Trans Mountain Expansion Project

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Attachment From Vaughn McMillan to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 36
  • Submitted: 2016-06-21
  • From Vaughn McMillan to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • From: Vaughn McMillan <email address removed> Sent: June 21, 2016 2:20 AM To: EGESA / UGHGA (EC) Subject: Please disregard all the hype about 'upstream G.H.G. emissions', and proceed at flank speed with the Trans Mountain Pipeline expansion. To Whom It May Concern, Anyone with a brain, and eyes that work, can tell at a glance that all this nonsense about ‘man-made global warming’, and ‘carbon footprint’, and any other enviro wacko terms, are simply contrivances used to strike enough fear in the hearts of silly men, to convince them like Big Al the kiddies’ pal wants them to, to believe at the start of the informative video I’m embedding a link to, that we must do ‘something’, to stop it. Invariably, that means a conspiracy to further enslave this and other Western industrialized countries’ tax payers to an even BIGGER confiscatory tax hike. Well I don’t buy it for a second, and the only reason YOU do, is on accounta because your level of beaurocrapsy wouldn’t even EXIST if it wasn’t prepared to fulfil it’s ‘watermelon manifesto’. Yes, watermelon - green on the outside, and all pinko in the middle! While your recently trumped up office sits around wringing it’s hands, looking for new ways to hobble and handcuff the nation’s energy industry, the inertia it’s causing in that industry may render the country a 3rd world nation status, due to being impossible to reboot from it’s slumber. For example, in spite of all the hoopla Ofloppa’s ‘deal’ with China on their g.h.g emissions is concerned, it’s just that, given that the Chinese don’t even have to start to commence to think about beginning to cut back on their emissions ’til 2036! A twenty year handicap ...

Attachment From Kinder Morgan Canada to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 28
  • Submitted: 2016-06-20
  • From Kinder Morgan Canada to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • Trans Mountain Expansion Project June 20, 2016 Environment and Climate Change Canada 351 St. Joseph Boulevard, 12th floor Gatineau QC K1A 0H3 Fax: 819-420-7410 Email: ec.egesa-ughga.ec@canada.ca Subject: Comments on Environment and Climate Change Canada (ECCC) draft Review of Related Upstream Greenhouse Gas Emissions Estimates for the Trans Mountain Expansion Project We are writing to provide comments on the draft Review of Related Upstream Greenhouse Gas Emissions Estimates for the Trans Mountain Expansion Project, which was published by ECCC on May 19, 2016 (the “ECCC Report”). The Trans Mountain Expansion Project. Trans Mountain is the holder of the National Energy Board (NEB) certificates for the Trans Mountain pipeline system which is operated by Kinder Morgan Canada Inc. The existing Trans Mountain system is an approximately 1,147 km pipeline system between Edmonton, AB and Burnaby, BC which transports a range of crude petroleum and refined products from receipt points in Edmonton, Alberta and Kamloops, British Columbia to multiple locations in British Columbia and Washington State. In response to growing market demand, Trans Mountain has sought approval to expand the existing system. The provision of enhanced access to Pacific Rim markets including California and Asia will provide critical access to alternative markets for Canadian crude oil producers. The proposed Trans Mountain Expansion Project (TMEP) would increase the operating capacity of the Trans Mountain system from approximately 300,000 bbl/d to 890,000 bbl/d through a twinning of the existing pipeline in AB and BC with about 987 km of new pipeline and associated facilities. TMEP ...

