KM – Media & Letter Updates

Open Letter to the Business Council of British Columbia

March 1, 2016

In their op-ed of January 21st, 2016, Messrs. D’Avignon and Finlayson, respectively the CEO and Executive VP of the Business Council of British Columbia, state that it is time for a mature conversation on oil exports against the backdrop of current economic realities.

As a group of retired Professional Engineers who have spent the past four years participating in the reviews of the Trans Mountain and Northern Gateway projects, we agree with their statement.

The authors rightly point out that the world demand for energy continues to grow and that the majority of this growth will be driven by India and China. They also state that Canada does an excellent job regulating its oil and gas industry, and that if we don’t help to fill this growing demand, countries with less stringent standards will step forward and take our place.

They ask: How does the world benefit if Canada says ‘No’? It is a fair question, and one that deserves debate.

However, that’s where the mature conversation ends. Rather than addressing legitimate and sensible concerns put forth by opponents, many of whom like CPE, support development of Canada’s energy sector and economy, they resort to tired rhetoric about these projects being held ransom by a campaign of ‘misinformation’.

Perhaps their argument is that since BC already has many thousands of kilometres of pipelines and sees hundreds of oil tankers per year, the measures that are in place are ‘good enough’. This ignores the basic reality that the Trans Mountain and Northern Gateway projects alone, without the projected boom of BC’s LNG industry, represent an enormous expansion of the oil and gas industry along Canada’s west coast. Canadians are justified in their demand for a comprehensive review of these developments.

Regarding ‘misinformation’, we would like to ask the authors if they are aware that:

  • The risk analyses upon which these projects were approved contain serious and fundamental flaws. For example, the ratio of time tankers spend in enclosed channels vs. open water is, according to the proponents, simply an assumption. Yet for engineers, this knowledge is critical in estimating the frequency of major tanker spills. This may seem like a trivial detail, but it is not.       In complex engineering projects tiny errors carry tremendous consequences. Every new engineer learns the archetypal example: the Challenger space shuttle exploded because a simple rubber seal failed.
  • Disregarding the above flaws, and accepting the risk analyses at face value, the proponents acknowledge that their projects each carry a 10% probability of a major spill within a 50 year operating life. This is a spill of approximately 2,000 times the size of the spill from the Marathassa in English Bay that occurred in the summer of 2015. Do the authors feel that 10% is an acceptable level of risk? We don’t.
  • The Canadian government’s own scientists have repeatedly cast doubt that the product being transported, diluted bitumen, can be cleaned up in the event of a major marine spill. ‘Dilbit’ is not conventional crude oil and experience accumulated over decades of cleanup of crude oil do not directly apply to this product.
  • The funding structure in place to pay for spill cleanup is woefully inadequate and Canadian taxpayers will ultimately foot the bill.
  • Safer port locations exist and have been proposed numerous times. For example, locating the Northern Gateway terminal at Port Simpson would eliminate the need for supertankers to traverse more than 400 km of narrow, congested channels for each of the 11,000 trips they will make in the projected 50-year lifetime of the project. Similarly, Roberts Bank, near the Tsawwassen ferry terminal, is an established port with a clear shipping line to the open ocean. Instead, Kinder Morgan plans to send loaded tankers from a terminal and tanker facility located in a densely populated metropolitan region, Burnaby, through the Burrard Inlet. The tankers would have to pass under two busy highway bridges and a railway bridge, before reaching English Bay and finally, the open ocean. Why have alternate locations never been seriously considered? Is it because they would increase the cost of the pipelines?

The authors’ focus on ‘misinformation’ and ‘fantasy’ belies their intention to have a mature conversation about the development of our energy industry. Yes, there is a vocal and perhaps even fantastical movement that wishes to see all energy development in Canada halted overnight. Yes, a west coast port is required to ship Canada’s energy products to developing markets in Asia. We believe Canadians understand and accept this reality.

However, we also believe Canadians are rightly skeptical about how thoroughly these projects have been regulated, especially in light of recent disasters like the Mt. Polley mine dam breach, the Kalamazoo oil spill, and the Lac Megantic tragedy, where ‘world-class’ regulations very clearly failed to protect people and the environment.

We agree that it is time for a mature conversation about the reality of Canada’s oil industry. We challenge the authors to address the legitimate concerns presented by our group and many others, instead of simply dismissing opponents as being misinformed and fantastical.

