Once again a group of health professionals gets the science wrong on diluted bitumen and the Trans Mountain Pipeline Expansion project

By now, my opinion of physicians and health care professionals wandering into the field of environmental policy are well known. As I have written previously:

While I trust MDs on matters relating to my health and wellness, I will stick with subject matter experts on topics that are not related to medicine.

Well another band of well-meaning, but ill-informed, health professionals are at it again. This time with a letter to the Prime Minister where they absolutely mangle the science behind the Trans Mountain Pipeline Expansion (TMX) project. While I could really go after their entire letter, I lack the time or the enthusiasm to do so. Therefore, this blog post will address the egregious errors from their sections on diluted bitumen. For simplicity here is the section of the letter I intend to debunk.

Specific to TMX, diluted bitumen is dangerous and considerably more toxic than crude oil. It behaves unpredictably in aquatic environments, sometimes floating, sometimes sinking. The marine spill scenario in the NEB review was very optimistic. It was set far away from any population center despite the clear hazards of a seven-fold increase in tankers through Vancouver’s busy harbour with three bridges and two dangerous narrows adjacent to downtown with over a million people, a population which includes Indigenous communities whose close connection to the land makes them particularly vulnerable to environmental contamination. We need to know the health impacts of a worst-case spill in the most populated area of the project, e.g. a large tanker spill, close to shore and under poor air quality and high temperature conditions prominent in the past several summers in British Columbia. We must additionally acknowledge that even best-case scenario clean-up of crude oil results in only 5-15% oil recovery, with spilled bitumen likely to have even lower levels of recovery.

Finally, the health impacts assessment did not adequately consider the extremely high risk from benzene, one of the most toxic components of the pipeline product diluted bitumen (dilbit). The increased risk of childhood leukemia was ignored by the review as was consideration of genetic and other special population vulnerabilities. 

Toxicity of Diluted Bitumen

The authors start the section by making a demonstrably false claim about the toxicity of diluted bitumen saying it is “considerably more toxic than crude oil”. They later take special notice of the benzene composition of diluted bitumen and the risk it poses to children and indigenous communities.

As most informed observers know, diluted bitumen, due to its chemical nature, is less toxic to humans than most refined fuels and most other crude oils. To explain, the most toxic components in petroleum hydrocarbon mixtures are their monoaromatic hydrocarbon constituents (like benzene, toluene, ethylbenzene and xylenes or BTEX). One of the features of bitumen is that, like other heavy oils, it has relatively low BTEX concentrations. Geochemically, bitumen is a type of crude oil where virtually all of the most toxic volatiles have been biodegraded in the subsurface. That is why the material is so viscous and why they have to add condensate to make it flow.

Relatively speaking diluted bitumen has some of the lowest BTEX concentrations of all crude oils. As detailed by in the US National Academies of Science (NAS) report on the subject:

The average BTEX in diluted bitumen at 0.89 % vol [reported in % by volume] was similar to the heavy crude oils at 0.84 % vol, whereas light and medium crude oils were 2.56 and 2.80 % vol respectively.

With special regard to benzene, both bitumen and condensate have some benzene (the five year average for benzene concentration in Cold Lake Blend is 0.23% +/- 0.03 %) but West Texas Intermediate crude has twice the benzene while low-benzene gasoline has almost 4 times as much.

What this means is that while diluted bitumen is toxic so are gasoline, aviation fuel, light crudes, medium crudes and West Texas Intermediate crude. All of which are substantially more toxic to humans than diluted bitumen. So when the ill-informed health professionals make the claim that diluted bitumen is “considerably more toxic than crude oil” they are absolutely and categorically wrong. Similarly, when they warn of the risks of benzene in diluted bitumen, they are once again barking up the wrong tree because any replacement for diluted bitumen will have considerably higher benzene concentrations than diluted bitumen and would thus pose a higher risk to human and ecological health.

Marine Risks

The topic of marine risks is also raised by the health professionals. I have written extensively on the topic of the marine risks of the TMX and my research shows that once again the their arguments are not consistent with the current research.

Their tired argument about “seven-fold increase in tankers through Vancouver’s busy harbour with three bridges and two dangerous narrows” completely ignores the added precautions associated with the TMX project. The NEB required a detailed risk analysis of the TMX. The critical document on this topic is the report Termpol 3.15 – General Risk Analysis and intended methods of reducing risk which evaluated the risks of the project. It concluded that “with effective implementation of risk reducing measures most of the incremental risk resulting from the project can be eliminated”.

To put a number on it:

  • Without the project the risk of a credible worst case oil spill is estimated in 1 in every 3093 years….If all the risk reducing measures discussed in this report are implemented the frequency will be one in every 2366 years.
  • This means that after the Project is implemented, provided all current and future proposed risk control measures are implemented, the increased risk of a credible worst case oil spill in the study area from the Trans Mountain tanker traffic will be only 30% higher than the risk of such an occurrence if the Project did not take place.

By increasing the number of tankers by 7 times, but also implementing the changes that were ultimately mandated by the NEB, the risk of a spill is less than one event every 2000 years. So no, the risk does not increase by 7 times, it increases by barely 30%. Moreover, remember that 30% is multiplied by a near-zero number. 30% more of near-zero remains almost-zero. Essentially, the experts have established that the project provides no significant increase in risk over those risks we accept every day.

In exchange for that negligible increase in risk we get economic prosperity and the economic health and goodwill of our neighbouring provinces. The dollars generated by this project are what pay for our health care system, which coincidentally pays all these physicians, nurses and health professionals.

Moreover, as I have noted previously, any cold-eyed analysis of the relative risks shows that the TMX reduces our regional risks of oil spills. Blocking the TMX will increase the likelihood of a disastrous rail spill that could spell the end of a major fishery or result in the deaths of dozens of innocents. It also increases the likelihood of a marine spill from a foreign-flagged tanker.

Spill Recovery

The authors also repeat that worn out quote about diluted bitumen spill recovery “even best-case scenario clean-up of crude oil results in only 5-15% oil recovery“. That factoid is, not surprisingly, based on an out-of-date study.

The federal government has spent millions of dollars researching the behaviour of diluted bitumen in an oil spill and has summarized the results at Transport Canada. The conclusion of the research is that diluted bitumen is somewhat easier to clean than heavy crude and can be much easier to clean than a light oil spill. As for that 5%-15% number the health professionals trot out. The 5% -15% number involves open ocean spills far away from spill response facilities not spills in a well-managed port. In the one example of a marine spill, in the Burrard Inlet, they were able to recover 95% of the spilled material.

Fisheries and Oceans Canada modeled an oil spill in the Salish Sea and concluded that the majority of the oil would stay on the surface rather than dispersing into the water column. That would mean that the floating oil would be recoverable using current spill response technologies. As for the sinking scenario, that scenario only applies in a tiny bit of the Salish Sea, in what is the widest sea lanes in the entire route.


So once again we have well-intentioned health practitioners demonstrating my father’s adage quite effectively: “never trust an MD on any topic that is not related to medicine”. In that short 214 word snippet from their letter we were able to find appeals to sentiment, wild exaggerations and outright errors. It simply amazes me how a bunch of Emergency Room Physicians, Family Doctors and other non-specialists can get so much air play on their ill-founded concerns and that no one else appears to call them on it when they do.



Here is a breakdown of the BTEX in every significant blend of Canadian diluted bitumen

BTEX dilbit

Source: Federal Government Technical Report: Properties, Composition and Marine Spill  Behaviour, Fate and Transport of Two Diluted Bitumen Products from the Canadian Oil Sands – ISBN 978-1-100-23004-7 Cat. No.: En84-96/2013E-PDF


As for crude oils – from Characteristics of spilled oils, fuels, and petroleum products : 1. composition and properties of selected oils.

