subject: comment and recommendation letter concerning the ... · the following letter is the...
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To:
Ms. Catherine Ponsford Tele.: (604) – 666 - 2431
Panel Manager
And
Ms. Kimberly Irwin E-mail Address:
Project Analyst, Pacific Yukon Region [email protected]
Pacific NorthWest LNG Project
Canadian Environmental Assessment Agency
Suite 410 – 701 West Georgia Street
Vancouver, B.C. V7Y – 1C6
Cc
Canadian Environmental Assessment Agency Tele.: (613) – 957 - 0700
c/o 1 – (866) – 582 - 1884
Ms. Karen Fish (613) – 957 - 0278
Communication Advisor
22nd
Floor, Place Bell E-mail Addresses:
160 Elgin Street [email protected]
Ottawa, Ontario K1A – 0H3 [email protected]
Ladies, Date: 2016.03.10th
(Thursday)
Subject: Comment and Recommendation Letter concerning the
Draft Environmental Assessment Report and Potential Conditions
For the
Pacific NorthWest LNG Project at Port Edward (British Columbia)
Reference Number: 80032
In this submission, with this cover letter you will find two documents. The first
attachment is the “Atlantic Pacific Spaceline Enterprise Incorporated Assessment of the Pacific
NorthWest LNG Project Proposal” PDF file which contains the argument for this submission.
The second attachment is A.P.S.E. Inc. “Plan B Attachments” PDF file containing to three
information folders in support the A.P.S.E. Inc. “Plan B” proposal.
To ensure that these documents get transmitted, they each will be sent separately, and
then they will be combined together and sent together via ‘Dropbox’.
Checking today the CEAA Pacific NorthWest LNG Project web site showed that CEAA has
received 24 95 Comments and Responses ranging from Ms. Alice Kuta, # 96, 2016.02.11th
to
Page 1 of 2.
The Office of the Wat’suwet’en, # 2541, 2016.03.09th
. We hope and trust that the A.PS.E. Inc.
submission will not get lost in ‘electronic’ paper blizzard!
Thank you for your time and attention.
Signed,
Yours truly,
Keith William Steeves
Pres. & CEO
A.P.S.E. Inc.
Tele.: (604) – 783 – 8528
E-mail Address:
E&OE Page 2 of 2.
The Atlantic Pacific Spaceline Enterprise Incorporated
Assessment of the
Pacific NorthWest LNG Project Proposal
Introduction
The following letter is the Atlantic Pacific Spaceline Enterprise Incorporated (A.P.S.E.
Inc.) comment and recommendation concerning the Canadian Environmental Assessment
Agency (CEAA) Draft Environmental Assessment Report, a document that includes the
Agency's conclusions and recommendations regarding the potential environmental effects of the
project, the proposed mitigation measures, the significance of adverse environmental effects, and
the follow-up program for the Pacific NorthWest LNG Project (PNWLNG).
Description of Project
The consortium led by PETRONAS through its subsidiary Pacific NorthWest LNG Ltd. wants to
build and operate a liquefied natural gas (LNG) facility and marine export terminal near Prince
Rupert, within the District of Port Edward, British Columbia. The proposed Pacific NorthWest
LNG facility would be located on Lelu Island, and would convert natural gas to LNG for export
to Pacific Rim markets in Asia.
Scope of the Project
The LNG processing facility would be located on Lelu Island and would use the adjoining Flora
Bank juvenile salmon seabed habitat area as a LNG carrier docking facility as the export
terminal. The ‘physical’ scope of this project is confined to this geographic area and its spatial
boundaries; hence, the ‘Scope of the Assessment’ and the ‘Scope of the Factors’ apply to this
site.
Terms of Reference
The three main documents that have been compiled to discuss PNWLNG project are:
A.) The PNWLNG Environmental Impact Study (E.I.S.)
B.) The CEAA Draft Environmental Assessment Report – February 2016
C.) Potential Conditions, CEAA web site, 2016.02.12
A.P.S.E. Inc. has assessed these documents in terms of this submission.
Page 1 of 10.
Problem and Conflict
A.P.S.E. Inc. would like to make it clear that we do not having anything against either
PETRONAS or its subsidiaries Pacific NorthWest LNG and Progress Energy Canada Ltd.
What we take exception to is the ‘site’ that is proposed for this facility. A.P.S.E. Inc. believes it
can offer a better site under its proposed “Plan B” proposal as described below.
As cited in recent submissions to the (Canadian) National Energy Board (NEB) in regards to
long – term LNG export licenses from the British Columbian west coast, the PNWLNG project
creates a problem for A.P.S.E. Inc. by “getting in the way”. The corporate interest of A.P.S.E.
