DCSIMG

Environmental Assessment Office

Collected Public Comments for Aurora LNG Digby Island Project

January 16, 2017 to March 9, 2017

Comments will be available on this page until March 23, 2017 and after this date all posted comments will be available through the Environmental Assessment Office Project Information & Collaboration (EPIC) application.

March 9, 2017

Dodge Cove Improvement District comment on Aurora Application Calculation of NO2 concentrations over residential areas - Kent, Washington

Public Comment Submission

Personal Information Withheld - Victoria, British Columbia

public comment submissionpublic comment submission

Joint comment on Aurora LNG Application by T. Buck Suzuki Environmental Foundation, Prince Rupert Environmental Society and United Fishermen and Allied Workers Union- UNIFOR

Summary of comments on Aurora Application

SkeenaWild Conservation Trust - Terrace, British Columbia

Public Comment Submission

Personal Information Withheld - Prince Rupert, British Columbia

Public Comment SubmissionPublic Comment SubmissionPublic Comment SubmissionPublic Comment Submission

Personal Information Withheld - Prince Rupert, British Columbia

submission

Personal Information Withheld - Dodge Cove, British Columbia

Report sheds new light on LNG blast in Algeria

Apr 14, 2004 02:00 AM

A newly released document provides important insights into the chain of events that led to the January explosion of a LNG facility in the African nation of Algeria. Several scientists who specialize in LNG research said the document indicates that a similar accident could occur at LNG plants like those proposed for Mobile Bay and elsewhere in the United States.

Initial reports blamed a faulty steam boiler for the massive explosion and fire at the government-owned Skikda, Algeria, plant. Those reports were incorrect, according to the new document presented by Sonatrach, owner of the destroyed LNG plant. A display titled "The Incident at the Skikda Plant: Description and Preliminary Conclusions" indicates, instead, that a large amount of liquid gas escaped from a pipe and formed a cloud of highly flammable and explosive vapour that hovered over the facility. The cloud exploded after coming into contact with a flame source.

The exact nature of the cloud is likely to be sharply debated as industry advocates and even a number of independent scientists have argued that an LNG vapour cloud, if it were to form, would be relatively small and would not explode. Most of the 27 people who died were killed by the force of the blast, according to the report. The report lists a "few casualties by fire," though the fire burned for eight hours.

The Sonatrach report was presented at an international LNG conference held in the Middle Eastern nation of Qatar in late March. Officials with the US Department of Energy (DOE), the Federal Energy Regulatory Commission (FERC) and ExxonMobil declined to discuss the document with the Mobile Register.

In the days after the accident, officials with the DOE, FERC and ExxonMobil, as well as Alabama Port Authority director Jimmy Lyons, stressed that the explosion seemed to be entirely related to a malfunctioning boiler. LNG plants in the United States, they argued, would not have boilers like the ones used at the plant in Algeria, so a similar accident could not occur at an LNG facility in America.

But several scientists who examined the new report told the Mobile Register that the type of accident described in it could occur at an LNG facility in this country, regardless of the type or number of boilers present. Almost any source of ignition, from a cigarette lighter to a pilot light, could have ignited a vapour cloud.

ExxonMobil and Cheniere Energy have both proposed building LNG facilities on the shores of Mobile Bay, close to residential neighbourhoods. Both companies said their facilities would not impact nearby residents, even in the event of a catastrophic accident. ExxonMobil would place its plant on land owned by the Port Authority at the former Navy home port; Cheniere would build on Pinto Island.

"I think this tells us that dealing with LNG is a tricky and dangerous business," said James Fay, professor emeritus at the Massachusetts Institute of Technology and one of the nation's leading LNG scientists. "It was apparently a very large gas leak that went on for a while before the explosion. That certainly doesn't give you a lot of faith in their gas detection equipment, with all this gas leaking out. I guess this means sometimes that equipment doesn't work."

Fay said the failure may have important implications for the siting criteria used by FERC when granting permits for new onshore LNG facilities. In particular, Fay said, FERC requires only that companies prove they can contain a vapour cloud and fire resulting from a 10-minute leak of LNG at the plant.

"The fire burned for eight hours, and that fact does seem unusual. I would have thought it would have burned up more quickly," Fay said. "Maybe there wasn't anyone to shut the equipment down. Maybe all of the workers perished in the blast, and the equipment just kept running, spewing LNG out so it just kept burning and burning. ... FERC's rules just say a company would have a 10-minute leak. That's it. But clearly this one kept leaking for a much longer time period."

Fay and others said the report is missing a critical piece of information: Whether the fuel that leaked from the pipe at the plant was LNG or a LPG, such as propane, or some combination of both. LNG and LPG were present in some quantities at the Skikda plant, the report said, though the damage to the facility was so extensive, it may be impossible to know exactly what kind of gas formed the vapour cloud.

Few would be surprised if LPG proved to be the culprit -- the vapours are known to be highly volatile, and prone to explode when exposed to flame. Pure LNG -- which is almost 100 % methane -- usually is thought to explode only in confined spaces, such as a building or the hull of a ship, according to scientists.

In presentations made in Mobile by the DOE, FERC and ExxonMobil, officials stressed that "LNG does not explode." They also said that if an LNG vapour cloud formed and was somehow ignited, the flame would move through the cloud so slowly that a person simply could walk ahead of it and stay out of danger.

While some scientists agree that may be true of "pure" LNG, which would be entirely methane, the scientific literature suggests that much of the LNG shipped to facilities around the country typically is contaminated with some quantity of more explosive "LPG" gases, such as propane.

A 1980 Coast Guard study titled "LNG Research at China Lake," states that LNG imported into this country is often far from pure, and it reveals that vapour clouds made from "impure" LNG actually explode as readily as the highly volatile LPG. When natural gas is super-cooled and turned into a liquid, as much as 14 % of the total cargo shipped as LNG may actually be LPG or other hydrocarbon fuels, according to the Coast Guard report. Natural gas contains these other fuels when it is pumped from the ground.

LNG containing these so-called "higher hydrocarbons" is known as "hot gas" and has a higher energy content than pure methane. The Coast Guard report reveals that vapour clouds of LNG containing at least 13.6 % of these other fuelscan detonate just like pure propane gas. The agency concluded in its report that this deserves "special consideration, as the commercial LNG being imported into the US East Coast has about 14 % higher hydrocarbons."

Several scientists said they were unaware of the Coast Guard's report. They also were unaware that LNG arriving in the United States sometimes contained significant quantities of other gases, such as propane, butane and ethane. They agreed that in light of the Skikda incident, statements made by the LNG industry and federal officials regarding the explosive potential of LNG vapour clouds may need to be re-examined.

"It's pretty clear that this was not sabotage," Fay said, discounting rumours that terrorists may have tried to damage the facility. "I think there is a strong suspicion that the explosion which occurred could have been an LPG explosion or an LNG explosion. If it were LNG, this would be the first major LNG explosion that occurred anywhere." It is also one of the largest vapour cloud explosions on record, according to scientists.

"The fact that there was a vapour cloud is huge," said Bill Powers, an engineer based in California who has studied LNG terminals, siting issues for both onshore and offshore proposals. "We don't know if it was an LNG vapour cloud or an LPG cloud or a mix of both, but, either way, it means it is the kind of accident that could happen here."

Powers pointed out that several terminals proposed for the United States would deal with both LPG and LNG. At the terminal proposed for Long Beach, California, for instance, Powers said the LPG tanks would be right next to the LNG facility. Powers also felt it was noteworthy that Halliburton had conducted a major renovation of the Skikda plant in 1999, updating all of the key safety equipment and computer systems.

A Halliburton website touts the revamped LNG terminal as a model of modern American workmanship.

"Halliburton is pleased to announce that its recently completed LNG Revamp Project at Skikda, Algeria, has passed all its performance tests," reads the company news release announcing the project's completion. "KBR's work included extensive revamp of the three LNG trains and associated utilities and auxiliaries and a complete revamp of the complex's electrical power and control systems. ... Over 9,000,000 construction man-hours were expended."

The three separate LNG regasification plants or "trains" that were revamped by Halliburton were destroyed in the explosion.

Powers said Halliburton's engineers had missed a weak link in their safety planning for the facility.

"That highlights the importance of putting these facilities in places where, no matter what, people will not be at risk. If a company like Halliburton missed a scenario that could cause this, that tells us that we cannot account for all possible accident scenarios at LNG facilities," Powers said.

"Halliburton would have exhaustively checked out every possible accident chain of events and accounted for it, countered it," he said. "They would do that before they give it a clean bill of health. That's how they operate. They must have simply missed this accident possibility."

Donna Polgar - Ladysmith, British Columbia

Please stop using our ocean and coastline to facilitate your LNG. There's more to life on our coast than supplying Asia with this product. Think about our ocean wildlife and the food we take from this wonderful ocean. Let's not let greed take over Canada.

Personal Information Withheld - Prince Rupert, British Columbia

No LNG on Digby Island or any where in B.C.

Personal Information Withheld - Prince Rupert, British Columbia

The location is just too close to Dodge Cove. If Christy Clark had a vacation home there I'm sure this site would not have been suggested by the province. You're going to site a major industrial project a few hundred meters away from one of the most charming and historic communities on the coast. What is going to happen to people's property values? Who is going to want to move there with an LNG terminal literally in their backyard?

Digby residents will also be sucking in the majority of emissions from this terminal. The airshed survey released last fall was unequivocal in that regard. You can't expect parents to raise children in that kind of environment. How do you plan to mitigate those impacts? How do you plan to protect those who can't afford the loss they'd take on their property from the long-term affects of breathing contaminated air?

However, no matter what is said here, by me or anyone else, there's no doubt in my mind that the government will simply allow this project move forward, effectively destroying this wonderfully unique little community. It's a travesty and I will never forget what has been done to these good people's lives and their hopes for their futures.

Personal Information Withheld - Vancouver, British Columbia

How is it that this proposed lng terminal can be built 0.5 of a kilometer from the boundary of the communiy of dodge cove when the national standards say a facility of this size must be a minimum of 3.5 kilometers distance from populated areas?

Personal Information Withheld - Dodge Cove, British Columbia

"A report by the IoMosaic Corporation – "Understand LNG Fire Hazards" found that the maximum impact hazard footprint of a 200,000 m3 LNG tanker will result from a pool fire leading to a fatality limit of 50 percent at a distance of 3.7 kilometres from the leak."

http://www.safetybeforelng.ie/licensing/lngterminal/kraterminal_preoral.htm

Nexen says that Prince Rupert will be 3 km away from Aurora LNG, while Dodge Cove will be 1/2 km away. Nexen will have Q-flex LNG carriers. "The capacity of a Q-Flex vessel is between 210,000 m3 and 216,000 m3.[5] Until the entry into service of the Q-Max-type carrier, it was the world's largest LNG carrier type with a capacity of 1.5 times that of conventional LNG carriers."

https://en.wikipedia.org/wiki/Q-Flex

I find the entire concerns and comments in the following report to be relevant to the situation here in Canada. Again, I feel it is the duty of the Canadian government to fully research the information from other existing communities on the relevant impacts that would be felt here on Digby Island and in Prince Rupert Harbour. I feel that these valid concerns and this information should be looked at.

14th November 2007

An Bord Plean�la,

64 Marlborough Street,

Dublin 1.

Submission to An Bord Plean�la regarding the Proposed Liquefied Natural Gas (LNG) regasification terminal located on the Southern shore of the Shannon Estuary in the townlands of Ralappane and Kilcolgan Lower, County Kerry (reference PL08 .PA0002 and PC 08.PC0002).

Dear Sir/Madam,

This submission is being made by nearby residents of the proposed LNG regasification terminal and by people with close family and economic ties to the area. We are totally opposed to the planning application in its present form and ask that An Bord Plean�la refuse planning permission to Shannon LNG.

It must be highlighted that there are serious environmental, safety, economic, residential-amenity and other concerns surrounding the proposed LNG terminal in Tarbert parish, which have not been raised at all to date. These concerns may be overlooked by the general public until it is too late as the decision by An Bord Plean�la on whether or not to grant planning permission will already have been made. This is because the new fast-track planning process allowed for this application means that all environmental, safety and development issues are being examined in parallel and by different government bodies without the right of appeal in the planning process that would exist if the application was first submitted to Kerry County Council. This is unacceptable because it is depriving the public of meaningful or effective participation in the planning process due to information not being disclosed in a timely manner and therefore removing the transparency that must continue to exist in the planning process. This is contrary to both the Planning and Development Act 2000 and the EU EIA directive. For this reason we herby insist on being allowed to make more submissions once this information has been obtained.

The primary concern is the lack of safety for nearby residents due to the fact that they live too close to the proposed site. Conservative scientific evidence provided below shows that it is unsafe to live within 3 miles of the site. This area covers the villages of Ballylongford, Tarbert and Killimer in County Clare. More seriously, the limited QRA undertaken by Shannon LNG itself admits categorically that a vapour cloud from a leaked tank could travel as far away as 12.4 kilometers before being ignited (page 32). This will mean that the Kerry towns and districts of Asdee, Moyvane and Beal, the Limerick town of Glin and the Clare towns of Kilrush, Moyasta, Killimer, Knock and Kilmurry McMahon, as well as surrounding countryside, are in the possible fallout zone. This is from Shannon LNG's own research.

This will therefore also prevent further use being made of the rest of the land bank due to the danger posed to people working nearby, if safety standards are in fact implemented.

The most serious environmental concern is that up to 100 million gallons of chlorinated seawater will be pumped into the estuary daily, causing serious environmental damage to the eco-system of this SAC area. The withdrawal and discharge of huge volumes of seawater would affect marine life by killing ichthyoplankton and other micro-organisms forming the base of the marine food chain unable to escape from the intake area. Furthermore, the discharge of cooled and chemically-treated seawater would also affect marine life and water quality.

The most serious economic concern is that the gas-industry's own standard-recommended exclusion zone of 2 miles around an LNG tanker will stop shipping – including the Tarbert-Killimer car ferry - in the estuary every time an LNG tanker is in the area (and Shannon LNG plan up to 125 tankers a year) and prevent marine use of the rest of the land bank – if those safety standards are implemented.

Finally, whereas the developer emphasises that it is in the national strategic interest to have an LNG terminal in Ireland, we are of the opinion that only a strategic interest in LNG as another strategic alternative source of gas in Ireland has been accepted and that there has been no acceptance of the strategic need for an LNG terminal if no suitable site in Ireland is found. This distinction is very important because this need for LNG is already being met with the construction of the LNG terminals in the UK which can then provide LNG to Ireland via the existing gas pipeline from the UK. It must also be noted that the developer, in any case, does not guarantee supply of LNG via Tarbert. What is proposed is no more than a private storage and transhipment facility albeit on a very large scale. It does not purport to offer any strategic benefit to the country, nor in reality does the country gain any strategic benefit from it. On the contrary, it undermines the stated government policy. It does so in a number of respects - in particular by entirely prejudging the outcome of the all-Island study and the strategic goal No. 2 in the government's white paper on delivering a sustainable energy solution for Ireland.(See 17 below). On that basis alone the application is clearly premature and should be refused.

The methodology used in this submission is to support each topic with data from published scientific reports, governmental reports, decisions and strategy documents, statutory regulations (both Irish and European) and from standards produced by the Gas industry itself. Any reference to non-scientific based claims will be clearly stated. Data was collected initially by various members of the association individually. This was then followed on by a visit to the Dragon LNG plant at Milford Haven in Wales on October 13th 2007 where the views of concerned residents were noted. Information was raised since then in contacts with Shannon LNG at their office in Listowel on October 15th, with other local residents in Tarbert in meetings with Shannon LNG representatives on October 18th and October 29th, and with various governmental, scientific, academic and voluntary organisations in Ireland and abroad. Our concerns were taken seriously by one and all but many questions were left unanswered. The overwhelming feedback has been that a submission of these concerns needs to be made to An Bord Plean�la,

For the reasons given below we submit that the Bord is obliged to refuse the application. We accept that the Bord may of course take a different view. While we reserve our rights to challenge such a view if necessary we make any comments on conditions that could be applied by the bord if it grants permission to the developer entirely without prejudice to our over-riding contention that this application should be refused.

STATUTORY REGULATIONS:

� Planning and Development Acts 2000 – 2006. This includes the Planning and Development (Strategic Infrastructure) Act 2006

� EU Habitats Directive 92/43/EEC On the conservation of natural habitats and of wild fauna and flora– as 25 acres of the site is in a Special Area of Conservation (SAC)

� EU 1998 Aarhus Convention Directives, Directive 2003/4/EC and Directive 2003/35/EC – on the right of the public to be informed on the environmental impact and being provided with the opportunity to make comments and have access to justice

� EIA directive 87/337/EEC as amended by Directive 97/11/EC - concerning the effects of certain public and private projects on the environment, the precautionary, preventative-action and polluter-pays principles

� Seveso II Directive 96/82/EC as amended by 2003/105/EC – for placements of hazardous sites

� EU Water Framework directive 2000/60/EC

� Kyoto Protocol

� County Clare and County Kerry Development Plans

� European Convention on Human Rights Act 2003

� Planning and Development (Strategic Environmental Assessment) Regulations 2004

INVALID APPLICATION

1. The developers in their planning application describe the 10 hectares to be developed offshore as zoned industrial. This is false as it is zoned Special Area of Conservation. We therefore object to this invalid and misleading application and want the whole application to be declared invalid – as would be the case if an individual made such a serious and misleading mistake in a planning application.

SAFETY ZONE

2. The evidence obtained from the Dr. Jerry Havens' Report (see. attachment 1), prepared by the Public Utilities Commission of the State of California for the Federal Energy Regulatory Commission, highlights worrying scientific evidence. Dr. Havens, Distinguished Professor of Chemical Engineering at the University of Arkansas and Director of the University's Chemical Hazard's Research Center, concluded that people living within 3 miles of the proposed site would be in harm's way (this radius covers the Kerry villages of Tarbert and Ballylongford and the Clare village of Killimer). "Dr. Havens is extremely qualified and has studied LNG safety issues for more than 30 years. His primary specialisation is in the analysis and quantification of the consequences of releases of hazardous materials into the environment, with emphasis on the consequences that can occur as a result of toxic and/or flammable gas releases into the atmosphere". "He has provided detailed analysis supporting his conclusion that there should be a minimum of 3 miles between an LNG terminal and a densely populated area. Anything closer than 3 miles could put the public in harm's way." This is based on a spillage of 3,000,000 gallons of LNG, which he claims is widely accepted as credible.

However, he also examines the consequences of a vapour cloud fire which could result if the LNG spill vapours were not immediately ignited and a vapour cloud formed. The cloud thus formed would drift downwind until it reached an ignition source or became diluted below the flammable concentration level - after which time it would not constitute a hazard. In his opinion, the maximum distance downwind to which portions of a cloud (sufficiently large to constitute a severe fire hazard) formed from the rapid spillage onto water of 3,000,000 gallons of LNG could be ignited is approximately 3 miles. If the vapour cloud were ignited as it drifted downwind, those persons in that area or immediately adjacent (thermal exposure could occur at some distance beyond the edge of the fire) who could not gain protection could be killed or seriously injured.

In any case, he states that such fires cannot be extinguished and would just have to burn themselves out.

Havens also deals with the explosion hazards of confined vapour cloud explosions, unconfined vapour cloud explosions, boiling liquid expanding vapour explosions, Toxicity hazards, Cryogenic ("cold" burn) hazards and Rapid phase transition (flameless explosion) hazards. Their importance in the public safety context lies in the potential for RPT's to cause secondary damage which could lead to cascading failures and further releases of LNG.

Dr. Havens' report is based on a spill of 3 million gallons. The EIS submitted by Shannon LNG proposes (volume 1 page 3) to design a jetty capable of taking ships with a capacity of up to 265,000 m3 of LNG. This is equivalent to 58 million gallons approximately.

The distance of the proposed site from vulnerable residential areas must therefore be taken into account by An Bord Plean�la.

3. The limited QRA implemented by Shannon LNG goes even further than the Havens' report when it admits that a vapour cloud could travel up to 12.4 kilometres before being ignited:

"A rule-set has been created for the QRA by considering the development of the largest cloud produced by the consequence analysis, that for catastrophic failure of a full tank in F2 weather. This cloud has a maximum downwind distance to LFL [lower flammable limit] of 12.4 km." (they do not state how far the cloud could travel beyond this distance before it meets the upper flammable limit – the level at which the oxygen mix with the gas is so high that the gas can no longer be ignited).

LNG FIRE HAZARDS

4. A report by the IoMosaic Corporation – "Understand LNG Fire Hazards" (see attachment 19 page 15) found that the maximum impact hazard footprint of a 200,000 m3 LNG tanker will result from a pool fire leading to a fatality limit of 50 percent at a distance of 3.7 kilometres from the leak.

5. The safety zone of 3 miles conservatively required by the Havens' report has implications for further residential development in the area surrounding the gas terminal. It will potentially have the effect of sterilising residential areas (stopping any new houses from being built on safety grounds) and it will also prevent other areas of the landbank from being developed as the levels of risk increase with more complex developments side by side. Shannon LNG proposes in the EIS (volume 1 page 5) that the remainder of the site may be used for a gas-fired power station , but the exclusion zone of 3 miles will make this proposal untenable. The Bord is asked to take these issues into consideration and issue an opinion on them as they will have serious social and economic long-term consequences on the area. In any case, Article 12 of the EU Seveso II directive states: "Member States shall ensure that their land-use and/or other relevant policies and the procedures for implementing those policies take account of the need, in the long term, to maintain appropriate distances between establishments covered by this Directive and residential areas".

6. SIGTTO (The Society of International Gas Tanker and Terminal Operators Ltd) is a non profit making company, formed to promote high operating standards and best practices in gas tankers and terminals throughout the world. It provides technical advice and support to its members and represents their collective interests in technical and operational matters. To become a full Member of SIGTTO it is necessary for a company to have equity interest in or to operate a gas tanker or terminal. Two of the company's published works are

- "LNG Operations in Port Areas : Essential best practices for the industry" (see. attachment 2) which SIGTTO describe as follows: "This document draws on this collective experience in setting out guidance to best practice for managing gas shipping operations within ports. It also illuminates the profile of risks attaching to gas operations, for the information of those who administer", and

- "Site Selection & Design (IP no.14) for LNG Ports & Jetties" (see. attachment 3) which SIGTTO describe as follows: "Information Paper No.14: Bearing in mind the high consequential risks of a serious accident in the LNG trade, this publication has been prepared for port developers as a guide to the minimum design criteria considered necessary when a port is to be built or altered to accommodate LNG carriers." Although HESS is not a member of SIGTTO, in the absence of direct Irish or EU regulation on the matter, it is only reasonable to expect that HESS would follow the standards set by its own industry.

In the public meeting held at the "Lanterns Hotel" in Tarbert on October 29th 2007, Shannon LNG stated that the SIGTTO standards were "a wish list for the ideal site, which was not, in any case, binding on Shannon LNG". We object extremely strongly to this claim because the Gas industry's own standards should be a minimum that the Kilcolgan Residents Association would expect to be applied. The Bord is fully entitled to regard that response from Shannon LNG as an admission that the present application does not match what they accept is "a wish list for an ideal site". There is no objective reason why the Bord should depart from that standard when assessing this application. The Bord has the opportunity, as well as the Statutory obligation to maintain the highest possible standard and the Company's statement eloquently describes exactly what that standard is

RISK ASSESSMENT

7. a) SIGTTO clearly state in "LNG Operations in Port Areas:Essential best practices for the industry" that risk exposures entailed in an LNG port project should be analysed by a Quantitative Risk Assessment (QRA) study which "must involve the operations at the terminal and the transit of tankers through the port" (Section 2 page 5).

Shannon LNG have only undertaken a QRA for the storage tanks on the shore, but no QRA has been done on the marine side of the operation. This is not in line with the industry's own best practice guidelines. The QRA includes a tanker on the jetty but it does not consider ship collision between two ocean-going vessels. It should be bourn in mind that tug boats themselves can also be a cause of collision

b) The SIGTTO standards also clearly state (page 7) that any risk-mitigating factors introduced - such as traffic control, exclusion zones around transiting tankers, tug escorts and specified limiting operating conditions of wind speed and visibility – should also be used in the QRA. This has not been done.

c) No QRA of intrusive risk exposures has been undertaken either. There are two categories of intrusive risk; that arising from intrusions threatening the physical integrity of the terminal and berthed tankers (e.g. heavy displacement ships), and that arising from the introduction of uncontrolled ignition sources.

d) Shannon LNG (in EIS Volume 2, section 3.10.2.3) states that "Shannon LNG understands that a more detailed Quantitative Risk Assessment (QRA) covering all navigational aspects of shipping will be undertaken by Shannon Foynes Port Company during development of the project". This splitting of risk assessment responsibility is not acceptable and indeed dangerous. Furthermore this is contrary to the EU 1998 Aarhus Convention Directives, Directive 2003/4/EC and Directive 2003/35/EC which declare the right of the public to be informed on environmental impact and to be provided with the opportunity to make comments and have access to justice.

e) The Quantitative Risk Assessment is based on "Land-use Planning Advice for Kilkenny County Council in relation to Grassland Fertilisers (Kilkenny) Ltd at Palmerstown". This is completely inadequate for a risk assessment of an LNG installation because the chemicals are different and the manner in which they leak is completely unique to LNG because it is at such a low temperature (-160 degrees).

f) One obvious and questionable claim in the QRA undertaken by the developer can be seen where only one of the four LNG storage tanks is covered by the inner zone contour in Figure 6.2 of the QRA on page 59. This means (using the criteria of table 5.1 on page 49) that it would be acceptable to build residential houses up against the remaining 3 LNG storage tanks even if the first tank leaks. This does not make sense and can only lead to the conclusion that the contours have been unrealistically tightened so as not to encompass current residential areas. We therefore object to this QRA which has not been made available to the general public.

h) We request more time from An Bord Plean�la to get our own independent technical assessment of the QRA undertaken by the developer because it has only been made available to us a very short time ago and is still not available to the general public.

i) Misapplication of Risk Assessment: Recently it has become popular on the international front to apply risk assessment to justify otherwise poor decisions not necessarily in the best interest of the public or the country. RA can be a very unwise tool to force the will of a powerful few on the uninformed public. One factor signalling some very poor applications of RA is the comparison to other risks that in a technical reality are not really related, especially as to consequences. Some consequences are so great that no matter what the probability the risks cannot be justified, especially if economic benefit to the decision makers is actually driving the poor application of this tool. A reality test in such poor applications is to ask what the real liability of the organisation is, if their risk call (aka their key technical "facts" assumptions) should prove wrong. Are their liabilities, both economic and criminal, for reckless decisions shall we say, limited by layers of attorneys citing loopholes, are the real assets moved off shore or to another country? What are the real corporate risks here if the RA is incomplete, inaccurate, or poor?

SITE SELECTION

8. SIGTTO clearly state criteria which must be followed in "Site Selection and Design for LNG Ports and Jetties". These include (page 12):

- Find a location suitably distant from centres of population

- Provide a safe position, removed from other traffic and wave action. For an "LNG carrier of about 135,000 m3 capacity, the waves likely to have such effects are those approaching from directly ahead or astern, having significant heights exceeding 1.5 metres and periods greater than 9 seconds" (page 7). The EIS submitted by Shannon LNG proposes (volume 1 page 3) to design a jetty capable of taking ships with a capacity of up to 265,000 m3 of LNG so the port criteria must satisfy this capacity of ship

These criteria seem to be unobtainable given the proximity of the villages of Ballylongford, Tarbert and Killimer (all 3 miles from the proposed gas terminal) and the huge amount of ships using the estuary already. Also, windage has to be accounted for because the specific gravity of LNG is a lot lower than oil and so the ship runs a lot higher on the water.

MOVING SAFETY ZONE

9. SIGTTO clearly state in "Site Selection and"LNG Operations in Port Areas:Essential best practices for the industry", that it is sound practice to establish a cordon sanitaire or exclusion zone around a transiting gas tanker. "Where traffic is proceeding in the same direction as the tanker the zone may extend some 1 to 2 miles ahead of the gas carrier, a distance determined by the distance required to bring the following gas carrier safely to a stop. Traffic following the gas carrier should be excluded for a similar distance, allowing scope for the gas carrier to slow down to manoeuvre without it being impeded by the approach of following ships. In general, traffic should not cross closer than 1.5 miles ahead or 0.5 miles astern of a gas carrier" (page 15).

a) These conditions have therefore an effect on the traffic moving through the estuary towards Tarbert, Moneypoint, Foynes, Aughinish and Limerick, especially since Shannon LNG have plans for 125 ships a year coming to the gas terminal

b) This also has an effect on the Tarbert-Killimer car ferry.

c) This also has an effect on all leisure boats using the estuary, including dolphin watchers in this SAC area of the Lower Shannon and the boats from Saleen Pier.

d) Furthermore, the exclusion zone will prevent other sea-based industries setting up in the land bank as they will not be able to access the site when LNG tankers are at port.

ENVIRONMENTAL POLLUTION: SEAWATER USE POLLUTING THE SHANNON ESTUARY:

10. Intermediate Fluid Vaporizer (IFV) technology using the Shannon seawater as a heat source is the intended method by which Shannon LNG will convert the liquid LNG to gas. The EIS (volume 2 page 63, section 3.6.3.2), notes that up to 5 pumps will be used to circulate up to 20,000 cubic metres of water per hour. This equates to 4.4 million gallons per hour. To prevent marine growth (bio-fouling) within the system, sodium hypochlorite (bleach, an oxidiser) will be added to the seawater on a continual basis. As it exchanges heat with the glycol solution, the seawater will be cooled such that at discharge it is cooler than the ambient seawater.

The withdrawal and discharge of huge volumes of seawater (over 100 million gallons on a daily basis) would affect marine life by killing ichthyoplankton unable to escape from the intake area (see attachment 4) . Further, the discharge of cooled and chemically-treated seawater would also affect marine life and water quality. For this reason, open-loop technology (and the Shannon LNG proposal is still an open-loop seawater technology even if it is using a closed-loop glyclol system) has been successfully opposed continuously by government bodies due to its negative environmental impact. This is because IFV technology poses the same environmental problems faced by Open Rack Vaporiser (ORV) technology which also relies on huge quantities of seawater (see attachment 7, section 3.5.2.3). It must be remembered that the Lower Shannon waters (including the 25 acres offshore of the proposed LNG site) are in a Special Area of Conservation (SAC) designated area (see attachment 6) – therefore constituting waters that must be protected under the EU habitats directive.

The waters of the Shannon can be protected using an alternative heating solution e.g. a closed-loop vaporiszer but this will prove more costly for Shannon LNG.

Concern also has to be expressed on the effect of the additional surface water runoff from the site and water supply to and from the proposed new pond (EIS volume 1 page 21) as well as the chemically-modified cooler seawater discharged from the vaporising process on the wetland habitats to the north-west of the site.

THE EU HABITATS DIRECTIVE

11. The Bord is bound to uphold the previsions of Art. 6 of the Habitats Directive and of the Irish implementing measures. It is plain that the provisions of Art 6(3) apply to this development. It is also plain that the development will by definition have negative implications for the lower Shannon Estuary candidate SAC. The Bord therefore has no basis for finding that the development will in the words of the Directive, " not adversely affect the integrity of the site".

The applicant itself does not purport to claim that the development comes within the provisions of Art. 6 (4) of the Directive and in our view they are quite correct not to attempt to make any such claim.

It is therefore not open to the Bord to grant permission.

We also rely on the protection afforded under European and Domestic law to the Ballylongford Bay proposed Natural Heritage Area and the Shannon-Fergus Special Protection Area in submitting to the Bord that the impacts of the development also mandate the Bord to issue a refusal.

12. The ecological sensitivity of the area has been recognised in the Kerry County Development Plan (see appendix 22) in declaring both Ballylongford Bay and Tarbert Bay as areas of Ecological Importance. For this reason we object to any environmental damage to this area.

13. The Environmental Protection Agency, in its 2006 report on water quality in Ireland (see attachment 23) emphasised the need to have, under the Water Framework Directive (WFD)(2000/60/EC) all waters, both surface and groundwater in good or higher status by 2015. We therefore object that the use of the Shannon waters as proposed in this planning application directly ignore or obligations under the Water Framework Directive.

PROJECT SLICING

14. Shannon LNG is artificially cutting this LNG project into pieces for the purpose of winning legal approval. Through this process, known as "salami-slicing", sections of this project will be assessed and permitted. The idea is that the less environmentally-questionable parts of the project are authorised and built first, making continued development of the project a virtual fait-accompli, even if the latter sections of the project seriously violate environmental regulations. This is contrary to, among others, article 2.1 of the EIA (Environmental Impact Assessment ) directive, which requires that "projects" likely to have significant effect on the environment – not parts of projects – are subject to the assessment.

Shannon LNG has made only vague reference to the pipeline from the proposed gasification terminal to Foynes even though this pipeline could also pose serious environmental and safety risks depending on the pressure of the gas in the pipeline.

It has only made vague references to its plans for the rest of its site on the land bank. They suggest maybe a gas-fired power station which would, they say, "be the subject of a separate planning application and EIS" (EIS volume 1 page5).

Shannon LNG also states (EIS volume 1 page5) that electricity to be supplied via 110kv lines from the ESB network at Tarbert will also "be the subject of a separate planning application".

Shannon LNG goes on to state (EIS volume 1 page5) that Kerry County Council will upgrade the coast road from Tarbert which "will also be the subject of a separate planning application".

It is to be feared that, due to the necessary exclusion zone required for LNG tankers, the land bank will only be fit for other "dirty" projects, which, if assessed along with the LNG gasification terminal, would almost certainly be denied planning permission.

This piecemeal approach to the planning process is extremely questionable as it does not deal with the sustainable development of the area.

LIMITED GAS SUPPLY

15. The justification for the project being that the supply of gas to Ireland is not assured must be questioned and it cannot be assumed that the proposed gas terminal is of overriding national interest. Reference has been made to the threat from the Russian pipeline. It must be pointed out that

- A gas pipeline also exists from Norway to the UK (see attachment 8). After the start up of the Langeled pipeline from Norway's Sleipner platform to the UK in the autumn of 2006, shockwaves were sent through the market. "History was made when over-the-counter prices fell to negative territory for the first time".

- LNG terminals in the rest of Europe provide an indirect source of gas through the European network.

- Gas has been discovered off the coast of Ireland

- Shannon LNG is giving no guarantees of supply whatsoever. It is assumed that the intention of the gas industry is to make LNG a commodity product where more gasification terminals increases liquidity in the market and the LNG tankers can change routes more easily if the spot price of LNG changes. From the Poten & Partners report (see attachment 8) Ofgem, the UK regulator, had to invoke use-it-or-lose-it provisions to stop BP and Sonatrach from diverting cargoes elsewhere to take advantage of price movements. Shannon LNG do not want the same types of provisions as can clearly be seen from the pre-planning consultation documents from An Bord Plean�la.

- Gas is still a fossil fuel and when the whole supply chain of LNG is considered from the extraction, liquefaction, transport and gasification stages it is thought that LNG is no cleaner than coal. This contradicts our national commitments signed up to in the Kyoto Protocol

LNG: UK Gas Sellers Face Looming Supply Glut

16. Poten and Partners have issued a report on their website of a looming glut of LNG in the UK market which should guarantee the supply of LNG to Ireland (see attachment 8). They state that a rapidly expanding import infrastructure in the UK threatens to outstrip requirement by a large margin. "In addition to Langeld, operation of the BBL and Tampen pipelines from the Netherlands and Norway will add 100 Bcm/y of new import capacity by 2010, equivalent to half the country's demand." The report also claims that "LNG import capacity will grow ten-fold during the same period". "This is thanks to the new dockside regasification facility at Teesside in northeast England and two grassroots terminals under construction at Milford Haven in Wales, known as Dragon LNG and South Hook", they add.

17. The Government White Paper, "Delivering a Sustainable Energy Solution for Ireland", the Energy Policy Framework from 2007 -2020 (see attachment 9 section 3.3.2), states that in implementing strategic goal 2 (ensuring the security and reliability of gas supplies):

"The UK is now the source of some 87% of our natural gas and the UK's own demand for imports is growing strongly. Norway will remain a significant supplier of gas to UK in the medium term. Ireland's location in Europe from the view-point of gas supply sources is becoming less peripheral. In the last 12 months the UK has achieved a significant increase in gas import capacity through accelerated infrastructure developments with resultant benefits for Ireland. Both pipeline and LNG capacity has increased significantly. These include the Langeled pipeline from Norway, the new pipeline from the Netherlands and new LNG terminals at Milford Haven. Further expansion of LNG capacity and gas interconnection is underway in the UK and Europe which will benefit Ireland in terms of security of wholesale gas supplies within this regional market… the prognosis for gas supplies is relatively secure as a result".

The White paper goes on to state:

"We will put in place an all-island strategy by 2008 for gas storage and LNG facilities in light of the outcome of the all-island study". This would represent an independent strategic view of LNG facilities, rather than depending on the non-independent representation by Shannon LNG. "He who pays the piper, calls the tune".

Therefore, while awaiting the government's all-island strategy for LNG facilities and while noting that "the prognosis for gas supplies is relatively secure", we strongly bring to An Bord Plean�la's attention that there is no over-riding urgent, strategic imperative or immediate need for an LNG terminal in Tarbert and that therefore, the "National Interest" cannot be used as an excuse to prime over and ignore the dangers being posed to the safety of the nearby populations in Clare and Kerry and the environmental damage that will be suffered on the SAC waters of the Lower Shannon which must be protected under the EU Habitats Directive if the development is given the go-ahead.

ALTERNATIVE LOCATION FOR AN LNG TERMINAL

18. The Second International Conference of Renewable Energy in Maritime Island Climates held in University College Cork in April 2006 suggested that Cork, close to the Kinsale Gas Field, would be an ideal site for an LNG terminal (see attachment 10):

"In the longer term it is important to fully explore and maximize geographical diversification in gas supply. One potentially promising option is through LNG (liquid natural gas) trade. This would provide give possibility to transfer gas from remote countries (Algeria, Nigeria, Malaysia, Trinidad and Tobago, United Arab Emirates and Qatar), without using pipelines, which are not economically viable. An LNG terminal in Ireland could be constructed near Kinsale Gas Field, connected to the gas platform, thus the existing gas pipeline from the gas field to Inch can be used. In this way, LNG could be used provide at least a quarter of national gas demand or be sufficient entirely for the Cork area. LNG can also be used as seasonable gas storage at the LNG plant (liquefaction and storage during warm season and vaporisation and injection into local pipelines during cold period). This service can increase the volume of storage in Ireland, which is currently limited to what is contained within the pipelines and remaining reserves at the Kinsale Gas Field."

19. The Second International Conference of Renewable Energy in Maritime Island Climates held in University College Cork in April 2006 also noted (see attachment 10) that:

"Germany has already started the construction of a gas pipeline from St-Petersburg to Germany under the Baltic Sea, avoiding borders. This is expected to provide more reliable supply from Russia to the West by 2010".

20. In 2006, a natural gas storage licence was granted to Marathon Oil Ireland Limited at parts of the Kinsale facilities (including the Southwest Kinsale Resevoir and wells, offshore platforms, pipelines, compression, processing plant and the shore terminal) used from time to time to inject, store and withdraw natural gas (see attachment 21, schedule 1 page 19) . This would seem to suggest that the Kinsale Resevoir would be a more ideal site for strategic gas storage than Kilcolgan.

PUBLIC ACCESS TO INFORMATION, PUBLIC PARTICIPATION AND ENVIRONMENTAL IMPACT ASSESSMENT

21. Shannon LNG submitted a risk assessment to the Health and Safety Authority on the same day it submitted the planning application to An Bord Plean�la. The HSA will make a recommendation to An Bord Plean�la based on its own examination of the risk assessment.

However, the risk assessment has never been made available to the general public and neither has it been submitted to An Bord Plean�la. This means that the public will not have access to vital environmental information (e.g. the environmental impact of an LNG leak) before the deadline of November 16th and people who would make a submission based on the risk assessment are now being illegally deprived of participation in the planning process. This is contrary to Article 6 of the EU EIA directive.

This issue can be solved by an order that the HSA or Shannon LNG produces both the Risk Assessment submitted and the HSA assessment to an Bord Plean�la and that this information be disclosed to the general public. Further submissions will have to be allowed from the general public – not only oral (for example in an oral hearing) but more importantly in written submissions. This is to take into consideration people who would be unable to speak at an oral hearing but who would have serious concerns they could put in writing. These written submissions will therefore have to be allowed from all members of the public who have not made a submission before November 16th in order to maintain transparency in the planning process.

We object that the division of responsibility for the Environmental Impact Assessment across a number of bodies including, but not limited to, An Bord Plean�la and the EPA is not clearly defined because the general public does not have all the environmental impacts before planning permission is applied for in order to participate fully in the planning process.

We as members of the public concerned have been given 7 weeks to prepare this submission to the bord. In that time we have faced a literally impossible task. We have been denied access to critical documentation including the materials submitted to the HSA and the HSA's own documents and reports on that material. Yet that material and the HSA analysis of it will without doubt form the basis of the HSA's opinion and the Bord in turn will rely on that opinion in the context of the Seveso II Directive. By the time we are eventually able to access the material to examine it further the Bord may have already dealt with the application on an erroneous assumption about the contaminants in the LNG. The Bord will have closed the door to further submissions from us. That is a clear example of one of the ways in which we are being shut out from meaningful participation in the process in flagrant breach of our rights under Irish and European Law. Our rights in this regard are guaranteed by the provision of the European Convention on Human Rights as adopted and as further made binding on An Bord Plean�la by the European Convention on Human Rights Act 2003 as well as by the principles of natural justice and the obligation on the decision makers including the Bord to apply fair procedures. There are several other aspects which are in breach of our rights including:

a) The complete inequality of arms between us and the applicant. This is accentuated by the ability of the applicant to engage in pre-application consultations with the Bord so that it can be advised on how to present the application. The Bord has concluded, with no public input, that the application is one fit to be dealt with as Strategic Infrastructure and has literally pre-judged that vital issue. That in turn puts the Bord in a position of objective Bias when it comes to assessing our contention that the application is no such thing and should not be considered as such.

b) The Applicants have been granted ample time to liaise privately with the Bord, to compile their material, to liaise with other Statutory bodies and to finalise this application. It has done so over a period in excess of 12 months. By contrast the local residents and other members of the public have been given no access to the statutory decision makers and instead are expected to convey our concerns in one fell swoop within 42 days of being granted sight of some, but not all, of the necessary documentation. This is fundamentally unjust.

QRA NOT DOWNLOADABLE

22. In a public meeting held by Shannon LNG on October 29th 2007, it was stated that the QRA would be available to the general public over the Shannon lng website. However, this has never been downloadable and has therefore never been available to the general public. This was reported by Catriona Griffin to An Bord Plean�la and was noted by the Bord.

BUILDINGS TO BE DEMOLISHED

23. We object to old buildings being demolished as they represent a history of all the people that lived there over the centuries. The old stone buildings also represent our national heritage as they are built in the style of the region. As these houses are also used by bats, we object that the homes of the bats will be destroyed, contrary to the Wildlife Act 1976/2000 and the EU Habitats Directive.

RESIDENTIAL AMENITY

24. We object to the detrimental affect of the proposed development on the lives of the nearby residents and general public.

i. The Environmental Impact Statement anticipates (EIS volume 1 page 17) that construction work will take up to 4 years

ii. The Environmental Impact Statement anticipates (EIS volume 1 page 17) that construction activities will require 24-hour working at the site.

iii. Added to this are the enormous changes to the visual landscape proposed (EIS volume 1 page 11).

iv. The noise and vibration impacts from construction traffic and blasting (EIS volume 1 page 17 and 18) are expected to be within the EPA limits. However, this does not take account of the fact that this area currently has hardly any noise whatsoever as it is on a lonely coastal country road and that the changed level of noise over many years is unacceptable.

v. In addition, Ballylongford village is not designed to take the huge increase in construction traffic expected.

vi. Trucks will come from Tarbert to the site but workers cannot be prevented from approaching the site from Ballylongford and no upgrade of the road between Kilcolgan and Ballylongford is proposed. This very winding road is therefore going to prove to be a death trap for the many people that currently walk on this road as a leisure activity.

vii. We are afraid that children might cut themselves on the barbed wire fencing proposed around the site.

viii. We object to the storage tanks proposed at 50 metres height and want them put underground on visual impact and safety grounds

ix. We object to the blight on the landscape from the water.

x. Tourists visiting the County of Kerry after crossing over the Shannon on the Ferry from Killimer to Shannon will not want to pass a dangerous industrial zone as proposed and this will have a hugely negative impact on the tourism sector in the north Kerry coastal regions beyond Ballylongford (Asdee, Beale, Ballybunnion). Furthermore, the site will not be in keeping with the county's reputation as one of outstanding beauty and will destroy our image.

xi. The environmental damage to the water caused by 100 million gallons of cooled, chlorinated water being daily discharged into the estuary will have a negative impact on the oyster farming on Carrig Island at the other side of Ballylongford Bay as well as the reputation of Ballylongford as it hosts the Ballylongford Oyster Festival every year (see attachment 18).

xii. The residents in the area surrounding this proposed development will have to live with the constant fear that an accident may happen at any time and this will be a constant source of worry and fear, no matter how long the terminal works without an accident. This is unfair to burden an innocent population with this threat and residual risk.

xiii. The EIS does not include the 2.9 metre barbed wire fencing in the photo montages and this is giving a misleading image of the full visual impact of the proposed development

xiv. The EIS does not include the proposed gas power station in the photo montage and this is also giving an extremely misleading image of the full visual impact of the proposed development.

xv. We object that the photo montages in the EIS do not represent the true size of the tanks and ask that this be confirmed independently.

xvi. We object that the huge construction traffic will effect the safety of the children on the school bus routes

RIGHT OF WAY

25. The EIS (volume 2 section 15.5.2) states that the right-of-way on the farm track at the western boundary of the LNG terminal site used by anglers to access the shore "will not be accessible to anglers when the LNG terminal is operational". We object to this.

26. The EIS (volume 2 section 16.14) claims that there are no registered rights of way or wayleaves on the site. We object to this because the site has always been used to access the shore for swimming, for angling etc by all the Kilcolgan residents, and to access the site owned by Stevie Lynch and John O'Connor of Lislaughtin.

HESS LNG's OTHER LNG TERMINAL REFUSED PERMISSION IN THE USA

27. The Weaver's Cove site ( see http://www.weaverscove.com/aboutus.html)describes Hess LNG as follows:

"Weaver's Cove Energy, LLC, is owned by Hess LNG, LLC, which is a joint venture owned equally by Poten & Partners and Amerada Hess Corporation. A team of professionals that are among the most experienced and reputable executives in the global LNG and energy industry manages Weaver's Cove Energy. The project team members have decades of experience in the design, development and operation of large energy projects around the world, as well as right here in Massachusetts."

One newspaper article described it as follows:

"The river that runs past a proposed liquefied natural gas terminal in Fall River isn't safe for frequent traffic by massive LNG tankers, the Coast Guard ruled Wednesday in what could be a fatal blow to the controversial project (see attachment 11 )"

And another paper said:

"BOSTON --A proposed liquefied natural gas terminal in Fall River may have been dealt a fatal blow.

The Coast Guard has ruled the river approaching the Weavers Cove Energy project is unsafe for navigation by massive LNG tankers.

The decision affirms concerns the Coast Guard expressed last year. The agency has since done an extensive review of the project.

A major problem is the relatively short distance between two bridges on the Taunton River. The Coast Guard found the safety risks of the 700 foot long, 80 foot wide tankers navigating the 1,100 foot gap were too great.

A Coast Guard spokesman says the ruling "kills the project, as proposed."

Weavers Cove officials did not immediately return calls for comment on the ruling" (see attachment 12 and 13).

The real lesson to be learned from the debacle at Weaver's Cove is that Hess LNG were stopped from building an LNG terminal on safety grounds even though they claimed that what they were proposing to do was safe. Our interpretation of this is that, no matter what the obstacle, Hess LNG will claim that they can make it work and ignore their own standards of Best Practice and put people's lives at risk in order to "clinch the deal". This further proves that Hess LNG is not capable of self-regulation and the independence of their own risk and environmental assessments have now to be seriously questioned. Furthermore, the increase in LNG traffic all over the world will only increase the risk of an accident and this only accentuates the need for the implementation of the strictest safety standards. We therefore implore An Bord Plean�la to refuse planning on safety grounds.

ACCOUNTABILITY

28. Shannon LNG is described as a wholly-owned subsidiary of Hess LNG Limited in the Environmental Impact Statement submitted by Shannon LNG to An Bord Plean�la (Volume 1 page 1). However, it has not been pointed out to An Bord Plean�la that Hess LNG is an offshore company incorporated in the Cayman Islands (see attachments 15 and 16). In the event of an environmental disaster at the plant Shannon LNG would be liable for the costs of any loss to property and human life. However, Shannon LNG has no assets of note. This can lead to problems in litigation where cases can go on for decades as attempts are made in the courts to apportion blame and liability. Companies can deny liability by creating shell companies in different jurisdictions, where ownership of the land is shared among some companies and ownership of the operations is shared out among other companies – all in different jurisdictions with different litigation laws.

Hess Corporation itself has never proposed that it could accept from the outset all responsibility for any environmental or human losses at the site for which Shannon LNG itself (or any other related companies) could be held liable as if it still owned the site and operations and that this liability would not be given away or sold without the express permission of the local planning authority in Ireland (Kerry County Council). This would have had the added advantage of creating an incentive for Shannon LNG to maintain the highest environmental and safety standards.

However, we object to the fact that an offshore company controls the private company that is applying for planning permission to construct this dangerous LNG terminal in Tarbert.

LNG CONTRIBUTING TO GLOBAL WARMING

29. In its report on LNG (see attachment 17), Greenpeace found that the use of natural gas that has been liquefied and transferred across the Pacific reduces the difference between natural gas power plant CO2 emissions and coal power plant emissions by nearly half. However, it also found that the development of LNG terminals would open up nearly limitless quantities of natural gas to the energy markets and that this shift threatens to turn natural gas, previously viewed as a "transitional" fuel, into a permanent source of global warming gases. This surely goes against the spirit of the Kyoto Protocol and we therefore ask An Bord Plean�la to note this and refuse planning permission for the project. Furthermore, this trend towards an increased dependence on LNG increases reliance on environmentally destructive fossil fuels and significantly delays the possibility of moving towards renewable energy sources by creating a costly infrastructure for LNG.

Furthermore, the idea of building a Gas Power station on the site (EIS volume 1, page 5) will increase the dependency on LNG as a permanent fuel rather than a transitional fuel and we object to this result.

DISAGREEMENT AMONG EXPERTS ON THE DANGERS OF LNG

30. A report for the US Congress was undertaken by the United States Government Accountability Office (see attachment 14) with advice from 19 of the world's top international LNG experts. The startling findings from this report was that even they seem unable to agree, hence the reports conclusion that the US DOE should carry out further tests on spills of LNG. We therefore also feel that due to the uncertainty in judging the risk to people's safety, An Bord Plean�la should apply prudence and rule against this planning application.

31. In The GAO Report for Congress (see attachment 14) the section on Cascading Tank failure is illuminating as it states that the worst case scenario is a small hole in an LNG carrier's containment; this is because the LNG Pool Fire will last longer close to the ship; so giving more time to heat the adjacent tank. A big hole allows the LNG to empty quickly from the tank in question so limiting the time any fire has to heat the adjacent tank. For this danger posed to the nearby residents we ask once again that An Bord Plean�la should apply prudence and rule against this planning application.

HOUSES NOT DISPLAYED ON SITE MAP

32. On the site map made available to the public, there are 6 houses missing – namely those of Raymond O'Mahony, Adam Kearney, Geraldine Carmody, Mrs. Kathleen Finnucane and two other houses belonging to the Finnucane family. We object that this is distorting the number of homes immediately adjacent to the site and question if this is also distorting the QRA.

NO BENEFIT TO KERRY

33. There is no plan to send any of the gas imported to Kerry. The only monetary benefit to Kerry shall be the rates that will be charged to the terminal and we object that this should influence the submission from Kerry County Council.

COMMUNITY ENGAGEMENT IN PLANNING

34. The final Report from the APaNGO project entitled 'community engagement in planning exploring the way forward' (see attachment 20) was launched at the international APaNGO closing conference in Brussels at the end of October 2007. The APaNGO project is one of the first studies of community engagement and involvement at the European level, covering findings from the seven Member States in North West Europe (Belgium, France, Germany, Luxembourg, the Netherlands, the Republic of Ireland, and the UK). It noted that the "legitimacy of any planning decision will vitally depend on the quality of democratic input to the process; without that input, decision-making itself will be discredited.

For this reason, and from the Aarhus Convention Directives on the right of the public to be informed on the environmental impact and being provided with the opportunity to make timely comments and have affordable access to justice, we therefore object that we do not have the financial means to challenge the EIS and QRA presented by the developer who has access to unlimited resources through Hess Corporation. This EIS and QRA are not independent. We need funds to challenge this with our own safety and environmental experts and therefore request that An Bord Plean�la puts those funds at our disposal in order to maintain transparency and equality in the planning process, given that this is for a complex chemical installation in a SEVESO II site.

QUESTIONABLE REZONING BY KERRY COUNTY COUNCIL

35. We object that the development is proposed on a green field site – even if it has recently been zoned industrial (EIS volume 2, section 4.6.3). In march 2007, the LNG site was rezoned from "Rural General" to Industrial (see attachment 29)

"The stated purpose of the variation was as follows:

The purpose of the variation is to facilitate consideration of suitable development of these lands in accordance with the provisions of section 5.2.9 of the Kerry County Development Plan 2003-2009 which states: 'lands have been identified at Ballylongford/Tarbert as suitable for development as a premier deep-water port and for major industrial development and employment creation'. The adoption of this variation gives effect to objective ECO 5-5 of the Kerry County Development Plan 2003-2009 which states: 'It is an objective of Kerry County Council to identify lands in key strategic locations that are particularly suitable for development that may be required by specific sectors. Land in such locations will form part of a strategic reserve that will be protected from inappropriate development that would prejudice its long-term development for these uses."

a) If the LNG terminal goes ahead then the landbank will not be a deep-water port as all other ships will be forbidden and unable to use the port.

b) The creation of 50 long-term jobs does not constitute "major employment creation".

c) The LNG terminal is in actual fact a hazardous chemicals installation, defined as the most dangerous of sites in EU legislation – a Seveso II site. This does not fall under the type of installation to be considered for the rezoned site because if it was the intention of Kerry County Development Plan to include hazardous sites within the landbank then Kerry County Council would never have given planning permission for the new houses currently being built (such as that of Jayne Kearney) less than 900 metres from the LNG tanks. Any new houses built after the LNG terminal is constructed would constitute "inappropriate development" which means that hazardous sites were never to be considered as appropriate development within the landbank. ,

d) This Seveso II site will sterilise the remainder of the site which means that the aim in the Kerry County Development Plan of "major industrial development and employment creation" cannot be fulfilled.

e) The County Manager stated that sufficient natural amenity lands had been reserved to the west of the site which included a walking route to Carrig Island. However, Carrig Island is at the other side of Ballylongford Bay and takes several miles by car to reach by driving through Ballylongford.

f) The County Manager went on to state that "the impact of development on the residential amenity of houses in the vicinity of zoned industrial land will be dealt with at the planning stage". This clearly shows that the site is not intended for a SEVESO II development.

g) More importantly Clare County Council objected to the rezoning on the grounds that:

"the proposed rezoning is likely to have a significant impact on the future development of the region, and will have a direct impact on the planned objectives for the Mid West Regional guidelines for the Shannon Estuary and in particular the Planning, Economic and Service Infrastructural development objectives for zone 5 of the plan. Any industrial development including the construction of a deepwater harbour will have a major impact on both the visual and ecological amenities of the area, and potentially on the Lower Shannon Estuarine Environment, including the foreshore of County Clare. Clare County Council would like an appraisal of any SEA investigation which may have been undertaken in respect of the proposed variation". The Kerry County Manager replied: "Any future application of these lands will be subject to an Environmental Impact Assessment. This process will ensure that any proposals will take into account impacts on the visual and ecological amenities of the area. A copy of the SEA screening report for the proposed variation will be forwarded to Clare County Council."

This is reprehensible. There is no evidence of an SEA having been undertaken as required for a variation to a development plan under Statutory Instrument No 436 of 2004 Article 7 section 13K and article 12 schedule 2A of the same Statutory Instrument (http://www.irishstatutebook.ie/2004/en/si/0436.htmlarticle12 ). Without any information in the public domain regarding the scoping or the actual execution of an SEA (see attachment 32), this rezoning is fundamentally unsound and invalid. Clare County Council does not even know that this is a SEVESO II development. This rezoning process is also being brought to the attention of the relevant authorities as we object that the variation and rezoning of this site has been undertaken in a highly questionable and indeed invalid manner. We therefore object to the planning application because we maintain that this land is not zoned industrial.

These points mean that An Bord Plean�la should rule that the proposed development does not conform to the Kerry County Development Plan for the site, nor to the Planning and Development Act and should therefore be refused planning permission.

OTHER ISSUES

36. We object to any possible movement by road of LNG, due to the dangers and want this to be confirmed by An Bord Plean�la.

37. We need An Bord Plean�la to rule clearly on the use that may be made of the rest of the landbank if planning permission is given to the developer. We object that the rest of the landbank will be sterilised. It must be remembered that if the Bord allows other installations be built on the site near the gas terminal then they will have an influence on the risk of an accident at the regasification terminal. A clear ruling on this matter must be made.

38. We need An Bord Plean�la to rule clearly on how close residential property may be constructed to the site. We object that people will not be allowed to build on their own property close to the site due to the dangers.

39. We need An Bord Plean�la to rule clearly on the exclusion zone it recommends for boat users on the Shannon Estuary and object that use of the Shannon will be hindered by LNG tankers.

40. We object that most of the statutory bodies informed of the planning application will not have time to make detailed submissions to An Bord Plean�la due to the minimum time scale of 6 weeks from the date of planning application. This is such a serious installation that considered opinions cannot be given in this short timescale.

41. Under Seveso II regulations, we insist that An Bord Plean�la, if it decides to accord Planning permission to the developer, gives a detailed ruling on the type of emergency plan to be put in place, both onsite and offsite, and insist on the implementation of an early-warning system to all residents within 12.4 kilometers, including (but not limited to) a form of public siren and information to be given to the same residents on how to react to this siren.

42. The Tarbert Development Association and The Ballylongford Development Association do not speak for the residents surrounding the Kilcolgan site and we object to any attempt to claim anything to the contrary as this does not represent local consultation as far as we are concerned.

43. Morgan Heaphy, Glencullare, asked Shannon LNG to elaborate on the exclusion zone in a written comment on one of the information days (see EIS Volume 4 , Appendix 1F) and this has never been answered in any format (other than the words "limited exclusion zone" (EIS volume 4 appendix 3c) ) and therefore this does not represent consultation with the nearby residents. We object that the developer has always maintained that the site is safe and has kept such a low profile in discussing safety issues that the general public has been completely unaware of the issues in the euphoria of having new industry and jobs coming to the area. This is completely against the spirit of the planning process and we object to this serious misrepresentation of the installation to our detriment and the developer's economic advantage.

44. We object to the application of the Strategic Infrastructure Act 2006 as it applies to this application as we are extremely worried about the possibility of "agency capture". By this, we mean that we are extremely worried that An Bord Plean�la may inadvertently become compromised by having too close an interaction with the developer during the decision making process. We expect An Bord Plean�la to maintain a professional distance from the developer and to inform us of all negotiations it has with the developer and to give us a right of reply to all correspondence between the developer and the Board. In the interest of public safety in this Seveso II development we require that all new information be disclosed to the public and that the public be allowed sufficient time to analyse the data and make further submissions, both written and oral.

45. A report on the LNG blast in Algeria (see attachement 24) mentions the contaminant gases that Lng is made up of. Note that when HSE ,Sandia and other regulators do tests with LNG, it is with 100% pure Methane. We object that the level of contaminant gases to be shipped by Shannon LNG have not been disclosed and request that An Bord Plean�la ask the developer to state the level of contaminant gases they expect to have in the LNG shipments and whether they will vary depending on the origin of the LNG in order that a QRA be undertaken and analysed with this information in mind:

"A 1980 Coast Guard study titled "LNG Research at China Lake," states that LNG imported into this country is often far from pure, and it reveals that vapour clouds made from "impure" LNG actually explode as readily as the highly volatile LPG. When natural gas is super-cooled and turned into a liquid, as much as 14 % of the total cargo shipped as LNG may actually be LPG or other hydrocarbon fuels, according to the Coast Guard report. Natural gas contains these other fuels when it is pumped from the ground. LNG containing these so-called "higher hydrocarbons" is known as "hot gas" and has a higher energy content than pure methane. The Coast Guard report reveals that vapour clouds of LNG containing at least 13.6 % of these other fuels can detonate just like pure propane gas. The agency concluded in its report that this deserves "special consideration, as the commercial LNG being imported into the US East Coast has about 14 % higher hydrocarbons." "

46. Is the limited exclusion zone proposed by Shannon LNG around the LNG tankers taking into account the risk of an ignition source as well as the risk of a collision?

47. Lloyds Casualty Week dated September 16 2005 (see attachment 25, page 11/12) noted an LNG fire from a pipeline leak in Kalakama, Nigeria started a wild fire covering 27 square kilometres. We object that the developer has not included pipeline incidents in the QRA because the pipeline EIS has not even been completed. This shows the dangers in slicing a project into several separate projects for planning purposes.

48. What is the thermal flux that An Bord Plean�la would determine as acceptable? Is it 1.5 kw/m2.?

49. We object that the State does not determine the most suitable site in Ireland for an LNG terminal, rather than a biased private-sector company applying for planning permission.

50. We ask that An Bord Plean�la take account of the Buncefield Reports (http://www.buncefieldinvestigation.gov.uk/index.htm ).

51. From speaking to people in Milford Haven it was noted:

a) Jobs increased initially but the unemployment rate increased when the jobs finished as some of the workers had settled down in the area

b) Rental costs were high during construction which made life more expensive for locals

c) Skilled labour (such as welders) were attracted away from local industry so some local business suffered as a result

d) There are other construction works on top of one of the tanks equivalent in size to a five-storey building. Will that be the same in Tarbert?

e) Dolphins used to be resident in the Haven but left and never came back

52. We object that this LNG terminal would increase or dependency on the Opec nations – contradicting Energy independence objectives (e.g. windfarms where we have best windspeeds in Europe )

53. We object that the permanent jobs to be created will not be for unskilled labour (see attachment 27), which means that it is likely that many will not be filled by locals.

54. We object that since the government is still giving licences for exploration that must mean more gas exists in the country

55. We want all archaeological sites protected (including the one near the jetty)

56. We object that the bird and sea life will be seriously impacted by the lights and the sounds

57. We object that the gas tanks will be visible from county Clare as that county will be expected to get all the disadvantages and none of the advantages (rates) from this development.

58. We object that we do not know if Shannon LNG has options to buy more land but need to know this as it would be an indication of their real intentions.

59. We object to the idea of dumping soil and stone from the site near to Scattery Island.

60. The Climate Protection bill on the 3rd October was in the senate and it refers to a 3 % decrease per annum. Facilitating the importation and dependence on more fossil fuels like LNG goes against the spirit of the Climate Protection bill.

61. We object that an offshore location for a terminal would be safer than the onshore one proposed.

62. We object that the terminal could hit house prices. An article in the Kerryman newspaper dated October 17th 2007, page 5 predicts a 29% drop (see attachment 28).

63. No Material Safety Data Sheets ( MSDS) have been supplied with the EIS and we object that these have not been provided. We ask that An Bord Plean�la obliges the developer to provide these and allow us sufficient time to analyse them.

64. While all chemistry is dangerous, we agree that it is also feasible it the hazards can be contained. However, we object to the real problem here which is one of scale. 4 tanks of LNG represent 2400 tanks of gas.

65. We object that the HAZOP study is not available to enable us and the general public participate fully in the planning process as required by the EU EIA Directive. We ask that An Bord Plean�la obliges the developer to put it at our disposition.

"A HazOp study identifies hazards and operability problems. The concept involves investigating how the plant might deviate from the design intent. If, in the process of identifying problems during a HazOp study, a solution becomes apparent, it is recorded as part of the HazOp result; however, care must be taken to avoid trying to find solutions which are not so apparent, because the prime objective for the HazOp is problem identification. Although the HazOp study was developed to supplement experience-based practices when a new design or technology is involved, its use has expanded to almost all phases of a plant's life. HazOp is based on the principle that several experts with different backgrounds can interact and identify more problems when working together than when working separately and combining their results. "

The risks we are especially interested in examining in closer detail include (but not limited to);

a) Static electricity and how to control it.

b) Catastrophic damage in the pressurisation process.

c) Catastrophic damage at the stage where odours are added to the gas with mercaptons.

d) Catastrophic damage at the stage where the glycol reheats the LNG

66. We object that no trucks should be travelling to or from the site for 5 minutes before and after a ferry boat lands because it has been noticed that the existing road network in Tarbert cannot take ferryboat traffic as it is at the moment.

67. We object that the full height of the storage tanks was lied about. The EIS (volume 1 page 4 ) clearly states: "The tanks will be a low-profile design and will be approximately 96m in diameter and approximately 50.5m high". This is extremely misleading as this EIS volume 1 – the non-technical summary – was widely distributed to the general public. From the drawings submitted to An Bord Plean�la (see attachment 31) it can be clearly seen that only the top of the concrete is 50.5 metres in height; the top of the tank elevation is 60.5 metres and the top of the pressure relief valve vent stack elevation is 71.5 metres in height. This means that the tanks are 40% higher than stated in the non-technical summary. This is highly misleading to the general public and therefore this has surely to lead, on its own, to this application being declared invalid. To add to that, Figure 3.14 (EIS Volume 3 part a) states that the height of the dome of the LNG tank is 10 metres lower at 50.5 metres. Which is it?

68. A clear example of the misrepresentation on the safety and environmental risks of the proposed LNG terminal that has taken place can be seen in the following wording in the brochure that was distributed by Shannon LNG in May 2006 which lead the general public to trust and believe (and because of no statements to the contrary from any of the statutory bodies) that this project was completely safe until now: (see attachment 26 page 7)

"Could the tankers leak?

In the unlikely event that there is a release from a tanker, the LNG will evaporate. That means the liquid will warm up and change back into a gas. This gas would quickly dissipate because it is lighter than air. Because the LNG is not transported under pressure any leak would evaporate more slowly and cover a much smaller area than a pressurised gas such as propane or butane. Compared to petrol or home heating oil, LNG is far less flammable and will not pollute the environment if it spilled"

Will there be an environmental impact?

Once it is in operation, the plant would have very few impacts – LNG import terminals are quiet, there is no smell, no smoke, no steam, and no noise that can be heard beyond the site boundary"

Such reassurance must be capable of objective verification. That is impossible as matters stand with this application. In addition the public concerned, of which we form part, have a legal and human right to participate effectively in any such verification process. We are being very effectively shut out from that process at present in all but name.