Benzene – µg/g BTEX – µg/g
Alaska North Slope Crude Oil (2002) 2866 16300
Alberta Sweet Mixed Blend (ASMB, Reference #5) 2261 18170
Arabian Light (2000) 979 10950
Sockeye (2000) 1343 8230
South Louisiana (2001) 1598 12210
West Texas Intermediate (2002) 4026 23370

If you want to look up the value for every major oil out there Environment Canada maintains an oil properties database


Posted in Oil Sands, Pipelines, Trans Mountain, Uncategorized | 5 Comments

Looking at the science on cannabis, kids and addiction

Last week the Canadian government finally legalized and regulated the production, distribution, and use of cannabis. Like many of my peers, this change in the law didn’t have a serious effect on my life. I didn’t ingest cannabis before legalization and I have no strong desire to do so now. It is not that I have any moral qualms about the stuff, I have just always worked in fields where post-incident drug testing is a reality and knowing my analytical chemistry have been aware that casual use can stay in your system far longer than most recognize. I have also had a lifetime of lung problems and being around people smoking anything leaves me searching for my inhaler. That being said, I have read a lot of misinformation by “cannabis experts” and so wanted to write a brief blog post highlighting some research that some of the activists would prefer you not understand. Specifically, that cannabis can indeed be addictive and it is very much something that you want to keep well away from young people. Let’s start with the second point first.

Cannabis and youth.

I can’t count the number of cannabis activists I have seen in the last few weeks proclaiming that cannabis is harmless and there shouldn’t be any serious limitations on its distribution and use. The simple fact is that cannabis is a psychoactive substance. Put another way, if cannabis was not a psychoactive substance there would be no particular reason why so many people would be interested in using it. As described in a science dictionary, cannabis

affects both the cardiovascular and central nervous systems. The major psychoactive component in marijuana is delta-9-tetrahydrocannabinol, or THC. After entering the bloodstream through blood-gas exchanges associated with smoking, THC combines with receptor sites in the human brain to cause drowsiness, increased appetite, giddiness, hallucinations, and other psychoactive effects.

One thing I was taught early in my study of toxicology is that the brains of adults and those of children react differently to the same compounds. That is why so many medicines that are fine for adults are not recommended for children. Cannabis fits into that class. While cannabis can, quite rightly, be recommended to children by doctors to treat specific maladies, it should be carefully avoided for most youth. The science is clear that cannabis use, and particularly heavy cannabis use:

All this makes it clear that cannabis is not the harmless substance for youth that some of its more ardent proponents claim and strongly supports the government’s decision to limit the use of the substance to adults.

Many activists have pointed to a recent Journal of the American Medical Association (JAMA) study on cannabis and cognition: Association of Cannabis With Cognitive Functioning in Adolescents and Young Adults, A Systematic Review and Meta-analysis. Let’s be clear that study did not deal with depression, schizophrenia or other anxiety disorders, but rather to cognitive function which involves things like reasoning, memory and attention. Moreover, the study didn’t actually say that cannabis was harmless. Rather, the JAMA study concluded:

Associations between cannabis use and cognitive functioning in cross-sectional studies of adolescents and young adults are small and may be of questionable clinical importance for most individuals. Furthermore, abstinence of longer than 72 hours diminishes cognitive deficits associated with cannabis use.

What do they say this means in plain English? That continued cannabis use may be associated with small reductions in your child’s cognitive ability but results suggest the cognitive deficits are substantially diminished with abstinence. Read that last line again carefully. They aren’t saying that kids won’t see a reduction of cognitive ability, only that following abstinence the loss won’t have a clinical effect on your kids. Put in a way parents will understand: if your kid uses cannabis regularly they likely won’t have cognitive deficits they just may lose a few IQ points over the long term. Not exactly a ringing endorsement in my mind.

An article in Scientific American put it best:

Repetitive or high doses of psychoactive drugs like cannabis, alcohol and hallucinogens interfere with the normal development of the brain. Not a good thing, and cause for controls on the access youth can have to substances.

Cannabis and addiction

As for addiction, the research is equally clear, cannabis is not as addictive as many other “drugs of abuse” but “it appears to conform to the general patterns of changes described in the Koob and Volkow model of addiction.  In non-science-speak what this means is that it creates a biochemical change in users’ brains…it is addictive. That is why cannabis use disorder is included in the Diagnostic and Statistical Manual of Mental Disorders Fifth Edition (DSM-5). Biochemically, the neurochemical basis of cannabis addiction is described:

The psychoactive compounds contained in cannabis induce their pharmacological effects by the activation of at least two different receptors, CB1 and CB2 cannabinoid receptors. Multiple studies have demonstrated the specific involvement of CB1 cannabinoid receptors in the addictive properties of cannabinoids. Several neurotransmitter systems involved in the addictive effects of other prototypical drugs of abuse, such as the dopaminergic and the opioid system are also involved in cannabis addiction.

What does this mean for users? Well for most casual adult users there is little need for concern. Cannabis is less addictive than alcohol and a lot less addictive than nicotine or many other “drugs of abuse”. As for it being a “gateway drug” that is also not strongly supported. Rather, the research appears to indicate that those who are predisposed to drug addiction often start with pot rather than pot making you predisposed to other drugs. That being said if you are a heavy daily user of cannabis you can develop a neurochemical dependence, which is the clinical definition of addiction. So when the government says that regular users of cannabis can become addicted, they are neither lying nor are they wrong.


To conclude, cannabis is a psychoactive substance that the research appears to indicate can be enjoyed in private by consenting adults with little long-term harm as long as it is enjoyed in moderation. Like many other psychoactive compounds it causes neurological changes in the brains of users and when used regularly can result in addiction. Moreover, those neurological changes while minor and usually temporary in adults, can have long-term consequences in youth and children. Thus, like alcohol, cannabis use by youth should be avoided except when prescribed by a medical practitioner for a recognized medical condition.

Posted in Canadian Politics, Uncategorized | 2 Comments

An Open Letter to Fraser Health about a miserable visit to your ER made worse by a lack of communication, price-gouging, and lousy amenities

This blog post is a bit of a change of pace from my normal fare. On Sunday (Oct 14th) I spent over six hours in the waiting room of Langley Memorial Hospital with my 6-year-old daughter waiting to determine whether she had broken her arm. I tweeted about my experience during the odyssey and Fraser Health asked me to send an email to provide them with details. This blog post is intended to describe the miserable service at the facility and highlight some simple changes that could possibly help improve Langley Memorial ER’s horrible reputation in our community.

Let’s start with a qualifier, all three of my kids were born in Langley Memorial Hospital and the service we got in their maternity ward was first rate. This is a common sentiment in our community. It is the place to go to have a baby. That being said, every family I have talked to on the subject agrees that taking a child to the Langley ER is a virtual guarantee of a bad experience. One I plan on never voluntarily repeating.

The day started well, a fun Sunday birthday party attended by my six-year-old daughter. However, at the end of the party she had a bad fall and complained that her arm hurt a lot. An hour later, her hand was badly swollen, and her wrist and lower arm were very tender to the touch. Moreover, our normally happy girl was complaining of the pain. This is something our rough-and tumble youngest of three never does. It being a Sunday, with no walk-in clinics available with x-ray units, we made a decision that we had better make sure she had not broken her wrist/arm and so I packed her up and we headed to the hospital.

