ORA has specific concerns regarding the environmental impacts of a converted pipeline in the event of an inevitable spill over its lifetime. A spill would have the potential to contaminate, and possibly permanently destroy key sources of drinking water that municipalities and First Nation communities rely on. While ORA is concerned about all spills that would occur, we will specifically address the spills of a larger and more environmentally significant volume that will occur over the life of the pipeline. What follows is an examination of the following questions:
- What is the expected frequency and volume of spills, based on historical data?
- Can the proponent’s proposed design credibly detect, contain, and effectively respond to environmentally significant leaks?
- Does the proponent’s application address the technical issues and risks that could arise from a conversion project that has already been in service for up to 40 years and was not designed to carry crude oil in the first place?
- Are the number of rivers, lakes, streams and wetlands adequately accounted for in the EEP documentation?
- Will the current NEB review process instill stakeholder confidence, and result in credible information on which this government can base its final decision?
The disappointing government responses received so far: