Joint Review -- Enbridge Northern Gateway Project -- CommentsSubmitted by: Mary MacDonald, , British ColumbiaSent by Express Post (Canada Post) to National Energy Board Joint Review Panel, Calgary ADDate: August 31, 2010

My comments are included below in bold italics in response to the specific issue beingaddressed,

DRAFT LIST OF ISSUES

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Need for the Proposed Project

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C”Is there a need for the Project?-D

- by whom exactly? Oil companies? Corporate investors overseas? Major ba)’f1s? or.First Nations in the impacted traditional territorities? Local community membeys? BritishColumbians? It is unclear what this question means or to whom it applies. Clacrificationneeded so Canadians can provide fuller comment & response.Potential Impacts of the Proposed Project

- Aboriginal interests; commercial interests; landowners and land use.This list does not go far enough in terms of looking at potential impacts both short term &long term — other impacts will be felt in the communities in close proximity to theproposed project and throughout British Columbia (due to oil tankers being introduced tothe north coast for the first time ever). In addition, impacts include future direction ofCanadian economy and cultural impacts along the route (to all community members), andthese impacts should be looked at & considered both in short term and long term.

Environmental Effects

- What are the potential effects on environment & social economic matters?What is entirely unclear here in this draft list of issues is the extent to which provincial(BC) and municipal/regional district government offices are going to be involved in thisreview. What should be set out clearly here -- and open to public comment in advance --

are the following:

1. What exact provincial, municipal & regional district offices & departments will beparticipating in their review?2. What are the exact issues that these specific offices/departments will each look at?What will be the scope of their considerations?3. Will the federal government appointed Joint Review Panel be bound by theirdeterminations on the particular issues under their jurisdictional mandate &consideration?

It is important to receive public review & comment on the foregoing to determine if thescope & structure of this hearing process is adequate with respect to particular issuesunder provincial & municipal jurisdiction & responsibility.Examples include: water quality (provincial - Ministry of Environment); drinking water forCity of Prince George from Nechako River-fed aquifer system (City of Prince George &

Province of BC) & related human health issues (Province of BC - Ministry of Environment& Ministry of Health)

The considerations here should also be included to encompass potential effects onhuman health.

Financial Regulation

Is the proposed method of financing appropriate?

Based on what? What are the guidelines being used by the JRP to determine whether ornot the financing method is appropriate? These guidelines should be clearly explained tothe public so we can comment more fully. This wording is very vague & difficult toprovide full response to. Without guidelines & further clarification about what this wordmeans, “appropriate” is a highly subjective word.

Also it is important that the full details around the financing of the project be disclosed tothe public so the public can comment

Design, Construction, Operation

Is the applicants consultation program for the project adequate?

Has it been fully open and transparent? Have all details of who has been paid for what(consultation, advertising & other aspects of consultation leading up the hearings) beenfully disclosed to the public?

Is the design of the proposed facilities suitable?

“Suitable” for what? Suitable is a highly subjective word and open to one’s owninterpretation & biases. It needs to be set out more clearly what will define suitability andin what context The test should be are they suitable given the environmental, socialeconomic, human health, Aboriginal rights and other considerations under review (andthese considerations should extend from the oil sands to the travel route for the oiltankers that would result from this project).

Safety, Mitigation, Prevention

What safety measures are in place to protect people & the environment?

A secondary issue is: are the safety measures adequate?

Are the proposed risk assessment, mitigation & prevention measures & programs appropriate forthe design, construction, operation & abandonment of the proposed facilities?

The question should rather be: are the risk assessment, mitigation and preventionmeasures and programs adequate to guarantee that safety and well-being of people & theenvironment will not at all be negatively impacted or jeopardized in both the short-termand long-term (long-term being the entire duration that this pipeline infrastructure wouldremain in place & including the duration of any residual implications and impact from thisproject in the future)

In addition, “abandonment” does not seem at all fining given the scope of this project -- if itis to be abandoned, where does that leave future generations? Cleaning up a rustinginfrastructure that our generation saw fit to leave in place?

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The track record of the proponent should also be considered in the review -- what hasbeen the proponent’s track record with respect to public safety & environmental issues inother geographic areas particular with respect to aging infrastructure? Does theproponent’s track record merit public trust in the geographic areas to be impacted forlong-term well-being and safety of environment and people? (which factoring in the oiltanker issue - which definitely needs to be addressed by this panel -- includes all of BritishColumbia & arguably, all of Canada).

Are the proposed plans & measures for emergency preparedness & response appropriate?

the question should be are they adequate to guarantee that the safety and well-being ofpeople & the environment will not at all be negatively impacted or jeopardized in both theshofl-term and long-term (long-term being the entire duration that this pipelineinfrastructure would remain in place & including the full duration of any residualimplications and impact from this project in the future)

GENERAL COMMENT ON ALL OF THE FOREGOING COMMENTS I HAVE MADE(INCLUDING ENVIRONMENTAL. SOCIAL ECONOMIC & HEALTH ISSUES): This projectneeds to be looked at & considered by the Panel in the context of seven generations fromnow, not merely the potential impact on the current generation.

In addition, the resulting expansion of the oil sands (and all the potential health,environmental & social economic consequences) & the resulting oil tanker traffic & travel(and all the potential health, environmental & social economic consequences) would alsoneed to be looked at rigorously by the JRP to ensure thorough & rigorous review of thisproject. The pipeline cannot be considered in isolation as it would not exist in isolationbut rather, is tied closely to oil sands expansion & oil tanker traveL Those issues alsoneed to be considered.

TERMS OF REFERENCE

Part I - Scope of the Project

The project includes the construction, operation, decommissioning & abandonment of thefollowing components;

Abandonment of the project is not ok - what about future generations? Do we simplyleave them with this rusting major infrastructure across the landscape to deal with? Howcan we know now what the longterm full effects of doing that would be?

GENERAL COMMENT ABOUT TERMS OF REFERENCE: The resulting expansion of the oilsands (and all the potential health, environmental & social economic consequences) & theresulting oil tanker traffic & travel (and all the potential health, environmental & socialeconomic consequences) would also need to be looked at rigorously by the JRP to ensurethorough & rigorous review of this project. The pipeline cannot be considered in isolationas it would not exist in isolation but rather, is tied closely to oil sands expansion & oiltanker traveL Those issues also need to be considered.

Any addition modifications or decommissioning and abandonment activities would be subject tofuture examination under the National Energy Baord Act and consequently under the CanadianEnvironmental Assessment Act as appropriate. Therefore, at this time, the proponent will berequired to examine these activities in a broad context only.

The foregoing is NOT ACCEPTA BLE. A major aspect of this proposed project is theIongterm impacts (for future generations) & it is not an adequate review to not considerthose longterm aspects fully also. In looking at & considering this project, the public

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needs to know clearly what the long term plans on the part of tbe proponent would be &what the long term potential environmenta4 social economic & health issues would ba

In fact, I would go so far as to say that a major reason for people opposing this projectwould be long term concerns so for the panel to not address these issues thoroughly andvigorously at this time would be a major shortcoming in the review process and will not atall inspire the confidence of the public in this process.

ADDITIONAL INFORMATION NORTHERN GATEWAY SHOULD BE REQUIRED TO FILE:

Information about the long term plans (to address the foregoing concerns), specifics offinancing (sources, contracts, details) for the project and all details of money spent duringconsultation process (amounts, location & who was paid). If they are not able to providedetails of oil sands expansion & oil tanker traffic, these issues should be fully consideredby the panel regardless.

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