This is one of the first significant applications to come before the Bord under the Strategic Infrastructure Act. How the Bord deals with it can be expected to set a bench mark for the future. We ask the Bord to refuse the application.

69. The Flight path of flights from Shannon Airport and the dangers they pose have not been assessed at all in the risk assessment. We object that this has not been done because of the potential of disasters occurring from plane crashes – accidental or otherwise as was apparent in the tragic 9-11 disaster in New York. It should also be noted that Hess Corporation is an American company and therefore represents a possible future target given the current political situation in the world.

FUNDING

70. Finally, we wish once more to flag the issue of requiring funding to be provided for our further participation if the process continues beyond this point. Funding would be essential to enable us to retain the necessary expert assistance in order to defend our personal, family, property, and public participation rights.

SIGTTO MEMBERS

71. SIGTTO members include (source http://sigtto.re-invent.net/dnn/Members/tabid/70/Default.aspx) :ABS Europe Ltd,Abu Dhabi Gas Industries Ltd,Abu Dhabi Gas Liquefaction Co Ltd,Adriatic LNG,Aegis Logistics Ltd,AES Andres,Allocean Ltd,Anglo-Eastern Ship Management (Singapore) PTE Ltd,Antwerp Gas Terminal N.V.,Atlantic LNG Co. of Trinidad &Tobago,Bahia de Bizkaia Gas, S.L,Barber Ship Management AS,Bergesen Worldwide Gas ASA,BG Lng Services LLC,BGT Limited,BHP Billiton International Inc,Bibby Line Ltd,BP Group,Brunei LNG Sdn Bhd,Bureau Veritas,Calor Gas Limited,Carbofin Energia Trasporti S.p.A.,Ceres Hellenic Shipping Enterprises ltd,Chemikalien Seetransport GmbH,Cheniere LNG INC,Chevron Shipping Company LLC,China LNG Shipping (International) Company Ltd,Chinese Petroleum Corporation,Chubu Electric Power Co Inc,Chugoku Electric Power Co In,CLP Power Hong Kong Limited,Cometco Shipping Co,ConocoPhillips Marine,Depa Gas Corporation of Greece,Det Norske Veritas,Dominion Cove point LNG,Dorchester Maritime Ltd,Dorian (Hellas) S.A.,Dragon LNG Ltd,Dynagas Ltd,Eagle Sun Company Ltd,ECO ELECTRICA,Egyptian LNG,Eitzen Gas A/S,El Paso Corporation,Empresa Naviera Elcano S.A.,Energy Transportation Corporation,ESKOM Holdings Ltd,Excelerate Energy LP,Exmar N.V.,Exxonmobil Development Company,Fleet Management Limited,Freeport LNG Development, L.P,Gaz de France,Gazocean Armement,Germanischer Lloyd AG,Golar LNG Limited,Grain LNG LTD,Guangdong Dapeng LNG Company Ltd,Hazira Port Private Limited,Hyundai Merchant Marine Co. Ltd,IINO Kaiun Kaisha Ltd,International Gas Transportation Co LtdIwatani International Corporation,Kansai Electric Power Co Inc,Kawasaki Kisen Kaisha Ltd,Knutsen Oas Shipping,Korea Gas Corporation,Kuwait Oil Tanker Co S.A.K.,Kyushu Electric Power Co Inc,Lauritzen Kosan A/S,Leif H�egh & Co ASA,Liquefied Natural Gas Limited,Lloyds Register,LNG Japan Corporation,Louis Dreyfus Armateurs S.N.C.,Malaysia Int Shipping Corp Berhd,Malaysia LNG Sdn Bhd,Maran Gas Maritime Inc,Marine Service GmbH,Marubeni Corporation,Medway Ports,Milford Haven Port Authority,Mitsubishi Corporation,Mitsui & Co Ltd,Mitsui OSK Lines Ltd,M�ller, A.P,Naftomar Shipping & Trading Co,National Gas Shipping Co. Ltd,Nigeria LNG Limited,NIPPON Oil Corporation,Norgas Carriers A/S,North Atlantic Pipeline Partners, L.P.,Northern Marine Management ltd,NYK Line (Nippon Yusen Kaisha),Oman Liquefied Natural Gas,Osaka Gas Co Ltd,OSG Ship Management Ltd,Pertamina Transportation LNG-JMG,Petredec Limited,Petrobras Transporte S.A. – Transpetro,Petronas Gas Berhad,Petronet LNG Limited,Phoenix Park Gas Processors LTD,Pronav Ship Management Inc,PT Arun NGL Co,PT Badak NGL Co,Qatar Gas Transport Company Limited,Qatar General Petroleum Corporation,Qatar Shipping Company Q.S.C.,Qatargas Operating Company Limited,Ras Laffan Liquefied Gas Co. Ltd,Rompetrol Petrochemicals,Sakhalin Energy Investment Co Ltd,Santos Ltd,Saudi Arabian Oil Co (Saudi Aramco),Seariver Maritime Inc,Sempra Lng,Shell International Trading and Shipping Co Ltd,Shipping Corporation of India,Shizuoka Gas Co Ltd,Single Buoy Moorings Inc,SK Shipping,SNTM-HYPROC,South Hook LNG Terminal Co Ltd,Statoil A/S,Suez Global LNG Limited,Suez LNG NA LLC,Talisman Energy,Tamanneftegas,Teekay Shipping,Terminal de LNG de Altamira S. de R.L. de C.V.,Texaco Angola Natural Gas Inc,The Bahrain Petroleum Co B.S.C.,The Egyptian Operating Company (elng),Thome Ship Management Pte. Ltd,Toho Gas Co Ltd,Tohuku Electric Power Co Inc,Tokyo Electric Power Co Inc,Tokyo Gas Co Ltd,Total Indonesie,Total S.A.,Trunkline LNG Company, LLC,Unicom Management Services,United Gas Derivatives Company,V. Ships Limited,Varun Shipping Company Ltd,Weavers Cove Energy,Wesfarmers LPG Pty Ltd,Woodside Energy Ltd,

Submission to An Bord Plean�la regarding the Proposed Liquefied Natural Gas (LNG) regasification terminal located on the Southern shore of the Shannon Estuary in the townlands of Ralappane and Kilcolgan Lower, County Kerry (reference PL08 .PA0002 and PC 08.PC0002).

Dear Sir/Madam,

Further to our submission dated 14th November we wish to add the following points:

1. The site layout plan submitted by Shannon LNG (drawing C013) it is noted

i. "AREA DESIGNAATED FOR GAS EXPORT A.G.I. (to be subject of separate planning application) "

ii. "AREA DESIGNATED FOR EIRGRID 110KV SWITCHYARD (to be subject of separate planning application) "

We object that this is not all submitted as part of the main planning application because it is another example of project slicing (raised in point 14 of our submission yesterday) and because of the dangers they pose for creating another source of static electricity, an ignition source, in the QRA.

2. We do not understand why the existing buildings closest to the main road have to be demolished, because there are no other plans for that area disclosed.

3. We urge An Bord Pleanala to view the RTE "Prime Time" program of November 15th, 2007 on the RTE website www.rte.ie/news/primetime/index.html, entitled "Safety Concerns over safety gas terminal: : Katie Hannon reports from the North Kerry Village of Kilcolgan where it is proposed to build a liquefied natural gas terminal despite some local opposition" and bring to the Bord's attention that it was clearly proved that:

i. Shannon LNG lied when it told the public that vapours from a leak would harmlessly evaporate – "a myth", the LNG industry Mr. Cox described it as

ii. The barrister clearly raised serious questions about the legitimacy of this fast-track planning process, which are depriving us for fair application of justice and which bring seriously in to question the manner in which this application is being dealt with.

For these reasons we recommend rejection of the planning application.

4. Adam Kearney has uncovered even more serious questions on the rezoning of the landbank to Industrial from rural general in March of this year as follows in an email to Kerry County Council today:

From: Adam Kearney Associates [mailto:info@akassociates.ie] Sent: 16 November 2007 11:40To: Kena FelleCc: McElligott, JohnSubject: SEA Screening Report

16/11/07

Dear Kena,

I would like to know if a SEA (Strategic Environmental Assessment) screening report was compiled by Kerry County Council for Variation No. 7 of the County Development (To rezone 188.8ha (466.53 acres) of land, comprising 105ha (261.43acres) currently zoned as Rural General and 83ha (205.1 acres) currently zoned as Secondary Special Amenity, in the townlands of Reenturk, Rallappane and Kilcolgan Lower, to Industrial zoning). If so I would like a copy of same It was stated in the County Managers report on Variation No. 7 in response to a submission by Clare County Council that a copy of the SEA screening report would be sent to them. Yesterday I spoke with the Senior Executive Planner John Bradley who made the submission on behalf of Clare County Council, he informed me that they had not received a screening report. I also contacted the EPA who cannot confirm receipt of the report either. As the deadline for public submissions to An Bord Pleanala for the proposed Regasification Terminal in Tarbert is this evening at 5 pm I am extremely restricted on time and need clarification on this issue. If it is the case that an SEA screening report was not conducted for a variation to a development plan then the validity of the rezoning has to be questioned. Under Statutory Instrument No 436 Article 7 section 13K and article 12 Schedule 2A of the same Statutory Instrument 2004 legislation it is quite clear on the procedures required for making a variation to a plan.

Yours Sincerely,

Adam Kearney

Tom Sheehy, of Kerry County Council sent the report today (see attachment 33).

The copy of the screening report was not sent to any of the statutory bodies as it was felt there was no need for an SEA as there was no environmental impact, in spite of the serious reservations raised by Clare County Council.

We object that since this planning application is going to have a serious effect on the environment an SEA must be undertaken before the land is rezoned and that planning permission should be refused as this will have a huge impact on the strategic development of the region. Furthermore, we intend to raise this question with the Department of the Environment, and both the Ombudsmans Office and the Standards in Public Office because we feel that this land was rezoned solely for Shannon LNG, when it was known that a huge environmental impact was going to happen – all this done in the interests of avoiding and SEA and rushing this Seveso II site through planning.

We request therefore, that until theses matters are concluded that planning be refused.

Yours faithfully,

Johnny McElligott

ATTACHMENTS

1. The Havens Report: From the submission by the "Public Utilities Commission of The State of California" to the "Federal Energy Regulatory Commission" on the proposed LNG facilities at the Port of Long Beach by "Sound Energy Solutions" Docket Nos. CP04-58-000 on October 4, 2005.

Internet reference:

http://files.meetup.com/207586/Rigassificatori%20-%20onshore%20LNG%20California%20(3%20miglia).pdf

2. "LNG Operations in Port Areas : Essential best practices for the industry" First Edition 2003, The Society of International Gas Tanker and Terminal Operators Ltd (SIGTTO) ISBN: 1 85609 256 9 Witherbys Publishing www.witherbys.com . or http://sigtto.re-invent.net/dnn/Publications/tabid/62/Default.aspx Price UK� 45. Hard copy only.

3. "Site selection and Design for LNG Ports and Jetties – Information Paper No. 14. 1997, The Society of International Gas Tanker and Terminal Operators Ltd (SIGTTO) ISBN: 1 85609 129 5 Witherbys Publishing. www.witherbys.comor http://sigtto.re-invent.net/dnn/Publications/tabid/62/Default.aspxPrice UK� 25.Hard copy only.

4. "LNG in the Gulf of Mexico", presentation by Jeff Rester of the "Gulf States Marine Fisheries Commission"http://www.seagrantfish.lsu.edu/pdfs/biloxi_07/JeffRester.pdf

The Gulf States Marine Fisheries Commission (GSMFC) is an organization of the five states (Texas, Louisiana, Mississippi, Alabama, and Florida), whose coastal waters are the Gulf of Mexico. This compact, authorised under Public Law 81-66, was signed by the representatives of the Governors of the five Gulf States on July 16, 1949, at Mobile, Alabama. It has as its principal objective the conservation, development, and full utilization of the fishery resources of the Gulf of Mexico, to provide food, employment, income, and recreation to the people of these United States.

To visit their homepage: http://www.gsmfc.org/gsmfc.html

5. Newspaper article on Fisheries agency expressing concern over Bienville LNG project, filed from Houston November 11th 2007 http://www.energycurrent.com/index.php?id=3&storyid=5952

6. "Lower River Shannon" Special Area of Conservation (SAC) Site Synopsis by the National Parks and Wildlife Service Internet Reference: http://www.npws.ie/en/media/Media,4177,en.pdf

7. Draft Environmental Impact Statement for Bayou Casotte Energy, LLC's Casotte Landing LNG Project under CP05-420 et al. Accession Number: 20060519-4002 Section 3 Alternatives http://elibrary.ferc.gov/idmws/file_list.asp?document_id=4405730%20

8. "LNG: UK Gas Sellers Face Looming Supply Glut" March 20, 2007, Poten & Partners Market Opinions. This article appeared in Poten & Partners monthly publication LNG in World Markets . Reference LNG and natural gas data is available at the LNGAS Data/News Website . Please go to www.poten.com/lngconsultingproducts.asp to sample these reports and order them http://www.poten.com/?URL=show_articles.asp?id=593&table=tMarket

9. The Government White Paper, "Delivering a Sustainable Energy Solution for Ireland", the Energy Policy Framework 2007 -2020, The Department of Communications, Marine and Natural Resources.

http://www.dcmnr.gov.ie/NR/rdonlyres/54C78A1E-4E96-4E28-A77A-3226220DF2FC/27356/EnergyWhitePaper12March2007.pdf

10. Proceedings of the 2nd International Conference of Renewable Energy in Maritime Island Climates. 26 – 28 April 2006. Security of Energy Supply in Ireland – A Key Driver for Renewable Energy. Kateryna Kornyeyeva, Brian P. � Gallach�ir and Eamon J. McKeogh, Sustainable Energy Research Group, Department of Civil and Environmental Engineering, University College Cork, College Road, Cork, Ireland http://www.ucc.ie/serg/pub/SOS-R2.pdf

11. Newspaper Article on Weaver's Cove http://biz.yahoo.com/ap/071024/ma_lng_fall_river.html?.v=1

12. Boston Globe Newspaper article on Weaver's Cove: http://www.boston.com/news/local/rhode_island/articles/2007/10/24/coast_guard_says_lng_waterway_unsafe_for_tanker_transit/

13. Projo Newspaper article on Weaver's Cove http://www.projo.com/massachusetts/fallriver/content/BZ_COASTGUARD_WEAVERS_10-25-07_RB7K2NO_v20.35aa5a2.html

14. "Maritime Security, Public Safety Consequences of a Terrorist Attack on a Tanker carrying Liquefied Natural Gas Need Clarification", United States Government Accountability Office (GAO) Report to Congressional Requestors February 2007. http://www.gao.gov/new.items/d07316.pdf

15. Shannon LNG Accounts B1 documents lodged at the Companies Registration Office.

16. Shannon LNG Limited – Director's Report and Financial Statements for the Year Ended 31 December 2006.

17. "Clean Energy Now. Liquid Natural Gas: A roadblock to a clean energy future". Greenpeace http://www.greenpeace.org/raw/content/usa/press-center/reports4/liquid-natural-gas-a-roadbloc.pdf

18. Ballylongford Oyster Festival http://www.ballylongford.com/ballylongfordoysters.htm

19. "Undersand LNG Fire Hazards" Iomosaic Corporation, 2007. http://archives1.iomosaic.com/whitepapers/0100ioM02202007WPS_Understand%20LNG%20Fire%20Hazards.pdf

20. Final Report of the INTERREG IIIB Advocacy, Participation and NGOs in Planning Project – "community engagement in planning – exploring the way forward". October 2007 http://www.apango.eu/closingconference/20071016_APaNGO_ENGLISH_FINAL_REPORT_PRINT_UK.pdf

21. Natural Gas Storage Licence granted to Marathon Oil Ireland Limited http://www.cer.ie/CERDocs/cer06101.pdf

22. Kerry County Development Plan – "Appendix G" – "Other Areas of Ecological Importance". http://www.kerrycoco.ie/planning/devplan03.asp

23. "Water Quality in Ireland 2006 – Key indicators of the Aquatic Environment" – Environmental Protection Agency, Ireland. http://www.epa.ie/downloads/pubs/water/indicators/name,23540,en.html

24. ."Report Sheds New Light on LNG Blast in Algeria" – Alexanders Gas and Oil Connections, Volume 9 issue 9, May 6th 2004

25. Lloyd's Casualty Week, September 16th 2005

26. "Major Project to secure Ireland's natural gas supply" - Shannon LNG booklet May 2006

27. Basic Job Descriptions at DownEast LNG http://www.downeastlng.com/docs/TypicalJobDescriptionsRev4.pdf

28. "Locals fear terminal could hit house prices" – The Kerryman newspaper October 17th, 2007 http://www.kerryman.ie/news/locals-fear-gas-terminal-could-hit-house-prices-1202905.html

29. County Manager's Report on Proposed Variation No 7 to the Kerry County Development Plan 2003 – 2009

30. Minutes of March 12th 2007 Meeting of Kerry County Council

31. Typical Arrangement LNG Tanks 1&3 Front Elevation – submitted as part of Planning Application to An Bord Plean�la by Shannon LNG http://www.shannonlngplanning.ie/files/PlanningDrawings/LNGTankAndJettyDrawings/C202.pdf

32. Notice of proposed variations of the kerry county development plan 2003 - 2009 http://www.kerrycoco.ie/ballylongfordvariation.asp

33. Ballylongford screening Report

Personal Information Withheld - Dodge Cove, British Columbia

Public Comment Aurora LNG March 09, 2017

It is very unfortunate that the proponents Nexen and Chinese National Offshore Oil Corporation, have been allowed to enter into a Provincial Environmental Review with such large gaps in their proposal for their LNG terminal. One of the biggest problems facing Canada and the world is the GHG emissions that are being released into the atmosphere. The Federal Government required the proponent to report not just the construction and production emissions but also the upstream emissions. During most of the public comment period, the public and stakeholders had no access to total emissions as requested, so all studies and participants of the working group were using figures, which did not reveal the true emissions. This is only one example of much unfinished research and large gaps in areas that are more obvious to the citizens that use the local land and water in sustainable ways.

Under CONCLUSIONS in the application, 4.3.10, Nexen, claims that "During full build out operations, annual GHG emissions are conservatively estimated to be 6,669,335 (6.7 mt) tonnes CO2e per year." Wow, this is a very conservative number. PNW-LNG is a plant with a proposal of less production annually and the indication is that they would be producing 13.9 million tonnes of CO2 annually. Why would they use a conservative number in their application, when they had not even reported their upstream emissions?

Now let's recap. PNW is to produce less CO2 annually and yet shows double the CO2 emissions of Aurora? This is indeed conservative data by Nexen and could be seen as false figures if both corporations are using the same formulas for determination of the totals. Also who determines these formulas to obtain the carbon equivalents. It seems that much of the data seems biased towards the industry, or shall I say the data is just "conservative".

The Pembina Institute reports that the emissions of PNW would be one of the highest producers of all projects in Canada. I use PNW as my project for comparison due to its similar but smaller production. It has been projected that with upstream emissions, Aurora LNG would produce approximately 91 million tonnes from extraction to burning annually. Then let's say it is not a conservative estimate such as Nexen-CNOOC uses but a "bullish" estimate. The next comparison comes to the CO2 data from Canadian government sources:

British Columbia: in 2005 - 62 mt (million tonnes) annually
2020 (projected) - 69 mt
2030 (projected) - 43 mt
Between 2020 and 2030 British Columbia needs to drop 26 million tonnes (approx. 30%).

1. How will this province reduce its carbon emissions by 30% in ten years if Aurora LNG is producing more than the total CO2 emissions of the whole province?

2. How is it that after 3 large CO2 emitting fossil fuel projects like Kinder Morgan, Fibrewood LNG and LNG Canada (Kitimat), that the PNW and Aurora LNG can even be invited to lease and begin environmental reviews?

The Paris Climate agreement that the Canadian Government committed to means Canadian CO2 emissions need to be reduced by 30% also between 2005 and 2030. Talk is cheap but commitments take careful planning and certainly not building CO2 emitting projects that top all others in their emissions. NO means NO and REDUCE means REDUCE not REPRODUCE!!!

Personal Information Withheld - Dodge Cove, British Columbia

On the East Coast, a report on "Potential Economic and Fiscal Impacts of LNG Terminals on the Whole Passamaquoddy Bay" was prepared for the region - by an outside company not the LNG terminals that wished to build. It has much useful information that is very relevant for us here on the west coast, which communities have no way of hiring a company to prepare a report for us. Really, this type of report should be done by the government for this area before any proponent studies take place. Where are the baseline studies NOT done by CNOOC-Nexen?

I have only seen part one of a two part report, that focuses on the direct employment impacts to local residents, and businesses, economic impacts on the real estate market and fiscal impacts related to community infrastructure, transportation, housing, public safety and property values. It would be interesting to see the second part" of the report as well.

This area sounds similar, on paper, to Prince Rupert and surrounding region. The economic base of the area was mostly abundant natural resources (forestry/agriculture/fisheries/aquaculture) and production and processing or raw materials into finished goods, and shipping that to distant markets. All people in the region (less than 30,000) historically relied on the region's natural resources as economic resources.

The beauty of the area has attracted tourists over many generations - and is a well established econmic activity that has unrealized potential.

"Preserving the rural character of the region is seen as key to the region's capacity to tap cultural resources for economic gain."

"The Passamaquoddy Bay region is one of , if not the, most productive areas for wildlife on the East Coast. The region has developed a greater than once billion dollar annual economy based on fisheries, tourism, aquaculture, and other resource based industries."

This seems pretty comparable to what I have read about present economy here in the Pacific Northwest Coast - economy that hinges mostly on the rich Skeena River estuary and rich marine life here.

"The question is not whether the communities in this region could benefit from economic development, but whether or not LNG terminals will move the region closer to its goals."

I find this very accurate - what are our regions goals? How does LNG impact our long-term goals for this area?

When I think of the environmental impact, and the impact to the health of residents here, and absolute destruction of long-term communities such as Dodge Cove on Digby Island, I hardly think that the short term non-renewable resource extraction and shipping industry is forwarding the goals of these region. How is forwarding the goals of this province, country, and world?

At this point I think of the commitments that the provincial government and federal government has made to reduce emissions - approving this project will wipe out much of existing economy, and negatively impact the diversification of this area which is much needed.

Why is our government not investing money in renewable energy, which would create jobs and also enhance long term goals and keep to the commitments they have made?

"Many of these communities have historically been involved in commercial fishing, tourism, shipbuilding, lumbering, milling, etc." Small, rural communities where people know each other.

"These communities are looking for the types of economic development that do not impact their significant historical, natural, and cultural resources."

That sounds like these region!

"The communities in our study area also seek to encourage economic development of a scale and type that is appropriate to their size and location…allow, in predominantly residential areas, the establishment of small industrial establishments that are compatible with the rural character of these areas that meets the needs of residents. Heavy industry is only allowed in existing commercial and industrial sites. Other plans cite the importance of small and cottage industries." "Since many local jobs are natural resource-based, this would involve assuring natural resources are protected."

This reminds me of the statement by CNOOC-Nexen that the community of Dodge Cove will go from being a rural marine community to an "industrial neighbour". That is not the goal for our community that Dodge Cove residents ever envisioned.

"THE FUTURE OF DODGE COVE:Dodge Cove residents' desire is to continue living here in an environment with sustainable food and a healthy lifestyle. We want to leave this historic community with its light footprint to the next generation just as all communities wish to be able to remain cohesive with an optimal quality of life. If Dodge Cove has a motto, it is the old mariner's law of the sea: if a sailor needs help, you stop and help. This is the strength of our community.A CONFIDENTIAL SURVEY WAS TAKEN IN DODGE COVE, AND 96% OF RESIDENTS SAID NO TO AN LNG TERMINAL ON DIGBY ISLAND."

https://friendsofdigby.wordpress.com/about/the-future-of-dodge-cove/

From Passamaquoddy Bay report again: "None of the communities in the study area have articulated a vision for their future that involves transformation from a diversified natural resource-based economy of largely small enterprises to large-scale heavy industrialization based on non-local resources. All communities recognize the importance of retaining existing jobs and developing complementary enterprises."

There is no study of our area here in the Prince Rupert region that has measured the impact of the informal economy , activities that can account for a significant share of income (or income equivalents).

On page 26 of the Passamoquoddy Bay report lists numbers for employment by an LNG terminal, during construction and operations phase, with SHOCKINGLY LOW numbers compared to the numbers we are being told from other sources such as CNOOC-Nexen or the BC gov't. Once construction is complete, this report lists 40 fulltime jobs at the terminal. And secondary jobs such as marine or maintenance as another 16-26 jobs.

The study says that since none of the materials and equipment are going to be provided by local sources, or even by Canada. It lists 97% of construction expenditure distribution as out of the country, with 2% in country, 1% in region, and 0% local.

As well, with labour, 79% out of country, 21% in country, 0% regional, and 0% local.

"By and large, local employment opportunities will come from those few positions that relate to the function of any business enterprise: administration, personnel, security, and maintenance. Based on their experience, dominant skill sets, and educational attainment, these are the jobs for which local residents will be eligible. With benefits, these positions might pay in the range of $30,000-$40,000."

The report goes on to talk about weather conditions such as fog (throughout most of the summer we have thick fog here as well) and increased risk of navigating the LNG ships relying on instruments with no visual landmarks, and for smaller craft without instruments that are not aware of the LNG ships. There is increased risk of collision.

Storms - which we have many - if a transiting LNG ship is caught in a storm, where will the emergency anchorage area be - and how will it impact existing marine traffic routes? And will it be sufficient for safety anchorage of an LNG ship? If the LNG ship does not head into dock but hangs back, how will that delay other vessel traffic entering and exiting Prince Rupert harbour?

The report talks about how deep draft vessels such as LNG ships need to be especially concerned with the currents at various depths, because the currents may significantly vary in strength and direction, which we have a large tidal range here in the Prince Rupert region. How will the tides and storms combine to effect safety of the transit of LNG vessels? "It should be pointed out tat, with an increase in LNG ship trafffic, the probability of a marine accident increases. However slight, the increased risk should be weighed against the value of the ecological assets in the area." The Skeena River estuary is known to be rich in biological resources.

In a letter by Dan Prichard of the Submerged Land Program of the Maine Department of COnservation, Bureau of Parks and Lands, he stated that "given the length of Maine's coastline and the shallow depth and narrow waterway of the proposed terminal site relative to the navigation and berthing requirements of the LNG vessels, it is difficult to imagine that the proposed site is the most suitable."

I compare this to the proposed Aurora LNG export terminal area - shallow (has to be dredged), exposed to to the south and southeast waves and wind (which is predominant in this area), close to and overlapping an existing community, close to the only airport servicing this region, right at the mouth of the main entrance to the main shipping channel for Prince Rupert Harbour, in the Skeena River estuary, it is hard to imagine that with the length of this coast, that this is the best location and the most suitable location to be found.

The Passamaquoddy Bay Report refers to the Society of International Gas Terminal and Tanker Operators, an international non-profit organization that has developed a series of best practices and operating standards for the LNG industry (mostly based on Sandia Laboratories experiments with LNG). Some of the SIGTTO standards that are listed in the report that were considered directly relevant to the proposed LNG development on the East Coast: (and that would also be directly relevant to the proposed LNG development of Aurora LNG here on Digby Island). Direct excerpts from SIGTTO:

"1)Port designers (should be directed) to construct jetties handling hazardous cargoes in remote areas where other ships do not pose a (collisions) risk and where any gas escape cannot affect local populations.

2)LNG tankers are vulnerable to penetration by collisions with heavy displacement ships at all but the most moderate of speeds. Such incidents ought to be treated as credible within any port where heavy displacement ships share an operating environment with LNG tankers.

3)Locations that already attract other craft, including pleasure craft and fishing vessels, are inherently unsuitable for LNG terminals. In such circumstances enforcement (of the exclusions zones) is highly problematical and, even with strenuous enforcement effort, may ultimately fail.

The potential violation of these standards, according to SIGTTO, could potentially compromise the health and safety of the local environment and residents." It seems strange that Nexen continuously claims that they believe they are complying with SIGTTO standards, when the proposed placement of the Aurora LNG terminal and berths right at the mouth of Prince Rupert Harbour, and within 1/2 km away from Dodge Cove, and only 3 km to Prince Rupert, seems to NOT be following SIGGTO standards at all.

The report goes into detail regarding that terminals are not to be close to any existing airport, with specific federal regulations (in the U.S.) regarding proximity to protect public safety by reducing the likelihood of a plane crash at the LNG site, which may occur either by accident (mechanical failure, operator error) or by intentional sabotage by a terrorist. In certain areas, air traffic is redirected while LNG vessels are in the area, including temporary flight restrictions, and smaller aircraft such as charters could be directly affected. How will this affect flights and airline safety at Prince Rupert airport, how will this affect seaplanes flying in and out of Prince Rupert Harbour?

" LNG terminals are industrial properties which, due to the particular hazardous characteristics of liquid natural gas, will impose additional public costs regardless of any resulting increase in resident population"

Current Federal law (U.S.) requires 1600 foot buffer zones around an LNG facility in case of thermal flash, which, according to Robert Gardner, hazardous substance specialist, is not enough. From the berthing to the CENTER of the entry to Prince Rupert Harbour is 500 metres, so all boats passing into Prince Rupert Harbour will be in a hazardous thermal flash zone if an accident was to occur.

To what extent will Nexen shoulder the cost of public safety? There is a significant lack of equipment or training to handle any type of LNG emergency, and experts have said that is a large accident or malfunction happened NO-ONE would be able to handle it. Digby Island and the communities of Dodge Cove and Crippen Cove are already seperated from emergency services. Any emergency could make it even harder to get personnel and resources to Digby Island. We only need to look at the last few oil spills in the Northern Vancouver Island area to see how remote areas can be difficult to get help to, especially in the face of weather conditions through the winter, and a lack of actual capabilities to deal with any emergencies.

"Jerry Havens, in an article for the Bulletin of Atomic Scientist, explains,"Today, accounting for less probable events such as terrorist attacks is, and must continue to be, an important consideration in the planning of LNG facilities. For nearly 50 years now, all discussions of risk and probability in LNG transport have focused on how to account for human errors. The new reality is that we must now consider malicious acts as well. "

"In another article, Havens explains, " a large LNG pool fire, on water (uncontained) is of the highest concern. Most predictions suggest that even the largest LNG tankers might be completely enveloped in a pool fire following a complete spill of a single 6.5 million gallon tank.

This raises questions about the vulnerability of the ship and the potential for additional releases. We do know some things about such fires. They could NOT be extinguished and would have to burn themselves out. And such fires would be expected to burn more rapidly and with greater intensity than crude oil or even gasoline fires."

Dr. James Fay (professor ermitus at Massachusetts Institute of Technology (MIT): "the danger zone for humans extends almost 4 miles from the terminal site, encompassing 20 square miles of land in the Pleasant Point area. For a tanker spill anywhere along the route leading to the LNG terminal, the thermal radiation danger zone for humans extends 1.5 miles from the tanker route, encompassing up to 4 square miles of land (along shores), depending up the spill location along the tanker track."

If you applied the distances that Dr. James Fay mentions to the Aurora LNG tanker route, berthing area, and terminal on Digby Island, that 4 miles would include Dodge Cove, Prince Rupert, Ridley terminals, the new propane storage being built at Ridley, and the already approved PNW LNG. The thermal radiation zone would include all traffic coming in and out of Prince Rupert Harbour.

"A safety study of a proposed LNG terminal in California concluded: "A 6,600,000 gallon release of LNG from a 16 foot hole in an LNG carrier into the water without ignition could form a cigar shaped flammable plume that could reach distances between 0.6 mile and 2.5 miles depending on wind speed and terrain. A plume from a release of the contents of large storage tank through a 16' hole could reach distances between 1.6 and 3.2 miles. If ignited, a plume will burn back to spill source, and people within a burning plume will be killed, and houses and vegetation will be ignited."

I fail to see this mentioned in the Aurora LNG final application, and especially in regards to Dodge Cove residents.

Dr. Havens also goes on to say that the thermal radiation could burn people 1/2 mile away from the EDGE of the fire. "Havens and other scientists contend that safety zones based on a limited 10 min spill could not protect the public from the kind of fire that would result from an LNG tanker accident. Havens says that those zones should extend a mile or more from the LNG terminal.

Dr.Fay calculated the thermal radiation zones for a max. LNG spill of 6000 metric tons, or 14,300 cubic meters (approx. 7% of a 200,000 cubic meter tankers capacity). " The thermal radiation damage zone within which people would experience burns and buildings would catch fire is about 1.1 km from the spill site in every direction." And according to Fay, the damaging heat of a fire will extend nearly a mile from the OUTER edge of the fire, not simply a mile from the spill source."

"These studies suggest a danger zone of approx. 2-3 miles in diameter centered on the site of the storage tanks with a danger zone of similar size surrounding LNG tankers as they enter and leave the dock. Significant damage to life and property is likely within this zone should a serious accident resulting in a spill of LNG on land or water occur. "

http://www.savepassamaquoddybay.org/documents/community_impact_studies/whole_bay_study/whole_bay_study/WholeBayStudy-Part_1.pdf

This entire report, both studies, should be read and analyzed by the BCEAO as what the information would mean here in the Prince Rupert Harbour area, which bears so many similarities to the Passamaquoddy Bay area.

Here is the Dodge Cove Declaration of Values:

The Dodge Cove Declaration of Values

Be it known that we, the undersigned duly elected trustees of the Dodge Cove Improvement District on Digby Island BC, believe that the lands, waterways and airshed that surround us are paramount to the physical and mental well being of ourselves, our neighbours, our livelihoods and our quality of life.

We recognize and honour the Tsimpsian people, and hold in high regard their culture and traditional methods of responsible stewardship.

This island supports thriving populations wildlife including Great Blue Herons, Canada Geese, several species of amphibians, numerous local and migrating raptors, flocks of songbirds and shorebirds, Coastal Gray wolves and occasional bears. Extensive patches of bog terrain dotted by undisturbed lakes and creeks, mixed species of coastal plants and forests, and clean air are vital to their existence. Surrounded by waterways of the Pacific Ocean, several species of wild Pacific salmon and numerous intertidal creatures contribute to the balance of this sensitive ecosystem. The natural beauty of this island and economic opportunity have drawn individuals and families to live and thrive for over 100 years in Dodge Cove.

Our rural community is comprised of diversely skilled professionals, trades people, fishermen, shipwrights, forest and resource workers, artists and entrepreneurs. Dodge Cove residents undertake the careful stewardship of our lands and waters. We use renewable energy wherever possible and apply common sense to the use of natural resources. We value garden agriculture along with forest and seafood harvesting to maintain our food security.

Therefore, it is impossible for us to stand by and allow any heavy industrial presence, including oil and gas development, that would threaten or harm our values and responsibilities as outlined in this declaration.

Respectfully yours,

Dodge Cove Improvement District Trustees

Personal Information Withheld - Vancouver, British Columbia

Please save the livelihood of the communities that have lived on Digby island for generations. Dodge Cove is home to my common law partner and has been part of their family for over 20 years. Aside from the communities, the fragile and rare ecosystems are home to important species, animals and mammals that are at risk if an LNG plant is developed. Thank you

Personal Information Withheld - Dodge Cove, British Columbia

What would Jerry Havens have to say about the proposed Aurora LNG site so close to existing marine traffic zones and communities? Here is a statement he made about another LNG terminal which is easily relevant about Aurora LNG.

Planning Permission for Shannon LNG Terminal

Submission by Professor Jerry Havens, Distinguished Professor of Chemical Engineering, University of Arkansas, USA.

Statement by Professor Jerry Havens

Oral Hearing on the proposed LNG terminal in County Kerry, Ireland

January 23, 2008

My name is Jerry Havens. I am a Professor of Chemical Engineering at the University of Arkansas in the United States. I am speaking here as a concerned scientist; my comments are not to be attributed in any way to the University of Arkansas. Thank you for allowing me to appear here on behalf of the Kilcolgan Residents Association (KRA).

As I understand why you might question the propriety of my "butting in" on this LNG terminal siting hearing, I hope you will give me a few minutes to explain my purpose.

I have spent my adult life researching the potential consequences of catastrophic releases of hazardous materials, with emphasis on fire and explosion hazards. I submit to you my resume, which gives more detail than I have time for here. I think it pertinent, and hopefully of interest to you, to state that I have had a close association with European authorities on such questions as the one before this authority since the late 1970's, having first served in England as a consultant to the Major Hazards Committee and the Health and Safety Executive in the conduct of the heavy gas trials at Thorney Island in Hampshire in the early 1980's. The Thorney Island trials were gas dispersion experiments which were recommended by the British Government as the result of the Flixborough disaster of 1974, in which there occurred a very serious explosion of a cyclohexane vapor cloud that resulted in worldwide changes in regulatory practices for handling of hazardous materials . Similarly, I investigated, and continue to study, the Bhopal gas cloud disaster which occurred in India in 1984, arguably the worst industrial chemical accident in history. I was invited to participate in research resulting from these catastrophic events, as well as other similarly directed programs in Europe largely because I was contracted by the U.S. Coast Guard in the late 1970's to develop a general purpose gas dispersion model that would be particularly applicable to LNG vapor dispersion, a subject that was of great interest in the 1970's, as now. I played a seminal role in the development of the two LNG vapor dispersion mathematical models currently required in the United States to be used by applicants for approval of LNG terminal sites. I have also been heavily involved in the development of the mathematical models that must be used to determine the fire radiation safety distances that must be observed for approval of LNG terminal sites.

In the U.S., presently, approval of land-based (as opposed to offshore) import terminal sites is the purview of the Federal Energy Regulatory Commission (FERC), whereas the U.S. Coast Guard currently plays the more formative role regarding the safety aspects of the shipping side of the project. I have most recently been heavily involved in continuing studies to better determine the potential consequences of marine incidents involving LNG – with emphasis on studies of the consequences of very large vapor clouds or pool fires that could result from massive spillage of LNG onto water.

I believe that there is sufficient similarity in the LNG terminal proposals under consideration that similar requirements for the protection of public safety are appropriate worldwide. These ventures, which involve the potential for very high consequence accidents or intentional events, are truly international and should be treated with a high degree of care and cooperation – it is in everyone's best interest to be as certain as practicable that we treat these issues with the respect they deserve.

I want to state before proceeding that I am neither for or against any particular LNG terminal on any other grounds than provision of public safety – that is the only expertise I am professing here - which brings me to why I agreed to appear at this hearing to speak on several issues that I believe are important for you to consider in the process of siting LNG import terminals.

Potential Consequences of LNG Releases from the Terminal

For the land based part of an LNG terminal, I believe that our current understanding of the consequences of releases on land, where they can be most effectively contained, is sufficient in large measure - needing for the most part only "maintenance" efforts to insure the propriety of that information to changing industrial practices. I am not here to suggest that we drastically need more study in this area - I am suggesting that the information that has been made available in the research programs already completed is not being brought uniformly on board in the siting process. I point to perhaps the most glaring example that I have observed in the discussions relative to the Shannon LNG terminal proposal. In discussions relative thereto, I have read, and heard expressed at large, the opinion that LNG vapor, being principally methane, is lighter than air and therefore will rise harmlessly into the air (if LNG is spilled) – out of danger. It is true that methane vapor at ambient temperature is lighter than air, providing an important and widely recognized safety feature of natural gas in contrast to heavier-than-air fuel gases such as propane or butane (or cyclohexane, as at Flixborough). But LNG is a liquid at very low temperature, about -165 oC, and the vapor initially formed from LNG is at that temperature also, and because of its low temperature, it is considerably heavier than air (about again as heavy). The result is that an LNG vapor cloud will spread laterally and remain close to the ground, prolonging both in distance and time the potential hazard to the facility and to the public. That hazard is primarily a fire hazard, rather than an explosion hazard, for reasons which I will be happy to explain but think I should not go on about here for want of more important things. So, one of the principal concerns that I want to highlight here is that in haste to site LNG terminals we should be careful not to cut corners on issues of public safety suc h as this glaring example implies.

Potential Consequences of LNG Releases from LNG Ships

The shipping side of the LNG importation business is more complicated, in my opinion, if only because the major emphasis on regulatory requirements for public safety have historically been associated with the land-based part of the ventures. In the United States, there are mandatory "exclusion zones" required for the land based terminals; these exclusion zones demarcating zones in which the public is not allowed. However, there are no such mandatory zones (as opposed to "safety/security zones" which are required by the Coast Guard during passage to or from, or at the terminal) to exclude the public from the vicinity of LNG ships. I believe that more serious consideration should be given to this gap in the provision of public safety measures relating to potential ship release incidents. The containment vessels (cargo tanks) on LNG carriers are, because of weight requirements primarily, likely to be more vulnerable to failure due to puncture damage, especially i f intentional, than the more massive land-based "full containment" storage tanks currently in favor. And, whereas spills from a land-based tank are required to have secondary containment features to limit spreading of the spilled LNG, no such measures appear to be practical for spills on water. The result is that if a large spill occurs from a ship onto the water, it will spread until it completely evaporates, whether burning or not. If ignition does not occur, a vapor cloud forms which can drift significant distances with the wind before it becomes diluted to a concentration where it cannot be ignited. During that travel, if the cloud is ignited the result is a vapor or flash fire which will severely endanger people or property caught in the confines of the fire. LNG is not odorized; unlike natural gas that leaks in your house or from a pipeline, which is required to be odorized, you cannot smell it. If ignition does occur the result is a pool fire, basically similar to any other fire that resu lts when liquid fuel is spilled on water and ignited. Large LNG fires on water have not occurred throughout the fifty to sixty years that LNG has been shipped on water. While that record is justifiably encouraging, we must not encourage, or allow, corner-cutting here either, in taking adequate and appropriate measures to protect public safety.

Rationally Assessing the Risks

The KRA asked me to respond to the "Prime Time" video presentation by Dr. Tony Cox regarding the Shannon LNG terminal proposal, and I agreed to do so. Dr. Cox and I worked together in the 1970's and 1980's in the various research efforts designed to get a better understanding of the potential for "dense gas" behavior of LNG vapor evolved from spills. The video presentation by Dr. Cox appears to be in essential agreement with me, as described above, regarding the interpretation of dense gas behavior by LNG vapor clouds.

However, at the close of the video, Dr. Cox stated: "The risk is in fact extremely low - and any rational person or any person who is fully informed ought to be able to accept them and I would." As I stated earlier, I have had a long association with Dr. Cox, which I hope to continue. But I am puzzled by his statement. I intend to talk with him about this issue to get clarification of his view, as I am fully aware of the difficulty of expressing one's full thoughts under the pressure of media scrutiny, but I have been unable to do so in the very short time since agreeing to be here today. So, I will try to tell you why I am concerned about his statement, and hope that he will be willing to set me straight if I have misinterpreted anything he said. Perhaps it is simply in the end a disagreement between us – but I think it is important that experts be prepared to defend their statements and I expect that Dr. Cox would agree.

I agree with Dr. Cox that the risk is low. But I believe to say that it is extremely low, which well might be interpreted by the public as justifying dismissal from further careful consideration, is not justified. I also agree with Dr. Cox's assertion that there is no such thing as a risk free activity. That is why I believe that in our increasingly technology-based society, which is likely to continue as long as we can maintain it, we have to balance the risk (probability) and the consequences in order to determine the acceptability of a venture such as LNG importation. However, adequately and quantitatively balancing risks and consequences is not easily accomplished - certainly not by just making subjective statements such as "extremely unlikely". Furthermore, even if the feared events are determined to be extremely unlikely, if the consequences of the event could be so severe as to raise serious questions as to the acceptability of the venture anyway, there may justifiably remain serious concerns.

That is the quandary we are in today with such ventures as LNG importation. As with the continuing difficulty in arriving at a measure of acceptability of risks that plagues the nuclear industry, the chemical/energy industry has developed a major consequence hazard identification.

As an example of the confusion that reigns in this area, I have heard repeatedly expressed that the energy content of an LNG ship is equivalent to that of 50 or more Hiroshima-yield nuclear weapons. In my opinion that is an unjustified stretch. However, the statement that the energy content of an LNG ship is that large is entirely true; the comparison however is meaningless unless the time in which the energy can be released (fraction of a second in a weapon; much longer in the case of an LNG fire involving the entire contents of the tanker) is considered. Nevertheless, the potential for catastrophic consequences to result from large releases of LNG, especially onto water, where spreading and rapid evaporation could not be controlled, cannot be dismissed. It is for these reasons that I believe the potential consequences of catastrophic failures of LNG ships should be more carefully considered.

The LNG shipping industry, as is clearly the case with the entire LNG industry, has an enviable record, of which I think they should be proud. However, this is surely not a time for complacency, or cutting corners. I believe that serious consideration should be given to recommendations to the United States Congress by the Government Accounting Office (MARITIME SECURITY – Public Safety Consequences of a Terrorist Attack on a Tanker Carrying Liquefied Natural Gas Need Clarification , GAO-07-316, February 2007) to determine the potential for cascading failures of the LNG containments (tanks). The GAO has called the cascading failure issue the leading unaddressed priority need for LNG safety research associated with LNG shipping.

If an LNGC were to be attacked in the proximity of the shoreline, either while docked at the terminal or in passage in or out of the estuary, and cascading failures of the ship's containments were to occur, it could result in a pool fire on water with magnitude beyond anything that has been experienced to my knowledge, and in my opinion could have the potential to put people in harm's way to a distance of approximately three miles from the ship. I have testified repeatedly that I believe that the parties that live in areas where this threat could affect them deserve to have a rational, science-based determination made of the potential for such occurrences, no matter how unlikely they may be considered.

In closing I want to say that the Kilgogan Resident's Association assured me in requesting my presence here today that their main concern "has been and remains the safety aspects of the Shannon LNG project and the idea of having to live with the thought of an accident, however remote, for the next number of decades." They have assured me that they are not against LNG, and that they have endeavored only to highlight any shortcomings for completeness in the quest to insure public safety to the maximum extent practicable. Finally they have assured me that they have attempted to be pragmatic in the consideration of what will ultimately be required tradeoffs of the environment with the economy.

It is because I agree completely with these sentiments, and because I want only to ensure to the maximum extent possible that we site LNG terminals, as should be the case for any other major hazards industry venture, in full view and observation of the best scientific knowledge and guidance available, that I happily agreed to appear here today.

Thank you,

Jerry Havens

Distinguished Professor of Chemical Engineering

University of Arkansas, USA

Personal Information Withheld - Gabriola, British Columbia

The people and the whole coastline do not want this to be built. It will enrich the foreign buyers and leave nothing but a toxic environment for we the people to live with, and our decision makers will be far away spending their bonuses for letting this happen. Look at the facts....businesses get their way by political donations, and we get nothing but their mess to live with. I say NO.

Personal Information Withheld - Prince Rupert, British Columbia

I am very much against LNG. Digby Island is a vital community that would be destroyed If LNG got the go ahead. Please, Please, Please, say NO to LNG.

Laurie Parkinson - Bowyer Island, Howe Sound, British Columbia

About 3/4 of the natural gas that BC extracts and uses comes from fracking. With the increased fracking from LNG export, soon 100% will come from fracking. Fracking often results in contamination of ground water with a cocktail of toxic chemicals that can be trade secrets of the fracking co. These chemicals are injected into the ground using a large amount of fresh water, which becomes permanently contaminated, removed from the hydro-logical cycle. I expect you have also heard of the earthquakes from fracking. Have you heard of the natural gas (methane) that leaks out of the ground, with fracking? Methane is a very powerful greenhouse gas - much worse than carbon dioxide. It leaks from the ground, from poor joins in the pipes, from the LNG plant, and from tankers as they go overseas. If old tankers are used, they have to vent warmed LNG (methane) as they cross the ocean, for safety reasons. So, according to David Hughes, highly respected Canadian geoscientist, BC LNG is 27% worse re greenhouse gasses than the best coal burning technology China can build. BC is not slowing climate change with an LNG export industry.

Karen Antonsen - Prince Rupert, British Columbia

No LNG Terminal on Digby Island. This way too close to Dodge Cove and the city of Prince Rupert.

Personal Information Withheld - Dodge Cove, British Columbia

I am submitting this report on Canada's oceans - I feel that it is very relevant to the Aurora LNG final application and the effects that will be felt by CNOOC-Nexens' proposal for the Skeena River estuary. I feel that the BCEAO should read this report and include it while reviewing whether or not the Aurora LNG project should be approved.
http://journals.plos.org/plosone/article/file?id=10.1371/journal.pone.0012182&type=printable

Laurie Parkinson - Bowyer Island, Howe Sound, British Columbia

All of the hopeful LNG export plants, including Aurora, are owned by multinational companies. They all have their ownership set up so there is an offshore company and a local company. The offshore company buys the natural gas and sells the LNG - and pays taxes overseas, not to BC or Canada. BC also doesn't charge PST on natural gas exported. So we won't get the usual taxes for roads and schools from Aurora or any other LNG plant. This is very poor return for the small number of long term jobs that come from LNG plants.

Laurie Parkinson - Bowyer Island, Howe Sound, British Columbia

Contrary to what the BC government says, oil and gas are not significant employers in BC. They only provide about 3% of the jobs. Yet the BC government can't seem to find enough subsidies to give the hopeful LNG export industry. Historically subsidies are paired with with a company providing lots of jobs. LNG plants hire a few hundred people directly, long term. Big mines hire several thousand people directly, long term. Both receive subsidies. The BC government can't seem to find enough subsidies to give the LNG industry. Most recently it's eDrive rate, and shortly after that, no resource co, including LNG, has to pay PST on electricity. This puts a lot of responsibility for BC taxes on the average citizen, not on LNG companies. It would be ok if LNG plants hired masses of people like big mines do. But LNG companies hire a very small number of people long term. Oil and gas provide 3% of BC's jobs. This doesn't make sense.

Laurie Parkinson - Bowyer Island, Howe Sound, British Columbia

There is presently a significant oversupply of LNG in the world. The global oversupply is becoming larger, soon to be 2x what is needed. The US got the jump on Canada re LNG plants because they used to have lots of LNG import plants. These import plants are being retrofitted to be LNG export plants. It makes no sense for BC to be planning any new LNG plants.

LJ Moore - Dodge Cove, British Columbia

To EAO, Public Comment re: Aurora LNG EA application

Submitted by: LJ Moore, Dodge Cove, Digby Island, BC

As well as being a health hazard to local residents, the Aurora LNG facility proposed for Digby Island would pose a considerable risk to other marine traffic using the Prince Rupert harbour entrance at the south end of Digby Island. In its application, Nexen provides no baseline data to account for present volumes of marine traffic . With 3 major ferries on scheduled runs to Haida Gwaii, Alaska and Port Hardy, container ship traffic, grain, coal and soon propane, tugs, barges and other commercial and freighter traffic plus a still-substantial fleet of fishing boats, local small vessel traffic, pleasure craft, sports fishing boats, kayakers and whale-watching vessels passing through the entrance; Prince Rupert harbour is a busy place. With a loading time of between 12 and 24 hours per LNG carrier at the rate of between 160 LNG carriers (2 trains) and 320 LNG carriers(4 trains at full build-out) per year to be loaded at a propsed jetty on Fredrick Point from a pipeline offshore at the narrow and dangerous entrance to Prince Rupert Harbour and with a 500 meter exclusion zone: not much time or space left for others to pass at a safe distance and enter the harbour Meanwhile, the federal government has plans to hand over the regulating and monitoring to the proponent and a port authority "regime" whose mandate is to promote big industries such as LNG. What about the rest of us?

"Locations that already attract other craft, including pleasure craft and fishing vessels, are inherently unsuitable for LNG terminals. In such circumstance enforcement of the exclusion zone is highly problematical and, even with enforcement effort, may ultimately fail." And "Port designers should be directed to construct jetties handling hazardous cargoes in remote areas where other ships do not pose a collision risk and where any gas escape cannot affect local populations" (Both quotes are from the Society of International Gas Terminals and Tanker Operators (SIGTTO) Standards.

Alternatives: Offshore terminals are becoming a reality. Enhances safety and security by keeping a buffer to infrastructure and population, avoids port related vessel traffic, weather delay and daylight restrictions, reduces onshore and nearshore impacts of dredging and site prep and allows projects to target specific markets where supply is needed. All the components for the facility are coming from China.The camp would be FIFO (fly-in-fly-out) with only 5-10% local employees and any of the hired locals would be on 2 week shifts and locked in for that time, same as the rest of the workers, so why put it on Digby Island anyways?

Fact evasion, controversial assumptions used in modelling, a patchwork assembly of baseline data for valued components or sometimes no baselines at all, no answers to valid and serious questions: Where is the logic in fast-tracking a project of this magnitude when there are so many omissions in the application and so much at risk in its approval?

LJ Moore - Dodge Cove, British Columbia

Public comment to EAO re: Aurora LNG EA application

Submitted by: Laura Moore, Dodge Cove resident, Digby Island, BC

I have come to the conclusion that the Aurora LNG if built at this location on Digby Island would significantly compromise the health and well-being of the residents of Dodge Cove, Metlakatla and the Fairview and Westview areas of Prince Rupert. Between the poorly chosen site in the Skeena River Estuary ,with their Project boundary overlapping the communities official boundary, the high volume of toxic emissions, the noise from all the blasting, heavy equipment and helicopter traffic during construction, the danger of a lethal gas leak during operations, the Marine Offloading Facility proposed for Casey Cove for transporting and dumping of toxic materials and dredgeate, of garbage incinerators from a 3000-man camp less than 1 km from the quiet and presently healthy community of Dodge Cove and an industrial highway in the communities watershed. I object to Nexen's conclusions that through mitigation and monitoring there will be no significant effects.

With the further destruction of critical eelgrass in Delusion Bay and with it salmon, cod, steelhead, crab and shrimp habitat; the elimination of all freshwater streams within 900hectares of the shoreline that makes Spire Ledge such a great fishing spot; the blasting and dredging, continuous lighting and tanker traffic for 30+ years and just 2 miles from the already-approved PNWLNG facility on Lelu Island; another nail in the coffin of the Skeena River estuary ecosystem with its rich and diverse life would be cruelly hammered home.

Consider the frequency of flaring which the Aurora application is very vague about and the fact that they plan to power their massive LNG facility (x4 the size of Woodfibre) with natural gas, adding even more to BC's GHG emissions. The proximity of the proposed power plant to Dodge Cove properties is only 750 meters. Imagine standing at the fence beside the Vancouver airport runway: the 2 generators would sound like a boeing 747 at take-off volume, 24 hours per day, 7 days a week, 365 days per year. That would be the magnitude of the sound in the community.

Nexen has also down-played and insufficiently informed the public regarding the hazardous characteristics of liquefied natural gas (LNG) and the effects it could have if there was an accident or malfunction so close to human populations and wildlife. Their application fails to describe worst-case scenarios. They also don't disclose major accidents, even disasters that have happened nor incidents where evacuations were necessary. What actually happens when there is a small leak, a medium leak, a big leak? All they say is that LNG does not explode and that the risks are "relatively" low. If it doesn't explode what exactly does it do? What is a flash freeze, how does asphyxiation occur in the case of a leak and what is a pool fire? Nowhere in the application are these mentioned or described. Why do Sandia and SIGTTO recommend 3km distances from communities and describe hazard zones and exclusion zones of 500 to 3000meters? Neither has Nexen formulated an Emerge ncy Response Plan nor an evacuation plan. They have not addressed the fiscal condition of the area, i.e. the relationship between the cost of services required to meet the health and safety needs of the population and the robustness of the tax base available to finance those services. The region does not have a large enough tax base to support large investments into hazardous materials response equipment. It is difficult to estimate the cost for coordinated emergency planning but it could easily run into millions. Who would pay? Who would be held responsible? Where is the transparency? And the public is supposed to trust in this process?

Personal Information Withheld - Prince Rupert, British Columbia

I have DEEP concern with LNG development on our beautiful BC coast and natural gas extraction period. The environmental impacts are NOT worth it. This particular plant threatens the livelihood of many coastal people. I DO NOT support LNG in BC. We need to move towards renewables! Geothermal, solar, wind, tidal.... there are so many options to invest in, lets invest in the future, not an outgoing way of thinking. There is no silver bullet solution but there are A LOT of solutions out there! Save our beautiful coast line for tourism, fisheries, biodiversity, and stability. No one pays to come to BC to see industry, they can get that anywhere. Please don't spoil what we have left.

Bill Troughton - Prince Rupert, British Columbia

The winds on the south end of Digby island regularly reach 90 miles per hour.I just want the powers that be to know that when these huge ships are jammed on the rocks and across the harbor entrance that many fisherman like myself new this disaster was going to happen. How come i don't here about the reality of Rapid Phase Transition Explosions anymore.

Personal Information Withheld - Dodge Cove, British Columbia

The reports from the residents in Rossport are heartbreaking. There is no reason that these terminals need to be placed so close to communities. The reports from Dodge Cove, Canada are going to be just as heartbreaking if the Aurora LNG terminal is approved. This will be another black mark on the management of this country, this location is not necessary any way you look at it.

"The flaming began in November and ran through into January. The flaring was part of the testing process for the plant, ahead of first gas coming ashore."

"the parish newsletter, "saying that all our troubles were over, that we had been saved at last, gas coming and money. They had no idea."

The population is split in 3 - "those who saw the dangers, and voiced their opposition; those who considered the issue from a business perspective and supported it; and then "the mass of those who were concerned, but not enough to say anything about it."

"the community were hungry for jobs, to try to keep the youth, and they didn't think about the flares or pollution."

People trusted those behind the project. "And that trust was manipulated, and destroyed."

The company, Shell, admits there was more flaring than "initially envisaged."

"I have no problem with Shell. I expect a dog to bark. But we do expect the government and the official agencies to do their jobs."

"Right from the beginning , they say it was about health and safety. Not gas. It was about health and safety in a small, rural, aging community, a knot of people in a sprawling, beautiful but mostly empty part of the western seaboard, conscious of their rights as citizens."

"It was their land, their livelihoods, their community they felt were under threat. What about the alternative plan for the terminal to have been built in a much quieter area some 20 km away? Couldn't there have been another way?"

"They are concerned about pollution, accidents, the fear of a potential disaster. (Now that the gas is going in right beside their homes) "how can we relax and say this is over?"

"The time taken up with learning and working about a subject that I have no interest in the wide earthly world in."

http://www.irishexaminer.com/viewpoints/analysis/corrib-controversy-gas-flow-not-the-end-of-communitys-struggle-331185.html

https://www.youtube.com/watch?v=FtIjMHRFrO4

http://documentarylovers.com/film/pipe-down/

Dick Spring - 20th October 1987 – then leader of the Labour Party on the introduction of the giveaway terms introduced by Ray Burke which were subsequently improved (for the oil companies) 5 years later by Bertie Ahern.

"We will now, as a result of the changes this Government have made, get absolutely no return whatever from the development of any foreseeable oil find .....

What is most serious about this development is that there has been, up to now, a certain level of national consensus about how we should view our natural resources — even parties that did not really believe it were prepared to pay lip service to the notion that the natural resources of Ireland belonged to the people of Ireland. In the breaking of that consensus, and in their cold-blooded decision to give those resources away, Fianna Fáil have committed what I have already described as an act of economic treason, one for which I believe they should not be forgiven by the young people and by the people at large."

http://www.shelltosea.com/content/just-how-bad-irelands-oil-gas-deal

Pat "Chief" O'Donnell, a fisherman from Rossport, was immediately wary of the environmental impacts of such a project on an area famed for its natural beauty. "I was worried from the beginning," he told me. "When I got the environmental impact statement in early 2000, I thought, 'this is colossal'. It seemed like they wanted to build a monster in the middle of a palace. It was going to destroy our home and my livelihood."

But the fisherman could never have imagined the devastating impact the Corrib gas project would have on this once close-knit community.

The David and Goliath story wasn't always told in the media, which came in for criticism for failing to portray the protesters fairly. "We were made out to be criminals, every element of the state was behind Shell. I was so naive I really thought someone would pay attention and see this for what it was – a small community defending itself," Pat said.

Pat O'Donnell reflected on the innocence of the remote village: "We were so naive…And for what? For protecting the land we love? For not wanting huge companies to destroy our home?"

"I was travelling with my son last night and we saw huge flares in the distance, which shows they're testing flaring now," Pat told me. "Massive flames in the sky, but if we burn a bit of rubber out the back we'd have the Gardai down on us straight away. If they had to kill people to get this through they would. Anything to clear the way," he said."

https://www.vice.com/en_uk/article/rossport-gas-exploitation-protests-209

Does Canada know its resource of oil and gas?

The Norwegian government (in 1958) did not know, but it still had a much different attitude and did not adopt a "civil servant attitude".

That same attitude cannot be said (being able to dictate terms to the oil and gas companies) with the way this industry is handled in Canada. We are in a position where we own our resources, and we are in a position as a country where we can dictate to the oil and gas industry. If this is not true, then why not?

Norway considered it strategically important to ensure Norwegian sovereignty over its rich resources. Why is Canada not thinking that this is equally important? Canada should be learning from all the countries that are mismanaging their resources and NOT following in those countries footsteps.

Eoin Finn - Howe Sound, British Columbia

I am opposed to your granting this plant an Environmental Certificate. For many reasons, including (principally):

- Siting: Were Canada internationally-accepted siting standards, including the Industry's own (SIGTTO), locating this dangerous plant so close to human populations would have been disallowed well before this stage of the assessment as being far too great a threat.

- Emissions: As shown in the attachment, direct GHG emissions from this facility, if gas-powered, will be in excess of 8.5 MTPA. Counting upstream emissions, that total is certain to exceed BC's entire 2030 GHG emissions budget and flies in the face of international commitments made in Paris at CoP21 in late 2015.

- Fracking: BC's gas is currently sourced 75%+ from fracking operations, which are highly destructive to the ecological health of N.E. BC. Fracking operations permanently pollute scarce groundwater, trammel indigenous rights and title guaranteed by the Federal Government, and leave our Province open to ridicule on the international stage for failing to live up to its UNDRIP obligations

- Economics: The economics of this industry are currently in tatters, and are certain to stay that way well into the next decade. Without the substantial financial assistance this BC Government has given the industry, such facilities would have gone away and scarce capital would be seeking greener pastures. The benefits to the local (BC) economy , given the tendency of such international investors to squirrel away profits to offshore tax havens, are minimal.

- Renewables are the future, and will replace fossil fuels as our primary energy source. If we are to survive climate change, that must happen. Why we would bother to invest in yet another sunset industry and call that progress is beyond me. Australia's LNG nightmare - where it is currently importing LNG (at 3x the local price) because it has overcommitted its available gas resource to exports, should be a sobering lesson for BC.

In summary, I feel that BC is proposing to develop this hazardous industry in an inappropriate location without first implementing a regime of regulations and regulatory oversight. These should be at least as rigorous as those in peer-group nations with more experience in LNG matters than Canada's. BC has not given sufficient regard to its environmental and safety consequences for Digby Island and and its inhabitants. We contend that both the NEB and EA processes by which the project has proceeded to this point are deeply flawed, and I request that these processes be suspended and approval withheld until those flaws are corrected and the process is repeated from a point where decision data required for improved processes are gathered and examined in a rigorous, fair, transparent and objective process.

Lou Allison - Dodge Cove, British Columbia

March 9, 2017 For the Public Comment for the Proposed Aurora LNG Development

from: Lou Allison, resident of Dodge Cove, Digby Island, BC

RE: Dodge Cove as "vulnerable" and "non resilient" as identified in the EA

The residents of Dodge Cove object to being characterized in these terms: over the last hundred plus years, the population of Dodge Cove has shown itself to be able to adapt to change and to remain vibrant within itself as a community, as well as providing a haven, long or short, for many people wishing to take a step out and back from their lives in other places.

I assume that the terms refer to Dodge Cove residents as "vulnerable" and "non resilient" in relation to the Aurora LNG Project. I would like to turn the question around to: who would want a giant LNG facility next door? Who would want to adapt to change, unasked for and unwanted, on this scale?

We don't. No one else would either. Does that make us non resilient? We are asked over and over to identify our concerns, to list our concerns, to discuss our concerns, to think about mitigation for our concerns. The repetition is tedious, for us and for everyone else. I think why we don't want the Aurora LNG facility next to us, on the Island we love, should be obvious.

Margo Elfert - Richmond, British Columbia

As a biologist who lived on Digby Island for many years, I understand what a great community it is, and how important the Skeena estuary is. Not only to the communities in the direct vicinity, but also to the communities up the Skeena who depend on this resource. I realize this is across from Lelu Island, but any disturbance in that area will have a negative effect on this productive but fragile ecosystem.

To add insult to injury, I understand that the market for this resource (LNG) no longer really exists, so I am afraid that we will ruin this area before we realize how economically unprofitable it will be.

Council of the Haida Nation - Haida Gwaii, British Columbia

submission from Council of the Haida Nationsubmission from Council of the Haida Nationsubmission from Council of the Haida Nationsubmission from Council of the Haida Nationsubmission from Council of the Haida Nation

Personal Information Withheld - Prince Rupert, British Columbia

I' m local and I support this project.

Skeena Watershed Conservation Coalition - Hazelton, British Columbia

sumission from Skeena Watershed Conservation Coalitionsumission from Skeena Watershed Conservation Coalitionsumission from Skeena Watershed Conservation Coalition

Personal Information Withheld - Dodge Cove, British Columbia

If it has not already been looked at by the BCEAO regarding the Aurora LNG proposed project, there is a report that was done by Compass. It is called "Impact Assessment of LNG and Other Development on the Metlakatla First Nation" prepared in 2014.

This report highlights many issues in this area, many concerns that would not just be for Metlakatla but also for other residents in the area.

At the time it assessed the potential impacts of 4 proposed LNG project: BG group Prince Rupert LNG, Spectra's Westcoast Connector LNG pipeline (to supply BG Group), Petronas' PNW, and TransCanada's proposed Prince Rupert Gas Transmission pipeline (to supply PNW).

Aurora LNG at the time of the release of this study was still months away from switching their proposed LNG terminal site from Grassy Point to Digby Island, otherwise I am sure that they also would have been named in this study. Even so, the study highlights several areas of impact and does a good job of reflecting many concerns, and includes statistics and data that may not be shown in the Aurora LNG final application.

Personal Information Withheld - Prince Rupert, British Columbia

I wish to voice my concerns regarding the new proposed Liquified Natural Gas project on Digby Island, British Columbia. Please see the attached PDF outlining these concerns. Thank you for your time and sincere consideration.

To Whom It May Concern:

I am writing today to voice my concerns regarding the Aurora LNG Digby Island Project.

As an ex-resident with close ties to the community of Dodge Cove and a Masters Student studying Environmental Sciences, I am attempting to see rationally how this project could be allowed to proceed. The present costs associated with the risk to people and ecosystems appear to outweigh any economic benefits from this project.

Some areas of concern that I feel should be addressed properly are: Consultation and consideration for the people living in the area; wildlife and ecosystem impacts of marine, wetland and terrestrial habitats; mitigation of marine transport risk; mitigation of short and long-term impacts to air and fresh-water; and mitigation of noise pollution impacts on both people and wildlife.