As a resident of Langley, we have three obvious choices for emergency rooms: Abbotsford (which has had a LOT of bad press in the last few months), Langley (our closest hospital) and Surrey (quite a bit longer drive). Before leaving the house my wife phoned Langley Memorial ER to ask if they had any issues or delays. The person on the other end informed my wife that they were not allowed to relay that type of information over the phone. A policy that makes exactly zero sense to me. Lacking any information to make an informed decision we headed down to Langley Memorial ER.

Arriving at the ER, I paid the $9 for two hours of parking, after all how long should it take to get an x-ray on a sunny Sunday?  Walking in the waiting room it didn’t look bad at all. There were a handful of people waiting and lots of available seats. They took my daughter’s information and asked us to sit to wait for the triage nurse. All pretty typical. The problem was, unbeknownst to us, a serious car accident had occurred earlier in the day that had turned the waiting room from a place where patients are seen and treated into a room where people would pile up, sitting for hours suffering in silence.

Shortly after we arrived a second family arrived with a daughter (eight years old) who had fallen the day before. Her parents were afraid of the lines at the hospital so decided to wait overnight to see if she felt better. I’m told this is a pretty common decision my fellow Langley parents make. We ended up being processed together so our stories are linked. The dad was at work so mom was there with her injured eight-year-old and a very bored four-year-old.

An hour after our arrival (clearly a bad sign) the triage nurse finally announced my daughter’s name. My daughter was whimpering (as she had not received any pain medication) and the triage nurse confirmed that she needed to see a doctor. So back to the chairs we went.

Almost two hours after we arrived the nurse called my daughter’s name and brought us back to “waiting area 3” inside the ER itself. There we mistakenly thought we might get some quick help. By this time the ER proper had filled up and my parking was about to expire so I left my daughter with the other child’s mom (they were also called in with us) while I went to re-up my parking. Recognizing that this was not going to be a quick trip after all, I moved my car to the longer-term lot (another $8.50 in parking fees).

Three hours into our wait, with still zero communication or further acknowledgement of our existence, my daughter needed a drink and a snack. Since we had seen no nurses or help of any sort, I went to the vending machine to buy a $2.50 bottle of water. You have to appreciate Fraser Health, charging double what every other machine charges for water in their ER. I suppose when you have a captive market you may as well milk them for all they are worth. Since my daughter was hungry and I hadn’t eaten since early in the day I decided to buy us snacks. Anyone want to guess what happened? Yes, I got my snack and then the machine took my money and my daughter’s snack got caught in the mechanism. While I really wanted to kick the machine into submission, instead I chose to pay for a second treat to get them both to fall. Honestly it is the little things that really infuriate. So three hours in and Fraser Health had soaked me for parking; over-charged us for water; and forced me to double-pay for their over-priced snacks while providing exactly zero help with for my deeply unhappy, whimpering daughter.

Remember how I said we thought we were going to get help when we moved out of the waiting room into the interior waiting area? Well it took another three hours in the back (five hours after our arrival) to finally SEE a doctor. Our daughter wasn’t taken to beds or anything like that, instead she (and the other girl) were both examined in the waiting room in area 3, where to no one’s surprise the doctor decided she needed an x-ray. Something either I or the triage nurse could have told them four+ hours earlier.

So after waiting five hours in chairs they finally sent us to the x-ray department. Needless to say, after all that time you can guess what happened. Yes, the one x-ray technician on duty was on a break. So, our two families (the other family joined us a few minutes after we arrived in the x-ray department) waited for a half-hour (once again without one single person telling us what was happening) for the x-ray that any cogent professional could have made clear was needed four hours earlier. Once the x-ray technician got back she quickly, and efficiently, took the pictures and we were sent back to area 3 where, in our absence, all the seats had been re-filled and we were left to stand to wait some more. Thankfully, a nice gentleman, desperately in need of stitches, gave us his seat as my daughter curled herself into the smallest ball she could, clinging onto the teddy bear she brought to comfort herself, on my lap.

45 minutes later the doctor came back to inform us that the arm wasn’t broken and that we should ice her arm and give her Advil for the pain and we were sent on our way. We had spent over 6 hours in the ER and our total face time was:

  • Less than 2 minutes with a triage nurse
  • Less than 5 minutes (in total) with an ER doctor
  • A couple x-rays

No food, no water, no nurses (except the nurses that rushed by careful to never meet our eyes), no pain killers but almost $20 in parking, plus over-priced water and a couple over-priced snacks. Most frustratingly there was not a spare word more than the absolute minimum needed to pass simple instructions to us.

As for that family that spent six of those hours with us? Their daughter did indeed have a broken arm and she was off for another wait, this time at the cast clinic. By this point the mom had switched with the dad as mom had to go to work. Thankfully, she was able to take their four-year-old with her as he had gone from bored to really angry and very tired. Six hours in an emergency room has that effect on very small children.

I finally got my daughter home just before 9 pm. For six hours I had held her curled up on my lap with no painkillers and no communication from the ER staff. As we left we could see the ER was absolutely full, with every seat filled and patients overflowing out the doorway. One particularly telling sight was a woman holding a hand that looked clearly broken in a wheelchair in the entrance-way.  Likely none had a clue, when they headed to their local Emergency Room, that the Langley ER was backed up and that they would likely spend the better part of their night waiting for treatment.

To be clear, during the minimal time we spent with a doctor, she was very kind, but it is simply ridiculous that a hospital in the modern age can’t supply families with a guesstimate about wait times. Vancouver Coastal Health operates a wait time app that helps their patients make informed choices. Even the blood donor clinic has a little sign that tells you that you will have to wait 45, 60, or 90 minutes to give a donation. But somehow Fraser Health doesn’t think that families should be allowed to make informed choices. Even in cases like ours where the person on the other end of the phone knew full well that that they were handling a major accident that would leave our little girl sitting untreated in pain for hours before being seen; they told us nothing. Had we known we could have re-directed to another, less busy, ER in the area.

The saddest part of our entire story (besides the fact an eight-yer-old girl spent 36 hours with a broken arm because her parents rightly feared the wait at the Langley ER) is the response I got from EVERY family I spoke with today at my kids’ school.

EVERY family that had used the facility had a nightmare story about Langley Memorial ER. All agreed that taking a child to the Langley Memorial ER is a virtual guarantee, a virtual guarantee, of a bad experience.

Think about that. It seems like our entire community agrees that they simply can’t trust their local hospital ER with their kids’ well-being. That is such an incredible indictment of your organization. An organization where patients are treated like mushrooms, with bottomless wallets, who are expected to sit quietly and not complain because the ER is literally plastered with signs warning that they can kick you out for raising a fuss. Frankly, if you want to build a connection with your community don’t play that ridiculous PR video (running on a loop) on the one television in the waiting room. Give us the information we need to make informed decisions about the health and treatment of our kids by posting wait times. Charge a fair price for parking and don’t soak us at the vending machines. Set up a water fountain where families who can’t afford it can get water for their sick kids. These are such simple things you can do. Other facilities and organizations seem able to make a bad experience a better one, why can’t yours?


Cover photo from Wikimedia Commons, the free media repository 

Posted in Uncategorized | 5 Comments

On the Canadian Centre for Policy Alternatives’ bad science about BC LNG emissions

Life is very busy right now so I don’t have a lot of time to blog. As such tonight’s installment is simply a quick-take to address a “Policy Note” from the Canadian Centre for Policy Alternatives (CCPA) about the LNG Canada project. The “Policy Note” is titled: LNG Canada: Short-term politics trumps long-term climate responsibility and makes claims that are inconsistent with the current state of science but keeps popping up on my Twitter feed. I’ve written before about CCPA reports on gasoline prices and on 100% renewables) and in both cases I was not been impressed by the rigour of the analyses. This new analysis doesn’t improve my opinion of them whatsoever.

