perhaps from Whistler or Manning Park. Then the beetles spread north up the west coast of BC toward Houston “with rapid population size increases in central and northern BC and then dispersed long distances with prevailing winds toward the east and Alberta.”

Some of the beetles from southwestern BC appear to have taken a different route, moving more slowly eastward in the south of BC toward Crowsnest Pass area and then moving northward along the base of the Rockies, Janes said, adding. “Our research suggests that these two routes have then met in the middle again, around Valemount and that is why we see the genetic patterns across the landscape that we observed.”

Selective pressure

The second part of the research was answering the question of how the beetles were able to do this. How could they withstand the colder temperatures to spread further north and east?

To answer the scientists used the same genetic markers (single nucleotide polymorphisms) to conduct “selective sweeps” of the beetle genome. The sweeps look for unusual genetic markers that could indicate the beetles are under “selective pressure.”

The study looked at specific functions in the beetle: the genes that govern “actin filaments” that “control muscle contractions like shivering and moving wings”; “the synthesis of cholesterol that provides energy for metabolic activities” and transport of ions across cell membranes.

Normally, female pine beetles can only fly short distances to find a new host tree to lay eggs. They can travel longer distances if they are up in the tree canopy and are then carried by the wind. Stronger pine beetles that can fly longer distances show the threat is likely evolving.

The study concludes that Canadian Mountain Pine Beetle range expansion:

may continue as populations are currently exhibiting signals of selection. These signals suggest ongoing adaptation of metabolic and cellular processes that could potentially allow them to withstand colder temperatures, shift developmental timing and facilitate longer dispersal flights.

Janes said further research is required to fully validate and understand these signatures of selection, but it does suggest that the beetle is adapting and that is why it “may have been able to breach the Rocky Mountains”

Water and trees

Precipitation samples
Colorado scientists collected precipitation samples to determine their unique chemical fingerprints. ( Lindsay Bearup/Colorado School of Mines)
In Colorado alone, the mountain pine beetle has caused the deaths of more than 3.4 million acres of pine trees. The new research findings show the consequences of an obvious observation: Dead trees don’t drink water

The Colorado study asked how all those dead trees are changing stream flow and water quality?

“The unprecedented tree deaths caused by these beetles provided a new approach to estimating the interaction of trees with the water cycle in mountain headwaters like those of the Colorado and Platte Rivers,” said Reed Maxwell a hydrologist at the Colorado School of Mines.

Maxwell and colleagues have published results of their study of beetle effects on stream flows in this week’s issue of the journal Nature Climate Change.

As the trees die, they stop taking up water from the soil, known as transpiration. Transpiration is the process of water movement through a plant and its evaporation from leaves, stems and flowers.

The “unused” water then becomes part of the local groundwater and leads to increased water flows in nearby streams.

“Large-scale tree death due to pine beetles has many negative effects,” says Tom Torgersen of the US National Science Foundation’s Directorate for Geosciences and program director for the NSF’s Water, Sustainability and Climate program.

“This loss of trees increases groundwater flow and water availability, seemingly a positive,” Torgersen says.

“The total effect, however, of the extensive tree death and increased water flow has to be evaluated for how much of an increase, when does such an increase occur, and what’s the water quality of the resulting flow?”

Under normal circumstances, green trees use shallow groundwater in late summer for transpiration.

Red- and gray-phase trees–those affected by beetle infestations–stop transpiring, leading to higher water tables and greater water availability for groundwater flow to streams.

The Colorado study shows that the fraction of late-summer groundwater flows from affected watersheds is about 30 per cent higher after beetles have infested an area, compared with watersheds with less severe beetle attacks.

“Water budget analysis confirms that transpiration loss resulting from beetle kill can account for the increase in groundwater contributions to streams,” write Maxwell and scientists Lindsay Bearup and John McCray of the Colorado School of Mines, and David Clow of the U.S. Geological Survey, in their paper.

Dead trees create changes in water quality

“Using ‘fingerprints’ of different water sources, defined by the sources’ water chemistry, we found that a higher fraction of late-summer stream flow in affected watersheds comes from groundwater rather than surface flows,” says Bearup.

“Increases in stream flow and groundwater levels are very hard to detect because of fluctuations from changes in climate and in topography. Our approach using water chemistry allows us to ‘dissect’ the water in streams and better understand its source.”

With millions of dead trees, adds Maxwell, “we asked: What’s the potential effect if the trees stop using water? Our findings not only identify this change, but quantify how much water trees use.”

An important implication of the research, Bearup says, is that the change can alter water quality.

The new results, she says, help explain earlier work by Colorado School of Mines scientists. “That research found an unexpected spike in carcinogenic disinfection by-products in late summer in water treatment plants.”

Where were those water treatment plants located? In bark beetle-infested watersheds.

 

The TRIA project (a collaboration of researchers at the University of Alberta, University of British Columbia, University of Montreal, University of Northern British Columbia). The TRIA project investigates the physiology, genetics and ecology of all three players in the mountain pine beetle system – the pines (lodgepole and jack pine, and their hybrids), the beetle and the fungus (several types).

The Colorado study is funded by the National Science Foundation’s (NSF) Water, Sustainability and Climate (WSC) Program. WSC is part of NSF’s Science, Engineering and Education for Sustainability initiative.

Rio Tinto donates $19 million Pebble Mine stake to charity: Financial Times

Britain’s Financial Times is reporting that Rio Tinto has donated its stake in Alaska’s controversial Pebble Mine to two Alaska charities, one run by a local First Nation.

Rio Tinto donates Alaska copper mine stake to charities  (registration/subscription required)

Rio Tinto had a 19 per cent stake in Northern Dynasty, a Vancouver-based mining company whose main asset is the Pebble project in Alaska.

The FT reports that Pebble is one of the world’s largest known undeveloped copper resources. The project is mired in disagreement because of concern over its potential effect on salmon stocks.

