..my comments focus on issues NOT COVERED in “Playbook’
Discussion 4: After reviewing the full suite of proposed legislation, regulation and policy in the intentions paper, do you have anything to add or comments about gaps, additions or what be done differently and why?
In my opinion ,
1.these new regulations should include a requirement for any wannabe proponent of new oil transport facilities to include an introductory report explaining how many potentially affected communities were consulted, to show that they have communicated and gained some idea as to the likelihood of public acceptance of the proposed location of facilities…The entire exercise of a hearing is to bring something forward that is in the public/national interest..Enbridge and Kinder Morgan ‘conveniently ‘’ ignored the public input before filing their applications ..and look where that ‘got us!’ One government thrown out and ..the new Federal government has done little ..except make a few hollow promises ,so far with no results…..
The NEB,were offered these shallow proposals and had no option but to issue recommendations to government with hundreds of CONDITIONS..
These proposed BC government amendments should include some direction about searching for the best(scientifically) evaluated facilities (pipelines,tankers)LOCATIONS to ensure that ,with the best science, the proposed location will minimize the probability,and the potential of a product spill…and then these ‘nuts and bolts details’ of this proposed ‘amendment ‘ then fit nicely ..
If the ‘’ ‘best’ location issue is dealt with elsewhere..then at least direct the proponents to the appropriate legislation/regulation ! But be sure to include this location evaluation as a must…that must preclude any wannabe pipeline,tankers facilities proposals !
2. I did not see ‘bitumen’ or ‘dilbit’ included in list ?
The proposed amendments in the bill would replace existing spill response provisions in EMA with new requirements for preparing for, responding to and recovering from environmental emergencies.
… the framework for the Province to develop and implement new rules for a comprehensive spill preparedness, response and recovery regulatory regime.