Project Review Committee Port Alberni Generation Project c/o Jan Hagen, Project Assessment Director and Project Committee Chair Environmental Assessment Office PO Box 9426, Stn Prov Govt Victoria BC V8W 9V1 jan.hagen@gems9.gov.bc.ca Re: Port Alberni Generation Project Dear Mr. Hagen and Committee Members: The project review for the proposed Port Alberni Generation Project (PAGP) must ensure that "all potentially interested parties" are involved (this phrase is from the EAO website), or are given the opportunity to be involved, in the review of the proposed project. Many people and organizations in Port Alberni have already indicated some of their concerns with the proposed project, and some people and organizations who are not from Port Alberni have also registered their concerns. There is clearly intense public interest in this project. But not all of those indications of concern have been addressed to the Project Committee, and not all potentially interested parties have as yet had an opportunity to express their concerns about the project. It is unlikely that all potentially interested parties will a) be aware of the proposed project, b) have studied the issues sufficiently to be able to make informed comments, and c) be aware of the September 10 deadline for public comments. The best forum for all potentially interested parties is a formal public hearing. I therefore strongly encourage you to recommend to the appropriate ministers that they refer the project to a Stage 2 Project Report which would enable broader public participation, and may reveal the need for the Stage 3 Hearing. There are many serious concerns with the proposed Port Alberni Generation Project. Some are within the mandate of the Project Committee to consider, and others are outside the jurisdiction of the Committee. This is unfortunate, because some of those issues that may be beyond the EAO jurisdiction, still need to be discussed in a public forum. Of greatest concern is the role the proposed project will play in provincial energy policy. Is it necessary? Are there alternatives that make better economic and/or environmental sense? Neither BC Hydro nor the provincial government have engaged the public in a discussion of these issues. But there are better alternatives. And there are strong indications that power from the project is not needed at this time. If the project is not needed or its purpose can be better provided in other ways, then the Project Committee should know that. You deserve to be in the position of making a recommendation for a project that is at least necessary, even if this determination is not within EAO jurisdiction. The Port Alberni Generation Project is one component in a set of tied, interdependent, electricity generating projects. It is absurd to be considering one part of the whole, out of context with the economic and environmental impacts of all the components. This project is part of a mega-project that also includes Island Cogeneration Project in Campbell River, Port Alberni Cogeneration Project, and the Georgia Strait Crossing Pipeline (GSX). In particular, PAGP cannot operate without gas from GSX, and without PAGP, GSX would not be required. Therefore, the Project Committee should also consider that in making a recommendation for or against PAGP, they are also creating the conditions of need or not-need for the GSX pipeline. Both these projects should, by this reasoning, be considered in a comprehensive review process. A recommendation to the ministers for a comprehensive review would be reasonable, albeit unusual. Some issues with the proposed Port Alberni Generation Project specifically, are these: - The greenhouse gases (GHGs) that PAGP will produce run counter to the agreements and commitments that Canada signed, at Kyoto, and most recently in August in Bonn, to reduce GHG output. While not yet constrained with regulatory limits, GHG emissions are infinitely easier to control if no more facilities that generate them are built. The Committee can put Port Alberni on the map as the first community to make a local, provincial, national and international commitment to reducing GHGs. - The economics of the project are fraught with risk. Quite apart from the capital costs of the project (and please remember, it's not just the plants in Port Alberni, but the GSX pipeline that must be built to operate PAGP), natural gas is increasingly expensive and so, therefore, will be the electricity generated from it. - Port Alberni Cogeneration (PAC) is an approved project that could be built at any time. Unless the project certificate is revoked for PAC, consideration of PAGP must assume that PAC is built and operating, and its emissions must be factored into the models for PAGP. - Local air emissions and effects on water are without question negative, and often poisonous, affecting people, wildlife, and lands all around Port Alberni. - It is against the Port Alberni Official Community Plan. - It helps to sever areas of Vancouver Island from relatively clean and cheap hydroelectricity. - It works to postpone developing green energy projects for Vancouver Island, BC, and Canada. - The handful of jobs that will be created by PAGP are not worth the environmental cost. - The vast majority of people in Port Alberni have said they don't want it. I hope the Project Committee will consider these comments, and recommend that the ministers deny the project application, or refer the project to a Stage 2 Project Review. Respectfully, CC: Stan Hagen, Minister for Sustainable Resource Management, stan.hagen.mla@leg.bc.ca Richard Neufeld, Minister for Energy and Mines, richard.neufeld.mla@leg.bc.ca Jean Crepault, Project Manager, GSX Project, CEAA, jean.crepault@ceaa.gc.ca