Should Oil transport be Determined by Environmental Conditions
This article is included because it deals with the imminent threat from oil spills that would affect the Ecological Reserves along the tanker route .
Metchosin Environmental Advisory Select Committee (MEASC) feedback regarding Western Canada Marine Response Corporations (WCMRC) Oil Spill Response and Coastal Mapping Program for Metchosin
In 2017, Western Canada Marine Response Corporations (WCMRC) held a workshop in
Metchosin where Metchosin residents provided input to WCMRC regarding which areas along
Metchosin’s coast should be identified as ‘sensitive’. WCMRC produced Geographic Response
Strategies (GRS) and On Water Tactics (OWT) for some of the sites identified during the
workshop. “GRSs are localized site-specific response plans tailored to identify sensitive
shoreline features threatened by an oil spill and describe how to protect them by preventing oil
from reaching the shoreline” (WCRMC, 2021). OWTs are developed for coastal areas that may
be too exposed, or lack suitable locations, to secure booms (WCRMC, 2021).
Western Canada Marine Response Corporations (WCMRC) “is an industry funded organization
that serves as the Transport Canada certified marine spill response organization for Canada’s
west coast” (WCRMC, 2021). Enhanced spill response is part of the Trans Mountain Expansion
Project which is anticipated to result in a sevenfold increase of tanker traffic in BC’s coastal
waters, and thus an increase in the risk of a diluted bitumen (dilbit) spill.
The aim of this report is to evaluate WCRMC’s current spill response plans in Metchosin, and to
provide recommendations to Council for their consideration. Council can forward the
recommendations to WCRMC with the purpose of increasing the efficacy of oil spill recovery in
Limitations and Recommendations of WCMRC’s Current Oil Spill Response Strategies
Process of Identification of Sensitive Sites for Spill Response in Metchosin
Limitation 1: The Data-driven Sensitivity Model used to Determine Site Selection
WCMRC’s data-driven shoreline sensitivity model, which is used to identify sensitive shorelines,
has not yet been applied to Metchosin. The model was developed in 2017 and has been
applied to Howe Sound with Barkley Sound/Alberni Inlet as a second study area. WCMRC
states that it will continue to apply the model to areas in coastal BC, prioritizing areas within
the ‘Increased Response Area’ (which Metchosin falls within). If the model were to be applied
to Metchosin, it is not clear which baseline data WCRMC would use to represent ecological,
cultural, or environmental features. Furthermore, it is not clear if WCMRC has a minimum
standard for the quantity and quality of baseline data prior to applying the model to an area, if
such data are available. If no data are available for a section of shoreline in Metchosin, that
area may not be flagged for creation of a GRS even though absence of baseline data is not
necessarily evidence of absence of ecological, cultural, or economic features.
MEASC recommends WCMRC apply the shoreline sensitivity model to Metchosin and consider
producing additional GRSs for new sites identified by the model. MEASC, and other local
experts, should be consulted during the modelling process to review the baseline data used in
the model, with the option to provide additional data and local knowledge. WCMRC should
submit a report to Council that outlines the baseline data used in the model, the areas
identified as sensitive by the model, and whether a GRS or OWT will be developed for each site,
and if not, why.
Limitation 2: Transparency of Process of Identification of Areas for Spill Response
WCMRC has not provided documentation from the 2017 workshop in Metchosin. During the
workshop, attendees identified sites in Metchosin that WCMRC subsequently did not produce
GRSs or OWTs for. WCRMC should provide feedback to the attendees and community
members including information on why WCMRC developed GRSs for some identified sites and
not others. Transparency of the site selection process is an important component in developing
trust with communities and will lead to more effective spill response outcomes because
community members will be empowered to provide feedback.
MEASC recommends that WCMRC provide a document to Council that outlines the results of
the 2017 workshop, including the following:
- all the sites that were identified by attendees
- which sites WCMRC did not produce GRSs or OWTs for, and a rationale for the decision
- relevant future plans (e.g., dates of GRS field verification, planned revisions, etc.)
Limitation 3: Ecologically Sensitive Areas without a GRS
There are some ecologically sensitive sites in Metchosin that do not have a GRS or OWT. This
limitation may be addressed if WCMRC acts upon Limitations 1 and 2. MEASC is concerned that
spilled dilbit may disproportionately impact the entrances of Metchosin’s shoreline wetlands
and lagoons such as Gooch Creek, Witty’s Lagoon, Weir’s Beach, and Sherwood Creek.
MEASC recommends that Limitations 1 and 2 are addressed by WCMRC and that GRSs are
considered for Metchosin’s shoreline wetlands and lagoons
Limitation 4: Revision of the Process of Identification of Areas for Spill Response
It is not clear whether the GRSs in Metchosin have been verified in the field. During WCMRC’s
GRS field verification process, the feasibility of the proposed strategy is tested, and information
is collected which can be used to revise and enhance the GRSs (WCMRC, 2021). This is an
important step for a number of reasons. First, it is an opportunity for Indigenous Peoples,
Council, community groups, and community members to share local knowledge and identify
additional sites of concern in the field (WCMRC, 2021). It is also important because there may
be instances where a protection strategy may not be appropriate for a given area and thus an
OWT may be developed instead (WCMRC, 2021). Lastly, it is not clear whether multiple GRSs
can be deployed at the same time due to equipment and labour constraints, and whether
implementation of some GRSs will be prioritized over others given the time-sensitive nature of
an oil spill.