Sincerely,

Brian Gunn
Spokesperson, CPE


Report from the Ministerial Panel for the Trans Mountain Expansion (TMX) Project

November 1, 2016

Ministerial Panel Full Report

CPE is mentioned in 2 places emphasizing the unacceptability of the risks of major collision spills and the possibility of collision of the tankers with the Second Narrows Railway and the Highway Bridges, and the fact that a proper risk analysis has not been done.  This evidence is important as the Ministerial Panel was submitted by the federal government and it’s approval of the KM Project and its’ order in counsel on Dec 10, 2016.


Our Letter Sent to the Prime Minister, the Ministers of Transport, Natural Resources and Environment

On December 16, 2015 we sent a letter to Prime Minister Justin Trudeau as well as the Minister for Environment and Climate Change, Catherine McKenna, the Minister of Natural Resources, James Gordon and the Minister of Transport Marc Garneau to address our concerns about where dilbit should be shipped out of along the British Columbia … [Read more…]


Concerned Professional Engineers Brief to the TMX Ministerial Panel

August 11, 2016 Burnaby – Summary

Concerned Professional Engineers (CPE) is a group of Professional Engineers with extensive experience in the planning, risk analysis, detailed design and construction of marine and materials handling systems.  We are NOT opposed to exporting oil from Canada.  We are opposed however, to the marine aspect of Kinder Morgan’s Trans Mountain Expansion (TMX):

  • The proposal for transporting diluted bitumen, from Kinder Morgan’s terminal in the Eastern Burrard Inlet to the open ocean, is based on a risk analysis produced by a reputable consultant DNV (Det Norske Veritas). We respectfully submit that this analysis is incomplete.
  • The analysis, which has not been subjected to an independent peer review, ignores the danger of Aframax tankers colliding with the Second Narrows Railway Bridge, which was shut down for four and a half months in 1979 after being hit by the Japan Erica. A loaded Aframax tanker would be five times heavier and could take the bridge right off its foundations, carrying its superstructure into the highway bridge 110 metres distance away, risking catastrophic collapse.
  • The proponent has an obligation to study the compliance of these bridges with the current Canadian Highway Bridge Code S6, which has a specific chapter on addressing vessel collisions. Of major importance to this assessment is vessel traffic, especially when tanker traffic is planned to increase significantly.
  • The major economic consequences to the region, should a tanker collide with a bridge, as well as environmental damage from a possible spill have not been taken into account.
  • DNV states that a spill of 8.25 million litres (3,000 times greater than the 2015 English Bay Marathassa spill) has a return period of 473 years. CPE equates this period to a 10 percent chance of such a spill in the 50 year operating life of the project.  This risk level is similar to that of a major earthquake hitting Southern BC during the next 50 years.  This risk is not ignored in the case of earthquakes and, similarly, must not be dismissed for tanker spills.  Engineers are tasked with designing both buildings and bridges to withstand a certain amount of force and must design to specific codes.  Today’s buildings have to be designed to withstand earthquake demands allowing for only a two percent chance that those demands will be exceeded in a 50 year period and, for important bridges like the new Port Mann, the S6 Highways Bridge Code requires the calculation of vessel collision forces allowing for only 0.5 percent exceedance in 50 years.
  • We believe that there are safer locations for an oil terminal that would not involve travel through highly populated areas.

The responsibility borne by the Panel is heavy, and it is important for panel members to understand what risks are inherent in this type of project, and to report back in an informed manner to the people who are going to make the final decision. 

Two other professional engineers share their views about Kinder Morgan TransMountain Expansion terminal being in the least safe location and offering safer alternatives. Protecting our environment – an important natural resource Like all British Columbians and Canadians we value the supernatural beauty of this province and the fact that it represents one of the last wild … [Read more…]


Learn about dilbit

What is Dilbit?   DILBIT:  BITUMEN AND CONDENSATE HAZARDS The Northern Gateway project, if implemented, will be sending the product Dilbit through a pipeline to be built between Alberta and a terminal at Kitimat, BC, for export to Asia via oil tankers. Similarly, the Trans Mountain pipeline will be transporting Dilbit between Alberta and … [Read more…]


CPE Letter of Comment to NEB regarding TMX

November, 2014

Who we are

Concerned Professional Engineers (CPE) is a group of Registered Professional Engineers. We have extensive experience in the design, operation and maintenance of resource export terminals, design of escort tugs, handling of ships and navigation. We
are not unconditionally opposed to the shipment of resources overseas, as we believe that we have an ample supply in Canada. We also believe that export of resources is a vital part of our economy and that we have been generally responsible at exporting resources in an environmentally sensitive manner. We feel nevertheless, that Canada should emphasize the export of value-added products rather than just the shipping of the raw resource.