The analysis starts with inflammatory rhetoric including calling LNG Canada a “carbon bomb” and calling support for the project a “form of climate change denial“. This type of rhetoric is unnecessary; it is harmful; but most importantly it is wrong. It is based on the false assumption, the CCPA keeps peddling, that “natural gas is not a “clean” fuel—it is just as carbon-polluting as coal.” It takes some digging to figure out how the CCPA managed to come to this incorrect conclusion but it appears the basis of the CCPA argument is a “Reality Check” called A Clear Look at BC LNG Energy security, environmental implications and economic potential written by David Hughes.

Ultimately, I could end this blog pretty quickly by pointing out that the CCPA analysis has been overtaken by real researchers. Since the report was prepared, a team of actual experts in this discipline produced a comprehensive peer-reviewed article on the topic Country-Level Life Cycle Assessment of Greenhouse Gas Emissions from Liquefied Natural Gas Trade for Electricity Generation. The article, by Kasumu et al., completely obliterates the CCPA argument and shows that BC LNG can help reduce global carbon emissions. But given the prestige of the CCPA, I think it is necessary to do the next step of explaining how the CCPA came to its incorrect conclusion.

The CCPA argument can be traced back to Part 8 (page 38) of the Reality Check titled Life-cycle greenhouse gas emissions. In this section the author takes the results of a US National Energy Technology Laboratory (NETL) study Life Cycle Greenhouse Gas Perspective on Exporting Liquefied Natural Gas from the United States and adapts it for the Canadian context.

The issues with the CCPA report start right at the beginning of the section. The author apparently isn’t willing to invest the time to research Canadian data (like Kasumu et al. do). Instead he simply takes the numbers prepared by the NETL, for export from New Orleans (???) to Shanghai, and uses them, holus bolus, for a Canadian project from Prince Rupert to Shanghai. The only adaptation he makes is to adjust for tanker shipping distance. As presented in the supplementary information for Kasumu et al., the CCPA report overstates the emissions for LNG regasification, for power plant operations and for transportation. But even using all these overstated values the CCPA assessment comes up with the conclusion (in Table 11) that BC LNG has substantially lower emissions than Chinese coal. An inconvenient conclusion for a CCPA report, which explains why the author doesn’t stop there.

Failing to prove that LNG is worse than coal using slightly souped up data, the author makes a couple of truly interesting assumptions to create Table 12. Table 12 is the one the CCPA apparently uses as the basis for their argument that LNG is no better than coal. Since the Table 11 LNG emission numbers were so much lower than the coal, the author first addresses the coal numbers. Coal represents the lion’s share of primary electricity consumption in China (graphic from Dr. Wenran Jiang’s incredible presentation at @Resource_Works – link https://www.resourceworks.com/sharing-science.


and they burn a LOT of coal


In the last several years China has been building some ultra-modern, high-efficiency coal plants which produce substantially lower emissions than the vast majority of their facilities. In Table 12, the author compares LNG solely to these new plants. The unstated assumption is that the Chinese will eliminate those ultra-modern plants to replace them with LNG. Or put another way, the unstated assumption is that China will close its newest and most efficient plants while retaining the hundreds of old, low-efficiency plants they have in their system. By doing so he is able to cut the differential between Chinese coal and BC LNG down by 300 Kg CO2/MWh.

You would think that this ridiculous change would be enough to make BC LNG less clean than coal, but you would be wrong. Even comparing BC LNG (with his inflated New Orleans production values) versus best-in-class coal, the BC LNG is still 20% lower in CO2/MWh. What is a CCPA author to do? How about figure out some way to inflate the Canadian numbers even more.

The author’s second “adjustment” involves adding a fudge-factor for fugitive emissions. Understand that the original number in Table 11 included the standard NETL correction for fugitive emissions. For Table 12 the author decided to go to the classic anti-LNG activist playbook and pulls out a report by Robert Howarth of Cornell University.

Robert Howarth is legendary in the anti-LNG camp for his 2011 paper with Santoro and Ingraffea titled: Methane and the greenhouse-gas footprint of natural gas from shale formations where they estimated fugitive emissions from natural gas production. As for the rest of the scientific community, they were much less impressed. His colleagues at Cornell published a scathing rebuttal of the Howarth paper then a follow-up. The Cornell group was not alone. Other commentators pointed out that paper incorrectly attributed to venting, gas that was actually burnt to run production equipment. While others had additional concerns. Here is a link to a well-written summary of the issues with the paper and the various information sources debunking most of its findings. Needless to say the only people who still believe the Howarth, Santoro and Ingraffea work are activists who are uninterested in the science.

Howarth subsequently prepared another paper: A bridge to nowhere: methane emissions and the greenhouse gas footprint of natural gas. It acts as a sequel to his earlier work and like every horror sequel the original beast, once thought slain, is revived to attack again. The new Howarth study asserts that unconventional wells have a leakage rate of 3.3%. This is more than double the value used by NETL in their analysis. By adjusting the NETL values with a boost based on 3.3% leakage rate the CCPA author is able to raise the LNG number over the Chinese ultra-clean coal number.

Needless to say, the scientific community has very little time for Howarth’s assumptions especially in the context of the BC natural gas industry. Howarth assumes that all unconventional well are vented and flared during installation and development. This would be a human health disaster in North-Eastern BC where venting those concentrations of sour gas would kill off drill crews. Rather, modern wells are generally “green-completed”, (they are connected to a pipeline in the pre-initial phase) and routine flaring and venting goes against BC Oil and Gas Commission Guidelines. While statistics for Canadian venting are not easily available, in the US only 3% of studied wells vented methane into the atmosphere. Just a reminder Howarth assumes 100% are vented. A study by the US Department of Energy showed very low methane leakage (roughly 0.4% of production) while other studies found unconventional wells with numbers up to 1.65% with the general numbers being closer to 1.4%. Coincidentally, the number used by NETL in their studies. Thus, the CCPA “correction” is both unnecessary and not supported by the science.

Now a topic I won’t discuss in detail in this blog post is the additional consideration that LNG Canada intends to electrify some of the critical steps in their LNG production/supply chain. By electrifying some processing, pipeline transport and liquifaction steps LNG Canada will have the lowest GHG LNG on the planet. Had the CCPA author included the electrification of these steps even with all his other fudge-factors he couldn’t make the Chinese coal more efficient than BC LNG.

So let’s summarize. In order for the CCPA to create conditions where “natural gas is not a “clean” fuel—it is just as carbon-polluting as coal” they had to use numbers from the US that overstate basic operational conditions; they had to ignore the electrification of critical steps in the LNG production pathway; they had to use thoroughly discredited fugitive emission values; and then they had to make the assumption that the Chinese would only use BC LNG to replace their most modern state-of-the-art coal facilities, presumably while leaving decade-old inefficient facilities in operation. I ask is that the sand on which anyone wants to build an intellectual construct? For most policy types that would be a no, but when your goal is to fight LNG, come hell or high water, I suppose the answer is yes.

Posted in Canadian Politics, Uncategorized | 11 Comments

More on the Southern Resident Killer Whales – this time on truthiness about acoustic threats and survivorship bias

Well it has been a busy week on the Trans Mountain Expansion (TMX) Project file with the NEB initiating their review of tanker traffic. In all the news surrounding the plan to update the marine assessment one topic that caught my eye  was a series of news reports about the Southern Resident Killer Whales (SRKWs) featuring some really scary “facts” about acoustic threats to the SRKWs. I have written previously about the risks posed by the TMX to the SRKWs but only gave a minor consideration to the noise generated by the project. Upon hearing the news stories I feared that I had missed something. Essentially every media report had the same paragraph, which said:

Misty MacDuffee, a biologist with Rainforest Conservation Foundation on Vancouver Island, said additional noise from just six extra oil tankers each week would raise the possibility of extinction for the Southern resident killer whales to between 15 and 24 per cent. Right now, that risk is less than 10 per cent, she said.