The FT report says the US Environmental Protection Agency said that it would investigate whether fisheries in the region could be protected. The EPA investigation stops any award of environmental permits for the mine in the meantime, and could lead to a permanent block on the project by the EPA.

According to the report, Rio Tinto said it would donate its shares in Northern Dynasty – worth about $19 million Canadian – to two charitable foundations in Alaska: the Alaska Community Foundation, which funds educational and vocational training, and the Bristol Bay Native Corporation Education Foundation, which supports educational and cultural programmes in the region.

The Pebble Mine would be near rich salmon rivers which flow into Bristol Bay, Alaska. Opponents of the project fear that the giant mine would irreversibly damage salmon stocks for centuries to come.

Related:

Pension funds pressure Rio Tinto to dump out of controversial Alaska Pebble Mine

DFO snubs District of Kitimat Council for a second time

 

Fishing and camping on the Kitimat River
Camping and fishing on the Kitimat River. (Robin Rowland/Northwest Coast Energy News)

Fisheries and Oceans has once again snubbed District of Kitimat Council, by refusing to appear in public before council to answer questions about key issues.

At the Monday, March 10 council meeting, the snub was on the issue of who is responsible for the Kitimat River, facing “increased usage of the riverbank during future construction periods” as well as concerns raised by council earlier over waste left by campers.

In the fall, DFO also refused to appear before council when the department was asked to do so on the issue of Clio Bay remediation.

A report to Council from the District’s Deputy Administrative Officer, Warren Waycheshen, noted that district administration “was recently advised that Fisheries and Oceans are unable to participate in Council meetings, however, they will continue to meet at an operational level to provide information on DFO’s regulatory role.

Waycheshen’s report noted” “District Staff will continue to correspond with Fisheries and Oceans on riverbank camping, and when another operational meeting can be coordinated, Council will be advised of the date and time.”

In other words, DFO officials will continue to meet with district staff and council, in private, but are not accountable to the Kitimat public for their actions, except through what district staff may report to council.

The rest of the report consisted of quotes form the amended Fisheries Act and what appears to be a printout of a DFO Power Point presentation on how it sees its current role.

So now that the federal government appears to have downloaded responsibility to the District, the riverbank ball is now in the hands of Kitimat Council, whether or not the Council actually has jurisdiction.

Councillor Phil Germuth presented a motion asking that District staff prepare a map showing who exactly owns the land along the Kitimat River and what that land is being used for.

In the debate, Councillor Corrine Scott noted, “The first paragraph says Fisheries and Oceans won’t attend a council meeting. Fine, we’ve got that part. But then that’s it. Everything else is about the fisheries protection program and policy statements and all the rest of it. But it doesn’t actually answer the question about any concerns regarding waste left by campers and whether its okay or whether we should be putting in more garbage cans or that sort of thing.

“That’s what I was looking for from a report. What should the setbacks be? Should there be any setbacks. Should there be any camping? Do we have to have a certain number of receptacles for garbage? I just don’t know. I was expecting more than what we got out of this report.”

Councillors Mary Murphy and Mario Feldhoff noted that the District has done reports on how the riverbank is used.

District Planner Daniel Martin told Council that DFO has said the department has “no real concerns’ about people camping on the river “unless they begin to destroy fish habitat.” DFO told Kitimat staff. “If the District has concern about access to the river, then control access to the river.”

“I know that we have a report, it was a very, very good report,” Scott then said. “That’s not what we’re talking about. I was waiting to hear what Fisheries and Oceans has to say, I know what we’ve got and what we’re doing and what is being monitored. I thought motion was to find out from Fisheries and Oceans if there was some kind of other issues we should know about.” Scott noted that if Martin’s statement had been included in the report, she would have been satisfied. “I was waiting to hear what the Department of Fisheries and Oceans had to say.”

Germuth then pointed out that he wanted to know who the landowners are so if Council descies to  control access to the river because, “If we put a gate up on the river, we’re not just controlling access for campers, we’re controlling access for everyone else that wants to go through. I want to know who owns the land, so if we decide to do something, we can chat with landowners.

“We’re not going to get anywhere with DFO,” Feldhoff said. “They’ve been here in the past, and , as I recall, they said they don’t think there is a problem. We may think there’s a problem but they don’t think it’s high enough in terms of priorities. So we might want to reacquaint ourselves with what was going on. There are enough reports to choke a horse, going back at least ten years.”

“Longer that that, I do believe,” Mayor Joanne Monaghan interjected.

Councillor Edwin Empinado agreed with Scott saying, “The response from DFO didn’t really answer the motion [the original question from Council]. Fisheries just gives us the Fisheries Act, their policies, regulations, guidelines, program changes. It doesn’t talk about riverbanks.”

Germuth’s motion was carried unanimously.

 

Two JRP conditions are already outdated, Cullen says

Skeena Bulkley Valley MP Nathan Cullen says at least two of the Northern Gateway Joint Review Panel’s 209 conditions may already be outdated.

In a news release January 15, 2013, Cullen said, “The requirement of $950 million in spill insurance was recently called into question as reports surfaced of cleanup costs at the sites of Enbridge’s 2010 Michigan spill surpassing $1.035 billion.”

The $1.035 billion figure was contained in Enbridge’s American arm, Enbridge Energy Partners, latest filing for the third quarter over 2013 with the US Securities and Exchange Commission.
Cullen went to say that, “The JRP’s order for Enbridge to carry out new research on the behaviour of diluted in bitumen in a marine environment has been questioned following the publication of an Environment Canada study confirming that diluted bitumen will sink in saltwater in high waves and where sediment is present.”

Cullen is referring to a study by Environment Canada Emergencies Science and Technology,Fisheries and Oceans Canada Centre for Offshore Oil, Gas and Energy Research and Natural Resoures Canada on bitumen that was completed in November and released this week.

