Environmental Assessment Office

February 1, 2012

Dear Judy, here are my thoughts, my address my phone # and permission to publish my comments and my name. 
Hope it works out. And yes faxing it to Victoria sounds great. Thank you... and sweetest dreams.

The proposal of VAFFC to ship jet fuel into any arm of the Fraser River is an Environmental RISK! It is a hazard to any creature living nearby those storage tanks!  Yes, It is a serious life-threatening Environmental risk. And, whoever has a hand in implementing the shipping of jet fuel into the Fraser River is morally responsible for any environmental chaos caused by their poisonous decision. God’s Blessing to our air,  our land, and to our water. 

Love, 
“Empress” Leila

This is what happens when aviation grade kerosene (Jet-A) spills into the waterways and land.
"Kerosene 4000' upstream from water plant intake. Versar states at 180 ppb kerosene people won't drink water because of bad taste".

On-Scene Coordinator's Report: Battle of Bull Run, Manassas, VA., March, 1980, Major Pollution Incident 

http://nepis.epa.gov/Exe/ZyPURL.cgi?Dockey=9100CIY1.txt 
accessed 1 Feb 2012

VAFFC seems to have complete disregard for the for the value of the Fraser River fishery commercially and to aboriginal heritage; the safety residential community where the proposed project site would be.

VAFFC has not done a detailed analysis to safer, more environmental responsible options to Cherry point.

This project must be stopped!!

Thank you for opportunity to express my comments.

David Russell - Abbotsford, British Columbia

I am a carpenter working for the company that upgraded the Jet Fuel tank   farm at YVR. With the amount of air traffic increasing every year, this upgrade was essential. It was also a much needed boost to a great many trades persons and companies.  There were welders, pipe fitters, carpenters, cement masons, boiler makers, electricians, etc.  Many apprentices in all these trades received valuable experience.  WS Nicholls commitment to the protection of the environment has been proven in the quality of the work that was done and has been done over many years working with fuel systems.  In all my years, I have never known a company that goes the extra mile like they do.  Currently, 40 trucks a day fill the existing tank farm.  When the new tank farm comes online, that will likely increase to 100 plus trucks a day clogging our roads.  Which will be safer, a well-built safe loading facility with a short pipe line buried deep underground to the airport, or 100+ jet fuel laden trucks towing trailers hoping they don't get cut-off or have to jam on the brakes to avoid a collision?  Either way, the fuel will have to come.  The current pipe line from Burnaby would have to be replaced.  It is very old and can't handle the volume that would be needed.  They would need to twin over 41 kms of line verses a short 14 km line that would be brand-spanking new, with all new safety protocols in place.  This would represent years of more work for trades people and millions of dollars pumped into the local economy.  Safey and the environment would definitely be a top priority for the builders and operators.  It is my wish that we consider carefully, the costs and risks of not adopting this very sound proposal.  Thank you very much. 

I am adamantly opposed to Vancouver Airport Fuel Facilities Corporation (VAFFC)  Environmental Assessment Certificate Application for the Vancouver Airport Fuel Delivery Project.

The Fraser river has been designated a Canadian Heritage River for its natural and human heritage to consider sailing Panamax tankers and barges laden with toxic and flammable jet fuel into the estuary, and the construction of  both the Marine Terminal and 80 Million Litre Tank Farm at the Rivers edge is just plain foolhardy, more than 70 fish species inhabit this River.  The Estuary is also home to the Reifiel National Migratory Bird Sanctuary (over 333 species), Alaksen National Wildlife Area, plus the Sturgeon Bank and South Arm Marshes Provincial Wildlife Management Areas, they all depend on our Government to protect them.

Jet Fuel is a Marine Pollutant.  VAFFC states within their Proposal that spills are a certainty, and even go as far as to predict amounts, these spills will be cumulative over the 60 year life of this project.   Environment Canada outlined in their document dated August 17, 2011  CEAR: 10-01-53860  ECPT: 09-0307  "The Project would present a new and unacceptable risk to the locally, nationally and internationally important fish and wildlife populations of the Fraser River Estuary, including migratory birds and species at risk;  and  "Based on its mandate for, and operational experience with responding to environmental emergencies, Environment Canada is of the opinion that there is limited ability with currently available technologies to effectively control a potential Jet-A fuel spill in the Fraser River Estuary."


Air quality and health concerns from jet fuel vapor releases, increases in SO2 and VOC's, noise from transfer pumps both from vessels berthed and from shore facilities will be heard by neighboring residents living a few hundred metres away.  The risks from operator error; vehicle/vessel accidents,  accidental spills, and fire and explosion are real.   Human exposure to jet fuel (hydrocarbons) even small amount will cause harm. 

In regards to Fire and Explosion - A Hazard to Life Assessment  must  be done, Google Jet fuel Tank Farm Fires to view incidents that have occurred including statistics.  Emergency escape routes must also be planned, in August 2011 this area was in near total gridlock for more than 6 hours with an incident at the Massey Tunnel.  


Richmond's Mayor Brodie and City Councilor's have publicly voiced their unanimous opposition to the many risks this Proposal poses.   I join the many others, including the more than 5,500 citizens who signed a petition opposing this proposal, which speaks volumes to the enormous opposition.

Since the Fraser River is a Federal Waterway, YVR is a Federal Airport, the Tank Farm is proposed  to sit on Federal Land, why has this Proposal not warranted a full Federal review under Environment Canada like a similar proposal on the North Arm of the Fraser some 20+ years ago?


I realize the economic importance of both YVR and the Fraser River to the Local, BC's and Canada's economy, and want to ensure both flourish and are not willing to sacrifice one for the other. VAFFC displayed 14 proposals at their Public Open House in Richmond in the Spring of 2011, I am sure that even more than these 14 proposals could be suggested by credible science-based studies to secure a much safer fuel delivery system to YVR while still protecting the precious estuary and citizens.   

I trust that our voices will be heard, and that the Politician's both at the Provincial and Federal level will Protect our Environment, its Citizens and future generations so all will be proud to call Canada their home.

Thank you for the opportunity to comment.

The jet fuel pipeline proposal by the VAFFC to use the Fraser River is the worst possible option available from an environmental perspective.  There will be a spill into the river and it is only a matter of time.  In this day and age to go into something like this with all these risks is so completely negligent.  We have to start considering the environmental factors as the absolute most critical, not the pocketbooks of corporations.  We citizens will not allow this to go any further.  Please encourage the VAFFC to explore the other options such as Option 3 or Option 8.  This has gone to far and we are counting on the EAO to do their job.  Seriously.

Richmond is an island in the estuary ecosystem of the Fraser River system. As a city, Richmond is situated on unstable land, in a floodplain, and is comprised of the most suitable fertile farmland in the world. We are a major stop of migrating birds of the Pacific Flyway, we have pristine bog ecosystems and are surrounded by the largest salmon river on the coast.
This project and environmental assessment are not acceptable for the risks are ignored. The precautionary principle is worth your understanding the next time you review a project. It implies that we have a social responsibility to protect the environment and the public from exposure to harm. With jet fuel it is a matter of WHEN it will contaminate its surroundings - the same land we grow our food out of; the same land we drink water from; the same air we breathe from; the same land that biodiversity depends upon. I cannot imagine a worse project for Richmond as it commits us to a pathway away from sustainability - the only thing that it sustains is growth of the YVR airport without any checks and balances. Exponential growth of our pollution is killing ourselves - just read the grave stones of my young neighbours who got sick and have passed away after living directly under the flight path - a place where jet fuel is dumping in excess over our heads. The EAO process should be about intervention not coverup and promotion. The highway 99 route is just a distraction, as the "tank farm" at the YVR end is already built - go look for yourself. Putting a pipeline alongside the highway is the worst place to put it, because then it is out of sight out of mind... until the leak and rupture wakes us up to the impact that we must react to. The EAO process should be PROACTIVE and reject this proposed project.

I oppose and do not want jet fuel shipped or barged into either arm of the Fraser.

As David Suzuki is saying: ''IT IS SIMPLE, WHEN YOU MOVE OIL, YOU SPILL OIL.''

In the words of the David Suzuki Foundation "It's Simple: When You Move Oil, You Spill Oil". Don't ship jet fuel on any arm of the Fraser River estuary.

This proposal is extremely poorly thought out from a safety and environmental standpoint.  The VAFFC should be embarrassed for putting forward such a foolish environmentally dangerous proposal that could affect the fish and wildlife of the Fraser River estuary for decades to come.  Not to mention, the danger that will be a constant threat to all who live, work and enjoy the lower Fraser River.  Environmental Protection in the Province of BC and in Canada must be strengthened to protect magnificent rivers like the Fraser.  The option to upgrade the pipeline from Burnaby to YVR and to build a pipeline from Cherry Point, WA., where VAFFC already gets jet fuel, are the responsible solutions.  Please respect the wishes of the City of Richmond and thousands of people who are desperately against this proposal.

As a Richmond resident for over 40 years, my initial reaction to having tankers with jet fuel in the Fraser River South Arm was “no way”.  Since then, I have done research, listened to both sides, read reports, and have come to a more informed and realistic view of this proposal.  Others, who haven’t already, could benefit from looking at the “big picture” instead of going with their first reaction and/or applying the principle of  NIMBY “not in my backyard”.  It would be nice to leave the politics out too.

This proposed project can be viewed in two parts.  The first part is the route of the jet fuel pipeline, and the second is having tankers with jet fuel in the Fraser River along with fuel storage near the docking facilities.

It’s a given that there needs to be a pipeline for jet fuel to reach the airport in Richmond.  The existing one is 40 k in length and part of it has passed through Richmond for years.  Upgrading & enlarging this pipeline from Burnaby looks to be extremely difficult given its long route through some residential areas.  I support the Highway 99 Pipeline Route as it would be far less of a threat than the pipeline we already have, given new technology and safety standards, and it is a definite improvement over the originally proposed route.  Should that pipeline originate from docking facilities in Richmond or from Cherry Point in Washington State - much further away and in another country?  That’s not an easy question.

After weighing pros and cons and keeping in mind that this is NOT crude oil or bunker fuel, and that this is NOT the open Pacific Ocean I feel the proposal to bring in jet fuel by river needs to be seriously considered, hence, the referral to EAO.   Do I like it?  Not much, but moving the airport doesn’t seem to be on the list of options.

Stop the Jet fuel proposal Please!

Toxicity of Jet Fuel

The toxic impact of jet fuel on the environment can be devastating. For that reason alone any major incidents involving Panamax tankers, a marine terminal or a tank farm laden with with up to 80,000,000 liters of toxic and flammable jet fuel must not be allowed anywhere in the Fraser River Estuary. 

A safer solution with fewer regrets is needed, such as a pipeline to existing refineries in BC or WA. This would eliminate the need for Panamax jet fuel tankers up the Fraser River.

"Jet fuel may be released to the environment by spills or leaks to soil or water during use, storage, or transportation. ... The more volatile components of jet fuels (low molecular weight alkanes) evaporate from soil and water and enter the atmosphere where they are degraded. Components with higher boiling points persist longer in soil and water.

Some components of JP-5 and JP-8 are soluble in water (e.g., the aromatics–benzene, toluene, and xylene).

Under turbulent water conditions, the more soluble hydrocarbons remain dissolved longer and may partition to soils and sediments and be biodegraded. The rate and extent of biodegradation are dependent on the ambient temperature, the presence of a sufficient number of microorganisms capable of metabolizing the component hydrocarbons, the amount of aromatic species in the jet fuel, and the concentration of jet fuel. Some components also volatilize or migrate through the soil to groundwater." [4]

Jet A and Jet A-1 which are produced to a standardized international specification. The only other jet fuel commonly used in civilian turbine-engine powered aviation is Jet B which is used for its enhanced cold-weather performance. Jet A-1 is similar to military JP-8, Jet B is similar to military JP-4. [3]

References:
1) Potential for Human Exposure to Jet Fuel.
http://www.atsdr.cdc.gov/toxprofiles/tp121-c5.pdf accessed 1 Feb 2012

2) Toxicity of jet fuel aliphatic and aromatic hydrocarbon mixtures on human epidermal keratinocytes
http://www.ncbi.nlm.nih.gov/pubmed/16485121 accessed 1 Feb 2012

3) Jet Fuel
http://en.wikipedia.org/wiki/Jet_fuel accessed 1 Feb 2012

4) ENVIRONMENTAL CONTAMINANTS ENCYCLOPEDIA - JET FUEL 4 ENTRY
http://www.nature.nps.gov/hazardssafety/toxic/jet4jp4.pdf 

Please keep any fuel tankers and fuel storage facilities OFF the Fraser river and the banks of the Fraser River. 

Please upgrade the existing pipelines and fuel storage facilities or use the Cherry Point facilities. 

Please do not pipe jet fuel through or under or around(Fraser River plan)the City of Richmond.  

Please think of the environmental costs to the people of Richmond and of the marine / city wildlife in the event of a likely fuel spill. 

my husband and i oppose jet fuel pumping through our river.
in the fraser river near 6 rd and steveston, i have seen river otters, seals, salmon jumping, eagles diving for ducks, commercial fishing and recreational fishing.
these signs of a healthy river are province's shared treasure.

Richmond Jet fuel pipeline

Please find my $.02 worth on the pipeline issue .

The residents of Richmond and the lower mainland in particular and the province of B.C. in general are in the enviable position of residing in one of the premier spots in the world. We are further blessed with an airport that is also adjudicated to be one of the best in the world.

All of us can take great pride in where we live and the infrastructure that surrounds us, and it goes without saying all of us care passionately about protecting that which we are so blessed to have and is the envy of many throughout the world.

Today we are faced with a growing Airport facility that among its many other requirements needs to upgrade the aircraft fuel inventory system. The existing Jet fuel pipeline has reached the limits of its ability to provide sufficient quantities of Jet fuel for the airlines that use the YVR facility.

There is at hand a proposal to upgrade that supply line that has generated significant controversy. Those that oppose this upgrade argue against it for a variety of reasons. Some of those being “the airlines want to save money by stockpiling fuel “. This would be factually correct and is not an unreasonable goal and for myself and those in favor of the expansion anything that can be seen to, at the very least stabilize the cost of airline travel , is a positive. Further concern has been given to the “inevitable spill”. No one can say such a thing could not happen, however that assumed inevitability could also be applied to the things we do every day such as driving to work or flying somewhere on vacation or business. Those things we continue to do knowing that something could happen but at the same time ensuring we have done everything possible to mitigate such an eventuality.

The matter of the proposed pipeline encompasses the same mitigation as referenced above as well as employing the tools that would be necessary should the very worst happen. To those that would argue this is proof of the “inevitable” I would ask do you have insurance for fire, theft, collision, or personal injury claims on your car and home. That answer is obvious and while we hope and plan that that insurance will never be needed it would be fool hardy to not have it.

The matter of the need to upgrade is without question,  the significant  economic gain should the plan proceed is not in question. The increase in taxes payable to the city of Richmond and the province of B.C. during and after construction is not in question. The fact of the project approval being subjected to the most rigorous environmental review possible is not in question, however what is in question is what do those who oppose the project on principal suggest as an alternative? 

VAFFC's proposed Highway 99 Pipeline Route and associated barge/tanker offloading facility and new tank farm project is a win/win for all parties involved therefore I write to show my full support for this project. 
VAFFC’s proposed project will enhance environmental safety by way of replacing an aging existing pipeline infrastructure with new Best Available Technology that will reduce the risk of environmental damage significantly over the long term as compared with the existing aging infrastructure. The proposed project would also be taking thousands of tanker trucks per year off the roads and highways that will again further protect our environment from spills.
VAFFC’s proposed project will also significantly reduce greenhouse gas emissions throughout the lower mainland by taking thousands of tanker trucks per year off our already congested roads and highways. This is obviously good for the environment and the health of the residents of the Lower Mainland.
I am the mother of 2 young children and I am confident that this project will result in a cleaner environment, safer roads and lasting economic benefits for their and even their children’s future.
Please proceed with this project ASAP:  thereby protecting/enhancing our environment while benefitting the socio-economic situation for the lower mainland. This project is a win-win for all.

The proposed jet fuel tank farm on south arm of the Fraser River and the accompanying jet fuel pipeline must be rejected.  It is clear that any fuel spills would put fish and wildlife populations and the people who live and work along the Fraser River at great risk.  You, at the Environmental Assessment Office, know this to be true and therefore it is imperative that you reject this latest proposal.  

Oil spills, large and small, happen on a regular basis every day throughout the world.  It is inevitable, therefore, that spills will occur on the Fraser River.  You know that this is the case and so do the proponents of the project.  The proponents, in order to meet their demands for fuel, have other options available to them.  This proposal is far too dangerous to contemplate.  No amount of cost saving, in order to improve the bottom lines of the airlines behind this proposal, is worth the risk to our environment.  Clean water, clear soil, and clean air are unequivocally essential to our well being.  How a jet fuel tank farm could be considered for placement along the Fraser River is extremely hard to conceive.  Do what you know to be right and reject the Highway 99 Pipeline Route Addendum.  Rejecting this current proposal will cause the Airport Fuel Facilities Corporation to more thoroughly address the issues that concern so very many of us not only here in Richmond, where the issue is front and center, but in the entire province and indeed, country.                                                                                                            

January 31, 2012

I feel the project as proposed is based on a sound evaluation by the proponant. I readily admit my involvement in the construction industry and see the project as a great opportunity for the employment for trades during the construction phase and opportunity for supply businesses.What is more important however is the long term economic benefit to YVR in that it is the most economical form of fuel delivery thereby aiding the competativeness of our international airport,which in itself generates a large contribution to the regional economy.It appears to me having read through the submission as posted on line that a thorough effort will be made to meet or exceed all regulatory requirements during the construction and operation of the proposed facility. Just think of then benifit of taking all of those fuel tankers off of our roads and bridges.

