I was pretty young when Wilmer Miller, my grandfather on my mom’s side, died of cancer. He was a farmer in southeast Saskatchewan, a soft-spoken man of integrity. About the only saying of his that I can personally remember is: “If you’re going to do something, do it right.”
I’ve tried to live up to that, and I hold other people to that standard, including the folks at Enbridge Inc., who have presented the public with an application to bring the first ever crude oil supertankers to the Great Bear Rainforest.
Of the thousands of pages in Enbridge’s application, arguably the most important are those that contain the risk assessments for potential oil spills from the pipelines, terminal and tankers. Spills happen fairly frequently and can be devastating, so professionally assessing the risk they pose is very important. If you’re going to do it, you’ve got to do it right.
Turns out, Enbridge didn’t.
Doing a risk assessment right means thoroughly dealing with both aspects of what is called the “Risk Equation.”
Risk = Probability x Consequence
In the case of oil spills, probability means how often a spill of, say, 1,000 barrels of oil might happen. Consequence means looking at how damaging that spill of 1,000 barrels would be in different situations, like in a river vs. in a ditch, in winter vs. in summer, a quick spill vs. a slow spill, a spill near Burns Lake vs. a spill near Prince George (the two communities might place value on different things).
The shocking fact is that despite spending more than $70 million on its application, which took years to produce, the work Enbridge has presented to the public more or less leaves out the consequence side of the risk equation, or deals with it sheepishly.
We found this out by applying for federal funding to pay an expert in environmental assessment to analyze Enbridge’s risk assessment and write a report for the Joint Review Panel. We wanted a leader in the field of environmental assessment to provide an independent analysis of Enbridge’s application. Thankfully, I just so happened to know someone who fit the bill perfectly – my mom, Stella Swanson. I’m going to go ahead and brag a bit by saying that she’s about as bulletproof a scientist as you could come by. She cuts through B.S., including my own on occasion, like a warm knife through butter.
Her overall conclusions of the adequacy of Enbridge’s risk assessments are as follows: “Volumes 7B and 7C (the risk assessments for the proposed pipelines and marine terminal, respectively) present a series of analyses related to hydrocarbon spills that do not provide an adequate basis for decision-making . . . Volume 7B does not include any true risk assessment while Volume 7C includes a standard risk assessment unsuited to the task of evaluating risks at a landscape scale. There are major sources of uncertainty that are not adequately acknowledged and/or incorporated into the analysis. There are no evaluations of the effectiveness of prevention and mitigation measures in the context of the actual environment of the pipeline and marine terminal. There are no commitments by the proponent to research and development of prevention and mitigation measures. Monitoring programs are described in an extremely cursory manner and there is no description of how monitoring data will be used to feed back into operations and further mitigation.”
The inadequacies are similar for Enbridge’s tanker risk assessment. In the media, Enbridge acknowledged the issues raised in Stella’s reports, claiming their risk assessments are “a work in progress.” But that explanation doesn’t wash because the holes in Enbridge’s work are gigantic, not the kind of thing you just “tweak” later. Furthermore, Enbridge was supposed to have submitted all of its evidence two months ago so that the public had time to review it. One thing we know for sure is that Enbridge had the resources to do it right, so why didn’t they? Use your imagination.
You can read the full analyses of Enbridge’s risk assessments here, including a Letter of Comment by Dogwood explaining why we think the Joint Review Panel process fails the public overall. Since we filed these analyses with the National Energy Board, the Haisla Nation has requested the Joint Review Panel compel Enbridge to file complete information – to do it right, in other words – before the process is allowed to proceed.