TSLEIL-WAUTUTH NATION

Vivian Au Project Manager

People of the Inlet

Regional Operations, Pacific and Yukon Canadian Environmental Assessment Agency (the "Agency") Government of Canada

Our ref: 13-223

March 12016

Dear Vivian Au,

Re: Federal Environmental Assessment of the Woodfibre LNG Project- Comments on Upstream Greenhouse Gas Emissions Analysis

This letter is in response to your February 9th 2016letter inviting Tsleil-Waututh Nation's comment on the upstream greenhouse gas (GHG) emissions analysis (the "analysis") for the Woodfibre LNG project (the "Project"). We have reviewed the analysis in accordance with our Stewardship Policy (2009).

The Agency's Environmental Assessment process must support Canada's GHG emissions reduction targets under the Copenhagen Accord of 2009, and more broadly, as expressed at COP21. The upstream GHG emissions analysis required of federally reviewable projects is a welcome improvement in this regard. However, it is integral that the process and analytical methods used in these analyses are rigorous, comprehensive, and informative for decision-making purposes. The GHG emissions study completed for the Woodfibre LNG project, falls short of these standards, undermining the potential and integrity of the federal EA process, and Canada's action on climate change respectively.

The quantity and quality of information provided in the GHG analysis conducted by Environment and Climate Change Canada (ECCC), is not sufficient to inform a decision as to whether the Project is likely to cause significant adverse environmental effects under the Canadian Environmental Assessment Act, 2012 (CEAA 2012), or not. Tsleil-Waututh's precautionary approach to approving development that impacts our territory is also not yet satisfied under Tsleil-Waututh Law. Considerable improvements to the scope and assumptions, methods, and certainty of the GHG analysis, are needed. Our comments herein speak to particular deficiencies that require remedy.

General Comments

Tsleil-Waututh understands that the forecasted estimated at-site GHG emissions of the Project are low at 129 kilotonnes of C02e per year or 0.054 t C02e per tonne LNG. This is below the BC Greenhouse Gas Industrial Reporting and Control Act threshold of0.16 C02e per tonne LNG. It is also lower than most other proposed LNG facilities given the electric drive of the liquefaction compressors.

1

3075 Takaya Dr. North Vancouver, BC V7H 3A8 Tel: 604-929-3454 Fax: 604-929-4714

However, the project will result in significant GHG emissions upstream and downstream of the facility as estimated by ECCC; estimates range from 700 to 880 kilotonnes of C02e per year associated with natural gas production, processing and transmission. The downstream emissions will likely be an order of magnitude higher (approximately six to eight times) in consideration of shipping, re-gasification, transport, and potential combustion for power generation. We understand that natural gas power generation at end markets will off-set GHG emissions produced through coal fired power generation.

While the numeric estimates provided in the analysis appear reasonable, the analysis is weak in scope and assumptions, method, and certainty.

Scope and Assumptions

It is disappointing that the analysis does not consider a full life cycle assessment of GHG emissions related to the Project. The overall GHG emissions of the LNG process should be considered in support of the integrity of Canada's environmental assessment process. GHG emissions in the atmosphere causing climate change, is a global issue not limited by geographic, political, financial or legal boundaries. The analysis should consider emissions associated with natural gas production, processing, transport, liquefaction, storage, ship loading, transport by ship, gasification, transport and ultimate use. While the allocation of emissions to select companies and jurisdiction is useful for accounting and emission attribution, it is not a similarly appropriate strategy to use in assessing and addressing global GHG emissions, atmospheric concentrations, and climate change. Tsleil-Waututh Nation would like to work with CEAA to develop a full GHG emission life cycle analysis process as part of federal environmental assessments.

Cumulative impacts should be considered in this analysis as the GHG emissions are dependent on a number of related LNG projects that are being developed. Specifically, FortisBC's Eagle mountain­Woodfibre LNG Pipeline project is planned to serve the Woodfibre LNG facility. It is essential that FortisBC's project be incorporated into the overall GHG emissions analysis which it currently is not. Inclusion of the FortisBC project should cover all phases including construction, operations and decommissioning. The Pembina Institute model allows for the consideration of cumulative impacts of numerous LNG projects advancing at the same time and the consequent impact on the upstream and GHG emissions; this model should be utilized for its potential. We would like to work with the respective proponents accordingly.

