January 26, 2010
The Honourable Jim Prentice
Minister of Environment
Government of Canada
By Email Correspondence to: Jim.Prentice@ec.gc.ca
Dear Sir:
Re: Enbridge Northern Gateway Project – Final Agreement on Joint Review Process
This letter is to state the opinions of the Sea to Sands Conservation Alliance with regards
to the terms of the Final Agreement on the Joint Review Panel process for the Enbridge
Northern Gateway crude oil/ condensate twin pipelines.
We are a group of concerned citizens based out of Prince George, British Columbia with
support from across western Canada. Prince George is a community that lies in close
proximity to the proposed Enbridge pipelines route, and is inhabited by people that are
closely tied to the surrounding land. We recently formed the Sea to Sands Conservation
Alliance to express our concern for this mega‐project. Interest in our group has been
considerable and our groups already have well over 600 supporters; opposition to this
pipeline project is increasing daily throughout British Columbia. We count ourselves as
part of a broader network of concerned citizens.
Our reasons for opposing the terms of the final agreement on the Joint Review Panel are
as follows:
1. We seriously question whether a three‐member panel comprised of two National
Energy Board members and one Environment Minister appointed member will be
adequate to evaluate this process. This is because of the magnitude of this project,
its broad‐sweeping implications and the number of communities and stakeholders
that will be affected by it.
2. The mandate of the National Energy Board seems to be too narrow to properly allow
panel members to address the variety of issues at stake. Of particular concern is the
panel’s decision to exclude the environmental impacts of the tar sands expansion in
its environmental assessment. This is very disconcerting because the proposed
Enbridge Northern Gateway pipeline could result in up to 30 percent increase in oil
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sands production. It seems short‐sighted and inappropriate to disregard direct
broader impacts of a project in an assessment.
3. Other pipelines in Canada of a similar magnitude have had more involved and
sophisticated review processes. For example, the Mackenzie gas pipeline joint
review panel terms of reference were drafted in conjunction with First Nations and
were much more comprehensive. The scope of this review included, among other
things, questions about whether the project would contribute to sustainability
within the region.
4. The concerns of the public, submitted during the public consultation process leading
up to finalizing the agreement, have not been adequately addressed in the terms of
this agreement. For instance, many members of the public noted the issue of the
moratorium on oil tanker traffic on this part of the coast. There has been a longstanding
moratorium on oil tanker traffic through the coastal inland waters of
northern British Columbia, initiated in 1972 and confirmed by Natural Resources
Canada in 2003. The terms of the Joint Review Panel do not provide for adequate
dialogue about whether British Columbians want this long‐standing moratorium
against oil tanker traffic lifted.
5. Aboriginal rights are not sufficiently addressed, particularly their right to
consultation confirmed by the Constitution and the common law. Several local First
Nations in our area (Carrier Sekani Tribal Council, Takla First Nation and Nadleh
Whut’en) have already issued media releases in response to the finalization of the
Joint Review Process. These groups state that their Aboriginal rights are being
violated. We fully support the position of First Nations groups from our area
concerning this issue.
6. We are concerned about the potential for lack of administrative fairness on the
panel. We do acknowledge that it is stated in the agreement that the members are
to be “unbiased and free from any conflict of interest in relation to the project”.
However, we remain concerned that in your capacity as Environment Minister, you
are selecting one of the three panel members. Our reason for concern is that you
have been quoted many times as being in support of oil sands production and
increasing markets for same, Mr. Prentice.
Some examples:
• “Prentice defends oilsands following National Geographic article,” retrieved
on January 15, 2010 from
http://www.cbc.ca/canada/story/2009/02/25/oilsands‐articles.html.
• “Speaking Points of Jim Prentice” (as Minister of Industry)
retrieved on January 15, 2010 from
http://www.ic.gc.ca/eic/site/icI.nsf/eng/01970.html.
• “Prentice won’t rule out oilsands emissions breaks”
retrieved on January 15, 2010 from
http://www.cbc.ca/politics/story/2009/12/15/prentice‐oil‐sands.html.
• “Alberta to US: Use the oil sands or lose them,”
retrieved on January 15, 2010, from
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http://network.nationalpost.com/np/blogs/fullcomment/archive/2009/08/3
1/alberta‐to‐u‐s‐use‐the‐oilsands‐or‐lose‐them.aspx.
During your previous portfolio as Minister of Indian Affairs and Northern Development
(May 23, 2006), you are quoted on a federal government website in an address to the
Canadian Energy Pipeline Association in Calgary, Alberta, as follows:
“I understand the enormous potential that oil and gas development will bring to
the country. . . Growing global demand for energy and upward pressure on
prices have made new projects feasible. The Gateway pipeline project is another
priority.”
In this same address, you emphasized a Conservative government “concerted and
coordinated federal response on major pipeline projects [that] will allow [your
government] to focus multi‐departmental resources on critical impediments that
threaten projects.”
Finally, you also spoke of your mandate at the time offering opportunities to “create
powerful synergies to realize the potential of pipeline development.”
The above quotes retrieved January 15, 2010, from http://www.aincinac.
gc.ca/ai/mr/spch/2006/cepaad‐eng.asp.
We question whether through your various statements referenced here and elsewhere,
you have expressed support for this pipeline project proceeding?
Our concerns about this review panel are not alleviated by the inclusion of two National
Energy Board members. The vast majority of energy projects reviewed by the National
Energy Board are approved (see for instance “environmentalists say scope of hearings is
too narrow,” Victoria Times Colonist, December 5, 2009, retrieved from
www.timescolonist.com on December 5, 2009).
While the National Energy Board certainly has a role to play, we are concerned that they
comprise two thirds of the panel, given the broad scope of the issues at stake relating to
this project.
In closing, the terms set in the Final Agreement on the Joint Review Panel process do
not reflect the concerns of the citizens and First Nations that would be directly impacted
by the Enbridge Northern Gateway project. An impartial review is necessary, which
includes an appropriate scope that allows for the relevant issues to be discussed and
addressed. There have been numerous calls from the public for a comprehensive public
inquiry into this project (several of which were articulated during the public input time
frame leading up to the formulation of this finalized agreement). We would like you to
consider those calls and establish a comprehensive review process that would have the
support of the First Nations and citizens of Canada that you represent.
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