Needless to say I found this level of precision to be very surprising and went looking to find where these numbers came from. The rest of this blog post will go into detail on what I found and will show how activists are selling a bill of goods to suit their faulty narrative. In the process I hope to explain, using the concept of “survivorship bias”, another reason why the TMX may be a positive for the SRKWs.

Let’s start with the basics, where did those numbers (the 15-25% chance of extinction) come from? It appears they came from an Raincoast Conservation Society Report titled: Report on Population Viability Analysis model investigations of threats to the Southern Resident Killer Whale population from Trans Mountain Expansion ProjectSpecifically Table 2 (page 34 of the .pdf file) from that report.

The two values represent the likelihood that the population numbers for the SRKWs will drop below 30 individuals (called “quasi-extinction” in the report) under the “Noise92.5” and “Noise100” scenarios. Not to be a pedant, but the report provides a likelihood of true extinction of the population as 0.3% and 1%, respectively under the two scenarios. That is a lot less than 15% and 24% cited in the media reports. It is funny how Ms. MacDuffee chose to use the term “extinction” even when the report clearly doesn’t use that term for these values.

So let’s look at the Noise92.5 and Noise100 scenarios. They are defined on page 33 as:

  • Noise92.5 = Feeding time reduced because of boat presence 92.5% of the time
  • Noise100 = Feeding time reduced because of boat presence 100% of the time

I hear you asking: what do they mean by feeding time reduced? Well in the report the authors identify a baseline scenario. In it they argue that due to the existing conditions in the Sea, the SRKW spend up to 85% of their foraging time in situations where noise from nearby boats interferes with their ability to hunt/communicate. Now here is the interesting part, the authors then decided to look at what it would be like if the noise was increased so that the SRKW encountered this level of noise for both 92.5% and 100% of the time. This is where the science simply disappears.

You see the authors don’t conduct any quantitative analyses to create these two numbers. The 100% is used as a worst-case scenario and the 92.% is used because it is half-way between 85% and 100%. So when Ms. MacDuffee uses that 92.5% value as the lower possible outcome in her media interviews she does so with zero basis in real-world conditions. As for the 100% value, that is even better. In the paper the authors make this statement:

With increased shipping traffic associated with the Project, Southern Residents could be around boats up to 100% of the time – according to the proponent tankers would be a “near continuous” presence. Thus, feeding could potentially be reduced by up to 19.5%.

That’s right they argue that six additional tankers a week (in a Strait that sees approximately 23,000 ship movements a year) will change the SRKWs’ exposure to noise from 85% to 100%. Yes you read that right, that is the entire basis of their argument. They don’t count the number of ships or look at population ranges, they just throw out that number and voila…a new “fact” has been created.

I asked the Raincoast Conservation Society about the source of their numbers and they referred me to a Nature Scientific Reports article (Evaluating anthropogenic threats to endangered killer whales to inform effective recovery plans) which is simply a  summary of their research output which was peer reviewed. The Nature Scientific Reports article, however, doesn’t even pretend to explain how they came across the 92.5% and 100% numbers, it just applies them. I’m guessing the peer reviewers didn’t buy the arguments they made in their initial paper so they just excluded the origin of the numbers for their article.

In a Twitter thread I pointed out that 100% is impossible since it involves tankers chasing whales throughout their range. The Raincoast Conservation Society responded that technically the tankers didn’t have to follow the SRKWs all the time, just in the designated critical habitat as defined by NOAA and the government of Canada as their summer foraging grounds. So when they say 100% of the time what they really mean is 100% of the time, during a narrow stretch in the summer. Except that is an entirely different story and not what was input into the model used in the report.

Why is my argument important? The first thing to notice is the overall habitat for the SRKW extends from California to Haida Gwaii. This information is available in the NOAA presentation: Distribution and Diet of Southern Resident Killer Whales.

SRKW habitat

Now remember the article only used summer foraging grounds. You may wonder why Raincoast was so adamant we only look at summer feeding grounds? It would be because of this:

Winter J

and this:

Winter K

You see the winter feeding grounds for J-pod are mostly in the northern Strait of Georgia while K- and L-pods travel along the Oregon and California coasts in winter. That means for essentially half of the year the SRKWs aren’t anywhere near where the TMX tankers routes. That really blows a hole in the whole 100% of the time narrative.

However, in the summer it is a different story.


In the summer they do indeed choose to forage near the tanker route, but this brings us to the second topic of our post: “survivorship bias”. Survivorship bias is:

a cognitive bias that occurs when someone tries to make a decision based on past successes, while ignoring past failures

The most famous example is from World War II (image source)


As described in Wikipedia:

During World War II, the statistician Abraham Wald took survivorship bias into his calculations when considering how to minimize bomber losses to enemy fire. Researchers from the Center for Naval Analyses had conducted a study of the damage done to aircraft that had returned from missions, and had recommended that armor be added to the areas that showed the most damage. Wald noted that the study only considered the aircraft that had survived their missions—the bombers that had been shot down were not present for the damage assessment. The holes in the returning aircraft, then, represented areas where a bomber could take damage and still return home safely. Wald proposed that the Navy reinforce areas where the returning aircraft were unscathed, since those were the areas that, if hit, would cause the plane to be lost.

So why is survivorship bias important on this topic? Let’s look again at that map of the SRKW summer foraging and notice where we do not see foraging. Notice how the south half of the Strait of Juan de Fuca all the way to the Puget Sound (the most active shipping route), is empty of sightings while the north half has lots of sighting. That should tell us something. Now look at Rosario Strait (labelled below for those who don’t know the regional geography).


Notice how there are no sightings in Rosario Strait while there are lots of sightings around San Juan Island. That should be raising a whole lot of red flags. If it doesn’t then this heat map makes it really obvious.

heat map

The SRKWs are apparently avoiding Rosario Strait and Anacortes as well as the US marine shipping routes. This is a pretty significant thing to recognize because fishers will tell you that salmon can be found in those waters. It should be prime habitat for the SRKWs but there were very few sightings in that area. What could be causing this effect?


Oh right, those red markings on the drawing are tankers supplying the US refineries with their crude. Now look again at that heat map. Notice that the whales are not avoiding the main shipping route along Haro Strait. That is because the wide main  channel and deep water attenuates the sound and so the whales are willing to use those waters for foraging. The whales are, however, avoiding the rich fishing grounds of the San Juan Islands, this is a very important thing to recognize if you are trying to help the endangered community recover.

I know that was a lot of pictures but it is pretty important to see. Taking survivorship bias into consideration we can recognize that the real challenge for the SRKWs appears to be US-bound oil tankers. These tankers, running along the south of the Strait of Juan de Fuca, through Rosario Strait and in the Anacortes, have essentially taken that entire section of the Salish Sea out of the foraging habitat for the SRKWs. That is a huge area of incredibly rich fishing grounds that the SRKWs are not using. Any project that reduced the number of large, loud tankers running in Rosario Strait and the Anacortes would be a potential bonanza for the SRKWs by re-opening that habitat for use.

Now I have to ask, can anyone remember what project is intended to supply the Anacortes and Puget Sound refineries with oil via a pipeline, thus reducing the number of tankers that have to make the Rosario Strait run? You are right, that would be the TMX.