The study found

. Like conventional crude oil, both diluted bitumen products floated on saltwater (free of sediment), even after evaporation and exposure to light and mixing with water;
. When fine sediments were suspended in the saltwater, high-energy wave action mixed the sediments with the diluted bitumen, causing the mixture to sink or be dispersed as floating tarballs;
(The use of the term “tarball” in this report follows convention in the literature and refers to the consistency of floating, heavily-weathered oil. It does not describe the chemical composition of the product.)
. Under conditions simulating breaking waves, where chemical dispersants have proven effective with conventional crude oils, a commercial chemical dispersant (Corexit 9500) had quite limited effectiveness in dispersing dilbit;
. Application of fine sediments to floating diluted bitumen was not effective in helping to disperse the products;
. The two diluted bitumen products display some of the same behaviours as conventional petroleum products (i.e. fuel oils and conventional crude oils), but also significant differences, notably for the rate and extent of evaporation.

Read the report:Properties, Composition and Marine Spill Behaviour, Fate and Transport of Two Diluted Bitumen Products from the Canadian Oil Sands (pdf)
The Joint Review Panel found that dilbit was “ no more likely to sink to the bottom than other
heavier oils”

The Panel acknowledges the variety of opinions from experts regarding the behavior and fate of oil spilled in aquatic environments. These experts generally agreed that the ultimate behavior and fate of the oil would depend on a number of factors, including the volume of oil spilled, the physical and chemical characteristics of the product, and the environmental conditions at the time.

The Panel finds that likely oil behaviour and potential response options can be predicted from knowledge of the type of oil spilled and its physical and chemical characteristics. Details of oil behaviour and response options cannot be specified until the actual circumstances of a spill are known.

The Panel is of the view that, if placed along a spectrum of: tendency to submerge; persistence; and recovery difficulty, dilbit would be on the higher end of the spectrum, similar to other heavy oil products.

The Panel accepts evidence from previous spills showing that, in response to circumstances at the time, the behaviour of heavier oils, including conventional oils and synthetic crudes, can be dynamic. Some oil floats, some sinks, and some is neutrally buoyant and subject to submergence and overwashing.

Although the project would transport different types of oil, the majority of the evidence presented during the hearing process focussed on whether dilbit is likely to sink when spilled in an aquatic environment. In light of this, the Panel has chosen to focus its views on dilbit. The Panel heard that the fate and behaviour of dilbit has not been studied as much as that of other oils.

Although there is some uncertainty regarding the behavior of dilbit spilled in water, the Panel finds that the weight of evidence indicates that dilbit is no more likely to sink to the bottom than other heavier oils with similar physical and chemical properties.

The Panel finds that dilbit is unlikely to sink due to natural weathering processes alone, within the time frame in which initial, on-water response may occur, or in the absence of sediment or other particulate matter interactions. The Panel finds that a dilbit spill is not likely to sink as a continuous layer that coats the seabed or riverbed.

“It hasn’t even been a month since the JRP released their 209 conditions, and it seems like we’re already seeing some of them become obsolete,” Cullen said.

“Throughout the review process, the JRP continually ignored the situation in Michigan as it unfolded before our eyes. They saw the spill caused by Enbridge’s negligence, which was worsened by Enbridge’s incompetence, and how it brought untold damage to the local ecosystem and cost over $1 billion US. But the 209 conditions didn’t reflect what we learned about Enbridge’s history or its culture, or what we’ve learned about diluted bitumen at all.”

The Joint Review process was set up to deliver a positive verdict, according to Cullen, regardless of what the real life case studies in Michigan had already shown. “To say that it won’t cost as much – if not more – to respond to a spill in a remote corner of northwestern BC during winter than it was in Michigan in the middle of July is ridiculous,” Cullen said.

“What’s even more astonishing is that we asked repeatedly for these studies on the behaviour of diluted bitumen in the marine environment to be part of the Joint Review Panel’s assessment. That the government waited until after the JRP had given its conditional yes to release these findings is not only appalling but also highly suspect.

Cullen says there are two key questions that the Harper government now must answer. “What kind of protection is the government providing when it lowballs on the insurance for oil spills? And what kind of oversight is it giving Canadians when the verdict is given before the evidence is released?”

 

Enbridge’s Michigan cleanup costs now exceed JRP pipeline conditions for Gateway, SEC filing shows

NTSB staff examine ruptured pipe
US National Transportation Safety Board staff examine a ruptured pipe from the Enbridge oil spill in August, 2010. The photo was released by the NTSB May 21, 2012. (NTSB)

The costs for Enbridge to clean up the 2010 Marshall, Michigan oil spill now far exceeds the maximum estimate that the Joint Review Panel gave for a major spill on the Northern Gateway Pipeline and also exceeds the amount of money the JRP ordered Enbridge to set aside to deal with a spill. Enbridge’s cleanup costs have also now edged past the higher liability amount requested by the Haisla Nation.

According to the US firm Enbridge Energy Partners’ filing with the United States Securities and Exchange Commission, as of September 30, 2013, the cost of cleanup was $1.035 billion US, not including possible additional fines and penalties that might be imposed by US authorities in the future.

In its decision, the Joint Review Panel estimated the cost a major oil spill from the Northern Gateway project would be about $693 million.  As part of the 209 conditions, the JRP ordered Enbridge to set aside “financial assurances” totaling $950 million.

Note all costs in this article are for a pipeline breach. The Joint Review Panel had different estimates for a tanker spill and the liability rules for marine traffic are different from pipelines.

In its filing for the third quarter of 2013, with the SEC, Enbridge Energy Partners say that the cost up until September 2013 had “exceed[ed] the limits of our insurance coverage.” The same filing says that Enbridge is in a legal dispute with one its insurers.

