As an Environmental Non-Government Organization, (ENGO) the Friends of Ecological Reserves (FER)1 are encouraged that the provincial Environmental Assessment Office (EAO) has conducted a review of this project including the marine transport portion.2 This submission by the Board of FER proposes strengthening the permit conditions that the EAO developed. We agree that additional permit conditions are absolutely necessary.

FER proposes the EAO strengthen permit condition 35 and expand its scope from the current requirement for TMX to simply produce “a single report regarding the current and future research programs that the Holder is leading regarding the behaviour and recovery of heavy oils spilled in freshwater and marine aquatic”.

We believe that it is short-sighted for the EAO office, acting in the public interest, to put confidence in a single report. This is a 30+ year project and to assess research, direct future research and monitoring, requires the need for on-going research and long-term environmental monitoring obligations for TMX who bring this long-term risk to our marine ecosystems.

See this PDF for the Recommendations to the EAO (15 pages)TMX project–EAO