Inc. require that a specific quantity (i.e., 10 per cent of the volume that PNWLNG wants to ship)
of natural gas be delivery to Nikiski, Alaska in order to carry out the A.P.S.E. Inc. corporate
agenda. It is perceived by A.P.S.E. Inc., the current 20 LNG applications recently approved by
the NEB will ‘prevent’ A.P.S.E. Inc. from carrying out its mission and reaching its goals.
Hence, the conflict!
Therefore, A.P.S.E. Inc. is in opposition to the PNWLNG project proposal which is to be located
at Lelu Island. A.P.S.E. Inc. is putting forth its “Plan B” proposal as a suitable compromise
solution to everyone involved.
Analysis of the CEAA Process
1.) PETRONAS as a Malaysian state – owned energy company is a corporate business
entity. As such, its economic actions are premised on principles and use and application
of Operations Research. Operations Research; i.e., also referred to as ‘O.R.’ (Ref 1) is
defined as
“… applying the ‘Scientific Method’ to the management of organized systems in
business, industry, government and other enterprises. An example where O.R. is
regularly applied is in the fields of energy and the environment. Typically,
applications of O.R. in this and other areas deal with decisions involved in
planning the efficient allocation of scarce resources - such as material, skilled
workers, machines, money and time - to achieve stated goals and objectives under
conditions of uncertainty and over a span of time. Efficient allocation of
resources may entail establishing policies, designing processes, or relocating
assets. O.R. analysts solve such management decision problems with an array of
mathematical methodologies”.
Page 2 of 10.
Within this topic is an important term called the Objective Function. Again, one sterile
terse definition for an Objective Function (Ref. 2) is:
“an equation to be optimized given certain constraints and with variables that
need to be minimized or maximized using nonlinear programming techniques. An
objective function can be the result of an attempt to express a business goal in
mathematical terms for use in decision analysis, operations research or
optimization studies”.
A much more simpler and easier to understand definition of Objective Function (Ref. 3)
reduces to:
“Objective: What is the goal? Function: How to measure performance?”
In the case of PETRONAS, A.P.S.E. Inc. makes the not unreasonable assumption that the
‘Objective Function’ for PETRONAS in terms of its Canadian holding contains these two
goals, namely:
A.) Minimizing cost and maximizing profit; and
B.) How to transfer their natural gas from their subsidiary, Progress Energy
Canada Ltd. in north east British Columbia to their Asian customers in Asia?
2.) The CEAA uses the Scientific Method in its evaluation process for each E.I.S. that gets
presented to it. Using the definition from Wikipedia.org (Ref. 4), ‘Scientific Method’ is
defined as:
“… a body of techniques for investigating phenomena, acquiring new knowledge,
or correcting and integrating previous knowledge. To be termed scientific, a
method of inquiry is commonly based on empirical or measurable evidence
subject to specific principles of reasoning. The Oxford English Dictionary
defines the scientific method as "a method or procedure that has characterized
natural science since the 17th century, consisting in systematic observation,
measurement, and experiment, and the formulation, testing, and modification of
hypothesis."
Page 3 of 10.
The application of the ‘Scientific Method’ is in use by the CEAA which can be seen by
the recorded statement posted under the CEAA Environmental Assessments page found
on its web site (Ref. 5):
“Environmental assessment is a process to predict environmental effects of
proposed initiatives before they are carried out.
An environmental assessment:
identifies potential adverse environmental effects;
proposes measures to mitigate adverse environmental effects;
predicts whether there will be significant adverse environmental effects,
after mitigation measures are implemented; and
includes a follow-up program to verify the accuracy of the environmental
assessment and the effectiveness of the mitigation measures.”
[Italics above have been added]
3.) The PNWLNG (E.I.S.) constitutes the ‘Observations’ that it has made at the Lelu Island
and Flora Bank juvenile salmon seabed habitat project site. Page 4 of 10.
4.) CEAA Draft Environmental Assessment Report with its ‘Value Components’ and
‘Potential Effects’ constitutes the ‘Hypothesis’ that it has postulated through its
assessment of the PNWLNG (E.I.S.) and various other documents and information
sources.
Below are listed the ‘Valued Components’ that were used in the PNWLNG assessment
for the Lelu Island and Flora Bank sites; namely:
1.) Air quality
2.) Greenhouse gas emissions
3.) Vegetation
4.) Migratory birds
5.) Freshwater fish and fish habitat
6.) Marine fish and fish habitat, including species at risk and marine plants
7.) Marine mammals, including species at risk
8.) Terrestrial species at risk
9.) Human health
10.) Current use of lands and resources for traditional purposes by Aboriginal
peoples
11.) Socio-economic conditions
12.) Physical and cultural heritage and historical and archaeological sites and
structures
Challenge
1.) From the 2013 April 8th
Draft Environmental Impact Statement Guidelines under Section
8 was listed the ‘Alternative Means of Carrying out the Project’ heading. Under this
heading PNWLNG was required to satisfy the following conditions that were stated;
namely:
“The EIS will identify and consider the effects of alternative means of carrying
out the project that are technically and economically feasible. The proponent will
complete the following procedural steps for addressing alternative means:
Identify the alternative means to carry out the project.