The underlying intent by VAFFC to ship or barge jet fuel into the Fraser River and its Estuary, regardless of which arm or by which pipeline transport route they wish to use, is the main problem across all sectors of our society who care about our environment and river.  It is a moot point to be discussing which pipeline route to take when our river, our Pacific Migratory Fly-Way waterfowl, and our fish are jeopardized not only by continuous spillage of transference of aviation fuel over water, but also by a possible huge spill or explosion.  When one is talking in terms of 80,000 litres of jet fuel, that’s a huge volume.  With the vagaries of wind and weather here on the Pacific Coast, one has only to look at the loss of 23 containers on a huge container ship near Prince Rupert.  Had that been fuel, or had the ship run aground or broken up, we could have been looking a disaster far larger than that of the Exxon Valdez.

The Fraser River Coalition and Wreck Beach Preservation Society first joined forces in 1974 to protect the river and foreshore long before VAFFC tried to inflict their 1988-89 proposal upon us  to barge over a million litres of jet fuel past English Bay,  Sturgeon Banks, Wreck Beach, and  bio-diverse Musqueam Marsh a week.  Both Fisheries and ENGO’s worked side by side to defeat the unthinkable proposal advocated by VAFFC then and we defeated it soundly in 1989.

VAFFC’s latest proposal or Addendum to re-route the pipeline away from Richmond  residential areas is  a smoke and mirrors or red herring to make the public think VAFFC is acquiescing to their fears of having  explosive jet fuel come too close to their residences.  But this is erroneous thinking if the main storage facility is going within explosion-distance from Waterstone Pier and the Silver City entertainment Centre. 
Even going down Highway 99, the pipeline will be crossing City lines and utilities and would need city permits to continue.  The fact that VAFFC still wants to ship large volumes of jet fuel into the Fraser reflects VAFFC’s shameful disregard  for the safety of our river, its estuary, the millions of migratory birds who must use the Estuary for rest and sustenance in their long flights, and the importance of the Fraser as the World’s largest salmon bearing river. 

VAFFC has done nothing to amend their proposal to send Panamax tankers of jet fuel into the Fraser River!  They still intend to do so regardless of where they say they will site their latest pipeline route.  They also still intend to build an offloading facility upstream of the Massey Tunnel and then store up to 80 million litres of toxic and highly flammable fuel on the banks of the Fraser River.

In addition, however, what plans does VAFFC have for jet fuel West of the George Massey Tunnel?  They cannot transport full Panamax tankers safely over the top of the George Massey Tunnel!  They always seem to gloss over this fact.  We know a certain amount of spillage occurs whenever fuel of any kind is transferred over water.  Never mind the effects of a major spill which is always inevitable; what will the cumulative effects in transferring so much 

fuel be (we know about 160 ships load are expected to maintain the storage tanks at 80-million litres capacity per year)?

We must all promote a much safer way of getting fuel to YVR, i.e., direct pipelines from the two refineries (one pipeline already exists) that presently supply 100% of the fuel used at YVR. This past week, the Airport announced a $1.8 billion expansion plan but not a cent in it to allow for a more environmentally-safe delivery of fuel to the "best airport in the world" and the "Gateway to the Pacific"!

The environmentally-sensitive environs around the airport and of course, the river itself must be protected so VIA  expansion plans must not impact incredibly-biodiverse Sturgeon Bank or the Musqueam Marshes on either side of the North Arm...  We can tell you that the battle in 1988-89 to finally send the VAFFC away in their efforts to destroy the biodiversity of the North Arm’s Estuary was hard won.  The Federal Ministry of the Environment held panels and heard testimony from such groups as the Fraser River Coalition and the Wreck Beach Preservation Society as well as from Fisheries..

Whatever the reason the Federal Ministry of the Environment has been forced to turn the EAO process over to the Fox in the Henhouse, Port Metro Vancouver, it must be rescinded and the Federal Ministry of Environment who has spoken out against this proposal, allowed to conduct the public hearings into this in a meaningful way. Forget about a so-called harmonized system of environmental assessment.  Why is a body that stands to profit from such a proposal allowed to make the recommendations as to the fate of the proposal? An equitable system of checks and balances must be in put in place and the words of Environment Canada in an August 17, 2011 letter to the EAO about “unacceptable risks” of transporting jet fuel into the Fraser and its Estuary, heeded.  At the Open House held January 28, 2012, one PMV executive point blank said that jet fuel has never been transported into the Fraser and that to do so now, would set a dangerous precedent.

And, lack of adequate public communications and a spate of understatements coupled with such a short time in which the public can make their responses, is a disgrace.  Shame on VAFFC, Mr. Pollard, and PMV!  Even Richmond City Staff have pointed this out, and the lack of information out there such as expecting the public to comment about safety ramifications of the proposal when the tanker safety or risk assessment study won’t be near completion until at least March 2012, is a disgrace.  How can you expect the public to make informed decisions when it is  missing large gaps regarding getting the fuel to the point of dissemination.

And,  also, why is it that the EAO  can only hear one proposal at a time?!!

The only way to clear up partial truths and the ignoring of others is to let the Federal Ministry of the Environment take over the EAO  process.  What good does the offer of mitigation do when our marshes biofilm and biodiversity are destroyed for decades?  Where would the migratory birds go?  How would they find these new areas of so-called mitigation?  Bird Road Map signs?!!

Although I could go on about safety and  risk factors, others will undoubtedly cover them.  I have a number of questions regarding the January 28, 2012 VAFFC Open House:  1.  Why wasn’t the open house advertised more widely by VAFFC?  2.  Why did VAFFC pick such a small community centre with an equally small parking lot forcing citizens to park along a busy city street?  3.  Why was the venue not one with a panel presentation and microphones to allow  members of the public to benefit from each other’s questions?  4.  Why did the EAO or VAFFC put out yellow sticky pads and black felts if they didn’t want folks to post their comments where others could see them?  5.  Why did VAFFC allow hecklers to try to start physical fights with peaceful and respectful protesters outside the community centre?  6.  What was the purpose of VAFFC minions photographing the protesters at great length…what did they fear from peaceful people concerned about their river and estuary?  7.  Why did someone unplug our electrical outlet for our microphone so our folk singers could sing our songs of concern?

Thank you for hearing me out.  You should know that English Bay and Wreck Beach are visited by hundreds of thousands of tourists annually and that they expect unpolluted waters in which to swim and by which to sunbathe and recreate.  Our Society has been protecting our beach, foreshore and forested cliffs for nearly 45 years now.  And we have joined hands with the Fraser River Coalition which is comprised of nearly 35,000 persons to help protect one of the World’s top heritage rivers and the World’s largest salmon-bearing river.  In addition,  we have all joined forces with the BC Shore Spawners Alliance to protect the surf smelt which would be destroyed by any spills, ongoing or major.  Finally, we are also proud members of VAPOR!

If a jet fuel pipeline must run through Richmond to feed YVR, the Highway 99 corridor is certainly the safest and most practical option proposed for the route.  There is far less impact to city residents, as major east/west streets, such as Williams Road, would not be dug up affecting traffic, utilities, and homes.  The more environmentally sensitive areas along Shell Road would also not be impacted.  Operational maintenance required during the pipeline's lifetime would also be easier to accomplish as a pipeline along the Highway 99 corridor would be far more accessible.  Should there be an accident involving the pipeline, be it natural or man-made, having the pipeline's route along the corridor would also lessen potentially disastrous harm to the residential areas.

Having said that, I firmly believe that the pipeline should be extended south to ultimately connect with a feed from the Cherry Point refinery in Washington state.  This would be a far safer option of transferring fuel to YVR than allowing tankers to traverse up the Fraser River, which is environmentally sensitive in regards to fish, birds, and other wildlife.  As much as the proponents for shipping fuel via tankers up the river to a shore-based storage facility claim the method is safe, there are far more opportunities for an accident to occur, such as the diesel fuel spill in Nanaimo Harbour demonstrated in April 2011.  These include, but are not limited to, ship collisions, groundings, faulty valves either ship or shore based, infrastructure failures, or human or procedural error.  A buried pipeline lessens the potential for an accident, and the environmental impact of an accident, tremendously.  In addition, the proposed storage facility itself would be a potential danger to the residents in the Riverport area, which is increasingly being developed, and also an eye-sore to those same residents and anyone travelling along the Fraser River.

Thank you for giving me the opportunity to comment on the Vancouver Fuel Delivery Project. I have recently become a resident of Richmond and first learned of the Highway 99 Pipeline Route Addendum through the Richmond News.  The location, furthest away from residents was a positive change to the over-all project.
However, after attending the VAFFC open house on Jan. 28th and reviewing the Vancouver Airport Fuel Facilities Corporations Vancouver Airport Fuel Delivery Project of Lower Mainland B.C submitted to the British Columbia Environmental Assessment Office I understand that there is a problem with getting the required jet fuel to the Vancouver Airport.  VAFFC a non-profit organization is owned by a consortium of commercial airlines, they own and operate fuel storage and distribution facilities and underground pipelines that transport fuel to the Vancouver Airport.  I understand that the existing fuel Delivery System will not meet the needs of the expected growth of airline traffic. Considering the fact that Canadian jet fuel only meets 40% of the YVR requirements and the balance is dependent upon US refineries, options must be explored.  This is why I feel as a Canadian citizen that a full environmental assessment should be conducted on this project.  Our waterways and marine life estuary's should be protected from the possibilities toxic spills of any kind. pipelines constructed with today's technology, Option 8, might be the way of accomplishing a sustainable solution to a obvious need of progress.  Thank you for allowing me to voice my opinion.

Talk about bait and switch!  I have no doubt that the VAFFC planned all along to change the routing for the proposed jet fuel pipeline across Richmond, moving it from residential neighbourhoods to the shorter, safer and less disruptive placement along Hwy. 99.  This was done to placate an ill-informed public and take the media focus off the half a million barrel oil tankers in the Fraser River along with an 80 million litre tank farm.  Why else would the VAFFC not have taken the cheapest and shortest route through Richmond from the very beginning? 
 
 It disgusts me reading all of the multiple comments on this site from people withholding their names (or lying about where they live) who support this environmentally insane plan.  It is obvious that many are from the same derranged personality along with those working for the oil and gas industry and the airlines that own the VAFFC.  Why not support the proposal on its merits instead of the economic benefits (read profits) to the airlines that own the VAFFC?  The answer is simple; this project doesn't fly when you consider the environmental risks and the glaring lack of process in finding the best solution to supplying YVR with fuel.
 
 At the last open house, a group of so-called protestors showed up for a short time to support the VAFFC & VAFDP and shout down VAPOR members.  They were on site only long enough to have their pictures taken by the media and then disappeared minutes later.  They held up full colour picket signs supporting super tankers and jet-A, all with different pictures and comments.  What is funny is that these signs were seen being removed from the back of a pickup truck that was later driven away from the community centre by a prominent VAFFC staffer!  Are they really that desperate that they have to stoop to dirty tricks? Did the VAFFC arrange for this goon squad to show up or pay to have these individual placards commercially produced?  Nice to see the main bully took off his Chevron hat and didn't swear or offer **Inappropriate language removed by the Environmental Assessment Office** when interviewed by Global TV.  This buffoon has been identified as working for a company that sells fuel pumps and is a member of the Petroleum Equipment Institute. 
 
 The concern over jet fuel tanker trucks on Hwy. 99 from Cherry Point is unfounded as Kinder Morgan informed me that they had current capacity in their TMJ pipeline except for certain high demand periods during the year.  The reason that these trucks are running is that it is cheaper for VAFFC member airlines to have fuel driven to the airport instead of barging it to Burrard inlet, off-loading the jet-A and then piping it to the airport.  Just as the VAFDP is all about accessing the cheapest supply of fuel, these trucks represent how the airlines will always go with the lowest cost option regardless of the risks involved.  These trucks could stop tomorrow if the VIA Authority had the backbone to tell the airlines to halt this practice.  Instead they are used as a smokescreen to try and justify this absurd proposal that would put massive tanker ships in the Fraser plus an even larger tank farm on its banks.  Did they learn nothing from the Exxon Valdez in Alaska or the recent BP blowout in the Gulf?  Water and oil don't mix and half a million barrels of jet fuel doesn't just evaporate and vanish into thin air as the VAFFC contends. 
 
 If SeaTac Airport in Seattle can pipe their jet fuel from Cherry Point why can't YVR, especially when considering it would be less than half the distance and that 60% of their fuel already comes from this refinery/storage complex that can off-load Panamax tankers?  The existing TMJ pipeline to YVR will be serviceable for years, allowing fuel to be piped safely from the Chevron refinery in Burnaby plus the Westridge Marine Terminal should it be needed. Add a new jet fuel pipeline from the U.S. to YVR, you have multiple transportation systems accessing a variety of sources.  Win-win except that the VAFFC won't be able to cut out the middle man and get cheap fuel while threatening the Fraser River, our wild salmon stocks, local residential and business developments and the many wildlife reserves in the estuary.  Its no wonder that Richmond and Delta councils plus former MP and B.C. Conservative leader John Cummins strenuously object to this diabolical plan.  Great to see Mayor Brodie giving many interviews supporting VAPOR's goals at the last open house. 
 
 This is the third time that an attempt has been made to bring giant jet fuel tankers into the Fraser River, with the two previous attempts being shot down because of the environmental risks associated with them. Nature hasn't changed, the mighty Fraser hasn't changed, the danger of jet-A hasn't changed, and the only difference in this plan is it calls for larger ships, bigger storage tanks and even greater risks.  Maybe YVR should throw the VAFFC a bone and give them some of the additional $1.8 billion it hopes to fleece from the flying public with its latest increase to the airport improvement fee.  Instead of wasting money on more marble and gold inlay for the terminal, why not help to finance a fuel delivery system that does not have the risks contained in the eco-criminal VAFDP?
 
 If the BC EAO process actually works and our politicians are not on the take, there is no way this proposal will ever make it past the demented drawing board (or dirty napkin) it was first scribbled on.  Should this project somehow get passed, expect a groundswell of public opposition calling not only for a boycott of flying from Vancouver in favour of Abbotsford, Bellingham and Seattle, but also the member airlines including Air Canada and West Jet aligned in this axis of evil known as the VAFFC.  Any politician stupid enough to allow tankers full of jet fuel into the Fraser should realize they will be targeted for expulsion in the next election as they don't deserve to hold public office.    
 
 Let's torpedo the tankers and sink this sick VAFD Proposal. 
 NO JET FUEL IN THE FRASER RIVER, THEN..., NOW..., FOREVER!!!         

I oppose the Highway 99 pipeline Route Addendum, and any ships or tankers filled with jet fuel (or crude oil as I hear they are now) travelling on the Fraser River or B.C. Coast. Please listen to 10 year old Ta' Kaiya sing on her "Shallow Waters" youtube, and let your heart fully absorb her sweet voice and words. Thank you.

Most industrial projects have both pros and cons to quality of life and that should be a driving factor for the decision process.  The job creation is a clear positive quality of life.  This proposal will create short term construction jobs, but so will the safer and environmentally responsible options, such as a closed pipeline system from the ARCO refinery in Ferndale to YVR or upgrading the existing pipeline system to YVR.

Does VAFFC’s marine terminal, tank farm and pipeline put any other industries at risk?  With the probability of a spill a 6000 litres every 6 years and 120,000 litres every 32 years as a conservative estimate from the proponent, will put a Fraser River fishery worth $100s million/year at significant risk.  Plus container traffic and other business on the river would be interrupted during cleanup.

A spill of toxic and flammable jet fuel into the Fraser River (a river estuary influenced by tides) would pose a significant contamination risk, noxious vapour and fire to the river side communities and environment of Richmond, Delta and New Westminster at great risk.

The proposed marine terminal would be located 350 meters from a 140 unit condominium complex and would present an unacceptable fire, vapour and explosion safety risk to the residents there.  That’s not to mention the social-economic impact to the residents (according to BC Assessment property values have dropped 10% lower than 2006 sale price while the rest of Richmond real estate has gone up significantly).  The proposed tank farm would store and transport about two times the current YVR fuel storage volume now stored at YVR where is it well protected by YVR and Richmond Fire Rescue. VAFFC would place another hazardous facility next to the fragile Fraser River and nearby, commercial and residential sites.  To provide the same fire – rescue level of coverage for this proposed site and neighboring community would require major Richmond City expense for new equipment, fire hall, and staffing.  This would most likely more than outweigh any taxes paid to city for this land and facility making this site a near ‘charity’ case and the citizens of Richmond would be indirectly subsidizing the airlines fuel cost.

Tanker trucks on our roads are not a solution, but this proposed project is not a solution, safer and more environmentally friendly solutions are possible.  This proposed project would present a significant risk to the quality of life thousands of people and environment and that is absolutely unacceptable.