Attachment From David Gooderham to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 18
  • Submitted: 2016-06-20
  • From David Gooderham to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • June 20, 2016 Environment and Climate Change Canada 351 St. Joseph Boulevard, 12th floor Gatineau QC K1A 0H3 Fax: 819-420-7410 Email: ec.egesa-ughga.ec@canada.ca RE: DRAFT REVIEW OF RELATED UPSTREAM GREENHOUSE GAS EMISSIONS ESTIMATES FOR THE TRANS MOUNTAIN EXPANSION PROJECT (TMX) Enclosed herewith: Comments on Draft Review of Related Upstream GHG Emissions for the Trans Mountain Expansion Project. Please note that the enclosed document is a revised version of the substantially identical material submitted earlier today. Kindly substitute this submission for the previous filing. Submission from: David Gooderham <contact information removed> 2 Comments on Draft Review of Related Upstream GHG Emissions for the Trans Mountain Expansion Project Table of Contents Analysis .............................................................................................................................. 3 Introduction ..................................................................................................................... 3 The Liberal Government’s assessment procedure (March 2016) ................................... 6 Evidence: the cost of shipping oil by rail and future oil prices ...................................... 8 The Kinder Morgan assessment report ........................................................................... 9 Failure of the assessment to answer the important question ......................................... 13 The challenge: emissions reductions in other economic sectors by 2030 .................... 15 The case of Alberta ...

Attachment From Glenda Steinley to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 22
  • Submitted: 2016-06-19
  • From Glenda Steinley to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • From: Glenda Steinley <email address removed> Sent: June 19, 2016 6:38 PM To: EGESA / UGHGA (EC) Subject: Trans Mountain Expansion Project (TMX) I consider Canada to be a very forward thinking Country. One with many experts and leading specialists in the Oil and Gas Industry whom are capable of ensuring projects will not only meet our imposed legislation as well as all concerns listed in the recommended conditions for this project by the NEB. Such as safety, environmental, etc. but will also surpass the challenges and set forth an example of how Canada can lead the world in developing these projects going forth. The world is and will be dependent on fossil fuels for many years to come and hence, pipelines will be essential to safely transport this commodity. There is no sense in repeating what has already been presented in many reviews, platforms from various groups regarding the safety, emissions, environmental aspects. What is not mentioned but of huge importance is the financial aspect of this and similar projects. The message that we send not only to Canadians but also those involved in the Oil and Gas Industries and related by-products at home and around the globe must be one that has merit and shows common sense leadership. We have resources that need to be marketed not only here in Canada but also globally. We simply cannot turn off the cash flow from this industry and think it will be replaced quickly. The theory that other industries compliant with Canada's green projects will come forth and create the jobs, build the equipment, resources needed to move off fossil fuel is unproven. Canada's climate has to many challenges for these corporations to consider starting ...

Attachment From Environmental Defence to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 21
  • Submitted: 2016-06-17
  • From Environmental Defence to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • June 17, 2016 Environment and Climate Change Canada 12th Floor, 351 Saint-Joseph Boulevard Gatineay, Quebec K1A 0H3 ec.egesa-ughga.ec@canada.ca RE: Review of Related Upstream Greenhouse Gas Emissions Estimates (Trans Mountain Pipeline ULC – Trans Mountain Expansion Project) (reference #80061) To Environment and Climate Change Canada, Thank you for the opportunity to provide comments on the analysis Environment and Climate Change Canada (ECCC) has undertaken on the Kinder Morgan Trans Mountain Expansion (TMX) project’s anticipated upstream greenhouse gas (GHG) emissions.1 The federal government has committed to an interim review process for major natural resource projects currently under review (including TMX) that incorporates an assessment of upstream GHG emissions by ECCC. However, there is no clear indication of how this assessment will figure into the federal government’s final decision to approve or reject projects or how this assessment will align with Canada’s GHG reduction targets and international climate obligations. The methodology as proposed by ECCC does not describe how the assessment of upstream GHG emissions would adhere to a projected market analysis that is consistent with global demand forecasts in line with the international agreement reached in Paris to limit global temperature rise to well below 2 degrees Celsius (°C) and strive for 1.5°C. The proposed methodology also fails to meet a credible, robust climate test that provides decision-makers with the tools necessary to ensure they are able to position the Canadian economy to thrive in a global market that is transitioning to clean energy in a climate-safe future. At the Paris climate summit, countries ...