Present evidence points to a lack of proper consideration of all the above concerns in the planning of this project. I hope this is seriously considered in the coming phases of impact assessment.

Some serious concerns have been voiced by the community less than 1 km away from the proposed project. These are impacting the residents negatively and affecting their physical and mental well-being.

These serious concerns include: Significant impacts from noise (including intense helicopter traffic within 500 m of homes), light, air and water pollution during construction and operation of the facility; proposed construction of a 3 lane highway through pristine wetlands and less than 500m from homes; loss of heritage, history, and quality of life; proposed construction of an off-loading facility requiring dredging and removal of eel grass habitat; a proposed tanker terminal which does not comply with the standards as set out by The Society of International Gas Tanker and Terminal Operators (SIGTTO); the potential for collision, severe winter storms, grounding of vessels, and oil spills or LNG tank ruptures; health risk associated with airshed, drinking water and soil pollution from NO2, SO2, CO, H2S, Particulate Matter and Volatile Organic compounds as well as CO2 and methane (the Prince Rupert Airshed study conducted by the BC Ministry of the Environment indicates the highest concentrations of pollutants will be directly above the community of Dodge Cove); degraded air and water quality causing acidification could have severe and long lasting negative effects on wetland species; disturbance to the riparian zone of Delusion Bay could negatively affect nesting waterfowl; road construction proposed through pristine undisturbed wetlands which would be severely degraded and pose a risk to migrating species as they cross; tall flare stacks emitting burning gasses in line with migration routes of geese, ducks, swans, sandhill cranes, numerous shore birds and song birds

These concerns should included in any cost benefit analysis of the proposed project. Detailed mitigation measures should also be outlined and communicated to the residents of the area.

Please consider these concerns, my opposition and the opposition of the residents of the area in the coming phases of this project. Above all else, please consider the people who will have to live in close proximity, downwind and downstream of this project, and their physical and mental well-being.

Personal Information Withheld - Dodge Cove, British Columbia

Non-aboriginal Pacific Northwest Coast maritime culture has not been discussed on any level. When looking for maritime culture in Canada, one invariably is directed to the East Coast Maritime provinces. When looking for Pacific Northwest Coast culture, one is pointed to the rich native culture historically and present.

There is much written about the HISTORY of non-aboriginal communities here on the Pacific coast, but there doesn't seem to be any direct studies or assessment of the present culture, and how quickly it is being impacted and changed by outside forces. This is somewhat of a modest approach of the residents of these communities, to not see our daily lives as important or as having any special meaning, and also since most of us live the way we do since we want to be left alone. Yet if the capability of being able to practice this culture is removed, then how will this culture survive?

With these major industrial projects such as Aurora LNG that is threatening to engulf the community of Dodge Cove, this will have a drastic impact on the culture of which we are part of. I don't see much acknowledgment of this, or awareness on behalf of the government. The loss of this unique way of living will be a loss for this region, this province, and this country. It used to amuse me to tell people the story about my uncle, who has travelled the world all over, and lives predominantly in southern BC. He had just returned from a trip to Portugal, and then flew north to visit us and so of course we brought him by skiff to our property on Digby Island, and I just remember his comment that is was a bigger culture shock for him to come visit me on Digby than it was when he went to Portugal. It really emphasized for me that we are living in a unique way, and what is second nature to us is surprising to other people.

"Culture is essential for human beings since it is the key for people to identify themselves and fit in the groups. The culture can be the sum total of people's behaviors, along with the things such as language, traditions including burial rituals, weddings, and so on. People will build their networks and relationships according to those cultural ideas, and form different types of groups of people. The similarities between the lifestyles of a people and their descendants pass on, gradually developing a cultural heritage.

Modernization2 and economic development is another cause of cultural extinction. In addition, cultural imperialism3 can also force some minority cultures die. The phenomena of cultural extinction are increasing all over the world. Cultural extinction includes the loss of language, traditions, habits, and customs. Like the various species of animals and plants, cultures can become extinct as well

Many traditional ways of life are also being lost because of industrialization and modernization.

What we can do to help preserve endangered cultures? Firstly, we need to raise people's awareness how important different cultures are and what the negative consequence would be if more and more cultures become extinct. In addition, people who are not members of a particular culture in their country should learn about the endangered cultures and the value that culture adds to the entire country. Countries need to identify innovative technologies and solutions to help preserve different cultures and cooperate with each other. Governments must work to stop cultural extinction.

https://msmunatunagb.wikispaces.com/file/view/Cultural+Extinction.pdf

Intangible heritage focuses on the customs, celebrations and human geography that is found in such places.

Songs feature heavily, as do oral stories, festivals, traditional craft items and the knowledge required to produce them. Sometimes, even rituals, as practised by a shaman, or what Unesco describes as "practices concerning the universe", find their place. Underpinning the concept of intangible heritage is the belief that these things that make a people – a nation, a place – tick are handed down from one generation to another. That is something to be celebrated in an increasingly globalised world becoming more homogenous by the day.

(It should be noted that of all the different cultures that are considered as being impacted and should be acknowledged as need help, from many different countries, that Canada has absolutely nothing on this list) http://www.international.gc.ca/trade-agreements-accords-commerciaux/topics-domaines/ip-pi/canculture.aspx?lang=en

The drafters of the 1948 Genocide Convention considered the use of the term (cultural genocide) but dropped it from their consideration. The legal definition of genocide is left unspecific about the exact nature in which genocide is done only that it is destruction with intent to destroy a racial, religious, ethnic or national group as such.

Article 7 of a 1994 draft of the United Nations Declaration on the Rights of Indigenous Peoples uses the phrase "cultural genocide" but does not define what it means. The complete article reads as follows:

Indigenous peoples have the collective and individual right not to be subjected to ethnocide and cultural genocide, including prevention of and redress for:

(a) Any action which has the aim or effect of depriving them of their integrity as distinct peoples, or of their cultural values or ethnic identities;

(b) Any action which has the aim or effect of dispossessing them of their lands, territories or resources;

(c) Any form of population transfer which has the aim or effect of violating or undermining any of their rights;

(d) Any form of assimilation or integration by other cultures or ways of life imposed on them by legislative, administrative or other measures;

(e) Any form of propaganda directed against them.

This declaration only appeared in a draft. The United Nations Declaration on the Rights of Indigenous Peoples was adopted by the United Nations General Assembly during its 62nd session at UN Headquarters in New York City on 13 September 2007, but only mentions "genocide", not "cultural genocide", although the article is otherwise unchanged.

Indigenous:
1. originating in and characteristic of a particular region or country; native (often followed by to): the plants indigenous to Canada; the indigenous peoples of southern Africa.

There are people that presently live in Dodge Cove that are indigenous to Dodge Cove.

There are people living on Digby Island that are indigenous to this region and others that are indigenous to coastal BC.

There is nowhere else that is home. This is OUR culture, this is OUR home.

Lana Lowe - Fort Nelson First Nation

Fort Nelson First Nation is pleased to provide initial comments on the Application by Nexen Energy ULC for its proposed Aurora LNG Digby Island liquefied natural gas ("LNG") facility near Prince Rupert, BC, and on the associated environmental assessment of the proposed Project.

This submission provides the BC EAO and CEAA with information on how the proposed Project will impact upon FNFN rights and interests as currently proposed, and what needs to be done to better assess these impacts and infringements. Despite not being afforded any form of status in this environmental assessment by the federal or provincial government to date, FNFN will show evidence herein that we are likely to be one of the most adversely affected parties, due to the inducement of upstream gas development activities in our territory by the proposed Project.

Fort Nelson First Nation Submission to Aurora LNG Public Comment Period

Personal Information Withheld - Dodge Cove, British Columbia

Hammerfest again: These concerns highlighted by the town of Hammerfest are all very valid and definitely are ones that have already been an issue with the communities of Dodge Cove, and the town of Prince Rupert, or issues that will be felt in the future especially if the CNOOC-Nexen Aurora LNG project gets approved.

- contact with stakeholders faded away once the social license to operate was achieved.

- residents had to sacrifice time (eg. Fishermen sacrificed time at sea) to engage in talks with Statoil to save their livelihood

- during construction, Hammerfest became invaded by a huge mobile work force, which occupied all the tourist accommodations which then directly harmed the tourism industry.

- local residents were overwhelmed and stopped visiting bars and restaurants

- the local community is now dependent on Statoil's financial contributions and property taxes, but merely transfering money to the community does not create community development.

- the town was a local small-scale community, with the municipality forming policies, changed drastically to Statoil becoming the dominant power

- local concerns for community development were overshadowed

- community development is mainly addressed by the "local user" community and lacks support from the "national policy" community

- the oil and gas industry just "ticked the boxes" that they had to re: environmental soundness and community development, rather than a real long-term investment in those areas - contacts with fishermen, local inhabitants and NGO's faded away once the company got what it wanted.

- "Performance- based supervision allows Statoil to consult national research institutes of their own choice to monitor different parts of the environment, which are not allowed to advise Statoil in policy making. Monitoring results are submitted by Statoil and discussed one-one one with the state agency at stake.

-research is broken up across different research institues and state agencies with different scopes and little communication between them. - In the end, knowledge in this marine community is concentrated in the national policy community which compromised access to this knowledge for all stakeholders. Statoil becomes rather powerful due to this monitoring system because it is the only one who has a proper overview of all available knowledge.

https://www.researchgate.net/publication/300080159_Liquefied_natural_gas_production_at_Hammerfest_A_transforming_marine_community

Personal Information Withheld - Dodge Cove, British Columbia

An very relevant article that should be read.

Four More Whoppers about LNG in British Columbia The real facts behind Christy Clark's rosy claims.

By Andrew Nikiforuk 16 Mar 2016 | TheTyee.ca Andrew Nikiforuk is an award-winning journalist who has been writing about the energy industry for two decades and is a contributing editor to The Tyee.Nikiforuk's book on hydraulic fracturing, Slick Water, was published this fall by Greystone Books.

BC Premier Christy Clark: a million-dollar website to drum up LNG jobs, but not a single job yet.
The B.C. budget claims the province is making money from shale gas. But last month The Tyee showed the province is pouring more cash into the industry than it is getting back.

Three Wacky Accounting Numbers for LNG and Shale Gas In fact the only time the B.C. government made any money from shale gas was during a land lease boom nearly a dozen years ago. Ever since then, revenues have dwindled to next to nothing due to low royalties and taxpayer-funded subsidies to the ailing shale gas industry.

Dig deeper, and four more claims made by the B.C. government turn out to be liquefied natural gas whoppers as well.

New information on employment numbers, shale gas reserves, transmission lines and the LNG promise of economic prosperity show that stretching the truth remains a persistent trend in the Christy Clark administration.

Whopper #1: Vastly less gas to sell than claimed Let's begin with the government claim that British Columbia "has more than an estimated 2,900 trillion cubic feet (tcf) of marketable shale gas reserves," or more methane in the ground than the entire United States.

Last year David Hughes, a former analyst with Natural Resources Canada who mapped much of the nation's coal and gas supplies, took a hard look at real reserves and found that the government claim had no basis in reality.

Hughes pointed out in a report for the Canadian Centre for Policy Alternatives that the BC Oil and Gas Commission estimated that B.C. only had 376 tcf of marketable shale resources. (Hughes added 40 tcf to this number for good measure, for a total of 416 tcf, to account for possible resources in developing plays.) But proven reserves, or what industry can extract with existing technology, were only 44.4 tcf. That's one sixty-fifth of the government's inflated figure of 2,900 tcf. When Hughes noted that the emperor was wearing no clothes, the emperor (Minister of Natural Gas Development Rich Coleman) accused Hughes of misrepresenting the facts.

Coleman wrote an op-ed that said "B.C.'s natural gas supports long-term prosperity." The op-ed did not correct the government's accounting errors.

But according to a series of freedom of information requests just received by Marc Lee at the Canadian Centre for Policy Alternatives, that's not what civil servants were telling politicians.

In several email exchanges, they admitted that the government had used the wrong terminology and "misused terms or values such as 'reserves,' 'resources,' or 'marketable' in describing B.C.'s oil and gas endowment."

Hughes notes that the BC Oil and Gas Commission now estimates raw methane reserves in the province to be 51 tcf. Once processed, that gas might amount to 44.4 tcf.

Yet National Energy Board regulators had already approved 12 export permits totalling 205 tcf at the time Hughes's report was published, and were reviewing seven more with a combined total of 435 tcf (the NEB has since approved another six permits).

If the Clark government's aspirations of five LNG terminals come to fruition, this would require exports of 150 tcf of gas by 2040, or more than three times current proven marketable reserves.

Given the uncertainties in resource estimates compared to proven reserves, coupled with Canada's own needs, Hughes, a conservative energy analyst, questions the wisdom of a strategy hell-bent on liquidating these finite resources as fast as possible, particularly if B.C. and Canada care about meeting the greenhouse gas emission reductions committed to in the Paris climate talks. Yet the dubious figure of 2,900 tcf remains on the government website.

Whopper #2: Vastly fewer LNG jobs than claimed The next wacky accounting LNG figure concerns the government claim that its non-existent industry will gainfully employ 100,000 British Columbians some great day in some near future, or more specifically 2018.

Last year, Lee at the CCPA also dug into that fiction.

He discovered that the impressive and magical number came from a report written by the accounting firm Grant Thornton. The firm only used government-provided data and economic models.

Not surprisingly the government published the report just prior to the 2013 election. In his study Lee found the numbers were highly inflated and bore no resemblance to the real economic world of LNG.

Lee concluded that B.C.'s LNG sector could be expected to support "only 2,000 to 3,000 construction jobs per LNG terminal over three years and 200 to 300 permanent workers once operational." As a consequence, five LNG terminals might create between 15,000 short-time jobs, but not 100,000.

When Lee released his findings last year the government immediately attacked the CCPA report as "misguided and poorly researched."

A freedom of information request, however, has revealed, once again, that email exchanges between civil servants largely supported Lee's version: real job creation numbers might be a few thousand but not 100,000.

One email thread confirms that the Petronas Pacific NorthWest LNG project will launch only "330 long-term operation careers."

Clear-headed analyses by the industry around the world also confirm Lee's realistic job assessment and question the government's credibility. The International Monetary Fund, for example, recognizes LNG as a capital-intensive industry with a poor record of job creation. A typical LNG plant will only create a few hundred jobs during the planning phase, a few thousand during the construction phase, and only a few hundred when operating. That's it.

Consider the example of Mozambique, which wants to exploit its rich offshore natural gas reserves. A 2014 report on its prospects emphasized the well-known fact that LNG is not a job-creating industry. "In terms of employment, the capital intensive nature of the industry means that its direct contribution to job creation is extremely limited, at less than 0.5 per cent of formal sector jobs," explained the Oxford Institute for Energy Studies report.

"Of key importance will be the ability to link the extractive sector -- which is capital intensive and responsible for few direct jobs -- to the wider economy," added the report.

And then the report makes this notable revelation: "Unlike the situation in Tanzania, where politicians frequently promise citizens tens of thousands of jobs in the gas industry, the Mozambique government's expectations of massive job creation have already been moderated. Most estimates put job creation linked to the LNG ventures at around 7,000–7,500."

To date, a million-dollar government website designed to connect citizens looking for work in the LNG industry has not connected anybody to anything. But it has employed one previous politician, Gordon Wilson, a former leader of the BC Liberal party.

Wilson now earns $150,000 a year to advocate for a capital-intensive industry that hasn't created any jobs -- except for Clark supporters.

In Australia, LNG has left another poor employment horror show that the government in B.C. has failed to study or acknowledge. Unfettered LNG exports in Australia not only increased both natural gas and electricity costs for consumers, but also reduced the manufacturing sector's ability to compete and create jobs.

"U.S. policymakers should look to the Australian LNG export example as a warning for what can occur due to escalating LNG exports," recently warned one industrial energy consumers' group. In other words, a successful LNG business could kill the province's manufacturing base by inflating natural gas prices.

Whopper #3: No, LNG prosperity is not close at hand Along with the jobs fiction, the government has also manufactured a prosperity fiction. In February the Conference Board of Canada published a glowing report on the province's proposed 21 LNG projects called "A Changing Tide: British Columbia's Emerging Liquefied Natural Gas Industry."

Even though not one project has proceeded to the construction phase, the optimistic report concluded that just three large LNG terminals could export 30 million tons per annum (MTPA).

Such activity would generate 33,000 permanent jobs and $7 billion in investment and raise GDP. It would also double the amount of shale gas production by an additional five billion cubic feet, and carpet-bomb much of northeastern B.C. with gas wells.

But these figures are all pie in the sky and again bear no resemblance to reality.

Here's one bitter taste of reality. Most readers will recall that Apache Corp., a Houston-based energy firm, conducted some of the largest frack jobs in northern B.C. and was one of the first companies to champion an LNG terminal. But in 2014 it sold its interests in its Kitimat proposal along with an Australian project. Here's why: last year the shale fracking company posted a loss of nearly $25 billion. That's right: $25 billion. Fracking shale gas, an exercise in declining returns, rarely pays the bills.

More reality can be found in a 2015 report by Oxford Institute for Energy Studies, a rigorous non-profit educational group based in London that analyzed the prospects for North America's LNG industry.

It was blunt: "Despite Canada's abundance of gas resources and the plethora of proposed LNG export schemes, the current business environment, characterized by low oil prices and industry consolidation, does not indicate that any Canadian LNG scheme will be commissioned before the middle of the next decade."

Moreover, "the window of opportunity to capture premium Asian markets has eluded the Canadian projects" because of deep uncertainty and falling demand in those markets. U.S. LNG projects are also cheaper.

The report concluded that the fate of Canadian projects is tied to the price of oil, and they would only succeed if oil were selling for somewhere between $76 to $90 a barrel, "which does not seem competitive with the first generation" of U.S. LNG projects.

In other words there is no emerging LNG industry in Canada, and if one does appear it won't arrive until 2025, or nearly a decade from now. And even that is uncertain.

The Conference Board (which makes no mention of the Oxford Institute report) was funded by Progress Energy, which is owned by Petronas, the Malaysian state-owned oil giant backing the Pacific NorthWest LNG project.

Most media stories on the report failed to mention this apparent conflict of interest. But the government of B.C. is only too happy to cite this as gospel while cheerleading a fantasy industry.

Whopper #4: Yes, Site C dam is for powering frackers Last but not least come some wacky accounting numbers on the Site C dam, a $9-billion public works project that analysts generally agree will increase everyone's electricity bills. Although provincial authorities swear the project has nothing to do with LNG, Ben Parfitt, an investigative journalist, has revealed otherwise in a DeSmog Canada article.

Last January, the province announced a new $300-million transmission line to power shale gas development in the south Peace Region. Two other transmission lines are also being proposed. The lines will allow shale gas drillers to use electricity to power their operations instead of methane.

As a consequence they'll have more gas to export and access to cheap energy subsidized by taxpayers.

What the press release did not explain, notes Parfitt, is that "virtually all of this new transmission infrastructure is being built at public expense to provide power to one entity and one entity alone -- the natural gas industry."

Two other proposed lines reinforce the story. One 140 kilometre-long project will fragment the forest to bring power to the Pink Mountain Region in the north Montney basin. It will benefit one shale gas extractor in particular: Progress Energy.

That shale gas drilling company is owned by Petronas, which successfully lobbied the government to lower its LNG tax rates. Meanwhile, Progress Energy paid for the boosterish Conference Board report.

Petronas is also one of the backers of the controversial Pacific NorthWest LNG project off Lelu Island at the mouth of the Skeena River.

ATCO, the anointed builder of the Petronas transmission line, recently argued that no public review of the project was necessary and asked for an exemption under Section 22 of the Utilities Commission Act.

"The project is being developed on an aggressive schedule to meet with Progress [Energy] timelines. Failure to meet these timelines reduces the feasibility of electrification and poses a substantial threat to the project proceeding."

Energy Minister Bill Bennett supported the corporate request in a Business in Vancouver story: "My understanding right now is that if I do not direct the BCUC [British Columbia Utilities Commission] to allow these projects to go ahead, that we may lose some interest on the part of the gas companies.... They just don't feel that they can wait for a long BCUC process."

When politicians elect to bypass mandated legislated safeguards to protect the public purse by evaluating the need for projects (and that's what the BCUC does), then they are no longer working for taxpayers.

But the logic is clear, says Parfitt. "The more transmission lines erected to allegedly 'green up' the field operations of fossil fuel companies, the more fossil fuel industry activity. The more such activity, the more the government and BC Hydro can justify Site C."

It's all a self-serving story. The government produces wacky numbers and accounting figures to justify corporate LNG scheming that no longer make any economic sense.

Years ago Jacque Ellul, the French philosopher, noted that "propaganda is called upon to solve the problems created by technology, to play on maladjustments, and to integrate the individual into a technological world." It's how government and industry now work.

In B.C. the government uses propaganda not only to integrate its citizens into its wacky LNG fantasy, but to subsidize foreign companies and pay for unneeded dams and transmission lines at the same time.

It is designed to make taxpayers smile while they are being robbed.

https://thetyee.ca/Opinion/2016/03/16/Whoopers-BC-LNG/

Personal Information Withheld - Dodge Cove, British Columbia

If projects like this (CNOOC-Nexen's Aurora LNG) are going to go ahead the project should be built in unpopulated areas where the least amount of impact can happen. I do not believe that projects like this should be going forward anyway.

The amount of capital invested in these projects is staggering. We should be using this capital to create sustainable sources of energy, it would create way more jobs and be better for the environment and the economy.

People say we need to get this stuff out of the ground and sell it now. Why? Is the world over tomorrow? No, we need these resources to make all the technology we rely on, so selling it all now is very near sighted, what about future generations?

Destroying my home so China can take our natural resources at a loss to Canadian tax payers is absolutely messed up. My home is being destroyed and we are getting nothing for it, as a country, or a region, or as a community. We are being sold out by our own government so that some foreign company can take our Canadian resources.

Anybody who thinks this will be a financial windfall for Canadians should actually research the numbers on this, financially and environmentally, and they will be shocked to see just how many lies they have been fed.

Our government shouldn't be allowed to enslave our country into deals beyond their own governing term. It's enslaving not just this generation but the next generation as well. Why should my child have to abide by these long-term deals that are made by a governing body that will be dead?

Personal Information Withheld - Dodge Cove, British Columbia

There is this idea that the LNG projects proposed for BC are for the "greater good" of our country. Yet we only need to look at Australia, or Scotland, and other countries that have reaped very little benefits from the oil and gas industry due to low tax incentives to encourage companies to build, and look at the debt of these projects and the burden that is placed on the average person, to know that this should not be a goal for our country.
These are finite non-renewable resources that belong to all Canadian citizens, that the gov't is essentially hired to manage. If this was an actual company, the decision makers (making these bad back-door deals that are giving our product away with such little benefit to the citizens of this country) would be fired.

"The court (in the U.S.) wrote that the public was not the "primary and paramount" beneficiary (of oil and gas pipelines), as the state had claimed.
"advances the proposition that (the pipelines taking over peoples' property) somehow will advance the development of infrastructure of the Commonwealth. Such a projected benefit is speculative, and, in any event, would be merely an incidental one," wrote Justice Debra McCloskey Todd for the majority.

"Mere economic benefit is not enough," said Bomstein. "Right now in Pennsylvania nobody is starving from lack of ethane. Nobody is crying in the streets for more butane. There is no apparent public need for these things and that's demonstrated by the fact that [the gas products] are being exported."

Once a company such as CNOOC-Nexen receives an approval for a project such as Aurora LNG, it's essentially a blank check to develop its infrastructure. With all variables to be "worked out with the agencies necessary" instead of putting those plans forward for public review. With such impact to local communities such as Dodge Cove, such decisions made by shady political leaders who are under intense scrutiny for their oil and gas industry connections and money-taking, and such a lack of benefit to this country, projects such as CNOOC-Nexens' Aurora LNG need to be told NO. Nobody is crying in the streets of Canada for more LNG to supply ourselves, but if it is drained from Canada, in the future that may very well be the case.

"Eminent domain attorney Rich Raiders, who represents a number of landowners who have cases with Sunoco, says his clients feel left in the dark on these decisions, and that the deck is stacked against them and in favor of pipeline operators."

https://stateimpact.npr.org/pennsylvania/2016/10/31/a-new-front-emerges-in-the-battle-against-eminent-domain/

Problems in Scotland with the oil and gas industry will most likely be the same in Canada. Overwhelmingly in the last 15 years we have seen the capture and increasing control of Canada by the oil and gas industry, of which there are many reports and data if one chooses to search for it. How are any of these issues different here? How are any of these issues studied in the Aurora LNG application, and by the Federal and Provincial governments of Canada? The avoidance of health standards, regulations, and requests for information from the Canadian government is clear throughout this entire EA process, and CNOOC-Nexen has done is best to make it look like the impacts will be minimal, when the reality is the impacts will be devastating on so many levels (that aren't even written into the AIR).

" the oil companies are failing to provide full benefit to the people of Scotland", The North Sea has been devastated by almost 45 years of oil exploitation with damage caused not only by disasters (such as the Braer grounding in 1993 luckily rough weather dispersed much of the oil spill) and oil slicks (which often go unreported) but also by the impact of everyday operations. This includes seismic ships setting off underwater explosions, drill cuttings being dumped on the sea bed, rigs and pipelines being coated in toxic chemicals, and the noise and light pollution of gas flaring. In recent years, Shell and BP have also moved into the pristine deep water of the Atlantic Frontier, host to enormous biodiversity including whales, dolphins and porpoises. The effects of exploration on these poorly understood ecologies could be devastating.

(Aberdeen) because of its reliance on the oil industry it would be very vulnerable to a price slump, or to oil companies moving out to more competitive locations.

Working in the oil industry is a precarious business, not just with the effects of climate change and the 'maturing' (i.e. 'running out') of the North Sea oil fields, but also with companies cutting jobs, casualising labour and very real health and safety issues. Besides, with the rapid advance of technology, there are now several unmanned rigs in the North Sea.

Casualisation and downsizing
'We believe cuts will have a massive impact on health and safety and that its only a matter of time before someone pays with their life.' John Wall, Amicus Scottish National Secretary. (The report does go on to list several "accidents" that did claim lives.)

80% of the North Sea workforce is employed by outsourced contractors rather than directly by the oil companies. 'Flexibility' is desirable to the companies as it allows them to change the number of employees in line with the booms and busts of the oil industry, and to keep costs down by forcing contractors to compete for their business. Outsourcing is also unhelpful in terms of safety, as with a transient workforce it is hard to maintain training, trust and cohesion, and outsourcing blurs the responsibility for accidents between operators and contractors.

Mounting accident figures on North Sea platforms have alarmed trade unions and led to questions about Britain's dependency on ageing oil and gas equipment where investment levels have fallen.

A confidential report by the Health and Safety Executive seen by the Guardian in December 2004 gave a frightening picture of broken safety equipment, ill-trained workers and badly-maintained systems.
'Despite one of the worst disasters in British history and the death of 167 men, the company has not been brought to justice and prosecuted for any offences relating to the death of the workers.'
Gavin Cleland, corporate manslaughter campaigner.

The major UK oil companies, in the meantime, have continued to erode workers' rights.
This was achieved by a series of financial inducements and psychological pressure.
The extremely anti-union oil industry and established unions failure to make them a safe place to work.
A note on workers
Oil workers don't have a great reputation. One source described life on oil rigs as 'builder culture gone mad'. The work is dangerous and requires long hours: 12-14 hours a day, 7 days a week (generally two weeks on and two weeks off). This working pattern is also disruptive to family life.

Oil workers may well be ready to speak about how globalisation has affected them through the profit-over-safety attitudes of the oil companies and the increasing casualisation and downsizing of labour.
It is probably safe to assume that oil workers will be less willing to speak up on climate change as any serious action on this would spell the end of their jobs.
The Grangemouth refinery and the surrounding plants and factories create a fantastical landscape at night, rather like the Blackpool illuminations, and the stories from fence line communities living within the glow of Grangemouth are shocking. There is constant noise and light from gas flaring at night, black smoke and fallout, high levels of asthma and fear of a major explosion. Incredibly, there has been no ongoing independent monitoring of the effects of the refinery on the health of those living nearby.

Recently there have been massive job cuts and R&D graduates have been favoured over locals.
The conditions also prevent other businesses moving in and have turned the nearby fertile agricultural land into marsh and bog.
Most locals commute to Falkirk, Glasgow or Edinburgh for work. Many locals are also afraid that the plant is a very serious security risk.
There is stronger feeling down the road in Bo'ness, a town that only suffers the pollution and has none of the employment benefits.
The 'capture' of Scottish universities represents problems for efforts to reduce climate change by replacing fossil fuels with renewables - public funding for oil and gas research mainly comes out of the same pots as funding for renewables research, so more research in the (big, rich, mature) oil industry means less for the (small, relatively poor, developing) renewables.
This hidden subsidy also serves to maintain oil industry competitiveness as compared to renewables and ties the thinking and strategy of universities to the interests of the oil companies."

Resources sourced by the G8:
1.Rising Tide, Beyond Oil: The oil curse and solutions for an oil-free future, October 2004, www.carbonweb.org/documents/beyond_oil.pdf, last viewed 10.03.05; Platform et al, Some Common Concerns: Imagining BP's Azerbaijan Turkey Georgia pipelines system, October 2002, available to download at www.baku.org.uk/some_common_concerns.htm, last viewed 10.03.05; Corporate Watch, 'The Oil and Gas industry 聳 A Guide for UK activists', 1998, www.corporatewatch.org.uk/publications/oil_gas.html, last viewed 10.03.05 2.Scottish enterprise website, 'About Scotland', www.scottish-enterprise.com/sedotcom_home/services_to_business_international/lis/aboutscotland/

about_scotland-keyfacts.htm, last viewed 10.03.05 3.Platform, Britain: 90 years as a Petro State, (forthcoming publication) 4.Corporate Watch Degrees of Capture: Universities, the Oil Industry and Climate Change, 2003,www.corporatewatch.org.uk/pages/degrees_of_capture.htm, last viewed 10.03.05 5.Valerie Darroch, 'African oil hopes for BowLeven on eve of flotation', The Sunday Herald, 05.12.04, www.sundayherald.com/46457, last viewed 10.03.05 6.'Wildcatter who came in from the cold. The Telegraph October 30th 2004 7.Rob Crilly, 'Tigers facing fresh threat at latest frontier in West's search for fuel' The Glasgow Herald 12.04.04, www.5tigers.org/news/2004/April/04_4_12w.htm, last viewed 10.03.05 8.KCA Deutag website, 'About KCA Deutag', www.kcadeutag.com/, last viewed 10.03.05 9.AMEC website, 'Rebuilding Iraq', www.amec.com/careers/careers.asp?pageid=699, last veiwed 10.03.05 10.Aberdeen Press and Journal 6/12/04 11.Seth Gitell, 'Cheney's corporate past ,' The Boston Phoenix, 21.09.00, last viewed 10.03.05 12.Bill Guerin, 'The time bomb that is Papua', Asia Times, 04.12.04, www.atimes.com/atimes/Southeast_Asia/FL04Ae04.html, last viewed 10.03.05 13.Wood News July 2004 14.'Wealth creation in Scotland' produced by the Royal Bank of Scotland. See note 152.

15.The Scotsman, 09.05.03

16.The Scotsman, 09.05.03 Source: www.ft.com 17.Brian Wilson, former energy minister and UK special representative on trade opportunities to Iraq, quoted in Brian Brady, 'British firms win 拢80m in contracts to rebuild Iraq', The Scotsman, 07.09.03, http://news.scotsman.com/archive.cfm?id=985202003, last viewed 10.03.05. For more info about corporate involvement in Iraq see Corpwatch website, 'War Profiteers', www.warprofiteers.com/article.php?list=type&type=176; www.voicesuk.org/, last viewed 10.03.05; future of Iraq Protal, www.justinalexander.net/iraq/, last viewed 10.03.05 18.Corpwatch website, Calum MacDonald, 'War Profiteers. Scotland: Contract 1030484 Turned Oil into Gold', The Herald, 16.11.04, www.corpwatch.org/article.php?id=11678, last viewed 10.03.05.

19.Terry Macalister, 'Iraq cash may be lost, says Weir ', The Guardian, 26.08.04, www.occupationwatch.org/article.php?id=6494, last viewed 10.03.05

20.'Iso-Britannia: Etsit盲盲n sopimusvalmistajia ydinvoimalaprojektii', www.finpro.fi/print.asp?Section=143&Item=105109, last viewed 10.03.05 21.Devonport website, 'About Devonport', www.devonport.co.uk/about-toplevel.htm, last viewed 10.05.03 22.Christian Aid website, 'In Depth, The scorched earth: oil and war in Sudan', March 2001, www.christian-aid.org.uk/indepth/0103suda/sudanoi2.htm, last viewed 10.03.05 23.Julie Flint, British Firms Fan Flames of War, The Guardian, 11.03.01, http://observer.guardian.co.uk/international/story/0,,450030,00.html, last viewed 10.03.05 24.Mark Milner, '650 jobs go at BP and Harland', The Guardian, 23.03.02, www.guardian.co.uk/business/story/0,,672572,00.html, last viewed 10.03.05 25.'Some Common Concerns' see section on 'workers' www.baku.org.uk 26.BBC News, 'Worker dies on North Sea oil platform', 02.01.05 http://news.bbc.co.uk/1/hi/scotland/4141689.stm, last viewed 10.03.05 27.BBC News, 'Shell admits shortcomings', 04. 12.03, http://news.bbc.co.uk/1/hi/scotland/3289329.stm, last viewed 10.03.05 28.Terry MacAllister, 'Poor safety of North Sea rigs exposed', The Guardian, 09.12.04,

www.guardian.co.uk/oil/story/0,11319,1369727,00.html, last viewed 10.03.05 29.Gavin Cleland, Speech, 'Conference on Safety and Corporate Criminal Accountability', October 2003, www.corporateaccountability.org/dl/confs/oct03/cleland.doc, last viewed 10.03.05 30.Blowout first edition 6th July 1989. Facsimile in 'Some Common Concerns'

31.'Some Common Concerns'
32.Just Transition Alliance website, www.jtalliance.org, last viewed 10.03.05 33.The Refinery Reform Campaign website, (how to set up low tech and low cost community monitoring for your local refinery), www.refineryreform.org/bucket_brigades.htm, last viewed 10.03.05 34.Pers.comm. Anonymous source 35.Scottish Environment Protection Agency, www.sepa.org.uk/index.html, last viewed 10.03.05 36.Baku-Cayhan Campaign website, 'BP's pipeline record', www.bakuceyhan.org.uk/more_info/bp_pipeline.htm#safe, last viewed 10.03.05 37.Corporate Watch Magazine, Issue 12, 'Fuel Facts...', Autumn 2000, www.corporatewatch.org.uk/magazine/issue12/cw12f4.html, last viewed 10.03.05 38.'Living within the Glow - Stories from the fence line. Stories and concerns from Grangemouth and Bo'ness residents' 2004 39.Ibid.

https://corporatewatch.org/content/g8-report-scotland-plc-oil-and-energy-industry-scotland-1

T"he line between lobbying and capture dissolves with corporations actually integrating themselves into the governmental and super-governmental infrastructure."

"This report…aims to raise the important questions that many are asking today about democracy in the face of global rule. Will we be subsumed into a a fossil-fuel-addicted economy or will we resist to build vibrant sustainable local economies?

Which will win out – ecological sanity or pathological capitalism? Will it be the corporate globalisation of profit and control, or a peoples' globalisation of ideas, creativity and autonomy?"

https://ia800801.us.archive.org/2/items/fp_corpwatchG8report/corpwatchG8report.pdf

Personal Information Withheld - Prince Rupert, British Columbia

I am in strong opposition of the proposed Aurora LNG project on Digby Island. The close proximity of this site to the residents of Dodge Cove, the potential for contamination of their drinking water source, and the unknown health impacts of living so close to an LNG facility of this size are all too high a risk to take. During the open house held in Prince Rupert there were several question I had that the staff were unable to answer for me. These included providing the predicted number of Canadian jobs that the project would create during the construction phase, what criteria were used to determine the impact on the Dodge Cove viewscape, and how they defined the term significant.

While the representatives of the project were able to give numbers on estimated total workforce during the construction phase, they could not say how many of those jobs would go to trained Canadians. This is an issue, as many of those who support LNG projects like this, do so because they believe it will bring more jobs to Canadians, and they feel it is worth the environmental impacts caused by the project if it creates well paying jobs. I believe without a estimate on the number of Canadian jobs created during construction, it is impossible to make that determination, and the public is left to make a decision based on a lack of proper information.

During the open house, it was stated that the project would be minimally visible from the Community of Dodge Cove, however this statement is incorrect. The project footprint covers over half of the waterfront in Marine Bay, adjacent to Casey Cove, and both of these locations are a part of the Dodge Cove Community. To say that a material offloading facility located in a bay which is used heavily by the residents of Dodge Cove is minimally visible is ludicrous. Furthermore, the proposed method in which the viewscape will be protected involves the use of vegetation which will clearly not grow on Digby Island. The area is a natural bog and is not at all conducive to the growth of large trees unless planted in specific locations. This project will have a detrimental impact on the visual quality of the community and destroy the ability of the community to use Marine Bay as a gathering place like they have done for generations.

Finally, there was a lot of use of the term significant and insignificant, yet no where on any of the displayed material was this term defined. This term has many different definitions depending on how you approach it, and unless this term is prominently displayed and defined for the public to understand, it is a useless statement to say something in not a significant impact.

In conclusion, I oppose this project in this location, and believe it should not be granting approval for the above reasons.

Personal Information Withheld - British Columbia

Way too close to communities!!!

Dr Margaret McGregor, Dr Larry Barzelai,Amy Lubic - Vancouver, British Columbia

As BC members of the Canadian Association of Physicians for the Environment (CAPE), we are submitting our concerns about the potential negative health impacts of the Aurora LNG Digby proposal in the attached letter.

Public comment submissionpublic comment submissionpublic comment submission

Evelyne Meynen - Hedley, former Prince Rupert

I lived in Rupert for a while and my sister has had a home on Digby for over 20 years. I have walked this beautiful natural area many times over the years. In my opinion this is such an inappropriate spot to put up any sort of industrial complex. It would ruin the peaceful, pristine wonder of this area.

Donna Carr, M.D., - Encinitas

Dear EAO,

Aurora LNG threatens community health and safety! The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of Dodge Cove residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved. The world is watching!

Sincerely,

Donna Carr, M.D., Encinitas

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kate Snyder - Smithers, British Columbia

Dear EAO,

I am opposed to the Auroa LNG plant planned for Digby Island. A LNG plant in this part of the Skeena River system would be extremely hazardous to the salmon and steelhead fish that migrate through. The CO2 emissions would put BC over the allowed limit. It would be dangerous to the residents of the island. It isn't worth the environmental and social damage to build the plant. The profits will leave Canada and we will have wrecked the salmon runs forever.

Sincerely,

Kate Snyder, Smithers

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Christine Malaka - Prince Rupert, British Columbia

Dear EAO,

The most important consideration in the proposed project of Aurora LNG on Digby Island is the destruction of critical fisheries habitat.

It is insane that this location has been allowed to be proposed and it cannot be approved. It is a studied and known fact that this is critical habitat and it must not be compromised. Any degree of impact is not acceptable when you consider all the consequences.

There are numerous other reasons why the project cannot be approved including the close proximity to communities and the unacceptable emission of greenhouse gases.

As a local resident I completely oppose this project.

Sincerely,

Christine Malaka, Prince Rupert

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Marlene E. Simmons - Victoria, British Columbia

British Columbia Environmental Assessment Office

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

RE: Comment on Aurora LNG

Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.

Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.

This facility and upstream development would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT.

Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please do not allow this project to put our coast, our communities and our climate at risk!

Marlene E. Simmons
Victoria, British Columbia

March 8, 2017

P.W.Bailey - Saanich, British Columbia

British Columbia Environmental Assessment Office

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

RE: Comment on Aurora LNG

British Columbia Environmental Assessment Office

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

RE: Comment on Aurora LNG

Given the unrelenting pursuit of a share of the projected profit and returns within the Global LNG Market, the interdiction of The Provincial Liberal Government of British Columbia, on behalf of the People of the Province of British Columbia does not reflect the mandate to which they were elected to govern and protect the Province of British Columbia.

Therefore, for this reason alone, the proposal to support, enhance, and develop LNG within the Province of British Columbia contradicts the reason for the election of the BC Liberals into government and must be denied.

Yours Sincerely,

P.W.Bailey

Personal Information Withheld - Prince Rupert, British Columbia

I would like to voice my opposition to the Aurora LNG Digby Island Project.

The issue I have with the project is the irreversible damage being done to our beautiful country by pursuing dirty energy. Another gorgeous part of Canada will be no more, and why? Because of the gas & oil industry working together with the government to profit from getting every last drop of oil from our land.

In particular to the LNG industry, I have always been confused by the apparent glee and positive spin the LNG industry positions itself. They are not defenders of the environment, and environmental regulations only reduce the profits being made by these industries. LNG standards currently recommend that LNG facilities be at least 3.5km away from any community. This is a minimum recommendation, and it will immediately be rejected if this project is allowed to proceed! Dodge Cove is only 0.5km away from the facilities, and even Prince Rupert is only 3km away! How can their be trust and good faith when recommendations within their own industry are already being ignored!

LNG involves fracking, which has been proven by science to cause extensive damage to the environment, and there is also the unknown in regard to the long-term effects of the fracking process. The time to transition to renewable energies was yesterday, but we definitely need to do it today. This is where the government needs to step in and start protecting the environment, instead of allowing it to fall apart before our eyes, so a very few individuals benefit - and in the end, do they even benefit? There are jobs in the renewable energy sector as well!

I have been living on the Pacific Northcoast for 10 years, and I would hate to see this beautiful part of Canada be destroyed by an industry that will only be around for another 30 years, and then? The LNG industry does not profit from transitioning to renewable energies. This is where we need to have responsible governments to protect our land and people. I only see lip service being paid to truly protecting the environment, and I hope I will be proven wrong.

There are many other social, health and heritage concerns; and I certainly hope we as a country become leaders, instead of destroyers, when it comes to turning the tables on the damage we have done to our environment. Thank you for allowing me to contribute to this discussion.

Personal Information Withheld - Comox, British Columbia

This does not make sense ! No to LNG

Zack - Digby island, British Columbia

I've called digby island home for almost 30 years, it's where I grew up with my little sister and parents. Our days consisted of long beach walks and digging clams when the tide was low and kayaking and fishing near the shore when it was high. I think to go ahead with the LNG request would be an extremely bad move for Digby island's Eco-system as well as the residents. The muskeg and marsh lands are home to a huge variety of animals and flora, which I believe would be negatively impacted by large scale construction. As for the residents we live on an island to be away from exactly this sort of thing, it's all about being in the outdoors without abunch of man made buildings. As a closing statement I'd like to bring up the next generation of kids on digby, I would like my future children to be able to grow up like I did, in a pristine wilderness surrounded by the ocean. Thanks for reading and I hope you take this into consideration for your decision.

Personal Information Withheld - Surge Narrows

the proposed facility would be too close to the city and would endanger too many other aspects of life in the surrounding area. I submit that this would be a terrible place to build the proposed facility. River estuaries need to be protected from this sort of development.

Personal Information Withheld - Madeira park

I grew up on Digby Island in Crippen Cove, it's always going to be home and is heartbreaking to hear what the proposed LNG plant is going to be doing to the island and the neighbouring community of Dodge Cove. There's expensive wild and rugged coast lines that are greatly untouched, and species of animals that will be affected by this. Growing up there was always a multitude of sea life to find along the beaches and in the tidal pools. After living in Vancouver I'm. Shocked by how much the human effect has had on the coasts down here, it's hard to find much of any life along the shores here. Please don't do the same thing up there, invest in something more sustainable and long term with less of an environmental impact. This isn't worth it.

Personal Information Withheld - Vancouver, British Columbia

Together with the Tsimshian people, the Digby Island community, our oceans, salmon, and forests who cannot speak for themselves, I say a loud, strong NO to the Aurora LNG project. It is not in the best interests of BC to pursue a dying industry at the expense of our invaluable land and waters. Now is the time to be investing in renewable sources of energy instead of an LNG facility that puts innumerable wildlife and ocean communities at risk.

Personal Information Withheld - Vancouver, British Columbia

Stop the Aurora LNG Digby Island Project. This community and the natural environment have too much to lose. It is time to move towards renewable sources of energy. Get with the program BC.

Fred Millar - Arlington VA USA

Comment on the Nexen Aurora LNG Export Terminal Digby Island

Application and Appendices for an Environmental Assessment Certificate

British Columbia Environmental Assessment Office

March 8, 2017

The bottom line: The Digby Island Aurora LNG Application ["Application"] cannot be viewed as a serious effort.

It systematically:

  • Ignores the history of LNG and similar hydrocarbon facility accidents, including recent escalations of these and expert assessments of likely future escalations [1]
  • Declines to take seriously safety issues regarding potential catastrophic LNG facility or vessel releases [accidental or intentional], even declining to present vividly any hypothetical potential releases or their impacts on nearby populations [2]
  • Asserts complacently without evidence that the existing regulatory system and industry codes are sufficient to prevent major LNG releases [accidental or intentional] [3]
  • Is non-transparent, withholding information on key assumptions and technical models, declining to describe major and significant potential public safety impacts, and keeping the most critical risk studies and management plans secret for now, to be provided sometime in the future

Application is therefore an obfuscation of issues the workforce, the community at risk, public officials and investors need to discuss in this proceeding. Those seeking more useful LNG public safety risk information may find some citations herein helpful.

A. The Application cavalierly touts the safety record of the relatively new worldwide LNG industry, and the practically Born Yesterday North American LNG export industry, as "exceptional" -- as if this were a non-controversial and reassuring reality that can be expected to continue. It is true that "pure" LNG under most conditions is less risky than other hydrocarbons in its potential for causing major accidents. It is also true, however, that current existing and proposed North American export terminals contain simultaneously huge quantities of LNG and heavier hydrocarbons that introduce much higher risks, some of which are not fully understood, as top experts admit.

And apart from the experienced LNG accidents in North America, the rising rate of huge and unexpectedly damaging Unconfined Vapor Cloud Explosions [UVCEs] at major hydrocarbon facilities worldwide suggests that even in much more established petrochemical industry sectors [refineries and storage] the long-standing disaster risk assumptions and prevention regulations are seriously insufficient. Both US and UK regulatory bodies have engaged in recent significant research of historical UCVE accidents worldwide specifically in the context of trying to understand "the potential for Vapor Cloud Explosions at LNG sites" [p. 1 -Table of Contents, HSL 2016] and specifically recognizing the increased risk of LNG facilities such as the burgeoning new LNG export facilities who have huge quantities of heavy hydrocarbons as well as methane on site.

In part because major LNG facilities have been built in large North American cities with significant disaster potential, lessons are being studied from the huge 2004 LNG disaster in Algeria as well as from the recent serious 2014 LNG accident in Plymouth WA – but neither of these are mentioned by Application.

Leading LNG expert Dr. Jerry Havens, Distinguished Professor of Chemical Engineering, University of Arkansas, attended the [US federal agency] LNG 200-person workshop at [US Department of Transportation] DOT Headquarters in Washington on May 18 and 19, 2016, that illustrates the momentum to revise current US LNG safety regulations. He later outlined in a July 28 2016 Comment to federal regulators regarding the Jordan Cove Energy Project LNG Export Facility [Oregon] how and why outstanding and basic LNG safety design and regulatory issues are currently hotly debated in North America, and indeed internationally, and why these issued demand urgent regulatory revisions.

Given the substantial worldwide integration of the energy industry, perhaps it is fair to assume that the currently perceived basic inadequacies of the main features of US regulation of LNG facilities likely apply generally in current Canadian regulations as well. Although it may be said that the current Application hardly features any Canadian regulations as weighty considerations, instead highlighting generally what the company will do as part of its due diligence.

Relevant to the current Nexen Application's studied averting of its eyes from describing, much less analyzing, any actual historical LNG industry accidents or other petrochemical Unconfined Vapor Cloud Explosion events that are important to consider in assessing the safety of the new and fast-growing North American industry of LNG export facilities, Dr. Havens pointed out:

"This is more than a debate about scientific theories of the hazards of [potential LNG explosions]… My comments provided verified information that at least four catastrophic UVCE events, all occurring under conditions that clearly justify their description as worst-case accidents (therefore normally considered highly improbable), have occurred in the past decade. … Those incidents, and additional ones, were also described by Dr. Atkinson at the workshop". [p 7] http://www.hse.gov.uk/research/rrpdf/rr789.pdf Dr. Havens briefly described these recent major accidents in his January 14 and February 8 2016 comments on the Jordan Cove Project. [3]

Regarding the need to take seriously the technical inadequacies of current LNG safety regulations, Dr. Havens in his 7 28 16 comment elaborated:

"…My comments are directed to the plans previewed by [US Pipeline and Hazardous Materials Safety Administration] PHMSA at the workshop for updating the federal regulatory requirements for safe siting of LNG facilities; especially relating to the workshop presentations made by Drs. Graham Atkinson and Simon Gant of the British Health and Safety Laboratories (HSL) regarding predictive modeling of flammable vapor cloud formation, dispersion, and explosion hazards.

I understand that HSL is under contract to PHMSA to provide an assessment of specific needs that should be addressed by PHMSA for its planned updating of LNG Regulation 49 CFR 193. I do not know the specific requirements of the contract with HSL, but it seemed strongly suggested at the workshop that HSL is considering at least two critical needs for LNG facility siting regulation evaluation and updating:

• Unresolved questions about the potential at LNG storage terminals for unconfined vapor cloud explosion (UVCE), with emphasis on the increased potential for severe explosions involving heavier-than-methane hydrocarbons used and stored in large amounts in LNG export terminals. (Workshop presentation by Dr. Atkinson)

• Protocols for approval of mathematical models for LNG vapor cloud formation, dispersion, and explosion potential, particularly for heavier-than-methane hydrocarbons. (Workshop presentation by Dr. Gant)" Comments, 7 28 16 p. 1

Dr. Havens is concerned to highlight the flaws in current US LNG safety-siting regulations [which one can assume applies also to the current Canadian national and provincial regulations] that allow Applicant use of proprietary and this virtually secret gas models that systematically lead to under-estimation of safety risks of LNG facilities:

"The main purpose of my comments is to request PHMSA to address concerns that have been raised that some of the mathematical modeling methods currently in use can produce results that severely underestimate vapor cloud explosion hazards (consequences) to the public. I am very concerned that PHMSA's current procedure for determining the hazards attending large-scale LNG Export Terminals, including the present protocol for approval of vapor dispersion models for such use, is seriously flawed, particularly regarding [Unconfined Vapor Cloud Explosion] UVCE hazards."[p. 1]

The most serious flaw in the current procedure, in my opinion, is that because the protocol allows approval of modeling methods that are proprietary, and thus not subject to independent scientific-peer review, neither PHMSA nor the public can confidently determine whether the models are suitable for purpose. The result is that the public is not provided the following information about the hazard-modeling process, all of which is necessary to make a science-based evaluation of the model predictions that form the basis for FERC's approval or disapproval of proposed LNG terminals:

• Details of data input to the model(s),

• Detailed results produced by the model(s), and,

• most importantly, a transparent description of the methods used in the models that is suitable for examination and scientific review to ensure that the methods are not used improperly.

The use of proprietary models denies the public an effective means of ensuring that errors in model application are not committed accidentally or intentionally. Such a process portends danger to the public. There is no question that the hazards attending the handling and storage of extremely large quantities of potentially flammable/explosive materials in LNG facilities, if the hazard determinations are not accurate, could result in catastrophic damages extending beyond facility boundaries.

PHMSA has a single means of ensuring that the decisions for approval of the safety provisions claimed are not subject to error – a scientific peer review process. There must be a means developed to insure that the public is provided information sufficient to independently verify the accuracy and applicability of the model predictions that determine [US Federal Regulatory Commission] FERC's decision for or against LNG facility approval." [p. 2]

Dr. Havens' Comment also raises the specific safety issues regarding proposed LNG facilities' use of gas-impervious vapor fences:

"The use of gas-impervious vapor fences is relatively new to the industry; it appears to be resulting more frequently associated with requests for approval for siting of very large facilities which cannot economically provide satisfactory exclusion distances to the facility property line without resort to such "vapor cloud mitigation practices". The majority of LNG Export Terminals now being considered have requested approval by FERC of vapor-impervious fences placed strategically to limit flammable vapor cloud travel beyond the applicant's property line. Such practices raise important (unanswered) questions about the increase in the severity of vapor cloud explosions that can result from such partial confinement. Based on my review of the Jordan Cove project DEIS, it appears that FERC has not considered the potential of such fences, some of which are 40 feet tall and constructed with reinforced concrete, to increase explosion overpressure damage. In my o pinion this neglect of explosion science knowledge is wrong."

The current Nexen Application is entirely vague on whether such a mitigation measure has been or will be proposed for the Digby Island facility [perhaps this is what is being suggested as the "secondary containment" mentioned on p. 9-25].

Other aspects of the Application which show a carelessness about safety:

"Worker safety is beyond the scope of this assessment [p. 9-47 and throughout]. Even though as shown in the Plymouth WA accident workers will be the most likely to suffer harm.

[Among the Application's categories of "Valued Components", neither "Human Health" nor "Community Health" – nor any other category -- clearly expresses major LNG release-related chemical hazards to public safety such as fire, explosion or toxic gas clouds.]

B. Application is complacent in describing release risks: Chapter 9 on "Accidents or Malfunctions" immediately sets the complacent tone which prevails throughout the document: "The LNG industry has an exceptional safety record." [p. 9-1]

Application [p. 9-1] then promptly suggests that the chemical/physical properties of LNG make it nearly [not completely] impossible for a serious accident to occur.

"The LNG industry has an exceptional safety record. This is partially attributable to the relatively low risk associated with the production, handling and transportation of LNG. Liquefied natural gas as a liquid is not flammable or explosive, and it is stored in non-pressurized conditions at sub-zero temperatures. The production of LNG for transport requires that impurities be removed. Therefore, LNG that is released into the environment will rapidly vaporize into natural gas, leaving no residue or contamination to the surrounding land, water or biota. When LNG vapourizes into natural gas (i.e., methane), the gas has a narrow flammable range of 5% to 15% by volume in air. However, natural gas has a lower density than air and rapidly dissipates in the air to concentrations that are below the lower flammable limit. Nonetheless, there is potential for accidents or malfunctions to occur during the course of Project activities."

C. Application almost never vividly describes the scale [see an exception regarding the potential amount released, but not dimensions of area covered, on p. 9-34 regarding vessel grounding or collision-caused release] nor the impacts of a single historical LNG release accident in North America or elsewhere, onshore or offshore. It suggests that there has never been a significant historical facility release by mentioning only the alleged perfect "fires or explosions" record of commercial LNG shipping [p. 9-34]

This industry silence about historical accidents has also noted to extend into industry and government silence about a recent quite serious LNG facility release, as one remarkable report by the Washington State public interest group Sightline has charged: "the LNG industry is creating a false safety record, and current regulations allow the industry to do so."

One recent serious LNG facility accident in a rural community nearby in the Pacific Coast region which injured workers is surprisingly ignored by Application. The LNG release, which also usefully illustrates the severe damages that can be caused by accident knock-on effects, was on March 31 2014 just a few hundred miles south of the Digby Island community, in Plymouth WA on the Columbia River. The Williams Brothers/Plymouth LNG peak shaving liquefaction facility suffered a "catastrophic failure and a resulting explosion", reportedly caused by operator error. The resulting detonation accident caused 5 injuries and $47 million in damages, with hundreds evacuated, and the LNG release continued for 25 hours.

See: http://www.phmsa.dot.gov/staticfiles/PHMSA/PipelineFailureReports/FIR_and_APPENDICES_PHMSA_WUTC_Williams_Plymouth_2016_04_28_REDACTED.pdf

http://www.sightline.org/2016/02/08/how-industry-and-regulators-kept-public-in-the-dark-after-2014-lng-explosion-in-washington/ HOW INDUSTRY AND REGULATORS KEPT PUBLIC IN THE DARK AFTER 2014 LNG EXPLOSION IN WASHINGTON 2 8 16 Lax industry oversight and incomplete reporting leave us with questions still today.

D. Application [p. 9-25] only briefly mentions the potential for a Worst Case Scenario LNG release at Digby Island, and follows with typically dismissive conclusions. In the section on On-shore Hazardous Spills:

"A likely [ed. note: meaning what Application authors would have likely chosen as] worst case scenario would include loss of on-shore containment of materials in storage tanks (e.g., LNG, gasoline, diesel or propane), or a natural gas pipeline rupture onsite upstream of the liquefaction process. This scenario may result in a large-scale release of hazardous materials in amounts or volumes greater than those described in the Spill Reporting Regulation (BC 2008).

The probability of a large-scale spill is very low due to the design of the Project, which includes spill prevention measures and controls specifically intended to reduce the probability of such an event (e.g., secondary containment). The implementation of spill response plans further mitigates the potential residual effects that could occur in the event of a large-scale hazardous spill. Fires or explosions that may result from a hazardous spill of flammable or explosive substances are addressed in Section 9.6.

On-shore hazardous spills have the potential to interact with the following [Valued Components] VCs: Air Quality, GHGs, Water Quality, Vegetation and Wetland Resources, Wildlife Resources (Terrestrial), Freshwater Fish and Fish Habitat, Marine Fish and Fish Habitat, Marine Mammals, Marine Birds, Infrastructure and Services, Land and Resource Use, Archaeological and Heritage Resources, and Human Health (see Table 9.3-1).

Preventative and Response Measures

The Project will be designed, operated, and managed to reduce the potential for hazardous spills of any size. Hazardous materials will be transported, handled, and stored in accordance with the Transportation of Dangerous Goods Act, WHMIS, and other applicable regulations.

The proposed facility will meet strict design codes and standards and will be designed to avoid confined spaces where spills of LNG could vaporize into natural gas and accumulate. Canadian Standards Association code Z276-2011 requires that LNG storage systems be located far enough from the facility boundary to mitigate the levels of radiant heat flux from fires and to mitigate the potential for spills to generate vapour concentrations beyond acceptable limits at the facility boundary. While these events could still have effects to staff onsite, these personnel will be appropriately trained to react and respond to any such event.

The Project will implement a series of preventative measures to reduce the probability of hazardous material spills of any size during all phases of the Project." [p. 9-25]

Similarly for Vessel Grounding or Collision [pp. 9-34ff], Application does for once suggest a figure of how much LNG might be released. A large disaster with an LNG ship, whose dynamics are poorly understood, has been the subject of many years of federal research in North America. But Application only briefly mentions the potential for significant LNG releases with possibly serious damages, only to dismiss the potential based on the safety record of the industry and the existing preventative and response measures. While such a release might impact marine birds or mammals, Applications states, the impacts on human health and community health are "not significant".[p. 9-42]

"In the event of a vessel grounding or collision resulting in a hull breach and containment failure of an LNG membrane tank, up to 48,000m3 of LNG may be released into the marine environment. Released LNG would vaporize quickly by absorbing heat from contact with warm water surfaces and the atmosphere. The resulting natural gas is only flammable if it occupies a relatively small range of 5 to 15% by volume of air. Water and other surfaces in the immediate vicinity of the spill would freeze. Upon cessation of the spill, the ice created by the spill would warm and melt rapidly back to ambient conditions.

If the LNG is released into the water and vaporizes quickly (i.e., rapid phase transition), a large amount of energy is released from the LNG transition from a liquid to gas. An explosion from pressurized gas in the immediate vicinity where LNG contacts water may occur. This explosion does not involve fire, but it can cause underwater blasts of pressure that could damage structures or injure marine life. Over the history of commercial LNG shipping, there have been no fires or explosions concerning an LNG ship's containment system in port or at sea (GIIGNL 2012)."

Applications describes in technically very over-simplistic terms potential LNG releases at the Loading Facility [p. 9-44 ff], mentioning briefly a worst case scenario dense "fog" that if ignited could possibly damage structures:

[p. 9-44] "This accident or malfunction scenario includes the potential for cryogenic releases of LNG at the loading facility. The likely worst case scenario for an LNG carrier while loading would be a separation of the LNG loading arm or loading line from the carrier resulting in the release of non-pressurized LNG and liquid pool formation on water with a subsequent vapour cloud of natural gas. Released LNG is expected to spread across the water surface, possibly freezing the water in the immediate vicinity. If spilled on a metal surface, contact with LNG may make the metal brittle. The vaporization of LNG to natural gas would create a dense fog in the immediate vicinity and reduce visibility of the affected area.

The natural gas vapour cloud will disperse into the atmosphere as natural gas is lighter than air, and the vapour cloud is only flammable if it occupies a range of 5 to 15% by volume of air. The probability of ignition of the vapour cloud is low. Ignition of the vapour cloud would result in a fire that would burn back to the source or to the LNG pool and continue as a pool fire over water. Natural gas vapours generated from the LNG pool will continue to burn until the LNG has evaporated. An explosion is not a likely scenario because LNG is not pressurized.

If the LNG is released into the water and vaporizes quickly (i.e., rapid phase transition), a large amount of energy may be released from the rapid transition of LNG from a liquid to gas. An explosion from pressurized gas in the immediate vicinity where LNG contacts water may occur. This explosion does not involve fire, but it can cause underwater blasts of pressure that could damage structures or injure marine life.

Although the probability of cryogenic releases of LNG at the loading facility is very low, there is potential interaction with Air Quality, GHGs, Water Quality, Marine Fish and Fish Habitat, Marine Mammals, Marine Birds, Marine Use and Navigable Waters, Community Health, and Human Health VCs (see Table 9.3-1)."

This seems to be the only case of a possible release, presented very briefly and very late in the document [p. 9-48 ] with an assessment by Application that a potential LNG release could be "significant" [but with no potential impact scale indicated, as Application did indicate regarding the possible shipping release event on p. 9-34]

E. Application suggests [pp. 9-2, 9-3] that proponent not only evaluates subjectively the factors involved in potential LNG releases but also is responsible for assessing what level of safety measures can "manage the risks to tolerable levels". Presumably these levels are also set by proponent management, since there is nowhere in Application any indication of objective or third-party risk levels or risk tolerance levels. Nor does Application provide any details of the selected "scenarios."

"Accident or malfunction scenarios were identified based on experience with similar projects, input from regulators and the Working Group, and professional judgment. This assessment considers the following accident or malfunction scenarios, consistent with the scenarios described in the AIR:

  • Motor vehicle collision
  • Facility impact from aircraft
  • On-shore fires or explosions
  • LNG Plant malfunctions (emergency LNG facility shutdown including emergency flaring)
  • On-shore hazardous spills
  • Stationary and mobile equipment (fuelling, fluid leaks)
  • On-shore hazardous material storage (fuels, waste, reagents)
  • On-shore releases of LNG (loss of containment of LNG or other hydrocarbons in the plant process area or storage tanks) • Process water and surface/storm water containment areas.
  • Vessel grounding or collision Aurora LNG Environmental Assessment Certificate Application Section 9: Accidents or Malfunctions 9-3
  • Releases from LNG carriers (cryogenic releases at loading facility)
  • Outflow of non-pressurized LNG (above and below waterline)
  • Liquid pool formation resulting in a pool fire.

The AIR lists fires, explosions and hazardous spills as "onsite" scenarios within the Project development area (PDA). For clarification, this chapter describes fire, explosion and hazardous spill events as originating "on-shore" with the potential to spread off-shore within the PDA. The AIR also listed power generation malfunction as a scenario requiring consideration. Power generation is the most likely cause of an LNG plant malfunction and therefore is being assessed as part of this scenario. Hypothetical events or interactions were identified for each scenario and were selected if they were recognized as a likely accident and had a potential consequence of concern." Application gives no indication of the criteria used in these selection decisions.

F. Application provides no clear presentations on the extent of potential offsite release risks. [4]

Application provides no vivid description nor analysis of the scope [distances and intensity] of the potential releases and their associated effects on people and buildings, etc., for example:

  • blast zones and damages
  • fire radiation zones
  • likely casualties

Application does not provide graphics to indicate the scale, distance nor impacts of worst case LNG release scenarios nor even alternative less-serious releases. Application suggests that these scenarios "will" be described in the future in the Environmental Management Plan and the Emergency Response Plan. Without these scenarios, presented in detail and vividly with site-specific effects considered, it is impossible to evaluate the Application.

G. Application provides almost no information on release prevention measures at the facility

There is very little discussion of adoption [or not] of significant prevention measures – only a brief suggestion of buffer zone in siting. The proposed facility would be very close to the nearby community and airport. Application suggests some buffer zones [of unstated dimensions] will be arranged, but without any mapping of potential offsite consequences, makes it impossible to gauge the efficacy of such buffer zones. Application mainly suggests that existing regulations on prevention, emergency response, etc. will be sufficient.

H. Application pays scant attention to risks to human health and safety

Application's format implies that Canadian law requires company and Responsible Authority attention to impacts on human health and community health.

Application in general systematically and substantially lowballs risks to human health and safety, and in only a few sections admits that significant hazardous releases [accidents or terrorism] causing death or injury could occur.

Application thus seems to adopt the implicit stance that any serious potential impacts for human health and safety can be asserted to be so improbable that any serious consideration or vivid presentation of possible serious scenarios to the reader is unnecessary.

I. Application does not provide nor summarize any of the essential Proposed Environmental and Operational Management Plans [e.g., the Emergency Response Plan] which Application asserts "will" cover critical measures on which safety depends: [p. 14-8]

  • "Spill response
  • Site security
  • Emergency support services and corresponding support staff
  • Fire safety, including fire code compliance and fire response."

Without the Application's providing the specifications for these, the adequacy of the plans [and of the industry-generated "guidance" CAN/CSA-Z246.2-14 on which they "will" be based] cannot be assessed.

Furthermore, Application is unclear about the status of emergency response capabilities and responsibilities in case of a release. It says Aurora LNG will be the primary responder [p. 14-8] and use the Incident Command System method of on-scene management, but does not indicate the relationship with nor capabilities of the nearby volunteer fire departments and community/provincial agencies, nor exactly how the facility will reliably provide notifications in any serious emergency:

"Nexen will initiate a proactive response when early signs indicate a potential emergency condition may be developing. Nexen's Health Safety and Environment (HSE) Emergency Response Plan philosophy is to initiate an early and rapid response to a safety issue and to scale down resources and response efforts as needed, rather than attempting to scale up response efforts when faced with an actively changing, deteriorating or misunderstood situation. Nexen's North American Gas and Tight Oil emergency management plan defines the framework and the tools that will facilitate the ability of Nexen to respond to emergency incidents in order to protect human life and mitigate adverse effects to the environment. In the event of an accident or malfunction scenario, Nexen will give prompt and appropriate notification of an emergency condition to government agencies, local Aboriginal Groups, area residents, stakeholders and authorities. Nexen will maintain lines of communic ation that provides accurate, consistent and timely information to employees, regulators, local Aboriginal Groups, governments, local stakeholders, the general public and the mass media."