In its SEC filing, Enbridge says:

Lakehead Line 6B Crude Oil Release
We continue to perform necessary remediation, restoration and monitoring of the areas affected by the Line 6B crude oil release. All the initiatives we are undertaking in the monitoring and restoration phase are intended to restore the crude oil release area to the satisfaction of the appropriate regulatory authorities.
As of September 30, 2013, our total cost estimate for the Line 6B crude oil release is $1,035.0 million, which is an increase of $215.0 million as compared to December 31, 2012. This total estimate is before insurance recoveries and excluding additional fines and penalties which may be imposed by federal, state and local governmental agencies, other than the Pipeline and Hazardous Materials Safety Administration, or PHMSA, civil penalty of $3.7 million, we paid during the third quarter of 2012. On March 14, 2013, we received an order from the EPA, or the Environmental Protection Agency, which we refer to as the Order, that defined the scope which requires additional containment and active recovery of submerged oil relating to the Line 6B crude oil release. We submitted our initial proposed work plan required by the EPA on April 4, 2013, and we resubmitted the workplan on April 23, 2013. The EPA approved the Submerged Oil Recovery and Assessment workplan, or SORA, with modifications on May 8, 2013. We incorporated the modification and submitted an approved SORA on May 13, 2013. The Order states that the work must be completed by December 31, 2013.

The $175.0 million increase in the total cost estimate during the three month period ending March 31, 2013, was attributable to additional work required by the Order. The $40.0 million increase during the three month period ending June 30, 2013 was attributable to further refinement and definition of the additional dredging scope per the Order and associated environmental, permitting, waste removal and other related costs. The actual costs incurred may differ from the foregoing estimate as we complete the work plan with the EPA related to the Order and work with other regulatory agencies to assure that our work plan complies with their requirements. Any such incremental costs will not be recovered under our insurance policies as our costs for the incident at September 30, 2013 exceeded the limits of our insurance coverage.

According to the SEC filing, the breakdown of costs include $2.6 million paid to owners of homes adversely impacted by the spill.

Despite the efforts we have made to ensure the reasonableness of our estimates, changes to the recorded amounts associated with this release are possible as more reliable information becomes available. We continue to have the potential of incurring additional costs in connection with this crude oil release due to variations in any or all of the categories described above, including modified or revised requirements from regulatory agencies in addition to fines and penalties as well as expenditures associated with litigation and settlement of claims.
The material components underlying our total estimated loss for the cleanup, remediation and restoration associated with the Line 6B crude oil release include the following:
(in millions)

Response Personnel & Equipment  $454

Environmental Consultants  $193

Professional, regulatory and other $388

Total $ 1,035

For the nine month periods ended September 30, 2013 and 2012, we made payments of $62.3 million and $120.9 million, respectively, for costs associated with the Line 6B crude oil release. For the nine month period ended September 30, 2013, we recognized a $2.6 million impairment for homes purchased due to the Line 6B crude oil release which is included in the “Environmental costs, net of recoveries” on our consolidated statements of income. As of September 30, 2013 and December 31, 2012, we had a remaining estimated liability of $265.9 million and $115.8 million, respectively.

As for insurance, Enbridge Energy Partners say:

The claims for the crude oil release for Line 6B are covered by the insurance policy that expired on April 30, 2011, which had an aggregate limit of $650.0 million for pollution liability. Based on our remediation spending through September 30, 2013, we have exceeded the limits of coverage under this insurance policy. During the third quarter 2013, we received $42.0 million of insurance recoveries for a claim we filed in connection with the Line 6B crude oil release and recognized as a reduction to environmental cost in the second quarter of 2013. We recognized $170.0 million of insurance recoveries as reductions to “Environmental costs, net of recoveries” in our consolidated statements of income for the three and nine month periods ended September 30, 2012 for the Line 6B crude oil release. As of September 30, 2013, we have recorded total insurance recoveries of $547.0 million for the Line 6B crude oil release, out of the $650.0 million aggregate limit. We expect to record receivables for additional amounts we claim for recovery pursuant to our insurance policies during the period that we deem realization of the claim for recovery to be probable.

In March 2013, we and Enbridge filed a lawsuit against the insurers of our remaining $145.0 million coverage, as one particular insurer is disputing our recovery eligibility for costs related to our claim on the Line 6B crude oil release and the other remaining insurers assert that their payment is predicated on the outcome of our recovery with that insurer. We received a partial recovery payment of $42.0 million from the other remaining insurers and have since amended our lawsuit, such that it now includes only one insurer. While we believe that our claims for the remaining $103.0 million are covered under the policy, there can be no assurance that we will prevail in this lawsuit.

 

The Joint Review, Enbridge and Michigan

The Joint Review Panel based its finding on the Marshall, Michigan spill on the figure of $767 million from the summer of 2012 –again showing the limitations of the JRP’s evidentiary deadlines since the costs are now much higher.

The JRP quoted Enbridge as saying:

Northern Gateway considered the high costs of the Marshall, Michigan spill, which were at least $252,000 per cubic metre ($40,000 per barrel), to be an outlier or a rare event because the spill occurred in a densely populated area, because the pipeline’s response time was abnormally long, and because there was the prospect of potentially lengthy legal proceedings.

Enbridge assured the JRP that the corporate culture and management changes and equipment upgrades since the Marshall, Michigan spill lowered that chances of a similar event.

The company based its models for the JRP on much smaller spills, including one spill at Lake Wabamun, Alberta from a train not a pipeline (Vol. 2 p 357)

Enbridge’s risk assessment did not “generate an estimate of economic losses caused
by a spill.”

The JRP says Northern Gateway relied on its analysis of literature, and spill events experienced by Enbridge and other liquid hydrocarbon carriers in Alberta and British Columbia. After assessing all of this information, Northern Gateway regarded the high costs of a cleanup as “conservative”–meaning the company expects costs to be lower than its estimates in evidence before the JRP.

In Northern Gateway’s view the most costly pipeline spill incident would be a full-bore oil pipeline rupture, with an estimated cost of $200 million, and an extremely low probability of occurrence.