Attachment From Canadian Association of Petroleum Producers to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 29
  • Submitted: 2016-06-17
  • From Canadian Association of Petroleum Producers to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • 2100, 350 – 7 Avenue S.W. Calgary, Alberta Canada T2P 3N9 Tel 403-267-1100 Fax 403-261-4622 1000, 275 Slater Street Ottawa, Ontario Canada K1P 5H9 Tel 613-288-2126 Fax 613- 236-4280 1004, 235 Water Street St. John’s, Newfoundland and Labrador Canada A1C 1B6 Tel 709-724-4200 Fax 709-724-4225 360B Harbour Road Victoria, British Columbia Canada V9A 3S1 Tel 778-265-3819 Fax 403-261-4622 www.capp.ca � communication@capp.ca June 17, 2016 Mark Cauchi Executive Director Oil, Gas and Alternate Energy Division Environment and Climate Change Canada 351 Saint-Joseph Boulevard Gatineau, Quebec K1A 0H3 (via email to: ec.egesa-ughga.ec@canada.ca) Dear Mr. Cauchi: Re: Trans Mountain Pipeline ULC – Trans Mountain Expansion Project: Review of Related Upstream Greenhouse Gas Emissions Estimates The Canadian Association of Petroleum Producers (CAPP) appreciates the opportunity to review and comment on Environment and Climate Change Canada’s (ECCC) draft of the upstream greenhouse gas (GHG) emissions estimates for the Trans Mountain Expansion (TMX) project. On April 18, 2016, CAPP submitted comments to ECCC’s draft methodology for assessing the upstream GHG emissions from projects undergoing federal assessments, which was published to the Canada Gazette Notice Part 1 on March 19, 2016. We note that the proposed methodology recognizes the evolving and leading nature of climate policies in Canada, which will result in further emissions reductions from domestic upstream oil and gas production. With respect to the conclusions made by ECCC in the assessment, we support the following key points: • That TMX is unlikely to impact global GHG emissions due to it ...

Attachment From Living Oceans Society and Raincoast Conservation Foundation to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 20
  • Submitted: 2016-06-17
  • From Living Oceans Society and Raincoast Conservation Foundation to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • www.ecojustice.ca info@ecojustice.ca 1.800.926.7744 VANCOUVER CALGARY OTTAWA TORONTO Dyna Tuytel 900, 1000 – 5 Avenue SW Calgary, AB T2P 4V1 Telephone: (403) 705-0202 Fax: (403) 452-6574 E-Mail: dtuytel@ecojustice.ca File No: 488 June 9, 2016 Sent via E-mail: ec.egesa-ughga.ec@canada.ca Environment and Climate Change Canada 351 Saint-Joseph Boulevard, 12th floor Gatineau, QC K1A 0H3 Dear Sir or Madam: Re: Comments on Draft Review of Related Upstream Greenhouse Gas Emissions Estimates for the Trans Mountain Expansion Project I write to provide comments on behalf of Living Oceans Society (“Living Oceans”) and Raincoast Conservation Foundation (“Raincoast”) on Environment and Climate Change Canada’s (“ECCC”) draft of the Review of Related Upstream Greenhouse Gas Emissions Estimates for the Trans Mountain Pipeline ULC – Trans Mountain Expansion Project (the “Draft Review”). Living Oceans and Raincoast were intervenors in the National Energy Board (“NEB”) review of the Trans Mountain Expansion Project (the “Project” or “TMX”), where upstream and downstream climate change impacts were excluded from the list of issues the NEB considered. Living Oceans and Raincoast have several concerns about the Draft Review, set out below. They are concerned that the Draft Review fails to actually assess the climate impacts of the Project and its compatibility with national and global climate targets, which would seem to be the purpose of ECCC being tasked with conducting an analysis of the project’s impact on GHG emissions to inform the Governor-in-Council’s decision making on the Project. 1. These reviews should be informed ...

