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Summary of Issues

Sent by Email Only

October 30, 2019

Tony Brady
President, Cedar LNG Export Development Ltd.
500 Gitksan Avenue
Haisla P.O. Box 1101
Kitamaat Village BC  V0T 2B0
tbrady@haisla.ca
Agency File No: 005734

Dear Mr. Brady:

Subject:   Summary of Issues for the Cedar LNG Project

The Impact Assessment Agency of Canada (the Agency) conducted a comment period from September 19, 2019 to October 20, 2019, inviting participants to provide feedback related to the Cedar LNG Project (the Project). Submissions received from Indigenous groups, federal authorities and the public are available on the Canadian Impact Assessment Registry (reference # 80208).

A Summary of Issues document, which reflects the issues raised through comments received by the Agency during the comment period, is enclosed with this letter. As it is a high-level summary, the Agency directs Cedar LNG Export Development Ltd. to review the original submissions posted on the Registry.

Pursuant to subsection 15(1) of the Impact Assessment Act, Cedar LNG Export Development Ltd. must provide the Agency with a Detailed Project Description that sets out how it intends to address the issues in the Summary of Issues and includes the information described in the Information and Management of Time Limits Regulations (the Regulations). The requirements for the Detailed Project Description are set out in section 4 and Schedule 2 of the Regulations. Please consult the Guide to Preparing an Initial Project Description and a Detailed Project Description at www.canada.ca/en/impact-assessment-agency/services/policy-guidance/practitioners-guide-impact-assessment-act/guide-preparing-project-description-detailed-project-description.html for further information.

Cedar LNG Export Development Ltd. is encouraged to provide meaningful responses to the issues included in the Summary of Issues. The Summary of Issues and Cedar LNG Export Development Ltd.'s responses will be used to inform the Agency's decision on whether to require an impact assessment for the Project, and to inform the information requirements and plans for the impact assessment, should one be required.

In preparing the response, there may be some issues that, in the view of Cedar LNG Export Development Ltd., are outside of its care and control. In this situation, Cedar LNG Export Development Ltd. may choose to identify the party or parties with the potential to address the issue(s).

As part of the comment period, the Agency also invited comments from the public and Indigenous groups on the request from the Government of British Columbia that the conduct of the federal impact assessment, should one be required, be substituted to the province. Comments received in relation to the substitution request will be considered by the Minister of Environment and Climate Change in making the substitution decision; they are not reflected in the Summary of Issues and Cedar LNG Export Development Ltd. is not expected to provide a response to those comments.

The Agency has estimated that it will take approximately 30 days – until December 2, 2019 – for you to provide the Detailed Project Description, including the response to the Summary of Issues. In consideration of efforts being made to coordinate the provincial environmental assessment and the federal Planning Phase steps under the Impact Assessment Act, the Agency recognizes that Cedar LNG Export Development Ltd. may require additional time to produce the Detailed Project Description. You are encouraged to contact the Agency in the next few days to discuss how much time will be required.

Important note: Cedar LNG Export Development Ltd. is reminded that all records produced, collected or received in relation to the impact assessment of the Project – unless prohibited under the Access to Information Act – will be considered public and posted on the Canadian Impact Assessment Registry Internet site.

For ease of reference, the Agency requests that the response to the Summary of Issues be provided in a table with reference to other parts of the Detailed Project Description as warranted. If you have any questions, please do not hesitate to contact me at 236-888-7499 or iaac.cedarlng-gnlcedar.aeic@canada.ca

Sincerely,

<Original signed by>

Nicola Cook
Project Manager

Enclosure:  Cedar LNG Project - Summary of Issues

c.c.: Mr. Robin Junger, McMillan LLP
Fern Stockman, British Columbia Environmental Assessment Office


Cedar LNG Project - Summary of issues

This document provides a high-level summary of the issues raised through comments received by the Impact Assessment Agency of Canada on the Cedar LNG Project (the Project) during the comment period on the Initial Project Description submitted by the proponent, Cedar LNG Export Development LtdFootnote 1. Original submissions are posted on the Canadian Impact Assessment Registry.