I am totally against these proposals in its 3 forms.  Richmond is built on a silt bed and the area on No 5 road is also on a peat bog.  As they propose to use flexible pipes, this guarantees that the pipes will leak. (The areas of flexiblity being the weakest point from which the fuel will leak).  This leakage will spill into the water and contaminate it. There is also the problem of smell if a leak occurs.  Either way this endangers the lives of the surrounding population.  If there is a blowout or spark, the peat bog that the refinery & pipes sit on would catch fire and this fire would be uncontrollable.  We have already had a peat bog fire a few years ago between No 4 & 5 road behind Kingsbridge and Francis Road.  The fire department had a terrible time trying to put this out.  Men were on the roofs with water hoses trying to water down their houses.  Any fire that starts will travel quickly because of the peat and the fuel will contiminate the soil,water and air. As for the bruial of the pipes 8 feet down.  This means below the water line, so any minor leak will take a long time to discover and repair.  Richmond is earthquake country and the gound is unstable and moves.  My picture frames on the wall move every time a heavy truck goes by or a plane goes overhead and forget to reduce its engines.  This whole proposal was not properly though out or investigated.  If the proposal goes though, it could and would endanger most of the people in Richmond.
Have we not learned from the Japan quake, the Burnaby spill of Jan of this year, the ruptured line of several years ago in Vancouver,and TransCanada pipeline spills. What is with this government?  Is the all might dollar greater than peoples lives.  Never before has a company tries to put a pipeline through a bog.  Obama cancelled the Keystone because of that reason. There are many lives at stake.  It was also very upsetting that the public was only given 1 weeks notice of the one day only meeting.  Most people in Richmond are not yet aware of the proposed Shell Road Route or the Williams Road route.  More public notice and discussion is needed.  Obviously we should not be voting Liberal in the next election.

I am generally supportive of the proposed project, but offer the following comments:

The letter dated January 6, 2012 from Adrian Pollard, Project Director VAFFC to Rachel Shaw, Project Assessment Director BCEAO refers to certain analytical studies of various options for the project(Section 4). VAFFC states that the studies were voluntary, outside the scope of the Application, and) “support VAFFC’s assertion that the proposed project is the best option” when [all] factors are considered. 

I submit that VAFFC would not have (i) commissioned the studies, (ii) described the consultants’ qualifications, or (iii) even mentioned the studies in the letter, if it did not believe that they would be relevant to the proposed project. I also suggest that proponent would likely have asked that the studies be included in the Application if their recommendations had been more favourable.

It is my understanding that determining the “best option” for the project is the responsibility the BC Environmental Assessment Office, not the proponent. As a result, the referenced studies should be included in the official assessment process.

First, this project enables YVR's plans to expand flights in the coming years. Emissions from air travel are a significant and growing accelerator of climate change. I strongly advocate contraction of the airline industry until airlines find a way to internalize the cost of their contribution to global warming. Luxury air travel is depriving people in other places of the necessities of survival.  I oppose this.

Second, the pipeline risks potential damage to the Fraser River from spills, damage to residents of Richmond from pipeline accidents, damage to a major transportation arterial from pipeline accidents. In addition it will impose increased traffic on one of the choke points in Vancouver area transit down the 99 corridor during construction. The public is being asked to assume all these very large risks so the private VAFFC corporation can profit from an alternative fuel delivery method. I oppose this.

This is prob. repeating the same thing, but I do very strongly oppose increased shipping of fuel on the Fraser River.
Think about it! it is the place where all Salmon - fry or adults have to pass through. A spill at the wrong time would wipe out another run - haven't we done damage to too many already? The Fisheries should be aggainst it, as well - in order to save their "bacon"!
No jet fuel on the Fraser!

I think having a jet fuel transportation is very wrong.  We need to protect the Estuary, fish and wildlife.
Put it at Cherry Point or fix the exixting pipe and keep them where they are in Burnaby.

No fuel pipeline on the Fraser. Why have government officials not been intelligent enough to nip this in the bud? It doesn't need public input. It puts at risk on of the greatest resources available to the people of British Columbia. Government officials should eliminate any and all projects that fly in complete defiance of risk management. Grab a brain and snub this project. Be ashamed of yourselves for entertaining the idea. Expect never to be elected again if you are an elected official so confused by your responsibilities that you would support this. This may as well have been a project to introduce handguns to preschoolers. How can you not sense the risk?

No shipping or barging of jet fuel into the Fraser River Estuary, period, and that includes into either the North or South Arms.

No floating barge off-loading facility on Sturgeon Banks, just across from Wreck Beach and English Bay. Juvenile salmon rest at Sturgeon Banks before heading to open sea. No jet fuel off-loading barge facility upriver from Wreck Beach and the vast, bio-diverse Musqueam Marsh, as well as 144 acres of forested cliffs behind Wreck Beach into the Estuary.

I object to the "Preferred ROUTE" for the pipeline through Richmond and the "Preferred Option" for routing a trail around the Jet Fuel Marine terminal. These are totally unacceptable choices. We should not be asked to select different pipeline routes from a facility that would necessitate the shipping of jet fuel into the river.

What should be done is to upgrade the existing Kinder-Morgan pipeline or even better yet, build a new pipeline to follow Highway 99 from the Cherry Point Refinery outside Ferndale, Washington. The long-term gains will far outweigh the expense once it is in place. We cannot afford any other possibility besides pipelines because of the huge risks to the environment. The Fraser River is the largest salmon-bearging river in the world. Our migratory birds, resident orca's and salmon need our protection NOW!

I am also disturbed about this input process. It is not democratic. VAFFC expects the public to be able to comment about the safety of the tankers before the safety assessment of these tankers is even completed. The assessment is expected to be done by March 2012, yet the deadline for public input is January 31, 2012. And further note that this deadline of January 31, 2012 is the actual deadline, not the published one of February 1, 2012, and this is also not democratic.

I am very concerned about VAFFC 's proposal to store, and ship toxic jet fuel along the Fraser River.Jet fuel spills are inevitable. This estuary is an ecological site of global importance to millions of birds, fish and other wildlife.This proposal is also dangerous to the thousands of people who reside in this are.  I am one of these citizens and I object strongly to the current proposal.

I am opposed to the Vancouver Airport Fuel Delivery Project. The mouth of the South Arm of the Fraser is among the most sensitive ecological areas in Canada. It is part of the globally significant Fraser River Estuary Important Bird Area,a BirdLife International recognized by scientists world wide. The proposed tanker route would pass close by the Alaksen National Wildlife Area and the George C. Reifel Migratory Bird Sanctuary. The South Arm also a critical area in the life cycle of anadromous fish, including the world famous Fraser salmon. The proposed route is totally unsuitable, as is the placement of fuel tanks on the river and the building of an additional pipeline. I strongly suggest that better alternatives to supplying the airport could be found. 

Not only the pipleline will boost the economy bringing thousands of dollars and much needed jobs to our communities, the project will allow a safer transportation of fuels lowering spill risks and hazards to our environment. Transportation costs will be reduced not to mention this action will lower our carbon footprint. I support the project 100%.

Do not bring tankers up the river when it is unnecessary. There is a piping option  running from the  existing refineries.  Neither is the best option for the estuary,  but tankers is the worst option.  The severe consequences  of any oil spill to the urban shoreline and coastal ecosystem are  not tenable when other ( probably lower cost)options exist.

The Nile is considered "the lifeblood of Egypt" and the Ganges is worshipped in India.  In my lifetime a once thriving clamming industry has disappeared here in the Delta, without a peep.  We have sold our estuaries to Norway for their fish farms, forgotten to put fish ladders on important Salmon runs, allowed huge amounts of pollutants to be dumped by industry into the Fraser, diverted water from all secondary channels to self- scour the main money making channel, allowing harbours of small villages to silt in.  The product of dredging, when it occurs, is seldom used for designed accretion but rather dumped down river from the dredge site never reaching the Georgia Straight where it is contracted to go because no one polices the process and it is much cheaper to just dump it as soon as possible than barge it all the way to the Straight.  Industry on this river is a free-for-all situation with no EFFECTIVE stewardship-just a show of nitpicking beaurocrats that target individuals but leave industry alone.  I do not believe that my comments on this form will have any effect whatsoever in preventing a disasterous oil spill here on the Delta, though I want to say I am opposed to this level of risk being tolerated for this purpose. 

January 30, 2012

I object to the VACCF jet fuel proposal

30 January, 2012

To Whom it May Concern:

I join over 5,500 citizens in outlining my grave concerns about the controversial proposal by VAFFC to store, ship, and offload toxic Jet Fuel along the Fraser River, including the option to run a fuel pipeline up Highway 99 from the terminal.

Some of my ecological concerns:

~ the Fraser River estuary is an ecological site of global importance to
millions of birds, fish and other wildlife. Indeed, the George C. Reifel Migratory Bird Sanctuary located in the heart of the Fraser River estuary, attests to this fact.

~ VAFFC admits that jet fuel spills are a certain consequence of their proposed jet fuel plan, projecting that 50 barrels of toxic jet fuel will be spilled in the Fraser River over a 6 year period, and 1,000 barrels of toxic jet fuel will be spilled over 30 years.

The disastrous impact of any spill at any time involving any area of the Fraser River estuary on water, birds, wildlife, soil, air and people, is simply too great a risk!

Further, the death dealing risks will impact not only the present, but also the future in ways we cannot yet fully know!

As we know, that what happens locally has a global impact on the earth and on all life everywhere!

~ VAFFC suggests that dispersion would be a main means of restoring water, plant life, soil, and marine sediment to safety for creatures and people after a spill. Jet Fuel is heavily stabilized for movement by high levels of deadly chemicals causing long term, death dealing effects on water, soil, plants, fish, wildlife, air and people.

~ VAFFC proposal to store toxic jet fuel in 6 six story fuel tanks located less than 50 meters from the water of the Fraser River is in and of itself too great a risk to the water, land and all life forms, including humans. It is unthinkable!

~ the tankers proposed as the carriers of the jet fuel are also of great concern. The inability of tankers this size to negotiate the proposed route along Fraser River means that the toxic jet fuel would need to be off loaded onto barges, increasing the likelihood and frequency of spills and other accidents. (see Drifting Fuel Barge: January 6, 2009 at VAPOR website www.vaporbc.com)

~ Environment Canada outlined in a fourteen page document dated August 17, 2011 that this proposed plan introduces a “new and unacceptable risk” to the people and the environment of the area. Is this environmental agency being heard?
Some of my economic concerns:

~ this proposal by the VAFFC attempts to control the entire process of purchasing, moving and using jet fuel for economic gain, with  no accountability to the Cherry Point refinery or Burnaby refinery, with no accountability to citizens, environmental groups, or even to government agencies. It is a proposal that minimizes costs, maximizes profits, and takes into account no environmental or human concerns.

~ residents of the area have already experienced a significant 5-10% decrease in the property value of their homes even with the possibility of this outrageous proposal in conversation! (see www.vaporbc.com)

~ following this property trend, one can ask about the negative impact on local services and businesses, and jobs, if this proposal should move forward.

Some of my Safety concerns:

~ the inevitability of fire resulting from explosions occurring at any point of transport in this proposed plan is also a given.

Richmond Fire Department representatives have already indicated problems with getting to the proposed site of the marine terminal and storage tank farm. It would take at least double the standard response time to reach the site, the type of fire would not respond to a water based response, and could endanger the lives of creatures and humans.

The intensity of the Miami Fire, March 24, 2011, melted existing on-site fire response equipment!  (see link at www.vaporbc.com) The amount of jet fuel stored and moved in this proposal makes fire a likely event.

~ all concerns voiced under environmental concerns, including the certainty of spills and fires, carry life altering and life threatening effects on people, both those living in the immediate area and living further away.

~ VACCF has not included in their proposal a description of a “hazard footprint”, an outline of the “worst-case scenario” in the event of an accident.

Perhaps this is the most alarming indication of the attitude of VAFFC to me. Though VAFFC admits that spills are certain, it seems they do not even admit to the possibility of unforeseen accidents, much less have a plan of response.

I sense here an arrogance, at the expense of the human and global environment that is beyond belief!

Some of my social-emotional concerns:

~ as evident in the multiple concerns expressed to Richmond City Council, from citizens, residents, and experts in biology and energy (see www.vapor.com) people are already experiencing social, emotional and physical suffering in the face of the possibility of this controversial jet fuel proposal by VAFFC.
Does VAFFC hear the people? Does VACCF care?

There are many more concerns and questions that I could raise concerning this proposal by VAFFC.

I support the VAPOR call for a full federal environmental review of the entire VAFFC plan.

I also support further exploration, research and study of alternative proposals. In particular, I support further consideration of:

~ proposal #3, involving the upgrading of existing pipelines

~ proposal #8, involving the largest and safest plan thus far, involving pipeline already in place and being used successfully.

I also welcome new proposals that may find creative ways to engage the expansion of jet fuel to YVR while safeguarding the land, water, creatures and people of this area and of the planet.

Here are my comments and the reasons for my opposition to this Project:

I am a 25 year resident/homeowner in Richmond BC.  I am opposed to the pipeline proposal due to concerns identified by my Mayor and Councillors, namely:
Concerns about shipping jet fuel via the sensitive Fraser River Estuary.  Environmental, public safety and economic issues related to having the off-loading and fuel storage facility and pipeline located along the river shoreline in Richmond BC.
I do not want jet fuel shipped through the Fraser River Estuary.   
There are far too many risks to the environment and to public safety.
I am opposed to to any option that includes an off-loading facility on the South Arm of the Fraser River, a new jet fuel line through Richmond farmland and urban areas of Richmond, or an increase in trucks carrying jet fuel on my City streets.
The proposed realignment of the pipeline in Richmond does not address the potential risks associated with this project to my community and I am opposed to the entire project.
Thank you for your consideration.

I am a 34 year resident/homeowner in Richmond BC.  I am opposed to the pipeline proposal due to concerns identified by my Mayor and Councillors, namely:
Concerns about shipping jet fuel via the sensitive Fraser River Estuary.  Environmental, public safety and economic issues related to having the off-loading and fuel storage facility and pipeline located along the river shoreline in Richmond BC.
I do not want jet fuel shipped through the Fraser River Estuary.  There are far too many risks to the environment and to public safety.
I am opposed to to any option that includes an off-loading facility on the South Arm of the Fraser River, a new jet fuel line through Richmond farmland and urban areas of Richmond, or an increase in trucks carrying jet fuel on my City streets.
The proposed realignment of the pipeline in Richmond does not address the potential risks associated with this project to my community and I am opposed to the entire project.
Thank you for your consideration.

I am opposed to the Vancouver Airport Fuel Facilities Corporation (VAFFC) proposal to build a new aviation fuel delivery system to serve YVR (which includes a marine terminal and fuel receiving facility located on the south arm of the Fraser River, and a new fuel pipeline to YVR, whether an underground pipeline or an overground one).  I am not opposed to responsible fuel delivery to the airport, just irresponsible plans to do so in ways that do not warrant the risks.  Here are my reasons why:

I am opposed to the VAFFC proposed addendum of having the pipeline go via Hwy 99 (Steveston Hwy to Bridgeport), as well as the option of the pipeline going through Richmond neighbourhoods.  I think that there are other alternatives that do not pose such serious environmental, economic, and health risks.  (Obviously VAFFC has seen its error in proposing an underground pipeline, but its new proposal does not adequately address the risks of another pipeline to make this addendum acceptable.)

I am also opposed to the VAFFC proposed Jet Fuel Marine Unloading Terminal and the 80 Million Litre Jet Fuel Storage Facility by the banks of the Fraser River (adjacent to residential condominiums, Watermania, and the Riverport entertainment area).  There will be spills; so to put something so environmentally harmful in an area close to Richmond residents, as well as so close to the farms that grow our food, and waterways that sustain wildlife, is not acceptable for our human health nor for the health of various species of wildlife whose habitats would be affected.  There will be unacceptable risks in having such a narrow route for the large tankers to navigate that also has other commercial and recreational traffic.  As well as navigation, mooring and unloading toxic and flammable fuel from a tanker on such a busy river-way is too dangerous.

The proposed area is also seismicly sensitive so a future earthquake could result in unforeseen devastation to the area, impacting its livability for humans and wildlife, and also its economic future.  

I am also opposed to shipping in jet fuel from south east Asia when there are other alternatives from within Canada that allow for a safer transport to YVR and which would likely require less environmental energy resources to get it here.

Another concern is that the fire and rescue services do not have the resources to adequately respond to a spill or a fire at the fuel off-loading facility and tank farm that is presently planned for Riverport.  The risks are therefore magnified, when a spill occurs or should a fire occur.

Also, the Port Metro Vancouver's tanker risk study has been delayed until after this comment period has closed.  The results of that study are very important to the Environmental Assessment, so the EA should not be concluded until after this study is completed.  (Also, this tanker study should be available to the public BEFORE the close of this comment period, so that we can also take its findings into account in our comments and concerns.)

The short-term financial benefits for VAFFC in no way justify the short-term and long-term risks for the human and wildlife community that are inherent in the proposed plan and addendum.

Please do not issue the environmental certificate to the VAFFC project----not even with the addendum----and require them to find an alternative way to improve the way to get jet fuel to their businesses.  Require that they consider other alternatives, and listen to these voices from the public that offer such alternatives.  The extra money to upgrade the existing pipeline that already goes to YVR is a preferable alternative.  There are other alternatives, such as the ones listed at http://www.vaporbc.com/options.html. 

Thank you for your attention to my concerns and my opposition to the VAFFC proposal and addendum.