Attachment From Greenpeace Canada to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 23
  • Submitted: 2016-06-17
  • From Greenpeace Canada to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • Reconciling the Paris Climate Commitments with the Kinder Morgan GHG Assessment Prepared by Keith Stewart, Ph.D. Greenpeace Canada SUMMARY At the core of the Environment and Climate Change Canada (ECCC) draft methodology1 for assessing the climate impact of Kinder Morgan’s proposed Transmountain pipeline is a confusion over which of the many possible futures we are using as the baseline for making our decisions. This matters because if we build our decision-making metric around an assumption that climate action will fail, then we will decide to do things that contribute to that failure. If, on the other hand, we base our decisions metrics on a future where we succeed in honouring the commitments made at the Paris climate conference, then we will make decisions that contribute to that success. ECCC’s draft methodology offers up a number of possible ways to calculate the greenhouse gas emissions (GHG) associated with the pipeline. Depending on which assumptions are chosen, the assessment could produce results that there are negligible (close to zero) or significant (17 million tonnes) greenhouse gas (GHG) emissions associated with the pipeline. Unstated in the methodology paper is the fact that the decision over which set of assumptions to use – and hence what number you get - is determined by what is adopted as the underlying ‘base case’ for evaluating the climate impact of the pipeline. The two possible base case scenarios are: 1. Canada (and the rest of the world) lives up to the commitments made at the Paris climate conference. In this scenario, the key questions are whether the additional GHGs associated with this pipeline fit within Canada’s 2030 carbon budget and whether ...

Attachment From Jessie Purcka to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 25
  • Submitted: 2016-06-16
  • From Jessie Purcka to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • From: Jessie Purcka <email address removed> Sent: June 16, 2016 10:22 AM To: EGESA / UGHGA (EC); Ministre / Minister (EC); Jim.Carr@parl.gc.ca; Chrystia.Freeland@parl.gc.ca Subject: Trans Mountain Pipeline ULC – Trans Mountain Expansion (TMX) To the Canadian Environmental Assessment Agency, Catherine McKenna, Jim Carr, and Chrystia Freeland. RE: Trans Mountain Pipeline ULC – Trans Mountain Expansion (TMX) My Name is Jessie Purcka Thank you for opening up discussion to the public regarding the improvements and added capacity of the TMX pipeline. I understand at this juncture you are specifically looking for comment on upstream GHG emissions. As a Canadian living in the province of <<(Your Province)>> I understand your concerns. However living in the western provinces of Canada and close to our resources I know the care that goes into each project. I fully realize that not only is it important to get our resources to market for the sake of our economy (and government revenues) and put Canadians back to work… but you need to give us a future and a hope. The Trans Mountain Pipeline ULC – Trans Mountain Expansion (TMX) as is so well written in the EACCC report - would not enable incremental oil production and would therefore have no impact on upstream GHG emissions in Canada. It’s because we are “pipe constrained” in this country. I would argue that we do not have the capacity to ship crude by rail safely. They certainly can not continue to do so over the Canadian Rockies. To leave crude delivery by rail not only increases GHG emissions in delivering the product - it also creates a risk in scenic Alberta and BC mountain passes and congests the rail system. This Pipeline should be considered ...

Attachment From Ken F. Douglas to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 27
  • Submitted: 2016-06-13
  • From Ken F. Douglas to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • From: <email address removed> Sent: June 13, 2016 12:45 PM To: EGESA / UGHGA (EC) Subject: Trans mountain Pipeline comment I would very much like to add my voice of support to this project. We cannot stand isolated from future growth and prosperity by sticking our heads in the sand of righteous sentiment. While I am an environmentalist , (I live off the grid), I do not believe that we can suddenly turn off the tap and become totally dependent on untried and questionable means of sustaining our future growth and economy. While it is true that we must adapt to change, it will not happen over night and we would be severely challenged to maintain our role in the world as a leader in rational thinking. All safeguards to build and maintain this pipeline would and should be vigorously applied as I know they will be. To leave the energy in the ground at this time would be a disaster to our economy and we would be joining the ranks of the third world. It would be a classic Canadian example of how a few managed to subvert a proud and prosperous country, if this project does not get off the ground in a timely manner. Thank you. Ken F. Douglas <contact information removed>