Reading back over this blog post I can’t help but get angry. We have activists dominating the media narrative making claims that are completely unsupported by the science. That 15% increase in likelihood of extinction (but not really extinction) is based on a number completely unrelated to the number of ships moving in the area (the Noise92.5 scenario). The 25% increase in likelihood of extinction (but not really extinction)  is based on an assumption that that the six additional tankers a week will result in a massive increase in ship noise over the entire year, over the entire range of the SRKWs habitat when the area already is a busy shipping route and the SRKWs only use that area for foraging for the summer months and are still willing to use that area even with all the ship traffic.

It is unconscionable that activists can make these claims and have the media credulously repeating them in print. The numbers are essentially a fiction. The supporting references show that the numbers have no basis in quantitative science and to believe that the 15% and 25% numbers are anything other than a useful modelling exercise means completely ignoring the underlying science.

This is simply another case of activists making false narratives about a complex topic safe in the knowledge that few real scientists will recognize their falsehoods and even fewer will call them out on it. This is the advantage the activists have in this debate. They are not limited by things like the truth or provable facts. They can rely on truthiness and information that feels right and still be featured in the morning paper. Meanwhile a project that has the potential to re-open huge swathes of habitat for an endangered species gets short shrift because it simply doesn’t sound right…even though it is.


Posted in Climate Change, Oil Sands, Pipelines, Uncategorized | 5 Comments

On the environmental and social consequences if the Trans Mountain pipeline expansion project fails

I have spent a lot of time in the last few years researching the Trans Mountain Pipeline expansion (TMX) project. Throughout I have always felt confident that good environmental and fiscal sense would prevail, and the pipeline would be built. Given the Federal Court decision I can’t help but start to doubt that confidence. The obvious question to ask is: what happens if the pipeline is not completed? In this blog I ask and answer 15 questions about a world where the TMX fails. The answers do not reassure me and I wonder if the many of the activists who have been fighting the TMX are ready for a world without the expanded Trans Mountain pipeline? To make it easier in the following list “it” means “the failure of the TMX project”. So what did I realize:

  1. Will it reduce the number of tankers in the Salish Sea: No
  2. Will it reduce the likelihood of a spill in the Salish Sea: No
  3. Will it reduce our ability to respond to spills in the Salish Sea: Yes
  4. Will it reduce the threat to the Southern Resident Killer Whales: No
  5. Will it increase the amount of oil moved by rail: Absolutely
  6. Will it increase the likelihood of a rail spill: Absolutely
  7. Will it increase the cost to transport Alberta oil: Yes
  8. Will it decrease oil sands developments: Yes, likely
  9. Will that decrease in oil sands development results in a decrease in global GHG emissions: Absolutely not
  10. Will it make it harder to fight climate change in Canada: Absolutely
  11. Will it decrease Canadian prosperity: Yes
  12. Will British Columbians remain hostage to high oil prices with zero control over supplies: Yes 
  13. Will it reduce the risk to First Nations communities: Absolutely not
  14. Will it reduce the prosperity of First Native communities: Absolutely
  15. Who wins and who loses if the TMX doesn’t go through?

    Losers: Canadians, the environment, salmon, the southern resident killer   whales and Canada’s fight against climate change                                           -Winners: Activist NGOs, American refinery owners, and foreign dictatorships

The rest of this post are short explanations for my conclusions. The rest of this post is a bit long although the answer to each question has been kept as short as possible. It is a testament to just how bad the outcome is that I couldn’t keep this section short. So many negative consequences will flow from the failure of the TMX.

1) Will it reduce the number of tankers in the Salish Sea: No

As described in my previous post the refineries in the Puget Sound will still need over 645,000 barrels/day (b/d) of crude oil. Currently Cherry Point refinery alone sees 500+ tankers a year and Toresco (a committed shipped on the TMX) has said they want to add 120 tankers a year to their Andeavor facility to make up for an absence of supply. Meanwhile Westridge will still be sending out a few tankers a month. So in the end we will still see 700+ tankers a year coming in and out of the Salish Sea with 620+ of them running the narrower and much more dangerous Rosario Strait.

2) Will it reduce the likelihood of a spill in the Salish Sea: No

I have written in detail about the relative risks associated with the project to the Salish Sea. Any cold-eyed analysis of the relative risks shows that the TMX reduces our regional risks of oil spills. Blocking the TMX will increase the likelihood of a disastrous rail spill that could spell the end of a major fishery or result in the deaths of dozens of innocents. It will put more tankers going through narrower waters with less support from escort tugs. That is a formula for increased risk.

3) Will it reduce our ability to respond to spills in the Salish Sea: Yes

The BC west coast has been chronically under-served for spill response. One of the big gets for BC in the TMX project was a toll on the new fuel transportation to pay for improved spill response. However, if there is no expansion that toll will not be paid and that money disappears. The result is a loss of spill response capability. Right now we are looking at losing $150 million and several spill response bases. Since the funds for the spill response was coming from the private sector there is no obvious way to replace those funds. When a spill occurs the equipment will not be there to address it. So damage will be greater.

4) Will it reduce the threat to the Southern Resident Killer Whales: No

I wrote about this in my last post. If you look at the entire Salish Sea, and not simply the Canadian side of the border, then you realize that the loss of the TMX will likely increase the risks to the southern resident killer whales, not decrease those risks. Foreign-flagged ships with lower safety standards will be coming in to the same waters, running through narrower straits while not following the slower speeds recommended by DFO to reduce ship noise. It will be more dangerous and louder for the southern resident killer whales. Meanwhile, more rail along the rivers puts salmon habitat at risk. Without salmon there will be no southern resident killer whales.

5) Will it increase the amount of oil moved by rail: Absolutely

As reported by Global News: the Paris-based IEA forecasts in its latest oil markets report that Canadian crude-by-rail exports will grow from 150,000 b/d a day in late 2017 to 250,000 b/d this year and then to 390,000 b/d in 2019. In June we crossed 200,000 b/d and current predictions are that we will see 300,000 b/d by December.

On the American side of the border just three (Tacoma, Anacortes, or Ferndale) of the region’s six refineries moved over 156,800 barrels of oil per day by rail in 2017 and every indicator is that the volume will be increasing absent TMX. These trains are carrying explosive Bakken crude through some of the most densely populated parts of the Pacific Northwest and along the sides of some of our most important salmon rivers.

6) Will it increase the likelihood of a rail spill: Absolutely

We all know that risk of incident is 4.5 times higher for transportation via rail over pipeline and more of the rail route is along the river sides than is the pipeline. Many activists complain about the sourcing of the 4.5 times stat so let’s go to Citylab and the Sightline Institute, both of  which warn about the increase in risk of oil spills associated with this increase in oil volumes. There will be more oil-by-rail spills and because our rail lines run along river sides we will have far more risk to salmon habitat.

7) Will it increase the cost to transport Alberta oil: Yes

Oil-by-rail increases the cost to transport oil, which means to sell the oil to their customers producers will have to discount the price of that oil. This decreases the royalties earned by the Alberta government and the money available for transfer payments to fund our social services.

8) Will it decrease oil sands developments: Yes, likely

This is the reason the activists have been fighting the TMX. By increasing the cost and decreasing the price the result is a slow-down of future development. Just ask Suncor. The problem with this is that it will not have any effect on global oil use (see next question).

9) Will that decrease in oil sands development results in a decrease in global GHG emissions: Absolutely not

We live in an integrated world economy with a glut of oil supply. Any decrease in Canadian production will be offset by an increase in supply from any of the 30+ nations that produce crude oil. As a fungible commodity our loss is someone else’s gain and absent some change in demand the result will be a trade-off with no change in global emissions but more money for foreign dictators. This is the part of the story the activists never want to admit.