Hello,
this is a comment regarding the Highway 99 Pipeline Route Addendum.
I have few concerns regarding the proposal:
1. The storage and loading/unloading terminal in the Fraser River poses the risk for all the fish and wildlife population of the Georgia Straight as during the low tide the water is moving very fast and any spills will be spread before it could be contained. These type of facilities should be located in a sill waters where there is less risk of the massive spread.
2. Both proposed routes are violating the rights of the people owning the homes along the proposed routes because both of them are planned to do very close to the houses, especially in the second proposal (in Addendum. If the disaster happens, their lives might be lost. When the route goes past the Alderbridge way in areas like Cambie and Bridgeport, some homes are located very close to a Hwy and it is not feasible to keep any reasonable distance between the houses and the pipeline. In case the proposed route is the only one that the owners want to consider, they would have to buy all the houses that are located to close to create the safety buffer zone, otherwise the lawsuit might be initiated by them.

3. In a world where the terrorism is a real possibility, the fuel pipe has to be reliably protected from an unsanctioned access and I do not see how it could be done in this location.

This project carries too many risks that cannot be adequately addressed in an emergency situation: this is unstable ground in an earthquake zone.  What will happen when the Big One hits us?!  This is far too close to important fish, bird and wildlife habitat in the Georgia Straight.  Please find another solution to shopping and storage of highly toxic and flammable jet fuel.

I attended the VAFFC Open house On Jan 28th and l was extremely disapointed in the comment form. We where only allowed to  make comments on the  three choices for the pipeline route and the two choices for the location of a trail around the Marine terminal.

Most of the over 140 people who attended where opposed to the entire project and had no venue to discuss the project as a whole.

Why state you are open to public comments when in fact you are NOT. The process is flawed and the VAFFC should be ashamed of the lack of true consultation. The BC EAO should be very unhappy with the process as well because it  demonstrates the lack of openness the EAO has in this consultant  process.

I can clearly see now that the system is broken and l agree  with the auditor general and their findings in regards to the lack of accountability in  dealing with Provincial environmental issues.

The VAFFC Jet Fuel Proposal is a prime example of the failure of the provincial government to protect one of the most important assets  we have " The Fraser River Estuary ".

Environment Canada states  " The project is a new and unacceptable risk to the locally, nationally and internationally important fish and wildlife populations of the Fraser River Estuary..."

The EAO has an opportunity to rise above the misinformation and biased process  and deny this application. Now is the time to demonstrate  the people of BC that the EAO has a purpose and that purpose is to protect the Environment.

I am totally against the Vancouver Airport Fuel Delivery Project.  
1. The Fraser River estuary is too sensitive an environment to support the shipping and storage of fuel at the planned location.  Any type of fuel spill or related pollution will jeopardize the river and the related environs, including the fishery and the Westham Island sanctuary.
2. The pipeline itself, transitting most of Richmond, is an inane idea.  The Highway 99 corridor is paralleled by No. 5 Road, and there are numerous housing complexes that could be put at risk.  Any rupture of the pipeline in this area or in the area of Bridgeport Road could be too catastrophic to imagine.  Furthermore, we are continually reminded that we are risk of possible earthquakes, and the consequences for such a pipeline could be devastating.
3. I don't believe that the proponents of this fuel delivery system have adequately explored other options that would eliminate most or all of the concerns being raised against it.  One option is the expansion/improvement of the existing pipeline.  A second option is to install a storage/offloading facility on the North Arm of the Fraser River in the vicinity of Iona Island or Deering Island.  This option would result in a very, very short transit to the airport and avoid the risks implicit in a pipeline transiting about 19 km across Richmond.

I have seen no comments anywhere favouring the installation of this pipeline, not in the media, newspapers or otherwise, and I am sure that my objections don't nearly cover the negative aspects of this project proposal.  The only positive comments I have read come from the airlines organization making the proposal.  Whatever decision is made on this proposal, we will have to live with it for decades into the future.  An alternate and less dangerous fuel delivery means must be identified.

this project proposal is absolute insane, considering the company that wants to push this has stated that spills WILL happen!!! We cannot continue killing our fish and Fraser river and planet!
If this project proceeds then a environmental catastrophy will happen!
NO NO NO NO NO
My livelyhood and my staff rely on the health of the Fraser river to raise and feed our families.

I noticed an article on the BC Local News website. I have copied the full article below.

What concerns me here is that the information printed appears to be deliberately misleading. Why isn't this kind of disinformation being addressed by the EAO?

The article sometimes refers to OIL rather than jet fuel:
"Any pollution that would affect the Fraser would pollute both shores," he said. "If one of those tanks bursts, the oil will spill out over to the banks and pollute the groundwater."
and...
"There's a saying that one gallon of oil pollutes a million gallons of freshwater, so the impact on the palatability and the usability of the freshwater for your drinking would be devastating," he added.

The comments above were attributed to Jim Ronback, who is identified as being a retired engineer. Since he is heading up the pipeline opposition (called VAPOR) he should be far more careful about getting the facts right and not distort the issue.

Jet fuel is not in the same league as oil when it comes to pollution and environmental damage. It would be useful for the EAO to publish some kind of yardstick that would enable the public to understand the comparative threat to the environment of these two products.

May I suggest a more suitable acronym for the organization: 
VAPID  – Vacuous Airport Propaganda In Denial

Full extract from: http://www.bclocalnews.com/news/137447858.html

** START OF ARTICLE **

By Christine Lyon - South Delta Leader
Published: January 17, 2012 8:00 AM 
Updated: January 17, 2012 8:39 AM 
A revised proposal by the Vancouver Airport Fuel Facilities Corporation to route an underground fuel pipeline beneath Highway 99 may alleviate safety concerns for some Richmond residents, but the new plan does nothing to protect the vulnerable Fraser River Estuary.
That's according to Tsawwassen resident Jim Ronback, a retired engineer and director of Vancouver Airport Pipeline Opposition for Richmond (VAPOR), a residents' group opposed to the VAFFC's proposal to meet demands for fuelling air traffic at Vancouver International Airport.
Ronback says the new plan to route the fuel pipeline under the highway instead of residential neighbourhoods is unacceptable and does not address his main concern—the construction of an offloading facility and fuel tank farm in Richmond on the South Arm of the Fraser River.
The proposed project consists of barges or oil tankers loaded with jet fuel docking at the marine terminal. A pipeline from that facility would then channel fuel across Richmond to the airport.
Ronback worries those fuel-laden barges and tankers could pose a serious environmental threat.
"Any pollution that would affect the Fraser would pollute both shores," he said. "If one of those tanks bursts, the oil will spill out over to the banks and pollute the groundwater."
"There's a saying that one gallon of oil pollutes a million gallons of freshwater, so the impact on the palatability and the usability of the freshwater for your drinking would be devastating," he added.
VAPOR members are advocating for a pipeline-only alternative, such as upgrading the existing pipeline between the airport and the Chevron refinery in Burnaby, or constructing a new 70-kilometre pipeline to the Cherry Point refinery in Washington State.
Mayor Lois Jackson and Delta council received a letter from project director Adrian Pollard dated Jan. 6. According to the VAFFC, the Highway 99 route shortens the total length of the pipeline by 1.3 kilometres, provides the most direct route from the marine terminal to the airport, offers more separation between the pipeline and urban development in Richmond and creates a smaller environmental footprint.
Pollard's letter also summarizes an independent third-party analysis of the project options and gives an overview of the emergency plan in the event of an oil spill.
Delta municipal staff are preparing a report to council on this subject.
The B.C. Environmental Assessment Office is accepting public comments related to the Highway 99 addendum from Jan. 11 until Feb. 1. To comment online, visit www.eao.gov.bc.ca.
** END OF ARTICLE **

How is it that the Highway 99 proposal was not a part of the original proposal? It seems like the obvious choice and it makes sense that one of the major traffic conduits to the airport doubles up as the transport route for the fuel.

The amount of effort taken on the environmental assessment on Highway 99 seems completely over the top. The creation the original highway plus the associated on-going maintenance and the amount of traffic along its route would indicate that a study of the environmental impact of the pipeline along Highway 99 may be a pretty pointless exercise (OK. I admit that I am not qualified to make that statement).
Why is there no weighting/measurement applied to the dangers of the jet fuel in relation to other hazardous liquids that are commonly transported - crude oil for example? How much oil is being shipped, piped and trucked around Vancouver in relation to the amount of jet fuel? How toxic is fuel oil and how long does it remain in the environment after a spill, especially when compared with crude oil? I believe that the concern over this project is out of proportion with the real problem that jet fuel presents - it's simply not in the same league as crude oil and this needs to be emphasized. 

Although the Highway 99 proposal is full of information, I feel that only an expert in certain subjects could accurately comment on much of the substance in the report. I would rather rely more on the federal and provincial government bodies to produce a concise report for the general public in addition to the lengthy detailed reports provided here. These agencies are representing the public and I am far more interested in a distilled assessment carried out by 'my' representatives (the public servants) with who we all place our trust. 

On the issue of public servants, if I were a resident of Richmond then I would be deeply unimpressed with the antics of the mayor who seems to be happy just to join the rabble rouses and throw rocks. With the location of Richmond being so close to the airport, it means that Richmond will always be impacted by the airport in both positive and negative ways. I believe it is incumbent on the local municipalities to be constantly be working with the airport authorities towards a common goal that will inevitably result in some kind of compromise. The mayor should have been actively involved at the front and from the outset, not just turning up to the presentations to mouth off and help himself to the free coffee and buns. 

The more I look at the proposal, the more I wonder about the current infrastructure and the amount of toxic chemicals (pesticides?) that are making their way into the rivers. The structure of the new pipe indicates that it will be far more resilient in the case of an earthquake, as opposed to the current pipes that were forged with pig iron by some blacksmiths in the days of yore. 

Next time that there's a public presentation for this project I will be joining the mayor of Richmond **Inappropriate language removed by the Environmental Assessment Office** 

30 January, 2012 

To Whom it May Concern:

I join over 5,500 citizens in outlining my grave concerns about the controversial proposal by VAFFC to store, ship, and offload toxic Jet Fuel along the Fraser River, including the option to run a fuel pipeline up Highway 99 from the terminal.

Some of my ecological concerns:

~ the Fraser River estuary is an ecological site of global importance to
millions of birds, fish and other wildlife. Indeed, the George C. Reifel Migratory Bird Sanctuary located in the heart of the Fraser River estuary, attests to this fact.

~ VAFFC admits that jet fuel spills are a certain consequence of their proposed jet fuel plan, projecting that 50 barrels of toxic jet fuel will be spilled in the Fraser River over a 6 year period, and 1,000 barrels of toxic jet fuel will be spilled over 30 years. 

The disastrous impact of any spill at any time involving any area of the Fraser River estuary on water, birds, wildlife, soil, air and people, is simply too great a risk!

Further, the death dealing risks will impact not only the present, but also the future in ways we cannot yet fully know! 

As we know, that what happens locally has a global impact on the earth and on all life everywhere!

~ VAFFC suggests that dispersion would be a main means of restoring water, plant life, soil, and marine sediment to safety for creatures and people after a spill. Jet Fuel is heavily stabilized for movement by high levels of deadly chemicals causing long term, death dealing effects on water, soil, plants, fish, wildlife, air and people.

~ VAFFC proposal to store toxic jet fuel in 6 six story fuel tanks located less than 50 meters from the water of the Fraser River is in and of itself too great a risk to the water, land and all life forms, including humans. It is unthinkable!

~ the tankers proposed as the carriers of the jet fuel are also of great concern. The inability of tankers this size to negotiate the proposed route along Fraser River means that the toxic jet fuel would need to be off loaded onto barges, increasing the likelihood and frequency of spills and other accidents. (see Drifting Fuel Barge: January 6, 2009 at VAPOR website www.vaporbc.com)

~ Environment Canada outlined in a fourteen page document dated August 17, 2011 that this proposed plan introduces a “new and unacceptable risk” to the people and the environment of the area. Is this environmental agency being heard?

Some of my economic concerns:

~ this proposal by the VAFFC attempts to control the entire process of purchasing, moving and using jet fuel for economic gain, with  no accountability to the Cherry Point refinery or Burnaby refinery, with no accountability to citizens, environmental groups, or even to government agencies. It is a proposal that minimizes costs, maximizes profits, and takes into account no environmental or human concerns.

~ residents of the area have already experienced a significant 5-10% decrease in the property value of their homes even with the possibility of this outrageous proposal in conversation! (see www.vaporbc.com)

~ following this property trend, one can ask about the negative impact on local services and businesses, and jobs, if this proposal should move forward.


Some of my Safety concerns: 

~ the inevitability of fire resulting from explosions occurring at any point of transport in this proposed plan is also a given. 

Richmond Fire Department representatives have already indicated problems with getting to the proposed site of the marine terminal and storage tank farm. It would take at least double the standard response time to reach the site, the type of fire would not respond to a water based response, and could endanger the lives of creatures and humans. 

The intensity of the Miami Fire, March 24, 2011, melted existing on-site fire response equipment!  (see link at www.vaporbc.com) The amount of jet fuel stored and moved in this proposal makes fire a likely event.

~ all concerns voiced under environmental concerns, including the certainty of spills and fires, carry life altering and life threatening effects on people, both those living in the immediate area and living further away.

~ VACCF has not included in their proposal a description of a “hazard footprint”, an outline of the “worst-case scenario” in the event of an accident. 

Perhaps this is the most alarming indication of the attitude of VAFFC to me. Though VAFFC admits that spills are certain, it seems they do not even admit to the possibility of unforeseen accidents, much less have a plan of response.

Many concerned citizens sense here an arrogance, at the expense of the human and global environment.

Some of my social-emotional concerns:

~ as evident in the multiple concerns expressed to Richmond City Council, from citizens, residents, and experts in biology and energy (see www.vapor.com) people are already experiencing social, emotional and physical suffering in the face of the possibility of this controversial jet fuel proposal by VAFFC. 

Does VAFFC hear the people? Does VACCF care?

There are many more concerns and questions that I could raise concerning this proposal by VAFFC. 

I support the VAPOR call for a full federal environmental review of the entire VAFFC plan. 

I also support further exploration, research and study of alternative proposals. In particular, I support further consideration of:

~ proposal #3, involving the upgrading of existing pipelines

~ proposal #8, involving the largest and safest plan thus far, involving pipeline already in place and being used successfully.

I also welcome new proposals that may find creative ways to engage the expansion of jet fuel to YVR while safeguarding the land, water, creatures and people of this area and of the planet.

January 30, 2012 - COMMENTS ON: THE PROPOSAL BY THE VANCOUVER AIRPORT FUEL FACILITIES CORP (VAFFC) TO SHIP JET FUEL INTO THE FRASER RIVER ESTUARY  As lifelong residents of Richmond and owners of the Mylora Golf Courses we are writing to express our concerns regarding the VAFFC proposal to:
‘ship toxic flammable jet fuel into the Fraser River Estuary and up the south arm beyond the George Massey tunnel, where fuel barges and large panama tankers would unload the fuel into a marine terminal and then pump the fuel into six large storage tanks (80 million litres) to be built on the north bank of the south arm of the Fraser River. It then calls for a pipeline to be built across the City of Richmond farmland, roads, residential neighbourhoods, schools, recreation areas and other community features (nature park and golf course) to deliver jet fuel 15 km to YVR’.
This letter is divided into two parts. The first part presents our views on the overall project proposal and the second part explains our concerns regarding the impact the Highway 99 Pipeline Addendum will have on our property, the Mylora golf Courses.
Part One – Overall Project Concerns
As lifelong residents we treasure the Fraser River and all its richness. We treasure it for the millions of salmon that go upstream to spawn in their natal streams and billions of juvenile salmon that migrate downstream to spend a portion of their lives in the estuary and for the 70 other the non-salmonid species that are also present in the river and the estuary. We treasure the Fraser River for the diversity of life it supports, including the large populations of over wintering birds, other bird populations and wildlife that survive on the Fraser River productivity. We walk, cycle and picnic on the south, west and north portions of the dyke, we always find something new that captures our attention. We boat and fish on the river and are in awe of the richness of life on the water, in and on the large marsh areas, in the mud flats and on the shorelines which are all supported by the Fraser system. For these reason we want this valuable rich ecosystem protected for our children, grandchildren and for future generations to come.
We oppose this project for the following reasons:’
1. Building a terminal and running a pipeline 15 km through Richmond on land prone to floods and to severe liquefaction during earthquake is a risk that we are not prepared to accept.
2. The jet fuel delivery corporation has indicated high frequencies of jet fuel spillage into the Fraser during normal transfer of fuel. Spilled jet fuel is highly toxic and persistent and spreads quickly over water. Spills will have a great negative impact on the Fraser River and its’ fish & wildlife and many sensitive habitats. We are not prepared to accept this risk.
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3. The resulting aftermath of a spill, explosion or fire at the terminal and tank farm could drift into residential and recreational areas located nearby causing an impact on human life and their enjoyment of it. We are not prepared to accept this risk.