Application manifests an over-reliance on flawless implementation of existing [but not provided] management plans:

Application assumes emergency plans will be successful, and shows little indication of concern for release consequences if mitigation measures prove ineffective, e.g., if they are overwhelmed by the scale of the release. There is no discussion of potential human error, as has been alleged to be at the root of the recent serious Plymouth LNG release in Washington State.

And Application tends mainly to assume that mitigations will:

  • be available as planned
  • work as planned
  • prevent unmitigated accidents

Application briefly asserts that Nexen has a "Safety First" culture and a proactive stance to emergency response [p. 9-2], but with no details on the capabilities available nor on any third party review of the corporate safety culture, plans and systems.

J. Application has too-sketchily outlined its methodology for ranking the effects and significance of various release risks -- in what amounts to a "trust us" message [pp. 9-2 to 9-6]. Application early on describes how it has developed a "qualitative" methodology for determining and ranking the significance of various hypothetical impacts of the facility, with no explanation of the weighting of various factors nor any way to avoid the appearance of narrow and pervasive subjectivity. There was seemingly no effort to get inputs from the at-risk workforce or community as to how to weight these factors, for example.

The brief description of the "risk matrix" methodology [pp. 9-2 through 9-6] suggests it was developed largely in-house by the proponent.

"Accident or malfunction scenarios were identified based on experience with similar projects, input from regulators and the Working Group, and professional judgment." It mentions no evaluation of this methodology nor of its validity or success in previous applications as assessed by government agencies, third party reviewers, or any other entity. It mentions no peer-reviewed publication on the methodology by any source. It fails to admit that the methodology could be only valuable in evaluating risks in a relative sense.

Most important it fails to outline the limitations of any risk assessment methodology that relies on in-house engineering judgment and the scores of non-transparent assumptions that go into such of course evidently biased judgments.

The brief outline [p. 9-3] of its methodology, accompanied by no detailed Appendix detailing specific methodological procedures, assumptions and decisions for the LNG release-related scenarios considered, only shows that the Applicant made numerous subjective judgments in selecting potential LNG release scenarios and evaluating their effects, and then assigning levels of significance to each. Apart from a few exceptions [e.g., p. 9-34] no indications are given of the scale or effects of the scenarios that might allow stakeholders or regulators independently to evaluate whether the assessed size, impacts, frequency of the proponent-selected scenarios are appropriate, complete or significant.

The Application's avoidance, for the most part, of the normally-used term "consequences" of a potential major hazard chemical release is useful to note: instead [p. 9-3] Application uses the bloodless terms "potential residual effects" or "potential interactions between the potential event and the Project VCs [Valued Components]." There is no vivid discussion or presentation of blast zones or burn damage zones, etc. on shore or offshore.

[p. 9-5] "As noted in Section 3.6.6, threshold criteria were developed for each potential effect, beyond which a residual effect would be assessed as significant. The thresholds present the limits of an acceptable change in a measurable parameter or state of the VC or CEAA 5(1)(c), based on resource management objectives, community standards, scientific literature or ecological processes (e.g., desired states for fish or wildlife habitats or populations). Residual effects significance thresholds have been developed for each VC (see Sections 4.0 through 8.0) and have been used to determine the significance of residual effects resulting from key accident or malfunction events. 9.3 Identification of Potential Interactions with VCs For each accidents or malfunctions scenario, consideration was given to whether the scenario could have an interaction of concern with each VC. Potential interactions between each accident and malfunction event and the VCs are indicat ed in Table 9.3-1. A check mark indicates that an interaction of concern could occur. Subsequent sections discuss the associated probability of the event occurring and the likelihood and consequence of post-mitigation residual effects following such an event."

Application suggests its methodology entails a reliance on unspecified historical data of dubious validity, perhaps LNG accident data, and makes sweeping generalizations presumably based on some available and valid data about the safety record of the LNG industry:

"The likelihood of events is discussed quantitatively where data are available (e.g., historic statistics); otherwise, a qualitative approach is taken based on professional judgment." [p. 9-4]

But Application provides no indication of what databases have been relied upon or will be relied upon in future as-yet-unavailable risk studies, with what levels of tested reliability, from what historical periods, collected by what methods, what data might have been discarded as unreliable, etc.

Application never expresses any uncertainties about the validity of databases to be relied upon, and shows no appreciation of the doubts experts often express of such databases, as seen in US DOT/PHMSA's 2009 authoritative and scathing critique of all of its own hazmat transportation modal accident databases, for example, as inadequate for even its own policy-making decisions. http://www.phmsa.dot.gov/staticfiles/PHMSA/DownloadableFiles/Files/DQA%20Report.pdf

Application's entire methodology indicates a substantial reliance on subjective "professional/engineering judgment" to make decisions for example: "Hypothetical, credible, high consequence events for each type of accident or malfunction were identified based on professional judgment, experience with similar projects, and input from regulators and the Working Group." [page number??]

But Application provides no substantial transparency, e.g., not indicating what are the major physical models and engineering assumptions [potentially scores of these] even in the key judgment decisions made. The result of such non-transparency is the inability of any third-party independent reviewer to assess the validity of the methodology.

K. Application indicates that the most important release risk studies are not available.

Application's descriptions of accident potentials in "Section 9.6 On-shore Fires or Explosions" [pp. 9-11ff] continues the pattern of only briefly describing what it suggests are quite serious releases of flammable liquids and gases reaching even off-site onto the Digby Island community, then promptly asserting the adequacy of existing codes and standards, and concluding that the risks are low.

But this section provides evidence that actually highlights the inadequacy of the Application in that it states that key risk studies related to serious potential LNG releases at the Project have yet to be produced:

  • fire and explosion analyses as per company requirements"
  • "a quantitative risk analysis" for the facility [p. 9-12] [which will no doubt have its own technically problematic aspects]
  • "vapour dispersion modelling" [p. 9-13]
  • experimental test data [p. 9-13]

Applications states the results of these studies will determine [pp. 9-12 through 9-13] such key Project safety-related features as:

  • "setbacks from occupied areas", and
  • "design mitigations"

With the Application's pervading lack of transparency and specificity and its withholding of key studies, it is difficult to take seriously its Conclusions [p. 9-18] that purport to distinguish between some predicted LNG fire or explosion release impacts from the facility that are "significant" or "not significant". In fact, the distinct impression is that the results of these risk studies are pre-determined, and are very unlikely to challenge any of Application's premature and peremptory conclusions that the facility risks will be "low."

L. Application declines to consider LNG industry accident risk-related cumulative impacts:

Application should have considered seriously the cumulative impacts of the proposed Digby Island facility along with the six or so other LNG facilities proposed for its Northwest neighborhood. For example, would a surge of LNG shipping in nearby waters raise the chances of serious collisions and potential LNG releases?

It is unfortunate if, as reported by Application, Government of Canada decisions on scope reportedly eliminated the consideration of transportation of natural gas to the proposed facility from mandatory inclusion in the Application, but the Applicant might voluntarily include some such consideration as entirely sensible [as proponents of new crude by rail unloading facilities in California and Washington State have done, in view of significant impacts on residents along the likely major transportation routes to the facilities], given the likely new impacts on transportation infrastructure and new levels of transportation release risk entailed. Application should describe whether the proposed Digby Island facility would entail transportation, by whatever modes, over very long distances and would put at risk many communities.

M. Application ignores potential LNG terrorism-related release potentials and risks: [5]

Application [p. 9-1] does claim to evaluate the effects of "a Project-related accident" ["as required in Section 19(1)(a) of the CEAA 2012"], and defines this as "unexpected occurrence or unintended action"-- which would arguably seem to include sabotage- or terrorism-related LNG releases.

Proximity of the proposed facility to the local airport flight path raises to a higher concern the question of potential terrorism. Especially since the 9/11 attacks with hijacked airliners – US regulators now have mandated locked major airliner cabin doors, but that is not a silver bullet solution to the potential of terrorism by planes of various sizes, as indicated by the No-Fly zones around sensitive terrorist target areas.

Application recognizes the potential at the Digby Island site of "facility impact from aircraft" [p. 9-8], but focuses on the probability of the accident potential being "very low" [as if anyone can pretend to be able to ascertain the probability of terrorists' actions], and does not describe the scope or extent of the potential consequences ["potential interaction with Community Health VCs" – that is Valued Components, possibly meaning people].

[p. 9-8] "Facility Impact from Aircraft

Description of Event or Interactions

There is a potential for an aircraft to directly impact the LNG facility considering that the Project is located within an existing aerodrome, namely the Prince Rupert airport on Digby Island. The types of aircrafts that could be involved in a direct impact to the LNG facility includes airplanes, float planes and helicopters from Project-related, commercial, private and personal/recreational applications.

Safety data are tracked, investigated and documented by the Transportation Safety Board of Canada to analyze safety deficiencies and identify safety risks in the Canadian transportation system. From 2005 to 2014, the number of aircraft accidents per year ranged from 30 to 70 in British Columbia (BC) (TSBC 2014). In 2014, 12% (30) of Canadian-registered aircraft accidents occurred in BC, two of which resulted in a total of three fatalities. That compares with a ten-year annual average of 51 accidents and 17 fatalities. This decreasing trend is attributed to an increase in professionalism (particularly in small and mid-sized commercial operations), high fuel prices resulting in less flying by private enthusiasts, and implementation of safety management systems for larger management systems for larger operations.

Although the probability of facility impact from aircraft is very low, there is potential interaction with the Infrastructure and Services, and Community Health VCs (see Table 9.3-1). The potential consequences of concern from an aircraft directly impacting the LNG facility includes serious injury to people, loss of human life and damage to property and infrastructure. Events that could occur subsequent to an aircraft directly impacting the LNG facility include on-shore fires or explosions, which are assessed in Section 9.6; and on-shore hazardous spills, which are assessed in Section 9.8."

Application does not describe these impacts with much more detail in that section, however.

Application in this section briefly mentions the "loss of human life", but again without indicating exactly how this could happen or how extensive a loss of life might be experienced. Nor does Application indicate whether the risk of such a facility impact is a significant risk to be mitigated. Application avoids this risk significance question by trying to have it both ways, in suggesting inappropriately that it depends [post facto] on whether a life is lost.

[p. 9-10] " If a facility impact from an aircraft resulted in the loss of human life, the magnitude of residual effects to community health would be high and within the geographical extent of the LAA. The residual effects would be characterized as a continuous effect that is irreversible with a long-term duration potentially lasting through the life of the Project. The context of residual effects to community health is resilient (moderate) because community health is moderate and slightly vulnerable to social, economic and environmental change.

The likelihood and consequence of residual effects to community health from a facility impact from an aircraft without the loss of human life are low. In this scenario, the risk matrix ranking would be low and the potential residual effects to community health are predicted to be not significant. The likelihood and consequence to community health from a facility impact from an aircraft resulting in the loss of human life are very high. In this scenario, the risk matrix ranking would be very high and the potential residual effects to community health would be significant."

The terrorism release question in regard to chemical transportation arises often in the US since 9/11, even in regard to the months-long security training and multi-jurisdictional pre-planning for Special National Security Events or even big crowd events in major NFL stadiums -- see attached. And has also arisen in connection with chemical transportation release risks, e.g., possible use of a hazmat train for terrorist attack on the Denver Democratic National Convention in 2008 forced a daily re-routing of most trains around Denver.

https://www.bnsf.com/employees/communications/railway/pdf/200810.pdf

http://www.huffingtonpost.com/gregory-daurer/denver-officials-ban-buck_b_120061.html

Given that the proposed Aurora facility will be touted as an important new addition to North America's energy infrastructure, it could be an attractive target for the kind of "homegrown" more modest type of terrorism whose potentials are newly appreciated. Application does not deal seriously with terrorism, however. While mentioning various potential mitigations of the aircraft-caused LNG release risk, e.g., whether the flight path could be changed, etc., it does not discuss these in any detail nor indicate whether the Project will adjust its potential flight-path-impacting "gas plumes" accordingly.

Potential LNG terrorism was a major focus of concern regarding a proposed Rhode Island LNG facility. [attached Clarke report commissioned by the Rhode Island AG] Richard A. Clarke Study LNG Facilities in Urban Areas: A Security Risk Management Analysis 2005 for

Attorney General Patrick Lynch Rhode Island [5]

As LNG risk expert Dr. Havens also has noted in his 7 28 16 Comment regarding "Intentional events" [p. 7] :

"A Closing Comment on Accidental vs. Intentional Events

…I believe it is just as important that the regulations begin to address the burgeoning problem of the potential for intentional acts against LNG facilities to cause extremely serious fire and explosion cascading events. It is clear that reliance on design of LNG facilities to minimize the probability (measure of likelihood) of accidental occurrences is turned on its head when intentional acts are considered. A simple fact plagues all of the energy industry, including the nuclear power and weapons sectors; it is relatively easy to assemble an explosive device that can be made to explode. Designing the same device to ensure that it doesn't explode is another matter entirely. We can start by doing a better job in applying our scientific knowledge to minimize the extent to which we provide opportunities to those inclined to take advantage. The incorrect use of our scientific tools, so as to mistakenly conclude that the design under consideration is a benign on e, leads us in the wrong direction."

--- Fred Millar, Ph.D. is an expert on energy transportation risks, based in Washington DC, and has testified by invitation in local and national legal and legislative proceedings involving nuclear, chemical and crude oil transportation.

--------- END NOTES -------

[1] Algerian Explosion Stirs Foes of U.S. Gas Projects By SIMON ROMEROFEB. 12, 2004
http://www.nytimes.com/2004/02/12/business/algerian-explosion-stirs-foes-of-us-gas-projects.html?_r=0
Blast at U.S. LNG site casts spotlight on natural gas safety Reuters 4 6 14 [Plymouth WA] http://www.reuters.com/article/us-lng-blast-analysis-idUSBREA3506Y20140406
Review of Vapor Cloud Explosion Incidents MH/15/80 Lead Authors: Graham Atkinson and Jonathan Hall Contributing Authors: Alison McGillivray Technical Reviewer: Jill Wilday Editorial Reviewer: Mike Wardman April 11th 2016
See link at: PHMSA Workshop on LNG regs YouTube 4 sessions taped includes references to historical LNG accidents.
http://phmsa.dot.gov/pipeline/public-workshop-on-liquefied-natural-gas-lng-regulations
Several online sources list the history of worldwide LNG "incidents".

[2] Governments and experts in the US and elsewhere have taken the risk of potential LNG catastrophic releases seriously for decades, e.g.:

Lessons learned from LNG safety research Ronald P. Koopman, Hazard Analysis Consulting, 4673 Almond Circle, Livermore, CA 94550, Donald L. Ermak Lawrence Livermore National Laboratory

Available online 20 October 2006 Abstract

During the period from 1977 to 1989, the Lawrence Livermore National Laboratory (LLNL) conducted a liquefied gaseous fuels spill effects program under the sponsorship of the US Department of Energy, Department of Transportation, Gas Research Institute and others. The goal of this program was to develop and validate tools that could be used to predict the effects of a large liquefied gas spill through the execution of large scale field experiments and the development of computer models to make predictions for conditions under which tests could not be performed. Over the course of the program, three series of LNG spill experiments were performed to study cloud formation, dispersion, combustion and rapid phase transition (RPT) explosions.

[3] The most recent compelling evidence of US and UK government interest in revising inadequate LNG safety regulations was the May 2016 PHMSA Workshop on LNG regulations attended by 200 experts – see video on YouTube 4 sessions taped includes references to historical LNG accidents: "This public meeting is to solicit input and obtain background information for the formulation of a future regulatory change to CFR 49 Part 193, Liquefied Natural Gas Facilities. Invited speakers include the National Fire Protection Association (NFPA), the Pipeline Safety Trust (PST), the American Gas Association (AGA), and the LNG industry." http://phmsa.dot.gov/pipeline/public-workshop-on-liquefied-natural-gas-lng-regulations

In a specific LNG siting proceeding context, Professors Jerry Havens and James Venart also have made a compelling case in their comment on the Jordan Cove Export Terminal [FERC Docket No CP13-483] January 14, 2015 that the US LNG terminal safe-siting policy is faulty, in that the existing federal safety standards "have not been subject to adequate science based review and appear to provide inadequate fire and explosion exclusion zones to protect the public."

\

Application must address the serious Havens-Venart safety questions raised at the national level in a Washington DC stakeholder meeting called to address them, and the subsequent report from UK HSE experts that confirm their validity.

1-14-2015 filing submitted to FERC by Jerry Havens and James Venart under CP13-483. http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20150114-5038

2-6-2015 filing submitted to FERC 2-6-2015 - Supplementary Comment with Questions by Jerry Havens and James Venart under CP13-483. http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20150206-5040

Submitted by Jerry Havens Distinguished Professor of Chemical Engineering University of Arkansas James Venart Professor Emeritus of Mechanical Engineering University of New Brunswick Regarding the Jordan Cove Export Terminal Draft Environmental Impact Statement Docket No. CP13-483 January 14, 2015 UNITED STATES LNG TERMINAL SAFE-SITING POLICY IS FAULTY

https://elibrary.ferc.gov/idmws/file_list.asp?accession_num=20150114-5038

NATURAL GAS: Explosive LNG issues grab PHMSA's attention -- Tuesday, June 7, 2016 -- www.eenews.net

http://citizensagainstlng.com/wp/2015/01/20/scientist-say-united-states-lng-terminal-safe-siting-policy-is-faulty/

https://valleygreenspace.files.wordpress.com/2015/10/havens-and-venart-ferc-jce-deis-comment.pdf

"Catastrophic UVCEs are Becoming More Frequent [comment on Jordan Cove Energy JCE DEIS proceeding docket]

Confirmed scientific knowledge of the causes of UVCEs indicates that their frequency would increase with the potential for release of large quantities of hydrocarbons, especially highly volatile ones. As we have stated earlier, the sizes of flammable hydrocarbon vapor clouds described in the JCE DEIS have lateral dimensions of up to 720 meters (~2,400 feet).

To our knowledge, there have been no UVCEs in the continental United States involving flammable clouds that large. The largest vapor cloud considered at JCE, which would follow a spill of ~3/4 million gallons of LNG, involves the most volatile of the hydrocarbons, methane (CH4), which is lowest on the explosion sensitivity scale; but the mixed refrigerant liquid (MRL) spills are very large, and they approach the range of maximum sensitivity to explosion.

It appears that the relative rarity of large UVCEs (until recently) is very likely due to the fact that most of the very large spills that have occurred did not evaporate rapidly enough, and/or were dispersed readily by the action of wind, to allow formation of a large flammable cloud . But, now there have been at least four instances within the last ten years of devastating UVCEs following very large releases of gasoline class hydrocarbons where the evaporation of the fuels was rapid enough, and the wind speed essentially non-existent, to allow the formation of flammable vapor clouds with lateral dimensions of several hundred meters. In all four cases these clouds were ignited (presumably accidentally) and the explosions resulted in cascading events leading to catastrophic damages to the facilities (refineries/tank-farms) and injury/and/or deaths in the public sector.

The first occurred in December, 2005, at Buncefield in the United Kingdom. There followed three more: Jaipur, India, 2009; San Juan, Puerto Rico, 2009; and Amuay, Venezuela, 2012. The following facts are a matter of record for all four:

• The events occurred in very low wind (near calm or calm) weather conditions.

• The maximum linear extents of the flammable clouds were at least 250 meters, ranging to at least 650 meters at Amuay.

• UCVEs occurred in every case that registered above 2.0 on the Richter Scale.

• The initiating explosions resulted in cascading events leading to total loss of the facilities.

We provide below photographs of these accidents (depicting the cascading fire and explosion effects) indicating the catastrophic damages that resulted. In our view, these four events, which have similar descriptions of the weather conditions and physical factors that could cause extremely 18 large flammable vapor clouds to form, and with which the vapor cloud scenarios considered in the JCE DEIS are clearly similar, should be a clear warning to parties planning facilities with similar potential for catastrophe. Buncefield, United Kingdom Jaipur, India Amuay, Venezuela San Juan, Puerto Rico Scientific Conclusions re the Buncefield Event are Directly Relevant to the JCE DEIS.

To our knowledge, detailed reports of the explosions in India, Venezuela, and Puerto Rico have not been completed. However, during the decade 2005-2015 since the Buncefield explosion occurred there have been published extensive reports of analyses thereof. The Buncefield explosion, which has been definitely established to be a UVCE, is thought to be the largest explosion that has occurred in peacetime Europe; damages now exceed two billion dollars. In 2012, there appeared a paper in the Philosophical Transactions of The Royal Society (Great Britain) by D. Bradley, G.A. Chamberlain and D.D. Drysdale5 entitled "Large vapour cloud explosions, with particular reference to that at Buncefield". As this paper appears to be the most 5 Phil. Trans. R. Soc, A 2012 370, doi: 10 1098/rsta.2011.0419, published 2 January 2012 19 recent to summarize the present understanding of the increasing potential hazards of unconfined vapor cloud explosions (UVCE) of hydrocarbon-air mi xtures, we quote directly from the Conclusions section thereof: A number of mechanisms for the propagation of combustion have been discussed, without reaching any definite conclusions as to what precisely happened at Buncefield. [pp. 18-20 in Jordan Cove submission]

[4] Vivid graphical depictions of potential accidents and their potential impact on at-risk populations, buildings, and environmental features are standard in any serious assessments of the risks of an existing or proposed facility. Such documents have been important in debates on siting LNG facilities in urban areas. See http://www.ecori.org/social-justice-archive/2015/8/3/national-grid-wants-to-bring-new-lng-project-to-providence-waterfront

https://books.google.com/books/about/LNG_Facilities_in_Urban_Areas.html?id=ZRuhNwAACAAJ

www.acushnet.ma.us/lng-advisory-committee/files/scnu-presentation

More generically for all high-risk chemical facilities, see the longstanding 1990's era US EPA guidance documents on graphic "plume mapping" and blast-zone depictions of high-risk chemical facilities, used by Local Emergency Planning Committees and similar depictions in many industry reports, available online at the EPA websites for the 1986 Emergency Planning and Community Right to Know Act [cf. both NRT-1 and Technical Guidance for Hazard Analysis] and for the EPA's Risk Management Plan Program under the Clean Air Act Amendments of 1990 Section 112 r, especially Guidance for Offsite Consequence Analysis, both generic and for specific industry groupings: ,

https://www.epa.gov/epcra

https://www.epa.gov/rmp/risk-management-plan-rmp-rule-overview

Multiple US agencies regulate different aspects of safety of LNG facilities:

http://www.phmsa.dot.gov/pipeline/technical-resources/liquefied-natural-gas/regulatory-information

[5] http://www.lbreport.com/news/may05/lngri.htm LBR summary of Richard Clarke 2005 report LNG facilities in urban areas: security aspects

http://www.worldcat.org/title/lng-facilities-in-urban-areas-a-security-risk-management-analysis-for-attorney-general-patrick-lynch-rhode-island/oclc/60341827?referer=di&ht=edition

LNG facilities in urban areas : a security risk management analysis for Attorney General Patrick Lynch, Rhode Island

Author: Richard A Clarke; Patrick Lynch; Pro Bono Publico.

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Personal Information Withheld - Okotoks, Alberta

Please provide clarification on how existing marine-based air emission rates were established within the regional assessment area (RAA). The Environmental Assessment Certificate Application, Appendix A - 'Air Quality Technical Data Report', references version 4.1 of the Marine Emission Inventory Tool (MEIT) as the source of marine vessel emission rates. It states that marine-based air emission levels from 2010 were forecasted to 2015 in the MEIT for the 2010 National Marine Emissions Inventory for Canada (SNC Lavalin, 2012b). The 2010 emission inventory report acknowledges uncertainty in the west coast emission estimates on page ES-4:

"The Canadian Coast Guard VTOSS data was found to be inferior to INNAV for purposes of marine inventory development. For this reason, the emission estimates for the west coast are considered to have higher uncertainty than estimates for the east coast. The INNAV system is now being used by the Coast Guard on the west coast (as of 2011) and will be available for future marine emission studies."

The conclusion section of the same report includes suggested actions for future improvements to the MEIT and Canada's national marine emission inventory including:

"Evaluation of the west coast inventory by acquiring and using 2011 INNAV data in MEIT V4.0."

Was the higher quality INNAV activity data added to the MEIT for the purposes of this Environmental Assessment?

A document posted on the EAO web site on March 7, 2017, 'MEIT User Guide V4.3 March 20, 2015.pdf' includes a model history section (Table 1-1, page 3) that lists version 4.3, March 2015 as the most recent version of the MEIT. However, another file posted on the EAO web site, 'Updated Tables_MEIT 4.3.1' includes tables of west coast marine emission estimates sourced from "Excerpt from MEIT Update 4.3.1 (by ECCC)". For transparency, please clarify which version of the MEIT was used as the source for the emission levels presented in the application and the source of the MEIT marine vessel activity data for the west coast (VTOSS, INNAV, others…). From this version of the MEIT, please provide reports in Excel spreadsheet format (and/or Excel pivot table format as mentioned in the User Guide) that show the emission levels used in the Environmental Assessment Application. Please also include a list of assumptions including if 100% compliance or partial compliance was assumed with the Emission Control Area (ECA) sulphur fuel standard and the IMO Tiered NOx emission standards for marine vessels operating within the ECA.

Thank-you,

mark mc myn - Terrace, British Columbia

Keep your filthy lng project out of the north.

Emily Hoffpauir - Victoria, British Columbia

Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.

Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.

This facility and upstream development would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT.

Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please do not allow this project to put our coast, our communities and our climate at risk!

Personal Information Withheld - Prince George, British Columbia

LNG on the NW coast is extremely irresponsible and shortsighted. Damage cannot be undone.

Personal Information Withheld - Dodge Cove, British Columbia

I have concerns that the effects to the entire Skeena River are not being looked at, and the effects up and down the coast that will result in the proposed major disturbance of situating the CNOOC-Nexen Aurora LNG terminal right in critical marine habitat.

Delusion Bay on Digby Island is a highly valuable habitat for many fish species, which in turn support the marine mammals, birds and other species of which the marine life is a critical part of the food web.

Study of Skeena River Estuary Juvenile Salmon Habitat "The southwest shore of Lelu Island and Delusion Bay (south end of Digby Island) are highly valuable habitats for neritic feeding species (e.g., Coho, sockeye, and steelhead)."

Page vi
http://skeenawild.org/images/uploads/docs/Skeena_River_Estuary_Juvenile_Salmon_Habitat.pdf
"...estuaries provide essential nursery and juvenile rearing habitats, with up to 80% of coastal wildlife species relying on estuaries during at least one stage of their life history (BCMOE 2006)"

As this report goes into great detail of habitat suitability - why the Skeena River Estuary is important for fish habitat, and the role that Delusion Bay and the south end of Digby Island plays in habitat for fish, I would hope that all the maps, information, and studies will be looked at. It seems to be contradictory to many of the findings of CNOOC-Nexen Aurora LNG in their Final Application.

"High levels of sediment and turbidity can reduce water quality in the estuary. Both of these conditions may affect the growth of eelgrass beds, the availability of food, and the survival of juvenile salmon."
"Filling, diking, dredging, and infrastructure development can damage or alter important nearshore or estuarine habitat, including riparian vegetation and eelgrass beds. Early marine survival of wild salmon depends on sheltered, intact coastal habitats as well as abundant food resources found in these habitats."

"Local shoreline development can lead to temporary or permanent loss of estuarine intertidal wetlands, which are an important nearshore habitat for juvenile salmon."
http://skeenasalmonprogram.ca/libraryfiles/lib_432.pdf
http://skeenasalmonprogram.ca/library/lib_433/
http://skeenasalmonprogram.ca/library/lib_434/

All the maps, information, and extended data related to this report highlights the importance of the south end of Digby Island and the Skeena Estuary. It highlights the importance of chlorophyll, algae, eelgrass etc. In this specific area. It highlights the sensitivity of this area to industrial activity. These need to be studied, as they seem to contradict many of the assumptions that Aurora LNG has made about the south end of Digby Island.

Personal Information Withheld - Dodge Cove, British Columbia

(letter sent to Provincial gov't)To Whom It May Concern:

I have lived in this area for 29 years, and on Digby Island for over 17 years. I am presently raising a 4th generation Dodge Cove resident. I choose to live in Dodge Cove because it is rural living close to nature that has quiet, fresh air, clean water, food harvesting and hunting and fishing. This is a unique coastal community that has been here for over 100 years.

The Nexen LNG proposal for Digby Island is going to drastically change all these reasons that I live here, with the change in the quality of my air and water supply, the noise and light that will be emitted through any construction stages and while the terminal operates, and the loss of my traditional food gathering areas.

Already my life has changed as my family struggles with the increased air traffic noise and activity in what has always been our nature space, trails for hiking and food related activities, as the site evaluation for this proposed LNG terminal is carried out. The noise and activity has been loud and is bothersome as well as affecting the animals and birds, many of which are species of conservation concern.

There are many reasons that an LNG export terminal should not be placed on Digby Island. Yet the main reason that concerns me is how close this terminal will be (1/2 km) to our community of Dodge Cove.

International LNG industry standards have 4 CRITICAL SAFETY CONDITIONS that are used when determining the terminal sites.
1) Primary Containment
2) Secondary Containment
3) Safeguard Systems
4) SEPERATION DISTANCE

LNG facility designs are required by regulation to maintain seperation distances to land-based facilities from communities and other public areas. Safe zones are also required around LNG ships.

In the event of an accidental release of LNG, the safety zone around a facility or ship protects surrounding communities and public areas from personal injury, property damage, or fire.

SIGTTO - the Society of International Gas Tanker and Terminal Operators - recommends that terminals are sited a minimum of 2.2 miles from any community or marine navigation zone, and urge for a minimum of 3 miles.

I strongly oppose this Digby Island location for an LNG terminal. This location does not adhere to international LNG terminal siting regulations. As these regulations are in place to protect citizens as well as the entire LNG industry, they need to be followed.

Nexen Aurora LNG says that they are committed to the highest safety and health standards for the public. If that truly is the case, then the Digby Island location is not viable for an LNG terminal.

Personal Information Withheld - Dodge Cove, British Columbia

The Honourable Marc Garneau, P.C., M.P.

Minister of Transport

January 24th, 2016

Dear Marc Garneau,

Thank you very much for taking the time to come to Prince Rupert recently. I hope you are able to return another time and meet with a wider proportion of local representatives.

I am a long time resident of Dodge Cove, Digby Island.

Digby Island played a pivotal role in national security, defending the Prince Rupert Harbour and Canada during the 2nd World War.

Submarine nets crossed the main channel and lookouts, guns, and soldiers were stationed in many places on Digby Island. Now, Digby Island has both the Prince Rupert Airport, the community of Dodge Cove, and other residential homes.

I am very concerned by the proposal of CNOOC Nexen to place the Aurora LNG export terminal at the mouth of Prince Rupert Harbour, on Digby Island.

The Aurora LNG proposal seems to be in complete contradiction to all terminal siting safety standards as laid out by SIGTTO, the U.S.

Department of Energy and studies done by Sandia Laboratories. SIGTTO states "that LNG ports must be located where they do not conflict with other waterway uses now and into the future....long narrow inland waterways are to be avoided...conflicted waterway uses include fishing and recreational boating..."

Prince Rupert Harbour has over 1000 large ships every year such as cruise ships, ferries and tankers entering and exiting through the mouth of Prince Rupert harbour. Between April and November, 7000 of other marine vessel traffic was counted such as commercial and fishing vessels, recreational, coast guard, RCMP, and other services as they enter and exit Prince Rupert Harbour. These numbers will only be increasing with the current container port expansion and future expansion plans. All the other marine traffic would need to be held up for hours each day with LNG tankers transiting the mouth of the Prince Rupert Harbour, or they would be in the LNG tanker Hazard Zone. All vessels are considered to be an ignition source.

The CNOOC Nexen Aurora LNG terminal would be built right in the path of all the airplanes flying in and out of Prince Rupert daily. They actually have a plan to extend the runways even further down the island and increase the airplane traffic.

"If an aircraft crashed into an LNG facility, the impact would almost certainly cause a fire fueled initially by the aircraft fuel.

It may also ignite the LNG, causing a larger fire at the facility...Danger to the public from this type of event would be reduced or eliminated by the separation distance of the facility." The Center for Energy Economics (U.S.)

Four Critical Safety Conditions are used when determining LNG terminal sites, the fourth condition being SEPERATION DISTANCE. As other countries are also very concerned about LNG terminals and tankers in relation to terrorist threats, we need to be as well. The proposed location for this terminal seems to be checking off the list of where NOT to place LNG terminals: at the mouth of the harbour with significant marine traffic, in the flight path by an airport, 0.5 km to the closest community and only 3 km to Prince Rupert.

CNOOC Nexen Aurora is only one of many proposals for the Prince Rupert Harbour which is not following international best safety standards.

I strongly urge for the Canadian government to adopt the SIGTTO safety standards as new regulation.

Since this proposed site is in complete contradiction to international LNG industries own best practices, what are the Federal standards and best practices when it comes to potentially dangerous projects such as this one?

I look forward to your reply.

Personal Information Withheld - Dodge Cove, British Columbia

Dear Catherine McKenna,

I have lived in the Prince Rupert and the outlying region for over 29 years, and on Digby Island for over 17 years.
My child is a fourth generation Dodge Cove resident, and my husband was born in Dodge Cove. Dodge Cove is a unique coastal community that has been on Digby Island for over 100 years, just across from Prince Rupert. Digby Island is a small island, only a few miles long, with the southern area part of the Skeena River estuary zone.

Dodge Cove is gravely concerned by the present CNOOC Nexen Aurora LNG proposal for 0.5 km away from our homes. Not only does this contravene international LNG best safety standards outlined by SIGTTO (which call for 2.2 miles or more from communities), but this also seems to completely stand against the commitment by B.C. to reduce GHG emissions to 80% below 2007 levels by 2050, and the commitment that Canada just made in Paris to lower emissions.

The Skeena River is the 2nd largest salmon river that brings over $100 million to our Northern economy through commercial fishing, and even more (a few billion??) through tourism. The fact that this location is being heralded as a viable option seems to be contradictory to managing our resources in an environmentally responsible way. The B.C. government seems to be struggling with their role and I do not believe that these LNG proposals should be a provincial matter but a federal one.

Canadian resources need to be managed in an environmentally responsible manner, that adhere to the larger goal of reducing emissions and improving clean technology. Proper siting locations that adhere to the LNG industries best safety standards as outlined by SIGTTO should be the only ones considered. Federal environmental assessments should be done on each proposal (at present, CNOOC Nexen Aurora is only being assessed provincially) and on cumulative effects as well.

This area that I live in has been livable and sustainable up to now, but these LNG terminal sites threaten our existing economy, environment, food security, and safety. CNOOC Nexen Aurora LNG says it is committed to the highest safety and health standards, yet would release close to the same amount of emissions as all the cars in B.C. into our airshed and watershed. I find it hard to believe that the "highest safety and health standards" do not protect myself, my family and my community from the CNOOC Nexen Aurora LNG proposal.

The provincial government keeps stating that these projects will be built by the "best standards" yet when asked have not stated what those "best standards" are. I would like to know what "best standards" these projects must adhere to?

I look forward to your reply.

Personal Information Withheld - Dodge Cove, British Columbia

This report should be read by the BCEAO if it hasn't been already.

A Clear Look at BC LNG Energy security, environmental implications and economic potential by David Hughes

Personal Information Withheld - Dodge Cove, British Columbia

More comments and concerns regarding the Aurora LNG project:
"Carbon trading energy legislation instead of bold long-term economic planning."

Naomi Klein What will the cost to this community/region be to have an emergency plan in place, this should be looked at before approval? And what exactly is the plan? The responsibility cannot be laid onto other local governments as Nexen will be the cause and the reason for needing it - needs to provide relevant data/plans/calculations regarding it.

The port and provincial govt is going to make $ from taxes but municipal gov'ts are going to bear the brunt of all expenses.

Dodge cove was not included in the list of communities to consult with at the beginning of the dAIR, and had not part in formulating the dAIR/AIR.

Dodge cove should have been a stand-alone VC in the AIR.

Digby Island property owners were not informed of the application for IUL or potential comment period or its impacts.

Digby Island property owners were not informed or consulted about the IUL overlapping the Dodge Cove OCP boundaries.

Nexen claimed the MFLNR approved it and they didn't need any local govt's approval. Complete disregard for the regional disctrict, local governments, existing OCP boundaries, and any local consulation.

Nexen used local water in the IUL - in drilling process- where are the studies about the effects. are baseline data being done beforehand?

Baseline data on migratory birds has not been done accurately by Nexen, and the disturbance to the island during Nexen's IUL does not give an accurate baseline. They studied most of the birds when the birds weren't even here - and then had major helicopter traffic happening when the birds returned.

If water is coming from Prince Rupert (Port) there needs to be a study on all the effects on the water supply etc.

Where is the site alternative section? There must be alternative sites to loading LNG away from human activity and the busy port?

Cumulative effects not just now but for the next 40 years (potential licence) need a study timeline of effects for that length of time - include local/regional/national/global cumulative effects for that timeline.

Pipeline and compressor station - effects are being kept seperate from the Aurora Project, residents in Dodge Cove were not made aware at the time for public comment that the pipeline would feed Aurora (Aurora was not looking at Digby Island).

Climate change potential effects on wind direction/water/spread of contaminants need to be studied. ESSA didn't include these effects in the recent cumulative airshed study.

The idea of issuing a 20 or 40 year permit without resolution of all these issues/concerns.

The land is tied up (even if no development) while they sit on it after approval, making it unusable for anything else.

"Ensuring the communities where we operate will benefit from our presence." David Markham - Nexen What benefits is Dodge Cove supposed to feel from Nexen's presence?

There is knowledge about the effects (50 sq km marine dead zone) and the BC gov't and CNOOC-NExen are going to mislead the public and put it in the Skeena River estuary - worst spot to put it.

This will be trading one economy(a long term renewable resouce based economy) for another (short term non-renewable resource based economy).

How will this benefit communities for the long term?

Naomi Klein - "In order for multinational corporations to protect their freedom to pollute the atmosphere, peasants, farmers and indigenous people are losing their freedom to live and sustain themselves in peace."

This is Dodge Cove - gardeners/fishermen and renewable resource sustainability jobs - plus the freedom to live and sustain ourselves in peace.

Naomi Klein - should be looking for ways to support these ways of life - not severing deep traditions of stewardship and pushing more people to become rootless urban consumers.

There is a joke in Dodge Cove - except it's not funny. We will be turned into "LNG refugees".

"while green groups battle over the research and "voluntary codes" oil and gas industry keep building infrastructure" Naomi Klein Where does government end and oil and gas industry begin? - naomi klein The money that perverts the political process acts as a kind of lid on the "frog in the pot" metaphor - it intercepts the survival instincts and keeps us all in the pot - naomi klein Politicians must be prohibited from receiving donations from the industry they are supposed to regulate - naomi klein

Naomi Klein "there are other far more effective ways to find green development than offsetting and carbon trade (the int'l carbon market - just another market ploy.) https://www.youtube.com/watch?time_continue=493&v=CN_vbJCWT6c

Personal Information Withheld - Dodge Cove, British Columbia

More comments and concerns about the Aurora LNG project:

Nexen repeatedly says they are not going to study certain effects - they are just going to apply from the "appropriate regulatory body" and NOT STUDY EFFECTS.

This is not an appropriate way of bypassing actual major concerns. Just because some government agency signs off and lets this project proceed does not mean that due diligence has been done!! Since this project is so close the community of Dodge Cove at 1/2 km away and only 3 km to Prince Rupert, putting both in major hazard zones if an LNG accident or malfunction happened, and also putting both in the way of all operating effects such as noise, air pollution, and water pollution, there should be no short cuts given by the government enabling this project to proceed without FULL studies in place.

The BC government is not representing the rights and concerns of established communities of non-native origin. The BC gov't claims they are representing us and making these decisions for us. Ignoring the community of Dodge Cove's concerns is hardly representing us. Members from this community have written many letters, spoken to many BC gov't employees and leaders, held meetings with Ministers, attended conferences and availed themselves of any opportunity to bring these issues of concern to any regulating body. This has had absolutely zero effect at having the concerns of this community listened to. The BC government is expressly NOT representing us, and IGNORING OUR RIGHTS AND CONCERNS, and have NO RIGHT to make this decision for us.

There are many discrepancies and uncertainties in public safety standards - even though international organization SIGTTO has direct safety standards that they urge governments to follow. Safety and siting need to be further studied before siting so close to human habitation.

Where is the data that proves that this close is okay? Sandia laboratories and SIGTTO are clear with their data that this close to communities is not okay. We should not have to prove that this close is UNSAFE… it has already been proven.

Who approves this site and on what basis? Why this site and not another site?

"Government isn't regulating large corporations to protect public interests, health or welfare, but instead making backdoor deals with disreputable partners."

Naomi Klein This accurately descibes what is happening here between the BC government, the Prince Rupert Port Authority, and Chinese National Offshore Oil Corporation.

"Communities on the toxic frontlines of extractive industries."

Naomi Klein This accurately describes Dodge Cove and Prince Rupert, and all the communities that will be affected in the fracking fields to extract the gas that are being told that "we understand your concerns" such as Nexen has repeatedly tried to say to Dodge Cove. Oh? You do? Is your child going to possibly get leukemia from living close to a toxic LNG terminal?

Fracked-Landscape_Simon-Fraser-University-University-Communications.

Personal Information Withheld - Dodge Cove, British Columbia

These are questions and concerns I have about the entire process and the application for CNOOC-Nexen to build the Aurora LNG terminal on Digby Island.

No unbiased peer-reviewed science.

No accurate extensive unbiased baseline data.

Nexen needs to assess prediction confidence of the stakeholders not their own company - we are the stakeholders, we do not have any prediction confidence in the predictions they have made - we don't care if they are confident in their own oil and gas industry babble, that doesn't mean that our community of Dodge Cove won't be wiped out by a major LNG accident, or unlivable by noise, water, air pollution.

Nexen has real nice plans (that the public doesn't get to see before approval?) but they are only "plans" who exactly is monitoring and making sure . Plans/platitudes.

Nexen is using publicly available information and findings from recent studies on assessments LNG projects in the region. The "region" should include global. Since Canada has no operating export LNG terminals, the information used from the assessments should include actual real data from other LNG export terminal sites that are operating, not predictions and guesses from local LNG assessments that haven't even been operating. Nexen must have access to much more information about LNG terminals than what is publicly available. How come we don't know their work record or other information?

Nexen is owned by China, by the Chinese National Offshore Oil Corporation, China does things like displace populations for industry as well as other human rights infringements. How come we don't have the CNOOC human rights record and environmental record.

VC's were selected "information collected during baseline data and investigative use studies". What baseline data was used or collected previously to formulating the AIR? Nexen says "the selection of VC's followed applicable EAO guidance and involved refinement through gov't agencies". Rationale was supposed to be provided for why VC's were NOT looked at. Nexen says they were following the gov't advice (is that the members of the working group?) yet did NOT include many details in the AIR that the working group asked for.

What are the BCEA and CEAA guidelines if the working group concerns are considered "resolved" while the proponent actually hasn't addressed the concern or studied what the gov't agents on the working group are asking for? When the CEAA or BCEA or another gov't agent asks for futher information/data/science, Nexen should have to do it.

Whales beaching themselves to get away from the noise (atlantic canada). All over the world there are reports of whales beaching themselves to get away from the noise (mostly generated by the oil and gas industry and increased tanker traffic) so how come that isn't looked at here, with Humpback whales feeding all winter at the Skeena River Estuary, and Northern Orca Whale populations coming here to feed several times a year.

image

Personal Information Withheld - Paris

Are you people living in the REAL world??

With all this dumping of millions of tonnes of pollutants into the air and heaven knows what damage in getting the stuff out of the ground, you must be nuts!!

With millions to be made, where the heck do you think you will be able to spend it when our earth is no longer safe or habitable for sentient life??

This is

Lou Allison - Dodge Cove, British Columbia

On Nexen's Public Engagement process: use of promotional materials to "inform" the public:

On a personal note, I am constantly incensed at the use of photos of the natural environment in the proponent's promotional material, including the small islands between Digby Island and Spire Ledge (Spire Island and Tuck Island) that will disappear under the proposed jetty for the tankers; the streams and beaches that will disappear under the concrete and storage tanks or within a security perimeter; the computer-generated graphics that idealize and sanitize the final concept; and the use of photos of trees and animals that we do not even have in this area (like what appears to be a mule deer and some coloured deciduous trees in the latest "Open House" brochure): disingenuous at best and intentionally misleading at worst. Clever public relations people can generate a seemingly endless stream of materials that smack more of propaganda than information. Calling the online newsletter by the clever double-entendre "Community Matters" is more of the same: the corpo ration does not exist for the benefit of the community and calling it so galls me.

Lou Allison - Dodge Cove, British Columbia

On the subject of Nexen ULC's avowed and advertised commitment to "relationship building" with "local community" for the Aurora LNG Project on Digby Island.

Dodge Cove, where I live, is not a "potentially affected community". We are a "most definitely will be affected community". Residents in Dodge Cove do not feel that their interests have been adequately acknowledged or that they have been offered effective management plans. Company representatives have been to meetings with residents and politely listened, and even at times expressed sympathy for our concerns, some of which have been expressed to them as ranting and raving due to the strong emotions evoked. (However, one company employee told us that he had heard far worse in other places. Basic civility has been maintained). They have been, by and large quick in responding to questions (except when there was turnover in the staff: we have seen many changes in employees in two years, at least in community relations). For some months, after being alarmed several times by people conducting activities around us without notice, which we are very unaccustomed to, we received weekly updating phone calls. The proponent also took several residents on a helicopter tour of the site to answer questions, though such was not asked for. Once investigative work started, the proponent did reduce the helicopter activity to eleven hours a day, not starting before 7:30AM and not flying directly over our community after a series of complaints were lodged by residents: this went on for seven days a week for months and was difficult to bear even with the concessions. The activity was incessant, not over our homes but still all around the community, with mostly three and up to four helicopters in the air at once with frequent trips to Prince Rupert for refuelling and to transport workers.

None of these measures, meetings, updates, concessions in helicopter routes and hours, which the proponent vaunts itself on and cites as part of its community engagement, come close in any way to palliating Dodge Cove's main concerns: proximity, destruction of habitat, and health and safety concerns. Dodge Cove came late to the table (self-invited) and has everything to lose and nothing to gain. With our intents at complete antipodes to those of the proponent, effective mitigation measures are non-existent. The proponent, to our knowledge, has not modified its plans to address our concerns, being given a licence by the Province to design with purposes and standards that we do not accept.

In short the proponent cannot satisfy its legal requirement to make effective management plans in regard to Dodge Cove: this remains a virtual impossibility due to the proximity and infringement issues.

Personal Information Withheld - Masset, Haida Gwaii British Columbia

The Skeena Watershed is one of the last remaining major life sustaining watersheds in the North Pacific providing sustenance to most of the people, and the health of the timber and wildlife in the entire Skeena Region. What is the rationale for risking all this for something that has several suitable sites away from both the Skeena and Fraser watersheds? What kind of madness is this? The carbon industry is a cyclical, high risk and pathogenic industry that is falling out of favor fast. Please don't allow the short term gains blind us to the risks and side effects of this completely unwholesome decision. The Skeena and Fraser fisheries, and the timber produced by healthy watersheds has built and sustained British Columbia. Let us please wake up from whatever influence we're under and protect this most important of all our resources.

Ryan King - Victoria, British Columbia

I do not accept or endorse this in any way. The risk of permanent damage to our coastline is not worth the financial benefit to a few business, with the taxpayers picking up the tab for all the risk. s

Robert Haslett - Smithers, British Columbia

There is substantial risk to to the estuarine environment that should over ride any corporate need for profits in this development.

ml johnstone

The duty of govts and citizens in these times is to protect our environments and restore the many areas already damaged by human activity. Therefore, this project should NOT be approved.

Janet kerpan - West Vancouver, British Columbia

I had the honour of working for the canadian coast guard for several years on digby island before we were transferred to west vancouver. The privilege of being able to commute by boat to the most amazing island so extremely close to Prince Rupert but you felt like you were miles away. The coast guard was the first responders to any sea disaster and Prince Rupert being a small, close knit society, it was many times I took the call on a fishing boat being lost with whole families being lost at sea. I knew many of those families. The people of Prince Rupert are hard working people who pay a high price having to earn a living there. To allow the Chinese to destroy there way of life for financial gain is outrageous and against the law as Digby island is well within the 3.5 mile radius in relation to the town of Prince Rupert and it's citizens.we should be doing all we can to help the economy of Prince Rupert through tourism and fishing. Allowing this to go ahead Wil l destroy tourism and fishing and Digby island.

Cristina Novelo, Cancún

Dear EAO,

Sincerely,

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Sandra Couch, Naperville

Dear EAO,

Sincerely,

Sandra Couch, Naperville

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Emma Morgan-Thorp - Victoria, BC

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

Hello, and thank you for taking the time to consider the perspective of one of your constituents,

I am writing to emphatically oppose the Aurora LNG proposal for a gas plant at Dodge Cove. The residents of the area oppose this planned disruption to their lives; in fact, the project violates international siting standards which require such projects to be located away from population centres and other marine traffic.

I am also concerned for the nonhuman residents of the area: noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, and on the great blue herons nesting at the Digby Island Nationally Significant Important Bird Area.

Aside from site specifics, I am opposed to LNG development on the coast full stop. This facility and upstream development would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT. Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please put a halt to this project, for the sake of BC citizens, wildlife, and ecosystems.

Emma Morgan-Thorp
Victoria, BC

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Emily Hoffpauir

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.

Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.

This facility and upstream development would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT.

Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please do not allow this project to put our coast, our communities and our climate at risk!

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Ahava Shira - Salt Spring Island, British Columbia

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

I am adding my voice to those who oppose the Digby Island LNG plant.

LNG is a highly polluting form of energy that has already contaminated hundreds of lakes and water sources in BC. Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.

Not only will the people of the places surrounding the island be impacted, the wildlife will be severely effected. Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

The Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

As for the effects on climate change and reducing our carbon emissions, this facility would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT. It would thus make it impossible for Aurora LNG impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

If we want to maintain our reputation as Beautiful British Columbia, we need to stop building new LNG plants and start focusing exclusively on renewable resources that DO NOT impact the natural world of BC in such harsh and unsustainable ways.

Please do not allow this project to put our coast, our communities and our climate at risk!

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Ahava Shira
Salt Spring Island, BC

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

I am writing on behalf of the Wilderness Committee and our 60,000 supporters across the country in regards to the proposed Aurora LNG project on Digby Island in British Columbia.

Wilderness Committee has many grave concerns about this project and therefore we oppose the development of the Aurora LNG project.

First among our concerns is the immense carbon pollution that would be generated by the terminal. We estimate that it will produce 15 megatonnes of carbon dioxide equivalent every year. This is similar to the entire emissions of Metro Vancouver, and it is at odds with our legislated climate targets.

Producing LNG in British Columbia undermines the hard work our citizens and municipalities are doing to reduce their emissions in other sectors. Not only will this be one of the most polluting projects in the country if it proceeds, but the gas will generate another 69MT of carbon pollution when it's burnt in Asia.

Beyond the climate impacts of the proposed Aurora LNG, it will have major repercussions for the residents and wildlife on Digby Island and surrounding waters. The tiny community of Dodge Cove will never be the same if this proposal moves forward.

Residents there have developed a sustainable community, and to bulldoze those dreams with this government's LNG ambitions is shameful.

Their safety is at risk as well. LNG tankers pose a small but extreme risk according to a study commissioned for the U.S. military. It found that if a gas cloud released by an LNG tanker was ignited, the blast could reach between 1.6 and 2.5 kilometres, engulfing entire communities in flames.

Clear design guidelines produced by the Society of International Gas Tanker and Terminal Operators suggest that building an LNG plant on Digby Island near the busy Port of Prince Rupert is ill-advised. Planning for this project must take public safety concerns into account and it should not proceed until Canada has meaningful regulations on the siting of LNG terminals.

Finally, the risk to wildlife posed by the project is immense. It would be located in a Nationally Significant Important Bird Area as well as critical salmon habitat with values similar to the better-known Flora Bank. Noise from the tankers would have a significant impact on the harbour porpoise, a species of special concern in British Columbia.

Please reject the proposal for Aurora LNG as it is out of line with provincial, national and global commitments to combat climate change and it will have serious impacts on local residents and wildlife.

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Thank you,

Peter McCartney

Climate Campaigner | Wilderness Committee

Malcolm Robinson - Prince Rupert, British Columbia

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

We know you people are trying to stuff this dirty business venture down our throats. And that it is by all means a safe and viable project according to your leading experts.

My concern though is traffic density.I am employed at the port in Prince Rupert. We have our container ships logs ships coal and grain ships oh and pellets. All navigating our inside waters. We know by adding to the mix it is just a matter of time before we have a catastrophy on our hands. But I to pretty much live of the sea or harvest alot of what is in my freezer. My concrete is how drastically is this traffic density going to affect the migration of our fish and shellfish? Do you have any or such scientific numbers to back it up where as our stalks or numbers will not drastically decline or further become extinct because of traffic alone? We know where we are going with an accident or catastrophy with your ships. It is not if but when it does happen.

RE: Comment on Aurora LNG

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Chris Jones, Fernie

Dear EAO,

The proposed LNG pipeline for Aurora seems to benefit a foreign corporation at the expense of some Canadian citizens.

The people who have lived here and depend upon the land to provide them food, water, and shelter should come first in the decision-making process, for some have been here for thousands of years.

There seems to be numerous risks that could affect their way of life with this LNG plant.

Sincerely,

Chris Jones, Fernie

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Eric Davidson - Lake Country , British Columbia

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

I wish to comment on the proposed Aurora LNG project for Dodge Cove. This project should not proceed for the following reasons:

Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.

Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.

This facility and upstream development would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT.

Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please do not allow this project to put our coast, our communities and our climate at risk!

Eric Davidson
Lake Country , B.C.

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Sarah Findlay - Vancouver, British Columbia

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

Auror LNG is a BAD IDEA ... there are better, cheaper and more environmentally friendly ways to create power. International markets are in decline as other jurisdictions go green ... this is not acceptable ...
fracking must STOP as it is polluting aquifers and causing earthquakes ...
just STOP it

Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.

Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.

This facility and upstream development would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT.

Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please do not allow this project to put our coast, our communities and our climate at risk!

Sarah Findlay

Vancouver, BC

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Dear EAO,

Sincerely,

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

March 7, 2017

Norma Kerby - Terrace, British Columbia

Northern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthern Amphibians Naturalists SocietyNorthe												rn Amphibians Naturalists Society

Personal Information Withheld - Kitimat, British Columbia

its not worth the risk. The Earth is being ravaged by our inability to change and evolve. It is time to stop our dependence on oil and gas and look to clean sources of energy and fuel. Please demonstrate true leadership and stewardship for the Earth and all it's inhabitants and say no to LNG.

Personal Information Withheld - Lake Cowichan, British Columbia

NO LNG on digby island

Josiah - Terrace, British Columbia

The LNG facility should not be built on Digby Island! The environmental risks are to great.

Shaheer Mawani - Australia

Once companies spend money on EIA statements it is very difficult to deny access by governments. I know because I am an offshore oil and gas engineer for Chevron. What's more is that more often than not EIA statements are 1000 page plus documents hiding the truth, misinterpreting the laws, and rarely ever include lessons learned from other areas. It is the governmanets duty to STOP Companies contemplating development in or around such environmentally sensitive areas such as Digby island. Open your eyes look at history and the Devi station this will cause. Think of the future, not only the now. STOP THIS IN ITS TRACKS BEFORE IT IS TOO LATE!

Personal Information Withheld - Price Rupert, British Columbia

Hi. I'm an 18 year old who grew up in Prince Rupert and is still living there today.

It is unfair to the residents of Digby Island who do not support having LNG right in their backyards. Both they, residents of Prince Rupert, and every living creature on this pristine coast will be put at risk by pollution and sea traffic that LNG will bring to the North Coast of BC.

We already have enough on our plates regarding to pollution in the Pacific. Fukushima, massive garbage patches, and spills. What is the use of bringing in an industry which isn't particularly flourishing in the market, primarily hires over-seas workers, brings staggering amounts of health hazards to people and other organisms alike, and could very likely be replaced in only some years by alternative methods of energy and job creation?

The North Coast has been doing quite well without LNG for years and still grows healthily to this day! With tourism, fishing, logging, exporting and importing goods through our port. Two of these, tourism and fishing, will be put at risk by LNG. That is not healthy for us.

If it ain't broke, don't fix it.

LNG isn't our last hope for the economy and well-being of the North Coast and rest of BC. We still grow everyday without LNG.

(The attachment is some photos of residents here who are unable to send a comment, question or concern.)

image

Personal Information Withheld - Dodge Cove, British Columbia

I believe that it is the governments' job to study the impacts that LNG terminals have had in other areas of the world, to other communities, while assessing the impact that any proposed development would have here.

Yes, we are a unique area that will have some different concerns and levels of impact compared to a different location, but if the data is available, if the scientific studies are done, and if it can be duly noted on the impacts that LNG terminals have had in other areas, I think that gives a wider understanding to some of the issues this region, and the communities of Dodge Cove and Prince Rupert would face.

Some of these issues may have already been looked at by CNOOC-Nexen for the Aurora LNG terminal, but many of these have been overlooked as well, or data and reports from other areas haven't been looked at, and from interests outside of the company wanting to build Aurora LNG.

Here is a report from Europe, and it details such topics such as rape! What impact will this have to residents of Prince Rupert? How safe will the women and children is this town be? How safe will the residents of Dodge Cove be with a 5000 man work camp a 10 min stroll through the woods?

The impacts to the housing market in Europe was drastic - with local residents having no chance to purchase houses, and increased homelessness and lack of rentals available at reasonable prices, (this we are already seeing here in Prince Rupert), and also additional costs to planning etc to the local communities, taxpayer money dealing with many issues. How is that ok, for municipal governments to bear the brunt of many different costs associated with this type of development?

Have the sociological impacts to this region been looked at accurately and without bias, or are all reports on this being presented by CNOOC- Nexen?

SOCIAL IMPACTS OF LNG
REPORT TO THE PEMBROKESHIRE
HAVEN SPATIAL PLANNING GROUP
November 2005
Ref: KW/JB

"CRIME
Between May and October 2005 the police have had to attend approximately 30 incidents that have occurred as a direct result of LNG construction ranging from allegations of theft to rape.
A typical offence resulting from a suspicion of indecent assault involved 120 hours of investigation at a cost of approximately £1,850, interpreter's costs of £5,000 and custody costs in excess of £2,000. The cost of this one investigation totalled approximately £9,000. The police have expressed concern about ensuring that there are sufficient additional resources to address additional crime and disorder resulting from LNG related construction, rather than dilute the quality of service elsewhere.

HOUSING IMPACTS
General Pembrokeshire and adjoining coastal rural communities generally have a relatively small housing stock, higher levels of second home ownerships, high level of in-movers for retirement and low wages, which in normal circumstances create enormous pressures in the local housing market for rental and purchase.
Affordability of housing for local residents is a problem.
The Chartered Institute of housing policy briefing "Young Working & Homeless identified Pembrokeshire as having the second highest house price to income ratio in Wales in 2004.

HOMELESSNESS
Public sector provision of accommodation is reducing year on year with total tenancies in
2002/03 totalling 8282 and in 2004/05 totalling 7862. The County Council's tenancies reduced from 6332 to 5848 with a small increase in Pembrokeshire Housing Association and Cantref tenancies.
The numbers of homelessness applications received by the Council have been increasing steadily year on year.
During July to September (Q2 2005), the number of applications increased substantially at a time when a reduction in applications would have been expected compared to the previous quarter.Closer analysis of the reason for the homelessness shows an increase in the numbers of homeless applications as a result of loss of private rented sector accommodation during the same period. Anecdotal evidence from homeless customers indicates that a number of landlords have terminated tenancies to let to LNG workers at higher rents than can be paid by the fo rmer tenants.

There is a concern however that the lack of affordable properties to purchase or for rent is having a detrimental effect on recruitment within the Health Service.
The Ambulance service had identified the need for a paramedic/EMT crew and a fully equipped ambulance when an early calculation suggested a population increase of 3,000 – 4,000 men. This early assessment will now require review in terms of numbers and ambulance response times.

TRANSPORT
The County Council has undertaken an initial preliminary assessment of traffic impacts based on information available in September 2005. This information indicated up to 20,000 additional movements per day at peak in Milford Haven and Pembroke Dock there is a lack of a public transport intermodal focal point for all transport services

OTHER LOCAL GOVERNMENT SERVICES
In addition to housing and transport services, the Council has been or will be affected by LNG related activity and other major projects in a number of other ways (planning is one). The County Council and the Pembrokeshire Coast National Park Authority are both affected by LNG related developments. The fee received in respect of the LNG terminals was:
Exxon site, National Park £16,620
Exxon and Dragon sites, PCC £33,880
The estimate of costs involved in processing these applications, and preparing evidence for Judicial Review, instructing solicitors etc is as follows:
PCC in-house legal costs 40,000
External legal costs
Other staff costs
32,000
£80,000
Total 152,000
PCNPA External legal
(excludes internal staff costs) £100,000
- 13 -
Note: These costs are in addition to an estimated £45,000 to PCC and £55,000 net to PCNPA of costs incurred in respect of the Bluestone Holi day Village planning application and review. PCNPA estimate that at least 1.5 work years has been taken up in dealing with both Reviews. The total costs to both Authorities could increase considerably in the future. PCNPA were awarded full costs of £100,000 in respect of the LNG judicial review but as the applicants were in receipt of legal aid no costs were forthcoming. It is considered inappropriate for local Council taxpayers to have to bear the cost of processing applications which are clearly developments needed in the 'National Interest'.

Waste Disposal
Any increase in resident numbers will have a proportionate impact on the waste system.
Evidence to date indicates that recycling initiatives are disregarded in many properties occupied by in-migrant workers and 1-2% increase in temporary residents will make recycling targets more difficult to achieve.
Education
The adult education service has seen a significant increase in English language tuition across a wide range of European and Eastern languages.

It is estimated that current construction activity has resulted in a significant increase in construction costs of around 25% over the last year. It is difficult to determine the exact increase due to contractors picking and choosing which projects they are prepared to tender for. There was a period in 2004 when some schemes failed to attract any tenders as local contractors had sufficient work on their books.
Some School projects saw the cost of construction per square meter double over a 3 year period.

All in all, local "first time buyers have no chance".
Rental prices were felt to be largely out of the scope of local people with poorly (local wage rates) paid jobs. Significant problems are faced by those with no family, people living on a single income and those with low paid jobs. One interviewee talked of comparatively old (22 - 30) young people unable to leave home and move into flats because of the cost.
This was considered to have a sociological impact on the young people of the county.
Reference was made by one interviewee to lower paid people unable to live in Pembrokeshire and moving out towards Tenby and even out of county to areas where rental costs were lower.
All interviewed said that stories about the eviction of tenants in order to obtain greater income from LNG clients are true, although this is not universal. There is significant evidence of landlords seeking the short term gain from the LNG projects.
A comment mad e by several interviewees was that the Council seemed to be "grateful" that the projects had come to Milford, yet commensurate increase in wage rates or an increase in affluence for the lower paid sector of the economy. Reference was made by three of those interviewed that much of the rental revenue made by landlords was not returned to the local economy. The view was also expressed that the Oil companies had yet to convince the local people of the benefit to the local economy from their activities, and their lack of commitment to the local area - citing the terms that had been negotiated in Scotland between Oil companies and affected communities."

Lou Allison - Dodge Cove, British Columbia

On the subject of the exploration activities conducted under the Licence for Investigative Use for the Aurora LNG Project on Digby Island:

To July 2016, according to information from the proponent, the company has conducted 96 bore holes to test the geology of the substrate: 94 on land, 2 intertidal. Many many core samples have been removed, crated and shipped for analysis. Plans are being made for more investigative work in 2017: months of more helicopters, more drilling, more shipping of samples. The proponent has stated that the use of helicopters, up to three in the air at a time, is obviating the need for building roads to obtain samples and is "greener". Certainly, if roads needed to be built, these would be difficult and expensive undertakings, given the extent of the bogs, ponds and uneven terrain. The company has tried to minimize its impact, but inevitably has cut down trees to build platforms and landing pads over bogs, and created extensive foot trails for workers. I have seen some of these, both on a helicopter tour the proponent offered when I asked questions (which was unnecessary but commendable) and by walking in. Others have seen them in overflights to and from the nearby Digby Island airport. I have pictures, including the stump of a bog pine that, despite its small diameter, is impossible to age by counting the rings as they are too tight to see by eye, obviously some hundreds of years. There is a significant impact to this investigative activity. Though the proponent is committed to restoring the habitat if there is a decision to not go ahead, I submit that this impact is long lasting and irremediable in the fragile bog environment, which is incredibly slow to mature and cannot readily absorb change. A felled tree is a dead tree. I do not accept that the pervasive use of helicopters makes an industry green: the immense quantities of fuel consumed contribute to overall global greenhouse gas production, and don't seem to be included in the models for emissions production. In my opinion, the ecological disturbance, irremediable effects and emissions production put the lie to any argument that this industry in green even in its initial phases.

Tom Spiller - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submission

Bill Smith - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submissinpublic comment submissionpublic comment submission

Sarah Ridgway - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submission

Jeremiah Randall - Dodge Cove, British Columbia

public comment submission

Mila Puharich - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submission

Dave Prosser - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submission

Des Nobels - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submissionpublic comment submission

Laura Moore - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submissionpublic comment submission

City of Prince Rupert - Prince Rupert, British Columbia

Please accept the attached letter of public comment from the City of Prince Rupert.

submission from City of Prince Rupertsubmission from City of Prince Rupertsubmission from City of Prince Rupertsubmission from City of Prince Rupert

Francine Masse - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submission

Karen McKinster - Dodge Cove, British Columbia

Statement of Personal Impact

public comment submission

Mathew Leakey - Dodge Cove, British Columbia

Statement of Personal Impact

Statement of Personal Impact

Paul T Charette - Smithers, British Columbia

This project cannot be built without serious detrimental effects to humans,wildlife,and the environment of Digby Island and area. It will require a large gas pipeline across the province with it's own slew of environmental effects and it will be supplied with fracked gas from NE BC that should be left in the ground. I am totally opposed to this project because of it's effects on the environment.

Sascha Gilbert - Dodge Cove, British Columbia

Statement of Personl Impact

Stetement of Personal ImpactStatement of Personal Impact

Sarah Brown - Dodge Cove, British Columbia

Statement of Personal Impact

Statement of Personal ImpactStatement of Personal ImpactStatement of Personal Impact

N. Carol Brown - Dadge Cove, British Columbia

Statement of Personal Impact

Statement of Personal ImpactStatement of Personal ImpactStatement of Personal Impact

Wendy Brooks - Dodge Cove, British Columbia

Statement of Personal Impact

Statement of Personal ImpactStatement of Personal ImpactStatement of Personal Impact

Mark Boyce and Evelyn Merrill - Dodge Cove, British Columbia

Statement of Personal Impact

personal inpact statement

Lou Allison - Dodge Cove, British Columbia

Statement of Public Impact

statement of public impact statement of public impact

Lou Allison - Dodge Cove, British Columbia

submission

Personal Information Withheld - Dodge Cove, British Columbia

I am writing a comment after reading a public comment that was released online on March 4th.

