Letter Opposing Woodfibre LNG's Proposed Amendments to Conditions 3.8 and 6.4

I write to express my strong objection to Woodfibre LNG’s proposed amendments to its environmental assessment certificate related to conditions 3.8 and 6.4 and I call on Minister Guilbeault to reject these changes.

I base my opinion on my 30 year career in global environmental management with the United Nations Development Programme (UNDP) and the United Nations Environment Programme (UNEP), and on my personal experience of visiting and now residing in Howe Sound (on Bowen Island), over the past 60 years.

After my own review of the available documentation, I conclude that Woodfibre LNG has not provided evidence to support assertions that the proposed changes to conditions 3.8 and 6.4 will not result in increased adverse effects – in fact, quite the contrary.

Citizens were asked to trust the approval of this project in 2016 based on agreed upon conditions and safeguards. I believe that it is not appropriate or acceptable to change these conditions and safeguards after the fact because this will seriously undermine public confidence in the entire review process -- especially when there are substantial risks that the changes will increase adverse effects.

I have participated in many of the Climate Change and Biodiversity Conferences of the Parties (COPs) since the Rio Earth Summit in 1992 when I began my career at the UN, and I have applauded numerous progressive decisions taken by the government of Canada in these forums.

Most recently I participated in the Biodiversity Convention COP 15 in Montreal in December 2022 where Prime Minister Trudeau and Environment and Climate Change Minister Guilbeault distinguished themselves and the country not only by hosting this historic COP with China, but also by pushing for the most ambitious commitments possible – including halting and reversing nature loss by 2030, while achieving a full recovery for nature by 2050; and conserving 30% of land and waters by 2030.

I also participated in the Climate Change Convention COP 26 in Glasgow where I was gratified to witness Canada as one of the first countries to endorse the Global Methane Pledge. In fact, Canada became the first and only country to commit to reducing oil and gas methane emissions by at least 75 percent from 2012 levels by 2030. This Woodfibre LNG plant is surely inconsistent with this commitment.

It should be noted that in this ‘UN Decade on Ecosystem Restoration’, the Woodfibre LNG project is located in the Átl’?a7tsem / Howe Sound UNESCO Biosphere Region, which is showing impressive success in marine life and ecosystem restoration – a model that is inspiring the whole world. And this model will surely be set back by weakening the conditions and safeguards of the LNG project previously agreed to.

It even seems possible that the proposed revision of Woodfibre’s conditions could jeopardize the legitimacy of this new Biosphere Region by undermining the explicit commitment to conservation, restoration and sustainable development that forms the basis of the UNESCO designation.

My grandparents first came to Bowen Island in 1916 and over many subsequent decades they witnessed the acute degradation of this region’s biodiversity from industrialization. And, over recent decades, I have personally witnessed the steady restoration of marine life from remediation of those industrial sites. How unfortunate it is to risk reversing this success story of ecosystem restoration that we can all see here in Howe Sound.

In this new UNESCO Biosphere Region, above all places, Woodfibre LNG must be held to the highest standards, including following the precautionary principle to minimize impacts to wildlife and ecosystems.

I am particularly concerned that Environment and Climate Change Canada (ECCC) in its letter and attachment dated December 19, 2022 (CIAR: 80060 / ECPT: 13-1201) identified key errors in IAAC's draft analysis of EEC’s own conclusions that the proposed changes to conditions could increase the adverse effects of the project. The draft IAAC report needs to be seriously reconsidered in order to avoid further loss of trust by the public and the scientific community.

With regard to Condition 3.8, just today, as I write this letter, I have seen groups of Steller Sea Lions feeding here in Galbraith Bay, a sight I had rarely seen over the past 60 years.

And after these same 60 years of swimming in this bay, I am well aware how human-caused underwater noise is a significant and critical component of water quality that we need to manage carefully, especially because marine animals rely in so many ways on sound to survive. This is true not only for the seals and sea lions but also the orcas, humpback whales and other resident sea-life that has so dramatically begun to recover in Howe Sound.

I have seen peer-reviewed reports suggesting that a 125 meter exclusion zone is insufficient to protect against adverse and detrimental impacts caused by underwater sound sources.  I also know that the science related to underwater noise impacts is developing rapidly and I see evidence that Woodfibre LNG appears to rely on outdated science to justify changing condition 3.8. Decisions by Minister Guilbeault must reference the most recent research.

Furthermore, as Canada has not yet delivered on its promises from the Oceans Protection Plan, this would be an inappropriate time to be relaxing conditions on underwater noise. In particular, Canada’s Ocean Noise Strategy, which is scheduled to be published in the coming weeks or months, should inform the IAAC’s – and the Minister’s -- decision-making in this case.

For these and many other reasons I do not support the amendment of condition 3.8 and the higher standard protection against underwater noise must be maintained in addition to the mitigation measures.

With regard to Condition 6.4, I believe that Woodfibre LNG must be responsible for all phases of the project, including decommissioning. This is particularly important in view of Canada’s and the international community’s commitments to reach net zero emissions by 2050, which is essential to avoid the worst aspects of cataclysmic climate change. Canada’s bold commitment to the Global Methane Pledge, mentioned above, also argues for the earliest phasing out of any Woodfibre LNG plant. To avoid intensifying climate disasters, Canada and other countries will need to shift strongly away from fossil fuel plants like Woodfibre LNG so we can assume that decommissioning it will need to happen in the next few decades, at the latest.

Woodfibre LNG should not be permitted to amend condition 6.4 so that it is only responsible for water quality and sediment during operation and construction. The company should be required to report and remedy any spills or sediment in that area whether caused directly by the project or not.

As mentioned above, although Woodfibre LNG wants to limit mitigation measures to only those related to human health, I see that Environment and Climate Change Canada (ECCC) has warned that this change "could allow the proponent to use administrative controls to prevent human exposure to contamination instead of preventing contaminants from entering the environment. For example, the proponent could prohibit the consumption of contaminated fish instead of mitigating the source of contamination." . Woodfibre must not be allowed to exceed pollution guidelines that threaten aquatic life.

Let’s remember that Vancouver will be the host of many important international gatherings this year, including the Fifth International Marine Protected Areas Congress (IMPAC5) just next week and the Global Environment Facility (GEF) Assembly this summer, August 2023.

Vancouver, the communities in Howe Sound, British Columbia and Canada should be proud of their local, provincial, national and global leadership in environmental sustainability and weakening the conditions and safeguards already agreed upon for the Woodfibre LNG plant is clearly not consistent with this record of achievement.

I therefore urge Minister Guilbeault to continue his bold leadership exhibited at CBD COP 15 and elsewhere and to reject these proposed changes to conditions 3.8 and 6.4.

Respectfully yours,

Dr. Charles Ian McNeill

1638 Mt. Gardner Road

Bowen Island, BC V0N1G2

Canada

Email: cimcneill@gmail.com (mailto:cimcneill@gmail.com), charles.mcneill@un.org (mailto:charles.mcneill@un.org)

Tel: 646 431-8038, 604 947-0798

30 January 2023