MEASC recommends that field verification for all Metchosin GRSs should occur if they have not
already, and that findings from the field verification are used to revise and enhance the GRSs in
Metchosin. MEASC recommends that each GRS should include its field verification status (e.g.,
if a GRS has been tested or not, and the date of the test). If certain GRSs will be prioritized over
others in Metchosin in the event of a spill, that information should be included on the GRS as
Efficacy of Spill Response
Limitation 5: Adverse Weather Conditions
It is important for oil spill response strategies to acknowledge spill response gaps and
limitations in addition to demonstrating their response capability (Nuka Research and Planning
Group, 2015). WCMRC is limited in its ability to respond to a dilbit spill in poor weather
conditions. Transport Canada Response Organizations Regulations (SOR/95-405) state that
equipment for on-water spill recovery in unsheltered waters must operate in Beaufort Force 4
conditions, which equates to wind speeds up to 28 km per hour and small waves (i.e., 1-1.5 m).
Spill responders will not deploy at higher wind speeds because limitations with current
technology render booms ineffective. Based on 2020 data at the Eastern Entrance of the Strait
of Juan de Fuca (at Race Rocks), wind speeds were 28 km per hour or higher 40 percent of the
time in the year, under which conditions no clean-up operations using existing technology
would be possible (Friends of Ecological Reserves, 2021). Furthermore, other environmental
conditions such as fog, darkness, and strong currents may also inhibit or prevent spill response
even when wind speed and wave heights are low (Nuka Research and Planning Group, 2006).
For example, the comprehensive response gap analysis conducted by Nuka Research and
Planning Group in 2015 found that open water mechanical recovery with aerial reconnaissance
would not be possible in the Juan de Fuca Strait 60 percent of the time in winter, and 40
percent of the time in summer, when multiple environmental factors are considered. “If a spill
occurs during a time when response gap conditions exist, the unmitigated oil slick will remain in
the environment until conditions improve. If the response gap conditions extend for several
days, there may not be any opportunity for on-water recovery” (Nuka Research and Planning
MEASC recommends that Council request that WCMRC include text in all GRSs stating that spill
response may be limited in poor weather conditions and prevented in conditions greater than
Beaufort Force 4. This will improve transparency of the limitations of the spill response
program in Metchosin.
MEASC recommends that Council urge Transport Canada to require that no transport of dilbit
occur when environmental conditions in the Strait of Juan de Fuca prevent the recovery of
spilled dilbit. A similar concern has been raised by the Prince William Sound Regional Citizen’s
Advisory Council for oil transport in Hinchinbrook Entrance based on the calculated response
gap in this area (Prince William Sound Regional Citizen’s Advisory Council, 2021).
Limitation 6: Spill Response Readiness
Currently, the GRSs do not indicate that equipment packages needed for spill response in
Metchosin will be located on-site.
Equipment packages should be strategically located near deployment locations to minimize
delay in spill response.
Limitation 7: Spilled Oil May Submerge or Sink
There is uncertainty surrounding the behaviour of spilled dilbit in different environmental
conditions (DFO, 2018). Although lab- and tank-scale testing shows that dilbit may float on
freshwater for at least 21 days (Dettman et al. 2017), these studies may not be representative
of the environmental conditions on coastal BC (for a summary of research and findings see
Government of BC, 2019). In some circumstances, oil spilled into the marine environment may
sink within as little as a few days if a combined effect of warm water temperature, decreased
salinity of surface waters (e.g., spring freshet), and moderate winds are present (Government of
BC, 2019). WCMRC indicates that a draft ‘Sunken and Submerged Oil Plan’ has been completed
(WCMRC, 2018a), but the current GRSs in Metchosin do not include spill response techniques
to address the recovery of submerged dilbit.
MEASC recognizes that Transport Canada’s Planning Standards for Response Organizations does
not describe any requirements for the recovery of submerged or sunken oil; instead, it only
provides standards for on-water recovery and shoreline cleanup (WCMRC, 2018b). Although
recovery of submerged or sunken oil is not required by Transport Canada, MEASC recommends
that Council urge WCMRC to publicly release their ‘Sunken and Submerged Oil Plan’ and carry
out and/or fund peer-reviewed research on the behaviour of spilled dilbit in environmental
conditions similar to what would be found in coastal BC. If research concludes that spilled dilbit
may sink in a short period of time in BC waters, then MEASC recommends that WCRMC update
the GRSs to include recovery strategies in the GRSs specific to submerged dilbit.
Limitation 8: Potential Use of Spill Treating Agents
Some uncertainty exists regarding the federal government’s plan to consider the use of
alternate response measures (ARMs) such as chemical spill treating agents as potential tools for
oil spill response (Government of British Columbia, 2019). The Government of Canada under
the Oceans Protection Plan has announced that it is considering expanding the available
response options, including ARMs, through legislative changes (Government of Canada, 2018).