Accidents and Malfunctions

Effects of accidents or malfunctions, including spills of hazardous substances, and the consideration of spill prevention and response plans in the assessment.

Effects of marine shipping-related accidents or malfunctions including effects to the health and safety of Indigenous peoples and on title, rights and interests, including distinct customs and cultural practices.

Acoustic Environment

Effects of underwater noise from Project activities including construction and marine shipping.

Effects of noise on health of human receptors, including those with a heightened sensitivity to noise exposure (e.g., Indigenous peoples, schools, childcare centres, places of worship).

Effects of noise on wildlife, including from construction activity, machinery use and increased vehicle traffic.

Alternative Means of Carrying Out the Project

Effects from all design options, including in relation to power generation, on Aboriginal rights, direct air emissions, and greenhouse gas (GHG) emissions.

Clarity on rationale for using floating versus land-based facilities.

Atmospheric Environment

Effects on air quality through land clearing activities, power generation, fuel combustion, incineration, flaring, and vehicle and vessel traffic.

Effects on air quality through improper management or disposal of materials, including contaminated soil and excavated materials, organic waste and wastes from construction, liquid wastes (storm water, sanitary wastewater, effluent run off, industrial wastewater from gas dehydration process, and ballast water discharge) and other hazardous wastes.

Effects from the emissions of pollutants on sensitive receivers (e.g., migratory birds, species at risk, health of Indigenous communities) and their habitat, including from soil and surface water acidification.

Consideration of emissions that may result in exceedances of established regional air quality thresholds for management action.

Climate Change and Greenhouse Gas Emissions

Impact on Canada's ability to meet its obligations and commitments in respect of climate change.

Effects of GHG emissions, including those generated by marine shipping, and the Project's contribution to climate change.

Country Foods

Effects on quality and quantity of county foods, including seafood (salmon, crab, halibut and eulachon), wildlife and plants, including medicines.

Effects on country foods from the release of contaminants of potential concern into the environment (air, water, soil) which could be absorbed by foods sourced through hunting, trapping, fishing, harvesting, grown for subsistence or medicinal purposes, or having Indigenous cultural importance.

Effects on the status of food security within the Indigenous groups and local communities.

Cumulative Effects

Cumulative effects on airsheds (e.g., Kitimat Airshed, Douglas Channel Airshed) and of GHG emissions from all phases of the Project in combination with other past, present and future industrial development and marine shipping.

Cumulative effects on nearby watercourses and waterbodies along the corridor for the feed gas distribution system.

Cumulative effects to species at risk from upstream gas development, including Caribou, Grizzly Bear, fish and amphibians.

Consideration of research on the efficacy of past mitigation measures and restoration projects in the surrounding area.

Cumulative effects of marine shipping on human health of the general population and Indigenous peoples, on fish and other marine species, and on marine navigation including by Indigenous peoples.

Cumulative effects of marine shipping to the rights, title and interests of Indigenous peoples within territories that overlap with the shipping route.

Economic Conditions

Effects on economic conditions resulting from increased population, economic activities and opportunities, changes to cost of living, social and cultural settings, and in- and out- migration.

Effects on local businesses that may provide supplies and services required for the Project, including tourism as it relates to effects to fish and fish habitat.

Effects on the labour force, including the availability of skilled and unskilled workers, existing working conditions, wages and/or average salary, full-time/part-time and temporary/permanent employment and training and recruiting plan.

Effects on domestic gas supply, including pricing, and global gas market analysis. 

Effects of the Environment on the Project

Effects of the environment on the Project through extreme weather events, increased precipitation due to climate change, tsunamis, landslides, slope erosion, rock/ground instability, marine geology, geohazards and potential of submarine landslides.

Inclusion of a seismic hazard assessment and terrain hazards assessment.

Fish and Fish Habitat

Effects on fish (including salmon and herring) mortality, lifecycle and productivity, and fish habitat, through alteration, disruption and destruction of fish habitat, during all Project phases.

General

Ability for the public to actively participate in the assessment.  