We have examined the marine aspects of the TMX project and found that increasing their transport of Diluted Bitumen (Dilbit) from their existing terminal in Burnaby, through the straits of Georgia and Juan de Fuca to the Pacific Ocean, presents a high risk to the environment and to structures located along these routes.

Project Risk

Our main purpose of getting involved in writing this Letter of Comment on the Trans Mountain Project is to point out that the risks of an accident and a bad spill from the increased traffic are considerable. Based on Trans Mountain’s own experts’ estimations, as submitted with their TERMPOL Report 3.15 (Table 34), of November 25, 2013, there is a ten percent (10%) probability that a spill of 8.25 million litres or more will occur in a
50 year operating period, even with all the proposed mitigation strategies. This is considerably greater than the mitigated spill risk of 9% for a 5.0 million litres spill estimated for the Northern Gateway project out of Kitimat. The probability of at least one spill in 50 years increases to 19% when spills of any size are considered. CPE does not have access to the model that KM’s experts (DNV) used to predict the probability of spills. This model should be made available and a completely independent analysis of the spill risk should be carried out.

We also believe that there has not been a proper analysis of the potential for a collision of a fully loaded or an empty Aframax-type tanker with either the First or the Second Narrows bridges, particularly with the present Second Narrows railway bridge. Aframax is a medium-sized crude tanker with a dead weight tonnage (DWT) ranging between
80,000 and 120,000 Tonnes and a length of 245 metres. The regional economic consequences of bridge damage (or collapse) following a collision accident cannot be over-emphasized. The history of collisions of vessels with these bridges needs to be carefully analyzed and re-evaluated with regard to the proposed TMX traffic. This review should include the number of times the railway bridge has been knocked out of service for a considerable amount of time and the number of times that it has had to be completely replaced. We believe that when this analysis is done the risks will probably be considerably higher than those stated by Kinder Morgan’s experts.

In our opinion, an analysis as to what would happen if there is a collision of a loaded Aframax vessel with the railway bridge or the highway bridge at the Second Narrows is required. What forces would be exerted on the bridges’ structures or foundations and what would be the expected damage to these bridges? Also, would the forces exerted by the vessel in striking the foundations of the bridge be sufficient to damage or ripping a double-hulled vessel, resulting in a release of its oil cargo? It is also important to assess the risk of collision of a tanker with the superstructure of the bridges. In this regard, the document “Second Narrows Movement Restriction Area Procedures” (Vancouver Fraser Port Authority, April 2010), provides available clearances both for the highway and for the railroad bridge. It should be required that the proponent provide a detailed study of how the tankers will meet these clearances, when attached to the tugboats, assuming either normal navigation under all weather conditions or under the possibility of mechanical/control failures.

We would like to refer you to a study by Dr. Ricardo Foschi, P.Eng and Emeritus Professor of Civil Engineering at the University of British Columbia.http://www.concernedengineers.org/?p=488.  He considered these vessel collision probabilities and prepared a set of questions that need to be answered by the project proponent. This preliminary analysis, based on requirements of the Canadian Highway Bridge Design Code (CAN/CSA S6), is attached to this letter as Appendix I entitled ‘Evaluation of Risks Associated with the Kinder-Morgan Project’. The analysis shows that the probability of collision with the bridges is very much dependent on the effectiveness of the tugboat assistance in case a tanker is out of control.

We think that a detailed modelling of the interaction dynamics of the system tanker- tugboats must be shown, and that this model should be used to estimate the degree of control that the tugboats can achieve. We are aware for example, that similar studies have been carried out by the city of Seattle for tanker traffic in Puget Sound and by San Francisco for similar traffic in Northern San Francisco Bay. We find that the proponent has not offered a similarly detailed modelling of the effectiveness of tugboat aid in relation to the existing infrastructure along Burrard Inlet.

We believe that increasing Kinder Morgan (KM) tanker traffic through the heart of the Port of Vancouver should be seriously evaluated vis-à-vis other alternatives. For example, Roberts Bank Superport was built for the purpose for handling large cargo ships and we believe it would be a much safer alternative for shipping Trans Mountain’s export Dilbit. Roberts Bank is safer because it is much closer to the open ocean, and does not have the obstacle course presented by the First and Second Narrows bridges.