Haisla evidence

In their evidence, the Haisla (and other First Nations and intervenors) were doubtful about Northern Gateway’s assurances. The Haisla asked that Enbridge have a minimum of $1 billion in liability, an amount Enbridge has now exceeded in Michigan.

Haisla Nation estimated the cost of damage to ecosystem services because of a terrestrial oil spill from Northern Gateway’s pipeline would be in the range of $12,000 to $610 million for a 30-year period.

The Haisla’s cost estimates were based on values for environmental goods and services and probabilities of spills that were independent of Northern Gateway’s parameters for estimating oil spill costs. In contrast to Northern Gateway’s estimated spill frequency and costs, the Haisla predicted that spills would occur more often and placed a higher value on damages to environmental goods and services.

Haisla Nation argued that Northern Gateway overestimated its ability to detect and respond to a spill. In the Haisla’s view this resulted in the cost of a spill and the requisite financial assurances being understated. Haisla cited several factors, including: remote location, limited access, challenging terrain, seasonal conditions, and river flow conditions that would cause the cost of cleaning up a spill in the Kitimat River valley to be significantly greater than the costs associated with Enbridge’s Marshall, Michigan spill.

For these reasons, Haisla proposed that Northern Gateway should be required to obtain a minimum of $1 billion of liability coverage through insurance and financial assurances. Haisla said that Northern Gateway should file annually the report from an independent third party assessing the financial assurances plan. (Vol 2 p359)

In response Northern Gateway said:

Northern Gateway said that Haisla’s findings were based on a number of fundamental methodological flaws and a lack of probability analysis to support the high frequency of occurrence of oil spill events. Northern Gateway argued that Haisla’s estimates of ecosystem service values were inflated because they were based on values from unrelated studies. In Northern Gateway’s view, Haisla relied on high passive use values that were not justified.

JRP ruling

As it has in most of its decision, the JRP accepted Northern Gateway’s evidence, including its explanation of the Marshall, Michigan spill and then went on to base its spill cost estimates not on a pipeline breach but on the 2005 railway spill at Lake Wabumum, near White Sands, Alberta.

The Panel accepts that the cleanup costs for the Marshall, Michigan spill were orders of magnitude higher because of the extended response time. In this application, the Panel accepts Northern Gateway’s commitment to complete the shutdown in no more than 13 minutes after detection. For this reason the Panel did not use the Marshall spill costs in its calculations. The spill volume and the resulting costs are directly dependent on the Northern Gateway’s control room staff and the pipeline control system fully closing the adjacent block valves no longer than 13 minutes from the detection of an alarm event, as well as the amount of oil which would drain out of the pipeline after valve closure due to elevation differences.

The Panel decided on a total unit cost of $138,376 per cubic metre ($22,000 per barrel). This is midway between the unit cost of $88,058 per cubic metre ($14,000) per barrel proposed by Northern Gateway and the unit cost of $188,694 per cubic metre ($30,000 per barrel) for the Lake Wabamun spill. It is about one-half of the Marshall spill’s unit cost. Giving weight to the Lake Wabamun costs recognizes actual costs experienced in a Canadian spill and the greater costs of spills in high consequence areas. In these areas, individuals, populations, property, and the environment would have a high sensitivity to hydrocarbon spills. The deleterious effects of the spill would increase with the spill volume, the extent of the spill, and the difficulty in accessing the spill area for cleanup and remediation.

Using these spill volume and unit cost values in the calculation below, the Panel estimated the total cost of a large spill could be $700 million. Total cost of a spill = 31,500 barrels x $22,000 per barrel = $693 million, or $700 million when rounded up.

(p362)

The Panel based the financial assurances requirements for Northern Gateway on a spill with a total estimated cost of $700 million and directs Northern Gateway to develop a financial assurances plan with a total coverage of $950 million that would include the following components:
i. Ready cash of $100 million to cover the initial costs of a spill;
ii. Core coverage of $600 million that is made up of stand-alone, third party liability insurance and other appropriate financial assurance instruments, and
iii. Financial backstopping via parental, other third party guarantees, or no fault insurance of at least $250 million to cover costs that exceed the payout of components i. and ii.
The financial backstopping would be available to fill the gap if the spill volumes or unit costs were under-estimated or if the payout from the core coverage would be less than 100 per cent.

The Panel noted that:

The evidence indicates that there is some probability that a large oil spill may occur at some time over the life of the project. In these circumstances the Panel must take a careful and precautionary approach because of the high consequences of a large spill. The Panel has decided that Northern Gateway must arrange and maintain sufficient financial assurances to cover potential risks and liabilities related to large oil spills during the operating life of the project.

Northern Gateway committed to investing $500 million in additional facilities and mitigation measures such as thicker wall pipe, more block valves, more in-line inspections, and complementary leak detection systems. This initiative should enhance the safety and reliability of the system and help reduce and mitigate the effects of a spill, but it would not eliminate the risk or costs of spills. This initiative is not a direct substitute for third party liability insurance and does not eliminate the need for liability insurance or any other form of financial assurance to cover the cost of a spill. (p 361)

So the JRP decision comes down to this, if you accept Northern Gateway’s position that pipeline spills are rare and mostly small, then the company has the financial resources to cover the damage. If, however, Northern Gateway is wrong and the costs of a pipeline cleanup exceed the $950 million required by the Joint Review Panel, as has happened in Michigan, then those JRP conditions are already obsolete.

(Northwest Coast Energy News encourages all readers to read the complete JRP report  and SEC filing since space and readability does not permit fully quoting from the report)

Enbridge misses deadline to clean up Michigan’s Morrow Lake; EPA cites reluctance to do winter cleanup

EPA map of Kalamazoo River
EPA map of river closures and dredging operations on the Kalamazoo River during 2013. (EPA)

Enbridge has missed the US Environmental Protection Agency’s deadline to clean up parts of the Marshall, Michigan bitumen spill by December 31, 2013.