Provision of government support to facilitate research related to public concerns.     

Inclusion of nearby communities, including Terrace and Indigenous communities, in the study areas for relevant valued components including air quality, economic conditions, human health and well-being, and social conditions.

General – Assessment Type

Value of federal assessment, particularly in relation to marine areas, marine life and habitats, impacts to Indigenous rights, and effects to human health, and referral to a joint review panel.

General – Project Description

Clarity on the proponent's involvement in any Technical Review Process of Marine Terminal Systems and Transshipment Sites (TERMPOL).

Clarity on whether a disposal at sea permit would be required. If required, effects of disposal at sea.

Clarity on the cooling method to be used for the liquefaction process.

Clarity on marine safety associated with the storage of liquefied natural gas in close proximity to other LNG terminals.

Clarity on the regional, provincial and national benefits of the Project.

Clarity on the location of bunkering of the offloading LNG tanker vessels and tugs.

Clarity on the source of expertise with designing, constructing and operating a floating LNG facility in B.C.

Methodology and the assumptions used to calculate GHG emissions estimates as described in the draft Strategic Assessment of Climate Change, including consideration of upstream effects due to extraction and transportation of natural gas.

Details on the pipeline and transmission corridor, including engineering and design information.

Clarity on condensate removal from project site.

Human Health and Well-Being

Effects of electric and magnetic fields at traditional, ceremonial or recreational use sites situated in the Project area, including along the proposed transmission line corridor.

Effects of air emissions on the health of Kitimat area residents.

Effects on potential human receptor sites, including residences, cabins, and traditional use sites (including temporary or seasonal sites for hunting, fishing, trapping, berry picking, recreation, ceremonial uses). Consideration of distance of key Project components to sensitive human receptor locations (including schools, hospitals, retirement complexes, assisted care homes).

Clarity on approach for consultation with local population regarding the detailed Health Impact Assessment (HIA) incorporating GBA+.

Effects on the community health profile including birth rates, death rates, injuries and chronic disease rates, mental health status and other community-relevant health issues.

Effects to human receptors from changes to air quality, visual conditions, noise, water and country food quality.

Effects on the existing health services and programs due to the influx of workers.

Effects on drinking water sources, both surface and/or groundwater (permanent, seasonal, periodic or temporary).

Effects due to gender-based violence, spread of sexually transmitted infections and human trafficking, due to the influx of workers to the communities.

Effects to human health through dermal contact with contaminated surface water or groundwater.

Effects on Indigenous community health using disaggregated data that is specific to Indigenous peoples.

Indigenous Peoples' Social and Economic Conditions

Effects to the social and economic conditions of Indigenous communities using disaggregated data that is specific to Indigenous peoples.

Effects on the wellbeing and day-to-day lives of Indigenous peoples living in the region and their communities due to social and economic effects of the Project (e.g. increased service and housing pressures in the region).

Effects on Indigenous groups' access to economic benefits and opportunities and identification of mitigation measures to address long-term youth unemployment.

Effects on contractors, companies and social conditions within local Indigenous communities due to changes in cost of living and access to the labour market. 

Indigenous Peoples' Use of Lands and Resources

Effects on the availability of resources, preferred use areas, socio-economic conditions and cultural wellbeing of Indigenous peoples through an increase in resource users (e.g. influx of workers that would fish or hunt).

Effects on the quality and quantity of resources used for traditional purposes, due to increased access to remote/culturally important areas, and restrictions of Indigenous peoples' access to preferred locations for harvesting or recreation, particularly in the marine environment.

Effects on Indigenous peoples' use of the area due to changes in sensory experience (including changes to noise, light, visual conditions) and safety or perceived safety concerns.

Effects on intergenerational knowledge transfer and the health and wellbeing of Indigenous peoples due to changes to the use of lands and resources.

Indigenous Peoples' Rights

Effects to the rights of Indigenous peoples and their traditional land use through the construction and operation of the Project.

Marine Mammals

Effects to marine mammals and their habitat from Project activities, including marine shipping that alter, disrupt or destroy habitat.