− Develop criteria to determine the technical and economic feasibility of the
alternative means.
− Identify those alternative means that are technically and economically feasible,
describing each alternative means in sufficient detail.
Identify the effects of each alternative means. Page 5 of 10.
− Identify those elements of each alternative means that could produce effects in
sufficient detail to allow a comparison with the effects of the project.
− The effects referred to above include both environmental effects and potential
adverse impacts on potential or established Aboriginal and Treaty rights and
related interests.
Identify the preferred means.
− Identify the preferred means based on the relative consideration of effects; and
of technical and economic feasibility.
− Determine criteria to examine the effects of each remaining alternative means to
identify the preferred means.
In its alternative means analysis, the proponent will address, as a minimum, the
following project components:
− LNG production process
− electrical power generation
− land based access to Lelu Island
− placement of jetty
− dredging and disposal of excavated sediment”.
[Italics above have been added]
PNWLNG, for their part, did include ‘Table 4’ under Section 4 – Alternative Means of
Carrying out the Project in their “Summary of the Environmental Impact Statement and
Environmental Assessment Certificate Applications” (February 2014) PP. 13 to 17.
PNWLNG claims to have investigated 20 sites, but rejected most of them due to:
A.) Inability of pipelines to reach sites, and
B.) Sites were located close to protected areas.
It is thought by A.P.S.E. Inc. that ‘Table 4’ created a bias in favor of Lelu Island as many
of the categories cited under ‘Table 4’ pertain to only Lelu Island.
2.) To apply the preceding Section 8 in this assessment, Inferential Statistics is used, where
a ‘Hypothesis’ is conjectured using the ‘Scientific Method’ through means of a counter
argument that is put forward to test and prove the validity of the claim of the
‘Hypothesis’. This counter argument is referred to as the ‘Null Hypothesis’ and defined
by the term (H0).
Page 6 of 10.
3.) For this submission, my company, A.P.S.E. Inc., is putting forward its “Plan B” proposal
as the ‘Null Hypothesis’ or (H0). “Plan B” would use the Zone 2 and 3 of the previously
proposed Alaska Highway Gas Pipeline Project (AHGPP) in conjunction with a new
Alaska spur pipeline route segment running from Alcan Border-Tok-Glennallen-Palmer-
Anchorage-Nikiski (Kenai). The AHGPP proposal has been around for approximately 40
years. It received full government approval back in the early 1980s, but for various
reasons it never was constructed. The current project proponent, TransCanada Pipeline
Company, still has the permits and the easement rights for this pipeline route. Please see
the “Plan B Attachments” PDF File which contains three separate sub-folders which
further define and describe this project. The main difference between the AHGPP and
“Plan B” is that the natural gas would be pumped ‘north-to-Alaska’ from the Montney
Basin and the Horn River Basin in northern B.C. to Nikiski, Alaska under “Plan B”
instead of having the natural gas flowing south from Purdue Bay on the Alaskan north
slope to the lower 48 U.S. states via Yukon, northern B.C. and Alberta as proposed under
the AHGPP plan.
Under the “Plan B” proposal; i.e., (H0), the above aforementioned Valued Components
listed in the CEAA ‘Hypothesis’ are in no way impacted by “Plan B”. The conditions
currently found on and around Lelu Island and the Flora Bank ‘main-as-is’ and are not
changed under “Plan B”. GUARANTEED!
Assessment
By comparison of (H0) with (H1), It can be seen that:
1.) “Plan B” is not in the physical ‘Scope’ as previously defined above. In other words, the
PNWLNG project ‘Scope’ does not apply to the “Plan B” proposal.
2.) “Plan B” is not in the ‘Terms of Reference’ as previously defined above. Again similarly
stated, the ‘Terms of Reference’ for the PNWLNG project do not apply to the “Plan B”
proposal.
3.) “Plan B” would avoid upsetting:
A.) Local environmentalists in the Prince Rupert area
B.) Local resident inhabitants in the Prince Rupert area.
C.) The regional or provincial – wide general population of British Columbia.
4.) H1 is not required by “Plan B”, i.e., (H0) because the measures advocated under H1 are
‘site specific’ and do not apply to (H0). Page 7 of 10.
