Letter to Enbridge Northern Gateway Pipeline on behalf of Sustainability Solutions Group

Hi everyone,

I've been away from my blog for a while. So long that the draft that was sitting on my blog page was the November 2011 start of this letter to the Enbridge Northern Gateway Pipeline Joint Review Panel, that I submitted in August 2012 on behalf of my colleagues at Sustainability Solutions Group. I will also post my notes from my presentation Monday.

Dear Members of the Northern Gateway Pipeline Joint Review Panel,

My name is Adrian Mohareb. I am a professional engineer and an associate with Sustainability Solutions Group (SSG). I am sending this letter, on my behalf and that of my colleagues at SSG, as comments on Enbridge’s Northern Gateway Pipeline (NGP) project. We wish to, by way of this letter, register our disapproval with the project, and outline some of the reasons we disapprove of the project.

While this letter is informed by my personal experience and reflects my opinion, it represents the position of my colleagues at Sustainability Solutions Group as well. Sustainability Solutions Group (SSG) is a collective of Canada's leading sustainability professionals. We are an innovative worker's cooperative that collaborates with clients to develop meaningful, creative strategies to integrate ecological, economic and social sustainability in their projects, organizations and communities. We pride ourselves in working closely with our clients to achieve real, on the ground social and ecological change through projects of unusual integrity. Our vision is a world of just, sustainable and healthy communities everywhere. Our co-operative of experts in energy, policy and design inspire sustainable buildings, communities and organisations.

My colleagues and I believe there are myriad reasons to disapprove of this project from an environmental perspective. Notably, there are the risks of pipeline spills and incidents to inland waterways and fisheries and the risks of tanker incidents in the Douglas Channel, the Hecate Strait and the Pacific Ocean. The economic threats to tourism and to the fisheries of an incident are great, and from the perspective of British Columbians, the threats simply cannot outweigh these risks.

In my previous position as Community Energy Manager for the City of Prince George, I met many people with concerns about the pipeline and its risks to the terrestrial, freshwater and marine ecosystems of British Columbia, and the livelihoods of those dependent on these ecosystems, including the First Nations of the region, who are acutely aware of and vulnerable to these risks. There are also socio-economic reasons to be leery of this project, but as I am an environmental engineer by training, I will leave these issues to others more capable, such as Robyn Allen and The Royal Society of Canada’s Expert Panel, to describe how this and other oil sands-related projects create adverse social and economic impacts in Canada.

My professional path has led me to view this project as a threat to the environment that cannot be countenanced by the perceived economic benefits. Furthermore, most analyses of the economic benefit neglect the economic harm that is done by emitting greenhouse gases (GHGs), particularly the social cost of carbon, which I have estimated at just over one-third of the current value of the project. I will discuss this later.

I will speak from my experience as a professional engineer, and my comments are informed by my education (a Bachelor’s in chemical engineering from Queen’s University, a Masters degree in environmental engineering from the University of Ottawa, and a Masters in Strategic Leadership towards Sustainability from the Blekinge Institute of Technology in Karlskrona, Sweden) and my professional experience, which includes the role of Community Energy Program Manager at the City of Prince George, and now as an associate with Sustainability Solutions Group, a consulting cooperative that seeks to work with organizations, developers and local governments to reduce the environmental footprint of the built environment.

Most notably for this submission, I am a former employee with Natural Resources Canada. My first role was as a Greenhouse Gas Technology Officer for Technology Early Action Measures, a program that funded greenhouse gas emission reduction projects at the late development and early demonstration stage. I then worked in the International Environment Policy Division, where my colleagues and I were involved in international climate change negotiations. I was the Intergovernmental Panel on Climate Change (IPCC) focal point for the division, and was on Canada’s negotiating team at the Fourth Assessment Report (AR4) meetings for Working Group Three (WG3) on Mitigation of Climate Change and for the Synthesis Report. It is through this work that I feel I have gained the expertise to speak out against this project.