10) Will it make it harder to fight climate change in Canada: Absolutely

Alberta made the completion of the pipeline a condition for their joining the national climate action plan. Alberta’s Climate Leadership Plan, which included an aggressive move off of coal for electricity, is also in doubt. So besides not affecting global emissions and reducing the money Alberta generates from its natural resources the loss of the pipeline will set back our national plan to cut our carbon emissions and will likely drive the Notley government out of power. Her more-climate friendly government will be replaced by a Jason Kenney government. Mr. Kenney has made it abundantly clear that he will fight the national climate plan using every tool at his disposal. Without Alberta and Saskatchewan as active partners Canada has no chance of meeting our Paris Agreement NDCs and we will likely lose the governments most committed to fighting climate change. Good work activists.

11) Will it decrease Canadian prosperity: Yes

The money generated by natural resources is pumped back into our economy and paid to our government as royalties and increased taxes. That is the money that pays for our social service net, medicare and other government services. The loss of revenue will hurt Canadian prosperity and reduce the money available to pay for the transition off fossil fuels.

12) Will British Columbians remain hostage to high oil prices with zero control over supplies: Yes 

Coastal British Columbia faces a 30,000 b/d shorfall in refined fuels which explains why we pay the highest gasoline prices in the country. So now instead of paying 2-3 cents litre more in increased tolls (tolls that would help pay for improved spill response) we will be paying a scarcity premium to US suppliers. The same 12-15 cents/litre scarcity premium  we have been paying for the last several years. We pay this premium because the current Trans Mountain is oversubscribed and we need to outbid Oregon and Californian buyers for the unallocated supply out of the Puget Sound. This will continue and instead of our gasoline purchases helping to pay for Canada’s social services net they will go to American refinery owners.

13) Will it reduce the risk to First Nations communities: Absolutely not

This is the part of the story that confuses me the most. Somehow the anti-pipeline activists have managed to convince some of the First Nations on the Fraser River that the pipeline is a greater risk to their communities than oil-by-rail. This means these First Nations have been fighting a project that has the potential to significantly decrease the risks to their communities and their food sources. These activists have literally convinced the First Nations to fight against their own best interests.

14) Will it reduce the prosperity of First Native communities: Absolutely

Every First Nation in BC relies on fossil fuels for transportation, to move foodstuffs, and to supply most of the necessities of life. Every First Nation in BC will paying more than they should for those fossil fuels if the TMX is not built. As well, the various mutual benefit agreements made between the project and the First Nations will not happen. These First Nations will be exposed to higher risks due to oil-by-rail and will lose money at the same time. That doesn’t even consider all the First Nations-owned companies slated to help build and maintain the pipeline that will not do that work. Hundreds of millions of dollars a year will be lost in communities with few other sources of income. It is simply amazing how activists using words like “sovereignty” and “pride” have convinced many First Nations to impoverish themselves.

15) So who wins and who loses if the TMX doesn’t go through?

Losers: Canadians, the environment, salmon, the Southern Resident Killer Whales, and Canada’s fight against climate change

Winners: Activist NGOs, American refinery owners, and foreign dictatorships

As an environmental scientist, when I hear activists claiming that they are fighting the pipeline to “protect the inlet” or to “protect our waters” I can say quite convincingly  that these arguments simply don’t hold water. The underlying challenge on the Trans Mountain file has been that it represents a compromise to provide the safest of the various alternative means to transport the liquid fuels we need to the Pacific Northwest.

If the TMX is blocked the crude oil necessary for our continued existence on the West Coast will still need to flow. It will simply flow via less safe means, specifically:

  • Explosive Bakken crude will flow in even greater quantities along rail lines that run the virtual length of the Columbia River and through the heavily populated communities of the Pacific Northwest.
  • Canadian oil trains will run in greater numbers alongside the Thompson and the Fraser Rivers and through every community along that route. A spill in either river will risk salmon runs that serve as the food source for, and are held sacred by, dozens of First Nations communities in British Columbia.
  • Instead of highly-regulated Canadian tankers bringing Canadian crude to California and Asia we will see the Puget Sound and Semiahmoo Bay full of tankers coming out of the Middle East and registered in whatever jurisdiction has the lowest safety standards.
  • The eventual risk to the Salish Sea won’t be the one major accident every 2000+ years described in the TMX risk assessments, it will be orders of magnitude higher.

So what are we looking at if the activists manage to stop the TMX? Certainly not a decrease in ecological risk. Rather we will see an increase in risk to our rivers and the marine environment…and at what cost? Any rent-seeker who thinks that blocking the pipeline will somehow help us fight climate change is barking up the wrong tree, because the countries that will serve as the replacement for Canadian oil (the Saudis, Nigerians and Algerians) are not paying into our federation; they are siphoning money out of it. If you want your bridges, roads and sewage plants built/repaired, then you are going to need money and blocking the Trans Mountain is exactly the wrong way to obtain those funds. If you argue that fighting the TMX somehow is part of a fight against climate change that is simply bad thinking. The pipeline was part of the national plan to fight climate change and that plan looks like it has been scuttled by the activists.

While I agree the current process has not been a perfect one; it had, at least, been a transparent one. The allocation of risks associated with the status quo has not involved the balancing of risks and is anything but transparent. As I have written numerous times, we need to wean Canada off fossil fuels as our primary energy source. If we are to avoid the serious consequences of climate change, we will need to eliminate fossil fuels from our energy mix. However, contrary to what many say, the process of doing so will take decades, and in the meantime we will still need petroleum hydrocarbons. The TMX project is the best project on the books to achieve that goal.

Posted in Canadian Politics, Climate Change, Climate Change Politics, Pipelines, Trans Mountain, Uncategorized | 17 Comments

On Southern Resident Killer Whales and the Trans Mountain Expansion Project

By now we all know about the Federal Court Decision on the Trans Mountain Expansion (TMX) project. The two grounds for quashing the Order in Council’s approval of the project were on First Nations consultation and on the assessment of risk to the southern resident killer whales. This post is about the latter.

In the Federal Court decision the court described the NEB final decision which found:

the operation of Project related marine vessels is likely to result in significant adverse effects to the Southern resident killer whale, and that it is likely to result in significant adverse effects on Aboriginal cultural uses associated with these marine mammals.

As I have pointed out online, in my opinion, the NEB’s assessment of the southern resident killer whales was one-dimensional in nature. You may ask what I mean by one-dimensional? What I mean is that the NEB only looked at the potential harms posed by the TMX to the population but it failed to consider whether the TMX may have positive influences. In this blog post I am going to take a holistic look at the TMX project with respect to the southern resident killer whales. I will consider how the project both increases risks and how it may reduce risks and/or stressors. In doing so, I want to help start a reasonable dialogue on southern resident killer whales and the TMX.

Let’s start by looking at the threats to this population. According to Fisheries and Oceans Canada:

The greatest threats to Resident Killer Whales are reduction in prey availability, contaminants, and acoustic and physical disturbance; ship strikes have also been recently identified as a threat. Exposure to toxic spills, interactions with fisheries and aquaculture, and climate change are other human-related threats that may negatively impact the Southern Resident Killer Whale population.

So let’s look at these topics one by one.


I will only briefly address this topic because I have previously addressed spills in detail. To summarize my previous post: the increased risk of a spill posed by the project is so small as to not represent a real concern. As I noted, the 7x increase in tanker numbers is counter-acted by the reduction in risk associated with the new safety requirements imposed by the NEB. This results in approximately a 30% increase in overall risk. However, the initial risk (1 major spill in every 3093 years) is so close to zero as to not elevate above de minimis levels. A 30% increase on an insignificant risk is still an insignificant risk. The real spill risks in the region are from barges, ferries and smaller, less well-regulated marine craft.