 4. Transporting the huge quantities of jet fuel on barges and panamax tankers up the Fraser will endanger property and human safety along the river. As someone who boats and fishes on the river it is hard to imagine those massive floating barges and tankers coming up the river with all the commercial and recreational traffic and debris on the river without a hugely increased safety risks for those citizens who are working or enjoying the river. We are not prepared to accept this risk.
5. A major incident on the river such as a collision, explosion, fire or spill can endanger human life and irrevocably damage and pollute the fragile environment and human habitat along the Fraser River Estuary and its shores for decades to come. We are not prepared to accept this risk.
We recognize that YVA needs a fuel source but we don’t think it should be this route – we would support a twinning or a rebuilding a larger version of the existing one.
Part Two - Impacts of Highway 99 Addendum on Mylora Golf Courses  As owners of Mylora Golf Courses, we are also concerned about the Highway 99 Addendum, which now seems to be the preferred route. As you are aware we have two golf courses one on each side of the freeway. This land had been in our family since 1938. Both of our courses, Mylora on Sidaway which opened in 1974, and Mylora on Five, which opened in 1984, have provided the residents of Richmond and surrounding areas with two well kept 18 hole executive courses to play golf on for many years.
From what we have read your studies indicate that the proposed addendum will have only a ‘minimal impact on the Mylora Golf Courses’. We have a different view.
· The Williams Road route means that the pipeline will go down the south side of our property to Highway 99, impacting our Mylora on Sidaway Course, and then from there will either turn right and go north down the East side of Hwy 99 impacting our Mylora on Sidaway Golf Course or go under the HWY 99 and then turn right and go north down the West side of Hwy 99 impacting our Mylora on Five Golf course.
· We are extremely concerned about our green belt of tall stately trees, Poplar, Birch, Alder and some Evergreens that we planted around the perimeter of our property in 1975 and 1976. These trees rim our property. The proposal to go down the William Road and along Hwy 99 on either the east and west side on the right of way will impact a total of 730 meters of our golf course property regardless of whether the route is chosen. Our trees are extremely important part of our golf courses and are irreplaceable, they:
o act as our property markers;
o provide a visual green belt;
o protect drivers from the distraction of looking at golfers and protect golfers from being distracted by traffic;  o serve as a noise barrier;
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o act as a physical barrier for the errant golf balls; and  o Provide habitat for many birds and wildlife.
· The report states that some of our trees rimming our property are on the Hwy 99 right of way. It further states that in uncleared portions ‘the entire pipeline workspace will be cleared & grubbed. Merchantable timber will be salvaged and trucked to local sawmills. Non merchantable timber will be removed.
· The report states that “from a socio-economic/socio community perspective trees removed for construction of the pipeline could likely be replaced in most cases if desired, but it may take some time for the new trees to provide the same screening and aesthetic value that currently exists”. Trees of this size cannot be replaced and would have a huge negative impact on our golf course. We would lose all the benefits identified previously. If destroyed those trees are irreplaceable. In fact up to 50% of our perimeter planting of trees could be destroyed.
· The report states that the section of the freeway adjacent to the Mylora Golf Courses is the narrowest and has the least available amount of space to carry out the construction activities from the freeway. Although the construction methodology, footprint and how access to Hwy 99 right of way is gained have not yet been finalized, we assume that this means the construction equipment may go west down the Williams Rd right of away – which will impact our Mylora on Sidaway Course on its’ south perimeter.
· If this is the case – that will be the route for haulage and flatbed trucks to get to and from Hwy 99 right of way for the purposes of hauling in and out:
§ Construction and drilling equipment;  § Debris from clearing the pipeline route;  § All the merchantable and non-merchantable timber;  § All the trench soil that cannot be stockpiled due to lack of physical space;  § New soil to backfill the trenches where soil was trucked out;  § Pipes prior to them be welded and installed; and  § Any other materials, equipment etc required.
· This level of activity would have a huge negative impact on our golfers and golf course income. Holes # 1, #2, #3, #4, and #5 are directly adjacent, mere meters away, to the proposal to go down the Williams Rd /East Side of Hwy 99 route, while Holes #1, #2, #3 on our Sidaway course and #16, #15, #3, #4, #5, #7, & #8 on Mylora on Five will be impacted with the Williams Rd /West Side of Hwy 99 route.
· Our golfing season is short, most of the golfing and therefore our revenue occurs from May through mid Oct with the peak being June through Sept. Your report states that construction is expected to progress at an average of 300 metres per week. It is not clear whether this figure include site preparation or just pipeline construction. You conclude any noise, visual impact or other negative impacts will only last for a few days possibly up to two weeks at any location.
· Given, the length of pipeline planned for instalment adjacent to our property 365 meters down the Williams Rd to Hwy and 365 meters north along Hwy 99, we believe that the noise and visual impacts on our golfers and staff from haulage and flatbed trucks coming and going all day long, of trees and bush being cut down, of holes being dug and filled, and of pipes being welded
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and laid etc all just a few meters from where golfers are trying to enjoy a game of golf will have a major negative impact on their experience.
· We expect that business will drop right off, as golfers do have alternative places to golf. Whether they return to play at Mylora again will depend on whether there is a barren mess left after the project is completed.
· The level of negative impact due to noise and visual pollution created by construction activities could be reduced if construction was to take place during non golfing prime season i.e. October to April.
· However after construction is completed we are very worried what our property will look like. Will all our tall stately trees be destroyed and will we be left with a barren mess. If so we believe we will lose a large number of golfers who will not want to golf adjacent to a highway with no green barrier.
· Post construction we will also be left with a pipeline running down the south side of our property and along the Hwy 99 on the East or West side. This is on land prone to floods and to severe liquefaction during earthquake. This is a risk that we are not prepared to accept  · The Francis Road corridor has been identified as a distinct possible alternative to the Williams Rd route. The benefit of that route as stated in your report is that it avoids a portion of the Highway 99 right of way where there are width constraints.
· The benefit to Mylora of using the Frances Rd option is that because it is north of our property and we would be left with our trees and as a result, our customers.
In summary, we support Richmond City Council motion that “Council is opposed to the transportation of jet fuel on any area of the Fraser River’. We would support a twinning or rebuilding and expanding of the existing pipeline.
If this project, as currently proposed with tankers and barges taking jet fuel up the Fraser to a storage site and then piping it 15 km across Richmond to YVR proceeds in spite of objections by Richmond Council and various citizen groups and citizens then our input on which route we prefer is as follows.
If the Hwy 99 addendum project proceeds as proposed, we would prefer to have the Francis Rd corridor used rather than the Williams Road as. The benefit to Mylora of using the Frances Rd option is that because Francis Road is north of our property we would not be impacted at all and we would be left with our trees and as a result, our customers.

As an owner of a unit at a nearby condominium complex that I purchased in 2005 for my retirement residence, I am adversely affected by the prospect of having the Proposed fuel unloading and storage facilities located only a few hundred metres from my home.  I know it poses a threat to my safety, my health, and my quality of life.

Also, as a proud resident of the best place in the world to live, I know there is too much at stake in the Fraser River estuary for the risk involved with large jet fuel tanker traffic. The high probability of accidental spillage of jet fuel and the operational toxic vapor releases at the Transfer and Storage facility will have damaging effects to the Rivers ecosystem and the air quality of the adjacent residential community, recreational and entertainment complex.

It is my belief that there is much greater risk of an incident occurring given the current methods of Jet Fuel delivery. Current demands of1,000 truck deliveries of jet fuel monthly equates to 24,000 truck movements down our highways annually. This will only increase over time.   The pipeline currently being used is more than 40 years old, technology / materials used today are far superior. 
Do we really want increased truck movements down the already stressed highways, or build a new pipeline using new technologies to safely deliver product to accommodate our #1 industry - Tourism.    

My vote is to build the pipeline, it is the safest way to move Jet Fuel through the lower mainland, and it removes 24,000+ hazards from our highways per year!!!

Thank you for the opportunity to provide feedback. I am writing to "voice" my opinion against the proposed jet fuel marine terminal and transportation of jet fuel tankers up and down the Fraser River. 

I understand that this public comment period is regarding the Highway 99 pipeline route addendum, however, this to me means that VAFFC is still pursuing the option of having jet fuel tankers traveling in the Fraser River. I do not support any pipeline option that still assumes the potential travel of these tankers and potentially endangering one of the World's biggest salmon rivers, the Fraser River, its estuary, the large populations of fish and wildlife and property and public safety. 

I am voicing my opposition alongside Environment Canada who also publicly opposed the project on the grounds of the environmental risks and the subsequent consequences on human health. Last August, Environment Canada said the current plan poses "a new and unacceptable risk to the locally, nationally and internationally important fish and wildlife populations of the Fraser River Estuary, including migratory birds and species at risk." The experts clearly have spoken against the travel of tankers up and down the Fraser River. Please listen to them.

Until VAFFC is in a position to propose a safer avenue by which to deliver fuel to YVR, I am no position to support any of the pipeline routes outlined in the addendum. 

Thank you again for the opportunity to voice my opinion.

I write to you today as one of the many members of the silent majority who would never usually take the time to support a project; that would obviously seem to be a win/win for all parties involved therefor not requiring documented support. 
I am writing to document my full support for VAFFC's proposed Highway 99 Pipeline Route and associated barge/tanker offloading facility and new tank farm project in its entirety. Obviously  a complete and thorough Environment study has been commissioned by VAFFC (completed by qualified third party independent consultants) to come up with 3 alternative routes and recommended  the Highway 99 Pipeline route as the best alignment to minimize environmental impacts during construction of the project  and any possible associated future risk do to operations of this infrastructure.
VAFFC’s proposed project will enhance environmental safety by way of replacing an aging existing pipeline infrastructure that was designed and constructed with 1960's technology. The proposed pipeline alignment project will use Best Available Technology that will reduce the risk of environmental harm by orders of magnitude over the long term as compared with the existing aging infrastructure. The proposed project would also be taking thousands of tanker trucks per year off the roads and highways that will again further protect our environment from spills.
This proposed project will also significantly reduce greenhouse gas emissions throughout the lower mainland by taking thousands of tanker trucks per year off our already congested roads and highways. Note that if this project does not move forward; thousands more trucks per year will be required to support airport operations in the future.
Ship transits through the South Fraser River are a daily/common occurrence at present. Jet fuel barges or ships transiting the South Fraser River are orders of magnitudes more benign than cargoes/commodities already transiting on a daily basis. This project would not appear to bring any further environmental risk to the river over its usual/daily/current exposure risk.
Clearly this project will benefit the local taxpayers with good, well-paid jobs during the construction phase of the work and will continue to support local employment through operations and maintenance for the next 60 to 70 years with good, well-paid jobs. This project will also support the on-going expansion of YVR employment, as without this project there is the real possibility that YVR will lose business to the huge airport expansions going on at Calgary, Edmonton and Winnipeg; this will therefore result in less potential employment her in Richmond (and less tax dollars to local/provincial governments). This is precisely the kind of project that we need to foster local employment that in turn flows tax dollars to local/provincial government to ensure that we as Canadians weather current and future economic down turns with the stability that this infrastructure project offers. 
I am the father of 2 young children and I am confident that this project will result in a cleaner environment, safer roads and lasting economic benefits for their and their children’s future.
Please proceed with this project ASAP, put our skilled workers back to work, keep our airport jobs here in Richmond, add to our tax base, all while protecting the environment!!! This project is a win-win for all.
Do not let the few that oppose this project take the rewards and benefits of the project away from the majority of the taxpayers that support the project (but remain silent), and need the benefits that this project will bring to the region for generations to come.

Maureen Fowler - Richmond, British Columbia

30 January, 2012

To Whom it May Concern:

I join over 5,500 citizens in outlining my grave concerns about the controversial proposal by VAFFC to store, ship, and offload toxic Jet Fuel along the Fraser River, including the option to run a fuel pipeline up Highway 99 from the terminal.

Some of my ecological concerns:

~ the Fraser River estuary is an ecological site of global importance to
millions of birds, fish and other wildlife. Indeed, the George C. Reifel Migratory Bird Sanctuary located in the heart of the Fraser River estuary, attests to this fact.

~ VAFFC admits that jet fuel spills are a certain consequence of their proposed jet fuel plan, projecting that 50 barrels of toxic jet fuel will be spilled in the Fraser River over a 6 year period, and 1,000 barrels of toxic jet fuel will be spilled over 30 years.

The disastrous impact of any spill at any time involving any area of the Fraser River estuary on water, birds, wildlife, soil, air and people, is simply too great a risk!

Further, the death dealing risks will impact not only the present, but also the future in ways we cannot yet fully know!

As we know, that what happens locally has a global impact on the earth and on all life everywhere!

~ VAFFC suggests that dispersion would be a main means of restoring water, plant life, soil, and marine sediment to safety for creatures and people after a spill. Jet Fuel is heavily stabilized for movement by high levels of deadly chemicals causing long term, death dealing effects on water, soil, plants, fish, wildlife, air and people.

~ VAFFC proposal to store toxic jet fuel in 6 six story fuel tanks located less than 50 meters from the water of the Fraser River is in and of itself too great a risk to the water, land and all life forms, including humans. It is unthinkable!

~ the tankers proposed as the carriers of the jet fuel are also of great concern. The inability of tankers this size to negotiate the proposed route along Fraser River means that the toxic jet fuel would need to be off loaded onto barges, increasing the likelihood and frequency of spills and other accidents. (see Drifting Fuel Barge: January 6, 2009 at VAPOR website www.vaporbc.com)

~ Environment Canada outlined in a fourteen page document dated August 17, 2011 that this proposed plan introduces a “new and unacceptable risk” to the people and the environment of the area. Is this environmental agency being heard?
Some of my economic concerns:

~ this proposal by the VAFFC attempts to control the entire process of purchasing, moving and using jet fuel for economic gain, with  no accountability to the Cherry Point refinery or Burnaby refinery, with no accountability to citizens, environmental groups, or even to government agencies. It is a proposal that minimizes costs, maximizes profits, and takes into account no environmental or human concerns.

~ residents of the area have already experienced a significant 5-10% decrease in the property value of their homes even with the possibility of this outrageous proposal in conversation! (see www.vaporbc.com)

~ following this property trend, one can ask about the negative impact on local services and businesses, and jobs, if this proposal should move forward.

Some of my Safety concerns:

~ the inevitability of fire resulting from explosions occurring at any point of transport in this proposed plan is also a given.

Richmond Fire Department representatives have already indicated problems with getting to the proposed site of the marine terminal and storage tank farm. It would take at least double the standard response time to reach the site, the type of fire would not respond to a water based response, and could endanger the lives of creatures and humans.

The intensity of the Miami Fire, March 24, 2011, melted existing on-site fire response equipment!  (see link at www.vaporbc.com) The amount of jet fuel stored and moved in this proposal makes fire a likely event.

~ all concerns voiced under environmental concerns, including the certainty of spills and fires, carry life altering and life threatening effects on people, both those living in the immediate area and living further away.

~ VACCF has not included in their proposal a description of a “hazard footprint”, an outline of the “worst-case scenario” in the event of an accident.

Perhaps this is the most alarming indication of the attitude of VAFFC to me. Though VAFFC admits that spills are certain, it seems they do not even admit to the possibility of unforeseen accidents, much less have a plan of response.

I sense here an arrogance, at the expense of the human and global environment that is beyond belief!

Some of my social-emotional concerns:

~ as evident in the multiple concerns expressed to Richmond City Council, from citizens, residents, and experts in biology and energy (see www.vapor.com) people are already experiencing social, emotional and physical suffering in the face of the possibility of this controversial jet fuel proposal by VAFFC.
Does VAFFC hear the people? Does VACCF care?

There are many more concerns and questions that I could raise concerning this proposal by VAFFC.

I support the VAPOR call for a full federal environmental review of the entire VAFFC plan.

I also support further exploration, research and study of alternative proposals. In particular, I support further consideration of:

~ proposal #3, involving the upgrading of existing pipelines

~ proposal #8, involving the largest and safest plan thus far, involving pipeline already in place and being used successfully.

I also welcome new proposals that may find creative ways to engage the expansion of jet fuel to YVR while safeguarding the land, water, creatures and people of this area and of the planet.

I am opposed to the proposed jet fuel tank farm in East Richmond and to the proposed transport of jet fuel by tankers in the south Fraser River. Neither the original pipeline through residential Richmond, nor the newer proposed pipeline along Highway 99 adequately addresses safety, environmental or community concerns, if South Fraser tankers and a Richmond tank farm are part of the proposal.  The proposed tank farm is located near the ice arena where my children play hockey and the swimming pool where they take swimming lessons.  We walk and ride bikes along the dyke. I am concerned about spills, fires, pollution, environmental degradation and deterioration in the quality of our community.  Richmond is an environmentally and seismically sensitive area, situated on beautiful waterfront that must be protected.  This project must be reconsidered. Building new industrial facilities, when options to upgrade to, or link with, existing facilities such as the ones in Burnaby or Washington State is environmentally risky and financially foolhardy.  This is the type of short-sighted planning that has landed much of the world in the state of environmental and economic mess it now finds itself.  Reduce, Reuse, Repurpose! You don't need a shiny new Tank Farm! Remember the Fast Ferry Debacle? Scale back the project, connect to an existing refinery, or upgrade the existing pipeline - before someone's vanity and ego project results in massive budget overruns and irreversible environmental damage to MY community.  Thank you.

I write to document my full support for VAFFC's proposed Highway 99 Pipeline Route and associated barge/tanker offloading facility and new tank farm. VAFFC has obviously completed a thorough Environment study (completed by qualified third party consultants) to come up with 3 route alternatives and recommend the Highway 99 Pipeline route as the best choice to minimize environmental impacts during construction and associated future risk do to operations.

This proposed project will enhance environmental safety as it will be replacing an aging existing pipeline infrastructure that was designed and constructed with 1960's technology; not to mention the fact that it will be taking thousands of tanker trucks per year off the roads and highways.