Local television news, WOOD-TV says the EPA is now considering “enforcement options.”
The EPA had already granted Enbridge a 10 month extension that the company requested in March, 2013, setting the new December deadline.

In November, Enbridge requested a second extension. The EPA denied that request.

From the EPA letter it appears that, as in previous years, Enbridge is trying to avoid continuing clean up work into the winter. The EPA rejects that position, telling Enbridge it shouldn’t wait until the spring run off could spread the sunken bitumen.

The EPA says that beginning in March, 2013, “Enbridge has successfully removed oil and sediment from two of the three major impoundment areas identified in the order and from several smaller sediment trap locations.”

The area that Enbridge failed to clean up is known as the Morrow Lake and Morrow Lake Delta. The cleanup in that area was delayed when the Comstock Township planning commission unanimously  denied Enbridge a permit for “dredge pad” after fierce public opposition

The letter to Enbridge, from Jeffrey Kimble, Federal On-Scene Coordinator denying the extension is another scathing indictment of Enbridge’s attitude toward the public and the cleanup, citing Enbridge failing to prepare “adequate contingency plans,” by failing to recognize the “serious opposition” the dredging plans.

Although the EPA had told Enbridge to consider alternative plans—and Enbridge claimed it did that—the EPA found the Enbridge’s own logs showed the company didn’t start considering alternatives until it was obvious that Comstock Township would reject their dredging plans.

The EPA letter also reveals that once again Enbridge is reluctant to do further cleanup work during the Michigan winter. The EPA rejects that stance, saying that “Removal of oiled sediments prior to the spring thaw will lessen the potential oiled sediment transport in the spring to Morrow Lake via increased river velocities from rain and ice melt.”

Although we recognize that the work required by the Order is unlikely to be completed by December 31, 2013, U.S. EPA believes that had Enbridge taken appropriate steps earlier as requested, it would not require an extension now. In particular, U.S. EPA believes that Enbridge has continuously failed to prepare adequate contingency plans for a project of this nature. For example, U.S. EPA acknowledges that failure to obtain a site plan approval for use of the CCP property for a dredge pad was a setback in the timely completion of the work in the Delta.

However, Enbridge failed to prepare any contingency plans recognizing the possibility of such an occurrence. Enbridge has known since at least the middle of July 2013 that there was serious opposition to its proposed use of the CCP property. When it became clear in August 2013 that opposition to the site use might delay the project, U.S. EPA directed Enbridge to “conduct a more detailed review of your options in short order.”

Although your letter claims that Enbridge “has considered such alternatives,” your logs indicate that Enbridge did not hold initial discussions with the majority of these property owners until long after the final decision to abandon plans for use of the CCP property. These contact logs do not demonstrate that Enbridge fully explored and reviewed alternative options in a timely manner so as to avoid delay in completion of the work. Although Enbridge claims that use of identified alternative properties would be denied by Comstock Township, Enbridge did not present any site plans to the Township for approval (other than use of the county park for staging of frac tanks). To the extent that any of Enbridge’s contingency plans include the use of land for dredge pads, U.S. EPA believes that Enbridge should begin multiple submissions for property use until one is accepted….

Enbridge claims that it cannot install winter containment in the Delta to prevent the potential migration of sediments to the lake. To support that claim, Enbridge has attached a letter from STS directing Enbridge to remove anchors and associated soft containment during winter monthsas these structures could damage STS’s turbines. However, none of the correspondence provided by Enbridge discusses the use of more secure containment methods, such as metal sheet piling, which may not pose the same risks as soft containment structures. Enbridge should consider using sheet piling to construct cells which would both allow winter work and contain the sediment during that work. Enbridge should therefore try to obtain access from STS for this specific work, and for other appropriate work, for the winter timeframe. Use of sheet pile cells would allow continued operations during the winter, especially in the southern zone of the Delta outside of the main river channel. Removal of oiled sediments prior to the spring thaw will lessen the potential oiled sediment transport in the spring to Morrow Lake via increased river
velocities from rain and ice melt.

Finally, U.S. EPA is unwilling to allow Enbridge to wait until after the likely spring high
velocity river flush to reinstall the E-4 containment structures. U.S. EPA has reviewed Enbridge’s modeling, which Enbridge claims supports its requested timeline, and has found it incomplete. The model has not incorporated, and does not match, field observation of flow velocities and water levels and their potential to impact upstream critical structures if containment is in place. Moreover, U.S. EPA completely disagrees with Enbridge’s assertion that there is no evidence of migration of submerged oil during high flow events. The results of three years of poling and sheen tracking demonstrate that Line 6B oil is mobile during periods of
high flow. Now that Enbridge has a five year permit from MDEQ for the E-4 containment system, U.S. EPA reiterates that this containment must be in place immediately upon thawconditions in the spring….

Although Enbridge’s proposed two phase approach may have components that can be incorporated into a final plan, it should not be considered the approved way forward. U.S. EPA believes that pausing the work cycle until new poling can be done in June or July of 2014 could again result in a wasted construction season in the Delta. Enbridge should consider and utilize a combination of techniques in the plan. For example, several dredge pad sites have been identified by Enbridge. Enbridge should obtain approval for one of these sites, or a combination of smaller sites, so as to support hydraulic dredging in conjunction with the current approved
approach and any potential dry excavation techniques. Enbridge should also consider other winter work techniques, such as cell build out and dewatering in the Delta via sheet piling.

As always, U.S. EPA will continue to work with Enbridge to develop adequate plans and complete the work required by the Order. However, nothing in this letter excuses any noncompliance with the Order nor does it serve as the granting of any extension to any deadline in the Order. U.S. EPA reserves all its rights to pursue an enforcement action for any noncompliance with the Order.

The EPA letter also calls into question the ruling of the Joint Review Panel on the Enbridge Northern Gateway. The JRP accepts, without question, Enbridge’s assurances that the company has changed its attitude and policies since the long delay in 2010 in detecting the pipeline rupture in Marshall, Michigan.