My deepest understanding of the project’s risks are based in the climate risks of this project, and the potential for increasing long-term damage to the climate that will result from it.

Enbridge’s Northern Gateway Pipeline is intended to move crude oil from the oil sands of Northern Alberta to foreign markets. In 2010, approximately 1.46 million barrels per day (bbl/d) of oil sands products were being moved for refining and end-use in the Canadian and American markets, with little export to other markets. It is a landlocked resource, since the resource must reach ports to be exported to other markets. While there remains some unused pipeline capacity (notably Kinder Morgan’s Transmountain pipeline), it is evident that there is a desire to move more oil sands crude to foreign markets. Enbridge has stated that the NGP is already fully committed. My understanding is that there is a goal to increase production of oil sands to 5 million bbl/d over the next 40 years, and sooner if possible. Achieving this goal will require an increase in pipeline capacity to move the product to other markets, as the Canadian demand is in the 3.5 million bbl/d range, and there is a desire to diversify recipients beyond the US market, after approval of the Keystone XL pipeline to the US Gulf Coast was delayed.

The twin pipelines are intended to move 193,000 bbl/d of natural gas condensates from Kitimat, BC to Bruderheim, AB., and 525,000 bbl/d of other oil sands products to Kitimat from Bruderheim. We can by and large expect this to be diluted bitumen (dilbit). Enbridge states that for pipeline transportation, dilbit is usually 25-30% condensate, and 70-75% bitumen. I’ll look at only the incremental GHG emission analysis resulting from the NGP in this letter, in order to demonstrate the additional impacts of this project. I define incremental as emissions that would not have happened without this project, as the oil sands resource is landlocked, and without pipelines to ports, cannot get to market. I have decided to be conservative with my assessment, and assume that natural gas condensates are not incremental (i.e., they would’ve found other markets for their purchase and use) and that the dilbit contains 30% condensates and 70% bitumen (i.e. the lower amount of bitumen). Therefore, in my assessment, the larger diameter pipeline, at full capacity, would transport 155,000 bbl/d of condensate and 370,000 bbl/d of bitumen to Kitimat.

A submission by Jacobs Consultancy and Life Cycle Associates to the Alberta Energy Research Institute outlined the well-to-wheel emissions factors for oil sands crude production. I have chosen to use well-to-wheel emission factors, on the assumption that the project would allow the increased exploitation of the oil sands, resulting in emissions that otherwise would not happen as the oil would be landlocked. I recognize that not all of these emissions would happen in Canada; in fact, only the extraction, mixing and pipeline transportation emissions would occur in Canada. However, the emissions are incremental, and combustion products are added to the global commons of the atmosphere, regardless of where the combustion occurs.

Life-cycle/well-to-wheel emissions for diluted bitumen produced from extraction by in-situ processes were estimated by Jacobs Consultancy to average of 105.4 g of carbon dioxide equivalent (CO2e) per megajoule (g CO2e/MJ). The energy content of dilbit is 5,020 MJ/bbl, meaning average emissions of 529 kg CO2e/bbl. For 370,000 bbl/day of bitumen being transported as dilbit, this means that there is an extra 196,000 tonnes of CO2e (t CO2e) emitted daily. Assuming that the pipeline operates about 350 days per year (i.e. assuming that there are the equivalent of approximately 15 days of downtime annually, this project results in 68.5 million t CO2e of incremental emissions (from the production of nearly 130 million bbl of bitumen annually). For comparison, the annual emissions of Sweden, a country of 9 million, have been lower than 67.5 Mt CO2e since 2005. Essentially, this project will result in the addition of a Sweden to the atmosphere. Based on the average 2011 bitumen price of $65.50/bbl, 130 million bbl/year of bitumen could be sold for approximately $8.5 billion. While it is not an equal comparison, the Swedish economy had a GDP of approximately $530 billion in 2011.