5.) “Plan B” would not only achieve the ‘Objective Function’ as specified above in
PETRONAS’ ‘Operation Research’ methodology, but would do it better!
6.) “Plan B”, i.e., (H0) as defined in Statistics is neither a ‘Type 1 Error’ nor is it a ‘Type 2
Error’. This can be shown and proven, but the assessment would get too mathematical
for the general reader.
Other Advantages
In response to a recent newspaper article (Ref. 6) last week, A.P.S.E. Inc. would like to address
the public comments that were stated in the article. In reply, A.P.S.E. Inc. claims the following:
1.) “Plan B” avoids the problems stated by Mr. Ron Shillum and Ms. Barbara Wesley.
Regarding Greenhouse Gas emissions, “Plan B” hopes to have a significant impact in
reducing this problem. A.P.S.E. Inc. respects native aboriginal rights and land claims.
“Plan B” would not succeed otherwise. Therefore, A.P.S.E. Inc. wants to establish both
trust and confidence with the various native communities involved in order to move
“Plan B” forward. If “Plan B” were to be accepted and approved, it is hoped that the
economics of “Plan B” will make sense in the end. “Plan B” is not on the B.C. coast.
2.) “Plan B” is an example that would advance Colleen Pritchett’s desire for a greener
world. A.P.S.E. Inc. believes that “Plan B” is a means of promoting the long run
elimination of fossil fuels and transitioning towards less harmful and more greener
method of energy production.
3.) “Plan B” would provide ‘associated’ jobs for the region and it would not be left out,
which Mr. Scott Duffus was concerned about. Also, as a side note here, Mr. Duffus is
being too negative. Local fishing and forestry can be revived and made sustainable
through intensive resource utilization, and not through ‘extraction economics’ as
practiced in the past.
4.) There are a number of other advantages involved with the “Plan B” proposal. These
were briefly mentioned in “Letter of Comments” applications to the (Canadian) National
Energy Board (NEB). Foremost in these advantages are the incorporation of NWMO
Option # 5 and the H5R Project. At this point in time, these items will not be discussed.
All that is required here is to show that the A.P.S.E. Inc. (H0) is superior to the
LNWLNG (H0). Discussion of the ‘Scope’ of the “Plan B” proposal will come later.
Page 8 of 10.
Outside Contact
Last week, in an initial attempt to build support for the “Plan B” proposal, A.P.S.E. Inc.
“reached out” to the state government of Alaska. At the present time, due to the short notice
given, lack of time available, and the lack of information available on this ‘new’ “Plan B”
project, the state government could neither endorse nor support without further information and
assessment; however, they remain open to new business should it develop. For this end, it is the
hope of A.P.S.E. Inc. that the Alaskans will eventually invite PETRONAS to use “Plan B” to
ship their natural gas to their Asian markets via transiting their Alaskan territory. Therefore, the
CEAA should take note of this transportation option as a possible viable alternative to
overcoming all environmental problems associated with the PNWLNG project in its decision.
Conclusion
The CEAA cannot ignore the A.P.S.E. Inc. “Plan B” and should not avoid it. The CEAA must
respond and must take in to consideration the A.P.S.E. Inc. “Plan B”. If the CEAA does not do
this in its analysis and evaluation of the Pacific NorthWest LNG Project, then the CEAA will not
be doing its job, and CEAA would be doing a great disservice to both British Columbia and
Canada.
In summary, “Plan B” (or H0) CLEARLY has been shown here as being both a better and
superior project proposal. A.P.S.E. Inc. therefore urges the CEAA to reject the Pacific
NorthWest LNG Project and accept the A.P.S.E. Inc. “Plan B” proposal instead.
References:
1.) Cited from “Scientific Method and Operations Research/What is Operations Research”
web site, Source: Cornell Engineering, School of Operations Research and Information
Engineering.
2.) Cited from “Objective function,” What is objective function definition and meaning,”
Scientific Method and Operations Research web site.
3.) Cited from “What is the meaning of an “objective function”, Mathematics Stack
Exchange web site. Reference Source: http://en.wikipedia.org/wiki/Objective_function.
4.) Cited from “Scientific Method,” Source: Wikipedia, the free encyclopedia.
5.) Cited from “What is environmental assessment?” General [topics], Basics of Environmental
Assessment, Environmental Assessments. (CEAA Site Map) (CEAA web site Modified
2015.03.25) 6.) Gordon Hoekstra, “Public comments back LNG project,” Vancouver Sun newspaper,
2016.03.02nd
, Tuesday, P. C2.
Page 9 of 10.
Signed,
Yours truly,
Keith William Steeves
Pres. & CEO
A.P.S.E. Inc.
Tele.: (604) – 783 – 8528
E-mail Address:
E&OE
Page 10 of 10.