The JRP, on the other hand, accepts, without question, Enbridge’s assurances that it has expertise in winter oil recovery from a pipeline spill.

Parties questioned Northern Gateway about locating and recovering oil under ice. Northern Gateway said that Enbridge conducts emergency exercises in winter and that Northern Gateway would learn from those experiences.
Northern Gateway outlined a number of oil detection techniques including visual assessment (at ice cracks and along the banks), drills, probes, aircraft, sniffer dogs, and trajectory modelling. It said that, once located, oil would be recovered by cutting slots into the ice and using booms, skimmers, and pump systems to capture oil travelling under the ice surface.

The company said that oil stranded under ice or along banks would be recovered as the ice started to melt and break up. It discussed examples of winter oil recovery operations during Enbridge’s Marshall, Michigan incident, and said that operational recovery decisions would be made by the Unified Command according to the circumstances.

Northern Gateway said that equipment caches would be pre-positioned at strategic locations, such as the west portal of the Hoult tunnel. It said that decisions regarding the location or use of pre-positioned equipment caches would be made during detailed design and planning, based on a number of considerations including, but not limited to, probability of a spill, access, site security,
environmental sensitivities, and potential for oil recovery at the response site.

(vol 2 page 153)

In its ruling, the Joint Review Panel said

The Panel finds that Northern Gateway’s extensive evidence regarding oil spill modelling, prevention, planning, and response was adequately tested during the proceeding, and was credible and sufficient for this stage in the regulatory process.
Parties such as the Province of British Columbia, Gitxaala Nation, Haisla Nation, and Coalition argued that Northern Gateway had not provided enough information to inform the Panel about proposed emergency preparedness and response planning. The Panel does not share this view.

Northern Gateway and other parties have provided sufficient information to inform the Panel’s views and requirements regarding malfunctions, accidents, and emergency preparedness and response planning at this stage of the regulatory process.

Many parties said that Northern Gateway had not demonstrated that its spill response would be “effective.” Various parties had differing views as to what an effective spill response would entail.

The Panel is of the view that an effective response would include stopping or containing the source of the spill, reducing harm to the natural and socio-economic environment to the greatest extent possible through timely response actions, and appropriate follow-up and monitoring and long-term cleanup. Based on the evidence, in the Panel’s view, adequate preparation and planning can lead to an effective response, but the ultimate success of the response would not be fully known
until the time of the spill event due to the many factors which could inhibit the effectiveness of the response. The Panel finds that Northern Gateway is being proactive in its planning and preparation for effective spill response….

The Panel is of the view that an effective response does not guarantee recovery of all spilled oil, and that that no such guarantee could be provided, particularly in the event of a large terrestrial, freshwater, or marine spill.

The oil spill preparedness and response commitments made by Northern Gateway cannot ensure recovery of the majority of oil from a large spill. Recovery of the majority of spilled oil may be possible under some conditions, but experience indicates that oil recovery may be very low due to factors such as weather conditions, difficult access, and sub-optimal response time, particularly for large marine spills. …

To verify compliance with Northern Gateway’s commitments regarding emergency preparedness and response, and to demonstrate that Northern Gateway has developed appropriate site-specific emergency preparedness and response measures, the Panel requires Northern Gateway to demonstrate
that it is able to appropriately respond to an emergency for each 10-kilometre-long segment of the pipeline.

The Panel notes the concerns of intervenors regarding Northern Gateway’s ability to respond efficiently and effectively to incidents in remote areas, and its plan to consider this during detailed design and planning. The Panel finds that Northern Gateway’s commitment to respond immediately to all spills and to incorporate response time targets within its spill response planning is sufficient to
address these concerns. Northern Gateway said that its emergency response plans would incorporate a target of 6 to 12 hours for internal resources to arrive at the site of a spill. It also said that it would target a response time of 2 to 4 hours at certain river control points.

The Panel agrees with Northern Gateway and several intervenors that access to remote areas for emergency response and severe environmental conditions pose substantial challenges. The Panel notes that the company has committed to develop detailed access management plans and to evaluate contingencies where timely ground or air access is not available due to weather, snow, or other logistic
or safety issues.

Despite the EPA letter (which admittedly was released long after the JRP evidentiary deadline) that shows that Enbridge did not consult the people of Comstock Township, Michigan, the JRP says

The Panel accepts Northern Gateway’s commitment to consult with communities, Aboriginal groups, and regulatory authorities. The objective of this consultation is to refine its emergency preparedness and response procedures by gaining local knowledge of the challenges that would be present in different locations at different times of the year
(Vol 2 p 165-167)

EPA letter to Enbridge denying deadline extension  (pdf)

How Gateway’s plans to dredge Douglas Channel show the limitations of the JRP mandate and ruling

(First in series of reports on how the Joint Review Panel report will affect the Kitimat region)

JRP map of blasting on Douglas Channel
Joint Review map of Northern Gateway plans for dredging and blasting on Douglas Channel (JRP)

 

If there is a significant flaw in the Joint Review Panel report on Northern Gateway, it can be found in the panel’s analysis of Enbridge Northern Gateway’s plans to blast and dredge at the proposed Kitimat terminal site.

While the Joint Review Panel does consider what it calls “cumulative effects,” the panel plays down those effects and offers no specifics about interaction between the Northern Gateway project and the two liquified natural gas projects, the KM LNG project at Bish Cove and the BC LNG floating terminal at the old log dump.

It appears the JRP considered the legacy effects of the Rio Tinto Alcan smelter and other Kitimat industries while not taking into consideration future development.

The dredging and blasting planned by Northern Gateway, as Enbridge said in its evidence,  appears to have only a minimal effect on Douglas Channel.

A glance at the map in the Joint Review ruling shows that that the dredging and blasting site is directly opposite Clio Bay, where Chevron, in partnership with the Haisla Nation, plan a remediation project using marine clay from the Bish Cove construction site to cap decades of sunken and rotting logs.