Here is the direct quote:

"I support the Aurora LNG project. Recently, they held a community information session in Prince Rupert where I learned that most of the development will be 3-4km from Dodge Cove. I initially had concerns that the facility may be too close to the community for their comfort but this put my mind at ease."

So this person, who has been fed false information by CNOOC-Nexen regarding the proximity of the project to Dodge Cove (and I must say Prince Rupert) now believes that the Aurora LNG terminal isn't very close to communities.

What kind of public information session is this - where false information and lies are given to the public - which is then said to be "informing the public" about the project, and "true consultation"?

In one little tiny comment (very easy to miss) - in an Aurora LNG news bulletin that was printed and also released online, CNOOC-Nexen actually did admit that they were 3 km to Prince Rupert (Prince Rupert, not Dodge Cove, which the person who went to the open house is claiming they were told 3 km to Dodge Cove).

Was this person told that the Project Development Area overlaps and removes green space from the Dodge Cove Official Community Plan in a major way?

Was this person informed that the 3 lane highway for the project is to run through the essential watershed that feeds the Dodge Cove Water Dam (in the Final Application for Aurora little is mentioned about our water dam and weird statements such as "the stream that possibly supplies water to the community" and all avoidance of the actual name of the dam even though it has a big sign that Nexen employees would have seen the ONE time they came to take a water sample)?

Was this person informed that residents of Dodge Cove would be living in a toxic air quality area according to the recent cumulative air effects report for Prince Rupert? Air quality laws are clear about what levels of pollutants are allowed and Dodge Cove will be in the RED (think DEAD) zone!!

Was this person informed that the residents of Dodge Cove have long been speaking out about the proximity of this project and how close it actually is at 1/2 km to less than 500 metres from our homes?

Was this person informed that Dodge Cove residents were driven crazy by helicopter traffic by Nexen "Investigative Use License" in which they clearcut approx. 120 areas as large as my house on our island, on undisturbed habitat that supports many red and blue listed species? Driven crazy by the constant loud noise of rotating chopper blades behind and beside our homes, to where residents complained about the noise? Was this person told that residents had raised these issues to the Ministry of Forests Lands and Natural Resources before they approved the IUL, and that none of the concerns of Dodge Cove residents were responded to - including site location and proximity!!

No, this person was reassured by CNOOC-Nexen employees that the project was 3-4 km away from us (impossible distance measures - did the maps at the open house show the Dodge Cove OCP and the overlapping of Aurora LNG PDA across it??)and no problem at all. Who oversees the information distributed at these open houses? These open houses are to properly inform the public, not just present the lies from the proponent, in this case Aurora LNG, and the complete disregard of everything that the Dodge Cove residents have been trying to make public (the proximity) is so infuriating!!!

This entire public consultation process is a joke.

https://www.youtube.com/watch?v=Tg1cMNuHgpI&feature=youtu.be

Keith Cociani - Prince George, British Columbia

This is far to large an industrial project to be put so close to Dodge Cove. I am most concerned about the massive NO2 emissions, inevitable when burning such a massive amount of fossil fuel. Even a clean fuel like natural gas burned in that volume produces huge amounts of NO2 which will acidify the very sensitive environment on Digby Island.

Linda Kemp - Quesnel, British Columbia

British Columbia Environmental Assessment Office

Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents. Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic. Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island. This facility and upstream development would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT.

Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please do not allow this project to put our coast, our communities and our climate at risk!

Linda Kemp

Quesnel, BC

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Sally Soanes - Parksville, British Columbia

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

This Aurora project is so polluting I really don't know how it can possibly be approved. It also violates the international siting standards. The site is so close to bird breeding grounds.By approving this project you are showing what BC now stands for. Big bucks talk and get approved here and climate change, the environment and its residents don't matter at all.

Sadly

Sally Soanes

Parksville, BC

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

JIM MCROBERTS, BELLEVUE

Dear EAO,

The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents.

Sincerely,

JIM MCROBERTS, BELLEVUE

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Elaine Fischer, Roanoke

Dear EAO,

Sincerely,

Elaine Fischer, Roanoke

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

March 6, 2017

Antonia Mills - Prince George, British Columbia

Note that the Aurora LNG Digby Island Project does not meet the specifications that such sites must be 3.5 km from a place of human habitation. Both the people and the environment would be harmed by its presence at the proposed site.

Ruth Brady - Hazelton, British Columbia

I am very concerned about the proposed Aurora LNG facility proposed for Digby Island. This project can not be allowed to proceed.

According to the Society of International Tanker & Terminal Operators, LNG facilities should not be built within 3.5 KM of any community. The residential area on Digby Island is .5 KM from the proposed facility and Prince Rupert is 3 KM away.

There would be a significant impact on fishing and tourism which provides the Province with hundreds of millions of dollars annually - in particular the Salmon. Putting Salmon at risk is tantamount to genocide of the First Nations that depend on the Salmon for their livelihood.

We are trying to reduce our greenhouse gases and this project alone would add 15 tonnes of CO2 to our Provincial totals.

Please. DO NOT LET THE PROJECT HAPPEN.

Deena Guffei - Vancouver, British Columbia

My concern is in regards to the proposed LNG project affecting Digby Island. The operations would be 0.5 kms away from the community of Dodge Cove and only 3 kms away from Prince Rupert. International tanker regulations state that ALL LNG facilities should be at least 3.5 kms away from any community - where humans need to breathe the air, drink the water and live daily lives! This along with the massive amounts of green house gas emissions generated and fracking are very concerning for me.

Nancy Fischer - Crippen Cove - Digby Island

What a waste of a beautiful place. You should be developing solar & tidal power instead!

Alan Burger, President BC Nature

The attached submission has the support of BC Nature (Federation of BC Naturalists) representing 53 naturalist clubs around BC with over 6,000 members.
BC Nature is strongly opposed to this proposed LNG plant for numerous reasons, primarily because of the the unavoidable impacts to wildlife and several listed threatened species. Our letter documents this in detail.

Federation of BC NaturalistsFederation of BC NaturalistsFederation of BC Naturalists

Carolyn Henry - Vernon, British Columbia

I say "NO" to this LNG building in such a beautiful place. Let our families and families to come have no such thing on their land.

Personal Information Withheld - Dodge Cove, British Columbia

I have concerns about what the dredging would do to both the fish populations that we depend on for food and for making a living (whether directly or indirectly) and also what that could do to our health. The impacts to our food have been looked at a little bit, but have studies such as the impact that dredging has had on the Gladstone area been looked at? Since dredging has taken place there, that area has seen a total collapse of marine life, making local businesses shut down. Why should Aurora LNG be approved, and allowed to dredge in the sensitive Skeena River estuary habitat when all evidence points to death for fish and marine life?

"The southwest shore of Lelu Island and Delusion Bay are highly valuable habitats for neritic feeding species (e.g., Coho, sockeye, and steelhead).With all of these potential projects on the horizon, flat land for development, especially land owned by the Port of Prince Rupert, is in short supply, thus forcing some of the projects into serious trade-offs between deep-water access and sufficient land for site development.Increased vessel traffic associated with these planned terminals, as well as potential oil tanker activity from proposed projects such as the Enbridge Northern Gateway, will also increase the possibility of spills and other marine accidents.

Although estuaries provide essential nursery and juvenile rearing habitats, with up to 80% of coastal wildlife species relying on estuaries during at least one stage of their life history (BCMOE 2006), they frequently occur in areas highly valued for industrial development.

What has changed in our environment that has now allowed this region to be considered a prime site for industrial development?

Estuaries worldwide are often areas of conflict between human resource need and environmental sustainability. This is further exacerbated by a site-by-site approach to habitat protection, which often saves sensitive habitat from destruction by one project only to have the same piece of habitat threatened by a neighboring project. A more holistic approach to habitat protection is required, underpinned by a thorough scientific understanding of the roles and vulnerabilities of the different species and habitats in the estuarine environment. In order to implement this approach, there is a need to better understand the cumulative, and often complex, anthropogenic impacts on estuarine environments."
http://www.oceanecology.ca/Juvenile%20salmon.htm

"What is Gladstone's LNG development really doing to the environment?
October 19, 2011 3.23pm EDT

Fish and other marine life have been infected by a strange parasite that seemed to make the leap to humans. The outbreak led to a local fishing ban which was recently overturned, despite lingering concerns about water quality and the health of fish.

Some commentators have suggested liquified natural gas (LNG) developments on nearby Curtis Island could be responsible for the ill health of marine life and the flow-on effects.

So what sort of assessments were done to predict the environmental effects of LNG developments? Was enough done? And what will be the long-term effects for the local environment and the people of Gladstone?

Fundamentally flawed

Quite simply, the Gladstone case highlights the flaws in the environmental impact assessment and approvals processes overseen by state and federal governments.

In order to start a project such as the one on Curtis Island, LNG companies are required to carry out environmental impacts assessments (EISs). These assessments must be approved by the state government and by the Commonwealth, if the type of environmental damage is covered under Commonwealth legislation – in the case of biodiversity impacts, for example.

Notably, these EISs are done by private companies hired by the businesses backing the project.

Dredging the Gladstone Harbour

The massive development of Gladstone Harbour – including dredging to allow large LNG vessels through – will cause many environmental and social problems, the extent of which has not been settled in EISs.

Fishy business

Fish habitats in Gladstone harbour will also be diminished by the project. New wharves are being created on top of sea grass beds. The dredging stirs up silt which remains in suspension in harbour waters, affecting the ability of fish to extract oxygen from the water, before settling out on sea grasses and wetlands.

The quantity of food available for both commercial and recreational targeted fishes is thus diminished.

The environmental effects will be long term. Dredging will continue to at least 2015, and the sea grass beds that are smothered will take some years to recover after dredging stops.

Another impediment to fishing is vessel traffic in the harbour. Hundreds of workers and materials need to be ferried to Curtis Island daily, and LNG vessels and their wharves have large exclusion zones around them.

The economic future of commercial fishermen using the harbour is not nearly as emotive an issue as damage to the Great Barrier Reef. But it is another cost of the development that has often been minimised in EISs and by the Coordinator General.

Social impacts assessments in the EISs suggest only a handful of fishing businesses will be adversely affected. But it is obvious that harbour-wide impacts affect – and will continue to affect – the livelihoods of a considerable number of fishing families.

Furthermore, local wholesaling, processing and exporting businesses will find it difficult to survive the reduction in supply of local fish.

An issue avoided in social impact assessments is the serious economic impact of the scarcity of skilled and unskilled labour on fishing and wholesaling businesses. These cannot compete with the high levels of remuneration offered by the transport, dredging and building companies operating in the harbour.

It's time for change

Given the massive economic and tax benefits to both state and Commonwealth governments of LNG developments, there is a conflict of interest when these same governments make environmental assessments.

Moreover, the chances of these judgements being biased are exacerbated when the EISs are put together by the project developers themselves.

Something needs to change to mitigate the inevitable damage done under the present assessment system by large projects such as LNG.

It would be costly to mandate that independent bodies carry out environmental and social assessments and reviews of projects. Nevertheless it is a solution that should be considered."

http://theconversation.com/what-is-gladstones-lng-development-really-doing-to-the-environment-3885

Youtube videos regarding Dredging problems in Gladstone and affect to local fish/seafood https://www.youtube.com/watch?v=LWkISQDRxdE

https://www.youtube.com/watch?v=D-nGtbQmd-I
https://www.youtube.com/watch?v=abt0mIu5cys
https://www.youtube.com/watch?v=muCc-W9X7og

https://www.youtube.com/watch?v=yF89lvngy-I
https://www.youtube.com/watch?v=uGsa_-5uh-Q

GLADSTONE DEAD ZONE FOR MARINE CREATURES Posted on September 2, 2012 by Sue

(More dead fish and animals)

"surfaced in the murky Gladstone Harbour controversy following recent claims by Fisheries Queensland that sick fish were getting better.

Commercial fishers have scoffed at the suggestion and in the past few weeks The Queensland Telegraph has been told of at least six dead turtles, five dead barramundi, three very sick barramundi, two dead dugong and other diseased catches.

Pictures and statements relating to some of these have been sent to Law Essentials, the Queensland firm co-venturing with Shine Lawyers in the fishers' compensation case, with a court judgement pending.

The more alarming claims made to the Telegraph include a "clean- up crew" patrolling the harbour day and night to remove dead or sick fish and marine animals, and a statement that Bio Security Queensland has informed fisheries officers there would be no further tests on diseased seafood "unless it was a new disease".

" This fish situation is not fixed, not going away and not getting better. Fishermen are leaving; they are pushing people to the limits with stress levels and they are dropping out," he said.

Fisher Gary Otto of Turkey Beach agrees. He knows one colleague who fished the same area, Chris Putman, who left for Hervey Bay this month because of diseased and depleted catches.

The Telegraph recently reported the Otto family's personal health battles after coming in contact with a toxic algae, *lyngbya majuscula, while cleaning their nets. He said then that up to 30 percent of his catch was diseased, he had pulled in a barramundi that was "alive but absolutely rotten" and he and his son were constantly fighting skin infections over the past 12 months.

Since then he had given up fishing the Turkey area but a couple of weeks ago he had taken his grandson fishing to Seven Mile Creek and they had caught a large blubber lip bream and a mullet which were both heavily diseased.

" I have another diseased barra alive in a tank to see how long it lives," he said.

Mr Otto said he had recently been fishing a few nights up in Gladstone Harbour when he had been approached by an unmarked boat "not a government fisheries boat," whose crew were wearing orange work shirts.

" Their job was to clean up any mess, any dead fish or turtles, before the public sees them," he claimed.

Besides the toll on Turtle Island, The Telegraph has also taken photographs of three dead turtles at Tannum Sands recently, the latest at Canoe Point last week.

About the same time a report was received of campers encountering a couple of dead barramundi and a dugong at Point Richards, south of Turkey Beach.

(*Toxic lyngbya algae is known to cause severe reactions including skin rashes and asthma like symptoms in humans and is also dangerous to marine animals. Blooms are associated with increased nutrient levels, sometimes following dredging, as reported in Moreton Bay following dredging of the Gold Coast Broadwater)."

http://www.greatbarrierreef.org.au/gladstone-dead-zone-for-marine-creatures/

"THE sickness plaguing a central Queensland fishery has spread to prawns and other species.

There is no end in sight to the crisis which has decimated the fishing industry in the burgeoning port of Gladstone.

"Harbour water is absolutely filthy from dredging." Dr Gardner said."

http://www.couriermail.com.au/business/devastating-disease-spreads-from-fish-to-other-marine-species-at-gladstone/news-story/daba804ba134e60d7ffc4513c8cb7ee3

The Dead and Diseased Marine Animals in the Gladstone Harbour "Between May 2011 and early 2012 a number of marine animals began dying in the Gladstone Harbour. They included turtles, dugongs, fish, crabs, sharks and stingrays. Many more were found to be suffering from diseases, most featuring red spots, lesions and parasites.We believe that the cause was more simple, and was a result of the wholesale stripping of seagrass meadows in the Gladstone Harbour in the latter part of 2010. In this article we shall explain why.

The State Government accepted these claims and approved the seagrass removal, even though it acknowledged that turtles, dugongs and dolphins would be displaced from their habitats. The Government claimed that the project is not expected to have a significant net negative effect on the diversity of the systems within the Port Curtis region, nor is it expected to have flow-on impacts to the communities that use the habitats within the project area. It may well have been right too, if only 89.18 ha of seagrass had been removed.

But the 89.18 ha figure was a lie. A fiction. A sham.

418.2 ha was removed or died around the dredging area in just months.

Both the GPC and the Queensland Government had noted in their EIS statements that seagrass in the vicinity of the project area may suffer impacts resulting in the smothering of existing substrates by sediments settling from the water column during the dredging and decant activities for the project, but the Government believed (or so it said) that the GPC's modelling indicating that the sediment from the dredging would fall where it was dug was true.

Someone should have told them how tidal waters work. The sediment from the dredging – which the GPC and the Government claimed would settle where it was dug – was in fact carried by the moving waters and spread across the harbour, choking seagrass meadows far and wide. Imagine throwing tonnes of toxic dirt on your lawn and you will begin to understand exactly what happened.

Over 600 additional hectares of seagrass died across the harbour.

Soon sick fish started appearing near the dredge site. Then sick crabs; and turtles; and dolphin, and dugong. Then the barramundi that were washed over the Awoonga Dam spillway began to arrive in the harbour. They soon became ill too.

The food chain had been disrupted by the removal of all the seagrass.

There was nothing to eat. The water became more turbid because there were no seagrass roots to stabilise the seabed. The marine life got sick, and many fish, dugongs, turtles, crabs and prawns died.

Sure, there were various contributing factors such as water quality, increased schools of barramundi, and salinity issues. But the base cause was that the seagrass meadows had been destroyed."

https://itsnotnormalisit.com/2015/03/10/exposing-the-ports-corporations-lies-the-truth-about-gladstone-harbour-part-1-the-slaughter-of-the-seagrass/

Image of Fish

Annette Witteman, Mayne Island

Dear EAO,

Please become aware that any small disruption of Salmon habitat is disastrous for their continued survival.

Big Industry can not possibly put in measures which will indefinitely protect the wild life who breath the water that surround their projects. I stand for the Ocean -Our Earths Lungs -I stand for the creatures who can not plea for their lives- NO LNG! NO TANKS!

Sincerely,

Annette Witteman, Mayne Island

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Neal Hoffberg, Issaquah

Dear EAO,

I stand with the Ierra Club of B.C. And the skeena watershed in asking you to block the developments of the Aurora LNG project.

Sincerely,

Neal Hoffberg, Issaquah

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kaaren soby, Telkwa

Dear EAO,...we live in the MOST pristine, most beautiful, most wild and free and spiritually imbued part,of,the world enjoyed by people around the Globe,cherished by the locals and foreigners alike. Your project,WILL destroy not only the Economics of the region ,but,the land and mammal wildlife, vast ecosystems which need to flourish in order to support all of us sharing in life on earth

It is a diabolical,unconscious, rapacious and ignorant beyond belief plan to destroy life on this sacred planet of ours. I hope beyond hope that you come to your senses and realize the vastness of destruction you are catalyzing

Sincerely,

Kaaren soby, Telkwa

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Mike Seyfried, Boulder City

Dear EAO,

I am writing you today in regards to the proposed Aurora LNG plant to be built near Prince Rupert. I urge you to consider the following points during your deliberations.

International tanker regulations state that ALL LNG facilities should be at least 3.5 kms away from any community - where humans need to breathe the air, drink the water and live daily lives!

At the mouth of Prince Rupert harbour, the proposed Aurora LNG Project (CNOOC-NEXEN) would emit 91 Million GHGs and other toxins, compared to the illustrious Petronas LNG plant, calculated to emit 85 million tonnes!

Thank you for your time and consideration.

Sincerely,

Mike Seyfried, Boulder City

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Deena Guffei, Vancouver

Dear EAO,

I am writing to share my concern about Aurora LNG affect on climate change, our community and wildlife.

AURORA LNG THREATENS SALMON AND WILDLIFE
The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.

Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

AURORA LNG THREATENS COMMUNITY HEALTH AND SAFETY
The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of Dodge Cove residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

AURORA LNG THREATENS OUR CLIMATE
As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget..

Please do the right thing and not move forward with this project.. Canada needs to be investing in RENEWABLE energy that does not threaten life and our planet.

Sincerely,

Deena Guffei, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kathleen Davies, Terrace

Dear EAO,

Sincerely,

Kathleen Davies, Terrace

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

David Carpenter, Stoddard

Dear EAO, Please put the environment that our children and their children will inherit as a priority. What will you tell your grandchildren when they ask what you did to protect the environment. Say NO to the LNG development on Digby Island. Thank You for doing the right thing for the Planet. David & Pat Carpenter.

Sincerely,

David Carpenter, Stoddard

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Antonia Mills, Prince George

Dear EAO,

We have to stop each and every LNG processing plant that will damage the environment and the will salmon in our rivers. It is totally unacceptable to put the Aurora LNG processing plant in as it will impact humans as well as fish.

It is time to stand up for what counts, and that is protecting humans and fish and the environment.

Sincerely,

Antonia Mills, Prince George

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Elizabeth Borek, Victoria

Dear EAO,

The Aurora LNG proposal violates international standards which call for a distance of 3.5 km between a plant and a community where people live. Approval of this project, which is only .5 km distant from the community, represents an attack of this government on the people Digby Island.
It also endangers many species which are red and blue listed.
Economically this project is insane. There is no need for this gas. BC will be destroying our precious and irreplaceable environment for nothing.
Is this government so corrupt that life, even human, has no meaning?!!!

Sincerely,

Elizabeth Borek, Victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Sivalla Lin, Salt Spring Island

Dear EAO, I am opposed to the LNG plant at Digby Island and Lelu Island. The Government should not develope industries that endanger salmon runs and coastal communities. Fracked gas is environmentally destructive. Clean, sustainable energy such as solar, wave and wind should be developed and used instead. Stop all LNG plans. Thank you, Sivalla Lin

Sincerely,

Sivalla Lin, Salt Spring Island

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Carol Ponchet, Hazelton

Dear EAO,

Hello and thank you for taking the time to read my letter. I live in Hazelton, a ways up stream on the Skeena river. I am deeply distressed that the potential for an LNG facility any where near the Skeena estuary and Prince rupert still exists. You must say 'No' to this dangerous possibility. The green house gas emmisions alone should suffice to say No to this proposal. As well, it is well known that no LNG facility should be anywhere within 3.5 kms of human habitation because of the risk of explosion and noxious gases. why even consider this proposal? It is sheer folly. Espacially when there are so many other ways of producing energy and employment that are far cleaner and greener, friendlier to our environment and all the flora, fauna and people who live there. Please help protect this pristine and beautiful part of BC forever!

Thank you!

Sincerely,

Carol Ponchet, Hazelton

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Liz Chisholm, Chilliwack

Dear EAO,

This has to stop! Your department's responsibility is to the citizens of British Columbia, and any economic benefits of this Aurora LNG project will be overshadowed by the threat to our salmon, our environment and our health. Do the right thing, for the right reasons, and remember who you represent.

DO NOT approve of this project.

I sign on behalf of my family of 4 children, 8 grand-children, 4 siblings, and their families.

Sincerely,

Liz Chisholm, Chilliwack

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Patti VanderLinden, Calgary

Dear EAO,

RORA LNG THREATENS SALMON AND WILDLIFE
The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.

Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

AURORA LNG THREATENS COMMUNITY HEALTH AND SAFETY
The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of Dodge Cove residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

AURORA LNG THREATENS OUR CLIMATE
As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

Sincerely,

Patti VanderLinden, Calgary

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Heather Ross, Bayfield Ontario

Dear EAO,

I was born in Terrace.

No. Do not risk such an extraordinary place.

Sincerely,

Heather Ross, Bayfield Ontario

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Heather Ross, Bayfield Ontario

Dear EAO,

I was born in Terrace.

No. Do not risk such an extraordinary place.

Sincerely,

Heather Ross, Bayfield Ontario

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ava P Christl, Victoria, B.C.

Dear EAO,

You already know the science - now you must listen to it. We need policies and practices that put people and place before profits. All the money in the world won't feed us when the rivers run dry and the fields are scorched. Governments at all levels need to be thinking about the future of all generations, not just the current one. We need to look for and implement solutions that protect the very resources needed to sustain life - water, air, soil. To do anything else is playing with our human fate. Is this how you want to be remembered?

Sincerely,

Ava P Christl, Victoria, B.C.

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Jordie McTavish, Revelstoke

Dear EAO,

A massive LNG fracked fas plant owned by a Chinese oil giant is not what BC and Canada need. Carbon based fuels are also not what the world needs or wants.

Profits for large corporations and risking the Skeena watershed is ludicrous. In BC we have sustainable fisheries upon which British Columbians rely upon for a living.

This is yet another short sighted carbon based energy idea when we have yet to exercise the many carbon free energy alternatives.

Please consider the people of British Columbians as well as the our unique wilderness represented by the Skeena watershed, salmon, Grizzly bears, and all that this fragile ecosystem represents.

Yours,

Jordie McTavish

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Earl Richards, Victoria

Dear EAO,

There is something "fishy" going-on here. With a thousand miles of coast line, why is a site next to a salmon spawning area being selected?

Sincerely,

Earl Richards, Victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Jackie Suzanne - victoria

Dear EAO,

Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds.

Auroa LNG project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

Please protect this sacred area where the First Nations rely on salmon as their primary food source by not building an LNG Plant that could seriously impose the natural beauty of Prince Rupert and the Skeena River.

Sincerely,

Jackie Suzanne, victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Al Varty - Vancouver

Dear EAO,

All of these LNG projects are bad for the provinces environment. The people of BC will be paying for this foolishness for years. Stop the idiocy now

Sincerely,

Al Varty, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

March 5, 2017

Personal Information Withheld - Dodge Cove, British Columbia

Hammerfest is often quoted as being a "success" story by the LNG industry. The LNG terminal is 4 km from the city center, and always visible, on a rock island with nothing else on it in view of the city. Yet the city doubled the property tax on that land, and receives approx. 193 million Norwegian Krone per year ( $22 million per year) in direct property tax alone from Statoil, and Statoil is 67% owned by the government of Norway, so there is also a major difference in direct benefits reaped by the city, and by the country. The below report talks about many of the issues that are also being felt, all that could easily (and some are already appearing) be felt here in the Pacific Northwest.
"Eight respondents representing a wide range of different backgrounds highlighted the municipality's property tax system as central to reaping local economic benefits of the Snow White project (Interviewees 1, 2, 3, 4, 8, 15, 16, 18). Property tax from Milk Island gives t he local municipality approximately NOK 157 million per year [64], while Hammerfest's revenue in 2013 totaled NOK 979.8 million [32].

Despite broad support for oil and gas, an undercurrent emerged in some of the interviews, particularly with interviewees who were not directly involved in business development or politics. The tendency was to first talk about all the benefits of petroleum, telling a similar, apparently "official," sunshine story. After a while, the word "but" often appeared followed by negative side effects, the main being economic and social inequality and the increased price of housing and services, all of which make life harder for people who are not working in the petroleum industry.

The social effects were described in different ways, including the transition from a simple life where most people knew each other, to a "harder" society with more focus on money and status. Words mentioned were "less focus on softer values" (Interviewee 1) and "increased class differences" (Interviewee 5). One interviewee explained: "The petroleum industry has led to, well, not exactly a snob factor, but money means more than before.… We still have our friends and visit each other but it has kind of become a bit 'colder.' People care more about status, [material] things and expensive cars. People talk about buying new snow scooters and where they are planning to travel. The petroleum industry has created an illusion that having much money is happiness. It was different before. Calmer" (Interviewee 15).

It was also mentioned that Hammerfest should have been better prepared for the consequences of petroleum development, as explained by Interviewee 14: "In the construction phase, 3000–4000 people came here from different places. There were many cases of drugs and violence. Statoil should have planned for this.… It was not good for the local community—a tough time." Other negative effects include less focus on developing other livelihoods: "Everything in the municipality caters for oil and gas business; large industrial areas are made available for the sector. Meanwhile, other sectors, such as tourism, do not have as powerful spokespersons, and do not get prioritized" (Interviewee 1).

Interviewees were often more reluctant about expressing negative opinions than positive ones. This may mean that negative opinions are controversial.

The interviews with the three with the most critical view of the petroleum industry provide a different snapshot; their opinions are not socially accepted and those expressing opposition to petroleum are often the subject of social sanctions. Perhaps what is stated as being what "the people" want is not always representative of all local views or even evidence of a nearly total consensus—not to mention views of "people" from outside the community in question.

Nevertheless, some petroleum supporters have been companies that are actively selling the benefits, rather than promoting a balanced discussion of the pros and cons. The lack of balance is further indicated by the hostility directed at outside opponents of petroleum. A narrative is built around the petroleum "adventure" and around boosting Hammerfest's self-confidence so that potential threats can be ignored and people with doubts silenced."

http://www.sciencedirect.com/science/article/pii/S2214629616300366

This resonates so much with what has been happening in B.C., and in Prince Rupert. The public consultations aren't really meaningful at all but a slick media presentation by gas salesmen that could care less what the impacts to local populations will be. Divide and conquer has been the main strategy of oil and gas companies around the globe, and the same is true here in this area. The divisive environment makes it especially hard for people to step forward and express concerns about their safety and their homes, as there is always a backlash from someone.

Another article had one interesting quote.

"The city's deputy mayor, Marianne Sivertsen Næss, remembers seeing fires at the site, and ash raining down on Hammerfest."

http://www.popsci.com/

This would definitely be an issue for the community of Dodge Cove, at 1/2 km away, and the city of Prince Rupert, at 3 km away, from the proposed site for Aurora LNG.

Disa Hovatta, Victoria

Dear EAO,

Please reject the Auroro LNG plant proposed for Digby Island.

This area provides critical habitat for steelhead, coho and sockeye salmon and migrating birds.

Concerns over the construction and eventual operation of the terminal are many. These include, but are not limited to:

- gas flaring (hazard to migrating birds)

- damage to wetlands and eelgrass habitat due to acidification

- tanker traffic risks (spills, collisions and noise impacts on marine species).

Further, the plant would pollute the pristine air, drinking water and soil of local communities. The 24/7 operation of the plant and infrastructure would result in significant noise, light and air pollution.

A 2015 survey showed that 96 per cent of Dodge Cove residents were opposed to the project.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. These First Nations rely on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage.

As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year, essentially negating climate change initiatives.

Sincerely,

Disa Hovatta, Victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

john pasqua, Escondido San Diego County

Dear EAO,

Sincerely,

john pasqua, Escondido San Diego County

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Craig Murray, Windsor

Dear EAO,

As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

Please don't allow this antiquated fossil fuel plant.

Sincerely,

Craig Murray, Windsor

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Karen Smith, Vancouver

Dear EAO,

Sincerely,

Karen Smith, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

March 4, 2017

Personal Information Withheld - Shawnigan Lake, British Columbia

No do NOT allow this to go forward. No & No again and again. It is wrong and the industry is already dead before it begins.

Personal Information Withheld - Prince Rupert, British Columbia

I support the Aurora LNG project. Recently, they held a community information session in Prince Rupert where I learned that most of the development will be 3-4km from Dodge Cove. I initially had concerns that the facility may be too close to the community for their comfort but this put my mind at ease. Also, there have been concerns expressed over its proximity to the airport. We really just have to look at the major airports around the world and their proximity to urban areas to understand that this isn't an issue.

From an environmental standpoint, I don`t buy into the fear tactics that many are spreading. LNG development stands to help decrease global pollution, and this project most certainly won`t harm the salmon. Many would like you to believe otherwise.

Welcome to Prince Rupert! Looking forward to seeing ground break.

Personal Information Withheld - Penticton, British Columbia

NO! NO! NO! TO LNG. The risk to the environment is just too great. If the plan is to build within the specified limit now - how can anyone believe in the event of a spill that corrective clean-up will happen?

Wendelin Gott - Victoria, British Columbia

Hello, I am opposed to the Aurora LNG Digby Island Project. This area is a sensitive wetlands and would affect the Skeena Salmon breeding, which would be a catastrophe for the fishing in the area. This is a inappropriate area for an LNG plant, as the future of the area needs to be considered environmentally,for tourism and fishing.

Wendy Poole - Comox, British Columbia

Growing up in Prince Rupert and area, I know how sensitive the area is. Where the LNG project is being planned for doesn't make sense geographically. The entrance to the harbour is narrow, not a place for dangerous materials to be processed and moved about.

This is another example of the intelligence of the people being ignored for the benefit of big business.

Why not be proactive, show leadership by looking beyond fossil fuels as energy, to sustainable energy. It's pure common sense, but doesn't fit the short term goals politicians perpetually focus on. We need to look at the greater good of ALL.

Agnes Watts - Vancouver, British Columbia

This is a terrible idea, from all aspects. It will do irreversible damage to the environment, both locally and globally, and irretrievable damage to salmon stocks, wild bird populations, and other wild populations in the area, all to prolong the use of fossil fuels, so that a few people in China and Canada can gain temporary wealth. Shame on them! Human greed will be our universal downfall.

Personal Information Withheld - Prince Rupert, British Columbia

This project needs to be moved! It will destroy our waters, it will kill entire species of wildlife, it will hinder tourism in Prince Rupert, it will increase pollution, it could cost every fisherman their livelihood. The cons list is endless. All for a probable 30 year stint. Then what? Who will be left to clean up the mess and destruction? My kids. Just has my generation has been paying for the old pulp mill, although I fear this would be at a greater magnitude. As much as the idea of job creation and money is great, its not everything. The cost is too high. Move this project east.

Personal Information Withheld - Dodge Cove, British Columbia

I have yet to see the following information regarding impacts on human health due to flaring, clearly stated in the Final Application for Aurora LNG.

These impacts would be of direct concern to residents in Dodge Cove, being 1/2 km away.

Also the lack of honesty in what critical illnesses that the residents in Dodge Cove would most likely experience, being so close to flaring, that even in the start up of the LNG terminal would take several weeks of 24/7 flaring, and then at any time other major releases of flaring whenever needed, as well as when ships are in (which is each day). Where has the impact to Dodge Cove health (such as leukemia?) been mentioned. I am amazed that our Canadian government would even possibly think about letting such a major industrial operation surround a community and let such health impacts be felt by Canadian citizens. In what Canadian first world country standards is this ok?

"3.2.2 Impacts of gas flaring
Communities have reported a range of illnesses associated with the pollution, including gastrointestinal problems, skin diseases, cancers and respiratory ailments. It is difficult to ascertain how many are specifically caused by the oil and gas industry as these are generally longterm illnesses. A 2001 scientific study of the adverse health effects of gas flaring in Canada lists various cancers, respiratory disease, heart disease, rheumatic disorders and eye problems (Argo 2001). EJP/ERA (2005) warn that gas flaring in Nigeria can cause leukemia among populations living close to the flares, citing supporting evidence from the US Environmental Protection Agency.They estimate that around 35,000 people live within a 1.3 km radius and 330,000 people within a 5 km radius of a flow station. Another study carried out in southeastern Nigeria showed evidence of acid rain due to gas flaring, which can contaminate waterbodies and soils (Akpan 2003)."

http://www.sierraclub.ca/national/oil-and-gas-exploration/soss-oil-and-gas-flaring.pdf

"To prepare for this support role we developed a broad understanding of the adverse impact of chronic exposure from multiple flaring discharges on the health of people who live and work in proximity to the industry. Proximity can be from 0.2 km up to 35+ km.

OBJECTIVE
It is our objective to convey the knowledge that the development of oil and gas comes with a terrible cost in human health. The cost is not for the workers on-site, though they are affected. It is to women and children, the aged and infirm, the teachers and doctors and pharmacists and priests and First Nations peoples who live away from but in proximity to a flare site. They live at home.

They are unprotected by Labor-code statutes about exposure because they live at home and are exposed where they sleep and eat as wind carries the plume of combustion products from the source to their residence Oil companies and the oil industry repeatedly tell us that there is no harm done by their activities, either to humans or livestock. They characterise their actions as responsible and benign, harmless to residents and with risks only to workers immediately affected. We expect Industry to tell this Hearing that no adverse human health effects are known and no adverse ecological effects are expected.

We will rebut their arguments and present flaring as a broad, multi-faceted disturbance of the system of human activities for as much as 30 km from any flare. We will use publicly available peer-reviewed scientific literature to present our rebuttal.

Discussing flaring in terms of single issues is like a painting in greys - lifeless. For a full appreciation of its long-term impact, flaring must be considered on several levels of adverse health effects. These include chronic diseases, viz. cancer, diabetes, heart disease etc.; issues associated with the constant presence of flaring manifested as stress and AI and chemical sensitivity; issues associated with the division of communities into camps, again usually manifested as stress."

http://www.europarl.europa.eu/RegData/etudes/etudes/join/2011/433768/EXPO-DEVE_ET(2011)433768_EN.pdf

image

Personal Information Withheld - Dodge Cove, British Columbia

I found a major difference between the measures used to predict community health for the local area, and what I would consider community health while living in Dodge Cove.

Measures that are being used in the AIR to predict community health are the following, many that do not even apply to us at all, since Dodge Cove has none of it. CNOOC-Nexen is using the figures for the LAA (prince rupert for sure, and possibly other surrounding communities) to describe conditions across the LAA. But conditions in Dodge Cove are not the same at all. The figures for the LAA in no way measure community health in Dodge Cove.

Crime - NONE
Human Economic Hardship
Health - (used to be great, stress is taking its toll) Education Children at Risk - NONE Youth at Risk - NONE Suicide Rates - NONE Self-Inflicted injuries- NONE HIV and other STD's - NONE Motor vehicle accidents - NONE Stress (We have lots now that the Aurora LNG export terminal is planned) Social cohesion and reduced conflict (Dodge Cove has in many ways had more conflict and less social cohesion thanks to the massive amounts of stress residents are now under) Income

When I talked to another resident about what our measures of community health would be, they mentioned a very simple but accurate measure of "whether people are happy".

I thought of things such as "can kids play safely on the beach at Marine Bay?" Is it safe for children to play outside on their own, walk around the community on their own, ride bikes around the community on their own?

Do we know all our neighbours and stop and talk to them on the road/trail/dock, do people help each other and watch out for each other?

Can we enjoy being outdoors, in our yard or on trails, can we hear natural sounds, the animals and birds, can we interact with the animals and birds, can we harvest our traditional foods where we traditionally harvest.

Do we need to have stressful meetings all the time to deal with outside pressures and influences, or can we just enjoy interacting with our neighbours in a stress-free manner including social and spiritual gatherings.

Are long-term residents moving away?

Can we sleep at night? Stress/noise levels.

Do we have privacy? Quiet? Access to traditional lands/waters that we have always had?

Can small businesses operate as they have always done?

Will other families move here to live full-time? Will similar minded people wish to live in this community? Will people be able to purchase homes and live here in a healthy manner?

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Lolree - Prince Rupert, British Columbia

Disgusting display of future poisoning of our people . This is not an area to have an lng plant or any lng plant . we do not want fracking methane dredging poisoning of our water lands or air . Too close to the populated areas . way to close to prince Rupert digby island and port Edward , who in their right mind decided it was okay to put children and families at risk , who decided it is okay to destroy our salmon , the very essence of life is water . get out of BC and stay out of BC and stay way from the north coast .. Very concerned about the total destruction of a very sensitive eco system such as ours ..

Kimberly Lowe, Gahanna

Dear EAO,

no to aurora ling. absolutely - no.

Sincerely,

Kimberly Lowe, Gahanna

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

rebecca koo, san diego

Dear EAO,

Sincerely,

rebecca koo, san diego

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Charlotte Snowsell, VICTORIA

Dear EAO,

,It seems the Liberal Party of BC are bent on destroying everything!. The great" hard hat group" continues to forge ahead projects, without regard to the historical values, environmental, wild life and human impact .... all for those votes and money. Keep Asia happy ... our county is for sale at all costs.

Aside from all these mentioned issues ,now, without regard for the salmon historical habitat and runs . Salmon are an irreplaceable food source for all and critical for the wildlife living on the land. Without touching anything the success is always in jeopardy. Everything depends on the balances in nature . It's a miracle to behold.

Who are these experts, that think they can play Masters of the universe? I am so discouraged to see such utter disregard .in my life time. I worry for our grandchildren .

Haven't we just gone through a lot of these concerns with the Petronas project. A disaster in the making!! So upsetting... our beautiful and bountiful Skeena River waiting to be ruined and polluted. We are still not sure of that. Tankers will be just as problematic with this fiasco. The seas are rough , storms frequent, congestion apparent right now Whose checking on double hulled carriers??Where are the cleanup crews? Never should we forget Valdez ( Maybe oil but still a disaster of unprecedented magnitude ( that we know about) Sorry will never be good enough !! Bittumin?.....LNG ? leave the river alone. Spare the wonderful neighbours of Prince Rupert and environs this dreadful conquest of their lives and homes!!

Please do something.

Sincerely,

Charlotte Snowsell, VICTORIA

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Rosemary Hartley, Nipigon

Dear EAO,

There is no recognition as to what nature can provide us in the longer term. Destruction of natural resources to access limited non-renewable resources leads us to a path where we will have nothing.

Plans should be in place to promote sustainable communities and how to make communities sustainable, not how to provide a profit for a few, for a short period of time.

Sincerely,

Rosemary Hartley, Nipigon

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Elizabeth Keenan, Toronto

Dear EAO,

Sincerely,

Elizabeth Keenan, Toronto

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Wendelin Gott, Victoria

Dear EAO,

I am opposed whole heartedly to the building of the Aurora LNG plant in the Prince Rupert/Digby Island area. This is an area that needs protection from pollution as it is a precious wetlands area and the Skeena Salmon use it in the continuing of their species population. This is not a viable project for this area and must not be built.

Sincerely,

Wendelin Gott, Victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

anthony montapert, ventura

Dear EAO,

Sincerely,

anthony montapert, ventura

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Elaine Becker, Roanoke

Dear EAO,

Big Oil is going the way of the dinosaurs - don't let them drag us all with them!

Please help save species, including Humans, from the ravages of tracking.Say NO to Aurora LNG.

Sincerely,

Elaine Becker, Roanoke

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

tom harris, bordentown

Dear EAO,

Sincerely,

tom harris, bordentown

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Jana Ronne, Vancouver

Dear EAO,

I want to express my opposition to the Aurora LNG plant.

The Digby Island area provides critical habitat for steelhead, coho and sockeye salmon and Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. The proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes.

Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

The plant would also pollute the pristine air, drinking water and soil of local communities. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

This project would also smash through BC's legislated climate targets and blow our carbon budget.

Sincerely,

Jana Ronne, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Agnes Watts, Vancouver

Dear EAO,

We can't have it both ways. We can't say we believe in saving the environment and meeting our Paris Accord commitments while simultaneously allowing a Chinese fossil fuel company to rape our environment and create vast amounts of carbon pollution, to feed their monstrous industrial requirements. LNG is no better than dirty coal, when all aspects of development and production are factored in. In this case the damage to the pristine environment of the north would be permanently devastating. China already has huge wastelands, thanks to industrialization. We must not let them do the same thing to our country. This plant is a terrible idea. It will create short-term wealth for a tiny amount of people, in exchange for the destruction of some of our most precious natural environment. That's no bargain and we must say no.

Sincerely,

Agnes Watts, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

marc schoenberg, farmington hills

Dear EAO,

Sincerely,

marc schoenberg, farmington hills

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ben Murray, Edmonton

Dear EAO,

NO to the Aurora LNG!!

This ill-considered project will jeopardize the health of Skeena Estuary's salmon population, not to mention the community of nearby Dodge Cove.

Do the right thing, and kill this project before it gets off the ground

Sincerely,

Ben Murray, Edmonton

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

J Churcher, Vancouver

Dear EAO,

Please say no to Aurora LNG.

In addition to aggravating the serious global climate crisis with which we are faced, this project will further imperil steelhead, coho, and sockeye salmon (already under threat), birds and wildlife at all levels of the ecosystem that depend on the nearby ancient muskeg estuary, and subject nearby residents, who cherish the natural world they've chosen to live within to all manner of pollution.

I am also extremely concerned about the risks involved with tankers navigating the narrow channel of Prince Rupert which is subject to strong tidal currents and severe storms (increasingly severe due to global warming).

In addition, the project flies in the face of indigenous priorities and wishes. When will this government recognize the rights of our first nations and cease from raping them of their rights and natural heritage?

My comments are cursory. I trust you are well aware of the details of all of the points I have raised and will respond to the growing tide of people around the world the value the health of our ecosystems ahead of fossil fuel development and the interests of business.

Sincerely,

J Churcher, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Rosemary Partridge, Saltspring Island

Dear EAO,

We must stop behaving as though we are the only life forms on the planet!,

Surely one of the most beautiful places and habitats on the planet is worth preserving.

Sincerely,

Rosemary Partridge, Saltspring Island

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kenneth Schadt, Vancouver

Dear EAO,

Aurora LNG is a massive fracked gas plant being proposed by Nexen, which is owned by Chinese oil giant CNOOC.

It would be built near Prince Rupert on Digby Island, just north of the Skeena estuary where up to a billion young salmon make their way to the ocean each year. The nearby community of Dodge Cove is at risk of becoming surrounded by a dangerous industrial zone.

... this carbon bomb must be stopped.

Sincerely,

Kenneth Schadt, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Jane Davidson, Englewood

Dear EAO,

Please stop dangerous industry from destroying our precious nature and wildlife. We must act against climate change and preserve what wilderness remains. This is our only hope for a good quality of life for ourselves and our children of the future..

Thank you.

Sincerely,

Jane Davidson, Englewood

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Claude Robert, Shefford

Dear EAO,

Sincerely,

Claude Robert, Shefford

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ray James Bradbury, WEST VANCOUVER

Dear EAO,

Please reject this horrendous and damaging Aurora LNG which proposal only harms British Columbia and its people.Leave this gas in the ground.

Sincerely,

Ray James Bradbury, WEST VANCOUVER

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Lee Fister, Allentown

Dear EAO,

Save all of nature in the name of Jesus!! don't kill but let live!!

Sincerely,

Lee Fister, Allentown

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Terrie Williams, Vidor

Dear EAO,

AURORA LNG THREATENS SALMON AND WILDLIFE
The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.

Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

AURORA LNG THREATENS COMMUNITY HEALTH AND SAFETY
The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of Dodge Cove residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

AURORA LNG THREATENS OUR CLIMATE
As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

Please, stop this carbon bomb and save our salmon.

Sincerely,

Terrie Williams, Vidor

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

isaqbelle boisgard, st-raymond

Dear EAO,

Sincerely,

isaqbelle boisgard, st-raymond

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Dear EAO,

Sincerely,

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ellen Koivisto, San Francisco

Dear EAO,

Fracked gas plants do not make good neighbors. They are toxic to wildlife, toxic to plants, toxic to people. No on the Aurora LNG near Prince Rupert on Digby Island. Save life.

Sincerely,

Ellen Koivisto, San Francisco

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

doug krause, winnipeg

Dear EAO,

Aurora LNG is a massive fracked gas plant being proposed by Nexen, which is owned by Chinese oil giant CNOOC.

It would be built near Prince Rupert on Digby Island, just north of the Skeena estuary where up to a billion young salmon make their way to the ocean each year. The nearby community of Dodge Cove is at risk of becoming surrounded by a dangerous industrial zone.

This carbon bomb must be stopped. Stand up for the Skeena wild salmon and the northern economy. They need your support.

STOP this from being developed. Please.

Sincerely,

doug krause, winnipeg

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

March 3, 2017

Personal Information Withheld - Dodge Cove, British Columbia

Below is a compilation of concerns and effects that were sent to the Ministry of Forests, Lands, and Natural Resources when CNOOC-Nexen applied for an Investigative Use Licence to drill across Digby Island.

There was absolutely no response from the MFLNR about these concerns before they approved the IUL licence, and I think it is valid to re-submit these concerns to the BCEAO, as many are still appropriate except on a much wider and more serious scale if the Aurora LNG project was to get approved.

Many of the concerns that were listed here did become a fact as Nexen helicopters disturbed both wildlife and residents throughout most of the past year. We have seen direct changes in wildlife patterns, direct changes to use of the island by both residents and visitors, and consistent helicopter traffic disrupting the Dodge Cove green space and use of those areas by residents, as well as constantly irritating residents in their homes with windows closed, as well as outside, including right overtop the community at times, inside the Dodge Cove OCP, and right above and behind our homes.

The stress of the ongoing activity, noise levels, and trying to engage in the EA process at the same time as trying to process what the hell we are going to do if this project gets approved, and the fact that everything we have invested in and built might be completely uninhabitable, has been a depressing and mentally anguishing process.

The fact that everybody we love around us will be affected and are going through the same stress and concern for the future is also very heartbreaking.

Impacts to Dodge Cove and Dodge Cove Residents

Impact to food gathering and hunting lands.
These drill sites are all over, and will have a direct impact to areas that are presently used for gathering many different kinds of food, and for hunting. The clearing sites will brush cut all berry bushes, and remove habitat for animals and birds, and remove plants of special concern as well as affect amphibians.The noise and traffic will disturb all the birds and animals that live and migrate here.

(Pages of animals, amphibians, and birds are identified as living on Digby Island and using Digby Island as migratory habitat. Many are identified as species at risk on the lists SARA, COSEWIC, and are provincially red and blue listed.)

Disturbance to wildlife.
Vegetation clearing can potentially destroy bird and amphibian eggs (many of which are species that are threatened or of special concern) and the offspring of mammals, birds and amphibians. Noise and construction activities that are adjacent to habitats can cause adult birds to abandon their nests, increasing mortality to eggs and young (exposure to cold and predators). Citizens of Dodge Cove have already been concerned about the impact that Nexen has already had on the species at risk, this increase in activity is unacceptable.

Water use.
The water use for the drilling is of concern. Where the water is being removed from is a concern. Impacts could be drastic on our watershed, salmon creeks, and other amphibians and wildlife that live on the island. Stream crossings are mentioned, this could destroy existing salmon habitat.

Base Line Studies.
Base line studies for the entire project (needed by the EAO to assess the impacts that this would have) must be done before the increased helicopter traffic and human traffic on this island. Have base line studies already been done?
And how were they completed - as there already has been a direct impact to the island and Dodge Cove residents in the last year from Nexen-CNOOC investigative work. It's not a base line if helicopters and people have already changed existing impact levels.

"Nexen does not anticipate any socio-community impacts resulting from the activities".
Dodge Cove is not even listed in the IUL application. Besides the many full-time residents who live here, there are also many part-time residents who it will also affect. Mental health, stress, and overall community health are serious concerns. Nexen says " "The helicopters, drilling rigs and clearcutting "brush clearing" will result in noise, dust, and emissions." These impacts will be significant to the residents of Dodge Cove and to tourists.

Proximity to Dodge Cove.
This is of major concern, as drill sites surround us and come within 0.5 km of our homes, so the traffic and impacts to our stress and health are very real concerns. The actual footprint of the Investigative Use Licence crosses over into our community green space, and we have already been dealing with the effects of that. At least once a helicopter has landed in our green space, to pick up employees that were in our green space, and disturbing residents of Dodge Cove.

Drilling in the watershed and how that will affect our water supply.
What bond does the company put against that in case it does affect the water supply. How will the dust and emissions from drilling affect our water quality? How will it affect existing water routes?

Visual Quality.
Hundreds of tourists each year use the hiking trails on this island, as well as the local residents.
These drill sites will damage the trails and create an unfriendly tourist environment. There are several areas of heritage landmarks that people hike to, and while these drill sites may be to the side of these landmarks, it will still have a direct impact on the visual quality of these places.

Dodge Cove and Digby Island has hundreds of visitors every year: friends, family, tourists, hikers, kayakers, campers, whale watchers, sportsfishermen, commercial fishermen, sailboats that live here for months on end. Dodge Cove has annual events that the wider community enjoy. Previous residents of Dodge Cove still come back for reunions and other events, such as weddings.

Dodge Cove has had sportsfishing lodges for the last decade, and those tourists enjoy the rest of the island (hiking) as well. Dodge Cove has houses rented out periodically to visitors who come here to enjoy the island, and the wildlife.

Many of these concerns impact present land use by the community and for tourism, as well as future land use. Marketable timber is larger trees, while "unmarketable" timber like the muskeg pines may be small and twisted, but often are 300 plus years old. Nexen has applied for 2500 cubic metres of timber (just marketable?) and if the average size tree is 2' across and 45' tall, then that would be 833 trees approximately. Or 533 average large trees, and 1000 muskeg pine trees. The residents of Dodge Cove have purposefully kept a low impact on Digby Island, this amount of trees to be clearcut and discarded is unacceptable. Mature and old forest that is removed can take more than 600 years to go back to pre-impacted conditions.

Personal Information Withheld - Dodge Cove, British Columbia

I don't feel that CNOOC-Nexen has looked at all these impacts that Aurora LNG could have on local populations such as residents of Dodge Cove, Crippen Cove, and Prince Rupert in the case of a major accident scenario. These concerns need to be looked at, and how the local populations could be majorly impacted by other health and property damage if a major accident occurred (if these populations were not completely killed by the accident).

"Main types of major accident scenarios:
Explosion - Levels of blast overpressure which may be harmful to humans and animals and damage buildings. Projectiles travelling at high speeds may also spread from the explosion presenting a risk to people, animals and damage buildings. Explosions may also initiate fires.

Fire - Ranges from an intense fire lasting several seconds to large fires lasting several minutes or hours. Potential for fire damage to people and the environment and fires may spread to other areas, a drifting cloud of flammable gas may ignite. Fires may generate smoke clouds which may lead to breathing difficulties and deposition of soot on property and vegetation.

Release of extremely cold liquids

The potential consequences of major accident hazards Potential consequences on Human Health:

Breathing air with high concentrations of gases other than oxygen can lead to asphyxiation and/or poisoning, which could result in unconsciousness Direct contact with liquefied gases has the potential to cause frostbite or cold burns and severe damage to eyes Injuries (possibly fatal) caused by flying debris etc. being ejected from the incident site.

Injuries caused by fragments etc. being ejected from the incident site Injuries from being blown over by blast pressure Potential for burns to body (possibly life threatening) Risk of eardrum damage from blast Traumatic injuries are possible due to being hit by flying fragments and objects Potential consequences on the Environment:

Physical damage to and contamination of unlisted buildings and offsite such as houses"

These are excerpts from the public information about Dragon LNG on the Health and Safety Executives website; http://www.hse.gov.uk/comah/comah-establishments.htm

Personal Information Withheld - Dodge Cove, British Columbia

Section 9 Accidents or Malfunction

The Final Comprehensive Study Report for Goldboro LNG in Nova Scotia, Canada, from October 2007, was a lot more up front about many of the impacts that any accidents or malfunctions could have.

When assessing spills, "LNG could have possible freezing effects", yet Aurora LNG does not address LNG freezing effects and impact to local vegetation, wildlife, humans if an onshore spill was to happen. Goldboro included sections about effects on SPECIES AT RISK, and how any accidents or malfunctions would affect those species, as well as assessing impact to wildlife/habitat, marine mammals, and fish/fish habitat. I fail to see that anywhere in section 9 for Aurora LNG. (I am also going to point out that the closest species at risk was approximately 10 km away from the proposed facility - where Aurora LNG will actually be built right on top of many species of risk, killing many species that have been highlighted by both the Federal government and Provincial government to need protection).

Aurora assuming that spills could be easily cleaned up, and not have a drastic impact to the marine environment, is laughable. Depending on the type of material, and our drastically changing weather conditions, extreme tides and storms, any cleanup may be next to impossible. Judging a large scale spill as only having a "moderate" residual effect impact seems also laughable.

"Federal Transportation Minister Marc Garneau says the sinking of the tugboat Nathan E. Stewart shows that oil spill response resources on Canada's West Coast are inadequate. "http://www.theglobeandmail.com/news/british-columbia/tug-sinking-shows-oil-spill-response-resources-inadequate-transport-minister/article32694781/

Has impacts such as avoidance of the habitat and disruption of feeding and migration patterns of marine mammals/fish/birds/wildlife been studied and assessed?

Goldboro is clear that an LNG spill could result in asphyxiation (oxygen deficiency) of marine mammals - nowhere do I see that clearly outlined in Aurora LNG's report.

Again, Goldboro "wildlife that may come into direct contact with LNG may be affected by freezing effects" and "an LNG release to the marine environment could result in direct bird mortality. As LNG is a cryogenic liquid at -161 degrees celius, the extreme low temperature could result in severe freezing on contact if birds remained on the water" in that area. It goes on to describe more, similar descriptions that are direct about the immediate potential effects, and residual effects, I fail to see in the Aurora LNG application. Again, it talks about freezing people on contact, or asphyxiation, I do not see this in the Aurora LNG application.

Aurora claims that a spill may temporarily delay marine traffic but is expected to be reversible within one month or less. Marine traffic in and out of Prince Rupert harbour, how much disruption, inconvenience, and taxpayer dollars would such an event cost the local and provincial residents? How many existing businesses in Prince Rupert would be disrupted by this, and what impact to existing economy? I do not see any estimates.

Why does Aurora LNG say that worker health is beyond the scope of the assessment? That seems strange. Impacts of accidents on workers should be assessed as well.

In "facility impact from aircraft" Aurora LNG fails to identify the very real problem that airplanes have with flaring plumes, and how the change in air above flaring can make a plane fall out of the sky.

On shore fires and explosions - Aurora constantly mentions impacts to the LAA without focusing on the fact that the community of Dodge Cove is on Digby Island, I fail to see any accurate descriptions of the impact to Dodge Cove in case of many accident and malfunction scenarios, including on shore fires and explosions.

Goldboro says "local air quality conditions associated with the fire and the flames have the potential to kill humans and wildlife in the area. The major emissions would be smoke (PM) and CO2 but would also include CO, NOX, SO2, VOCs and PAHs (polycyclic aromatic hydrocarbons). A large fire could create PM levels greater than the ambient air quality standard over distances greater than 10 km" yet the Aurora LNG application says that people should avoid exposure to smoke and particulates by remaining indoors and closing windows (would this really help the residents of Dodge Cove asssuming we were not killed already by fire/explosion?) and even Prince Rupert is only 3 km away and could be drastically affected. This assessment fails to accurately describe affects and residual effects of a fire or explosions. There seems to be no accurate reflection of health impacts that could result from exposure to smoke.

Proof that LNG accidents happen:

In 2014, the explosions at an LNG facility in Washington had much impact. The closest town 2 miles away and surrounding communities had to evacuate, workers were injured, it caused $69 million in damages, shut down traffic on the nearby Columbia River, on the highway and damaged the railway. According to news articles it released LNG vapor clouds into nearby residential areas, and fumes from the facility sickened residents, emergency responders, and endangered the public.

http://www.sightline.org/2016/06/03/williams-companies-failed-to-protect-employees-in-plymouth-lng-explosion/

http://www.sightline.org/2016/02/08/how-industry-and-regulators-kept-public-in-the-dark-after-2014-lng-explosion-in-washington/

Personal Information Withheld - Port Edward, British Columbia

I am concerned about the proximity to the local population and the surrounding wildlife. Our local lands need protecting for future generations..

I understand the need for the industry as we are not ready to to use renewable resources solely yet. But what is plan to get us off the resources? How will LNG help with that? How will LNG help the local wildlife and population?

Personal Information Withheld - Gabriola Island, British Columbia

A plant shoud be built no closer than 3.5 kms from a populated area. Dodge Cove is obviously right beside the plant and the people there will lose everything. They are not the only ones who will be affected. The City of Prince Rupert is within a 3 km radius!

Personal Information Withheld - Prince Rupert, British Columbia

I am extremely concerned about an LNG plant being so close to the city of Prince Rupert. Regulations state that a plant can be no closer than 3.5 kms from a populated area, and Prince Rupert is 3 kms from the proposed site. The air quality will be severely impacted by a plant this close to the city. I have concerns about LNG tanker traffic in an area with severe weather such as we have. The people of Dodge Cove, which is directly beside the proposed site, will lose everything. They will no longer be able to live in their homes. We are in Canada! This sort of thing should not happen in a country like Canada! My concerns for the my health and the health of my family would most likely necessitate a move away if this plant were to happen. This is the wrong site for an LNG plant. Please, please find a different site farther away from populated areas!

Personal Information Withheld - Vancouver, British Columbia

Given that the ____ standard for distance a facility should be located from a community is 3.5km, how can the project go forward when the nearest community is closer than this distance? Such a facility should not be put in place at closer than the recommended distance, particularly given recent precedent of major natural gas leaks in frozen winter waters that have not been able to be contained or halted. Lacking any regulations to ensure the safety of a community in the case of a gas leak even at further than the recommended distance, the project appears too risky to be advanced. Given the high number of vulnerable and threatened species that make their home on the project site, I believe before going forward the project should be able to provide evidence from environmental studies that there is no risk to those species (or to the nearby community). I am unaware of any such research that can be used to defend the position that these species would not be put at risk.

In my own life, I am familiar with a yearly ethics review process to prove that a given research project does not put vulnerable populations at risk. The infinitely larger scope of this operation suggests that it should be subject to equal if not greater scrutiny, to proactively demonstrate that no harm will come to those communities and species in the immediate impact zone of the facility. Without such scrutiny, the project is an obvious threat to the safety of both human lives and vulnerable species. The onus is on the project developers to show a higher standard of evidence that the reduced distance from the threatened community and species will not result in irreparable harm. I suggest that the project not move forward until such evidence can be provided.

Max Kurz - Terrace, British Columbia

I think the Aurora LNG location on Digby Island is way too close to the population and should be permanently shelved.

William McDuff - Prince Rupert, British Columbia

The proposed development is only a kilometer and a half of a community that was formed specifically because it was further away from the development of Prince Rupert. There are better locations for this project.

Shane Deinstadt -Prince Rupert, British Columbia

I fully support the development of a facility on Digby Island.

This location is ideal for development as it is located some distance away from Prince Rupert, would have little or no impact on the Prince Rupert Airport and future expansion

Canada is blessed with tremendous natural resources which need to be sent to market in order for Canadians to continue to enjoy the standard of living we have all become accustomed too.

Personal Information Withheld - Smithers, British Columbia

PLEASE DO NOT GO AHEAD WITH THIS LNG PROJECT!! IT WOULD JEPORDIZE SOO MUCH. PLEASE LISTEN -STOP- THINK- DON'T DO THIS!!!

March 2, 2017

Personal Information Withheld - Alberta

No to Aurora. It is dangerous to the local environment and population and life on Earth in general.

We are tired of seeing wreckless unnecessary industrial development.

kevin Blackman - Prince Rupert, British Columbia

Fantastic project with minimal impact if any to residents in the region. We need this project to help the area develop and become self reliant with a clean energy project.

Personal Information Withheld - Squamish, British Columbia

Stop expansion of oil and gas. Support expansion of renewables. Our natural BC environment is the most precious thing we have.

Stop destroying it NOW.

Personal Information Withheld - Shawnigan Lake, British Columbia

I say NO to LNG anywhere period. The communities and environments affected can't be expected to accept 100% of the risk so that the LNG corporations can make a quick and very profitable, low risk buck! It's time to think of sustainable energy models like, wind, solar, geothermal and keep fossil fuels in the ground!

Personal Information Withheld - Dodge Cove, British Columbia

In the original AIR that was being studied by the working group, and on all the maps at the Public open houses, and maps distributed by CNOOC-Nexen in pamphlets and brochures, and online, Dodge Cove and Dodge Cove's OCP were not accurately shown.

This is a form of falsifying information, when maps are being distributed and the one community that will be the MOST IMPACTED by the CNOOC-Nexen Aurora LNG project is not being shown. It skews the information to look like no community is very close to the proposed project, and on just looking at the maps, a person would quickly assume that Prince Rupert would be the closest community, followed by Metlakatla.

Since this was also often the case at "public consultation" open houses, if the information shown to the public DOES NOT include Dodge Cove, then how would the public understand the project and comment on any concerns related to proximity to an existing community, and health concerns?

The majority of the maps shown at open houses DID NOT show Dodge Cove on Digby Island.

Therefore no TRUE public consultation through open houses has happened.

Some of the maps in the Final Application have been modified to include Dodge Cove, but many still do not show Dodge Cove. Also even if Dodge Cove has been added,most do not show the Dodge Cove OCP and the overlap that the project would have into the Dodge Cove watershed.

With this in mind, the working group and anyone else studying the AIR, and original application previous to the final application, and all the people looking at maps at public open houses, would have been given falsified information.

How is this informing the public and consulting with the public/and working group members?

It is ridiculous to wipe an over 100 year old community off the maps to present to the public a pretty picture of where Aurora LNG wants to build.

Personal Information Withheld - Dodge Cove, British Columbia

In the U.S., in terms of safety LNG terminals/tankers need to be safe seperation distances "to protect the public, states' concerns include provision of adequate fire and medical emergency services (such as burn centres), whether in rural or populated areas.

I am concerned that the safe seperation distance and also provision of adequate fire and medical emergency services does not exist with Aurora LNG proposal.

I am concerned that proper studies have not been done on "potential domino effects on nearby facilities". If an accident was to take place at the Aurora LNG location, domino effects studied would have to include, all 4 trains, all 3 tankers, Ridley Coal and Grain terminals, PNW LNG terminal and tankers, and any other possibilities such as any Freighters with fuel travelling past (or cruise ships/ferries etc). Only then would we see the true potential effects on a worst-case scenario, and how that would effect Dodge Cove and Prince Rupert, also surrounding communities such as Port Edward. And the same would be if an accident was to occur at one of these other facilites, how would that create a domino effect to include Aurora LNG berths and trains.

Potential accidents that need to be included in study would also be the crash of aircraft into a storage tank. This is usually attributed to terrorist action, which does need to be a concern, but especially on Digby Island with the proposed Aurora LNG terminal at the foot of an airport that has several flights a day, and then drastic proposed increase in air traffic to transport workers to the island, this would increase the risk substantially! Any accident of this kind would effect Dodge Cove and Prince Rupert. I am concerned that this has not been fully studied, and again worst case scenario needs to be looked at. Even if it is not likely to happen, the outcome would be enormous.

"There is no reason to believe that introduction of "measures of risk" without supportable quantification may contribute to the contentiousness surrounding the determination of safe seperation distances" "The QRA model identified uncertainties in determining appropriate dispersion seperation distances, recognizing that NO LARGE-SCALE VALIDATION TEST RESULTS WERE AVAILABLE." studies based on Sandia report SAND 2004-6258 suggests that overpressures will arise only when a cloud is confined and obstacles to a propagating flame are present, for explosion effects associated with delayed ignition (vapor cloud explosion), yet the explosion of a cloud of light hydrocarbons such as butane in December 2005 at the Buncefield, U.K., tank farm - IN AN OPEN SPACE!

I have concerns that proper tests on LNG are unavailable, and lack of knowledge of the ACTUAL actions of this gas in relation to REAL situations is unavailable, and that these TESTS NEED TO BE DONE before putting an LNG terminal so close to people. Is the LNG industry scared to have these tests performed, since the results would not work in their favour?

Buncefield - in which a few thousand people had to evacuate and smoke was in a 10 MILE RADIUS, it was pure luck that close businesses were shut for the night or everyone would have died in the the BIGGEST PEACE TIME EXPLOSION in the UK, and originally the siting was further from residential areas but later pressure included encroaching proximity.

If there was an accident, where there was a fire and "explosion", if the initial leak, fire, and blast did not effect residents of Dodge Cove and Prince Rupert, how would the smoke? Wind predominantly blowing in our direction most of the year, the smoke would fill our communities quickly and settle in Prince Rupert Harbour, and how would this effect evacuation routes/plans. Most smoke stays low-lying in the harbour, because of rain. How would this effect everyones health in evacuating, breathing in this smoke while trying to leave? Our health would be severely compromised by any release of smoke and the after-effects could compromise our livelihood as well.