Attachment From James Klassen to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 24
  • Submitted: 2016-06-11
  • From James Klassen to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • From: James Klassen <email address removed> Sent: June 11, 2016 4:01 AM To: EGESA / UGHGA (EC); Ministre / Minister (EC); Jim Carr; Chrystia Freeland Subject: Trans Mountain Pipeline ULC – Trans Mountain Expansion (TMX) To the Canadian Environmental Assessment Agency, Catherine McKenna, Jim Carr, and Chrystia Freeland. My name is James Klassen. Thank you for opening up discussion to the public regarding the improvements and added capacity of the TMX pipeline. I understand at this juncture you are specifically looking for comment on upstream GHG emissions. As a Canadian in Northern BC I understand your concerns. However living in the western provinces of Canada and close to our resources I know the care that goes into each project. I fully realize that not only is it important to get our resources to market for the sake of our economy (and government revenues) and put Canadians back to work… but you need to give us a future and a hope. The Trans Mountain Pipeline ULC – Trans Mountain Expansion (TMX) as is so well written in the EACCC report - would not enable incremental oil production and would therefore have no impact on upstream GHG emissions in Canada. It’s because we are “pipe constrained” in this country. I would also argue that we do not have the capacity to ship crude by rail safely. They certainly can not continue to do so over the Canadian Rockies. To leave crude delivery by rail not only increases GHG emissions in delivering the product - it also creates a risk in scenic Alberta and BC mountain passes and congests the rail system. This Pipeline should be considered critical Canadian Infrastructure. The same basic route has been effective – but by adding capacity and ...

Attachment From Mathew Peter Morrison to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 30
  • Submitted: 2016-06-11
  • From Mathew Peter Morrison to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • -----Original Message----- From: Pete Morrison <email address removed> Sent: June 11, 2016 7:04 PM To: EGESA / UGHGA (EC) Cc: The Morrisons <email address removed> Subject: Trans-Mountain Pipeline Expansion Project To whom it may concern, I am lifetime resident of British Columbia (born and bred) and I have spent many years working and living in Alberta as well. I am 100% in favour of both the Trans-Mountain Pipeline Expansion project and the Enbridge Gateway Project for many reasons, but I will explain four primary reasons today. They are: 1. The National Interest. The fact is that Canada is an oil producing nation. However we are also leveraged badly by our American neighbors to sell our resource at a heavily discounted price because we currently only have one route of export from Canada and that is through the US. We are literally losing billions of dollars that could be used to advance our nation and its people because if we don't sell to American interests we don't sell more than we consume. European multinationals also reap the benefit indirectly through their American subsidiary companies and refineries in the US. This is a blatant waste of Canadian resource and potential. 2. The Environmental Interest. Resource recovery and exploitation in Canada works to some of the highest environmental standards in the world. The same cannot be said of the Middle East, South America, Africa, and Russia by any stretch of propaganda. Therefore any barrel of oil produced and sold out of Canada can be said to lessening the environmental damage done by the use of petroleum products on a global scale. This is partly how the Scandinavian and European countries balance their own environmental goals ...

Attachment From Michael Lyons to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 31
  • Submitted: 2016-06-10
  • From Michael Lyons to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • From: Michael Lyons <email address removed> Sent: June 10, 2016 8:06 PM To: EGESA / UGHGA (EC) Subject: Trans Mountain Pipeline Dear Committee: I write in full support for this project. As an ordinary, everyday Canadian citizen who works hard to support his family and community and has been involved in various energy projects for the past 12 years I can assure you that these are built with great attention to detail in regards to every facet of construction. My field specifically is in Health and Safety and it is my passion so having been up close to the men and women who build these projects I see how hard they work and how much they care as individuals about what they do. The project’s success means their success along with their families and communities. Being currently involved with an energy project in a small community I have witnessed first hand how American and other influences have suddenly appeared in our community to stimulate opposition to our project and others like it. It is clear they are well funded and extremely disruptive to our communities, regions, provinces and indeed our country. I agree with Premier Wall in that we face a very real threat to our economy if we allow ourselves to be highjacked by them. I ask that you do what’s best for our country by approving this project, with strict controls, and help us take back our place in the world. We should be exporting resources, not importing them. Thank you. Michael Lyons Squamish, B.C.