The boundaries for analyses are unclear. The direct (on site) and indirect (i.e. emissions due to off-site power generation) are included, but it is not clear whether all Project phases are included (i.e. construction, operations and decommissioning). Tsleil-Waututh Nation requests that these boundaries are clarified.

ECCC state the natural gas would be produced whether or not the Project is developed. This is not correct as the natural gas will not be produced without markets, and Woodfibre LNG would create access to an important market. We expect that this notion be removed in concept and word from the analysis.

The proponent has not declared the likely source of natural gas thereby making estimates of upstream GHG analyses scientifically vague (low in accuracy). The proponent has also not indicated which specific sources will supply the natural gas for liquefaction. This is surprising because LNG developers usually require natural gas supply, pipelines, LNG facilities, and customers for the LNG to

2

3075 Takaya Dr. North Vancouver, BC V7H 3A8 Tel: 604-929-3454 Fax: 604-929-4714

be secured before they are willing to proceed with project investments. We encourage the proponent to disclose the intended source supply.

Methods

The analysis authors state that there was "limited time for this analysis and lack of reliable data and methodologies ... " (p.2). It is not excusable for an analysis of this type and purpose, to be conducted in a manner which jeopardizes the results and associated governmental decisions. Tsleil-Waututh expects that the Agency will review and amend unnecessary time-pressures and resource constraints that risk the integrity of project GHG emission analyses; this applies to the analysis in question and all future like studies.

The data used by the three models overlap so they are not independent models. The Clearstone model and data is used in two cases, and GHGenius is used in two cases. The implications of this multi­model approach, absent of a clear discussion on complementarities and conflicts, risk methodological credibility. We feel that the selected models are reasonable tools but request that the current analysis be amended to explain how these models are appropriately used in tandem to one-another.

Some of the models do not provide breakdown to production, processing and transport components, making it difficult to compare different models and assess the accuracy of the results. Further, it is unclear how adjustments were made by ECCC. ECCC did not fully explain the assumptions and methodology relied upon for calculating upstream emissions. Tsleil-Waututh requests that any adjustments made by ECCC accordingly be explained.

The models used are built on assumptions that may not be valid. For example, the analysis depends on assumptions such as where the natural gas for the project is sourced and the requirements for reducing or mitigating GHG emissions. Since the proponent has not specified the source of the natural gas, the assumption and resulting estimates could be incorrect. We encourage the proponent to provide source information to inform revisions in the GHG emissions analysis. Until and unless this is done, the analysis is inherently incomplete.

Forecast changes in upstream emissions are not explained. ECCC acknowledges that forecast of anticipated reduction in upstream GHG emissions are not considered. This is exemplified when the analysis authors discuss the potential for increased usage of underground injection for storage of C02

(especially if production increases in basins such as the Horn River with high C02 content in the extracted natural gas), electrification of gas production operations, or reductions in methane emissions due to more stringent requirements for leak detection and repair, equipment standards, or well completion practices. Tsleil-Waututh would like to know how forecast changes in upstream emissions were made.

The forecast for upstream emissions should be extended beyond 2030. Given that the Project is expected to have a 25-year expected lifetime, the analysis should forecast at to at least year 2042.

Certainty

The results are generic and do not deal with the specifics of the Project because the proponent has not defmed the sources of natural gas as previously discussed. Moreover, the analysis states that emissions should be taken as rough estimates given uncertainties inherent in the current analysis. This is an acknowledgement by ECCC that the methods need improvement so as to provide greater certainty. Without improved methods and greater certainty, the results are not functionally adequate to serve government decision-making.

3

3075 Takaya Dr. North Vancouver, BC V7H 3A8 Tel: 604-929-3454 Fax: 604-929-4714

<Original signed by>