In 2016, the federal government approved the use of the dispersant Corexit 9500 in the event
of an oil spill from an offshore facility (Government of Canada, 2016). Although offshore oil and
gas production currently exists only on Canada’s East Coast, the federal government’s approval
of Corexit 9500 may set a precedent for spill response in BC. Based on one study from the
Deepwater Horizon disaster in 2010 in which Corexit 9527 and 9500 were applied, the authors
found that Corexit 9500 and oil together caused toxicity up to 52-fold higher than oil alone in
marine plankton (Rico-Martínez et al., 2013). In the federal government’s Regulations
Establishing a List of Spill-treating Agents, it states that “the potential for increased exposure to
components of the oil by aquatic organisms following the use of dispersants is a known risk
associated with their use” (Government of Canada, 2016). Prior to approval for dispersant use,
the Chief Conservation Officer “must make a determination whether use of the [spill treating
agent] is likely to achieve a net environmental benefit in the particular circumstances of the
spill” (Government of Canada, 2016). Effective spill response requires a response as quickly as
possible from the time when a spill occurs. Given the large size of BC’s coastline, the dynamic
nature of environmental conditions, and the potentially toxic effects of chemical dispersants to
humans and marine organisms, if dispersants were approved for use in BC, it would be very
challenging for someone to accurately determine whether their use would achieve a net
If the federal government approves the use of chemical spill treating agents in offshore or
coastal waters in BC, and if WCMRC subsequently adopts the use of spill treating agents in their
offshore response strategies, MEASC recommends that Council opposes their use in all BC
waters, unless independent peer-reviewed research demonstrates their efficacy in dilbit
dispersal and a net benefit of these treatments for the ecosystem.
Department of Fisheries and Oceans (DFO). 2018. Status Report on the Knowledge of the Fate
and Behaviour of Diluted Bitumen in the Aquatic Ecosystems. DFO Can. Sci. Advis. Sec. Sci. Resp.
Dettman, H.D., Farooqi H., and Namsechi, B. 2017. Test Tank Study of Diluted Bitumen and
Conventional Crude Weathering in Fresh Water. Presented at the Fortieth AMOP Technical
Seminar, Calgary, Alberta.
Friends of Ecological Reserves. 2021. Input to the BC Environmental Assessment Office and
additional conditions proposed for the TMX project related to protecting the marine
Government of British Columbia. 2019. Final Argument of the Province of British Columbia.
Part 1 of 2. Accessed from https://docs2.cer-rec.gc.ca/ll-
_A6R3H6.pdf?nodeid=3747518&vernum=-2 on May 22, 2021. 38pp.
Government of Canada. 2016. Regulations Establishing a List of Spill-treating Agents (Canada Oil
and Gas Operations Act). SOR/2016-108. Accessed on June 2, 2021 from
Government of Canada. 2018. Responses of: Environment and Climate Change Canada,
Fisheries and Oceans Canada and Canadian Coast Guard, Heath Canada, Natural Resources
Canada, Parks Canada Agency and Transport Canada to Information Request of Province of BC,
Trans Mountain Expansion Project Reconsideration. Hearing Order MH-052-2018, Board File
Nuka Research and Planning Group, LLC. 2006. Response gap methods. Report to Prince William
Sound Regional Citizens’ Advisory Council. 27pp.
Nuka Research and Planning Group, LLC. 2015. Technical Analysis of Oil Spill Response
Capabilities and Limitations for Trans Mountain Expansion Project. 164pp.
Prince William Sound Regional Citizens’ Advisory Council. 2021. Oil Spill Response Gap.
Accessed on November 11, 2021 from https://www.pwsrcac.org/programs/oil-spill-
Rico-Martínez, R., Snell, T. W., Shearer, T. L.. 2013. Synergistic toxicity of Macondo crude oil and
dispersant Corexit 9500A® to the Brachionus plicatilis species complex (Rotifera). Environmental
Pollution, 173: 5-10.
Transport Canada. 2019. Response Organizations Regulations. SOR/95-405. Accessed on June 2,
2021 from https://laws-lois.justice.gc.ca/eng/regulations/SOR-95-405/
Western Canada Marine Response Corporation (WCMRC). 2018a. A6L5G5, Response to
Province of British Columbia Information Request (“IR”) No. 1 to Western Canada Marine
Response Corporation (WCMRC). Accessed on June 6, 2021 at https://docs2.cer-rec.gc.ca/ll-
Western Canada Marine Response Corporation (WCMRC). 2018b. A6Q6G1, Response to
Georgia Strait Alliance (GSA) Information Request (“IR”) No. 1 to Western Canada Marine
Response Corporation (WCMRC). Accessed on June 6, 2021 at https://docs2.cer-rec.gc.ca/ll-
Western Canada Marine Response Corporation (WCMRC). 2021. Geographic Response
Strategies: Standards and Procedures Manual. 65pp.
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