The Clio Bay project was not part of the evidence before the Joint Review Panel, the plans for the project were not formulated until well after the time for evidence before the JRP closed. But those deadlines show one area where the rules of evidence and procedure fail the people of northwestern BC.

The JRP is a snapshot in time and changes in the dynamics of the industrial development in the Kitimat Arm are not really considered beyond the terms of reference for the JRP.

It appears from the report that Enbridge plans to simply allow sediment from the blasting and dredging to float down Douglas Channel, dispersed by the currents and the outflow from the Kitimat River.

Northern Gateway said that dredging and blasting for marine terminal construction would result in a sediment plume that would extend over an area of 70,000 square metres for the duration of blasting activities.

Approximately 400 square metres of the assessed area of the marine terminal is expected to receive more than 1 centimetre of sediment deposition due to dredging. Outside of this area, typical sediment deposition levels alongshore where sediment is widely dispersed (a band approximately 4 kilometres long and 400 metres wide) are very low; in the range of 0.001 to 0.1 centimetres. Dredging and blasting activities are expected to occur over a period of approximately 18 weeks.

Northern Gateway expected most of the sediment plume created by construction activities to be minor in relation to natural background levels.

Northern Gateway would use bubble curtains to reduce pressure and acoustic effects of blasting, and silt curtains to reduce the effect of sedimentation from dredging. It said that bubble curtains are used extensively for other activities, such as pile driving, to reduce the effect of high pressure pulses that can cause injury to fish.

It added that bubble curtains have been tested extensively with blasts, and literature shows they are effective.

Northern Gateway said that physical effects from suspended sediment on marine fish and invertebrates could include abrasion and clogging of filtration mechanisms, which can interfere with ingestion and respiration. In extreme cases, effects could include smothering, burial, and mortality to fish and invertebrates. Direct chemical-related effects of suspended sediment on organisms, including reduced growth and survival, can also occur as a result of the uptake of contaminants
re-suspended by project construction activities, such as dredging and blasting, and as a result ofstorm events, tides, and currents.

The Haisla Nation and Raincoast Conservation objected to Northern Gateway’s figures, noting

Northern Gateway’s sediment and circulation model and its evidence related to contaminated sediment re-suspension at the terminal site. Both parties said that the sediment model was applied for the spring, when the increase in total suspended solids would be negligible compared to background values. In the event of delays, blasting and dredging would likely occur at other times of the year when effects would likely be higher, and these scenarios were not modelled.

The panel’s assessment of the area to be blasted found few species:

Species diversity within Kitimat Arm’s rocky intertidal community is generally low. Barnacles, mussels, periwinkles, and limpets can be found on rocky substrate. Sea urchins, moon snails, sea anemones, sea stars, and sea cucumbers are in shallow subtidal areas. Sandy areas are inhabited by commercially-harvested bivalves such as butter clams and cockles.

Northern Gateway told the JRP that it would “offset” any damage to Douglas Channel caused by the blasting and dredging

Northern Gateway said that construction, operations, and decommissioning of the marine terminal would result in both permanent and temporary alteration of marine fish habitat. Dredging and blasting, and installing physical structures in the water column for the marine terminal would permanently alter marine fish habitat. Based on the current terminal design, in-water site preparation would result in the physical alteration of approximately 1.6 hectares of subtidal marine habitat and 0.38 hectares of intertidal marine habitat. Northern Gateway expected approximately 353 square metres of subtidal marine habitat and 29 square metres of intertidal habitat to be permanently lost.This habitat would be compensated for by marine habitat offsets.

The project’s in-water vertical structures that would support the mooring and berthing structures could create new habitat, offsetting potential adverse effects. The structures may act as artificial reefs, providing marine fish habitat, food, and protection from predation. Although organisms currently inhabiting the work area would be killed, the exposed bedrock would be available for colonization as soon as the physical works are completed.

In its finding on marine sediment, the panel, as it does throughout the ruling, believes that the disruption to the environment caused by previous and ongoing human activity, means that the Northern Gateway Kitimat terminal won’t make that much difference.

Sediment quality in the marine environment is important because sediment provides habitat for benthic aquatic organisms. Northern Gateway’s baseline data for the area immediately surrounding the marine terminal indicated some contamination of water, sediments, and benthic organisms from previous industrial activity. Industrial activities in the Kitimat area have released contaminants through air emissions and effluent discharges since the 1960s. Sources of contaminants to Kitimat Arm
include effluent from a municipal wastewater treatment plant, the Alcan smelter, Methanex Corporation’s methanol plant, and the Eurocan pulpmill, as well as storm water runoff from these operations and the municipality.

Area is largely controlled by natural outflow from the Kitimat River with suspended sediment levels being highest during peak river runoff (May to July, and October) and lowest during winter. Storm events, tides, and currents can also suspend sediments. Levels of total suspended solids fluctuate seasonally and in response to climatic variations, but are generally highest during the summer.

Commercial and recreational vessels currently operating in the area may increase suspended solids by creating water turbulence that disturbs sediments. Given the current sediment contamination levels and the limited area over which sedimentation from construction activities would be expected to disperse, the Panel finds that the risk posed by disturbed contaminated sediment is low. Northern Gateway has committed to monitoring during construction to verify the predicted effects on sediment and water quality for both contaminants and total suspended solids..

The dredging and blasting section of the Joint Review Report is small when compared to the much more extensive sections on pipeline construction and tanker traffic, and the possible effects of a catastrophic oil spill.

Although minor, the marine sediment section exposes the question that was never asked, given the disruptions from years of log dumping at Clio Bay and Minette Bay and the decades of  developments at the mouth of the Kitimat River, and future development from LNG, when do cumulative effects begin to overwhelm? How much is enough? How much is too much? If every project continues to be viewed in isolation, what will be left when every project is up and running?