I am concerned that Canada does not have any Federal regulations regarding the siting of LNG facilities, but seem to be looking at each case on its own, instead of putting in standard regulatory framework as a base guideline first, and then looking at each case on top of that. I am concerned that in this case, the Provincial government is assessing this potential LNG terminal instead of the Federal government, and yet if there was an "accident" it would directly affect other Federally regulated sites such as Ridley terminals and the Container Port.

The U.S. has a regulation that says "safe seperation distances between the facility and the public sufficient to keep the latter out of harms way", based on a "pool fire" ignition, or a "vapour cloud fire" this is why they made two types of hazard zones, FROM WHICH THE PUBLIC IS FORBIDDEN, or "exclusion zones'. The vapour cloud exclusion zone, the maximum distance for a spill and resulting gas evaporation and forming a cloud that drifts downwind until it ignites, includes OUR COMMUNITY and also the Container Port, Prince Rupert Waterfront, and Prince Rupert.

A vapour cloud could definitely find an ignition source within our community, as any spark (even of static electricity!) could set it off, and definitely also could happen from the container port. I am concerned that this would happen.

These studies were based on a spill of an operating line that could be shut off in 10 minutes or less. There is NO guarantee that a spill would be 1) from an operating line and 2) shut off in 10 min or less.

I am concerned that the actual vapour cloud could be much larger. In 2000, in the US they changed it to the "single accidental leakage source" but also only looked at primarily pipe ruptures whether larger or small diameter. What about other ruptures??? not just pipes can fail - so if the vapour cloud and resulting exlusion zones could actually be much larger, I am concerned that this has not been assessed/studied, and indiscrepancies of the "design spill" model don't apply to actual REAL possibilities.

The assessment methodology of LNG was further criticized that for "the scientific basis, especially for pool spreading, is quite unphysical." And "the cloud formed in a dike should not disperse or dilute at all until the pure vapour has accumulated in the dike to the level of top of the wall is unphysical and is likely to lead to very optimistic (non-conservative) hazard predictions." I am concerned that it is flawed scientific studies such as these that are the basis for LNG terminal hazard predictions, and I am concerned that these flawed studies are leading CNOOC-Nexen to believe that Digby Island will be suitable for placing an LNG terminal, even though Dodge Cove is much to close.

I am concerned about all the discrepancies pointed out on fire radiation exclusion zones, are studies such as these that are shown by top industry scientists to be flawed, are also the basis of CNOOC-Nexen fire safety. Are fire studies done based on the liquid level in each storage tank - that could be 35 m? Are the studies done for a fire with the full containment tank diameter of approx 85 m? Are fire studies done with tank fires at all, or only with spills and ignition on ground? Are fire exclusion zones based on these studies about tank fires, or on ignition on ground?

Such a tank fire, if burning on top, and suffering a roof collapse, COULD NOT BE EXTINGUISHED and would have to BURN ITSELF OUT, a process that could require TENS OF HOURS. How would this effect surrounding communities, evacuation plans, etc. What kind of manpower would be required in case of such a situation, and would that manpower be available. And what if such a fire created a domino effect with the other tanks?

Is there any data on pool fires larger than 20m diameter on water and 35m diameter on land? Much larger fires are considered possible from LNG ship releases. "Important uncertainty exists in the accurate quantification of the fluxes that would be experienced from the surface of such large fires". Does CNOOC-Nexen base all fire info on small controlled fires that have been tested, which allows for much lower safety zones? How would a larger fire change emergency services, and affect surrounding communities?

Sandia's analyses indicate a fire following rapid release of 1/2 of one "typical" MOSS tank (MOSS ships carry LNG in 4 or more alum spheres) through a 5 sq.m hole onto water could expose people to 2nd degree burns approx 1 mile from the center of the fire, and vapour dispersion distances for a spill that size but not ignited are 2-3 miles. Dodge Cove is only 250-500 m close at the closest point of the project, and approx 2 miles from the furthest distance of the project, so these numbers are very concerning. As well, this does not take into potential for cascading events, what if more that 1/2 a tank was released, what if a vapour cloud ignited and burned back to further damage the ship, what if the storage tanks were also compromised. The LNG industry seems to have done very limited studies on the actual effects that these scenarios would have. Ship size has increased, and increases in distances were by approx 10%, which means Dodge Cove could be engulfed by a vapour cloud of a release of LNG of 1/2 of a tank or more. LNG ships can have brittle fracture of structural steel due to contact with LNG and also insulation failure due to fire exposure, as the foam melts, causing cascading effects in the case of an accident, which could easily result in much larger accidents that ones studied by Sandia laboratories. Sandia seems to be the only laboratory to have performed any studies on LNG, and yet the scenarios studied are very limited.

Dodge Cove residents being overlapped by this giant industrial terminal that plans to store and ship immense quantities of fuel that has the potential to kill us, are supposed to believe ON TRUST ALONE that CNOOC-Nexen Aurora LNG will be able to GUESS at the outcome of all these other potential accidents that could occur and prevent them from happening. Locations are not supposed to be close to communities, so that if an LNG spill does happen, we will be safe.

image fire

Personal Information Withheld - Prince Rupert, British Columbia

Absolutely irresponsible for this to be located in such close proximity to our town.

Personal Information Withheld - Prince Rupert, British Columbia

Ridiculous to even think of putting such a project at the mouth of our harbour and that close to the airport.

Vicki Harper - Smithers, British Columbia

No community wants the LNG terminal site to be in their backyard. LNG is to risky of a proposal.

Personal Information Withheld - Hagensborg, British Columbia

It is time to move onto renewable energy sources, not expand LNG or fossil fuels. The oceans, the animals and our food and the people are much more important that this pipeline. Be brave. Make the moral choice for the environment.

Personal Information Withheld - Salt Spring Island, British Columbia

Please take responsibilities of the territory that you have been given the honour of stewardship. The entire world depends on the health of our environment, making the proposal of expanding the fossil fuel industry groundless. These words come from an 18yr old female student, and they Strongly suggest that you consider them; the parties that condone irresponsibilities, like what is being demonstrated by leading bodies presently, will be dismantled and frowned upon in the near future. The culture of fossil fuels is coming to an end and as a citizen with a widely shared viewpoint, the groups that support that culture will also be disrespected. Similar to how the general social opinion of the culture of slavery is presently seen. So please, consider even just my generation.

L Halme - Vancouver Island, British Columbia

I am not in favour of this proposal. The spoilage of the pristine island and surrounding ocean is unacceptable as is the threat of a catastrophic event.Not only that but the fracking is too risky for our clean water supply and there seems to be too much LNG on the market worldwide.

Ron Rankin - Port Coquitlam, British Columbia

Should never be allowed. This company should be looking looking for a greener way. Save the planet.

Personal Information Withheld - Vancouver, British Columbia

I cannot for the life of me, figure how this project even got off the drawing board with the reality of this Government issued report from the early 70s http://lnginnorthernbc.ca/images/uploads/documents/A%20biological%20Assessment%20of%20Fish%20Utilization%20of%20the%20Skeena%20River%20Estuary.pdf

MetisBC- Surry, British Columbia

comment from Metis BCcomment from Metis BC

Personal Information Withheld - Interior, British Columbia

Why is a project of this magnitude, crossing watersheds and multiple areas of concern for aquatic and riparian species, being shoved down locals throats when the future state of the environment is so uncertain? Once this is constructed, it cannot be undone. We are running out of natural landscapes in BC, and we will not be able to buy back ecosystem health.

michelle elliott, sydney

Dear EAO,

Sincerely,

michelle elliott, sydney

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

ISABEL CERVERA, Madrid

Dear EAO,

Sincerely,

ISABEL CERVERA, Madrid

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

March 1, 2017

Raleigh koritz, Plymouth

Dear EAO,

Sincerely,

Raleigh koritz, Plymouth

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Beverley Playfair - Fort St. James, BC

British Columbia Environmental Assessment Office,

RE: Comment on Aurora LNG

I have spent 12 years in this area out on a boat. This is the last place in BC that should have this LNG plant. The people who live on this tiny Island have been there for years for a purpose they want to leave a clean quiet life. What is the pollution going to do to this area? This is Prince Rupert on the North Coast of BC where it rains and is foggy and socked in 325 days of the year. I invite anyone or all of you responsible for this decision to visit this area and then make your decision.

Thank you.

Beverley Playfair
Fort St. James, BC

Thank you

cc: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Dave Deleurme, Kelowna

Dear EAO,

I want to add my voice in opposition to the proposed Aurora LNG. We need to put a stop to large multinational corporations destroying our natural habitats for the sake of profits. LNG is an expensive, unnecessary endeavour. The government should say no to this massive boondoggle.

Sincerely,

Dave Deleurme, Kelowna

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

G Loewen, Vancouver

Dear EAO,

Save our coastline,salmon, and keep our water clean. We should not jeopardize our beautiful coastline, the Eco system, and our water for the sake of big business. LNG is still a form of fossil fuel and not sustainable.

Sincerely,

G Loewen, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Erica Pinsky - Vancouver, BC

British Columbia Environmental Assessment Office

I am writing to express my absolute opposition to the Auroran LNG proposal.

I am opposed to any new LNG projects in our province, as research and the experience here in BC and in states south of the border shows that in addition to the habitat destruction, environmental devastation, water contamination and massive use of our limited water resource, without which life on this planet will not be sustainable, there is a documented increase in earthquake risk and frequency.

With respect to Aurora LNG, putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.My understanding is that Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

From an environmental perspective the noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia. In addition, Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.

Perhaps most significantly Aurora LNG would make it impossible for BC to meet its legislated climate targets. This facility and upstream development would produce 15 megatonnes of carbon pollution every year, while the gas shipped to Asia would release another 69 MT. It is clear that such a project is at odds with both national and international efforts to reduce emissions.

I respectfully ask your office and the current government of BC to please say no to this project which will put our coast, our communities and our climate at risk!

cc: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Roz Isaac, North Vancouver

Dear EAO,

It's time to put aside monetary interests and do the right thing for the environment for future generations, particularly in the First Nations communities.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

Sincerely,

Roz Isaac, North Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Patricia Erwin, Duluth

Dear EAO,

Sincerely,

Patricia Erwin, Duluth

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Lisa Neste, High point

Dear EAO,

Sincerely,

Lisa Neste, High point

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Diana Disney-Coker, Mars Hill

Dear EAO,

This would be insane. Don't let big oil (especially China!) enrich themselves while poisoning wild areas and the wildlife that lives there. All the money in the world is not worth this destruction.

Sincerely,

Diana Disney-Coker, Mars Hill

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ruth Cain, Clearwater

Dear EAO,

Sincerely,

Ruth Cain, Clearwater

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ludger Wilp, Bottrop

Dear EAO,

Sincerely,

Ludger Wilp, Bottrop

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Bonna Mettie, Paradise

Dear EAO,

Sincerely,

Bonna Mettie, Paradise

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Antonio García-Palao Redondo, Madrid

Dear EAO,

I say no to Aurora LNG

It is a question of love and care to the planet

Thank you

Sincerely,

Antonio García-Palao Redondo, Madrid

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

shirley mills, sandwell

Dear EAO,

The proposed fracked gas plant on Digby Island is to dangerous.The local community and up to a billion young salmon will be put at risk.
The terminals burning gases will be a threat to migrating birds.
This is not the place for such a dangerous plant.

Please reconsider.

Sincerely,

shirley mills, sandwell

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Annie Wei, Queenslnad

Dear EAO,

Sincerely,

Annie Wei, Queenslnad

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Elaina Valzania, Greenland

Dear EAO,

Your industry supporting Gas is a disasterous idea since it will destroy Salmon and water and contaminate air and earth. All of life needs clean air and water to survive and with the anniliation of all of our environment all living species are soon to follow. We cannot keep destroying the air and water and expect to live healthy lives and if you have families you care about they should take priorities over profits. Once the damage is done we can never go back.

Sincerely,

Elaina Valzania

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Deirdre Keohane, Vancouver

Dear EAO,

Sincerely,

Deirdre Keohane

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Anne Moeller - Charleston

Dear EAO,

Sincerely,

Anne Moeller

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

natalie gosnell - Prince Rupert, British Columbia

I don't think LNG is very considerate of what actually happens when they come into unknown territory and just start building and operating. I was born and raised in Prince Rupert, I live in Vancouver now. I've seen both sides of the work spectrum. In Vancouver its all about money, profit, "success". In Rupert it's different. It's about the spiritual and emotional success the land provides us, NATURALLY. Financial stability comes with it and is our bonus ! Our culture, the way we raise our children in Prince Rupert and surrounding areas are largely based off the land and all it has to offer us.

How would you feel if you are living a happy life with your family and one day someone says "I don't like the way you are living, and I think the way I do things is going to profit you" ... You would disagree, or unwillingly agree ? With the facts that you know about how your family works and survives, you would defiantly disagree. My name is Natalie, I am from Haida Gwaii, eagle clam, Ts'aahl laanaas Clan is my house name. I more the strongly disagree with LNG and what they promise to offer. "More Jobs" mean nothing in a community like ours. We are one of the few communities in BC, the world, that don't abide by the concrete jungle world. Now I don't believe in God but I do believe what is "right" for the world.

Let us keep our mostly unharmed environment. Let me grow as a person in this money hungry world until I am ready to move home and raise a family. Let me raise my future children in the same environment as I have. My future children's lives would be so different. They will not see the beauty of a high tide, and all the silver fish brushed along the top of the water. They will not hear the convocation of eagles living across my parents house. Or be able to catch the perfect salmon off the water front docks. Or to smell the scent off fresh cut yellow cedar on a hot summer day. Dried or smoked salmon will be a thing of the past. My comfortable and happy life style at home will drastically change.

Life isn't always about making money and buying things. Life is about what you do with your time and how you effect the people and world surrounding you. It took me many years to realize this. And I wish the corporate at LNG would realize to. I can say a million more valid points but I would rather not bore you with a email no one will read or reply. I feel hopeless typing this. I am crying thinking of the negative impact this will have against our people .... Destroy another communitiy, belief and culture built with mother nature. Not mine. Please. STOP !

Personal Information Withheld - Dodge Cove, British Columbia

Community of Dodge Cove Personal Impact Statement

Digby Island Culture and Quality of Life Dodge Cove is a community of over one hundred years situated on the east side of Digby Island. We contribute the founder of our community to George Dodge- a significant Canadian surveyor of the Northwest coast and the Alaska-BC International Boundary Line. George Dodge set up his surveyor's camp at Fairview Bay in 1910, which is directly across from Dodge Cove. In 1911, the Marine Station was built on the south side of Casey Cove as a means of protection for mariners and Canadians. In about 1911-12 with the expectation of immigrants and industry, a Hospital was built on Dodge Island locally known as Hospital Island. A compatible Dr.'s House was built on the south side of the cove and a bridge connected the two structures. By the 1920's many Norwegian settlers found this as a perfect place for their industry and their families. Industry revolved around fishing, sawmilling, and boatbuilding as well as other spinoffs from this industry.

Dodge Cove was also used as place for recreation and the appreciation of its beaches and beauty, because when the hospital fell into disuse very quickly, significant outdoor parties were held at the hospital. To this day Dodge or Hospital Island is a part of our existence as well as the trail that skirts Casey Cove Beach. It is a loop from our road along the beach to the Dr.'s House and either to the top of CBC Hill or past the Dr's House on the south side of the Cove back to the main road. The trails that begin in our community and extend out from it are all maintained on a volunteer basis. Trails that lead anywhere are a significant part of our unique existence on this island as they all have many uses. There are trails that lead to the ridge behind our properties that take us to the Dodge Cove dam, the ponds, Mt. Comblain and Wahl Lake. There are so many trails we have used for hunting, photography, wild food gathering, and recreation that it would be difficult to describe all of them. In the last ten years two tsunami trails have been built. One is mid Dodge Cove and one is at the north end of Dodge Cove. A trail leads northward to Crippen Cove partially under the power lines that lead to the airport. There has been a very close connection between these two communities. A trail leads to Delusion Bay from one of the creeks on the south side of Casey Cove. Residents walk the beach to access the trail for hunting and recreation purposes. A Cabin there attests to the fact that it has had many visitors. There is cabin near southwest beach as Spire Ledge is a famous fishing spot. Beaches there and on the west side are used for recreation and log beach combing and boats and kayaks use the whole island for circumnavigation. There are local businesses that rely on log salvaging and fishing as well as boat building and photography. These will be negatively impacted by the plant in the heart of our island and from the jetties at the south end. Many mariners run out to Spire ledge and the sound to watch the whales in the winter. That will come to an end also. As a property owner, I will not want to hike to the back of my property and hike the ridge to Bhudda Hill because there will be a camp from 1000 to 5000 of mostly men workers. I will not be going to bring my guests to see the view to the west. I will not be bringing guests or family to see Spire rocks, to whale watch or to fish. My family will not be able to hike to Delusion Bay to birdwatch, hunt, or photograph. My guests and family will be cut off from Lake Wahl, nmed after a famous boatbuilder that lived and created industry in Dodge Cove for most of his life.

At Frederick point are the remains of the Old Fort where even socials were held during the war. Again this was a significant spot for defense of our harbour. Where there should be safety for all those entering the harbour, for fisherman, tugboat operators, captains, ferries with tourists and all local people, instead there will be ground zero of a Hazard Range which, due to a malfunction or leak, could take the lives of all people and animals within a 2.2 mile radius (Sandia National Laboratories). An old road runs from Frederick Point along the east side of Digby Island which was built during the war. Will I feel safe and secure for myself, my visitors or my family walking the beach to the Boy Scout Camp for berry picking or nettles? Of course not. Who would want to walk closer to the hazard in a hazard zone? Will I be allowed to hike the island either south or west of Dodge Cove? Of course not! If this is not safe for me then it is not safe for others. That is why it is called a Hazard Zone. What really angers me is that Canada has not given any thought to the hazards that exist in letting the Chinese Government/ Nationally Owned Company buy a strategic inland wharf (where a Marine Base was built) and that they have acquired by lease from the Provincial government, an island that is most important for the protection and security of the Prince Rupert World Port and the Prince Rupert Airport. Obviously the importance of marine travel and ports for the protection of Canadians is at its lowest point.

All the spaces in between these important places are just as important as the trails because without the health of the soil, the water and the air, then who would want to gather the food. It will be contaminated. If the fresh water habitat, the bog habitat and the fish habitat are sick then the health of the people will fail. The environmental application does not consider the sedimentation of our bog or streams from construction and how it will affect our drinking water, nor does it consider the acidification or eutrophication of our community water even though the changes due to green house gases will be significant. This LNG process will produce over 20% of BC's green house gases with upstream emissions. Of course Nexen-CNOOC has not put in their upstream emissions yet and they won't have to until much of the work on the application is finished. The application is a disguise for the truth as there are many missing parts that the public or the working group has not seen yet.

When I go to the sacred places, such as Bhudda Hill, the highest point on the island, where visitors leave offerings for their loved ones who have passed on and we look to the west, there will be no buffer zone and no visual quality left as Nexen claims. Before the Panoramic Pacific view there will be a workers camp with the noise and industry of the LNG trains and generators and the three lane highway which will overlap our Official Community Plan. One reason the OCP is so important to all communities is to protect watersheds so communities have the right to life...water. We rely on the water just as it comes from the natural uncontaminated bog. The construction of the highway and all else related to Aurora LNG will irreversibly degenerate the quality of life on Digby Island.

All the spaces in between all the trails holds our green space, our water, our air and all other living things which are imbedded in the psyche of everyone who has ever lived on this island or visited it. Because of the beauty and the unique culture of the people, the island is a hotspot for artists and photographers. The Cove has had a few schools, three of which are still standing. The last school has been renovated to be the Community Centre. Many organizations work from this Centre. The old outdoor basketball court was has been used as a stage for musicians during The Dodge Cove Art Show. There is the Dodge Cove Arts Guild, the Digby Island Arts Group, The Coastal Quilters, and the Dodge Cove Recreation Society that depend upon the School for events and functions. The Recreation Society, the Dodge Cove Improvement District and the Dodge Cove Harbour Authority use the School's offices. The computers serve the public and mariners. The DC Authority maintains the dock and structures while the DCID maintains the Dodge Cove Dam and the Community Water.

With the construction of Aurora, the beauty and sacred places will be gone, and with them the naturalists, artists and travellers who have come over the hundred years of our existence to reap not only the benefits of our backdoor wilderness but the commercial aspects also, whether it is the craftsman on the waterfront or the artisans who seek the history and wild places. All of it will be gone, because as go the fish, so go the fishermen, with the fishermen gone the boatsheds the builders/craftsmen will be gone. Our unique culture, of potlucks at the Schoolhouse, Santa Clause and Christmases, Winter Solstice celebrations at Casey Cove, Halloween costume parties, the Dodge Cove Art Shows and home cooked Easter Brunches where over one hundred visitors come to celebrate, not the event, but the location will dwindle or disappear. New Year Dances, Canada Day barbecues and First Fish Barbecues at Casey Cove North Beach will all be gone because this Island will not be suitable to the health of populations. These events are all part of our diverse make up and tight knit community. It is my community and I have realized over the years how a community is built and how a community remains healthy. Part of my family's income will be affected as artists' interest in Dodge Cove dies as the beauty is destroyed. Many Dodge Cove citizens gain income from their art. As fishing and tourism decreases, and our population decreases on the island it will affect income from boat repairs that is part of income in my family also.

The dredging and floating camp will ruin not only the fish and bird and beaches of Casey Cove but will ruin the wilderness and relatively quiet beach where residents and visitors go for stress free walks and where school children learn about beach habitat. The GHG emissions and methane have known carcinogens, the Hazard Zone has its own explosive dangers and anyone would have to think more than twice about raising children here. Why have the proponent, the provincial and federal governments allowed this aggressive invasion on a population? The safe and secure community with access only by the water will be gone as a complete abnormal town within a fence, with one purpose, will be built behind us in our green space. We love the physical activity of walking hiking, skating on Wahl Lake, outdoor barbecues, fishing, birdwatching, toad observations, gardening, messing about with boats and family life. I live here because the ocean is in front of me and the wilderness is behind as I know others in my community do. The volunteerism and cohesion of this very old style traditional way of life will pass by. This is a community with a very small footprint. We have no trucks and cars. We should be the model for everyone who cares about a better quality of life and a reduction of greenhouse gases. This island is my health but it is also a part of the health of Prince Rupert and its citizens.

Is this not more important for us to exist and live in a healthy lifestyle in a secure location, to show Canada that this traditional style community still has more relevance than a project of environmental destruction? In fact, shouldn't Canada depend on this less is more way of life? Didn't Canada make this commitment in Paris? LESS IS MORE. Aurora LNG obviously is much more and is a commitment of more GHG'S until 2050, long after the world's temperature has risen 1.5 degrees.

Robin Pozer - Haida Gwaii, British Columbia

Trudeau...preaches global environmental health with Canada leading the way and then does this. The snub to to the West again and reveals his his mismanagement of our country's wellness and culture for short term profit...if any.

Personal Information Withheld - British Columbia

This project is great. Bring on good jobs!

Personal Information Withheld - Toronto, Ontario

Why is the Government so hellbent on ignoring the terrible track-record of leaks in pipelines? Sure, the companies portray their rates as low, but when you actually dig into the data, there is a large amount of oil and natural gas that leaks into the environment. This is old, dirty technology. If BC wants to show leadership, start by looking forward towards new energy sources instead of backward to this project. It's a no-brainer!

Ian Wachs - British Columbia

There is no way an area this pristine should be put in jeopardy or completely destroyed in the name of non renewable energy. The fact the plant would only be around for 30 years makes even less sense. This is the last watershed of it's kind and it should be left untouched for ever so generations can enjoy it. The money should be invested in renewables.

Personal Information Withheld - Dodge Cove, British Columbia

Here are comments I would like to submit to the EA process

Personal Information Withheld - Dodge Cove, British Columbia

I would like to submit these letters sent to the Environmental Assessment Office to the public comments, as they speak to the EA process

lamme janssen - Whaletown, British Columbia

To be sending dirty, fracked fuel to another country through pipelines over b.c. and freighters in the oceans is irresponsible, especially when it is a fuel that is becoming economically not viable. The risk to the B.C. environment and to our planet just cannot justify it. Do not do it.

Personal Information Withheld - Penticton, British Columbia

Building the Aurora LNG Plant on Digby Island is simply wrong. We should be investing in clean energy, not building plants that will increase CO2 emissions. Humans are responsible for climate change, building this will make life worse, not better. And when we know better, we must do better.

Personal Information Withheld - Mansons Landing, British Columbia

The proposed building site is too close to human habitation and the island contains a unique ecosystem of wet lands that should be protected, not developed. No to Aurora LNG on Digby Island. Absolutely NOT!

Personal Information Withheld - Creston, British Columbia

Our planet can take no more. The air the land and the water are all suffering from our tax dollars subsidizing fossil fuels. Why won't our politicians spend our money more wisely, oh ya they take banko for themselves.

Personal Information Withheld - Digby Island, British Columbia

Though I am sure more information will be released after the Environmental Assessment is complete, my official position on this project is already one of opposition. First of all, the proposed terminal is only half a kilometre away from the community of Dogde Cove and 3 km away from Prince Rupert. The Society of International Gas and Tanker Terminal Operators states that all LNG facilities and carriers should be at least 3.5 km away from communities. Is this because there is something toxic about the processing of LNG that could harm communities or because it is extremely disruptive in terms of noise/construction/waste etc?

Either way, besides the fact that the proposed design is already too close to near by communities (based the standards of the SIGTTO), I do not believe that a project which threatens the area with noise, destruction of natural features, toxic waste, and increased vehicle/marine traffic, etc. should be anywhere near such a pristine, beautiful, diverse and fragile area like the Skeena Estuary, which is home to many species that are endangered or nearing that status. In fact, by contrast, this area would be perfect for a conservation project (see the Wetland area within the proposed site, for example).

An LNG terminal could also have a devastating impact on sustainable industries of the area (ex. fishing and tourism), and it is completely unfair that locals who depend on the SUSTAINABLE abundance of the area to support themselves in this way be threatened by a destructive project that benefits mostly the company building it and it's Asia-Pacific trade relations. The healthy salmon population alone brings in millions of dollars every year for the people there which would be massively impacted by an industrial project in the estuary.

Last but not least, why would BC continue investing in projects like these, that we know are not only bad for our environment because they require destroying incredibly important and diverse areas in order to build, but which also would add millions of tonnes of CO2 to our atmosphere when we know we need to find alternative means of clean energy that do not do this? Investing money in these LNG projects and granting them permits to build is a huge waste of time and money that should be going into finding other, cleaner, more sustainable and lasting means of producing energy and economic growth. For those reasons and more, I am prepared to oppose the Aurora LNG Digby Island Project and others like it on the coast of BC should they be approved. This is not the time or place for such illogical and destructive industries.

Personal Information Withheld - Victoria, British Columbia

Hello,

With respect, I ask you to stop the plans for the Digby island project. It is not accepable to place this project on this territory, which is within 3km of the Prince Rupert and 0.5 km from the Dodge Cove community. The location of this plant violates the condition that all LNG facilities must be 3.5km away from a community. It is not acceptable to proceed with this project despite British Columbians pleas to re-consider. This is not an acceptable project location. I stand alongside the community and do not consent to this. Thank you for your attention and consideration of this life-altering decision. In honour of the next 7 generations of life on this planet, thank you for stopping the progression of this project.

With gratitude.

February 28, 2017

andreas vlasiadis, athens-greece

Dear EAO,

Sincerely,

andreas vlasiadis, athens-greece

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Margie Fourie FOURIE, PORT ELIZABETH

Dear EAO,

Sincerely,

Margie Fourie FOURIE, PORT ELIZABETH

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Marina Parfenova, Moscow

Dear EAO,

Sincerely,

Marina Parfenova, Moscow

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

mauricio carvajal, 9291583

Dear EAO,

Sincerely,

mauricio carvajal, 9291583

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Bonnie Faith, Cambridge, MA USA

Dear EAO,

Sincerely,

Bonnie Faith, Cambridge, MA USA

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Hal Trufan, Matthews

Dear EAO,

Sincerely,

Hal Trufan, Matthews

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ronald Ratner, Sioux Falls

Dear EAO,

Sincerely,

Ronald Ratner, Sioux Falls

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Colleen Lobel, 92126

Dear EAO,

Sincerely,

Colleen Lobel, 92126

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Dianne Douglas, Phoenix

Dear EAO,

Sincerely,

Dianne Douglas, Phoenix

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Donlon McGovern, Portland

Dear EAO,

The placement of Aurora LNG poses a grave environmental threat to an established industry, salmon. The ecological dominos toppled by the harm from fracking begin with the salmon to the wildlife dependent upon them as a food source to the First Nations people dependent upon them not only as a food source but as an economic benefit. Don't allow the Chinese to profit at the cost to your people and your environment as well as your economy. Do it right and the salmon will pay you back for many generations to come.

Sincerely,

Donlon McGovern, Portland

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Sheila Desmond, Cameron Park

Dear EAO,

I've known numerous fishermen throughout the years; hardworking men and women who would probably lose their livelihood if these salmon were killed.

Aurora LNG is not interested in the environment, the salmon, the livelihood of our fishermen, or the health of the ocean.

Digby Island is a beautiful, natural resource of British Columbia and needs to be protected. The people of Prince Rupert do not need their area polluted and destroyed over greed, nor does the rest of British Columbia need the entire environment destroyed over money.

,

Thank you for considering my comments.

Sincerely,

Sheila Desmond, Cameron Park

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

JOHN PASQUA, Escondido San Diego County

Dear EAO,

DUMP THE AURORA L.N.G TODAY TO SAVE THE WETLANDS AND SALMON HERE.

Sincerely,

JOHN PASQUA, Escondido San Diego County

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Dear EAO,

Sincerely,

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

John Brewer, Montreal

Dear EAO,

The Aurora LNG plant should not be built for the following reasons..

1. The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.

Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

2. The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

3. As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget

Thank you for taking the time to read my concerns..

Sincerely,

John Brewer, Montreal

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Bonnie Lynn MacKinnon, Georgetown

Dear EAO,

Sincerely,

Bonnie Lynn MacKinnon, Georgetown

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Martina Capannini, Firenze

Dear EAO,

Sincerely,

Martina Capannini, Firenze

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Peter Cummins, Cairns

Dear EAO,

Sincerely,

Peter Cummins, Cairns

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

cristina nagy, mar del sur

Dear EAO,

Sincerely,

cristina nagy, mar del sur

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

NANCY O, NEWARK

Dear EAO,

Sincerely,

NANCY O, NEWARK

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Julie Sasaoka, concord

Dear EAO,

Sincerely,

Julie Sasaoka, concord

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Dear EAO,

Sincerely,

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Rob Seltzer, Malibu

Dear EAO,

Sincerely,

Rob Seltzer, Malibu

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ma. Elena Guillermo, Merida

Dear EAO,

Sincerely,

Ma. Elena Guillermo, Merida

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Fleurette Burak, StCatharines

Dear EAO,

Sincerely,

Fleurette Burak, StCatharines

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

DEBORAH SMITH, OKLAHOMA CITY

Dear EAO,

THIS IS A VERY BAD "THING"!!! AND THE WHOLE ISSUE MAKES ME VERY ANGRY!!!!THIS CARBON BOMB MUST BE STOPPED!!!

The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas..

The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.

Sincerely,

DEBORAH SMITH, OKLAHOMA CITY

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Betty Kowall, Salmon River

Dear EAO,

Sincerely,

Betty Kowall, Salmon River

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Andrea Frank, Beach Park

Dear EAO,

Sincerely,

Andrea Frank, Beach Park

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ruth Rogers, Woolwich

Dear EAO,

Sincerely,

Ruth Rogers, Woolwich

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Laraine Bowen, Oakville

Dear EAO,

Sincerely,

Laraine Bowen, Oakville

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Dagmar L. Anders, Chemnitz

Dear EAO,

Sincerely,

Dagmar L. Anders, Chemnitz

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Tami Palacky, Springfield

Dear EAO,

Sincerely,

Tami Palacky, Springfield

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Diane Kent, Phoenix

Dear EAO,

Sincerely,

Diane Kent, Phoenix

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Beth McHenry, Parksley

Dear EAO,

Sincerely,

Beth McHenry, Parksley

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Anna Jasiukiewicz, Ostrów Wielkopolski ostrowski

Dear EAO,

Sincerely,

Anna Jasiukiewicz, Ostrów Wielkopolski ostrowski

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Anita Coolidge, Cardiff by the Sea

Dear EAO, Well, yet another disastrous plan that will wreak havoc on nature...and all for greed!!! Please say NO to this. We all need to go GREEN -- NOT greeD!!!

Sincerely,

Anita Coolidge, Cardiff by the Sea

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Cheryl McEachern - Vancouver

Dear EAO and ministers,

As a registered voter in British Columbia, I am writing to insist that you do everything you possibly can to block the approval or construction of the Nexen Aurora LNG plant being proposed.

That land and water is so much more valuable to us as a healthy, natural ecosystem that delivers nutritious food and clean, breathable air for all than it could ever be as a source of profits for distant Chinese billionaires.

We really need to get past the idea that cash is the valuable bit in life. We can't reach our provincial or national climate targets AND build such a catastrophic mess. We need to get past the antiquated Industrial Age. There are SO many new sources of energy generation. These legacy fossil fuels are dangerous, outdated and ludicrous.

We have all the resources and information available at our fingertips right now for B.C. and Canada to be innovative world leaders in clean energy and technology development. With the shambles that the United States are in, we could surpass them on the world stage, yet we are stuck with too many embarrassingly greedy and unimaginative politicians who lack the clarity or leadership to seize this chance. How about you? Are you ready to be a person worth remembering in the history books of Canada? Do you have the fortitude to fight the good fight and speak out against corporations buying our country out from under us?

We're counting on you to use the power afforded to you to make our country one worth respecting on the world stage.

Thank you for your time.

Sincerely,

Cheryl McEachern, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Carol Thompson - South Park

Dear EAO,

Sincerely,

Carol Thompson

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Lawrence Crowley - Louisville

Dear EAO,

Sincerely,

Lawrence Crowley, Louisville

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Personal Information Withheld - Nanaimo, British Columbia

The environment of Digby Island and surrounding territory cannot support projects of this type. Do not allow this to happen.

Personal Information Withheld - Prince Rupert, British Columbia

Don't do this. We rely on this land/water to sustain us.

Personal Information Withheld - Terrace, British Columbia

Please stay away from Digby.

Christine Leipscher - Squamish, British Columbia

I've become more and more disappointed in our government and the lack of concern they seem to have for our environment, and the people living amongst it. This is just one more huge nail in the coffin of our coastline.

Frances Fasano - North Vancouver, British Columbia

THIS IS SO WRONG. When are we going to realize we cannot keep doing this to our planet. This should not go ahead.

Samuel Grenier - Kelowna, British Columbia

Whether we build this facility on Lelu or Bigby island there is no difference. The key to the issue that its not a feasible project. Not for our economy, not for jobs, and not for the environment it will impact. Ask yourselves whether youd throw away a multimillion dollar industry (renewable) for a pipeline and tankers that could destroy our pristine wildlife and land. Wake up and smell the roses! This is irresponsible and plain down right wrong. I want our evonomy to flourish too, but not in this manner! Make the right decision. Your re-election counts on it.

John Muirhead - Courtenay, British Columbia

LNG is not a green solution to climate problems. Christy Clark is pushing this industry as our contribution to solving our GHG emissions in BC. It's been proven that from beginning to end, LNG can be worse than coal when it comes to emissions. Not to mention the effects of tanker traffic for marine mammals and the added potential for spills.

David O'Kane - Vancouver, British Columbia

A project of this size that only has a 30 year lifespan is certainly not worth the possible destruction of wildlife and fish habitat on and around Digby Island and the Skeena River. The majority of B.C. taxpayers will never see a tangible benefit from this development. The low cost of natural gas makes this particular project uneconomical. We should be looking east to market our gas to Alberta (and other provinces) as they begin to replace their coal-fired plants. New technology makes gas fired electricity generation cheap and comparably cleaner. Please do not make a politically motivated decision. You must speak for ALL British Columbians. Thank you for your service.

Sheryl McDougald - Roberts Creek, British Columbia

NO Digby Island terminal!! Bad science, bad for wildlife, outdated technology, too close to towns, and a terrible waste of resources.

franz scholz - West Kelowna, British Columbia

what is the matter with you ignorant people,has big oil and gas filtered so deeply into your psyche that your willing to expose one of canadas biggest fisheries to its ultimate destruction all for the sake of corporate greed...shame on you...wind,solar and Geo thermal are far better,safer and in the long term renewable energy sources...start investing into the future not the destructive,dirty past

Personal Information Withheld - Vancouver, British Columbia

I support the Aurora LNG Project.

Heather Ross - Ontario

No. Just. NO. I was born in Terrace. Leave The Mighty Skeena to the indigenous people who've cared for it for the millennia.

Personal Information Withheld - Prince Rupert, British Columbia

Comments:

  • poorly sited (project too close to heavily populated area)
  • inadequate consideration of cumulative effects (on both marine environment and social/economic impacts)
  • disregards recommendations from Province's own commitments on marine spatial planning and Federal Oceans Act; fails to articulate how project corresponds with local municipal, regional, First Nations and prov/federal planning and land-use frameworks.
  • short-term economic opportunism at the expense of long-term social-economic resilience
  • rationalizing this (and other LNG) projects as "good for the climate" is shockingly irresponsible, insulting and indefensible - it relies on manipulative cherry-picking of facts about carbon emissions. A disgusting dereliction of responsibility on the part of decision-making and regulatory bodies.
  • typical steamrolling development decisions masquerading as consultation

Personal Information Withheld - Hagensborg, British Columbia

We must protect what remains from a century of destruction.

Invest in alternative energies.

Petroleum is over!

Let Canada become a leader in alternative fuels!

Personal Information Withheld - Powell River, British Columbia

People and the environment before profit!

Personal Information Withheld - Victoria, British Columbia

NO, just NO for all the very obvious reasons--salmon, First Nations, danger to FN and Prince Rupert communities from an explosion and other adverse pollution etc. NO, this should be a no-brainer!

Steve - Kitimat, British Columbia

the questions that should be asked are:- what are the risks to the environment and the people of this area? do the economic benefits to the greater area as well as the people of Prince Rupert out weigh the risk to the environment ? would the project benefit some areas of the environment than others and what affect would this have on the Eco system. if the benefits to the wider community outweigh the possible risk to the environment then I say go for it. People who use fossil fuels for transport, heating, clothing and food should look hard at themselves before jumping on the "Not in my back yard" band wagon.

Personal Information Withheld - Cortes Island, British Columbia

The long lasting environmental destruction is not worth the gamble for perhaps 30 years of use. The proposed building site is too close to human habitation and the island contains a unique ecosystem of wet lands that should be protected, not developed. No to Aurora LNG on Digby Island. Absolutely NOT!

Personal Information Withheld - Victoria, British Columbia

This project should not proceed. It is economically flawed and environmentally a disaster. In the name of short term gain, which is debatable, the project will cause irreparable long term damage.

The world is moving toward more efficient power and energy production. When we get there, do you want to look back on these types of projects and say to yourself "Wow, if only we had not done that. If only we had invested in new technology instead."

These types of projects are archaic and only serve a handful of people economically but harm masses environmentally.

Use the science. Do not bow to the companies that are putting the pressure on. Listen to your heart and head.

Personal Information Withheld - Victoria, British Columbia

Renewable and environmentally safe energy is where cutting edge world leaders are at. We are so provincial in BC. We're a joke. No to LNG!

Personal Information Withheld - Denman Island, British Columbia

No to anything to do with LNG, pipelines, gas, oil or other hydrocarbons - Leave Digby Island alone. As an islander, I understand their fragile ecosystems must be preserved and protected for future generations.

Personal Information Withheld - Creston, British Columbia

This environmental disaster must be stopped.

Michele Rodger - Terrace, British Columbia

I do not understand why we continue to pus for a facility that is so in the wrong place. For an industry that has such a dirty process of extraction, that is going to cause problems for the water ways for generations to come and then the government has the audacity to call LNG green. What the hey is wrong with this picture -everything. Do not allow an LNG plant on Rigby Island - the protest well be great, there are many who are rightly so very apposed to this and they well stand for what is right.

Personal Information Withheld - Gabriola, British Columbia

These waters are too precious to be risked. Put the money into a safer energy, please. This energy solution is so short-term and the harm to wildlife and people's sustainability too great.

Tom A Bates - Victoria, British Columbia

The world is flooded with LNG. With solar coming on line there is no need for this. Do you know what you are doing? We will have to PAY contrys to buy our LNG, please give your head a shake. No to dams, pipe lines, and LNG. More people working in the green industry than the oil business. Thank You Tom Bates

Gary J Parker - Victoria, British Columbia

As a tax paying citizen of Canada and resident of BC, I utterly and completely reject,oppose and condemn this proposal. It makes no economic sense and it is a clear and present danger to the environmental integrity of our pristine coast. I will oppose this and contribute towards resisting it if implemented. An absurd, ill thought out and ridiculously unrealistic proposal

Personal Information Withheld - Cloyne, Ontario

NO.

NO.

NO.

Digby island is a treasure. Enough that the airport is there. No where else in our country have I seen more creatures of nature in such a small area.

Diana Schroeder - Courtenay, British Columbia

LNG cannot proceed under the current environmental review process that does not take into account the upstream issues in regards to fracking and waste. It also omits an assessment of impact of increased tanker traffic and emissions. We must have an opportunity to look at the social implications as well. We know that, with the corporate taxes so low, it is not in the best interest of British Columbians to sacrifice their wild salmon fishery, Native fishery and their sustainable tourist industry.

Lawrence Crowley, Louisville

Dear EAO,

Sincerely,

Lawrence Crowley, Louisville

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Gwen Hadland - Hillsboro

Dear EAO,

Having been a resident of Dodge Cove for a number of years, the possibility of the construction of an LNG plant in that area deeply disturbs me. I was also a salmon fisherman in the area & know of the damage that could be done to this important fishing area. it is a beautiful & critical place for salmon.

Since it is also near the Metlakatla reserve, I feel we owe it to the native population to do all we can to preserve their fishing rights. These are the original people & deserve to be treated with respect.

Please do all in your power to prevent this LNG plant to be constructed. Thank you!

Sincerely,

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Carol Jurczewski - Riverside

Dear EAO,

Sincerely,

Carol Jurczewski, Riverside

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Barbara Vieira - Staten Island

Dear EAO,

The Aurora LNG is a massive fracked gas plant being proposed by Nexen. The location of this plant will be a threat to the Skeena actuary where up to a billion young salmon make their way to the ocean each year. The nearby community of Dodge Cove is at risk of becoming surrounded by a dangerous industrial zone and will negatively effect the wild salmon economy in that region.

This project must be stopped

Sincerely,

Barbara Vieira, Staten Island

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ilia Fridland - Cantley

Dear EAO,

As a Canadian who loves British Columbia, I am writing to politely demand that the Aurora LNG project be firmly rejected. The risk to wild salmon stocks is not worth the temporary wealth this dirty project would generate.

Sincerely,

Ilia Fridland, Cantley

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Aaron Bouchard - Bridgewater

Dear EAO,

Sincerely,

Aaron Bouchard, Bridgewater

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Stephanie Whitman - west kelowna, British Columbia

British Columbia Environmental Assessment Office

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

RE: Comment on Aurora LNG

Hello, I am a deeply concerned citizen, writing to you in all my hopes, that you will hear the voices of the people of the lands that you so govern and protect. Over the past century humanity has taken an enormous toll on the planet as a whole, this I am sure you are aware of. This project is only taking another deep dark step further in hurting the beautiful planet that we live on and rely on for life, our mother earth. Not only will this project be hugely disruptive for the community of Dodge Cove, but it will have such a devastating impact on the natural environment of the area and the planet as a whole.

We must all take responsibility as humans to protect the lives of those we put at risk against their will, incredible beings such as the harbour porpoise who will be dramatically effected by the noise from the tankers and facility. The great blue heron and many other birds habitat this area and to preserve their environment is vital to their survival, and the survival of this entire ecosystem. With climate change on the rise, we need to take action now in all ways that we can. This project is a step in the completely wrong direction. If humans are going to have a future on this planet, it is going to need to be a sustainable future. I know that we can do better than this as humans. I know we have the technology to live sustainably and symbiotically with our planet. Putting the environment first is simultaneously putting ourselves first. This project will make it impossible for BC to meet its climate targets to reduce emissions with the amount of pollution it will cause, while also violating international siting standards that require projects to be located away from population centers and other marine traffic. Our coast, our communities and our climate is under so much risk, I urge you to please lend your consideration and compassion. Thank you,

This letter was created with the use of an online letter writing tool at wildernesscommittee.org

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Brittney Kneller - West Kelowna

Dear EAO,

I strongly feel that this would greatly impact the salmon and wildlife in the area. Migratory birds and other animals will suffer severe habitat loss. It will also impact the environment in which the community lives. The resources the community uses will be polluted by the emissions produced.

For these reasons, I strongly disagree with this project.

Thank you.

Sincerely,

Brittney Kneller, West Kelowna

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

freddie williams - benoni

Dear EAO,

STOP AURORA LNG NOW!

AURORA LNG THREATENS SALMON AND WILDLIFE

The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas

AURORA LNG THREATENS COMMUNITY HEALTH AND SAFETY

The plant would pollute the pristine air, drinking water and soil of local communities.

AURORA LNG THREATENS OUR CLIMATE

As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Stella Gambardella - Roma

Dear EAO,

Sincerely,

Stella Gambardella, Roma

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ed Vieira - Staten Island

Dear EAO,

The Aurora LNG is a massive fracked gas plant being proposed by Nexen. The location of this plant will be a threat to the Skeena actuary where up to a billion young salmon make their way to the ocean each year. The nearby community of Dodge Cove is at risk of becoming surrounded by a dangerous industrial zone and will negatively effect the wild salmon economy in that region.

This project must be stopped.

This project must be stopped

Sincerely,

Ed Vieira, Staten Island

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Victoria Peyser, Newark

Dear EAO,

Sincerely,

Victoria Peyser, Newark

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Joan Walker - Bishop

Dear EAO,

Sincerely,

Joan Walker, Bishop

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Animae Chi, NY

Dear EAO,

Sincerely,

Animae Chi, NY

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

diana Schroeder - courtenay

Dear EAO,

Sincerely,

diana Schroeder, courtenay

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

natasha salgado - Toronto

Dear EAO,

Sincerely,

natasha salgado, Toronto

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

February 27, 2017

Lisa Neste - High Point, NC

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.

Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.

This facility and upstream development would produce 15 megatonnes of carbon pollution, while the gas shipped to Asia would release another 69 MT.

Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please do not allow this project to put our coast, our communities and our climate at risk!

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Barbara Vieira - Staten Island, New York

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

Putting a facility like this right next to the historic community of Dodge Cove will massively disrupt the lives of its residents.

Aurora LNG violates international siting standards which require such projects to be located away from population centres and other marine traffic.

Noise from the tankers and facility would have a significant adverse impact on the harbour porpoise, a species of special concern in British Columbia.

Digby Island lies in a Nationally Significant Important Bird Area, and great blue herons have a nesting colony on the island.

This facility and upstream development would produce 15 megatonnes of carbon pollution, while the gas shipped to Asia would release another 69 MT.

Aurora LNG would make it impossible for BC to meet its legislated climate targets and is at odds with both national and international efforts to reduce emissions.

Please do not allow this project to put our coast, our communities and our climate at risk!

This letter was created with the use of an online letter writing tool at wildernesscommittee.org

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Personal Information Withheld - Burnaby, British Columbia

I believe the environmental risks of our province need to be considered and given serious consideration before any mass project. The risks involved with this project in such a fragile precious ecosystem are not worth it. On top of that the risks involved with fracking in order to get the necessary amount of natural gas to support this plant are also not worth it. It is a short sighted project to line the pockets of a few while risking so much and to leave the tax payers paying for it long after it's run its course. Please consider the voice of the many and not just the few.

Thank you

JIm Bradshaw - Maple Ridge, British Columbia

British Columbia Environmental Assessment Office

RE: Comment on Aurora LNG

Please accept this letter as opposing this Aurora LNG project since the complete BC LNG push by the BC Liberal Government is totally irresponsible given the impossibility of meeting our climate targets such action creates.

The era of fossil developments are over as such activity only further imperils our climate. It is time to face the facts and get your heads out of the sand and do something to develop renewable energy.

This letter was created with the use of an online letter writing tool at wildernesscommittee.org

CC: Premier Christy Clark, Minister of Environment Mary Polak, Minister of Natural Gas Development Rich Coleman

Nii Jiits K am Ha an - Vancouver, British Columbia

Our next 7 generations need Mother Earth intact waterislife Our survival depends on the lands & waters, please do not take it awayby putting in liquid natural gas pipelines to our naturally pristine lands & waters is potential for irreparable damage

The lands & waters for indigenous peoples is akin to mainstream society's cupboards & fridge

Its a stand for ALL humankind & our next 7 generations

Personal Information Withheld - Terrace, British Columbia

Build it! Just wolves and deer no salmon streams. It's a no brainer

Personal Information Withheld

It is wrong for our elected government to not keep environmental standards at the highest level possible. We only have one planet and it is in grave danger because of choices made by all of us. Be a leader in keeping British Columbia natural and meeting climate change targets. Say NO to destroying the province's natural world class beauty with fracking and LNG plants. We need leadership from all levels to protect not destroy the air we breathe and the water we need for survival.

Ian - Vancouver, British Columbia

Plants like these have been built all over the world, and in all cases, fish harvesting in the regions became obsolete for decades. It has long been a sustainable industry in the area, and this would adversely impact the local economy for short term gains, as the market for LNG wanes. We should be preserving Canada's north for future generations.

Personal Information Withheld - Chemainus, British Columbia

JUST FORGET ABOUT it AINT EVER GOING TO HAPPEN

Personal Information Withheld - Salish, British Columbia

NO LNG. Skeena deserves better. BC deserves better. The evidence of damages that will occur are everywhere, please be aware of the consequences, and please do not approve the LNG terminal in the Skeena.

Dave Anderson - Smithers, British Columbia

Economically - Financially - No long term value - Environmentally unstable - no long term benefit with the risk of air water pollution. The list goes on how stupid the government can be in even think this project or any others like will benefit Canada never mind BC or Prince Rubert. If the government thinks there is a market for LNG in China go to the NASA Earth site and have a look at the massive solar fields they are building.

Their solar program make Canada look as they are in the dark ages!

Which maybe true because our trade mentality is sell ourself sort ever since it discovered beaver and maple syrup. Just give it away !

China is the largest importer of Lithium that says something about the value of LNG!

Susan E Smith - Smithers, British Columbia

Once again the BC Liberal Government is trading off the the long term health and future of our priceless coastal habitat against the false promises of future prosperity!

The proposed Aurora LNG fracked gas plant proposed by Nexen, for construction adjacent to Delusion Bay, puts at risk critical habitat for steelhead, coho and sockeye salmon. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.

Flaring gasses pose risks and other concerns for bird life and mammals. Roadways, plant construction and acidification of the air and water will directly damage wetlands and the eel grass habitat vitally important to salmon. Tanker noise will impact harbour porpoise, a species of special concern.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage.

As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. This project would also smash through BC's legislated climate targets and blow Canada's carbon budget.

Personal Information Withheld - Squamish, British Columbia

British Columbia is not for corporate Sale leave the oceans alone.

Sarah Burgess - Prince Rupert, British Columbia

I disagree with this project because of its close proximity to the people of dodge cove. I know that flaring does happen at lng facilities, and have been around flaring once in my life. It instantly gave me a headache, and I felt unwell. We were in a vehicle, and approximately half a km to one km away. I cannot imagine it would be healthy to be living around this all the time. Not to mention the flammability of natural gas. This gives me a very uneasy feeling. Especially since I have such good friends that I cherish very much in dodge cove. This project does not belong in prince rupert. I am not against jobs, nor am I against this town growing, but I don't believe lng is the way to do it! I would love for our town to grow and prosper, and there are so many wonderful people here. I feel like we can come up with better ideas that would bring more long term local jobs. So many of my friends are talking about leaving if this project goes through. People that contri bute to this town. Business owners (several), teachers, carpenters, people in tourism, nurses, musicians, welders, mariners, librarians(to name a handful). People that have always loved this amazing city, but like I, just can't see themselves living in an lng town. The thought of picking up and leaving a place I love so much, and have those relationships broken as we scatter across Canada really is not something I want to think about. I honestly dread this lng decision almost every day, and hope that it doesn't come to fruition.

Peter van Eunen - Lower Mainland, British Columbia

Peter Van Eunen - The question is asked, in the face of building an industry that may be obsolete in 30 yrs. does it even make sense to put the entire region at risk? It would only make sense if all you're concerned with is short term (dubious) profits and you don't give a damn about the region or the people who call it their home. Christy!!!

Rhondi Hurlbut - Valemount, British Columbia

Please put the resources and focus of our tax dollars into renewable and sustainable energy. Water and all it sustains seems to be nowhere on the conscience or consideration of this government. Underground, rivers, streams and oceans are all in danger due to lack of oversight or foresight. Geothermal, solar and wind are successfully being used in so many parts of the world and we are still ripping and polluting for short term gain and a misguided economic philosophy that no longer works for the people or the earth.

Bradford Bryce - CA, USA

I hope that you will deny this permit and never allow this project to be built. It will destroy yet another beautiful place in exchange for corporate earnings

Ann MacLeod - Victoria, British Columbia

No thanks to the proposed LNG Digby Island project. I want to see BC develop reneval energy sources asap and stop compromising our pristine river systems, watersheds and shorelines with oil and gas projects. NO NO NO.

Personal Information Withheld - Ontario

I'm ashamed to admit I'm Canadian. I'm ashamed that we are no longer viewed as environmental leaders in the world. The risk to all the inhabitants of Digby Island is just too great! Please, make the right choice.

Trina Wahl Whittaker - Port Albernie, British Columbia

Absolutely opposed to this. My family has ties to Dodge Cove on Digby Island spanning 5 generations. There is even a lake on the island (in a marsh that should be protected, not destroyed) named after my forefathers.

Why not invest in renewable, clean energy? Not destructive, quick fix money makers at the expense of the environment and residents.

David Bowering and Josette Wier - Terrace and Smithers, British Columbia

Please find attached our comments regarding the Aurora application.

Comment Submission

Personal Information Withheld - Dodge Cove, British Columbia

Biodiversity is necessary to support ecosystems and support human life on earth. That is amazing: ESSENTIAL FOR HUMAN LIFE.

Where in the Aurora LNG Final application does it address the fact that this export terminal would be drastically effecting the biodiversity on the B.C. coast and address the impacts it might have - to Canada - to the world - the impact to human life.

This article is clear that the biodiversity of the B.C. Coast is GLOBALLY SIGNIFICANT. I believe that this fact needs to be looked at, and full impacts that this project (especially in the site proposed for the rich and sensitive Skeena Estuary which is a major source for B.C. coastal life) needs to be part of the assessment for this project. Many references below exist that provide further information on the biodiversity of the B.C. coast, and yet throughout the Aurora LNG Final application there seems to be many gaps on impact, missing species that use Digby Island and the Skeena Estuary, and the impact that this project would have on those species. It would be interesting for the impact to the human species on a larger scale to also be assessed, not just a "local" or "regional" impact.

"The conservation of biodiversity, first recognized in the early 1980s (Wilson 1988), provides economic, scientific, cultural, and aesthetic values, but its greatest value is in maintaining the life-sustaining systems of the biosphere (UNEP 1992).

In 2005, another global assessment conducted by many of the same organizations reported that humans have depleted 60% of the world's grasslands, forests, farmlands, rivers, and lakes (MEA 2005a). They also reported that human activity is putting such a strain on the natural ecological functions that the ability of the planet's ecosystems to sustain future generations can no longer be taken for granted (MEA 2005a).

This accelerated extinction is the result of human activities such as altering and destroying habitat, pollution, over-harvesting species, introducing non-native species, and producing greenhouse gases that are causing a changing climate (Wilson 1992). Globally, the pressures on biodiversity are expected to continue or increase, further compromising the ability of these ecosystems to support human life (MEA 2005a, 2005b).

Canada is the steward of major portions of the world's tundra, boreal and temperate forest, and aquatic ecosystems.Canada has an estimated 24 percent of the world's wetlands and constitutes about 20 percent of its circumpolar area. It is also one of the few countries in the world that maintains large, relatively unfragmented ecosystems with functioning natural processes.

British Columbia's Biodiversity
British Columbia occupies 10% of Canada's land area while containing more than half of Canada's vertebrates and vascular plants and three-quarters of its bird and mammal species (BCMELP 1993). Over 300 species of birds breed each year in British Columbia – more than any other province in Canada. Sixty-five species breed nowhere else in Canada and for several other species, British Columbia (specifically coastal British Columbia) holds the majority of the world population.

Coastal BC's Biodiversity
Marine coastal ecosystems are among the most productive and diverse communities in the world (Poore and Wilson 1993). The rugged BC coast, with its characteristic fiords and islands, provides an environment that hastens the divergence of species by separating and isolating populations. As time goes by, isolated populations grow more adapted to their local environment and, in doing so, diverge in appearance or behaviour from other populations of their species. It is not surprising that 44 of the 62 vertebrate subspecies and significant populations endemic to coastal British Columbia occur on coastal islands (including Vancouver Island). As such, coastal BC is the most biologically diverse area of British Columbia. Specifically, ·78% of all the mammal species in BC (D. Nagorsen, unpubl. data compiled for BC Ministry of Environment, 2004), ·64% of the birds that regularly breed in BC (R. Cannings, unpubl. data compiled for BC Mini stry of Environment, 2004), ·64% of BC's amphibians (Green 1999), ·69% of BC's reptiles (Gregory and Gregory 1999), and ·67% of BC's freshwater fish species (McPhail and Carveth 1994) are found on the coast.

Even more compelling is the extent to which endemic (meaning locally unique and native) species occur on the coast:
·Two-thirds of the mammal species and subspecies that are found only in BC occur nowhere else in the province but the coast (D. Nagorsen, unpubl. data compiled for BC Ministry of Environment, 2004).
·Three-quarters of the subspecies and significant populations of freshwater fish found only in BC are exclusive to the coast (McPhail and Carveth 1994; BC Ministry of Environment, unpub. data, 2004).
·All of the bird subspecies that breed only in BC do so exclusively on the coast (R. Cannings, unpubl. data compiled for BC Ministry of Environment, 2004).
·In the Queen Charlotte Islands alone, 8 of the 12 coastal endemic breeding birds occur, including local variants of Stellar's jay.
·Approximately 10% (238 of a total 2316) of the province's vascular plant taxa, including subspecies and varieties, occur only on the Pacific coa st between Alaska and Mexico (Douglas et al. 2002).

Coastal and Marine Birds
There are over 200 species of common coastal birds with more than 120 species connected to our marine waters. More than five million seabirds use the B.C. coast as breeding habitat (Rodway 1991) including storm-petrels, rhinoceros auklets, ancient murrelets and Cassin's auklets (Gaston 2008). More than 75% of the global population of Cassin's Auklets breed and forage on islands and in the waters off the Queen Charlotte Basin.

Marine Plants
Marine plants include the microscopic phytoplankton and the larger species referred to as macroalgae (seaweed) and aquatic angiosperms. In British Columbia, more than 500 species of macroalgae have been recognized, making up about 4.5 % of the world's total marine algal species (Tunnicliffe 1993, Hall 2008).

Cold Water Marine Corals
BC has a diverse range of cold-water corals with at least 61 recognized species (Jamieson et al. 2006) from many different groups including Gorgonian corals, Stony corals and Sea pens. Jamieson et al. (2006) provide a comprehensive overview of taxonomy of the cold-water corals of the B.C. coast.

Hexactinellid Sponge Reefs
BC's marine environment contains some of the only siliceous (hexactinellid or glass sponge) reefs in the world (Thompson 1981, Prescott-Allen 2005). Hexactinellid sponge reefs were thought to be extinct until 1987, when they were discovered in the waters of BC's Hecate Strait and Queen Charlotte Sound (Conway 1999). These glass sponge reefs can extend 18 metres in height from the sea floor and collectively cover an estimated 1,000 square kilometres (Fargo et al. 2007).

Terrestrial invertebrates
While significant efforts have been made to document species of birds and mammals, little is known about canopy arthropod communities. There are an estimated 163,487 species of insects in North America, of which only 66% are taxonomically known (Redak, 2000). In Canada, approximately half of the estimated 66,000 insects have been described, and in British Columbia there may be as many as 40,000 arthropod species, many of which are undescribed and associated with ancient forests. (Winchester, 2010 http://web.uvic.ca/~canopy/index.html). Winchester's working group has suggested that canopies in the Pacific NW may be as diverse, if not more than, tropical rainforests.

Coastal BC Ecosystems
The biodiversity of coastal British Columbia is of global importance. The province's remaining old-growth coastal rainforests represent approximately one-quarter of all remaining coastal temperate rainforests worldwide (BCMOF 2004). These forests are globally rare, yet they have exceptionally high biological production and biological diversity. In addition, the province bears some of the global responsibility for at least 19 coastal species that, in addition to being at risk in BC, are also at risk globally (CDC 2005). " References

Much of the language in the above passages is paraphrased or taken verbatim from technical papers in the British Columbia Coast and Marine Environment Project 2006, Hall's 2008 State of the Ocean in the PNCIMA, and Biodiversity BC's Taking Nature's Pulse. The BC Coast and Marine Environment Project 2006 started in 2004 and was planned and funded in collaboration with Fisheries and Oceans Canada, the University of British Columbia Fisheries Centre, and the University of Victoria Geography Department, and Environment Canada. The Project focused on a region extending westward from the height of the Coast Mountains and included the marine area within Canada's 200-mile limit. The full report can be found at http://www.env.gov.bc.ca/soe/bcce/images/bcce_report.pdf. Biodiversity BC was formed as a partnership of government and non-government collaborations in 2005. Its funding ended in 2009. The full report can be found at http://www.biodiversitybc.org/

BirdLife International. 2004. State of the World's Birds 2004: Indicators for our changing world. Cambridge, UK.
BCMELP (Ministry of Environment, Lands and Parks). 2006. British Columbia Coast and Marine Environment Project, 2006. Biodiversity Ministry of Environment, Victoria, B.C.
BCMELP (Ministry of Environment, Lands and Parks) 2000. Extinct and Extirpated Species. Wildlife in British Columbia at Risk brochure. Wildl. Br., Victoria, BC. wlapwww.gov.bc.ca/wld/documents/extinct.pdf.
BCMOF (Ministry of Forests). 2004. 2004/05-2006/07 Service Plan. Victoria, BC. www.bcbudget.gov.bc.ca/bgt2004/sp2004/for/for_appendix1.htm.
Biodiversity BC. 2007. Taking Nature's Pulse: The Status of Biodiversity in British Columbia. http://www.biodiversitybc.org/EN/main/where/132.html
CDC (BC Conservation Data Centre). 2005. BC species and ecosystems explorer database. Ministry of Environment, Victoria. srmapps.gov.bc.ca/apps/eswp/.
Conway, K. W. 19 99. Hexactinellid sponge reefs on the British Columbia continental shelf: geological and biological structure with a perspective on their role in the shelf ecosystem. Canadian Stock Assessment Secretariat Research Document.
Douglas, G.W., D. Meidinger, and J. Pojar (eds.). 2002. Illustrated flora of British Columbia, vol. 8: General summary, maps, and keys. Minist. For. and Sustain. Resour. Manage., Victoria, BC.
Fargo, J., L. MacDougall, and I. Pearsall. 2007. Ecosystem overview: Pacific North Coast Integrated Management Area (PNCIMA): Appendix G: Groundfish.
Gaston, A. J. 2008. Seabirds. Environment Canada. in http://www.ecoinfo.ec.gc.ca/env_ind/region/seabird/seabird_e.cfm
Green, D.M. 1999. The amphibians of British Columbia: A taxonomic catalogue. Wildl. Br., Minist. Environ., Lands and Parks, Victoria, BC. Wildl. Bull. B-87.
Gregory, L.A., and P.T. Gregory. 1999. The reptiles of British Columbia: A taxonomic catalogue. Wildl. Br., Minist. Environ., Lands and Parks, Vi ctoria, BC. Wildl. Bull. B-88.
Hall, A. 2008. State of the Ocean in the Pacific North Coast Integrated Management Area (PNCIMA). David Suzuki Foundation. 159pp.
IUCN (World Conservation Union). 2003. 2003 IUCN Red list of threatened species. www.redlist.org.
Jamieson, G. S., and L. Chew. 2002. Hexactinellid sponge reefs: areas of interest as Marine Protected Areas in the North and Central Coast. Canadian Science Advisory Secretariat Research Document:77.
Jamieson, G. S., N. Pellegrin, and S. Jessen. 2006. Taxonomy and zoogeography of cold water corals in explored areas of coastal British Columbia. Canadian Science Advisory Secretariat Research Document:49.
McPhail, J.D., and R. Carveth. 1994. Field key to the freshwater fishes of British Columbia: Draft for 1994 Field Testing. Aquatic Inventory Task Force, Resources Inventory Committee, Victoria, BC.
MEA (Millennium Ecosystem Assessment). 2005a. Ecosystems and human well-being: Biodiversity synthesis. World Resource s Institute, Washington, DC. www.millenniumassessment.org//en Products.Synthesis.aspx.
MEA (Millennium Ecosystem Assessment). 2005b. Ecosystems and human well-being: Synthesis. World Resources Institute, Washington, DC. www.millenniumassessment.org//en/Products.Synthesis.aspx.
MEA (Millennium Ecosystem Assessment). 2005c. Ecosystems and human well-being: Wetlands and water synthesis. World Resources Institute, Washington, DC. www.millenniumassessment.org//en/Products.Synthesis.aspx.
Prescott-Allen, R. 2005. Coast Information Team Review Report. Cortex Consultants Inc.

Poore, G.C.B., and G.D.F. Wilson. 1993. Marine species richness. Nature 361:597-598.
Redak, Richard. 2000. Arthropods and Multispecies Habitat Conservation Plans: Are We Missing Something? Environmental Management, Volume 26, Supplement 1 Rodway, M. S., and M. J. F. Lemon. 1991. British Columbia seabird colony inventory: Report # 8 – Queen Charlotte Strait and Johnstone Strait. Technical Report Series 123:82.

