Comment re: Trans Mountain’s Report on BC Environmental Assessment Office (EAO) Condition 35 about the Fate and Behaviour of Bitumen Research

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Preserving and protecting over 450 islands and surrounding waters in the Salish Sea 
Bowen  Denman  Hornby  Gabriola  Galiano Gambier  Lasqueti  Mayne  North Pender  Salt Spring  Saturna  South Pender  Thetis 
 
 
 
200-1627 Fort Street, Victoria BC  V8R 1H8 
Telephone  (250) 405-5151    Fax  (250) 405-5155 
Toll Free via Enquiry BC in Vancouver 604.660.2421.  Elsewhere in BC 
1.800.663.7867 
Email  information@islandstrust.bc.ca 
Web  www.islandstrust.bc.ca 
 
January 30, 2023       File No.: 11- 5020-30 
 
Via e-mail: christine_trefanenko@transmountain.com; 
Emergency_Management@transmountain.com 
 
Christine Trefanenko 
Manager, Project Emergency Management 
Trans Mountain 
 
Dear Christine: 
 
Re:  Trans Mountain’s Report on BC Environmental Assessment Office (EAO) Condition 35 about the Fate 
and Behaviour of Bitumen Research 
 
I am writing at the request of the Islands Trust 
Executive Committee to offer comment on the draft 
Trans Mountain Report produced to fulfil BC 
Environmental Assessment Office (EAO) Certificate 
Condition 35. Thank you for inviting Islands Trust to 
review and comment on the draft Report.  The Report 
sets out Trans Mountain’s current and future research 
programs regarding the behaviour and recovery of 
heavy oils, and how Trans Mountain will work with 
spill responders to support the incorporation of the 
results of the research into their emergency 
preparedness plans and programs.  
I feel it is important to state, as a priority message, 
that the Islands Trust Council has a history of opposing 
the Trans Mountain Pipeline Expansion Project, and 
island communities have voiced strong concerns 
about the impacts of an oil spill resulting from the 
project could have on their livelihoods and the 
ecology and cultural values of region. The values of 
this region demand a world-class research standard 
and associated response preparedness. 
 
.../2 
 
 
Diluted bitumen after about nine days of weathering at 
about 15
o
C. A lower temperature typical of the Salish Sea 
could increase thickness seen here. 
 

Christine Trefanenko 
January 30, 2023 
Page 2 
 
Preserving and protecting over 450 islands and surrounding waters in the Salish Sea 
Bowen  Denman  Hornby  Gabriola  Galiano Gambier  Lasqueti  Mayne  North Pender  Salt Spring  Saturna  South Pender  Thetis 
 
 
We appreciate the work done but remain concerned that there still may not be enough known about the fate 
and behaviour of diluted bitumen to fully inform the real-world spill response challenges associated with 
diluted bitumen in the Salish Sea.  
As an example, the Report points to Trans Mountain studies that indicated conventional diluted bitumen 
remains floating for extended periods of time, and that diluted bitumen does not separate. While this may 
be the case, the Report does not spell out nuanced research details that would inform how a response to a 
spill of diluted bitumen might differ from other responses. For example, a 2018 report by the

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