News/Reports
NEB forwards one of our requests on effect of sea-sprayed oil on terrestrial systems to TMX.
As part of their most recent round of Information requests to Kinder Morgan/TMX, The National Energy Board has forwarded one of our concerns for a formal answer. This shows how important it is to have documented the foreshore as well as upland segments of our marine Ecological reserves. Hopefully, the support of this question by the NEB might obtain a straightforward answer from the Project proponent, TMX.
From http://docs.neb-one.gc.ca/fetch.asp?language=E&ID=A71268
6.15 Effects of oiled sea spray on terrestrial SARA-listed plant and lichen species Reference: A4Q2T7, The Board of the Friends of Ecological Reserves, Final Evidence Report, PDF pages 4 and 93 of 172
Preamble: In the reference, the Board of the Friends of Ecological Reserves states that several ecological reserves border on the ocean and, although, mainly created as terrestrial reserves, they are not exempt from the hazards of oil spills on the coastline. It also states that there are also numerous rare plants and lichens in the spray zone of such ecological reserves that would be susceptible in the case of an oil spill when storms are blowing sea spray laden with oil, and that this would very likely lead to local extirpations.
Request: Please provide an overview of the potential effects from oiled sea spray on SARA-listed terrestrial plant and lichen species and their critical habitat.
On August 20 Trans Mountain responded with the following:
From page 66-67 : ( bold added)
6.15
Effects of oiled sea spray on terrestrial SARA-listed plant and lichen species Reference: i) A4Q2T7, The Board of the Friends of Ecological Reserves, Final Evidence Report, PDF pages 4 and 93 of 172
Preamble: In the reference, the Board of the Friends of Ecological Reserves states that several ecological reserves border on the ocean and, although, mainly created as terrestrial reserves, they are not exempt from the hazards of oil spills on the coastline. It also states that there are also numerous rare plants and lichens in the spray zone of such ecological reserves that would be susceptible in the case of an oil spill when storms are blowing sea spray laden with oil, and that this would very likely lead to local extirpations.
Request from Board of FER: Please provide an overview of the potential effects from oiled sea spray on SARA-listed terrestrial plant and lichen species and their critical habitat.
Response from TMX: For reasons described in the response to BC Nature & Nature Cda IR No. 2.30 (Filing ID A4H7Y8), Trans Mountain evaluated potential environmental effects of credible worst-case and smaller oil spill scenarios, including effect on plant and lichen species at risk, at representative risk informed locations. More specifically, the Ecological Risk Assessment of Marine Transportation Spills (ERA; Filing ID A3S4K7), adopted a habitat-based approach to evaluate all of the water surface, and all shoreline within the regional study area (RSA). This evaluation did not extend into the supratidal zone, where 43 Species at Risk Act (SARA)-listed plant and lichen species (37 vascular plants, 3 moss, and 3 lichen), and their critical habitat, have the potential to occur.
As described in ERA Section 5.3.1, most shorelines (83%) in the RSA were found to be protected from high energy wave action, and therefore would not be susceptible to potential effects from oiled sea spray. Oiled sea spray could affect SARA-listed plant and lichen species on high energy rock, boulder, cobble, and sand shorelines that comprise 17% of the RSA. Analyses provided in ERA Section 6 demonstrate that shorelines with a high probability of oiling generally represent less than 10% of available habitat within the RSA, therefore it is reasonable to conclude that only a small fraction of the exposed shoreline areas within the RSA would potentially be at risk of oiling. The risk of oiling in the supra-tidal zone would be still lower, as it would require high wind/wave conditions leading to the formation of sea spay to occur at the same time as the hypothetical oil spill. In the event that such conditions were to occur, and areas of critical habitat for SARA-listed plant and lichen species were exposed to sea spray containing spilled crude oil, it is reasonable to conclude that harm to shoreline communities (i.e., death of oiled vascular plants, mosses or lichens) would result. For SARA-listed species or critical habitat, this would correspond to a 67 of 121 Trans Mountain Response to NEB IR No. 6 High effect magnitude. The recovery potential of such communities following oiling is unknown, and in consideration of their SARA status, as well as the documented sensitivity of some lichen species to air pollution, it must be assumed that the prognosis for recovery would be poor. However such an effect on SARA-listed plant and lichen species is demonstrated to have a low probability of occurrence in Volume 8A, Section 5.2 (Filing IDs A3S4Y3 and A3S4Y4). Potential oil sea spray related effects on SARA-listed plant and lichen species are therefore concluded to be not significant based on the significance framework and criteria provided in Section 4.3.1 of Volume 8A (Filing ID A3S4Y3).