This proposed project will also significantly reduce greenhouse gas emissions throughout the lower mainland by taking thousands of tanker trucks per year off our already congested roads and highways.


Clearly this project will benefit the local taxpayers with good, well-paid jobs during the construction phase of the work and will continue to support local employment through operations and maintenance for the next 60 to 70 years with good, well-paid jobs. This is precisely the kind of project that we need to employ our citizens while returning tax dollars to government to ensure that we as Canadians weather current and future economic down turns.

Please proceed with this project ASAP, put our skilled workers back to work, while protecting the environment!!!

January 29, 2012

I have spent considerable time examining all the details regarding this project.  Although there are negative aspects to the project, as there is with any project, I feel that the positive attributes are much greater and I support it completely.  It saddens me that any reporting of the project focuses only on those opposed to the project.  It is for this reason I wanted to have my voice heard.

I am writing to oppose strongly VAFFC's proposal to build a marine tanker unloading terminal and jet fuel pipeline in Richmond.

I think it will be a huge mistake to build the marine terminal on the Fraser River. If it is built, oil spills will become a big risk to the river, the marine species, as well as birds and our residents. The unloading facilities and storage facilities, as well as the tankers will be the triple-threats to the above-mentioned. The 15-km upstream voyages of the tankers have much chance of going wrong including tankers running aground and colliding. As well other boaters and marine communities will be at risk as these tankers travel up and down the Fraser due to the increased traffic and wakes. People who used to enjoy the river and walk down to the shore will face the danger of larger rogue waves due to the tankers' wakes. The stakes are high for the salmon as well as other fish in case of any accidents as it is the main channel of the Fraser. In addition I don't quite understand why the proponents have also been ignoring the large bird sanctuary on the Delta side of the river? The increased risk and danger due to the terminal will put the economic, social and environmental costs very high in case of anything untoward happening which the proponents again are ignoring.

As well the pipeline route through Highway 99 in Richmond is no better than the previously proposed routes through the city for the following reasons. The construction of the pipeline on the busy highway will disrupt traffic and increase the risk of accidents. The new route will still run through residential neighbourhoods and commercial establishments. During construction and operation the potential for any pipeline accidents cannot be ruled out, especially since all of Richmond has a high risk of liquefaction after a major quake. It will pose a great danger to the residents and properties near the pipeline due to rupture and fire. The pipeline will run very close to Richmond Nature Park and other golf courses and community parks. Any accidents such as spills and fire will be highly damaging to these green spaces, trees, and wildlife habitats especially the Nature Park. Not to mention the environment like streams and trees will be affected no matter what the VAFFC can say to avoid in their study and during construction.

In case of accidents like oil spills during operation, the highway will be closed, further disrupting traffic. If it is after a major earthquake, as Highway 99 is a major transportation artery and needless to say an evacuation route, rescue and evacuation will be significantly hampered by the potential rupture of the pipeline and the resultant spill and fire.

VAFFC's study and addendum is also trying to hide and twist some facts, undermining their credibility and exposing their disregard of evidences against them. The study states that the City of Richmond would prefer a pipeline route through Highway 99. In fact the city council has been strongly opposing the building of marine terminal and fuel pipeline. They made it sounds like the city is neutral in opinion. In addition, in the VAFFC's addendum's Table 5A-2, it has underestimated the number of residential properties near the highway and proposed pipeline. For example, on the west side of Highway 99 from Cambie Road to No. 4 Road, the number of residential properties in the table is only three. In fact, within 100 metres the number of properties is more than 30 including detached houses and townhouses. The methodology in identifying affected properties in their study is obviously questionable and the report is likely including other figures like this in their favour. And once again their report fails to acknowledge or update the tanker terminal's impact on the environment and its risk. They could be drawing much attention to the routing and diverting away the critique on the terminal which is an equally important issue.

I suggest the VAFFC to recommence the study in twinning the existing pipeline which will produce less environmental footprint and less danger to the river and the neighbourhoods.

I would also recommend to the BC EAO to reject the application of the current VAFFC's proposal and send it back to study the twinning instead, if the VAFFC insists on building any pipelines.

I want to go on record as being against this proposal. Richmond City Council is also against it, and I believe in this case they are speaking for the public. Please listen to their voices and forget this idea.

I support this application.  There needs to be a moderization stratagy for delivering jet-fuel to YVR.  Relying mostly on the Chevron refinery in Burnaby is not acceptable for the long-term operations of YVR.  Personally, I would like to see the Chevron refinery closed.  It is much too close to residential development.

Having a new modern delivery system will increase the environmental safety factor for this type of operation.

The upgraded wharf facility must meet the new Provincial Standards for flood-proofing measures with a Flood Construction Level of 6.2 m.

The environmental assessment process used for this VAFFC project is not transparent. It does not instill confidence that due diligence will be applied to adequately address the public safety, system safety, and the protection of the environment in the Fraser River Estuary. These aspects are being looked at in a piece-meal fashion instead of in an integrated whole. The fact that the legal triggers in the BC EAO Act for this kind of project does not require a mandatory environmental assessment is most disturbing. With BC EAO, in the lead, using a dedicated staff but not experienced in dealing with a complex system like this and the short staffed Port Metro Vancouver as the delegated Federal entity to carry out the responsibilities for the Canadian Environmental Assessment Agency as well as the Department of Oceans and Fisheries, leaves much to be desired.

A complex project of this scale and with so many potential catastrophic impacts on numerous stake holders and the environment requires a Environmental Panel Review. This project also requires that the proponent demonstrate that this integrated complex of interacting systems meets or exceeds the requirements of the International Technical Commission (IEC)Standard 61508 on Functional Safety.

VAFFC does not have a Safety Management System adequately staffed needed for this project.

Neither VAFFC, BC EAO nor PVM have not demonstrated that they fully appreciate the scale of the worst case catastrophic hazards and their enormous footprints, such as a plane crashing into the jet fuel tank farm holding 80,000,000 liters of toxic and flammable jet fuel. 

A risk study for the VAFFC project must be done in concert with the Tanker Risk Study to determine the combined worst case hazard footprints and their elimination or mitigation before any informed decision can be made on the acceptability of all the risks. 

VAFFC is proposing a highly complex integrated and partially automated fuel delivery system involving Panamax tankers carrying toxic and flammable jet fuel into the Fraser River estuary and unloading them at a proposed marine terminal and storing up to 80,000,000 liters of jet fuel in a huge tank farm on the banks of the Fraser River only 400 meters from a residential and entertainment complex (in an earthquake zone subject to liquefaction) and then pumping it via a pipeline to YVR’s tank farm. A safety critical system like this must demonstrate by objective evidence that all aspects of the system including the tankers are at least two failures away from any catastrophic hazard involving public safety or the environment and that all failure and error modes - pilot, operator, management, hardware, software, communication, etc., are designed to fail safe. The fail safe design must also take into account the  interactions between people, components, systems, weather, tides and currents in the Fraser River. If the risks cannot be reduced to a level that is acceptable then the project must be rejected.

BC EAO and Port Metro Vancouver and the federal and provincial ministers of the Environment and Transportation must decide whether or not ALL RISKS, including the worst case catastrophic scenarios affecting public safety and the environment over the 60 year life of the project covering the entire integrated marine and land based system, are reduced such that they are below a specified threshold of acceptability. This must be done for Option #1 as amended by the Addendum. 

If and when Option #1 has been determined to be an unacceptable risk to public safety and the environment then a similar exercise of determining the risk case must be done for Options #3 - pipeline to Burnaby upgraded, and or #8 - pipeline extended to Cherry Point, WA.

Only the one with the least regrets amongst these options must be considered for approval. 

It is not sufficient to claim that is has been designed to be safe. The system engineers have already created arguments for why their design is safe. The effectiveness in finding safety flaws and design weaknesses by system safety engineers has usually resulted from the application of an opposite mindset from that of the developers.

The following excerpts from the seminal paper and book by Professor Nancy Leveson, Engineering Systems, MIT are worth noting:

“Certification of safety-critical systems is usually based on evaluation of whether a system or product reduces risk of specific losses to an acceptable level.” ...

“The Cullen report on the Piper Alpha loss, published in 1990, was scathing in its assessment of the state of safety in the industry [2]. The Cullen report concluded that safety assurance activities in the offshore oil industry were: Too superficial; Too restrictive or poorly scoped; Too generic;  Overly mechanistic; Demonstrated insufficient appreciation of human factors; Were carried out by managers who lack key competences; Were applied by managers who lack understanding; Failed to consider interactions between people, components and systems.”
…
“… people tend to test hypotheses in a one-sided way, by searching for evidence consistent with the hypothesis they hold at a given time [10, 13]. Rather than searching through all the relevant evidence, they ask questions that are phrased so that an affirmative answer supports their hypothesis. A related aspect is the tendency for people to focus on one possibility and ignore alternatives. In combination with other effects, this one-sided strategy can obviously bias the conclusions that are reached. “
…
“To avoid confirmation bias and compliance-only exercises, assurance (risk/safety) cases should focus not on showing that the system is safe but in ATTEMPTING TO SHOW THAT IT IS UNSAFE. It is the emphasis and focus on identifying hazards and flaws in the system that provides the “value-added” of system safety engineering. The system engineers have already created arguments for why their design is safe. The effectiveness in finding safety flaws by system safety engineers has usually resulted from the application of an opposite mindset from that of the developers. 

Whatever is included in the assurance case, the following characteristics seem important:
• The process should be started early. The assurance case is only useful if it can influence design decisions. That means it should not be done after a design is completed or prepared in isolation from the system engineering effort. If safety cases are created only to argue that what already exists is safe, then the effort will not improve safety and becomes, as apparently has happened in the past, simply paper exercises to get a system certified. One result might be unjustified complacency by those operating and using the systems.

• The assumptions underlying the assurance case should be continually monitored during operations and procedures established to accomplish this goal. The system may be working, but not the way it was designed or the assumptions may turn out to be wrong, perhaps because of poor prediction or because the environment has changed.  Changes to the system and its environment may have been made for all the right reasons, but the drift between the system as designed and the system as enacted is rarely if ever analyzed or understood as a whole, rather than each particular deviation appearing sensible or even helpful to the individuals involved.

• To make maintaining the assurance case practical, the analysis needs to be integrated into system engineering and system documentation so it can be maintained and updated. Safety assurance is not just a one-time activity but must continue through the lifetime of the system, including checking during operations that the assumptions made in the assurance argument remain true for the system components and the system environment. In the author’s experience, the problems in updating and maintaining safety assurance do not arise from the form of the assurance documentation or in updating the argument once the need for it is established, but in relating the assurance case to the detailed design decisions so that when a design is changed, it is possible to determine what assumptions in the safety analysis are involved.

• The analysis should consider worst cases, not just the likely or expected case (called a design basis accident in nuclear power plant regulation.

• The analysis needs to include all factors, that is, it must be comprehensive. It should include not just hardware failures and operator errors but also management structure and decision-making. It must also consider operations and the updating process must not be limited to development and certification but must continue through the operational part of the system life cycle.

• To be most useful, qualitative and verifiable quantitative information must be used, not just probabilistic models of the system.

• The integrated system must be considered and not just each hazard or component in isolation.”

References:

1) The Use of Safety Cases in Certification and Regulation, Nancy Leveson, MIT. - to appear in Nov/Dec 2011 edition of the Journal of System Safety. 
http://sunnyday.mit.edu/safer-world/safety-case.doc accessed 29 Jan 2012

2) Professor Nancy Leveson's MIT website:
http://sunnyday.mit.edu/safer-world/index.html  accessed 29 Jan 2012

3)Engineering a Safer World: Systems Thinking Applied to Safety (Engineering Systems), Nancy Leveson, MIT, 2011. A free online version is available from her website – 
http://sunnyday.mit.edu/safer-world/safer-world.pdf  accessed 29 Jan 2012

4) IEC 61508 Standard on Functional Safety 
http://www.iec.ch/functionalsafety/faq-ed2/ accessed 29 Jan 2012
http://en.wikipedia.org/wiki/IEC_61508   accessed 29 Jan 2012

I attended the January 29 presentation,studied all the info again, asked many questions and came to the same conclusion I have held since this project was made public. This presentation is a white wash of a very bad idea. In spite of all the safeguards they plan to put in place, their risk assessment is flawed. They have the blinders on. This is being pushed through in the name of progress and the vision for the lower mainland is doomed if ideas like this are forced upon us by certain interest groups who don't share this vision. How did something like this get this far in the first place? There are alternatives. YVR is a big part of Richmond but should not be  allowed to put our environment at unreasonable risk. This risk is beyond unreasonable. 

I am very concerned with the environmental impact and safety related to the plans for the delivery of the fuel to a new tank farm in Richmond. 
The main concern I have relates to the tanker traffic in the South Arm of the Fraser River. As a Richmond resident who lives in a home by the Sturgeon Banks, I am particularly concerned about the increased tanker traffic in the area.  Any fuel spill will put migratory birds at risk and also will put the health of the residents of Richmond at risk. 
As we live on an island that is in an earthquake zone, the location of the tank farm is also a concern. There are homes nearby the proposed location of the tank farm. There is also an entertainment and recreation area near the site. The site is by the Massey Tunnel. 
I urge you to reject the location of the fuel terminal, and to consider alternatives that do not bring tanker traffic into the Fraser River estuary. 

i grew up in richmond,spending many years practicing and racing off ferguson rd.could not help but notice the amount of fuel trucks taking product down to washington state daily.the pipeline would eliminate this dangerous practice,keeping roads and highways safer,and reduceing enormous amounts of fuel used transporting" FUEL".
new engineering and construction practices would make everyone more comfortable than relying on antiquated infastructure that is almost at the end of its lifespan.

Safety first!! No protective measures, however many as claimed by the VAFFC, can prevent a disastrous mishap. Such statements of reassurance are empty words that carry no weight. They offer no peace of mind whatsovever. We the people of Richmond will not be fooled by the deceitful and manipulative ploys of big businesses whose bottom line is corporate profits $$$$$$.

Our city officials have spoken on behalf of the people's interest. We rally behind them in strong opposition to a proposed fuel storage terminal and pipeline in Richmond.

January 28, 2012

I like this proposal.  it will remove a lot of fuel trucks on the road that i see on hwy 91.

As a resident of Richmond for 22 years I strongly oppose the plan to build a marine jet fuel offloading facility on the Fraser River. YVR needs to look into upgrading its existing pipelines and/or build a new pipeline to Cherry Point in the U.S. My concerns are as follow: 1-If there were to be a large oil spill the economic and environmental consequences would span generations. 2-Even small oil spills, which seem inevitable in our time, can cause deleterious damage to the ecosystem. 3-jet fuel is very toxic and increased river traffic seems to be a recipe for disaster. The proponents have not reasonably explained why this facility is the only option. One can only imagine it is based on money. There are more important things in life than money. 4-It's dangerous to house such a facility near condos, a sports complex, and a movie theatre 5- The river is a tourist attraction and brings joy to the community; Panamax tankers would be unsightly on the river.

Robin Silvester, the driving force behind this project, recently published an article making light of those who work towards Food Security. His argument is that because Agriculture is not a heavy-hitting economic activity, it should not be a deciding factor in future Port expansions. If Agriculture does not make his list of significant indicators, imagine fisheries and estuary wildlife!  Oh, and he is also the one who paid for the "independent" study that found his favored route to be the best route, using similar significant indicators.  http://www.bcbusinessonline.ca/profiles-and-spotlights/people/robin-silvester-port-metro-vancouver

Robin Silvester is president and CEO of Port Metro Vancouver, which has replaced the Federal Environmental Assessment agency as a partner with the British Columbia Environment Assessment agency ... which will be making the final recommendation  (according to the representative of the BCEAE which I talked to today)

Fool me once, shame on me.  Fool me twice, shame on you.

Can we please stop this sham of a process and put somebody other than Robin Silvester in charge of deciding the outcome of this project!!?

I DO NOT WANT tanker traffic along the Fraser River and a fuel tank farm on the Fraser River. The environmental risk to the Fraser River and the City of Richmond is too great. This area is ecologically fragile and would be devastated by the smallest leak. Transferring fuel via pipeline through a geological bog is courting disaster of the highest magnitude. Also considering the major traffic arterial road (Highway 99) and the densely populated areas of Richmond the pipeline would run through is, in my opinion, a recipe for disaster.  DO NOT ALLOW THIS TO HAPPEN.

It takes mere common sense to realize based on historical past that there are no foolproof safeguards against natural disasters. With the proposed fuel storage facility and pipeline in residential neighborhoods the consequences of a catastrophe when it occurs will be magnified a hundred-fold.The loss of lives and destruction of properties will be massive!! Will the VAFFC assume responsibility and be held accountable to compensate the affected communities and their families ??

It is dictatorial for giant corporations to impose their will on citizens all for economic gain at the risk of lives, safety, security and peace of mind. During these hard times we the struggling working class do not need any additional stressor in our already stressful lives. As parents we are focused on protecting our children from hazardous elements.

A firm NO to the VAFFC's irresponsible proposal to introduce danger and fear into our lives and surroundings.

January 27, 2012

I BELIEVE THAT IS GREAT.  THIS WILL HELP OUR FUTURE.  MORE WORKS MORE REVENUE TO BC.

i think this project should be approved, it's needed, safe, and provides well paying job's to our community.

I would like to add my support for this project.  I feel it is environmentally safe.  I'd hate to see it vetoed because some people think "something MIGHT happen".