The other major contamination concern is from persistent organic pollutants (POPs) including chlorinated compounds, PCBs and dioxins. Now as we should know by now, the vast majority of these are derived from the current and historic activities in the Puget Sound and from Metro Vancouver. If you really want to reduce threats to the southern resident killer whales maybe it is time to upgrade water treatment in the Metro Vancouver area. Another suggestion would be to eliminate the combined sewers in Metro Vancouver. Our American cousins have huge historical pollution problems and maybe cleaning up some more of the Superfund sites in the Puget Sound would be appreciated by the whales. Unlike many, I don’t see the Victoria sewage as a major concern because Victoria has virtually no heavy industry so most of their waste is organics that don’t bioaccumulate and dissipate in the Strait of Juan de Fuca.

Physical Disturbances/Collision

With respect to physical disturbances and collisions, the argument goes: increasing the number of tankers would increase the number of collisions with marine mammals. This argument, while persuasive, is quite shallow. As the academic literature makes clear, killer whales are not at a major risk from collision in most of the Salish Sea. The major risk of collision is in Johnstone Strait, which would be a problem if tankers were heading in that direction, which they are not.

As for the increase in tanker traffic, the TMX tankers would represent an increase of 720 more ship movements in a Strait that sees 23,000 ship movements a year. Recognize that both the Port of Vancouver and the Port of Seattle are engaged in major expansions. So the increase in ship movements posed by the TMX will barely be significant.

So how did the court find differently? Well that is an example of the one-dimensionality of the NEB assessment and the Federal Court’s decision. In paragraph 425 of the Federal Court decision the court makes a big thing of noting that:

The Board expressed its expectation that Project – related marine vessels would represent a maximum of 13.9% of all vessel traffic in the regional study area, excluding the Burrard Inlet, and would decrease over time as the volume of marine vessel movements in the area is anticipated to grow.

This, of course, represents a massive case of cherry-picking. That number comes from Table 22 of the NEB report and represents the increase in project-related tanker traffic in Haro Strait compared to 2012 shipping. What a bizarre comparison.  In virtually every other part of the route the increase is much lower and by comparing the number to 2012 numbers it ignores the commensurate increases associated with the Port expansions. More importantly, this assessment ignores a critical consideration. Let’s look at Haro Strait (image source):


Now what do we see the to the east of Haro Strait? That would be Rosario Strait. For those unaware, Rosario Strait is the alternative marine route in the area. As has been pointed out:

Studies have identified Rosario Strait as the most dangerous tanker route in the inland waters of Washington state. Yet because of the location of refineries, this is the state’s busiest tanker thoroughfare, with more than 500 oil-laden ships sailing through it every year.

If there is ever a major spill here, its toll could be worse than that in Prince William Sound. Rosario Strait is in the middle of the delicate San Juan Islands and just a swift current away from the largest population areas of Washington state and British Columbia. All around it is the region’s richest concentration of sea birds, marine mammals, clams, oysters and commercial fish farms.

One of the benefits of the TMX is that it is intended to supply the Puget Sound refineries via the Puget Sound Pipeline System. The Puget Sound Pipeline, which is a spur line of the Trans Mountain, can supply the Ferndale Refinery, the Cherry Point Refinery, the Andeavor Anacortes Refinery and the Shell Anacortes Refinery. By supplying crude to these refineries, via the Puget Sound Pipeline, the TMX would reduce the number of tankers running through Rosario Strait. Consider that there are over 500 tankers that go up the Rosario Strait to the Cherry Point Refinery. |Moreover, a further 120 new tankers a year are proposed for the Andeavor Anacortes Refinery. That represents 620+ tankers that could be reduced/eliminated if the TMX is completed. The last time I checked 620+ is a bigger number than the 540-600 tanker increase associated with the TMX.

Every mariner alive will tell you that Haro Strait is much safer than Rosario Strait but the reduction of travel through Rosario was never considered in the NEB/Federal Court analyses. Unlike the NEB/Federal Court, the southern resident killer whales don’t acknowledge international borders and use both straits. Given the relative sizes of the two straits, Rosario Strait poses a much higher risk of collision and an orders of magnitude higher risk of a spill. Yet in the one-dimensional NEB/Federal Court assessment they only looked at the increase in Haro Strait traffic while ignoring the safety improvements inherent by reducing tanker transits through Rosario Strait.


Everyone knows about the acoustics issues but if acoustics are really a concern then rather than quashing the TMX, the court should be cancelling the Port of Vancouver’s expansion plans. That being said acoustics are a serious concern and so as part of the Recovery Strategy for the Northern and Southern Resident Killer Whales (Orcinus orca) in Canada they will be slowing down the tankers to reduce their noise. But going back to the previous section, the increase in TMX tankers will essentially be offset by the reduction in tankers in American waters. The construction of the pipeline will likely be a wash acoustically.


We all know that the biggest threat to the southern resident killer whales is a shortage of food. The resident whales mostly eat salmon and the reduction in salmon stocks has been pointed to as the likely major source of their recent struggles. One big benefit of the TMX is how it will substantially reduce the likelihood of a oil-by-rail spill. The risk of incident is 4.5 times higher for transportation via rail over pipeline; the relative risk to salmon is even higher for rail, because most rail lines are situated far closer, for a longer proportion of their length, to the rivers. That means that a rail spill is more likely to affect a salmon river than a pipeline spill would because the pipeline mostly avoids the riversides.

Looking at the project from a risk assessment perspective, if you are a community that depends on the health of our rivers, you will want to get as much of that oil off the rails as is possible. From a salmon perspective a rail spill has the potential to destroy a run or even kill a river. So if you care about the major food source for the southern resident killer whales then getting oil into pipelines and off the rails is something that the courts and the NEB should be looking to do as soon as humanly possible.

What is most frustrating from the perspective of a risk assessor is that reading the NEB report the only time oil-by-rail was considered was with respect to the lower costs associated with the pipeline. The reduction in GHGs associated with pipelines versus rail and the reduction of risk to aquatic and marine ecosystems associated with getting oil off the rails was completely omitted in the analysis. Another one-dimensional analysis.


From my kitchen table in Langley I can’t do a full risk assessment of the TMX project with respect to the southern resident killer whales. But looking at the TMX project, from a holistic perspective, it becomes clear that the original NEB assessment was deficient. The NEB assessment only looked at the negative effects on the Canadian side of the border while ignoring all the benefits associated with the project on the US side of the border. Now we all know that the southern resident killer whales don’t recognize international borders so they will experience both the risks and benefits associated with the project. More ship movements through Haro Strait will be off-set by the reduction of tanker movements through Rosario Strait. More tanker noise on the Canadian side of the marine corridor will be balanced by less tanker noise on the US side of the corridor. From that perspective the TMX seems to be a wash from a risk perspective. However, when we consider that any reduction in oil-by-rail will reduce the risk to the salmon, upon which the southern resident killer whales depend for their food, the project may potentially have a net benefit to the population.

To conclude, I am confident that when a detailed assessment is carried out, the net effect of tanker traffic increases and decreases, associated with the project, will be a wash. Moreover, if the NEB considers the decrease in risk to salmon created by getting oil off the rails, on both sides of the border, that overall the TMX will be shown to be a net benefit to our endangered southern resident killer whales.

Posted in Pipelines, Trans Mountain, Uncategorized | 24 Comments