Stuart, S.N., J.S. Chanson, N.A. Cox, B.E. Young, A.S.L. Rodrigues, D.L. Fishman, and R.W. Walter. 2004. Status and trends of amphibian declines and extinctions worldwide. Science 306:1783-1786.
Thompson, R. E. 1981. Oceanography of the British Columbia coast. Canadian Special Publications of Fisheries and Aquatic Sciences 56:291.
Tunnicliffe, V. (1993) Biodiversity: the marine biota of British Columbia. in Our Living Legacy: Proceedings of a Symposium on Biological Diversity. M. A. Fenger, E. H. Miller, J. A. Johnson & E. J. Williams (eds), Royal B. C. Museum, Victoria: pp. 191-200.
UNEP (United Nations Environment Programme). 1992. Preamble, convention on biological diversity. United Nations. www.biodiv.org/convention/articles.asp.
UNEP (United Nations Environment Programme). 2001. Global biodiversity outlook. United Nations. www.biodiv.org/gbo/default.asp.
Wilson, E.O. (ed.). 1988. Biodiversity. National Academy Press, Wash ington, DC., 521pp.
Wilson, E.O. 1992. The diversity of life. W.W. Norton and Co., New York.
Winchester, Neville http://web.uvic.ca/~canopy/winchest.html
World Conservation Monitoring Centre. 1992. Global biodiversity: Status of the Earth's living resources. Chapman and Hall, London, UK. xx + 594pp.

https://www.raincoast.org/2011/05/bc-coastal-biodiversity/

Sheila Dobie - Saltspring Island , British Columbia

Dodge Cove is a settlement of people! This is not land to just do what you want with. It is the home to many people in every season and has been for generations- including a vast history of First Nations use and habitation.
I lived in this village for 28 years raising my family.

My friends living there have described what seems like complete disregard to their presence- thus company needs to be taken to task for their plan to impact such a community. Water quality values, recreational areas and residential quality of life are all at stake. The Environmental values are being threatened- thus is a very sensitive ecological zone. I'm astonished that this project is proceeding based on a development for an energy type with no future.

Please refuse thus Development!

Invest time and resources in true renewable energy!

Roland Alcock - Sooke, British Columbia

Dear EAO,

I am writing to urge you to reject the huge liquid natural gas (LNG) plant proposed by Nexen on Digby Island not far from the mouth of the Skeena River in BC.

Firstly, I oppose the approval of the Nexen Aurora LNG terminal on Digby Island as it poses a very significant threat to the second-largest salmon run in Canada and the communities and entire ecosystems that depend on it. There is direct experience from Russia of the ecological damage such a huge LNG industrial development close to the estuary of a salmon bearing river can do. The site of the proposed Digby Island plant would be a disaster for migrating sockeye, steelhead and coho salmon as it is an estuarine and wetland environment similar to Flora Bank at the mouth of the Skeena river. These habitats are the crossroads for migrating juvenile and spawning salmon.

Secondly, and even more seriously, the proposed project violates the self-determination and sovereignty of the the Metlakatla, Lax Kw'alaams and Gitxaala first nations as the proposed site is within their Traditional Territories. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, BC and Canada must obtain free, prior and informed consent from First Nations before approving the project. Approving it would break Prime Minister Trudeau's promise to prioritize and rebuild relationships with First Nations.

Thirdly, there is the much bigger context of the proposed project in that it completely opposes and renders moot any Government of Canada commitment to more direct and immediate actions to combat climate change.

In late 2015 the IPCC released its latest report and this distinguished scientific body has continued to up the ante and sound the warning that anthropogenic causes are certainly behind the unprecedented global warming being experienced in recent decades. Scientists at NASA and NOAA have recently reported data to show the year 2016 did in fact break the former 2015 record as the warmest globally ever recorded!

The dire impacts from these climate changes have already been felt in BC with the expansion of the devastation caused by the mountain pine beetle, and the increasing appearance of the tick that causes Lyme disease. These are very real economic and health impacts which already affect the people of BC directly!

In addition, there are serious consequences for the Canada's North as climate change is radically altering the environment and threatening the way of life of the northern indigenous peoples.

In the light of all this, it is unconscionable that the government of BC is actively encouraging and enabling the growth of the LNG industry. The huge export volumes contemplated will generate millions of tons of carbon added to the earth's atmosphere. These impacts will stem from the burning of the fossil fuel and also more seriously from methane pumped into the atmosphere from infrastructure leaks and from "fracking" activities which smash the rock strata to release the methane gas.

These climate change contributions will not just cause environmental impacts to worsen "somewhere far away" - the effects will be felt right here in BC! "Exporting" emissions does not absolve BC from suffering the impacts. The current BC government policy is directly supporting and adding to the destruction of the BC economy and threatening the health and well being of BC citizens.

In addition, there is no way to both approve this project and honour the 1.5 degree global warming limit agreed to by the Government of Canada at the recent Paris conference.

For example a similar LNG terminal project has been proposed by Pacific Northwest/Petronas on Lelu Island right at the mouth of the Skeena. To quote the Canadian Environmental Assessment Agency's (CEAA) conclusion on page 52 of the draft report on that project "The Agency concludes that the Project is likely to cause significant adverse environmental effects as a result of greenhouse gas emissions after taking into consideration the implementation of best achievable technology and management practices and compliance with the B.C. Greenhouse Gas Industrial Reporting and Control Act".

On the basis of the climate change impact of these two projects alone, the BC Government should work with the Federal Government, on behalf of all Canadians to:-
Place an immediate moratorium on all further natural gas expansion and "fracking" activity. Fracking is a very destructive method of extreme energy extraction and a step in the wrong direction for the climate, water and public health.
Halt or seriously slow down plans to massively increase LNG production and export.
Permanently ban the construction of more pipelines across BC designed to enable shipment of millions of tons of fossil fuels for export.

The BC Government could then divert the money that is earmarked for massive infrastructure upgrades in support of LNG, including the expansion of BC Hydro's generating capacity via the proposed Site C dam and instead implement home energy efficiency improvement programs, invest in green energy development (especially wind power), and fund green energy R&D at our institutes of learning and research.

Many more jobs will be created in BC on a permanent sustainable basis by building a local energy industry based on renewables. Germany has already made enormous strides in employing solar power as have several US states such as Arizona. BC could do the same, as could the rest of Canada.

All that is required is some vision, leadership and a recognition that the government in power today is not just working to secure a healthy and prosperous future for the present, but owes a similar debt to the future generations of the citizens of BC and Canada. The citizens of BC will not stand idly by while the BC Government blindly aligns with and supports the forces that would continue to destroy the earth's environment and download billions of dollars worth of agricultural, forestry, fisheries, coastal property, and other economic and health damages onto future generations of Canadians.

I therefore urge the BC EAO to reject the proposed Nexen Aurora LNG terminal on Digby Island near the Skeena estuary.

Thank you.

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Virgil Pauls - Winnipeg

Dear EAO,

Aurora LNG threatens salmon and wildlife

The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.

Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

Aurora LNG threatens community health and safety

The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

Aurora LNG threatens our climate

As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

Say no to Aurora LNG!

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Mary-Ann Reid - Vernon, British Columbia

Dear EAO,

Please protect Canada--our home. Please, please, do not allow the LNG fracking practises proposed by Nexen. Our water and all the life in and near our rivers and oceans is fragile, and our land is precious. We depend on the health of our land, water, salmon, and all other wildlife. This project puts our environment and human life at risk. Say NO to Aurora LNG!

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Nicole Boon - Maple Ridge, British Columbia

Dear EAO,

I a deeply concerned about the threat the Aurora LNG plant will have on Skeena salmon and wildlife. The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.

Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

This plant will also threaten community health and safety. The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

Finally, Aurora plant threatens our climate. As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

Clearly, the Aurora LNG plant is a terrible idea. One that this province does not want or need.

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kathleen Williams - Lehigh Acres

Dear EAO,

Sincerely,

Kathleen Williams, Lehigh Acres

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Allen Olson - Minneapolis

Dear EAO,

Sincerely,

Allen Olson, Minneapolis

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Mary Thomas - Richmond, British Columbia

Dear EAO,

Sincerely,

Mary Thomas, Richmond

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

giana peranio paz - hendersonville

Dear EAO,

Sincerely,

giana peranio paz, hendersonville

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

mandi T - Los Altos

Dear EAO,

Sincerely,

mandi T, Los Altos

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Walter Firth - Wollstonencraft

Dear EAO,

Sincerely,

Walter Firth, Wollstonencraft

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

February 26, 2017

Amanda Lee - Burnaby, British Columbia

Dear EAO,

Please say no to Aurora LNG.

The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Becky Quirk - Nelson, British Columbia

RE: Comment on Aurora LNG

I am writing to express my opposition to the Aurora LNG Dodge Cove project.

My opposition is based largely on the known and unknown environmental impact this project would have. Permitting a project of this nature would be contrary to our obligation to protect our treasured wildlife of our province

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman From Subject Received Categories Becky Quirk Protect Dodge Cove from Aurora LNG Sun 6:27 PM lies in a Nationally Significant Important Bird Area. In addition, the noise resulting from both the tankers and the facility itself would adversely affect the harbour porpoise.

The project itself and the associated development would produce 15 megatons of carbon pollution every year. The gas shipped to Asia which this project is facilitating would cause another 69 megatons. It is not reassuring that a LNG pipe with similar features to the project proposed here has recently had a leak and even the experts are not sure of the environmental effect of that leak.

http://www.cbc.ca/news/canada/north/alaska-underwater-pipeline-leak-1.3987159
In short, I am asking you to honour climate targets, protect our dwindling wildlife, and protect that unique nature of our province by stopping this proposal from proceeding.

Thank you.

This letter was created with the use of an online letter writing tool at wildernesscommittee.org

Jon Healey - Salt Spring Island, British Columbia

Dear EAO,

For the sake of the common people you serve do not allow Aurora to construct an LNG plsnt on Digby Island.

When I was groeing up on the coast in the 40s and 50s we Had a thriving salmon fishery. Employing thousands of us. No longer;...instead we have hollowed out or derelict communities, boat basins full of derelict fishing vessels and poverty. The causes are varied and do include over fishing. But a major, possibly the most important cause has been habitat destruction. by industrial develoment. The fishery could be revived, provide employment for thousands and support healthy communitied. But not if industries such as Petronas and now Aurora LNG are permitted to contunie the destruction of important habitat. The serous deleterious effects of these developments can not be avoided or satisfactorily mitigated. For the sake of the common people you serve do not allow Aurora to construct an LNG plsnt on Digby Island.

Thank you

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

February 25, 2017

Personal Information Withheld - Dodge Cove, British Columbia

Community Health

6.6.5.2. If construction is to occur continuously, 7 days a week, with two shift rotations each day (for approx. 5 years) where is the studies on how this will affect community health? What is the exact number of "10% of construction management workforce to be hired from the LAA"? Is that 1 person, 10 people, what? If 95% of the 5000 man work camp is to be fly-in/fly-out workers, that will be 4750 men flown in and out on a two-week rotational basis. How will the increase in flight traffic over Digby Island effect the communities there, how many planes is that, what would the increase in noise and air emissions from those planes alone be, or the traffic noise and air emissions from transporting those workers by bus to the workcamp directly behind Dodge Cove homes?

Table 6.6-23 Fails to include the new propane storage terminal slated for Ridley on the Potential Cumulative Effects on Community Health.

6.6.6.2 CNOOC-Nexen's claim that the Aurora LNG terminal is also expected to have positive effects on community health and wellness need to be supported with data. "While not considered in the assessment of cumulative effects, the Project is also expect to have positive effects" seems to be unsupported, therefore questionable. For communities such as Dodge Cove and Crippen Cove, there do not seem to be any positive cumulative effects.

6.6.6.3 Residual Cumulative Effects
"depending on the extent and success of mitigation measures implemented by project proponents, residents of the RAA may experience rapid changes in personal support networks and social environments, due to rapid influxes of population, increased levels of disposable income and a general expansion of RAA communities (includes changes in crime)" "mitigation measures proposed by Aurora LNG and other project proponents are therefore expected to manage to an acceptable level the cumulative adverse effects on personal support networks and social environments within the RAA" Where is the data to support whether or not these mitigation measures will work? Where is the data on how drastically these changes will affect the regional communities? Baseline data needs to be supplied on existing conditions, and more information supplied on the mitigation measures. Simple statements from the proponent saying that they are confident that mitigation measures will work is not enough.

Summary Page 6.6-108
"Cumulative effects with the project on community health and wellness are expected to be high in magnitude, extend throughout the RAA, to occur continuously over the long-term and within a socio-economic context that is not resilient to change. The Project's contribution to cumulative effects is reversible following decommissioning." These seem to be contradictory statements. How are the cumulative effects reversible?

Residual Cumulative Effects Page 6.6-109 "the combined area of all project footprints is relatively small compared to the total available area within the RAA from which country foods harvesting can occur"
What about the project footprint compared to the total area in the LAA from which country foods can be harvested? The impact of these projects all in the one small local area will be drastic, and less so at a regional level.
"The magnitude of cumulative effect on country food harvesting due to land taken up by reasonably foreseeable projects will be low" what supports this statement

Summary Page 6.6-110
"The Project's contribution to a cumulative change in harvested foods will be low in magnitude and primarily occur within the LAA" "due to the relatively small size of affected harvesting areas relative to that available within the RAA, effects occur within a socio-economic context that is resilient to change" Saying that the changes will be mostly in the LAA, and comparing the size to the entire RAA is not an appropriate measurement.
"adverse cumulative effects on harvested foods will be moderate in magnitude"
"effects will be reversible following decommissioning""because of the large size of the RAA, and availability and abundance of terrestrial and marine country food species available for harvesting, cumulative effects occur within a socio-economic context that is resilient to change"

Where is the data to back up these statements? The Project destruction of large sections of the Skeena River Estuary, the permanent irreversible loss of 6,180 square metres of eelgrass (that supports marine food chains) will have high magnitude cumulative effects on country food harvesting, and will be irreversible. The permanent removal of entire ecosystems and old-growth forests on Digby Island and therefore food harvesting cannot just be reversed. The accumulation of toxins over time, in the soil and vegetation does not support this statement; how would this be reversible?

Page 6.6-111 "it is unlikely that the magnitude of predicted effects will be as high as predicted in this assessment, therefore the likelihood of cumulative effects on country foods, is considered low."
This is only supported by the assumption that all the proposed projects in the LAA will not be built, meanwhile this fails to recognize the residual cumulative effects that Aurora LNG will have on the LAA.
Table 6.6-24 claims that the residual cumulative effects on community health ore low to moderate in magnitude, resilient in context, low in likelihood, and reversible. Where is the data and baseline studies to support these claims?

Page 6.6-113
"vulnerable populations and residents of Dodge Cove and Crippen Cove are more likely to disproportionately experience adverse effects on community health and wellness due to lower levels of resiliency to change (i.e., there is low capacity for community health and wellbeing to recover from a perturbation (Project-effects) in consideration of baseline conditions among these populations)"
No baseline conditions on these populations are presented with this statement. How much more likely to experience adverse effects?

Page 6.6-113
"Thus when they do visit nearby communities (e.g. due to Project-related work or following the completion of shifts) they will be expected to conduct themselves in an appropriate manner" Does this mean that workers will be allowed to "visit" Dodge Cove and Crippen Cove, and Prince Rupert? Just because they are expected to behave in an appropriate manner doesn't mean that that willl actually happen (e.g. much mention has been made of increased levels of crime, drug and alcohol use, and prostitution to supply camp workers) so how will this affect community health - especially on communitites that at present have none of these problems?

6.6.8 Prediction Confidence
"It is also not possible to predict with high confidence how individual households will respond to Project opportunities, or experience change in conditions affecting health, due to individual motivations and actions"
Since there is a complete lack of baseline data to support how the changes will take place in these local Pacific Northwest communities, it is impossible to predict with any confidence "it is difficult to predict with precision changes in community health and wellness in either the residual effects case or in the cumulative effects case" does not support the statements that the residual effects or cumulative effects would be low/reversible.

lake

Peter J Williams - Houston, British Columbia

The fact of the matter is Oil and Gas industry are what is wrong with the world. Only the corrupt governments and people directly involved benefit financially. This is as old as corruption itself. To the rest of us(including those who can not speak for themselves) this is about life. It is proven that Oil and Gas industry destroys the environment everywhere they go especially where it is extracted. It is also proven that WE tax payers always get the bill for so called clean ups and reclamation. Oil and Gas industries get paid millions of dollars a year just to be here. They then allege losses for the year and sue Canada for this alleged loss. They use tactics like paying Gitxsan Development to sell out Gitxsan people and traditional territories. Gitxsan Development Gordon Sebastien, the elder gets paid over $22 million dollars a year to destroy his own nation. Oil and gas industry do not let facts get in their way because they clearly believe they own everythin g and everyone here.

Personal Information Withheld - Dodge Cove, British Columbia

1)In all sections of the final application: changing the language of the Final Application to sometimes include Dodge Cove or Crippen Cove does NOT mean baseline studies are done or that the impacts to the residents of Digby Island are appropriately addressed.

2)Table 6.6-1 "Change in harvested foods" will effect much further that the prescribed LAA and RAA. The entire Skeena River and people that foodfish from the river could be affected, yet the entire Skeena River is not taken into account, or all the communities that eat from the River. ( RAA looks like it only goes up to Dorreen, does not even include Hazelton, Moricetown or any other communities further) Why is that?
The same could be said for the coastline. It is scientifically proven that the Skeena River salmon range widely up and down this coastline, but where are the changes in harvested foods for other areas that depend on this fish? Or eulachon, or any other harvested foods that could be affected by change in food chain/food web if Skeena River Estuary is impacted?
A description of how this would affect local communities is not the same as having accurate baseline data. Direct change (changes to local harvested foods) and indirect change (e.g. contribution to climate change and food supply) should both be studied.

3)Page 6.6-10 Technical Boundaries
Health Canada has identified the difficulty of general shortage of up-to-date info on health status and the determinants of health for communities and individuals, and a shortage of info on psychological well-being and socio-economic factors.
Health Canada identified difficulty in adapting health info collected for specific reporting and management purposes for use in the assessment of adverse residual and cumulative effects.
Baseline studies need to be accurately done before approval of projects, especially that are this large and would negatively impact community health.

4)Page 6.6-10 Info from Prince Rupert (LHA 52) is used to describe baseline conditions within the LAA. This does not accurately portray baseline conditions in the quiet, safe, rural residential areas on Digby Island.
This fails to capture the impact that CNOOC-Nexen Aurora LNG will have on local small communities especially the residents of Digby Island.

5)Page 6.6-14 The World Health Organization (WHO) broadly defines health as a "state of complete physical, mental and social well-being and not merely the absence of disease or infirmity. Health includes consideration of social, economic, cultural and psychological well-being."
Yet the following determinants of health are completely omitted from the Community Health section of the Application: Education and literacy, Employment and working conditions, Physical environments, Healthy Child Development, Health Services, Gender, and Culture.
These omissions and the fact that very little baseline is available, fails to capture the entire impact that the CNOOC-Nexen Aurora LNG project will have on the residents of Dodge Cove, Crippen Cove, and Prince Rupert.

6) Page 6.6-26 Housing Vulnerability
This fails to capture the latest reports that Prince Rupert (mostly due to increased housing costs due to the LNG "boom") population has recently decreased drastically. As well, many times residents on Digby Island have temporarily residences in town for the ability to stay overnight on very late work nights, or in extreme stormy conditions. That possibility is no longer available as a result of the direct increase in apartment rates.

7) Page 6.6-43, Table 6.6-17 Claims (during construction) that waste management (waste collection and treatment) will have no effect on a change in harvested foods. Claims that Commissioning and Start-up (includes hydro-testing and discharge to the marine environment) will have no effect on a change in harvested foods.
Claims that Natural Gas pre-treatment and natural gas liquids extraction will not effect change in community health and wellness, or a change in harvested foods.
Claims that (during Operation) waste management (collection, treatment if needed, and disposal of solid waste and wastewater, including stormwater and cooling water from the power generation facility water) will have no change on harvested foods. Claims that (during decommissioning and abandonment) that waste management will have no effect on a change in harvested foods.
These claims to have no potential to interact with community health are not considered further.
More information would need to be given to conclude that these interactions will not happen. These statements need to be justified.

8)Page 6.6-44 Change in Community Health and Wellness "all Project components and physical activities identified with in Table 6.6-16 have the potential to affect community health and wellness (for residents of Dodge Cove and Crippen Cove) because they are associated with changes in population, and employment and income" yet Table 6.6-16 Health Benefits of Select Country Foods does not seem to apply to this statement - so what Table is the accurate one?

Page 6.6-44"Because all Project activities and physical works…can interact with community health and wellness, including those without a check mark..this component has been marked as having a potential interaction." So why would they not include a check mark, if the table is supposed to? Why if there is a seperate interaction for residents of Digby Island, why not just include a table showing ALL the components as checked for Digby Island? It is misleading to not checkmark the tables appropriately, but then to include "disclaimers" that the tables should actually be checked.

9)Page 6.6-45 Operations
The statement that natural gas pre-treatment and natural gas liquids extraction, or LNG production (including routine flaring!), and waste management will NOT have an adverse affect on change in harvested foods during operations needs to be studied and justified.

Since very little information has been given on these areas, concluding that they will NOT affect harvested foods seems presumptuous. Flaring DOES affect the surrounding environment and WILL affect harvested foods.

10)Page 6.6-45 Decommissioning and Abandonment There is no description of the length of time it would take for the claim that "remediation and reclamation of the site has the potential to beneficially affect harvested foods by increasing the abundance of targeted species, where harvesting of foods will have been reduced or restricted (by the project)".
Once these entire ecosystems have been removed, including red and blue listed ecosystems, and sensitive areas such as the impact to the rich Skeena River Estuary, where is the evidence that any of it would come back after?
And if it does, how long would that take? How many 100's of years? Old growth forest ecosystems and glacial sands from the time of the caveman cannot just be replaced to what it presently is.

Also "since no adverse effects on the volume of harvested foods from operations to post decommissioning are anticipated this interaction is not considered further."
This claim needs to be justified.

11)Section 6.6.5.1
Claiming that the proximity of the worker camp to Dodge Cove (would be approx 950 m away from closest residence) fails to accurately describe the overlap of the Project into the Dodge Cove Offical Community Plan. A much more accurate measure would be the distance from the worker camp to DODGE COVE OCP Boundary - which would be much closer. Or the description that the worker camp would actually be built across our existing watershed and trail systems - would change the assessment of the change to the Dodge Cove community health and wellness.

12) 6.6.5.3
The statements that air quality, noise, and freshwater acidification and eutrophication will NOT effect Dodge Cove and Crippen Cove residents does not present accurate long-term health effects of the thousands of tons of pollutants that would be released into our air, water, and soil annually.
Page 6.6-65 Health Status "for residents of Dodge Cove and Crippen Cove changes in the acoustic environment..could adversely affect levels of stress and anxiety and therefore health status." contradicts the statement just previously that noise will NOT effect Dodge Cove and Crippen Cove residents. The simple fact that a compressor station with engines comparable to 8 Boeing 747 jet engines will be built in very close proximity to the residences in Dodge Cove, how will that effect personal safety, social support networks, social environments, mental health, stress and anxiety, physical environments, culture?

13)Page 6.6-70 Presence of Workers
The community of Dodge Cove, which is within walking distance from the camp facilities, and Crippen Cove..residents are at a greater risk of adverse effects as..the presence of a large workforce on Digby Island could adversely affect baseline levels of "sense of community belonging" and quality of life.
How will having a 5000 man workcamp within 10 minutes walk of the private homes of Dodge Cove affect: personal safety, social support networks, social environments, mental health, stress and anxiety, physical environments, culture?

14)
14)
Will the residents of Dodge Cove and Crippen Cove be within a gated controlled community that needs constant security and seperation from the rest of the island - simply because the site location of CNOOC-Nexen Aurora LNG is too close in proximity to the present existing safe, residential rural communities of Dodge Cove and Crippen Cove.

15)In the summary Page 6.6-72 "Dodge Cove and Crippen Cove residents and vulnerable populations, who are predicted to experience high magnitude effects"
It is clear that vulnerable populations includes women, children, senior, fixed income households, lower income households, and homeless. The already vulnerable populations in Prince Rupert will be at HIGH RISK to experience negative effects, and the never-before vulnerable residents on Digby Island also will be at HIGH RISK to experience negative effects.
This is unacceptable. Even saying this, how can the claim that "residual effects during Project operations will be low to moderate in magnitude - moderate for residents of Dodge Cove and Crippen Cove" because of the relatively small operational workforce. Relative to what? The operational workforce (of 300 potential workers) alone is 6 X the size of the present full-time residents at Dodge Cove. And how are the adverse affects considered to be shor t term and reversible? In what way is 25 years short-term, or reversible once Dodge Cove and Crippen Cove are changed. How is it considered that the socio-economic context is resilient to change, when it is clearly stated that Dodge Cove and Crippen Cove has low resiliency. If this project is approved, the impacts to Dodge Cove and Crippen Cove will be long term, and irreversible.

16)Mitigation measures Table 6.6-21
The LNG carriers, tugs, and barges will be speeding around at 16 knots within the LAA - the average commercial fishboat travels at 6 knots, the average kayaker much slower. How will this speed impact existing marine traffic at the mouth of Prince Rupert Harbour. Tourists and locals presently kayak around the entire Digby Island, with most focusing on the south end of Digby Island and Delusion Bay.

17)Page 6.6-101 "Project activities and physical works are not expected to result in a degradation of environmental quality that would lead to a change in the quality of harvested foods that would support perceptions that would decrease consumption."
How is this justified? It would seem that removing the entire ecosystems that support food harvesting would lead to a change in the quality of harvested foods, as well as changes to the volume of harvested foods, and the presence of an LNG terminal releasing toxins into the air, water, and soil will affect drastic changes to the local harvested foods as well as perceptions of food quality that would decrease consumption. The dredging that will cause suspension of contaminants back into food chains will also change harvested foods, and the perceptions that would decrease consumption.

"based on the frequency of operational shipping and fishing techniques used within the LAA, the Project is predicted to have a low magnitude effect on marine harvesting" It would be hard to choose a location that would have a higher impact on the marine harvesting in the area, Spire Ledge is well known and the south end of Digby is a rich and essential area for local marine harvesting. This statement needs to be justified, what is CNOOC-Nexen basing this statement on? "it is predicted that the Project will have a negligible effect on harvestable marine resources and thus marine food consumption during operations" is also contradictory to local marine harvesting. That also fails to account for the impact that destruction in the Skeena River Estuary will have for the entire Skeena River and other areas on the coast that the Skeena River supplies marine harvest to.

Claiming a low to moderate likelihood of residual effects on harvested foods in Table 6.6.5.5 need to be justified.. Changes to harvested foods are irreversible, and high likelihood to happen, high magnitude, low resiliency, unlike what the table is showing.

Nancy Thacker

Dear EAO,

This project must not be permitted. The cost to the environment and health of the residents in the area is unacceptable, even under controlled conditions. The habitat of the salmon would be destroyed and the effects of this would ripple down the food chain.

The air, water and soil would be severely compromised. 95% of the local residents surveyed oppose this project - don't the people have a say in the conditions in which they and their ancestors have lived for generations? Our BC government must respect First Nation's Rights and honour Canada's commitment to reducing carbon emissions and climate change targets.

Sincerely,

Nancy Thacker, Victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Valerie Raynard

Dear EAO,

The proposed Aurora LNG project threatens salmon, wildlife, and community health and safety for the surrounding area. Please DO NOT approve it.

Most concerning, it is a threat to the very fragile salmon ecosystem which is part of our identity, our heritage, and our environment as British Columbians.

It makes absolutely no sense to ruin the environmental future and legacy of British Columbians for a short term monetary gain to the government and a foreign multinational corporation.

Politicians are supposed to protect and champion all their constituents' best interests, not those of foreign corporations or the rich elite.

Thank you,

Valerie Raynard

Sincerely,

Valerie Raynard, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Michael Cameron

Dear EAO,

Stop destroying the planet.

Sincerely,

Michael Cameron, Victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

February 24, 2017

Bob George

Dear EAO, I believe our coast to be one of the most amazing areas of the planet, and our Salmon one of creations most special species. If you risk destroying these precious resources, for some temporary monetary gain through the fossil fuel industry, and your gamble doesn't work out, history will look at our generation as the greedy, selfish pigs that we seem to be. This is YOUR responsibility. It will be ON YOU!

Sincerely,

Bob George, Kelowna

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kraig and Valerie Schweiss

Dear EAO,

We write to you to plead for the Skeena salmon that will invariably be killed by the massive fracked gas plant, Aurora LNG, owned by a Chinese oil company slated to be built near Prince Rupert on DIgby Island. For the following reasons, we would like to detail why this plant is so WRONG for the area:

1) It threatens salmon and wildlife. The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho, and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to those posed to Flora Bank salmon by Petronas. Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons, and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction, and acidification of the air and water would directly damage wetlands, important eel grass habitat, and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbor porpoise, a species of special concern.

2) It threatens community health and safety. The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air, and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96% of local residents were opposed to the project. The plant would be built less than a kilometer from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbor is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels, and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams, and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health, and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should NOT be approved.

3) It threatens our climate. As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping, and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

We hope that our explanation of the threats to our wildlife,, human health and safety, and our climate will help you to see that building such an imposing structure will severely and permanently damage our ecologically dependent economy upon which we rely for our very survival. We cannot in good conscience let this plant be built here. Thank you for your understanding and compliance with our needs and wishes.

Sincerely,

Kraig and Valerie Schweiss, Sterling, IL

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Eileen Floody

Dear EAO,

I am truly tired of the complete neglect of wild salmon habitat. The protections for ocean habitat are nonexistent at federal or provincial levels. Salmon are the backbone of the coast, as cliche as that may sound. The assaults they face, from salmon farms, industrialization, water pollution, logging malpractice, ports, dredging, and now LNG facilities, and the worst overall, global warming are combining to bring about the extinction of this vital and iconic species. It is way past time to stop the war on nature. No Aurora LNG. And, what really annoys me - "Aurora" - the name for the northern lights and the goddess of dawn. What an insult! This project only brings death, not light and life.

Sincerely,

Eileen Floody, Tofino

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Evelyn Ball

Dear EAO,

I am writing to you regarding Nexen;s proposal to build the massive Aurora fracked gas plant near Prince Rupert. It would be right next door to Delusion Bay, which provides critical salmon habitat considered to be as valuable as Flora Bank.

Aurora LNG could pose risks similar to the risks posed to Flora Bank by Petronas.

This salmon-killing carbon bomb does not belong here.

Sincerely,

Evelyn Ball, Lockport

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

kara middleton

Dear EAO,

I am very concerned that there is a proposal by Nexen Corporation to build a fracked gas plant near the Skeena estuary, which is a critically important salmon breeding habitat, and also an important wetland. Both salmon habitats and wetlands have been disappearing from our coastal areas at alarming rates; and the climate change, environmental, economic and cultural implications are inestimable.

Please, do the right thing, and say "no" to this treachorous proposal.

Sincerely,

kara middleton, sooke

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Lorinda Campbell

Dear EAO,

Sincerely,

Lorinda Campbell, Vanderhoof

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

bonnie robinson

Dear EAO,

Hello. As a Canadian I am very concerned with the state of our water and our wild fish populations of salmon. I live in the Yukon and have witnessed the decline of salmon for the past 30 years. Very few salmon are making it back to spawn. Right now the Pacific Ocean is in desperate need of protection. You must do all you can to protect wild salmon.

Sincerely,

bonnie robinson, Haines junction

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Personal Information Withheld - Dodge Cove, British Columbia

A few excerpts from an article highlighting concerns regarding proximity of LNG terminals/tankers to communities/existing marine tanker zones and questions regarding emergency situations.

LNG and Public Safety Issues

Summarizing current knowledge about potential worst-case consequences of LNG spills onto water. by JERRY HAVENS Professor, Chemical Engineering, University of Arkansas

"However, limiting discussion to the initial results of a terrorist attack is not necessarily sufficient.
My year-long look at the LNG vapor dispersion issue for the Coast Guard produced a report3 in 1978 that reviewed several predictions by leading authorities of the vapor cloud extent, following spillage of 25,000 m3 LNG onto water. Those estimates ranged from 0.75 mile to a little over 50 miles. The range was narrowed by showing the errors in reasoning underlying the lowest and highest estimates, but the uncertainty range could not be tightened closer than three to 10 miles.

First, the use of a thermal flux criterion that would result in second-degree burns in 30 seconds is not necessarily appropriate to ensure public safety, as such exposure essentially ensures that serious burns will occur at that distance to persons who cannot gain shelter within 30 seconds.Aside from questions about the ability of even the most able to gain shelter in such a short time, questions are also raised about the safety of those less able."

How would Prince Rupert Hospital, schools, elderly, residences, be evacuated? How would emergency services respond to a major accident/malfunction?

From what I have read, no plan has been released publicly to deal with this, and emergency services have been put back onto the Regional District, and Prince Rupert which means many things.

A)The taxpayers will be paying for this B)Assuming the emergency responders in Prince Rupert are not physically injured or dead themselves C)That right now there is no experience in dealing with LNG accidents D)There is not adequate emergency services to respond to anything of magnitude

In the case of an ignitable vapour cloud, how would residents be evacuated when any spark could ignite it (including static electricity?) How would residents of Digby Island be evacuated (assuming they are not immediately dead) when any way on or off the island needs engines, therefore sparks?

"Lower thermal flux criteria (~1.5KW/m2) are prescribed in other national and international regulations designed to provide safe separation distances for the public from fires. Since such lower thermal flux level criteria could increase the distances prescribed in the ABS Group and Sandia reports by as much as one and a half to two times, this end point criteria for ensuring public safety from LNG fires should be reconsidered, especially if the goal is to provide for public safety."

"However, the Sandia report states that cascading events, resulting either from brittle fracture of structural steel on the ship or failure of the insulation that results in LNG vaporization at rates exceeding the capability of the relief valves, cannot be ruled out.

Foamed plastic insulation, widely used on LNG carriers, would be highly susceptible to failure by melting or decomposition. It is a cardinal safety rule that the pressure limits on tanks carrying flammable or reactive materials should not be exceeded, as such excess portends catastrophic rupture of the containment. While the Sandia report concludes that such cascading events would be very unlikely to involve more than three of the five tanks on a typical LNG carrier, the report's optimism in this regard is unexplained.

Once cascading failures begin, what would stop the process from resulting in the total loss of all LNG aboard the carrier?

Other hazards associated with spilling LNG onto water include oxygen deprivation, cold-burns, rapid nphase transitions, and explosions in confined spaces, as well as the potential for unconfined vapor cloud explosions (UVCEs) if the LNG contains significant heavies."

Since the Aurora LNG export terminal is proposed for within 500 metres of the center of the main marine channel with large and small scale existing marine traffic travelling through - I am surprised at the lack of description around potential emergencies. The potential effects to the communities of Prince Rupert and Dodge Cove, including residual and cumulative effects if an accident happened, have not been adequately assessed or described.

Studies on large scale accidents of this nature have not been adequately done by either government or the oil and gas industry, severe information gaps are letting both make assumptions with human lives.

https://www.hsdl.org/?view&did=685565

I would like to include the following well written article by Graeme Pole that highlights many of the concerns that I have regarding the Aurora LNG proposal. Many of these issues have been glossed over with media propaganda from both the government and the proponent. Many issues raised at open houses, in previous public comments periods, or by letters to the government have been ignored or responded to with such statements as "we understand your concerns".

"The Merriam-Webster dictionary defines due diligence as: "The care that a reasonable person exercises to avoid harm to other persons or their property." As the debate on British Columbia's proposed liquefied natural gas (LNG) industry enters its fourth year, it is past time to bring one aspect of that industry under scrutiny – the safety of people in proximity to LNG vessels and terminals.

Breaking all the rules

The default document on this topic is one created by the LNG industry itself. In 1997, the Society of International Gas Tanker and Terminal Operators (SIGTTO) published Site Selection and Design for LNG Ports and Jetties. The document is clear and succinct in describing how to enhance LNG safety:

·LNG ports must be located where LNG vapors from a spill or release cannot affect civilians.

·LNG ship berths must be far from the ship transit fairway to prevent collision, and since all other vessels must be considered an ignition source.

·LNG ports must be located where they do not conflict with other waterway uses now and into the future.

·Long, narrow inland waterways are to be avoided, due to greater navigation risk.

·Waterways containing navigation hazards are to be avoided as LNG ports.

Anyone familiar with the marine approaches to Prince Rupert and Kitimat will be aware that to propose marine transport of LNG from terminals in those harbours violates all of the SIGTTO standards referred to above.

Prince Rupert at Risk

Although industry analysts agree that not all will be built, four large terrestrial LNG export facilities are proposed for the Prince Rupert area, along with three, smaller floating facilities. At full build-out, the large plants would generate 796 round-trip transits of LNG vessels into port, the smaller facilities 208. That's almost three round-trips per day. In 2014, the Prince Rupert Port Authority reported that 494 vessels called at port terminals to take on and offload trade resources and goods, and that was a year when coal export was markedly down.

A typical LNG tanker – larger than an apartment block Key concerns are not just that LNG export could triple industrial vessel transits at Prince Rupert, and that the BC government sees no harm in promoting that possibility. Vessels in the Q-Max LNG carrier class are 345 metres long with a capacity of 266,000 cubic metres of LNG, comparable in size to the large ships that now dock at the Fairview Container Port.

The potential tripling of marine traffic at Prince Rupert would principally involve extremely large vessels carrying a dangerous commodity in a confined waterway.

Russian Roulette

The likelihood of a breach to one of the five or six storage tanks on a typical LNG vessel – whether accidental or intentional – is low. It has not happened since LNG marine transport began in 1959. But LNG itself as a substance, through its manufacturing process and in its steady-state in storage, possesses innate hazards. LNG terminals and storage facilities have suffered catastrophic explosions.

As more vessels are added to LNG fleets, making more voyages into confined and treacherous waters such as found on BC's north coast, the chances of at least an accidental breach in a marine setting will increase. World events of the past two decades indicate that the risk of an intentional breach cannot be dismissed. For the LNG industry to tout past "safe" performance as an absolute indicator of future probability is hubristic.

Cold Explosion

What would happen if LNG were to escape from a marine vessel storage tank? In 2004 and 2008, the US Department of Energy commissioned Sandia National Laboratories to find out. Sandia reported that an instantaneous fireball would not be likely. What would be more likely is a "cold explosion" known as a rapid phase transition. The temperature of LNG is -161.5°C. Escaping from a vessel, LNG would release a blast as it froze the ocean surface, then evaporate as it warmed and picked up water vapour to form a low, heavier-than-air vapour cloud that would drift outward. The larger the breach, the larger the cloud.

Outright ignition of regasified LNG would require it to mix with air in a range of 5 percent to 15 percent LNG. If this cloud of LNG vapour were to spread from a vessel or a terminal with optimal conditions for ignition, an aerial fireball would be possible. That ignition would typically "backtrack" from the spark to the source of the cloud. But with an onshore wind a fiery blanket could disperse over land. Sandia's research suggested that typical aerial dispersal distances from a small breach would be 3050 m from a near-shore source, and 4600 m from an offshore source.

Hazard Zones

LNG burns at more than 500°C. Sandia's reports described three zones of hazard around an LNG vessel should a breach occur with ignition. Within 500 metres of the vessel, death to all living things on the water, surfacing from the water, in the air, or on adjacent land would be likely. This could result from shrapnel, incineration, cryogenic freezing or from suffocation. Between 500 metres and 1.6 km from the vessel, these threats lessen but are still critical. Second-degree burns to exposed human flesh would typically result from 30 seconds of exposure.

Structural fires, grass fires, and forest fires would be ignited. Effects would lessen moving from 1.6 km out to 3.5 km, beyond which the hazard is considered negligible. In the US, these hazard zones have been embodied in regulations governing LNG facility location. It is also standard for LNG ports to have fireboats that are foam-capable, as use of water on an LNG-fed fire would exacerbate it.

Plotting the Sandia hazard zones along the shipping lane at Prince Rupert is informative. All human settlement in Prince Rupert, Port Edward, Dodge Cove, and Seal Cove is within the hazard zones. More than 13,000 residents are at risk, along with up to 3,000 people who may be visiting at any given time. More than 60,000 passengers depart the port on ferries and water taxis each year in these hazard zones.

If this information can be gleaned from reliable sources on the Internet (such as Government of Canada and Prince Rupert Port Authority websites), with distances confirmed using Google Earth, be assured that the BC government, federal government, and the LNG industry are aware.

In harm's way

Fishing fleet at Cow Bay in Prince Rupert LNG vessels transiting to the proposed WCC LNG facility on Tuck Inlet (across Fern Passage from Seal Cove) would ply the length of the Prince Rupert Harbour shipping lane and its approaches. The Fairview Container Terminal is on the verge of the 500-metre hazard zone, as is a 4 km length of the CN Rail line. The Coast Guard base, City Hall and its Emergency Operations Centre, the Fire Hall and its 911 call centre, the Prince Rupert Port Authority with its Port Security Operations Centre and Emergency Operations Centre, the BC Ferries and Alaska Marine Highway terminals, the Via Rail terminal, the Seal Cove Coast Guard Search and Rescue helicopter base and BC Ambulance medevac base, and the RCMP detachment all lie within 1.6 km of that shipping lane. Prince Rupert Regional Hospital and the BC Ambulance station are on the 1.6 km line.

To cement brazen disregard for the SIGTTO guidelines, LNG vessels approaching WCC LNG would pass other LNG vessels berthed for loading at the proposed Aurora LNG facility on Digby Island, at a point where the navigable waterway is scarcely 1 km wide. They would also pass LNG vessels docked at New Times LNG and Orca LNG on the Prince Rupert waterfront.

Boston-bound LNG ships require armed escort Boston is the only US city with an LNG facility. The Everett terminal in Boston Harbour imports LNG – meaning that vessels enter the harbour loaded and leave empty – the opposite to what is proposed for BC's north coast. Typically, only one LNG vessel every eight days makes the trip to Everett LNG, but the stir that each passage creates is instructive in terms of appraising risk.

When four days from port, an LNG vessel approaching Boston must contact the US Coast Guard with a manifest and crew list. The Coast Guard runs checks on the crew. When 12 miles from port, the Coast Guard boards the vessel to inspect it and to begin surveillance to ensure that all other vessels keep 500 yards away. When five miles out, a pilot boards the vessel and four tugboats are engaged. Passage into port is only permitted in daylight and with clear visibility.

Five armed boats, two from the Coast Guard and one each from three police agencies, escort the LNG vessel into harbour. Law enforcement officers patrol all piers and jetties along the route, with a helicopter or two dedicated to observe from above. Bridge traffic over the harbour is halted as the vessel makes way beneath. Marinas are shuttered and guarded for 20 minutes before and after each transit. The security cost? About 80,000 USD per transit. The economic cost? Unknown.

Tight restrictions on lone Atlantic Canada import port The Port of St. John, New Brunswick, is home to Canaport LNG, Canada's only LNG import facility. Transport Canada has implemented Boston-like measures for LNG transits: mandatory security screening of LNG vessel crews; a "marine safety zone" of 0.5 nautical miles (926 m) around any LNG vessel; no anchoring within 1.5 nautical miles of an LNG vessel; and no overtaking of LNG vessels when they are underway in the harbour.

When an LNG vessel is offloading at Canaport LNG, a 620 m radius from the centre of the terminal is off-limits to all marine traffic except tugs and service craft employed with that vessel. Given the large "sail areas" of LNG vessels, the harbour master may consider other "special provisions" to accommodate them, or may order them to leave port when they are empty and it is windy.

Harper rejected LNG on East Coast

In 2006 and 2013, the Canadian government rejected plans for LNG vessel transits through Head Harbour Passage and Passamaquoddy Bay, New Brunswick, to a proposed LNG facility in Maine. Describing those Canadian waters as "a unique and highly productive marine ecosystem," the 2013 letter from the Canadian ambassador to the US Federal Energy Regulatory Commission summarized concerns related to "the environmental, navigational, and safety risks as well as the adverse economic consequences…". Which begs the question: What is so different about the setting for LNG vessel traffic proposed for BC?

Although piloting will be required, Transport Canada has not announced its plans for LNG carriers on BC's north coast. According to its website, the Prince Rupert Port Authority is considering implementing "safe transit zones" and "traffic separation patterns to define specific routes for specific types of vessels." In other ports, separations of as much as an hour are required between LNG carriers and other watercraft.

What about other boaters?

Photo: Flickr/KsideB

What if, as is likely, setbacks and separations are mandated around LNG vessels approaching BC's north coast? For one thing, LNG plants with planned multiple berths (Aurora, Pacific Northwest, and WCC) would not be allowed to have more than one LNG vessel at dock. But of greater importance, with the possibility of three LNG vessels a day entering and three a day exiting the port of Prince Rupert, what would be the effect on BC Ferries, the Alaska Marine Highway, the airport ferry, the Metllakatla ferry, water taxis, commercial fishing (especially salmon and herring openings), tour operators, cruise ships, and recreational boating and fishing?

Why aren't these potential economic impacts and inconveniences being weighed against the touted benefits of the LNG industry? Although the issue was raised by the public during "consultation," why wasn't the possibility of restrictions to marine traffic included in the descriptions of any of the proposed LNG projects? Is it because the backlash would be over public safety, not mere inconvenience? And who in government has investigated the insurance requirements for LNG carriers and ports? Each LNG vessel is typically its own limited liability company, flying a flag of convenience; its owners beyond the reach of law should calamity occur.

Graeme Pole lives near another LNG "ground zero" – in the Kispiox Valley, near the route of the Prince Rupert Gas Transmission Project.

http://ecosocialistsvancouver.org/article/prince-rupert-risk-lng-tanker-danger-elephant-water

February 23, 2017

Karl Bilodeau

Dear EAO,

Sincerely,

Karl Bilodeau, Whistler

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Faizel Desai

Dear EAO,

RE: Aurora LNG

The Aurora LNG is a massive fracked gas plant being proposed by Nexen, which is owned by Chinese oil giant CNOOC.

It would be built near Prince Rupert on Digby Island, just north of the Skeena estuary where up to a billion young salmon make their way to the ocean each year. The nearby community of Dodge Cove is at risk of becoming surrounded by a dangerous industrial zone.

I oppose the Aurora LNG project for the following reasons:

The AURORA LNG THREATENS SALMON AND WILDLIFE

The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.

Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

AURORA LNG THREATENS COMMUNITY HEALTH AND SAFETY

The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

AURORA LNG THREATENS OUR CLIMATE

As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

NOT CANADIAN OWNED

The Aurora LNG project is not Canadian owned. The Chinese oil giant CNOOC owns it and only has Chinese interests in mind. As past history indicates, they may choose to use only Chinese labour, Chinese equipment and not respect our Laws, environment, labour or otherwise.

Canadians need to be employed but our environment needs to be protected and our citizens need to benefit from our resources. If we can use LNG to power our hydro-electric grid, power our vehicles or heat our homes, we should have access to our natural gas first. Canadians First.

Please reject the Aurora LNG given my concerns noted above.

Thank you for your time and consideration.

Sincerely,

Faizel Desai, Surrey

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Jody Lownds

Dear EAO,

Please accept this letter commenting on the proposed fracked gas plant proposed by Nexen to be built near Prince Rupert on Digby Island.

The location of the proposed project is right beside a critical habitat area for steelhead, coho and sockeye salmon in addition to important wetland areas for migrating geese, ducks, swans, sandhill cranes, great blue herons and song birds. The project as proposed would directly damage these wetlands and critical habitat.

The project as proposed would also produce an additional 6.7 million tonnes of GHGs per year (NOT including emissions involved in plant construction or shipping and burning of the fossil fuel overseas.

Given the environmental interests involved and the risks posed to those interests by this project, it simply should not be permitted to proceed.

Sincerely,

Jody Lownds, Revelstoke

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Graeme Pole

British Columbia Environmental Assessment Office

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

RE: Comment on Aurora LNG

Prince Rupert at Risk

The Merriam-Webster dictionary defines due diligence as: "The care that a reasonable person exercises to avoid harm to other persons or their property." As the debate on British Columbia's proposed liquefied natural gas (LNG) industry enters its fourth year, it is past time to bring one aspect of that industry under scrutiny – the safety of people in proximity to LNG vessels and terminals.

The default document on this topic is one created by the LNG industry itself.
In 1997, the Society of International Gas Tanker and Terminal Operators (SIGTTO) published Site Selection and Design for LNG Ports and Jetties. The document is clear and succinct in describing how to enhance LNG safety.

  • LNG ports must be located where LNG vapors from a spill or release cannot affect civilians.
  • LNG ship berths must be far from the ship transit fairway to prevent collision, and since all other vessels must be considered an ignition source.
  • LNG ports must be located where they do not conflict with other waterway uses now and into the future.
  • Long, narrow inland waterways are to be avoided, due to greater avigation risk.
  • Waterways containing navigation hazards are to be avoided as LNG ports.

Anyone familiar with the marine approaches to Howe Sound, Prince Rupert, and Kitimat will be aware that to propose marine transport of LNG from terminals in those locations violates all of the SIGTTO standards referred to above.

In March the federal government approved Woodfibre LNG near Squamish. If built, this small-scale facility would generate 40 round-trip transits of LNG vessels in Howe Sound each year. Six LNG facilities are proposed for Kitimat at the head of Douglas Channel – a waterway derided by critics of the Northern Gateway bitumen pipeline because of its inherent dangers to large vessels. Yet up to 460 round-trip LNG vessel transits could take place each year if all six plants were built. Four large terrestrial LNG export facilities are proposed for the Prince Rupert area, along with three, smaller floating facilities. At full build-out, the large plants would generate 796 round-trip transits of LNG vessels into port, the smaller facilities 208.

That's almost three round-trips per day. In 2014, the Prince Rupert Port Authority reported that 494 vessels called at port terminals to take on and offload trade resources and goods, and that was a year when coal export was markedly down.

At Prince Rupert, the key concerns is not that LNG export could triple industrial vessel transits, and that the BC government sees no harm in promoting that possibility. Vessels in the Q-Max LNG carrier class are 345 metres long with a capacity of 266,000 cubic metres of LNG, comparable in size to the large ships that now dock at the Fairview Container Port. The potential tripling of marine traffic at Prince Rupert would principally involve extremely large vessels carrying a dangerous commodity in a confined waterway.

The likelihood of a breach to one of the five or six storage tanks on a typical LNG vessel ¬– whether accidental or intentional – is low. It has not happened since LNG marine transport began in 1959. But LNG itself as a substance, through its manufacturing process and in its steady-state in storage, possesses innate hazards. LNG terminals and storage facilities have suffered catastrophic explosions. As more vessels are added to LNG fleets, making more voyages into confined and treacherous waters such as found on BC's north coast, the chances of at least an accidental breach in a marine setting will increase. World events of the past two decades indicate that the risk of an intentional breach cannot be dismissed. For the LNG industry to tout past "safe" performance as an absolute indicator of future probability is hubristic.

What would happen if LNG were to escape from a marine vessel storage tank? In 2004 and 2008, the US Department of Energy commissioned Sandia National Laboratories to find out. Sandia reported that an instantaneous fireball would not be likely. What would be more likely is a "cold explosion" known as a rapid phase transition. The temperature of LNG is -161.5°C. Escaping from a vessel, LNG would release a blast as it froze the ocean surface, then evaporate as it warmed and picked up water vapour to form a low, heavier-than-air vapour cloud that would drift outward. The larger the breach, the larger the cloud.

Outright ignition of regasified LNG would require it to mix with air in a range of 5 percent to 15 percent LNG. If this cloud of LNG vapour were to spread from a vessel or a terminal with optimal conditions for ignition, an aerial fireball would be possible. That ignition would typically "backtrack" from the spark to the source of the cloud. But with an onshore wind a fiery blanket could disperse over land. Sandia's research suggested that typical aerial dispersal distances from a small breach would be 3050 m from a near-shore source, and 4600 m from an offshore source.

LNG burns at more than 500°C. Sandia's reports described three zones of hazard around an LNG vessel should a breach occur with ignition. Within 500 metres of the vessel, death to all living things on the water, surfacing from the water, in the air, or on adjacent land would be likely. This could result from shrapnel, incineration, cryogenic freezing or from suffocation. Between

500 metres and 1.6 km from the vessel, these threats lessen but are still critical. Second-degree burns to exposed human flesh would typically result from 30 seconds of exposure. Structural fires, grass fires, and forest fires would be ignited. Effects would lessen moving from 1.6 km out to 3.5 km, beyond which the hazard is considered negligible. In the US, these hazard zones have been embodied in regulations governing LNG facility location. It is also standard for LNG ports to have fireboats that are foam-capable, as use of water on an LNG-fed fire would exacerbate it.

Plotting the Sandia hazard zones along the shipping lanes in Howe Sound and at Prince Rupert and Kitimat is informative. For example, all human settlement in Prince Rupert, Port Edward, Dodge Cove, and Seal Cove is within the hazard zones. More than 13,000 residents are at risk, along with up to 3,000 people who may be visiting at any given time. More than 60,000 passengers depart the port on ferries and water taxis each year in these hazard zones. In Howe Sound, xxx people would be at risk. Not surprisingly, xxx municipal governments and xxx regional districts are on the record as opposing Woodfibre LNG.

In an emergency, the public expects that emergency infrastructure will be safe from massive harm, or that a back-up plan exists to patch together responses if key infrastructure is damaged or destroyed. This is clearly not the case at Prince Rupert. LNG vessels transiting to the proposed WCC LNG facility on Tuck Inlet would ply the length of the Prince Rupert Harbour shipping lane and its approaches. The Fairview Container Terminal is on the verge of the 500-metre hazard zone, as is a 4 km length of the CN Rail line.

The Coast Guard base, City Hall and its Emergency Operations Centre, the Fire Hall and its 911 call centre, the Prince Rupert Port Authority with its Port Security Operations Centre and Emergency Operations Centre, the BC Ferries and Alaska Marine Highway terminals, the Via Rail terminal, the Seal Cove Coast Guard Search and Rescue helicopter base and BC Ambulance medevac base, and the RCMP detachment all lie within 1.6 km of that shipping lane. Prince Rupert Regional Hospital and the BC Ambulance station are on the 1.6 km line.

And to cement brazen disregard for the SIGTTO guidelines, LNG vessels approaching WCC LNG would pass other LNG vessels berthed for loading at the proposed Aurora LNG facility on Digby Island, at a point where the navigable waterway is scarcely 1 km wide. They would also pass LNG vessels docked at New Times LNG and Orca LNG on the Prince Rupert waterfront.

Boston is the only US city with an LNG facility. The Everett terminal in Boston Harbour imports LNG – meaning that vessels enter the harbour loaded and leave empty – the opposite to what is proposed for BC's north coast.

Typically, only one LNG vessel every eight days makes the trip to Everett LNG, but the stir that each passage creates is instructive in terms of appraising risk. When four days from port, an LNG vessel approaching Boston must contact the US Coast Guard with a manifest and crew list. The Coast Guard runs checks on the crew. When 12 miles from port, the Coast Guard boards the vessel to inspect it and to begin surveillance to ensure that all other vessels keep 500 yards away. When five miles out, a pilot boards the vessel and four tugboats are engaged. Passage into port is only permitted in daylight and with clear visibility. Five armed boats, two from the Coast Guard and one each from three police agencies, escort the LNG vessel into harbour. Law enforcement officers patrol all piers and jetties along the route, with a helicopter or two dedicated to observe from above. Bridge traffic over the harbour is halted as the vessel makes way beneath. Marinas are shuttere d and guarded for 20 minutes before and after each transit. The security cost? About 80,000 USD per transit. The economic cost? Unknown.

The Port of St. John, New Brunswick, is home to Canaport LNG, Canada's only LNG import facility. Transport Canada has implemented Boston-like measures for LNG transits: mandatory security screening of LNG vessel crews; a "marine safety zone" of 0.5 nautical miles (926 m) around any LNG vessel; no anchoring within 1.5 nautical miles of an LNG vessel; and no overtaking of LNG vessels when they are underway in the harbour. When an LNG vessel is offloading at Canaport LNG, a 620 m radius from the centre of the terminal is off-limits to all marine traffic except tugs and service craft employed with that vessel. Given the large "sail areas" of empty LNG vessels, the harbour master may consider other "special provisions" to accommodate them, or may order them to leave port when they are empty and it is windy.

In 2006 and 2013, the Canadian government rejected plans for LNG vessel transits through Head Harbour Passage and Passamaquoddy Bay, New Brunswick, to a proposed LNG facility in Maine. Describing those Canadian waters as "a unique and highly productive marine ecosystem," the 2013 letter from the Canadian ambassador to the US Federal Energy Regulatory Commission summarized concerns related to "the environmental, navigational, and safety risks as well as the adverse economic consequences…". Which begs the question:

What is so different about the setting for LNG vessel traffic proposed for BC?

Although piloting will be required, Transport Canada has not announced its plans for LNG carriers on BC's coast. According to its website, the Prince Rupert Port Authority is considering implementing "safe transit zones" and "traffic separation patterns to define specific routes for specific types of vessels." In other ports, separations of as much as an hour are required between LNG carriers and other watercraft.

What if, as is likely, setbacks and separations are mandated around LNG vessels approaching BC's coast? For one thing, LNG plants with planned multiple berths (Aurora, Pacific Northwest, and WCC) would not be allowed to have more than one LNG vessel at dock. But of greater importance, with the possibility of three LNG vessels a day entering and three a day exiting the port of Prince Rupert, what would be the effect on BC Ferries, the Alaska Marine Highway, the airport ferry, the Metllakatla ferry, water taxis, commercial fishing (especially salmon and herring openings), tour operators, cruise ships, and recreational boating and fishing? Why aren't these potential economic impacts and inconveniences being weighed against the touted benefits of the LNG industry? Although the issue was raised by the public during "consultation," why wasn't the possibility of restrictions to marine traffic included in the descriptions of any of the proposed LNG projects? Is it beca use the backlash would be over public safety, not mere inconvenience? And who in government has investigated the insurance requirements for LNG carriers and ports? Each LNG vessel is typically its own limited liability company, flying a flag of convenience; its owners beyond the reach of law should calamity occur.

Last words on the issue of LNG marine safety and due diligence go to those responsible – industry and government.

Engaging with our stakeholders in open and honest dialogue is a critical part of the way we do business and essential in helping us to understand concerns, share information and build strong relationships. In carrying out these activities, we are guided by five principles: inclusion, respect, timeliness, responsiveness, and accountability.

WCC LNG Project Description

If spilled, LNG evaporates into the atmosphere, leaving no residue on either soil or water. No environmental cleanup is required.
BC government website, LNG fact card #5

Graeme Pole
Hazelton, BC

This letter was created with the use of an online letter writing tool at wildernesscommittee.org

Robert Mann

Dear EAO,

I am concerned about the future health of B.C.'s diverse salmon runs, the great part they play in larger ecosystems and as well, the important and commericially viable food source they represent to this province.

I hope the Skeena river salmon run can be well protected. If the Nexen, Aurora LNG plant plan will do harm to the Skeena salmon, if this is what good science concludes or has concluded, I hope measures will be taken by government to reconsider the LNG development plans in such a sensitive area.

Sincerely,

Robert Mann

Sincerely,

Robert Mann, North Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

brad higgs

Dear EAO,Please reconsider this proposal

brad higgs, Westmoreland

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Amy Quinn

Dear EAO,

Sincerely,

Amy Quinn, Grafton

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Personal Information Withheld - Dodge Cove, British Columbia

The negative effects that the Aurora LNG project will have on the community of Dodge Cove, and the town of Prince Rupert, have not been accurately assessed. CNOOC-Nexen seems to be avoiding many questions that the provincial and federal governments ask them to further provide info on - by saying that they don't have to, since the AIR did not ask them to. Well, whether or not they have been asked to in the AIR, when the Canadian government is asking for further info, or when local communities have unanswered concerns on their negative impacts and safety it seems that a foreign national corporation that wishes to come onto Canadian soil should have to answer these questions.

Let's look to another LNG terminal and see the effects. http://www.eca-watch.org/problems/eu_russ/russia/sakhalin/LazebnikKorsakovLNG_04dec04.htm

The construction of the Liquid Natural Gas plant (a part of the Sakhalin II Project) and its negative impacts upon the local infrastructure as well as the inhabitants of the town of Korsakov December 4, 2004 This article was prepared by Lina Lazebnik, a teacher at the Korsakov Middle School No. 2, and a member of a local grass-roots group of citizens known as "Knowledge is Strength". Assistance with this article was provided by Dmitry Lisitsyn, the head of the NGO known as Sakhalin Environmental Watch.

This is a translation to English from the original Russian.

In many ways, the problems we are seeing here derive from the fact that the Sakhalin Energy Company did not do the baseline work that it needed to ahead of time. It didn't create the appropriate conditions for the Sakhalin II project to really get established. For this reason, all the stress and strain that was felt at the very beginning of construction was to fall on the shoulders of the local people, and upon the local officials and the town itself. Another basic reason for the immense social impact here was the fact that there was no individual attention paid to the impending social problems here by anyone amongst the contractors or subcontractors-- the very people who should have had an interest in what was happening. All this time Sakhalin Energy has been entering into contracts with dozens of other companies. But the main issue for the management teams here is to minimize expenses at each stage of fulfilling their contracts. This means that the management folks are really only trying to save money at every step of the game.

At the very early stages of construction (that is, from August to December of 2003), there were about 1,500 workers who descended upon the town of Korsakov--living there for a year, either in the town itself or in one of the small villages nearby. These imported workers became inhabitants of the town, paying no taxes, and availing themselves of all the social services and infrastructures during this entire time. And despite all the bonuses and the investments into the development of Sakhalin which the Sakhalin Energy folks like to boast about, the local government budgets have ended up running very large deficits over the last two years. There were simply not enough social-support resources to go around, even for the long-term residents of the town. What's more, the government budgets here have no way to withstand the influx of yet another 1,500 people (by the fall of 2004 the number of imported workers here had increased to nearly 3,000).

Because of the complete lack of preparation for the conditions that might arise, the appearance of such a large number of new people (i.e., the construction workers for the Liquid Natural Gas, or LNG plant) has caused:

• a decline in the overall water supply system for the city; • a decline in the sanitary system that disposes of all industrial and domestic wastes; • a serious increase in the overload on medical services in the town, services which are fully provided for by the local government budgets, and which include the hospital, local clinics, and ongoing ambulance services; • a serious increase in the incidence of epidemic illnesses in the region; • a serious increase in the amount of violent crimes committed against the local residents by the newcomers.

The local reservoirs have not been able to provide enough water for Korsakov for several years now. The water pipeline system here is quite old as well, and has not been repaired or updated for at least ten years now. There is systematic rationing of water now, with water turned on for three hours in the morning and three hours in the evening. Even then, in several parts of the town it is quite common for the water to be turned off anywhere from several days at a time to almost a month.

And now the situation is becoming even less fortuitous, since Sakhalin Energy decided to lay one of its oil pipelines right through a small watershed where water is collected [for the city reservoir]. This has ruined the topsoil near the rivers and streams here, especially in some of the steeper parts of the watershed, leading to a lot of soil runoff and sediment pollution in the reservoirs that serve as the source of public water. The local authorities were even forced to stop using them. Local experts now predict that "…..Korsakov might be without water for the entire winter." In sum, the appearance of 1,500 new residents in the town who are working on the plant has really caused a sharp increase in the demand for water--while, on the other hand, the oil pipeline that was laid by Sakhalin II has put two of the reservoirs out of commission, removing about 40% of all the water that once was used on a daily basis by the town.

The sanitation system here, which also has not been repaired or updated for more than ten years, really cannot manage to treat the waste waters that come from Korsakov at this point. As a result, a very significant amount of untreated water is now being dumped into the sea here. Moreover, the growth in local population did not bring in any improvements in the treatment facilities. For the last year, Sakhalin Energy has been sending its waste waters from the LNG plant site to the existing treatment centre for Korsakov. And once they had managed to overload this system, they began to send their waste waters to the treatment plants in the neighbouring villages of Dachnoe and Solovyovka, where the local systems are extremely old and close to a complete and dangerous breakdown. This method of dealing with the problem continued right up to October 2004, that is, until a new treatment centre began to take on the waste waters in the new village that was set up for the c onstruction workers in Prigorod.

One should note that the construction workers who were brought here hail from many different countries, such as Turkey, Pakistan, Kirgyzia, Uzbekistan, Moldova, Ukraine, Tajikistan, Kazakhstan, as well as from many other cities from all over Russia. They brought with them their own diseases and infections, including more than a few venereal cases. There are a number of rather exotic illnesses that have appeared here. The local Korsakov physicians have no experience [with these] and are not sure how to treat them. Already there are cases of AIDs. There are also a number of new cases of tuberculosis and pediculosis [lice]. Official statistics show that, in the time immediately after construction of the LNG plant began, the number of people in the town suffering from pneumonia rose precipitously. And this is not your run-of-the-mill type of pneumonia. What is really unusual is that local people are coming down with pneumonia year-round now, and not just during the short season that once was the rule.

For the most part, the construction workers at the plant have no medical coverage at all. And despite all their efforts, the medical teams already serving Korsakov have not been able to force the contractors at the plant to cover the medical costs for those suffering from venereal diseases or AIDs, as is required by Russian law. And insofar as some 1,500 workers have been living in and around the town of Korsakov for over a year now (and many still live there now), one way or another there has been no end of contact with the local residents. This has led to the spread of many diseases and to a growing overload for the hospital here, which had a hard enough time taking care of the existing health problems for the local people before.

The problem here really comes down to the fact that a very large number of the workers here have no medical policies. Correspondingly, the people who are employing them have not been paying for any of the medical services that are provided by the local health care system. In the vast majority of cases, the Korsakov medical teams have been forced to render services for free to all the workers at the LNG plant-- not only in cases of severe illnesses but also in cases where ambulance services were required. This has meant ultimately that the local people have had to pay for these services, since every one of them is covered by their own local employers, who pay fees for the public medical insurance policies that support the local health care budget, which in turn goes to pay for all medical services in the region.

A good example of what is happening is an incident that took place at the beginning of 2004 in the Korsakov hospital. A plant worker was brought in after he had gotten into a drunken brawl and injured his eye. As it turned out, the hospital had to spend the equivalent of 120 thousand rubles [about USD $4,275] on his treatment. For three months the doctors requested that his employers pay for the treatment. But, in the end, the company refused to pay anything.

This is not an unusual case at all: there are many such incidents to cite. This is a town where an LNG plant is being built, where around 5,000 people now live-- and there is only one small health care center that can provide primary care. In other words, we aren't talking here about a place with large-scale medical facilities. What this all means is that any serious outbreak or other health problems among the workers could easily become a tremendous burden upon the Korsakov medical staff. By Russian standards, a town with around 5,000 people should have a functioning hospital with several dozen doctors, each with their own specialization. There should be high-tech equipment available, with in-patient facilities that can house a few dozen patients at least.

Another incident happened in March of this year, when there was a case of massive poisoning at one of the larger subcontracting groups, known as the Amur Tiger Company. Some twenty-five people were brought into the Korsakov county hospital with a diagnosis of severe food poisoning. After research into the matter by the state public health officials, the cause of the poisoning became obvious. There had been numerous and severe violations of public health standards in the place where food was being prepared for the company workers. Many of the food products given to the workers had "use-by" dates that had long since past. And the food preparers themselves had not been subject to any kind of inspection, medical or otherwise. (In one case the chief cook was found to have a severe infection on his hand, with pus oozing out.) The foodstuffs were being stored in non-refrigerated areas, and food that had not been consumed the day before was simply served again the next day, etc. The office of the mayor of Korsakov estimates that the treatment alone for all those who came down with food poisoning would cost the county the equivalent of 15% of all the taxes and land-rental fees that the various LNG companies had paid into public coffers during the previous year.