The question needs to be asked: why is the product not proposed to be shipped through Roberts Bank? This question needs to be asked of the Port of Vancouver as well. It also seems that restricting vessel size to Aframax class is unnecessarily constraining, when VLCC-class tankers could be used at Roberts Bank offering three times the capacity or requiring one third the number of ships. The pipeline transportation corridor to Roberts Bank could also be available along the Roberts Bank Coal Traffic rail right-of-way.
The product being shipped

The behaviour of Dilbit in seawater as has been the subject of much debate. There is no clear evidence that should a spill occur, and depending on the sea conditions, the product will stay on the surface long enough for it to be cleaned up. It can be safely said however, that cleanup costs of a Dilbit spill will be very large. The cleanup and compensation cost of $7 billion, attributed to the Exxon Valdez Alaska incident 25 years ago, may be a low approximation to the requirements for a spill in the Kinder Morgan project. It is even possible to speculate that Kinder Morgan may want the oil that is being spilled to sink, so that it is out of sight and out of mind.

The project proponent must be asked to produce scientific evidence on the behaviour of Dilbit under all sea conditions and produce a realistic clean-up response strategy. The company needs also to produce a scientific assessment of any spill consequence related to the toxicity of the product.

Liability for costIt is clear that of the owner of the tanker, not Kinder Morgan, is liable for spill cleanup and compensation costs. We believe that the funds available according to the latest estimates of the Federal Government are $1.3 billion, which would fall vastly short of cleaning up and compensation for a 8.5 million litre (or greater) spill. It is likely that the Dilbit will separate from the condensate that enables it to float, and that it will then sink and form tar balls which, over the years, will make their way to the shores of Greater Vancouver, triggering a continuous clean up and compensation mess. It is our view that the product should be upgraded in Alberta then shipped as light crude.

The liability fund estimated by the Federal Government is a long way from covering the actual costs for cleanup and compensation. In our view, Kinder Morgan should require that all the vessels that come to pick up the product should have unlimited liability insurance. If this were the case, the insurance company would do a realistic assessment of the risks and would increase the premiums. These premiums would then be added to the cost of the barrel of oil and we would see a more realistic cost of the price of oil.

We urge you to consider these matters very carefully, and thank you for allowing us the opportunity to submit a Letter of Comment on this very important project.

Yours sincerely,

Brian Gunn
Spokesperson for Concerned Professional Engineers. www.concernedengineers.org

EVALUATION OF RISKS ASSOCIATED WITH THE KINDER-MORGAN PROJECT

By: Ricardo O. Foschi, P.Eng

October 2014

  1. OIL SPILL PROBABILITIES

Kinder Morgan presents calculated return periods (in years) for oil spills of different volumes. These are given in Table 34 of their TERMPOL Report 3.15. The oil spills result from marine accidents or incidents.

By definition, the return period is an estimation of the average time elapsed between spills of a given volume. As such, approximately 50% of the spills would occur before the return period and 50% would occur after that time. Therefore, the return period is not a good statistic to communicate probability of a spill. Of importance is the probability that at least one spill, of a given volume, would occur within the operating life of the project.  The calculation of such a probability is straightforward given the return period and the operating life.

Table 1 below shows the results of this calculation, starting from the Kinder Morgan estimations.

Oil spill volume (m3) Return Periods (in years) Probability of at least one spill in 50 years

No projectProject with no mitigationsProject with all mitigations

No projectProject with no mitigationsProject with all mitigations>16,5003,0934562,3660.0160.1000.020>8,250619914730.0800.4200.100>0.0 (any)309462370.1500.6600.190

The above Table permits the following conclusions:

  • With no mitigations the probabilities of at least one oil spill in 50 years are too high. Thus, mitigations are essential and must be enforced.
  • Even with mitigations, probability of at least one oil spill in 50 years, greater than 8,250 cubic meters, is deemed to be too high (0.10 or 10%). This is comparable to the probability for a spill greater than 5,000 m3 calculated for Northern Gateway (9%). The probability for a large spill of 16,500 m3 is more tolerable (0.02 or 2%), but even a more moderate spill would cause very substantial damage.
  • Even with mitigations, there is a 19% probability of an oil spill, regardless of volume. This is also too high.
  1. COLLISION PROBABILITIES WITH SECOND NARROWS BRIDGE

The methodologies for the determination of the probability of collision of a vessel with a bridge pier are specified both in the American AASHTO Code (1991) as well as in the Canadian CSA-S6-00 (2000). Both Codes essentially contain the same provisions, differing in the system of units used in the prescribed equations. The methodology followed here agree with that specified in the Canadian Code CSA-S6-00.

