Turning the Tables on Northern Gateway

The best way to deep six the Enbridge Northern Gateway project currently undergoing federal environmental assessment is to focus on Table 8-8 of the Marine Shipping Quantitative Risk Analysis filed by Enbridge as part of its application currently before the NEB and CEAA. Within that Table there is one mitigated risk statistic that is so damning that it could stop the project in its tracks. That statistic claims that the return period for a spill greater than 5000 cubic metres is 550 years. Sounds innocuous enough- right? Not so fast, Buckwheat! Leaving aside the question as to what on earth a ‘return period’ is, it turns out that the statistic in question translates into somewhere between an 8.7 and 14.1% chance of one or more spills greater than 31,500 barrels of oil occurring over the fifty year lifespan of the project. If the pipeline capacity is 525,000 barrels per day, then the chance is 8.7%. If, on the other hand, as one suspects, the pipeline will instead be built to its maximum, expanded capacity of 850,000 barrels per day from the outset, then 14.1% is the magic number. Now, Enbridge does not classify tanker spills according to whether they are small, medium or large. However, the International Tanker Owners Pollution Federation (ITOPF) does, for statistical purposes, and it is noteworthy that they classify a large spill as being anything over 700 tonnes, or approximately 5131 barrels. In other words, by international standards a 31,500 barrel spill is a large spill indeed- roughly six times larger, in fact, than ITOPF's threshold for what constitutes a large spill. And with up to a 14.1% chance of at least one spill of this magnitude occurring from a Northern Gateway tanker, this project is little more than a game of Russian Roulette.

Why, one might ask, is this particular statistic so important? The answer is because the Joint Review Panel’s recommendation as to whether Northern Gateway should proceed is likely to turn on risk; all other considerations, however important they may be, are secondary. Also, as the saying goes, a chain is only as strong as its weakest link. Thus, if it can be shown that one of three components of the project- the marine transportation component ( the other two being the pipeline and the marine terminal ), is too risky, then standard environmental practice dictates that the project should not proceed. To be more precise, if a proposed project could have significant adverse environmental effects, then it should not move forward- period, whatever the anticipated benefits! And who would doubt that a marine oil spill somewhere within the Project Area involving 31,500 barrels of oil could have significant adverse environmental effects? A spill of that magnitude could actually have catastrophic and irreversible effects, especially if it were to occur during the winter, say, in the middle of Hecate Strait, when cleanup would be next to impossible most of the time, and where wind and waves could whip the oil around, impacting hundreds if not thousands of miles of coastline in the aftermath of an incident.

Thus, a winning strategy for those opposed to the project on environmental grounds would be to cross-examine Enbridge on this particular point during the Questioning phase of the Hearings currently underway in Prince Rupert. The beauty of this approach is that it does not require the introduction of new evidence on the part of Intervenors in opposition to Northern Gateway. On the contrary, it relies on Northern Gateway’s own evidence, merely showing it in a different light. And for the record, the author has already drawn this particular risk calculation to the Joint Review Panel’s attention, first in his August 28, 2012 Letter of Comment, and more recently in his January 7, 2013 Oral Statement to the Panel in the course of the Community Hearings in Victoria. Furthermore, at least two other people who made Oral Statements at the Community Hearings quoted this statistic from the author’s Victoria presentation, one in Vancouver and one in Kelowna. But not only is the Panel fully aware of this statistic; the proponent itself had one or more representatives present at the Community Hearings.

So, anyone who does challenge Northern Gateway on this risk calculation during cross-examination in Prince Rupert is free to cite the statistical calculation the author came up with through persistent digging. If you do mention it, feel free to cite this Letter of Comment, as well as this Oral Statement. If the Panel itself had any credibility, it would have already asked Northern Gateway for its views on this statistical interpretation, just as it has on other points and statistics raised during the Hearings. Northern Gateway should be asked, for example, whether they consider a 14.1% chance of what by any standards would be a major oil spill occurring as a result of tanker shipments represents an acceptable level of risk, from their standpoint. And the Panel itself has little choice but to pass judgment on the same statistical probability in its Final Report, due by the end of 2013. Ditto for the Government of Canada, which will make the ultimate decision as to whether this project should proceed, unless of course the proponent itself sees the light and walks away from it, approval or no approval.

Lastly, Intervenors in opposition to Northern Gateway should get the Panel to require the Applicant to calculate the chances of spills for each of ITOPF's three spill size categories:

-Small spills less than 7 tonnes (≈10 m3);

-Medium spills of 7 to 700 tonnes (≈10 to 1,000 m3);

-Large spills greater than 700 tonnes.

For the record, the author's recent critique of the Enbridge Northern Gateway proposal is the subject of several press articles, including these two in particular:

1) “Tankers too risky on B.C.’s North Coast, oil-spill consultant says”, Larry Pynn, Vancouver Sun, January 12, 2013;

2) “A significant risk”, Leslie Campbell, Focus, February, 2013, pp. 4,5.