Thereafter, the Korsakov medical teams tried to contact the companies that had been contracted to build the plant. However, by May of 2004, when the construction had already been going on for nine months, with a total of 2,000 workers taking part-- none of the companies at hand, neither the Sakhalin Energy Co., nor its general contractors at the Japanese company CTSD, nor even the subcontractors that had been brought in, had shown any willingness to set up any system or process for looking into the health of their own workers, including the vast majority who had come from outside Sakhalin Island to do the building work.

Now, the future operation of the LNG plant also carries with it the threat of many serious accidents (the recent disaster at an LNG plant in Algeria shows how a large explosion can cause a very serious fire). Both the physicians and the local government agencies here have already approached the CTSD Ltd. Co. with the proposal that they take into account the possibility that there might be a large number of casualties, should there be a serious accident at the plant. They proposed to the company that a special evacuation program be set up to deal with these potential casualties. That way, medical help could reach them quickly, and the patients could be placed in the medical facilities here without delay. However, even this proposal for cooperation was to be ignored by the builders of the plant.

Then, at the beginning of 2004, there was a bad automobile accident at the construction site. There were nine workers who were brought into the Korsakov hospital, with various traumas. This was just too large a number of people for them to be treated at one time. This means that, if the number of injured from some future accident runs into the tens or twenties, there simply is little chance for the Korsakov medical establishment to be able to deal with this on its own. That's why it is necessary to set up some reasonable response regime to deal with a possible large-scale accident in advance.

When a large portion of the work force had been living in the town itself, the living conditions that they experienced could hardly be called either civilized or humane. The various large and small sub-contracting companies-- most of whom came from off the island-- decided to place their workers in whatever sort of living quarters were available, at least to begin with. Sometimes the most unpractical living areas were provided-- one example is where they set up a number of beds in the open workshops located in the first buildings erected for the plant. They were reduced to setting apart the living area by hanging fishing nets.

In a few cases the number of workers living in one room of this sort reached as many as a hundred. There would be only one washing machine to serve all of them, two toilets and only one shower. Each worker was given an iron cot that was only 2.5 feet wide, with a top and bottom bunk, one mattress per worker, with one set of sheets that was supposed to last them several months at a time. There was no dryer in sight, or any way to dry the clothes and the linens that needed to be washed. And since these workers were working round the clock, they could go weeks without being able to dry any of their wash. And rainy days didn't see any letup in the work either.

The workers weren't able to work or live in anything approaching decent conditions. Even now the typical working period for most of the contracting companies goes from ten to fourteen hours a day, with only one or two days off each month. This despite the fact that-- during the negotiations that allowed Sakhalin Energy to build this plant in the first place-- the company was to promise that, from the very beginning of any construction work at the plant, they would first build a so-called "pioneer" [camp] village for the 1,500 workers that would be brought there. This promise turned out to be an empty one, and the construction of the plant went on simultaneously with the construction of possible living quarters for the workers.

The main reason that the contracting companies are bringing in so many workers from the mainland, by the way, especially from the former Soviet republics, is that they are doing everything they can to save money on salaries. In many cases they promise wages as high as $1,000 a month; but they never offer the worker a contract to sign. To get the hired workers to believe in these promises and come to Sakhalin in the first place, they usually give them an immediate advance of $1,500. But then it turns out that they have to work under very difficult conditions, for up to nine months or more, not earning any extra money while they pay back the advance. Many (about 1/3 of the imported workers) can't hold out, and return home, not having received any real salary during their stay. A lot of them are forced to leave because of some illness or injury that occurs here, insofar as the contracting companies are mostly not paying for any medical treatment.

The workers that come from the other former Soviet countries are willing to work for very low wages. They are now on foreign soil, and are not familiar with the local laws. They have no way of defending their own workers' rights. For this reason it is quite easy to force them to work in the most difficult conditions, and pay them next to nothing for doing so. They are really fed and paid almost nothing. Workers from Sakhalin have the ability to hire a lawyer, and many of them are members of local unions. As locals, they know their own laws better, and they know that it's possible to go to the local attorney general's offices or go to the labor boards to protect their own rights. That's why it would have been much more challenging to deceive any workers who were locally based, and to force them to work for less money without adhering to any standard of working conditions.

So, the contracting companies here don't find it profitable to hire the local Sakhalin workers. For one thing, they would have to pay them more, plus it would be harder to manipulate them to make them work for longer hours than what is allowed by law. The Korsakov labor center statistics show that, during the last year-- out of the 4,500 local Sakhalin people who applied for a job by sending in their resumes to the companies building the plant-- only 172 of them have been hired.

A good many of the workers who came to work at the construction site in the fall of 2003 only received their first real wages at the end of June 2004; they only got paid then because of a visit paid by representatives from the EBRD, the US Ex-Im Bank, and the JBIC folks. During the meetings between these representatives and the local population of Korsakov, the problem of nonpayment of wages became clear to everyone. As a result there were a number of pointed comments made by these banking institutions to Sakhalin Energy. Before that, the workers were only fed, and, from time to time, they were given mere advances of only 2-3 thousand rubles [about USD $70- $100) for a month. The complete data on how much workers are actually getting paid has been held under very tight wraps. But because of investigations that were conducted by several Sakhalin journalists, it was learned that workers at the LNG construction site on average earn between 8 and 18 thousand rubles [about USD $285-$640] a month for non-stop 12-14 hour days. The earnings of workers from the former Soviet republics very rarely reaches 10 thousand rubles [about USD $360] a month; but this money is extremely hard for them to get their hands on, when it comes down to it.

The fact that no plan was made to handle all the additional heavy-vehicle traffic around the construction site has also caused a huge set of problems for the residents of Korsakov.

The town of Korsakov and all the fishing villages within Korsakov Region are connected by one dirt road that runs mostly along the shores of Aniva Bay. The LNG plant-- in Prigorod-- will be between these fishing villages and the town itself, which is about 12 kilometers away. There are thousands of people who use this road constantly. What's more, there are several villages and hundreds of dacha complexes [groups of small private cottages with subsistence gardens] that are situated along the road to the plant. A great number of the Korsakov locals, as well as many residents of the larger southern Sakhalin area, use this road to go out into the country to fish, hunt, gather wild mushrooms and berries, or simply to take a holiday on the sea. It is this very stretch of road between Korsakov and Prigorod that has come under the heaviest use by the huge construction trucks that pass by in the thousands.

One recalls how the Sakhalin Energy people made many promises during the negotiation and contract-signing stages of work here. They managed to tell the Korsakov county agencies, and the townspeople as well, that the main cargo loads destined for the construction site would be arrive via sea routes, and not land routes. They said that only during the very early stages, while they were building a special dock for unloading, would a small portion of the heavy loads be sent through the existing port of Korsakov-- and from there, through the town itself. However, today, after a full sixteen months of construction work, as many as 90% of the cargo loads that go to the site are arriving via the main streets of the heart of Korsakov itself. They barrel past the public schools and through residential areas. Then they head out along the Korsakov-Prigorod road, which still does not have any asphalt.

The promises made by Sakhalin Energy obviously have been impossible to fulfill, since even if the special loading docks had been built and put into use, this would take only a small portion of the truck traffic off the road. The largest part of the truckloads coming to the site are carrying building materials-- sand, gravel, and other quarried rocks for building. And these would not come through the port anyway, because they come from the island itself. There is no difference whether the loading dock in Prigorod is put to use or not. It really has no effect on how the building materials will be brought in. Most of the materials arrive from the mine and quarry sites located a few dozen kilometres north of Korsakov. From these sites there are only two possible routes of transportation:

1. The somewhat longer route, that goes right through the center of Korsakov. The main advantage of this for the truckers is that almost the entire route is well-paved, it being the main road to the southern tip of the island; 2. The main shortcut, which goes entirely along a dirt road, past the small village of Chapaevo. The main drawback to this route is that it is a dirt road that has been used for many years, and really is not appropriate for such heavy traffic, since it has always been in need of constant repair.

For the most part, the people who are building the plant prefer that the first route [through the town center]. It is, after all, the one that costs the least (there's no need to constantly repair the road, for example). But late last year, and even early in 2004, the other alternative was also used rather actively, as it is even today, since the dirt road has not completely been broken up into ruts and ravines. Both of these routes entail transport across a 12 kilometer section of dirt road that lies between Korsakov and Prigorod. It is only the second route [via Chapaevo] that does not bring truck traffic into the town of Korsakov itself, since it meets with the connecting road on the outskirts.

Sakhalin Energy was supposed to put forward a detailed plan for handling traffic before any work was to have started at the site. They were supposed to have taken these plans and presented them for approval by the county and Sakhalin Province authorities. It is interesting that the company spent several years previous discussing this very problem at various gatherings-- at which they gave a number of different promises, at times contradictory to each other. Yet, no plan of any kind for handling the transportation operations around the construction site was ever committed to paper. And no documents exist to show any work to this effect. Without a doubt, it would be in the interests of the region and the province to have the second [Chapaevo] route used for supplying building materials, requiring that capital improvements be made to this dirt road, to the point where it would be made to detour around the village of Chapaevo as well.

The authorities in Korsakov have tried to receive more information on the scale and nature of the truck traffic that travels the roads of their region. They want to be able to estimate the total load, and determine what measures should be taken to strengthen and improve the roads that are being used. But neither Sakhalin Energy, nor CTSD, nor any of the other subcontractors have given any response to the questions that have been posed to them on this subject. Only one of the contracting firms has managed to reply that, during the first year of construction, it was gauged that some 40,000 cubic meters of sand and about 60,000 cubic meters of crushed rock had been trucked across the Korsakov roads (for a total of about 180,000 metric tons transported).

At the time that construction started at the site, there had not been any signs of new road-building, and no efforts had been made at road improvement at all (with the exception of a few streets within Korsakov itself). The construction of the plant went on using the existing system of roads in situ. There had been absolutely no accounting for what the sharp increase in traffic would do.

So, with the increasingly intensive use of the roads, by the spring of 2004 it turned out that many sections of road were simply in ruins. The Sakhalin climate is quite damp. In springtime, during the thawing of the snows, a massive amount of water floods the land. Traffic along the dirt roads at this time (from March to June) is bound to have the most ruinous effect. This is why for many years the province authorities have only allowed a limited amount of heavy freight truck traffic along the dirt roads of the island. In essence, they allow heavy truck traffic during this time of impassable roads only by a system of special permits. However, as of the spring of 2004, the LNG plant builders had still been able to completely ignore these longstanding restrictions. Consequently, the dirt roads here, especially the Korsakov-Prigorod portion, were completely broken up and ruined.

The local traffic of privately-owned cars between Korsakov and the fishing villages of Ozerski, Beregovoe, and Novikovo, all along the Aniva Bay, was almost completely shut down during this period because of the state of the road. The enormous trucks had left such deep ruts in the road to the [LNG] plant that even an all-terrain jeep would have had trouble getting through. The detour towards the building site, which should have led traffic up to the site as early as the beginning of 2004, was still not open for operation (it only opened in the month of October, 2004). From the start of March right through April it was very difficult to supply locals with food or with any postal mail. Locals simply couldn't reach the central hospital either (there were even incidents where the ambulances got stuck in the awful roads here). No one could go out into the countryside at all; not even to visit relatives.

And so, in order to force Sakhalin Energy, and CTSD and the other subcontractors to do some repairs on the road, the local Korsakov officials held a "round table" for everyone to discuss the problem. However, not one of the companies responsible for building the plant sent any representatives to this meeting. That's when the mayor called for the local citizens to get out and picket the road in the region around Prigorod. They did manage to stop truck traffic in its tracks for several hours. But even with this, no representatives from Sakhalin Energy or from CTSD were willing to come forward into a dialogue with the local residents and their elected officials. It was only after the local press started writing about the alarming situation that the province-level officials started to exert some pressure on both companies-- at which time they started to take some action to repair the road.

The same situation arose around the road running through Chapaevo. This road was at first used for transporting sand and hard rock materials. The heavy loads that came through eventually completely destroyed the road, leaving the local residents totally isolated from the outside world. One could pass over this road only in trucks with very high undercarriage clearance. It was here that the locals were able to force some repairs of the road, but only by setting up pickets and blocking trucks from passing. More than a few residents of the larger Korsakov region were forced to repair their cars after the beating they took from driving across these terrible roads.

CTSD and Sakhalin Energy had agreed to pay USD $2 million to the Korsakov County coffers, of which three-hundred thousand was supposed to cover or compensate for the needed repair and rebuilding of roads here. However, by the estimate of independent experts, it would take no less than USD $7 million to give full compensation for all the damage and other negative impacts to the roads and road traffic of the region (which itself does not include all the losses incurred by local businesses and by private people as they went about their business).

The town residents are having trouble dealing with the truck traffic.

Before the construction at the site started, Sakhalin Energy and CTSD had agreed to widen and otherwise improve the thoroughfares, so as to provide for truck transport along the streets of Korsakov. However, they managed to do this by getting rid of the sidewalks for pedestrians. As a result, pedestrians in the town are now in a lot more danger. Already one of the town's residents walking along the truck routes through the center was hit by a bus that was carrying workers to the LNG plant. Her suit is now in court.

The truck routes here pass through a number of residential areas. In some cases the road with all these trucks runs only a matter of 10-15 meters from the front doors of these houses. This causes a lot of inconvenience for the locals, mostly from the incessant noise, and the dust and dirt that is kicked up. For the first few months of construction the trucks were roaring by even at night. There are houses here which shake strongly with the passing of each truck, rattling the dishes, shaking everything. The air quality has gotten a great deal worse along the truck routes, mostly from the exhaust that comes from each truck. Also, the middle school in Korsakov has suffered some impact, since truck traffic streams right past it. In front of the school are two of the most dangerous intersections in town. Now each student has to have a teacher accompany him or her to cross the street both before and after school. And the classrooms have become incredibly stuffy and uncomfortable, since the windows have to be closed at all times to keep out the dust and air pollution that can even make it impossible for the kids to breathe.

The kids themselves decided to start monitoring all the truck traffic in front of their school, and found that each school day some 150 trucks passed by en route to the LNG plant site (this did not include other trucks or other heavy traffic). There's a stoplight right in front of the school, which means that many trucks just stand there idling, with traffic often backing up. So as to avoid this backup, the trucks from the LNG plant often drive right across the square that is in front of the school, even during the time in between classes when the kids are out on the street. This still happens all the time, forcing the school administration to erect a concrete barrier in front of the school.

In the spring of 2004, when the roads were blocked up with the thawing snows, the trucks that came through town began to track an immense amount of dirt and mud into town. The streets in town were covered in layers of mud. When they dried in summer, they turned into massive dirt and dust piles. The city officials in charge of the roads in Korsakov tried to force the drivers and their bosses to start cleaning their trucks-- but nothing came of it. When the local police inspectors started to fine the drivers as they passed through town, the drivers just turned around and washed their trucks in some of the spawning streams near town. There has been no plan put forward to set up a truck wash at the plant.

Before all this started, the sight of a heavy truck on any of Korsakov's streets was a rare thing indeed. The local people had no idea that all the construction going on over there in Prigorod would bring them so much trouble.

The builders of the LNG plant are ignoring all the requirements set down by law concerning compensation for polluting the environment.

In accordance with the federal law on "Protecting the Environment", every business enterprise that might cause pollutants to enter the atmosphere during operations, or that contaminates the water or soil around it, must set aside a special fee to pay for having caused this pollution, a payment which goes to the federal, regional, and local state budgets. The greater the volume of pollution, the larger the payment to be made. This standard of operation pertains even to the use of private automobiles.

Nevertheless, the business contractors at hand here-- such as: BAM Mechanical Construction, Far East Mechanical Construction, Rosneft Resources, Moscow Electrical Line Construction, Tiger Amur, and Angarsk Construction Management-- not to mention the Japanese CTSD Corporation and IKEM-- all have been conducting work here without making a single payment of this nature. The State Environmental Inspectors have checked into this a number of times, and have each time revealed a complete absence of any documentation that would allow these companies to use the natural resources here (these documents should be set up to show the limits to the amount of waste that can be produced at the site, or how this waste must be handled; it also sets limits to the amount of pollution that may be released into the atmosphere, as well as how much in the way of other pollution may be allowed in the local natural environment).

This all means that the companies are getting away without taking care of any fines or other payments for polluting the environment here. Thanks to this trickery, the plant builders here have been able to save a ton of money, while the state budget coffers at all levels are not getting their fair share of payments. Even today, after a number of attempts at sanctioning these companies, a few of them are still avoiding payment, and have yet to submit the appropriate licensing documents that would set them up to pay compensation for the pollution they release.

The Korsakov residents are also losing one of the best beach sites in the region, with very little in the way of compensation proposed-- thanks to the construction of this LNG plant.

At the very site where the plant is being built, there is a fine sandy beach that has been popular for many years among the local residents. This beach once provided all kinds of valuable opportunities for enjoyment:

• It is here that one can both swim and sunbathe for a good part of the warm season. In fact, this is about the only place in the Korsakov region that is suitable for swimming, since nearer to the town itself the water has been seriously polluted by other industries and by the release of municipal wastes. Many of the poorer children who couldn't be sent to camps by their parents would often spend most of their summers on this one good beach.

• In addition, this beach is noted for some of the best sport fishing in the region, with a number of species of salmon and others to be caught here.

• One type of salmon uses tidepools here to spawn, after which many local people would gather the mature fish in buckets.

• After good storms, the local people would also be able to go out and gather a number of shell fish, which would have washed up on shore.

• There are also small groups of fishermen who are licensed to catch the salmon here, coming in from all over southern Sakhalin.

In sum, the significance of this beach to the tens of thousands of local residents who use it would be hard to overestimate.

The beach itself occupies a strip of shoreline that is about 2,400 meters long (about 1.5 miles). Of this amount, some 800 meters was set aside for the plant itself, just to the east of mouth of the Merey River. This area is already out-of-bounds for local residents. Along this stretch of beach a protected dock is being built, for offloading equipment. Another dock is being built here for shipping cargo, alongside the fuel pipeline that will run out into the sea to a special offshore facility for exports.

The CTSD and Sakhalin Energy companies came up with an assessed value for these 800 meters of beach that amounted to USD $800,000-- which comes to $1,000 per meter of beachfront property. The beach here averages about 15 meters in width, so the price put on this land was about $1,000 per 15 square meters. How this compensatory sum was reached, and whose imagination was used to reach it, is a mystery to us all. This money has already been handed over to the town, although it quickly became evident that this would somehow not really compensate for the loss of the beach. You couldn't even use this money to build a decent swimming pool in the town, which has been a dream of the local residents for years. It wouldn't be enough to pay for rebuilding the bridges that lead across the Aniva inlet to some of the other similar beaches that are recreational favorites of the people from southern Sakhalin. You wouldn't have enough money either to build up a new beach to the north of town, where the water is fairly polluted anyway. For this reason, it was decided to use the money to rebuild the city park. But even here, once work on this began, it became quite clear that this money would only go as far as paying for the design and other digging and preparatory work for the park.

Sakhalin Energy had promised to leave the remaining 1,600 meters of beach untouched for use by the local population. It was stated over and over again, in no uncertain terms (including in all the planning documents for construction) that this beach would not be affected by the construction work here, and that people could continue to enjoy fishing and other recreational activities here. But, as it turned out, the so-called "public health zone " around the plant is now slated to stretch out some 3.5 kilometres. And this means that the entire beach will be encompassed within the overall territory of the plant.

By the current laws in Russia concerning the protection of public health, these off-limit zones cannot allow for the construction of any hazardous industries in an area also used for public recreation. This means that the folks at Prigorod cannot be allowed to use this beach at all. What's more, CTSD Ltd. has already prepared a project to build up a road here that will run right along the beachfront. They know that the strong ocean currents could be a problem. So, as part of their project plans, the company intends to build a rock barrier right along the beach, between the road and the high tide level of the beach. There's no doubt that this kind of barrier will result in the disappearance of the beach itself. Nevertheless, not a word has been spoken about how the town might be compensated for the loss of the remaining 1,600 meters of beachfront property.

This is but a spare list of all the problems that are emerging here, thanks to the construction of this now controversial LNG plant. We have said nothing here about the larger environmental impacts on the fisheries here, by the way. Nor do we mention the arrogant and offensive manner in which the managers of these Western companies have been treating the Russian workers at the site. There's also the matter of how the Sakhalin newspapers have been all bought off by Sakhalin Energy, so that for a certain amount of money they are willing to print only the most positive materials about the construction of the plant here. And how about how so many of the small farmers and dacha owners who have been forced off their land? Or the crime wave that has hit the region around the construction site itself?

There is much that remains hidden from our view as well, since Sakhalin Energy seems to like to operate "behind closed doors" at all times. They have a very strict regime for controlling all the information they hold. They keep a tight air of secretiveness in any case where there might be a hint of negative news about their operations. They show no tolerance for any kind of criticism at all either. But, because of all these problems that we've begun to list here, the local people are starting to look at the LNG plant with more and more antipathy and aggression."

So, I know that many might read this and say: well, this is Canada, not Russia. This won't happen here. But as already noted, the Canadian government itself has requested information from the Chinese National Offshore Oil Company in regards to the proposed Aurora LNG project - and it has so far yet to materialize. Data from the impact of LNG terminals on communities in other areas of the world could be analyzed to come up with a more accurate prediction of the impact that will be felt here, but neither the Canadian government or CNOOC-Nexen seem to care to do that.

The complete disregard for Canadian citizens' wellbeing, and for Canadian towns and communities - leads me to believe that many of the issues written about Russia and the problems locals felt from an LNG terminal being built, will also become the issues that we will feel here in Canada. This project should not even be at the FINAL public comment period, since baseline data has not been accurately done, and there is missing data that has been asked for.

I urge the BCEAO to read reports from other LNG terminals and effects that they have had on local populations - and refuse to allow this public comment period to continue. The Aurora project has not treated this project as serious - but has tried to present a position that this will have a minimum impact on local residents, and that they will have "plans" in place to deal with any likely negative scenario. Yet those negative scenarios are not being fully looked. Not to worry, someone somewhere at sometime will see these plans. Not the current working group, not the BCEAO. Not the public, not the local residents, not BEFORE the approval of this project.

fire

Personal Information Withheld - Dodge Cove, British Columbia

Since Aurora LNG final application has failed to look at accidents or malfunctions from terrorism, here are some clear statements. Everyone considers Canada to be low-risk for terrorism, but in todays' very uncertain global political field and changing pressures it cannot be completely discounted. There are very real concerns in many countries that have suffered terrorist attacks, such as the U.S., and LNG terminals such as Yemen have suffered a number of terrorist attacks on its 350 km feed-gas pipeline as well as a rocket attack on it's LNG export terminal, and other alarming potential attacks by boats. The point of assessing an LNG terminal is to assess ALL possible effects that it could have on the surrounding communitites and environment. Would placing an LNG terminal close to population and airport increase the risk of terrorist attacks to the residents living here? What additional security would be put in place regarding that potential? How will the exist ing marine traffic be affected by additional security? How would local residents be affected by additional security? Nexen's Aurora LNG newsletter pointed out that LNG comes into Boston Harbour safely, close to populations, as well that has been verbally said by Nexen employees. But the fact is that Boston Harbour is virtually shut down while an LNG ship approaches, and multiple security measures are taken that have not even been discussed here or in this application. So it is not an accurate comparison.

"Every day you're thinking about it. It's very, very dangerous," Anthony Pinto, of East Boston, said as pointed his cane across the harbor, down the Mystic River, past the Tobin Bridge to the dock for Distrigas, the company that runs the area's LNG facility.Some studies say an attack by a missile or boat bomb on a tanker could spill half the cargo over the water, causing a catastrophic, searingly hot fire that would burn people and buildings a half-mile away. But a study paid for by the industry and used by the Coast Guard in approving a safety plan for Boston found the burn zone would be contained to a much smaller area.U.S. Energy Secretary Spencer Abraham has asked Sandia National Laboratory to study LNG safety issues, particularly transportation.James Fay, a professor emeritus of mechanical engineering at the Massachusetts Institute of Technology, is a leading expert on liquefied natural gas and former chairman of the Massachusetts Port Authority board. He b elieves a boat bomb, like the one used against the USS Cole in 2000 would cause at least half of the ship's cargo to seep over the water and ignite in a raging blaze."There's no doubt that with a big enough bomb you can blow a hole in the side of the vessel and the cargo will burn," Fay said. "It's well understood that for the big fires we're talking about that distances like half a mile or so, you can get second-degree burns to exposed skin in about 30 seconds."Jerry Havens, a University of Arkansas professor and expert in both fires and weapons of mass destruction, said he agrees with Fay's assessments. Both he and Fay recognize LNG as a valuable resource — but one with risks.

http://www.nbcnews.com/id/4276348/ns/us_news-security/t/are-natural-gas-ships-boat-bombs-terror/#.WK8clmwizVI

Boston Harbour Security measures are strict, shut down marine traffic, cost up to $25,000 each shipment, and is obviously of a very different nature than what is being proposed here, by Aurora LNG, at the entrance to Prince Rupert Harbour, within a disastrously close distance to Dodge Cove, Prince Rupert, the airport, Maher Terminals, Ridly Island Grain and Coal (and soon to be Propane), yet it seems that there has failed to be a real analysis of potential hazards/accidents/malfunctions/terrorist attacks/additional security measures and what those will mean to residents living here. If any of these security measures are to be taken, what cost to taxpayers will come with that? How will the present traffic in and out of the harbour be affected, how will traditional activities by boat and on land be affected, how will recreational activities be affected?

These concerns of transiting dangerous cargo of this size that could potentially wipe out everything around it have led to (unsuccessful) attempts by the mayor of Boston to permanently suspend LNG shipments to the Everett terminal passing through Boston harbor.

"All crew members have U.S. visas, and access to the ship is closely controlled, with visitors escorted. Security teams accompany the ship. Bomb-sniffing dogs inspect the ships and divers conduct bottom surveys during the transit. Follow-up inspections are conducted upon arrival at Boston, and security teams come aboard to inspect and escort, and special teams monitor the critical watch stations.

"If we note any anomalies at any time from departure to transit to arrival without determining if the anomaly can be investigated and cleared, we won't permit the ship to enter this port," said Morkan. On the water, a security zone surrounds the ships, enforced by as many as a dozen response boats from the different agencies to keep other craft away from the tanker, along with one or more helicopters. Airport movements are coordinated, and the Tobin Bridge is closed when the ship passes under.

As noted earlier in this report, the LNG safety provisions in the Pipeline Safety Act require the Secretary of Transportation to "consider the ... need to encourage remote siting" of new LNG facilities If terrorists caused even 10 percent of the typical LNG tanker's payload to spill and ignite, the resulting fire could be calamitous, according to a 2004 report by Sandia National Laboratories for the U.S. Department of Energy. The study didn't publicly estimate casualties for Boston; in fact, no study has since 1977.It's not hard to imagine why Boston remains the country's only major city with an LNG terminal.The tankers were such cause for concern after 9/11, Mayor Thomas Menino asked a federal judge to ban them from the city. "This is serious stuff," Menino says. " We don't have the equipment to put down an explosion of an LNG tank. They say, 'Well, it will never happen.' Well, 9/11 hadn't happened either. We live in a different era."

Shouldn't the 1977 risk-assessment study be updated?

Yes. Boston Deputy Fire Chief Jay Fleming has been agitating for this type of update for years. Menino says the Department of Homeland Security in February promised him an assessment of how to get LNG out of the harbor, but has yet to deliver a report. The DHS declined to comment.

How would the city respond to an LNG fire?

The worst kind of fire would be an event so large and unprecedented, it's near impossible to prepare for. The Massachusetts Firefighting Academy in Stow has an LNG training program, but it focuses on fighting fires from smaller-scale leaks, such as from pipelines or transport trucks. Pool fires (see page 91) are just too big. "We're not training for that type of an incident," says State Fire Marshal Stephen Coan, "and I don't think that you can train for that type of an incident" on a large scale. Still, Boston city officials, Distrigas, and the Coast Guard say they regularly collaborate on joint emergency drills.

What does Menino want?

The mayor wants tankers to stop coming, which would happen only if the region found other ways to get natural gas: via offshore facilities, for instance, or more pipeline, says Donald McGough, director of the city's Office of Emergency Preparedness. City officials have said each shipment costs $25,000 in public-safety measures.

THE ROUTE

Every LNG tanker cruises past the piers and bridges of downtown and Charlestown before docking in Everett. Here are some of the security measures taken along the way:

Four days out

The LNG tanker is required to alert the Coast Guard of its approach and provide a manifest. The Coast Guard runs background checks on the crew. (Distrigas performs its own background checks before its ships sail.) The tanker must contact the Coast Guard again at 48, 24, 12, and 5 hours outside Boston Harbor.

Six to twelve miles out

Two Coast Guard officers board the tanker for safety checks and to watch for vessels that get within 500 yards. The Coast Guard also sends in teams of 12 to 24 officers for random security sweeps, though they're more likely to spot check ships from Yemen.

Five miles out

A member of the Boston Harbor Pilot Association meets and boards the tanker. After safety and information protocols are performed, the pilot directs the ship toward the harbor at about 10 knots, or 12 miles per hour.

Entering Boston Harbor

When the ship enters the North Channel, that's the point of no return. Until then, the harbor pilot can decide to stop, no questions asked. From here, though, the pilot has committed. As the ship passes through the harbor, it hugs the East Boston shoreline, where the channel is deeper. The Coast Guard allows LNG tankers to enter only on clear days.

Pleasure Bay

As the ship slows, four tugboats lash themselves to its sides. (The tugs can haul the tanker and help it maneuver in case of emergency.) Here, the tanker enters the security zone, and law enforcement appears. No unauthorized vessels are allowed within 500 yards. At least five small boats — the Coast Guard, city and state police, and Massachusetts Environmental Police among them — escort the tanker. One or more choppers hovers above.

http://www.bostonmagazine.com/2010/06/safe-harbor/

http://www.defensemedianetwork.com/stories/u-s-coast-guard-countering-maritime-security-risk/

February 22, 2017

Personal Information Withheld - Dodge Cove, British Columbia

"Potentially catastrophic pool fires or vapor cloud fires could arise from a serious accident or attack on LNG infrastructure. Proposed LNG terminals will directly impact the safety of communities…serious (safety) hazards remain since LNG is inherently volatile and is usually shipped and stored in large quantities.…

Pool Fires. If LNG spills near an ignition source, the evaporating gas in a combustible gas-air concentration will burn above the LNG pool.8 The resulting "pool fire" would spread as the LNG pool expanded away from its source and continued evaporating. A pool fire is intense, burning far more hotly and rapidly than oil or gasoline fires.9 It cannot be extinguished — all the LNG must be consumed before it goes out. Because an LNG pool fire is so hot, its thermal radiation may injure people and damage property a considerable distance from the fire itself. Many experts agree that a large pool fire, especially on water (due to heat transfer), is the most serious LNG hazard.10 Other Safety Hazards. LNG spilled on water could regasify almost instantly in a "flameless explosion," LNG vapor clouds are not toxic, but they could cause asphyxiation by displacing breathable air.The extent of such contact would likely be limited, however, as a major spill would likely result in a more serious fire.

Terrorism Hazards. LNG tankers and land-based facilities could be vulnerable to terrorism. Tankers might be physically attacked in a variety of ways to destroy their cargo — or commandeered for use as weapons against coastal targets.

LNG terminal facilities might also be physically attacked with explosives or through other means. Some LNG facilities may also be indirectly disrupted by "cyberattacks" or attacks on regional electricity grids and communications networks which could in turn affect dependent LNG control and safety systems."

I don't believe that these issues have been adequately described or assessed in the Aurora LNG final application. I don't believe terrorism hazards have been considered at all.

"Federal safety regulations require LNG terminals to be surrounded by "exclusion zones" to protect neighboring communities in the event of a pool fire or flammable vapor cloud. Critics of these LNG safety provisions argue that the thermal and vapor exclusion zones they specify may be too small, in part because the "design spills" on which they are based are too small.

They argue that catastrophes such as terrorist attacks on storage tanks could release far more LNG far more quickly than assumed in siting plans — resulting in larger, hotter pool fires or larger vapor clouds closer to nearby populations. Critics also argue that federally allowable levels of thermal radiation from pool fires are too high, since radiation at these levels could still burn people in a relatively short period of time."

I don't believe that descriptions of what the effects to neighbouring communities in the event of a pool fire or flammable vapor cloud are adequate. The Aurora LNG final application really does not adequately look at human health in any accident or malfunction scenario, or at the cumulative or residual effects. I am going to assume that since the highest likelihood scenario, if a major accident or malfunction happened, would be that the community of Dodge Cove would just no longer exist, therefore cumulative and residual effects do not need to be looked at? Due to proximity of the proposed LNG terminal to Dodge Cove, the overlap of any major accident seems to have the potential to be able to completely incinerate the community.

"As noted earlier in this report, LNG spills on water are potentially more dangerous than spills on land because LNG may spread much more quickly over water and is not readily contained. Consequently, some experts believe an LNG tanker accident or attack resulting in a major spill could pose a hazard to coastal communities along the tanker's route. EXPERTS SAY… LNG ships carry four to six tanks. If about half of a single 6.6-million-gallon tank spilled from a 54-square-foot hole and the vapors ignited, the fire would "cause significant damage to structures, equipment, and machinery" within a 1,280-foot radius and leave second-degree burns on people more than three-quarters of a mile away, according to Sandia's study, which measured impact on open water. In a city, variables such as buildings would affect the fire's path and intensity. Sandia's worst-case scenario measured the result of LNG spilling simultaneously from three tanks, which "would set structur es aflame out to 2,067 feet and burn people as far as [1.3 miles] away," says study coauthor Mike Hightower. Sandia is now studying scenarios in which tanks are breached successively."

The fact that the Aurora LNG terminal would be at the main entrance to Prince Rupert Harbour,and the berthing only about 500 m to the centre of the that main channel, there is a direct risk to all boats passing through, including large cruise ships and BC ferries.Aurora LNG section 9.9.1 - Vessel Grounding or Collision "credible worst case scenario..is a hull breach and containment failure of one LNG membrane tank and one marine fuel tank."

That does not seem to a credible worst-case scenario, if Sandia Laboratories is studying scenarios in which tanks are breached successively than why is that not reflected in the final application. It may be a low risk of happening, but we need to see the consequences of the actual worst-case scenario, and it would have a high consequence.

University of Arkansas chemical engineering professor Jerry Havens, points out that something need go wrong only once.

The Aurora LNG final application 9.9.1 also claims that it is very unlikely for the tankers to become grounded in shallow waters, collide with another vessel along the shipping route, or collide with marine terminal infrastructure.

I question this conclusion as the reality is that several freighters have created collisions, or grounded themselves on the shore or on rocks in this area. High winds create extreme conditions which don't seem to be taken into account in this application, or the history of large ship accidents in Prince Rupert Harbour and the surrounding area.

There is also a list of 35 incidents involving LNG ships (up to the year 2013, since then there has been more).

(CH-IV International - Safety History of International LNG Operations - Appendix B - Chronological Summary of Incidents Involving LNG Ships)

"THE FIRE
1. LNG immediately begins to evaporate when it spills. A vapor cloud forms and grows, and you hope there's no spark. Even with a spark, only the cloud's edges, where 5 to 15 percent of the air is LNG, can ignite. Yet if that part catches fire, the whole thing burns.

2. In an attack, a spark would probably be present as the LNG began to spill, so a fire would start right away. Because the LNG hits the water faster than it all can evaporate, it would form a pool on top of the water. As more spilled, the pool — and the fire — would grow.

3. The LNG would continue feeding the blaze (imagine the fire being attached to the pool) until all the fuel evaporated and burned off, which could take anywhere from three to forty minutes. By then, anything within reach could have ignited and set off other fires.

We believe remote siting is the primary factor in safety. Because of the inevitable uncertainties inherent in large-scale use of new technologies and the vulnerability of the facilities to natural phenomena and sabotage, the public can be best protected by placing these facilities away from densely populated areas."

Throughout the Aurora LNG final application Accidents or Malfunctions section there seems to be a lack of true description of worst-case scenarios. There seems to be many "manageable" scenarios described, yet preventative and response measures are inadequate if a real worst-case scenario NOT described in the application was to take place.

"This is serious stuff," Menino says (mayor of Boston Harbour) "I take it very seriously, and my public-safety officials take it very seriously. We don't have the equipment to put down an explosion of an LNG tank. They say, 'Well, it will never happen.' Well, 9/11 hadn't happened either. We live in a different era."

"Most hazard analyses for LNG terminals and shipping depend on computer models to approximate the effects of hypothetical accidents.
Historical LNG safety experiments have been limited in scale and scope. But LNG hazards models are extremely complex and inherently uncertain, relying on calculations and input assumptions about which fair-minded analysts may legitimately disagree. Even small differences in an LNG hazard model have led to significantly different conclusions. Referring to previous LNG safety zone studies, FERC noted in 2003 that "distances have been estimated to range from 1400 feet to more than 4000 feet for hazardous thermal radiation."

This is hardly comforting as the fact that 4000 feet = 1.2 km, and the community of Dodge Cove will only be 1/2 km away from the Aurora LNG terminal and therefore possibly in hazardous thermal radiation zone.

"Each of the available studies appear to have significant limitations …for example, the ABSG Consulting study released by FERC in May 2004, which reviewed existing LNG hazard models, concluded that 1)No release models are available that take into account the true structure of an LNG carrier 2)No pool spread models are available that account for wave action or currents 3)Relatively few experimental data are available for validation for models involving LNG spills on water, and there are no data available for spills as large as the spills considered in this study. "

If there is a lack of data - in existing hazard models - than how can we actually know the impacts that would take place, especially with the south ends of Digby Island having much wave action and currents, as the tide pushes in and out of Prince Rupert Harbour every 6 hours. If there is no data on large spills, and the data for small spills is being used to calculate what a large spill would be like, than that is a big data gap.

"It is often argued that a significant hazard which is nonetheless highly unlikely does not represent an unacceptable risk to the public. In this view, worst-case hazard studies alone do not provide a sufficient basis for evaluating public safety. Unfortunately, few LNG safety studies comprehensively and convincingly address the probability of catastrophic accidents or attacks actually occurring."

It seems that the Aurora LNG final application fails to comprehensively look at both the worst-case scenarios for accident or malfunction of the terminal and it's impacts to local communities (especially Dodge Cove at 1/2 km away) and also at the unacceptable RISK to the PUBLIC. The proposed site alone for the Aurora LNG terminal proves this, and the lack of the Section 9 to accurately describe impacts to the local communities and residents seems clear.

"Civil and Criminal Liability. One reason LNG tanker and terminal operators seek to ensure public safety is to avoid civil and criminal liability from an LNG accident. Even if no federal or state regulations are violated, LNG companies still face civil liability for personal injury or wrongful death in the event of an accident. In the Bellingham case, for example, the pipeline owner and associated defendants agreed to pay a $75 million settlement to the families of two children killed in the accident.91 In 2002, El Paso Corporation settled wrongful death and personal injury lawsuits stemming from a natural gas pipeline explosion near Carlsbad, New Mexico which killed 12 campers. Although the terms of those settlements were not disclosed, two additional lawsuits sought a total of $171 million in damages."

Over 27 Land LNG Facility Incidents are listed in : The CH-IV International - Safety History of International LNG Operations - Appendix A - Chronological Summary of Incidents Involving Land-Based LNG Facilities, which only lists accidents/incidents up until 2013. Another 3 have happened since then. These 30 LNG related terminal events include many large and small incidents, and are only the ones that are reported. This does NOT include all the other natural gas related incidents, including all the PIPELINE accidents, of which a natural gas pipeline will be feeding gas to the LNG terminal, so can not be discounted.

"Banning Onshore LNG Terminals. As some have suggested, Congress could ban the construction of any new LNG terminals onshore in the belief that, due to their hazards, such terminals simply should not be built anywhere near people.94 Many "remote siting" advocates would likely support such a ban. Indeed, developers have already proposed numerous offshore LNG terminals — largely to avoid public safety concerns."

One of the things that the BC environmental assessment process does not consider: whether this site is an accurate location in the first place. Should onshore LNG terminals even be proposed? Why are alternative locations - onshore or offshore - not also being assessed and put forward for the choice of what the best location would be?

(Even Russia does an environmental assessment on a minimum of 3 locations for every LNG terminal proposed - why is Canada not setting forth siting regulations?) I would like to see a list of the other locations that Nexen employees verbally claim to have "considered" as none of those locations are public knowledge or addressed in the Aurora LNG applications, and it would be interesting to see - why was this location on Digby Island supposedly chosen above these other sites - especially with the difficulties of proximity to residents, communities, existing marine traffic zones, and the only airport servicing this entire area.

"LNG is inherently hazardous and its infrastructure is potentially attractive to terrorists. The recent LNG terminal fire in Algeria demonstrates that, despite technological improvements since the 1940s, LNG facilities can still experience serious accidents."

All of the excerpts from the LNG Import Terminals, Siting, Safety and Regulation really deal with some major concepts and data gaps that the Aurora LNG final application does not deal with. Since this would be one of the largest LNG export terminals in Canada (of which Canada does not have one single LNG export facility yet - and lacks solid regulations for LNG export) and the closest proximity to communities, these existing studies and problems with hazard modelling and data gaps need to be addressed. Are the residents of Dodge Cove, Crippen Cove, and Prince Rupert to be human guinea pigs? If a major accident happens, there will be drastic consequences for the people that live here.

LNG Import Terminals: Siting, Safety and Regulation CRS Report for Congress http://www.iags.org/CRS_RL32205.pdf
(note, there seems to be two versions of this report - some of these quoted statements are from a printed version, but this online link fails to include a few of the same statements) https://www.everycrsreport.com/reports/RL32205.html

http://www.bostonmagazine.com/2010/06/safe-harbor/
http://www.defensemedianetwork.com/stories/u-s-coast-guard-countering-maritime-security-risk/

image of BC Ferries

Sheila Peters - Smithers, British Columbia

I am very concerned about the possibility of an LNG project on Digby Island. There is already more than enough pressure on this rich marine eco-system and the important archaeological sites in the area have barely been studied. A project of this size in this location would be a mistake.

Margaret Johnson

Dear Environmental Assessment Office:

Re: Please do NOT allow the proposed Aurora LNG fracked gas plant to be built.

It is with a sense of urgency that I am writing to you. I am deeply concerned that this proposal should br denied for the following reasons:

The negative impact on salmon and wildlife;

The negative impact on the health and safety of the surrounding communities.

The negative impact on our climate..

PLEASE DO NOT ALLOW THIS PLANT TO BE CONSTRUCTED.

Sincerely,

Margaret Johnson, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Colt Cash

Sincerely,

Colt Cash, Penticton

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Janice and Dave Rider

My husband and I recently spent time in the Great Bear Rain Forest, where we had the privilege of watching chinook, chum, pink, and coho salmon in various estuaries and rivers. These salmon and the water that nurtures them are, quite literally, life for the grizzly and black bears in the area; for birds as diverse as gulls, bald eagles, great blue herons, and ravens; for trees and plants nurtured by decomposing salmon bodies amongst their vegetation; for First Nations people; and for smaller organisms in water that we simply never stop to consider.

We are deeply upset about Nexen's proposal to install Aurora LNG, owned by a Chinese oil corporation with no investment in our safety and well-being, in the area of Prince Rupert on Digby Island. We recognize that this area is extremely similar to the one that we visited in and around Klemtu. The wild salmon around Digby Island - coho, steelhead, and sockeye - are extremely vulnerable to interference. They also support flora and fauna. Digby's wetlands, which are necessary for the continued health of migrating birds such as geese, ducks, swans, cranes, herons, and song birds, would be compromised as would the eel grass habitat and Delusion Bay's serenity. The harbour porpoise, already comprised by activity in the area, would be further set at risk.

And what of First Nations people here? Is their strong opposition to this proposal being considered? The plant site would be less than one kilometre from Dodge Cove which means that it would violate international siting standards.

And what of BC's legislated climate targets?

Climate change is fundamentally and irrevocably tied to water issues - ocean water concerns, wetland water concerns, and various water tributary concerns. Whenever decisions are made, we need to ask, "How will this impact water?" We cannot afford to put drinking water at risk. Neither can we afford to put the species that depend on pristine water at risk, including ourselves.

We strongly feel that Nexen's proposal should not go ahead. Thank you for your consideration.

Sincerely,

Janice and Dave Rider, Calgary

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Sue Maxwell

Dear EAO,

I grew up in Kitimat and know the beauty and richness of the marine life of that area. Please prevent the LNG plant from being built by Delusion Bay. Our salmon stocks are declining so we should be preserving all the critical habitat to allow for their return (as well as getting rid of open net fish farms). We also need to be looking at climate change as the biggest threat we are currently facing, so prevent LNG as well as flaring will ensure a decrease in GHG emissions. Preventing the flaring will also prevent numerous other air emissions that may threaten bird life.

The reasons to prevent this further expansion of LNG are numerous but the reasons to proceed are few (and getting fewer) as these projects provide few new permanent jobs, that may not be filled by British Columbians and BC is offering more and more subsidies for these plants that eventually BC will be paying for the environmental destruction. The costs far outweigh any potential benefits. It is not worth the risk.

Sincerely,

Sue Maxwell, Whistler

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

G. Alan Robertson

Dear EAO, You cannot possibly do an assessment on this proposed LNG plant and find it meets the criteria for approval. On so many fronts it does not but mainly the very real danger of losing B.C.'s vital Skeena salmon fishery. Your conscience alone should tell you the destruction of this estuary would be a criminal act of unforgivable proportion, especially added to the Petronas proposal. This is madness ! Stand up to your responsibility and reject this proposal!

Sincerely,

G. Alan Robertson, Salt Spring Island

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Brian Fink

Dear EAO,

Sincerely,

Brian Fink, Philadelphia

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kate Archibald

Dear EAO,

Healthy wild salmon populations are just too important to the health of the BC coast. Wild salmon are already in a very precarious position as it is foreseeable now, as it never has been before, that one day they could vanish from this coast. We MUST do ALL that we possible can to preserve the health of their habitiat. A new fracked gas plant on Digby Island is one more nail in the coffin. I cannot sit back and allow this to happen on my watch, as someone who was born and raised on this coast and has been nourished by wild salmon since before I was even born.

Thank you for listening,

Sincerely,

Kate Archibald, Manson's Landing

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Theresa Hood

Dear EAO,

Fracked natural gas is not sustainable. Fracking is dangerous and detrimental to the environment.

We must come up with economics that nourish our environment as well as the humans that live on this wonderful planet.

These are the times when we are being called to make radical changes in the way we live and do business.

If not now, when? If not us, who?

Sincerely,

Theresa Hood, Nanaimo

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

February 21, 2017

Jan Yeb's Ypma - Dodge Cove, Digby Island, British Columbia

That this project, so close to the village of Dodge Cove and its citizens in terms of threats to the quality of life, the safety of our water supply, the negative effects of noise, air pollution, and marine traffic safety should NOT be approved as presently planned, is a foregone conclusion.

Jan Yeb's Ypma - Dodge Cove, Digby Island, British Columbia

What a rare little gem of a place this Digby Island is! So close to Prince Rupert and yet so rich with native and later settler's history.

So accessible to other Canadians who wish to enjoy the natural wealth of the area's flora and fauna.

Why jeopardize it in this day and age, when these qualities are disappearing before our eyes?

Jan Yeb's Ypma - Dodge Cove, Digby Island, British Columbia

Not going ahead with this project..... protecting the quality of life of all Digby Island inhabitants, including the areas' abundant but fragile wealth of marine and terrestrial flora and fauna, now that would be something to be proud of, eh what?

Can we expect such a richness of vision and wisdom from Canada and BC?

Yes, we can, for this is the new, post-industrial Canada.

Jan Yeb's Ypma - Dodge Cove, Digby Island, British Columbia

A government can be called noble-minded if it shows respect and honours quality of life for its citizenry. >

Isn't it wonderful to know that British Columbia is such a place?

Personal Information Withheld - Dodge Cove, British Columbia

The broader contexts of which Digby Island residents use, manage, and occupy the surrounding land needs to be considered. We have interests in the proposed area of development. The government wants information relating to the specific nature of those interests. This process of soliciting information puts the onus on Dodge Cove and other Digby Island residents to review its interests in the area affected by the decision and then to formulate a written response to the proposed development. "Discussions" and "mitigation" fail to reflect the true relationship we have with the place we live. Many communities, especially small ones such as Dodge Cove, struggle to participate fully in the consultation process. Responses require the compilation and presentation of information. With very little help or experience in doing so, how are we, the residents of Digby Island, supposed to compile generations of information and local knowledge into a presentable case that reflect s accurately how integrated our entire lives are with the natural function of Digby Island? This is an almost impossible task especially with a very tight time frame, and most of our information is maintained not in recorded writings but in the knowledge of past and present residents. An entire history of a community should not be dismissed so easily as CNOOC-Nexen Aurora LNG Final Application has done.

The broader ethnographic contexts of our history and our culture are rarely considered. Our perspectives which unite our understanding of the land with our social and community activities are greatly different from a compartmentalized planning process. We are expected to separate information about our local biology from information about our cultural practices. The fact that our communities will be devastatingly impacted and changed beyond any measure of our present knowledge is not accurately captured in the Auora LNG final application. With little bits of information stuck in throughout the application, instead of a solid highly detailed description of our community, it's longevity, and any history that could accurately reflect a portion of what needs to be acknowledged.

As well, any traditional use studies identify location of activities and minimize the importance of our places, our activities on the land, and the complexities of our family-based connections to these places. Our interests are being limited mostly to the area of the proposal, even though that same proposal will change the entire ecosystem of Digby Island, and so our interests on our use extend to the entire island which will be dramatically negatively impacted. Any traditional use studies do not take into account holistic or spiritual importance of these land uses for our community.

Biodiversity, sustainability, and ecosystem functions will be compromised for the entire Digby Island. This has to be acknowledged and our land use and affect to our community has to reflect this.
For our community, practices such as hunting and fishing, food gathering and simply being part of the natural life in this area are broadly integrated into our land use and movement of people, and family relationships. The studies by CNOOC-Nexen for Aurora LNG try to state where activities have occurred but there fails to be a comprehensive and holistic understanding, and recognition, of our cultural practices and ideological connections to the land and the surrounding living things.

Site-specific land use maps also draw attention only to particular locations on a map while minimizing the cultural value of the space in between those locations. So much attention is given to to the places in which people say they conduct activities that a wider area, an important of place in and of itself, is forgotten. Traditional land use studies focus on a restricted number of activities and interests, and do not pay attention to spirituality and culture. They do not accurately reflect how communities such as Dodge Cove use the land in part to poor understanding of the culture that we have here.

We must assert the importance of place to communities such as ours, to the people that live here, and to the personal and social identities of both. Existence requires emplacement. A focused awareness founded on the experiences of the individual at a particular location. There is a complete non-awareness from CNOOC-Nexen employees of the culture in this area, and a disconnect in understanding the motivations and roots that communities like ours instill in individuals.

There has never been a fixed boundary map around the area of use for us - there has never been a fixed boundary of only using the land and waters inside Dodge Cove Official Community Plan. This process is making us define our usage overtop of lands when in effect we have all been sharing the use of these lands and waters. How do you define boundaries on land and water like that?

Even the smallest of our use footprints is connected to the larger area of Digby Island and the surrounding waters, to the historical and present movement of our community, and the connection to our homes. The fluid and flexible nature of our way of thinking and our activities is not represented by a map of fixed boundaries. A cultural security and continuity approach regards a land base as necessary to cultural identity and survival.

Our identity is linked to a long history of Digby Island. If we look only at the proposal site, that is a piecemeal small-spot approach to the proposal. We need to consider the impact to the entire area that we use, as the proposal is a vast majority of that area and impact will extend to our entire land and water use area. We have been the habitual land/water users of Digby Island for over 100 years - the entire area surrounding our community, although actual resources were freely shared and exchanged. Consideration has to be given to the impact on the surrounding vegetation and streams and any other area even if not in the project footprint.

The land has defined and sustained us as a people. The spaces between maps have to be viewed as part of larger, culturally meaningful area. That area is NOT freely available/awaiting development.
We have emotional and spiritual connections to places even if we do not have location specific markers. All sites are connected to the wider area and cultural identity and continuity.

A lack of demonstrable use of the land does not mean a lack of knowledge, connection, or claim to that land. We are careful about our impact on the island and always have been. The Aurora LNG Final Application mentions that they have observed certain areas to be high-use by our community (such as Casey Cove/Marine Bay) but have not seen significant use of the rest of Digby Island. This is pimarily due to the fact that the CNOOC-Nexen employees have been on the island, inhibiting hunting and other activity - the helicopter traffic in the last year has been significantly disturbing both to Dodge Cove residents and to the wildlife on the island, the community was specifically told by Nexen to not go anywhere near where they were working, and at times when people did try to continue their usual activities there were told to leave by CNOOC-Nexen employees.

Therefore the use of the island and waters while CNOOC-Nexen has invaded the island have not been the norm, also factor into that residents have been overwhelmed by stress, meetings, and paperwork trying to study and be informed regarding the negative impacts that the Aurora LNG export terminal would have on our community, on top of their daily work and regular chores to the point that it has been impossible to live in the same manner that we have been accustomed to for decades.

There is a lack of nuanced, qualitive research by CNOOC-NEXEN on the impacts of the Aurora LNG terminal. The final application for Aurora LNG fails to acknowledge the devastating impact that the Aurora LNG export terminal would have on the culture and identity of the residents on Digby island, fails to acknowledge the traditional knowledge and use of the land and surrounding areas in any meaningful way, fails to acknowledge the impact that this project will have on the surrounding area as if the impact will mostly be constrained within the boundaries of the Project area. The Aurora LNG project Final Application uses very old and inaccurate methods of trying to measure land use, and fails to acknowledge that never before have we used this area within boundaries on a map, and ecological and cultural impacts cannot be defined by those boundaries.

Referenced from article:
Making Place for Space: Land Use and Occupancy Studies, Counter-Mapping, and the Supreme Court of Canada's Tsilhqot'in Decision By Thomas McIlwraith and Raymond Cormier - printed in BC Studies Number 188 Winter 2015 /16

image

Personal Information Withheld - Kispiox Valley, British Columbia

There is sufficient evidence to show that LNG produced by burning natural gas along with the fracking and compressor stations will produce more greenhouse gases than burning coal for the same amount of electricity. The electricity to power LNG conversion would be created by burning fracked gas on site. Acid rain and degraded air quality would be introduced to northern B.C.

How will Canada and B.C. make it's commitment to reducing greenhouse gases- it won't if this project goes through. This is not the direction that Canada should go. We should be pursuing renewable energy projects.

The dredging of delusion bay will be another blow to the health of Juvenile salmon habitat. The disruption of the community of Dodge cove will be devastating. The "nox" gasses produced by burning the fracked gasses for lng production will cause problems throughout the Prince Rupert area in poor weather conditions. The increased tanker traffic in an already crowded corridor will be a cause for concern. There are many reasons for not pursuing an LNG terminal on Digby Island or anywhere else in northern B.C. , so why take chances on the health and sustainability of our northern communities. Please do not go forward with this project!

Gord Longley

Dear EAO,

It's the same old story.... Economics or a healthy sustainable future for humanity All livin' things))?
Since man/woman has crushed grapes, leaders of Big Money individuals/corporations and power/control religion has been spinnin' lies and tryin' to delude the masses that they have our best interests in heart.
Not buyin' the B.S. It's not so much, you, the politicians and policy makers, that are the problem but the "system" itself.
Here's a radical, but well thought out, solution...

#ubuntucontributionism
#ubuntuplanet.org
#michaeltellinger

- G -

Sincerely,

Gord Longley, SALMON ARM

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Mona Braschuk

Dear EAO,
I am totally opposed to creating more fracking projects anywhere. In fact, I believe all fracking should stop now. It is destroying huge amounts of water which is, in case you have not been made aware, essential to support all life forms.
It is time to promote and support alternate forms of energy production. The "Green Economy" will provide more jobs and more wages and more government revenue in the long term.
I urge you to stop supporting all fracking projects as they will not provide any long-term benefits and, in fact, will generate long-term environmental destruction that future generations will be forced to deal with.

Sincerely,

Mona Braschuk, Victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kat Zimmer

Dear EAO,

I strongly oppose the building of the Aurora LNG plant. This plant would blow BC's carbon emissions out of the water and this is unacceptable given Canada's commitments on climate change.

I am also very concerned about the impacts to salmon and other wildlife in the area. The area was classified as being as valuable as Flora Bank for salmon by Dr. Barb Faggetter. With climate impacts and salmon populations already at dangerously low levels, we cannot create more risks for them.

Digby Island's ancient muskeg wetlands also provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

I am also very concerned about community safety. The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

Finally, as a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

Please do not allow this project to go forward.

Sincerely,

Kat Zimmer, Victoria

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Tami Palacky

Dear EAO,

Sincerely,

Tami Palacky, Springfield

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Deborah Hobbs

Dear EAO,

Please do not allow the gas plant being proposed by Nexen, the Aurora LNG to be built on Digby island which is just North of the Skeena estuary where young salmon make their way to the ocean each year. This plant would be going into critical habitat for various species of salmon. This area also provides important habitat for migratory birds. recent reports suggest there are declines in bird populations. The tanker traffic and noise will also cause significant impacts to the harbour porpoise which is a species of special concern. Other problems with this project are the potential damage done to the air quality, drinking water of the local communities. This project impacts First Nations and violates their rights if they do not approve this. This project will also further add to climate change of which we are already experiencing and must take action to slow it down. Please do not let this project destroy this beautiful BC coast.

Sincerely,

Deborah Hobbs, Edmonton

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

bronwen evans

Dear EAO,
I am writing in regards to Aurora LNG. Please do not allow this massive fracked gas plant to be built. Up to a billion young salmon make their way into the ocean each year, where this is being proposed to be built. This would mean disaster to the surrounding area. Please do not allow this to happen.
thank you for taking the time

Sincerely,

bronwen evans, vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Peggy Moody

Dear EAO,

Sincerely,

Peggy Moody, Iron Mountain

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Ida Middleto

Dear EAO,
I fully support LNG in the Prince Rupert area. Please develop this resource and build the necessary infrastructure, facilities and develop the areas needed to bring, and transport this resource. The majority of residents in Prince Rupert and Port Edward fully support this project. Please bring it to us!!!
I DO NOTsupport the Sierra Club's point of view!!!

Sincerely,

Ida Middleto, Prine Rupert

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Peggy Watkins

Dear EAO,
I disagree with the Aurora LNG project. It is being proposed for Delusion Bay which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank and should be protected!
This project would also endanger community health and safety and disregard First Nations rights. Please say NO to this LNG project.
Thank you.

Sincerely,

Peggy Watkins, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Dawn Bright

Dear EAO,

Development and progress are good, but not when they are overused or showing harm to the environment and the creatures it supports. There are already too many stressors on the environment due to many hands in the pot to make money and create jobs. I am not in favor of this project though. Fracking is causing too much damage and even causing some earthquakes. If you want your children and your grandchildren to enjoy the beauty of life you must stop this plant from being built. Every damaging project put together is destroying too much life and it WILL affect our health and future as well.

Sincerely,

Dawn Bright, Abbotsford

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Eric Athlan

Dear EAO,

Sincerely,

Eric Athlan, Montreal

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Kelly Loewen

Dear EAO,

Please stop the proposed Aurora LNG plant on Digby Island. This area is an extremely important habitat for millions of salmon, one of our province's most iconic and important animals and sources of food for First Nations, bears, eagles, and the rich forests of the interior.

LNG is NOT clean. We need to reject this proposal and reject LNG in BC. Nobody wants it except industry insiders who stand to profit, while the province stands to suffer. Not only salmon but drinking water are at risk when fracking occurs that will be supplying this LNG plant.

At the very least, the project should gain clear and informed approval by the First Nations whose UNCEDED land this is proposed to be built on, and the area is their source of food. Spills and contamination are an unmitigable risk.

Sincerely,

Kelly Loewen, Prince George

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Carlos Sanchez

Dear EAO,

Sincerely,

Carlos Sanchez, MIrabel

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Nicole Thom

Dear EAO,

Skeena estuary habitat is irreplaceable. The increased anthropogenic activity and habitat loss and degradation will add that much more to the cumulative impacts already happening on the watershed and estuary!

This project does not have BC's best interests in mind! We are supporting foreign investors who don't care about the environmental impacts that BC bares.

Please do not let this project go through.

Sincerely,
Nicole Thom

Sincerely,

Nicole Thom, Port Coquitlam

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Mark M Giese

Dear EAO:

Aurora LNG threatens salmon and wildlife.

Aurora LNG threatens community health and safety; please cancel it..

Thank you.

Sincerely,

Mark M Giese, Racine

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Michael O'Neill

Dear EAO,
The proposed Aurora liquefied natural gas plant near the Skeena Estuary is so wrong-headed that it is difficult to take it seriously. When I was a young man I heard that BC harvested 10 times as many salmon as Alaska. Now that I am an old man I hear that Alaska harvests 10 times as many salmon as BC. They gave been good stewards of their environment. We have not. When I first started scuba diving in BC waters 44 years ago, every underwater crevice was filled with rock cod, and every kelp bed was filled with greenlings. Dalhousie University's meta-study of fish populations found that 85% of the larges fishes that used to inhabit world oceans are gone. But diving in BC I know that most of the smaller fishes are also gone. Most British Columbians do not see beneath the surface of the sea so how could they know that most of BC's coast is already the desolate waste that Rachel Carson predicted in Silent Spring? The southern Orcas of BC & Washington are an endangered species whose only remembrance may soon be a pathetic logo on a hockey team's jerseys.
The waters of our northern BC coast are less devastated, but we could change that in a hurry with a Fossil fuel plant adjacent to the Skeena Estuary. We could create more sustainable jobs cleaning up the estuaries we have already polluted, rather than destroying one of the few remaining healthy river systems.
So why would we even consider such destruction? So China can produce more shoddy textiles and put more Canadian workers out of their jobs? So politicians can get more fat contributions for their next election campaign? So the few remaining First Nations children can no longer drink the water in their wells?

Sincerely,

Michael O'Neill, Courtenay, BC

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Lorraine Lowry

Dear EAO,

Sincerely,

Lorraine Lowry, Toronto

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Daniel Mckenzie

Dear EAO,

I am so sick of hearing about all these environmentally destructive gas and power plants being built. This is for all the people involved in the process of these backward projects, give your heads a shake and ask yourselves, do you want a future on this planet? Do you want this for the next generation? Clean free energy is everywhere and you have to be pretty blind minded not to see that, or you've been eating from our sickly corrupted, money hungry governmental system that's been poisoning the people with chemical food, chemical drugs, and chemical injections into our infant population. I'm always hearing: We need more growth in our economy! We need more jobs for people! What we actually need, is a sustainable economy, one that stops growing and levels out to a sustainable point. An ever-growing economy is doomed for destruction, poverty, and food and water exhaustion. It starts with education, the whole education system needs an over-haul and a update, its needs to evolve with the people and people need to evolve with the right education to learn properly and for there own uniqueness. The population on our planet is way above sustainable, if education is not altered to teach this and many other important aspects about living with nature, then we won't have a planet to come back to in our next phase of evolution. This should be top priority for all leaders of the world. Controlling population with poison in our food supply is an act of genocide and the people responsible should be held accountable and justice needs to come about for their crimes against humanity and nature. I can only hope the readers of this will not be null minded and take every aspect with the utmost seriousness. This is of critical importance.

Lets make a future we can be proud of.

Daniel Mckenzie

Sincerely,

Daniel Mckenzie, Salt Spring Island

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Nancy McInnes

Dear EAO,
I am very concerned about plans to build a huge gas fracking plant on Digby Island, near Prince Rupert. This area is important habitat for several salmon runs. A fracking plant would threaten the survival of the salmon. The ocean channel near Prince Rupert is narrow and can be treacherous, giving a risk of serious accidents involving large tanker ships.
We must put our highest priority on the survival of wild species and the health of local environments. If there were such an accident causing a catastrophic oil spill, it would be impossible to reverse the damage.
Sincerely,
Nancy McInnes
Nanaimo, B.C.

Sincerely,

Nancy McInnes, Nanaimo

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Silvia Bertano

Dear EAO,

I'm writing to say no to Aurora LNG

SAVE SKEENA ESTUARY!

Sincerely,

Silvia Bertano, Torino

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Lynn Hamilton

Dear EAO,
AURORA LNG THREATENS SALMON AND WILDLIFE
The plant would be built beside Delusion Bay, which provides critical habitat for steelhead, coho and sockeye salmon. This habitat zone is considered to be as valuable as Flora Bank. Aurora LNG could pose risks similar to the risks posed to Flora Bank salmon by Petronas.
Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.
AURORA LNG THREATENS COMMUNITY HEALTH AND SAFETY
The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.
The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.
The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.
AURORA LNG THREATENS OUR CLIMATE
As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budget.

Sincerely,

Lynn Hamilton, Courtenay

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

Debra Herst

Dear EAO,
Digby Island's ancient muskeg wetlands provide important habitat for migrating birds such as geese, ducks, swans, sandhill cranes, great blue herons and song birds. The terminal's gas flaring would send burning gasses into the air along their migration routes and could pose other concerns for land wildlife. A proposed three-lane road, plant construction and acidification of the air and water would directly damage wetlands, important eel grass habitat and the area surrounding Delusion Bay, destroying bird nesting areas and blocking migration routes. Tanker noise would also cause significant impacts to the harbour porpoise, a species of special concern.

The plant would pollute the pristine air, drinking water and soil of local communities. Construction blasting and drilling and 24/7 operation of the plant and associated infrastructure would create significant impacts from noise, light, air and water pollution, degrading wildlife areas and quality of life for residents. A 2015 survey showed that 96 per cent of local residents were opposed to the project.

The plant would be built less than a kilometre from the historic community of Dodge Cove, violating international siting standards. The entrance to Prince Rupert Harbour is a hazardous narrow channel with strong tidal currents and severe winter storms. This raises the potential for collisions, grounding of vessels and oil spills or LNG tank ruptures.

The proposed site is within Metlakatla, Lax Kw'alaams and Gitxaala Traditional Territories. For millennia, these First Nations have relied on the area for fishing and food harvesting. A report prepared for the Gitxaala Nation showed the project poses direct risks to food security, fisheries, community health and cultural heritage. As a signatory to the UN Declaration on the Rights of Indigenous Peoples, Canada must obtain free, prior and informed consent from First Nations before approving the project. If it can't demonstrate this, the project should not be approved.

As BC's largest LNG facility to date, this fracked gas plant would produce 6.7 million tonnes of greenhouse gas emissions per year! And that doesn't even count the emissions involved in plant construction, shipping and burning of this fossil fuel in Asia. This project would smash through BC's legislated climate targets and blow our carbon budge

Sincerely,

Debra Herst, Vancouver

cc: The Honourable Christy Clark, The Honourable Mary Polak, The Honourable Rich Coleman

February 20, 2017

Personal Information Withheld - Prince Rupert, British Columbia

I have several concerns with the proposed project. The proponent has taken a very low profile approach with the project and there has been little to no d