I'm not opposed to responsible fuel delivery to the airport, but this plan is unacceptable! I insist that VAFFC look at better options to meet their need.  So many accidents have happened with the proposed type of delivery, it is foolhardy to think this time it will be different at YVR. Thank you for doing the responsible thing!

I support the pipeline project and understand that it will be built with the safety of the environment a top priority. I also support the jobs that this project would create and the money fed into the BC Economy.

The Steveston Community Society stands in solidarity with Richmond City Council to strongly oppose the proposed jet fuel pipeline through Richmond. Steveston is at the geographical forefront of the Fraser River, and in our view there are simply too many potential risks that outweigh any benefit to shipping jet fuel through the Fraser River Estuary to an offloading facility along the South Arm of the Fraser River. 

Steveston is a community born from the banks of the Fraser River, and continues to this day to depend on its health and well being. Environmental, public safety and economic issues related to having the off-loading and fuel storage facility and pipeline located along the river shoreline in Richmond are too great to allow this proposal to move forward.

We urge you to listen to the concerns of Richmond citizens, and of our City Council, in opposing any option that includes an off-loading facility on the South Arm of the Fraser River; a new jet fuel line through Richmond farmland and urban areas of Richmond; or an increase of trucks carrying jet fuel on City streets. Further review must be undertaken, and alternatives found to safely deliver fuel to the Vancouver Airport with minimal risk to the environment and the public-at-large.

Thank you for this opportunity to provide this feedback.

My knowledge about this project is from what I read in the newspapers.
If that information is correct then this project is a major threat to the Fraser River. Please reconsider the plan and get this fuel away from the River

I am in favor of the proposal as it stands. The matter of fuel delivery to YVR is not going away. Currently there exists a pipeline for fuel oil delivery, the YVR facility is adjucated to be one of the best in the world and is growing to accomodate increased air traffic.

Aircraft refueling is a part of that growth and cannot be ignored. I find that most of the opposition to anything to do with refined or non refined hydrocarbons is not tempered with any relevant facts specific to any proposal but instead is driven primarily by special interests who are simply against any change or amendment to that which exists. This without regard to any efficiency or economic  benefit that would be forthcoming from any upgrade as has been proposed in this example.

The project is both economical and environmentally sound. This is creating jobs and making sure we can sustain the travel capacity needed. As Vancouver grows it will be imperative to make sure a viable plan enables a smooth flow of people. Creating a pipeline is that plan!

We support the highway 99 pipeline route

TO WHOM IT MAY CONCERN.
I HAVE BEEN A RICHMOND RESIDENT FOR OVER 20 YEARS. 
I AM IN FULL SUPPORT OF THE FRASER RIVER TO YVR PIPELINE PROJECT .

MY REASONS ARE : 
1) WITH THE TECHNOLOGY THAT EXISTS TODAY RELEVANT TO FUEL HANDLING AND PIPELINE TRANSPORTATION  THE PROCESS IS VERY SAFE.
THE FUEL WE ARE TALKING ABOUT IS REFINED FUEL ( NOT HEAVY OIL )  
2) THE FUTURE OF THE YVR AS A VIABLE AIRPORT FOR AIRLINES TO USE      PROFITABLY IS AT STAKE HERE.
3) THE YVR IS THE LIFE BLOOD OF RICHMOND.

I'm in complete support of this project as it's required to meet the growing demands of the airport and Vancouver.  This will also create much needed jobs in our market, not to mention reduce the enviromental impact that trucking the fuel in from the states creates.  Presently over 30 trucks are crossing the boarder going to the airport and without this expansion those numbers will only increase creating congestion, jeopardizing safety and increasing greenhouse gases.

I think it just makes sense to build this pipeline environmentally and logistically at the moment thousands of trucks drive the fuel up from the USA to deliver the fuel to the tank farms. The demand is there and will be only get greater.  
It is saver to have the fuel  reach the tank farms via pipeline than with all those trucks crossing the border they could have an accident easier than a tanker would they are in a lot of traffic. I understand that a tanker accident would be a disaster but this is in our hands to avoid. At least this way the tankers have to follow Canadian rules and no one else is reliable to keep the environmental standards. I don’t think it is responsible to depend on others the way we do, it is our demand in fuel that makes this all necessary so I think we have to see all sides of the medal. This pipeline makes the airport more independent and I think that is a good thing. 

As a resident of Richmond, I support the Highway 99 pipeline route. The pipeline should, as much as possible, remain in an easily accessible utility corridor. In my opinion, the Highway 99 route is superior to the  previously proposed route.

Removing tanker trucks from the highway, reducing green-house gas emissions, reducing the strain on infrastructure, lowering the cost and all the while, creating much needed employment in the lower mainland. This project is must do project!

I support this project. 

Please act to disallow this disgusting and environmentally harmful monument to the economically harmful and unhealthy use of obsolete fossil fuels. While they will benefit only a few, the majority of our people will have to bear the consequences.

January 26, 2012

We vehemently oppose the proposal to allow tankers of toxic and flammable jet fuel, a marine terminal and storage tanks in the Fraser River estuary.
Vancouver Airport Fuel Facilities Corporation must NOT be allowed to change the pipeline route from residential neighborhoods to Hwy 99 right of way. The risks to public safety and the environment are too great. As with all the other pipeline leaks, it's not a matter of IF they will happen, it's WHEN.

Completely against tankers on the Fraser river.  Too much potential  for disaster.  Upgrade the existing pipeline. Have vision.
Years from now people will remember the environmental office in 2012  listened to the people.  Stand strong for future generations. 

The prospects of having a fuel line linking the YVR and a off loading facility in the area of the lower mainland is just a no brainer. As it is now I travel daily on the HWY 99 to and from work in Richmond. I have had several near misses with heavy trucking and other vehicles on route to my employment. My understanding is that at pressent there are as many as 40 plus fuel trucks daily heading to the airport. After the new facility is completed, (not easy to miss the huge tanks), we can expect an incredible increase in traffic, which I'm sure will not be around 40 but a whole lot more tankers. I for one would very definately rather see a hidden structurally engineered pipe line that would meet and exceed our pressent day restrictions on safety. Let's do the right thing and make the hwy's and people safe, and let the engineers do there job to create a safe means of transporting the fuel to the airport underground. It's definately a no brainer.

Jet Fuel is toxic to marine life and birds so l am opposed to the 80 million liter Jet Fuel Tank farm and the Marine terminal planned for the south arm of the Fraser river.If the Vaffc insists on building a pipeline through Richmond then they should continue it all the way to the refinery in Washington. Panamax tankers filled with Jet Fuel do not belong on the Fraser River , it is too narrow to shallow and there is too much marine traffic.
Pipelines are the best solutions and l encourage you to stop this process and ask Environment Canada to help you study better options.

This is not just our river it belongs to the entire eco systems and the Environment Assessment Office should know that !

We used to live around Middle Arm & North Arm Fraser River. and we really don't want anything that may have any chance to contaminate Our water.
Thanks

Regarding the Highway 99 Addendum:

Several points can be concluded from reading the Highway 99 Addendum.
1.  By limiting the topic of the addendum to an analysis of the Highway 99 route through Richmond as opposed to analysizing Option 3 (upgrading the pipeline from Burnaby) and Option 8 (the Cherry Point pipeline as well, demonstrates the complete disregard of the proponents for public safety and environmental protection.  The process has been totally flawed when safer options are not adequately presented in the assessment.
2. There are some significant plant and animal species along Highway 99  identified in the addendum  which will be impacted by pipeline construction.  There will also be disruptions and human safety concerns.  This is over a short distance.  However compared to the potential for long term and severe environmental consequences to the South Arm of the Fraser if jet fuel is barged up the river and unloaded in a residential area, the environmental and safety costs are much less with pipelines. These environmental and safety impacts have been comprehensively documented by the public and government agencies.
3. What is illustrated by the addendum is that using  the existing pipeline route (Option 3) a route along an existing transportation corridor such as Option 8, is far preferrable to barging jet fuel where there are many potential risks for jeaopardizing human health and the health and integrity of the Fraser River Estuary.

January 25, 2012

Hello,

I am writing to voice my opposition to the oil offloading facility that is proposed for the south arm of the Fraser River for jetfuel purposes. This would mean tankers bringing jetfuel into the mouth of the Fraser, where the environmental damage from a spill would be huge.

Please do not threaten this river with such a dangerous project.

Many in Richmond (myself included) are upset with the premise of this proposal and the lack of real public input to this point, as well as the potential for contamination from a spill of fuel into the Fraser River and/or Richmond.  The VAFFC has claimed publicly that this is the only viable plan and route for jet fuel to reach the airport, but many don’t see it that way and view this as only motivated by profit for the VAFFC and its members by cutting costs for fuel supply, without any regard for local residents or the environment.

I am absolutely against allowing oil tanker traffic traveling up the south arm of the Fraser River now or at any time in the future. 
I walk stretches of our beautiful river every other day and I know how devastating a spill would be. 
Can the powers that govern help find another route to get fuel to our airport? 

Oppose Panamax Tankers full of  TOXIC And Flammable  Jet Fuel Off-loaded to a Marine Terminal and 80 Million Litre Tank Farm in the Fraser River for 60 years

John McDonald - Richmond, British Columbia
The proposal is absolutely brilliant.  We need to solve the issue and this does it in the best way possible.  We need fuel for the airport for the future and this secures Vancouver as an International hub.  Calgary is doubling the size of their airport and if we do not secure Vancouver as a major stop for airlines we will soon have to fly to Calgary to go anywhere.  Look at the flights now, if you want to travel anywhere in the world half of the flights go direct from Calgary instead of Vancouver.  When I fly to Hawaii or the Caribbean from Vancouver I want to go direct, not through Calgary.  Even flights to Mexico on the way back you have an 8 hour lay over in Calgary now.  Come on people vote yes for BC and Vancouver,  this project should have already been completed by now and the citizens of BC should already be enjoying the rewards.  Larger quantities of fuel because of improved infrastructure means more airlines flying into the GVRD which means more people spending money in the GVRD which means more jobs in the GVRD.  This is a major upgrade to the old systems in place now, environmentally and economically.  Lets do it!!

I am absolutely opposed to having oil tanker traffic on the south arm of the Fraser River. I walk this area frequently and know how devastating a oil spill would be. We need to stop this plan from happening,there must be other options to get fuel to the airport.

I am writing to voice my opposition against the Marine Terminal and Fuel Tank Farm up any part of the Fraser River. I would like the Vancouver Airport Fuel Facility Corporation to consider options that are safe and responsible for the people living in this city and for the precious ecological services of the Fraser River and delta that sustains our wellbeing.  Vancouver is recognized around the world as one of the best cities to live in because of the beautiful and healthy communion between people and nature. The VAFFC have reported that spills are a certainty: a 50 barrel oil spill is likely to happen every 6 years and a thousand barrel spill, every 30 years. There is no hazard footprint analysis in their report of what the impacts of a worst case spill scenario will be, and how many years it would take for the ecosystem to recover. The fact that they will not consider human error, equipment failure and invest in authentic, independent research about worst case scenarios is, at best, proof of short-sightedness and lack of professionalism and at its worst a rejection of accountability. Environment Canada is also opposed to the project on the grounds of the environmental risks and the subsequent consequences on human health. A spill would not just poison the local fish, plants, birds, amphibians and insect species, the toxins will spread throughout all ecosystems, which comprise all the residents in the lower mainland as well.

I am concerned and upset that the topmost consideration for this project is cost and that the health of the community does not warrant a thorough and sincere evaluation of risk and the consideration of alternatives. 

The Cherry Point refinery in Washington state has an existing marine terminal, and also has a pipeline that runs all the way to Abbotsford, BC. I would like the VAFFC to research this option and I trust the Richmond City Council to make their decision based on the health, safety and wellbeing of the community they serve. 

January 24, 2012

The Fraser River is an eco sensitive area with salmon runs etc..  The impact of oil tankers would have a great impact on the environment.  
Storing large quantities of jet fuel with all the risks associated with this so close to residential areas would be irresponsible.  Then there's the issue of having to dig and install pipeline across all of Richmond makes no sense.
It seems more prudent to update the existing system of delivery!

As a long time resident of Richmond I am writing to express my
objection to the proposed pipeline from a safety point due to the  inherent risks or danger to both the marine environment  and nearby residents. There is an existing pipeline which can be  upgraded safely without putting tankers on the Fraser river. With  Vancouver and Richmond growing and taking a prominent place on the
world stage we cannot allow this project to go ahead thereby endangering us and future generations to come. Please have vision for the future and do not let this new pipeline proceed.    

To The EAO

I feel building the Jet Fuel Tank Farm  so close to a residential area is madness.  When the Jet Fuel Tanks caught fire at the Miami airport last year it melted the fire fighting equipment. This is far too risky for this area with homes  and the Entertainment Blvd shockingly close to the proposed area.

As a Air Canada Employee l can tell you that while the airport looks pretty on the outside the mechanical aspects  of the building are often not working properly .

I Fear that that same level of low standards  will  be repeated at the Jet Fuel Tank Farm and the Marine terminal. I have spoken to fire fighters who told me  the new Jet Fuel tanks in the north end of Sea Island  where promised to include safety features built in and those have yet to be built.

A Jet Fuel fire like the one in Miami is dangerous at the airport but absolutely frightening  on the south arm of the Fraser river. There is no cost saving measures that are worth putting lives in danger.

Please stop the current proposal and ask Environment Canada to do a proper Environment study so smart decisions can be made.

I feel up grading the current pipeline to the Burnaby refinery or running a new Pipeline to the Cherry point Arco refinery are much better options and in the end will save Air Canada and the other airline far more money. The airlines could build good will with the public for their  Safer approach to the needs of Jet Fuel at YVR or continue down this path of disregard for human lives.

January 23, 2012

January 22, 2012

I would like to echo the following sentiments, for myself and my family, of a previous commenter, Shahira, as they represent my sentiments so precisely:

January 21, 2012

Please abandon the new pipeline to a proposed Fraser River Marine terminal and the jet fuel farm.  We do not want transportation of jet fuel on the Fraser River.  We do not want the fuel stored so close to the river.  We do not want the fuel piped through Richmond to the airport.
Please choose some other option.  Upgrade the existing pipeline to the Burnaby refinery or run a pipeline to the Cherry Point just south of the border.
We would like to save the Fraser River for future generations.

January 20, 2012

Maximum Win versus Minimum Regret,

The "Evaluation of Fuel Delivery Options" report posted on the Vancouver Airport Fuel Facilities Corporation website to rationalize their choice of available options is not scientifically based on objective evidence. Thus it lends itself to being highly biased. Its strategy is slanted towards a maximum win instead of minimum regret. This attitude makes a profound difference on how one handles and eliminates hazards that lead to major catastrophes that can result in fatalities, injuries and property damage due to spills of toxic and flammable jet fuel resulting in fires, explosions and contamination of the water table and persistent pollution of the Fraser River Estuary.

The so called "established multi-criteria analysis" methodology used by the VAFFC consultants to assess the 4 options is very subjective and highly arbitrary. They weight each of the five "dimensions" equally, e.g., Environmental, Socio-economic, Economic, Operations, First Nations.  Within each dimension there are one to three different themes. The themes are weighed equally within their dimension. Within each theme, there can be two to five indicators. The various indicators within each theme are also weighted equally and normalized to add up to 100%. Then each theme is normalized to add up to 100% for each dimension, thus contributing 20% of the overall score. Depending upon what and how many indicators and different themes you pick you can bias the results any way you want to favor a particular option.

The consultants provide no assurance for the relative importance, accuracy and completeness of the data reviewed. Thus safety may have the same weight as aesthetics. They assume the data is factual and accurate but they take no responsibility for errors of omission or commission or fraud or misinterpretation. There was no field sampling and analytical testing. There were 15 members on the evaluation panel. It did not include any qualified system safety engineers or representations from the municipalities of Richmond, Delta, or the affected members of the public. There was no hazard analysis or fault tree provided to identify the hazard footprints of the worst case scenarios. They do not even consider the impact of fires or explosions.

The scoring is **Inappropriate language removed by the Environmental Assessment Office**  -backwards. The more questionable, low concern, incorrectly weighted, and less relevant indicators included for an option, the better chance it has becoming as the one with the "most merit".

It is an unacceptable method for picking the best option. He who controls the indicators and themes to be used, controls which option will be picked.

In analyzing the hazardous impacts on the environment and public safety, you must use a minimum-regret strategy instead of a maximum-win strategy. Instead VAFFC should have directed their consultants to do a Net Environmental Benefit Analysis (NEBA) to choose the best option by comparing the impact of spills and related incidents for each option including the original pipeline-only options to upgrade the pipe line to Burnaby refinery (#3) and extend the (Hwy 99) pipeline to the BP refinery in Cherry Point in Washington State (# 8). This would confirm that the number of accidents per ton-mile of fuel transported and the maximum severity of environmental damage are much less for pipelines than for oil tankers.

The consultants' study says that spills in the Fraser River would have acceptable impacts. This totally contradicts what Environment Canada said to the BC EAO last summer, i.e.,  "The Project would present a new and unacceptable risk to the locally, nationally and internationally important fish and wildlife populations of the Fraser River Estuary, including migratory birds and species at risk;"   This level of concern is not expressed by this new study. It goes out of its way to downplay the negative aspects of the toxic and flammable jet fuel in the estuary and goes overboard to rationalize a bad option. Unfortunately this does not even attempt to look at the safer and more environmentally friendly options. This is really very manipulative and sad in terms of objectivity and the future of our river and its fish and wildlife resources and the safety of the public.

