One of the largest environmental assessments (EAs) ever conducted in Canada for a pipeline
A major energy infrastructure firm proposed to expand an existing crude oil pipeline and storage system in Western Canada. The firm was seeking federal and provincial regulatory approval for the project, which required effective participation in a public hearing process managed by the National Energy Board (NEB).
The scale of the project, strong public scrutiny, and the fact that our client was adhering to a new and very stringent environmental assessment process made this one of the largest and most demanding Canadian EA processes ever carried out for a pipeline. The project involved:
- Multiple regulatory bodies in Alberta, British Columbia, and at the federal level;
- A large number of stakeholders, including many Indigenous participants and multiple municipal government participants; and
- A very large number of information requests (IRs) both from the National Energy Board (NEB) and from interveners.
Because of the large number of interveners, including environmental groups and municipal leaders who actively opposed the project, our client needed to perform more sophisticated air quality and noise assessments and distribute more detailed technical information than a pipeline project would typically require. For example, we carried out photochemical air shed modelling twice, a process that had never before been required for an NEB-reviewed project.
We served as technical discipline leads for noise, air quality, terrestrial spill hazard/risk assessment, and greenhouse gas (GHG) emissions. We conducted studies in each of these areas that satisfied the requirements of the NEB and those of provincial regulators. We also supplemented studies led by other teams in areas such as human health risk assessment, and informed the engineering design of the marine loading and storage terminals.
Our in-house teams’ combination of experience, scientific knowledge, regulatory understanding and communication capabilities were important to our ability to deliver accurate and meaningful engineering guidance on the anticipated effects of the proposed expansion. The fact that our experts are in-house, not on contract, let us support our client with consistency, efficiency and contextual awareness throughout the six-year EA process. We drew expertise from several of RWDI’s Canadian offices to ensure that our team’s expertise was optimally adapted to our clients’ technical needs, and we were able to respond quickly to client requests – related to informal information requests or preparation for hearings – that required timely responses.
Our contributions included:
- Supporting the stakeholder engagement process by providing experts with strong scientific backgrounds and communication skills to attend workshops, information sessions and meetings with environmental groups, landowners, Indigenous communities and the general public. Our representatives made presentations and answered questions to increase awareness of the steps being taken to quantify effects, inform design and demonstrate that the project can comply with all applicable environmental regulations.
- Helping the client engage regulators in face-to-face meetings. We responded to a range of informal information requests from regulators, and adapted our predictive modeling and engineering design guidance in response to their feedback.
- Scoping the EA by attending pre-consultations with regulators and affected municipalities and communities, including Indigenous communities, to establish key concerns and research questions.
- Conducting analyses of noise and emissions from all aspects of the project, including pump stations, storage terminals, pipeline and facility construction.
- Performing air and noise predictive modeling to inform engineering design for new product storage terminals as well as product loading at a marine terminal.
- Supplementing studies from other parts of the EA team – for instance, by providing measurements and modeling results to support the human health risk assessment.
- Helping our client respond to the enormous volume of Information Requests (IRs) they received; we prepared responses to the roughly 1300 IRs that fell in our subject areas, providing detailed technical information and predictive modeling to address concerns expressed by regulators and interveners.
- Developing Environmental Management and Protection Plans along the entire span of pipeline including at storage terminals and pump stations.
Ultimately, we submitted four substantial technical reports in support of the EA report, several supplementary reports many of which were used to inform engineering design and assisted in the preparation of the Final Argument and Reply Evidence filed with the NEB. RWDI also provided comments on the NEB and British Columbia draft Conditions, responded to comments from interveners for suggested changes, and peer-reviewed a relevant report from Environment and Climate Change Canada.
Because the project was the subject of considerable media attention and public debate, it was vital that exceptional care be devoted to preparing scientifically credible evidence to the client – both to articulate the project’s merits, and to demonstrate their capacity to effectively manage environmental components of its realization.
The NEB recommended the approval of the project, subject to numerous conditions, and it was subsequently greenlit by the federal government. The government noted that its decision was based on a rigorous debate on science and evidence rather than local, regional or national political arguments. Our client engaged our team to support them in fulfilling several of the conditions articulated by the NEB.
We continue to work with the client to develop strategies to effectively communicate our findings and plans to senior government officials. Several of the Management Plans required ongoing consultation with Indigenous communities, landowners and regulatory authorities and have been approved by the NEB.