Attachment From Nooaitch Indian Band to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 16
  • Submitted: 2016-05-19
  • From Nooaitch Indian Band to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • From: David Lawrence Sent: May 19, 2016 6:10 PM To: TMXproject / TMXproject (NRCan/RNCan); EGESA / UGHGA (EC); Gardiner, Timothy (NRCan/RNCan) Cc: Larry Jordan; Chief Marcel Shackelly Subject: RE: Trans Mountain Expansion Project – Recent Developments Ross, I summarized the recommendation report and have the following comments .  After reviewing the summary I very quickly came to the conclusion that “social license” for the NEB to operate in Canada are unlikely to be achieved in our lifetime.  The Board recommendation report and outlined approach to consultation undermines the Crowns’ fiduciary duty to and Nation to Nation relationship with First Nations, especially in light of the SCC Tsilhqot’in decision and GOC endorsement of the UNDRIP and FPIC . Essentially there is not much more to say. Also, in term of the principles of government’s interim approach including draft assessment of GHG methodology and assessment report I have additional comments :  Consultation on the methodology was not in any way adequate ;  The assessment methodology and report are fatally flawed. Essentially, useless calculations regarding upstream increased GHG are linked to Canada’s efforts to tackle climate change and linked to the potential impact of upstream GHG and their contribution to increases in global temperature what is the point of the assessment? Regards, David Lands and Resources Manager Nooaitch Indian Band 2954 Shackelly Road Merritt BC V1K1B8 From: TMXproject / TMXproject (NRCan/RNCan) [mailto:NRCan.tmxproject- tmxproject.RNCan@canada.ca] Sent: Thursday, May 19, 2016 1:57 PM To: TMXproject / TMXproject ...

Attachment From Alberta Climate Change Office to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates

  • Trans Mountain Expansion Project
  • Author: Administration
  • Reference number: 12
  • Submitted: 2006-07-01
  • From Alberta Climate Change Office to Environment and Climate Change Canada re: comments on the Review of Related Upstream Greenhouse Gas (GHG) Emissions Estimates
  • Attachment included
  • Alberta Climate Change Office 11 th Floor, South Petroleum Plaza 9915 – 108 Street Edmonton, Alberta T5K 2G8 Canada www.alberta.ca June 30, 2016 Environment and Climate Change Canada 12th Floor, 351 Saint-Joseph Boulevard Gatineau, Quebec K1A 0H3, ec.egesa-ughga.ec@canada.ca To Whom It May Concern: Subject: Trans Mountain Pipeline ULC – Trans Mountain Expansion Project Review of Related Upstream Greenhouse Gas Emissions Estimates Draft for Public Comments Thank you for your notification of the upstream greenhouse gas emissions estimates for the Trans Mountain Expansion Project that was posted for public comment on May 19, 2016. I am pleased to respond on behalf of the Government of Alberta. Alberta has prepared the attached submission to refine and improve Environment and Climate Change Canada’s analysis and emissions estimates. Alberta’s submission focuses on:  Providing Alberta-based emission factors that use third party verified (audited) emissions and crude production data from Alberta’s 2015 Specified Gas Emitters Regulation,  Accounting for expected emissions intensity reductions from Alberta’s Climate Leadership Plan,  Exemption of upgrading emissions and recommendation to exempt refining emissions, recognizing that these can occur upstream or downstream of the pipeline and inclusion in this analysis may lead to carbon leakage to downstream jurisdictions, and  Quantification of Part A and Part B estimates with Alberta-based emission factors.  Reinforcing the proposed 100 megatonne legislated oil sands emissions limit, with consideration for cogeneration and upgrading, as a statutory backstop to cumulative oil sands emissions growth ...

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