Yours safely,

References:

"Evaluation of Fuel Delivery Options", Golder Associates Ltd., and Ausenco Engineering Canada Inc. (Report No. 1114470246-003-R-Rev0, Dec 16, 2011 (On VAFFC website) 

"Freshwater Net Environmental Benefit Analysis, Analysis Exercises", US EPA Region V US EPA, OSWER, Office of Emergency Management, 2006 

"Marine Spill Response Options: The Manual",  Scott B. Robertson, Alexis E. Steen, Robert L. Skewes, Robert Pavia, Ann Hayward Walker, 1997 Oil Spill Conference, IOSC 

"Pipelines are inherently safer to the public than other modes of freight transportation for natural gas and hazardous liquids (such as oil products) because they are, for the most part, located underground."
- Page 3 GAO/RCED-00-128 Oversight of Pipeline Safety

"From 1989 through 1998, pipeline accidents resulted in an average of about 22 fatalities per year. Fatalities from pipeline accidents are relatively low when compared with those from accidents involving other forms of freight transportation: On average, about 66 people die each year from barge accidents, about 590 from railroad accidents, and about 5,100 from truck accidents. While these statistics provide an indication of the relative safety of pipelines for transporting natural gas and hazardous liquids, the total  number of major pipeline accidents (those resulting in a fatality, an injury, or property damage of $50,000 or more) increased by about 4 percent annually over this 10-year period. Most fatalities and injuries occurred as a result of accidents on pipelines that transport natural gas to homes and businesses (primarily intrastate pipelines), while most property damage occurred as a result of accidents on pipelines transporting hazardous liquids (primarily interstate pipelines). Furthermore, pipelines that transport hazardous liquids account for nearly eight times as many major  accidents per mile of pipeline as do pipelines that transport natural gas to homes and businesses. The Office of Pipeline Safety’s data on the causes of pipeline accidents are limited to a few categories, but these limited data indicate that damage from outside forces, such as excavation, is the primary cause of such accidents."
- Page 4  GAO/RCED-00-128 Oversight of Pipeline Safety 

------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------ ------  The following table clearly summarizes the relative risk of various modes of transportation

Table 1: Relative Occurrence of Transportation Accidents Per Ton-Mile of Oil Transported, 1992-97


Event        Pipeline*    Rail    Tank ship     Barge     Truck
Fatality        1.0        2.7      4.0         10.2       87.3
Injury          1.0        2.6      0.7          0.9        2.3
Fire/explosion  1.0        8.6      1.2          4.0       34.7

*The rates of occurrence are based on a value of 1.0 for pipeline. 
Values of less than 1.0 indicate a better safety record.
Source: Association of Oil Pipelines.
- Page 10 GAO/RCED-00-128 Oversight of Pipeline Safety 
In PIPELINE SAFETY -The Office of Pipeline Safety Is Changing - How It Oversees the Pipeline Industry, United States General Accounting Office - May 2000  

January 19, 2012

Letter from Environment Canada to EAO:

"The conservative risk assessment is noted in terms of the likelihood of a spill; however, we do not agree that the overall Project assessment is conservative"

"the department does not share the same confidence as the  proponent that the spill response plan would effectively and reliably protect the high ecological values and sensitivities of the estuary. Under ideal conditions spill recovery is challenging, with  inevitable loss of product."

"The Application states that, ‘It is estimated that most fuel entering the marsh woulddissipate in a matter of days to weeks but some residual fuel may remain attached to the vegetation canopy, exposed root masses and peat for months’, whereas the response provided in the Tracking Table states that, ‘Persistence is likely…’. These statements are inconsistent, and highlight the scientific uncertainties and associated risks surrounding the impacts of Jet-A fuel on the receiving environment."

"To presume the birds would utilize alternative habitats/food  without credible evidence is unwarranted speculation that constitutes an unacceptable population-level risk to at least one migratory species, the Western Sandpiper."

"Environment Canada cannot support the proponent’s assertion that the biofilm is resilient"

"Environment Canada does not agree with the principal conclusion of Supplement 3:
To conclude, in the highly unlikely event that a worst-case spill of jet fuel was to occur in the Fraser River (as presented in Chapter 19 which also conservatively assumes no mitigation canbe applied to reduce the volume or reach of a spill), the toxicity of dissolved constituents in the water would not be a concern for aquatic life."

"Environment Canada notes that Supplement 4 does not address the potential toxicological consequence(s) to sediment from a spill of jet fuel, or the toxicity of the fraction, if any, that adheres to particles in the water column as opposed to dissolving."

"Although the proponent notes in this Supplement that there is an almost complete lack of understanding of the nature and the toxicology of jet fuel, the toxicology issues are not subsequently addressed for sediments."

"At this time, Environment Canada does not have the same level of confidence as the proponent in a spill response plan to effectively and reliably protect the high ecological values and sensitivities of the Fraser River Estuary."

Letter Dated: August 17, 2011

And these are only a few quotes from the letter.  To me it's clear that Vancouver Fuel Facilities Corporation (VAFFC) is cutting corners (not dotting their i's and crossing their t's) on the required studies and there is clear bias and intent to misinform.  How is anyone supposed to have any confidence in the project based on these gross errors?

The VAFFC delayed 8 months to determine that they could put the pipeline down Hwy 99 (this is an obvious route and should have been in the initial submission), but then states that they result to move the pipeline routing.  So are you saying that as soon are VAFFC gets approval they can basically make any change they want by adding that quick note?  The Tanker Risk assessment is conveniently delayed until after this comment period closes. Why are are we commenting on something that is not complete? Get your homework done and submit completed proposal.  Where is hazardous footprint study and emergency response from commercial space and residential 140 unit condo complex 350 meters from this proposed site?

I do not support any bulk fuel transport in the Fraser River estuary!

January 18, 2012

I am writing to register my strong opposition to the proposed pipeline.  I object on so many levels it is difficult to know where to start.  I am an avid bird enthusiast and realize the importance of the Fraser Delta to the migrating bird populations. Oil spills do happen no matter how many safeguards we put into place.  We already have too much oil spillage from boats that presently use the river.  Also I strongly object to the storage 'farm' that is proposed alongside the Fraser.  In the case of earthquake, tsunamis, and rising water levels all make this site environmentally at risk.  I believe the airport fuel delivery that is required should be delivered by twinning the existing route.  It may cost more initially but it is time we started to realize what nature, provides for us in innumerable ways and we need to value its contribution in dollars and cents as well.  We would probably then have no difficulty removing the proposed pipeline from running anywhere near major waterways.  Please also register my NO, NO, NO to oil tankers on the West Coast.  We are one of the last if not the last remaining marine 'breadbaskets' for the rest of the world.

The Highway 99 proposal is preferable to the Williams Road/ Shell Road proposal originally submitted to EAO spring of 2011.The tank farm location positioned on the banks of the Fraser River to service the pipeline is however a potential disaster.Newer aircraft are very fuel efficient.The need for increased fuel capacity at YVR is questionable.
The existing fuel supply to YVR can be expanded and is an option.
This project, if built could connect to an existing source at Blaine WA. resulting in no requirement to construct the Fraser River tank farm. Thank you for this submission opportunity.

January 17, 2012

It is too risky to have a pipeline.  Projects of this kind have proven to be less than successful and detrimental to wildlife and people alike.  And, with the industry players usually preoccupied with minimizing responsibility as their contingency plan, I am surprised that these sorts of projects continue to be accepted by elected governments who are supposed to have its citizens interest at heart.  To add insult to injury, more often than not our tax dollars are being used to help with cleanups (whether by subsidies, tax breaks or commissioning projects that act as satellites to industrial projects--before, during or after implementation).

It is true that our species has made some spectacular technological advances.  It is also true that we have arrived at a crucial tipping point in the safety and well being of the environment and all who depend on it--and yes, we all depend on it.  We cannot, in all good conscience, continue down this well worn path: where economics trumps healthy living conditions for all concerned.

The proposal for fuel storage and offloading at the mouth of the Fraser River is foolish and dangerous. The complex tidal currents would spread potential fuel spills throughout the Fraser River ecosystem. This river is already under too much pressure, and yet it continues to provide wild salmon for human consumption. I am deeply concerned for the salmon stocks, and the other wildlife that depend on the Fraser River for survival.

It's impossible to prevent contamination once fuel is being offloaded and stored in an area. Even small leaks in fuel will lead increase the contaminant load in the Fraser River - further weakening the immune systems of the wildlife there.

I am so tired of filling out these environmental assessment forms for the most inane and ridiculous proposals. Come on, jet fuel storage at the mouth of the Fraser River?!? People are demanding that our governments protect the natural systems that we are a part of. WE CANNOT LIVE WITHOUT NATURE BECAUSE WE ARE NATURE. It is demoralizing to know that our government does not understand this, or worse, doesn't care. 

What's more: we don't want an oil and coal based economy in Canada. We can do so much better. NO MORE OIL. NO MORE COAL. NO MORE PIPELINES. NO MORE COAL MINES.

I am particularly concerned about any further oil delivery infrastructure that will be placed on unstable ground.  There is high risk of a major earthquake in the area and it is understood that the expected earthquake will liquify regions such as Richmond and Delta.  Why would there be a serious consideration of a submerged oil pipeline which would surely break in the case of a large earthquake, spreading oil at a time when emergency services would be sorely taxed.

I am a Vancouver resident, and I am strongly opposed to any plan that will introduce more tankers carrying dangerous fossil fuels into our Harbour.  Spills are inevitable.  Technology fails and human error can never be eliminated.

The Fraser river sockeye run has already been decimated from the cumulative effects of shortsighted development and resource management policies.  I fear that more tankers and the pollution they will inevitably bring, could deal a fatal blow to this historic resource.  Can you imagine a jet fuel spill at the mouth of the Fraser when salmon are returning to spawn?

It is also important to note that the proposed project would be developed on unceded Coast Salish territories--specifically the Squamish, Tsleil-Waututh and Musqueam Nations--and I feel it is of paramount importance that these communities have a meaningful role in this decision.

January 16, 2012

Would this mean tankers bringing jetfuel into the mouth of the Fraser River?  We know the environmental damage from such a spill could be enormous.  Thanks for your consideration

The river estuary that is threatened by potential jet fuel accidents funnels all the fish migrating to and from the greatest salmon river in the world. Safeguarding the Fraser Estuary is important for food security, ecology, and our identity as British Columbians. That is the core of the jet fuel port issue, and the airport fuel company continues to skirt it with the Highway 99 modification.

What is the tradeoff for adding another threat to the wild salmon of the Fraser River at a time when the Cohen Commission is struggling to grasp the existing threats so that the decline of sockeye in the Fraser can be reversed? The supposed benefit is only to the company, which can save money when there is greater competition among its suppliers. 

However, if the environmental risk to food security, ecology and our identity (our British Columbia culture) is expressed in dollars, the financial benefit will be quite different in the big picture.  We are probably looking at a relatively small gain for the fuel company at a relatively large expense in the broad range of environmental effects. 

Even if these considerations spill beyond the explicit mandate of the environmental review, there must be latitude for the project reviewers to encourage the fuel company to pay a more fitting amount of attention to the larger good.

When will we come to grips with the realities that  1.  We live on a finite planet with finite resources?
2.  Expansion, especially of this scale, is an obsolete and suicidal strategy?

Are you people crazy? How on earth could you even contemplate allowing jet fuel tank farms to be located on the Fraser River estuary? The risk to the river is far too great. There WILL be an accident. Why would you take a chance on completely poisoning the mighty Fraser River? Marine terminals are far too iffy. If you think we have trouble with spawning salmon now.......

January 14, 2012

The hazard footprints for worst case secnarios causing injury and death are missing for the pipelines to and from the jet fuel tank farms. It is vital that these hazard footprints are provided for both the pipelines and tank farms and in combination. They must be made public to assist in an adequate Safety and Environmental evaluation of the VAFFC proposal and its addendum. 
For the pipeline and tank farm pool fire scenarios, you can assume that an incident flux (a measure of thermal radiation level per unit time per unit area) of approximately 1,600 British Thermal Units (BTU)/hr-ft2 would cause second degree burn injuries on bare skin and that an incident flux level of 3,200 BTU/hr-ft2 would cause third degree burns that may cause death. These two levels are based on experimental data and are typically used in determining injury and fatality hazard footprints(FEMA, USDOT, and USEPA, Handbook of Chemical Hazard Analysis Procedures, 1989). An exposure of greater than 3,000 BTU/hr-ft2 of heat flux would cause any buildings that are not fire resistant to ignite. [page 8, "14c. Safety Technical Report - LAX Master Plan, December 1997, Camp Dresser & McKee Inc."]

It does not matter how many reasons and/or excuses you use to try to build this pipeline.  It is and always will be, unacceptable to we who live in the surrounding areas.  There is no acceptable risk to spoiling our Fraser River or our city lands.

Our answer is still NO!

To The BCEAO
Re VAFFC Jet Fuel Proposal

Hwy99 Option
The revised Proposal for the delivery of JET FUEL to the Vancouver international airport is very disappointing.
I feel with all the EXPERT advisors hired by the VAFFC that a more well thought out plan was possible.Clearly the evidence has been manufactured in such a way to lean towards the Marine terminal and the 80 million liter Tank Farm originally proposed for the south arm of the Fraser River.British Columbia deserves a fair process by an independent source that can be trusted to thoroughly look at all the options available to make the right choice not simply the most beneficial choice for YVR.The City of Richmond also feels that a independent study is prudent for this critical issue.
The risk to the environment and the communities along the Fraser River is just too great and totally unnecessary when better options are available.
I can only support the Jet Fuel pipeline on the Hwy 99 corridor if it keeps on going , all the way to the Cherry Point refinery just over the Canada ,USA border. This option was number 8 in the original VAFFC study and has not been given the proper scrutiny by the experts.
The Cherry point refinery  is a very successful port with an incredible safety record. Using this option would eliminate the need for Panamax tankers loaded with Jet Fuel on any part of the Fraser River and be the logical choice for the revised pipeline .
Environment Canada wrote  August 17th 2011 that  " The Project would present a new and unacceptable risk to the locally, nationally and internationally important fish and wildlife populations of the Fraser Ricer Estuary, including migratory birds and species at risk...."
On Jan 13th 2012 the cruise ship Concordia ran aground in Italy and this accident is a good reminder of just how quickly things can go wrong. We must protect the Fraser River and we are depending on the Environmental Assessment Office to do 6thier job and say NO to this proposal

January 13, 2012

January 12, 2012

There will be more hazardous oil tanker traffic in the Salish Sea, Burrard Inlet and the Fraser River Estuary if any of the options 1(the current application), 2, or 4 studied by the consultants for the Vancouver Airport Fuel Facilities Corporation (VAFFC) come to fruition. (Evaluation of Fuel Delivery Options by Ausenco Sandwell and Golder Associates, Dec 16, 2011).  The report is available on the VAFFC website. Option 3 is the only one which eliminates oil tanker traffic within the Fraser River Estuary. Thus the Addendum to the original VAFFC application is unacceptable since it does not protect the Fraser River Estuary from high consequence events.

The VAFFC application along with its Addendum has not provided a Safety Case that addresses the impact of the worst case scenarios and the related combined hazard footprints for fire, explosion and contamination at the fuel farm, marine terminal, oil tankers, barges and pipelines.

The following scenarios that must be considered are adapted from:
"In December 1997, Camp Dresser & McKee Inc. conducted a hazard analysis of the potential for fire and/or explosion at the LAXFUEL Fuel Farm. As a minimum, the following worst-case scenarios for fire or explosion at the fuel farm facility were considered."(page 7 of 14c. Safety Technical Report - LAX Master Plan, December 1997, Camp
Dresser & McKee Inc. )


♦ Scenario 1: This scenario assumes that a single tank in the 80,000,000 liter tank farm in the largest containment area were to rupture and the fuel were to subsequently ignite. The berm of the containment area is assumed to remain intact.
♦ Scenario 2: This scenario could be initiated from Scenario 1. If the fire was not immediately controlled, the heat caused by the contained flames could result in the rupture (with possible explosion) of one or more of the other tanks within the bermed area.
♦ Scenario 3: The impact of a large aircraft crashing into the fuel farm or an oil tanker at berth or a pipeline or a collision between vessels or with obstacles in the Fraser River estuary could be expected to cause a similar but larger event. With such an occurrence, the secondary containment would probably be damaged, and unable to control the released fuel.
Under this scenario, burning fuel could flow along the ground surface to the storm drain system surrounding the facility and into the Fraser River Ignited fuel might flow within the system, creating thermal damage, although there would be little risk of  explosion. It is likely that a fire within the storm drain system would quickly burn out due to a lack of oxygen.
♦ Scenario 4: An incident during off-loading of a tanker or barge causing and fire and explosion could spread to the tank farm and a fully loaded tanker at berth. The heat caused by the flames could result in the rupture (with possible explosion) of one or more of the other storage tanks or the berthed oil tanker  

In this hazardous and toxic jet fuel delivery project it is folly to only do a voluntary screening level environmental assessment without a rigourous and thorough safety case conducted by System Safety Engineers, that addresses the hazards of the jet fuel tankers navigating and berthing within the Fraser River Estuary, unloading at the marine terminal and filling the tank farm and transporting the hazardous and toxic jet fuel via pipeline to YVR.

January 11, 2012