Letter NEB re TMX Reconsideration Hearing

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Bowen  Denman  Hornby  Gabriola Galiano  Gambier  Lasqueti  Mayne  North Pender  Salt Spring  Saturna  South Pender  Thetis 
 
 
200 - 1627 Fort St., 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 
 
October 3, 2018    File No.: 5020-30 
 
Via Fax: 403-292-5503 (toll-free 1-877-288-8803) 
 
Ms. Sheri Young 
Secretary of the Board 
National Energy Board 
Suite 210, 517 Tenth Avenue SW 
Calgary, AB T2R 0A8 
 
Dear Ms. Sheri Young: 
 
Re:  Islands Trust submission to NEB re TMX Reconsideration hearing 
 
The Islands Trust, as a government body established by the Province of British Columbia through the Islands Trust Act, asserts 
that Project-related marine shipping should be part of the designated project under CEAA 2012 and that marine shipping 
should be considered as more than incidental to the project. In 2011, we were the first agency to assert that the National 
Energy Board should be considering marine shipping when assessing expansion of the Trans Mountain Pipeline.  
 
List of Issues 
 
The Islands Trust respectfully suggests that the Board requires additional evidence about the environmental effects of 
Project-related marine shipping. 
 
The Islands Trust requests that the Board consider environmental effects of Project-related marine shipping related to use of 
anchorages in the Southern Gulf Islands. The concern is that Project-related vessels may end up at anchor in the event of 
pipeline product delivery issues, or that other vessels might be diverted to the 33 commercial vessel anchorages in Southern 
Gulf Islands due to delays resulting from additional Project tankers through the Second Narrows Movement Restricted Area. 
There has not, to our knowledge, ever been an environmental assessment of the impacts of anchored vessels in the Southern 
Gulf Islands which includes Southern Resident Killer Whale critical habitat. Increases in light and sound from anchored vessels 
may impact terrestrial and marine species (including species at risk) through potential changes to foraging, migration, and 
transitory patterns. The significant light and sounds from anchored vessels may also impact human health and there is 
potential environmental damage due to anchor dragging on the seabed. There are also concerns associated with the risk of 
contamination from discharge of sewage and foreign bilge water from anchored vessels. 
 
The Islands Trust also submits that there may be the need for additional evidence related to air emissions impacts in the 
Southern Gulf Islands and Boundary Pass/Haro Strait. There are concerns about air emissions in the Islands Trust Area from 
project related vessels particularly in light of cumulative effects from increasing vessel traffic generally. There are also 
concerns at the local level about the emissions that may be emitted from marin

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