Marine Shipping

Effects to the environment and marine safety from marine shipping including support tugs and vessels, with consideration of mitigation measures.

Effects of marine shipping on human health of the general population and Indigenous peoples, fish and other marine species, air quality, GHG emissions, and marine navigation including by Indigenous peoples.

Effects of marine shipping to the rights, title and interests of Indigenous peoples within the territories that overlap with the shipping route, including beyond the Triple Island Pilotage Station.

Comprehensive consultation with each Indigenous group whose territory overlaps the shipping route.

Effects of marine shipping on the harvesting of marine resources by Indigenous peoples along the shipping route including changes to access, noise, the ability to harvest in important locations at preferred times in preferred ways, perceptions of safety, loss of fishing gear, and subsequent community repercussions.

Effects of marine shipping and wake on traditional customs and practices of Indigenous peoples, including harvesting and associated travel, sustenance for communities, feasting and trading, and the transference of traditional knowledge.

Consideration of Indigenous/community-developed valued components in the assessment of marine shipping effects.

Details on the increase in shipping through the region, size and speed of vessels, plans for mitigating underwater noise and impacts to marine mammals, and increased vessel traffic effects on fishing lanes, access to resources, and changes to the social and ceremonial sense of place and self.

Migratory Birds And their Habitat

Effects on migratory birds through clearing activities, collisions with vehicles or infrastructure, flaring events, increased presence of humans, use of heavy equipment and increased sensory disturbance during construction and operations.

Effects on the quality, availability and ecological function of migratory bird and wildlife habitat, including wetlands and provincially listed ecological communities.

Social Conditions

Effects on population composition, density and growth, ethnic identity, family structure, and dependency ratio.

Effects on access, ownership and use of local resources (e.g. land tenure).

Effects on the existing local and regional infrastructure in the Project area, including railways, highways, traffic, pipelines, water mains, sewage lines, power lines and any other potentially affected facility.

Effects on the existing local and regional services in the Project area such as: accommodation, recreation, waste disposal, police, fire fighting, ambulance and health care services, education, and day care.

Effects on navigable waterways and waterbodies including access and users of the waterways.

Species at Risk, Terrestrial Wildlife and their Habitat

Effects to federally listed species at risk, including Northern Resident and Transient Killer Whales, as a result of death, harm, or harassment of an individual, the destruction of the residence of one or more individuals or the destruction of critical habitat of federally listed species that may occur through Project construction and operation.

Effects to federally listed species at risk due to increased human presence, use of heavy equipment, vegetation clearing, and collisions with vehicles and infrastructure.

Mitigation measures designed based on the most recent best management practices, guidelines, and scientific literature, and implemented to be consistent with all applicable recovery strategies and action plans.

Mitigation measures, follow-up and monitoring programs to avoid, reduce or compensate for effects to federally listed species and their habitat (e.g., Marbled Murrelet nesting habitat).

Water – Groundwater and Surface Water

Effects to surface water quality from wastewater, storm water and process water discharge, and accidental releases of solid, liquid or hazardous waste.

Effects to groundwater quantity through the use of surface water and groundwater as a water supply source during construction and operation.

Effects to contaminant loads in streams through the use of nearby water sources.

Effects to water quality through improper management or disposal of materials, including contaminated or hazardous wastes.

Effects of water withdrawal/alteration on local watersheds including watercourse flows.

Wetlands

Effects to wetlands, including wetland water quality through the construction of Project components (e.g., roads, power generation facility)

Visual Environment

Effects of change in visual environment to human receptors and wildlife, including the amount of night-time lighting of the facility.

Vulnerable Population Groups (GBA+)

Effects on vulnerable population groups (GBA+) such as women, disabled persons, elders and youth as a result of impacts from the influx of workers to the communities.

The differential impacts on diverse groups of people resulting from all phases of the Project, including disaggregated data, and mitigation strategies to address these impacts including the incorporation of a GBA+ approach.

Approach to consultation, including that consultation activities consider barriers to participation for local under-represented groups.

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