Let’s also consider the environmental cost of this project. The social cost of carbon, defined as “…an estimate of the economic value of the extra (or marginal) impact caused by the emission of one more tonne of carbon (in the form of carbon dioxide) at any point in time; it can, as well, be interpreted as the marginal benefit of reducing carbon emissions by one tonne” in the IPCC AR4 report, in chapter 20 of Working Group Two (WG2) on impacts, adaptation and vulnerability to climate change. In this report, it was estimated that the average social cost of carbon from peer-reviewed studies was $43/t CO2e. If we multiply this number by the 68.5 million tonnes resulting from the project, we end up with a social cost of carbon for the project at $2.95 billion. This is equal to 35% of the annual revenue from the bitumen produced in this project. I should note that this cost is expected to increase as time goes on, but I have not undertaken an assessment of future costs vs. revenues, as I cannot determine how much they will increase, nor can I determine how much the price of bitumen will change.

This external cost is passed along to Canada and to the rest of the world as the cost of the impacts of extreme events such as hurricanes, floods, heat waves, sea level rise and droughts, lost agricultural production from the changed climate, and illness brought on by vectors that are able to survive in new areas and infect people that were not previously threatened by the illness (e.g. the expansion of malarial zones). Quite literally, the economic value of this project will be gained by the few on the backs of many others, who will only suffer damage from the climate impacts of the project.

At the 2009 United Nation Framework Convention on Climate Change (UNFCCC) 15th Conference of the Parties (COP15) in Copenhagen, the Canadian government committed Canada to a 17% reduction in emissions from 2005 emissions by 2020, and the government has also announced a 65% reduction target for 2050. While great strides have been made in reducing emissions from electricity production, particularly in Ontario with the closure of most of the coal-fired generation, there remains much to do to achieve the carbon emission reduction goal. This target is a contribution to a global target of reducing emissions by 50 to 85% from 2000 levels by 2050 in order to avoid increasing global temperatures by more than 2ºC, the generally agreed threshold for avoiding dangerous anthropogenic interference in the climate system (outlined in IPCC AR4 WG3, and agreed by governments in Copenhagen). In order to meet this target, which would limit the worst of the impacts of climate change, society simply has no alternative – we must reduce the amount of greenhouse gases being emitted. Meinshausen et al. state that globally, we can only emit 900 gigatonnes (Gt) CO2e between 2000 and 2050 to have an 80% chance of meeting the 2oC target; global emissions between 2000 and 2011 were about one-third of this 900 Gt limit, meaning that we must greatly reduce our emission rate. We simply cannot emit the 2800 Gt CO2 that would result from burning all of the proven reserves of fossil fuels; In fact, we can only burn about 20% of those fossil fuels over the next 38 years. Some reserves must stay in the ground. Slowing the extraction of oil sands (perhaps a moratorium on new developments, as was called for on a temporary basis by the oil sands companies in 2008) would allow for Canada to play its part. As well, I would suggest the government put in place policies, such as carbon pricing, as called for by the Canadian Council of Chief Executives.

From a personal perspective, I have noted that the Federal Government’s activities have played a role in the decline in the morale of my former colleagues at Natural Resources Canada. Most civil servants I know enter the public service out of a sense of obligation to Canadian citizens, and to serve the public interest. They do not feel that their current mandate offers the opportunity to serve the interest of Canadians effectively.

Members of the Joint Review Panel, I urge you, as an independent body, to reject this project on the basis of the increased greenhouse gas emissions. Doing so would assist Canada in meeting its greenhouse gas emission targets, and would avoid a minimum of $3 billion of impacts per year, every year, for the lifetime of this project, borne on the backs of the global community. I would like to thank you very much for your time, and wish you all the best in making this undoubtedly difficult decision.

Sincerely,

Adrian Mohareb

On behalf of Sustainability Solutions Group Worker’s Cooperative