This methodology has been used to evaluate the risk of collisions with several new bridges across the Fraser River:  Golden Ears, Pitt River, Port Mann and the Skytrain Canada Line.

The methodology is based on the estimation of:

PA = probability of aberrancy, or the probability that a vessel will be out of control or likely to be involved in a collision incident;

PG =  conditional, geometric probability that a vessel will collide with a pier, given that the vessel is out of control or likely to be involved in a collision.

The product   PE = PAPG  gives the probability that a collision will take place, which has to be modified according to the number N of vessels transiting per year or in any interval T. From historical accident data in US waterways, the Code gives the value  PA= 0.6 x 10-4, applicable to ships.

The geometric probability is calculated considering that the position of the ship in distress is randomly located, with a mean equal to 0.0 (the centerline of the navigation channel) and a standard deviation equal to the length  Ls of the vessel. This random position s is assumed to obey a Normal distribution.

If mitigation aids from tugs were present, then the standard deviation of the position s would be smaller. For perfect mitigation, the tugs would keep the vessel along the centerline of the channel.  In the calculations shown here it is assumed that the standard deviation could be a value  (Ls / r) , with r being a factor either 1, 2, 4 or 6. Thus, r = 6 would imply a more effective mitigation by the intervention of tugs.

The probability PE is finally corrected for the number of vessels transiting the bridge location per year (here assumed to be 600), and then for the period of operations T = 50 years.

The vessel considered is an Aframax tanker, with a length of 245m and a beam of 34m. The opening of the central span of the highway Second Narrows bridge is 350m.

Results are show in the following Table 2:

Factor r PG PE PAnnual (600 vessels/y) Pat least one collision in 50y
r = 1     (no tugs) 0.304 1.9152 x 10-5 0.0114 0.437
r = 2 0.155 9.7650 x 10-6 0.0058 0.254
r = 4 0.027 1.7010 x 10-6 0.0010 0.050
r= 6 0.004 2.5200 x 10-7 0.0002 0.008

It can be concluded, from these results, that the probability of at least one collision with the bridge, over 50 years of operation and at 600 vessels per year, must be mitigated by the use of tugs. This is essential and must be enforced. With proper and effective mitigation, it would appear that collision with the bridge could have a low probability of occurrence.

Collision with the bridge does not necessarily mean major damage or collapse of the structure, nor an oil spill. However, damage to the bridge would result in interruptions of traffic flow with associated economic consequences.  Collapse of the bridge or substantial damage could be studied, but it would require a detailed structural analysis of the bridge and its footings.

  • A more comprehensive model should be studied to relate the factor r to the tug intervention policy.
  • These results apply to the highway Second Narrows or Ironworkers Memorial bridge. The situation for the railroad bridge would be more risky, given that the channel between the bridge towers is much smaller than 350m. For this bridge it would be even more essential to provide an effective mitigation policy.

CPE Letter of Comment to NEB Regarding TMX

July 23, 2015

We are a group of Concerned Registered Professional Engineers (CPE).  We have extensive experience in the design, operation and maintenance of resource export terminals, design of escort tugs, handling of ships and navigation.  We wish to make it clear that we are not unconditionally opposed to the shipment of Canadian resources overseas, since we generally have an ample supply in Canada.

While the export of resources is a vital part of our economy, we believe that exporting must be done in an environmentally sensitive manner; safeguarding a sustainable future for next generations.  We have examined the marine aspects of the Trans Mountain Expansion (TMX) project and found that their plan to increase the transport of Diluted Bitumen (Dilbit) from their existing terminal in Burnaby, through the Port of Vancouver, the Straits of Georgia and Juan de Fuca and to the Pacific Ocean, presents a high risk to the environment and to infrastructure located along these routes.

Our purpose in writing this Letter of Comment (LOC) on the Trans Mountain Expansion Project is twofold, as described in what follows:

The risks of an accident and a bad Dilbit spill, as submitted by TMX resulting from the increased tanker traffic, are considerable. Trans Mountain’s own experts show estimations of risk associated with different spill volumes, and do so in terms of “return periods”.  These are average expected times between spills, and are generally long, as shown in their TERMPOL Report 3.15 (Table 34), of November 25, 2013.  This manner of reporting results is misleading and presents an over-optimistic picture for the general public.  In fact, the return periods shown in the TERMPOL Report are mathematically equivalent, for example, to a ten percent (10%) probability that a spill of 8.25 million or more litres will occur in a 50 year operating period, even taking into account all the proposed mitigation strategies (use of escort tugs).  This is considerably greater than the mitigated spill risk of nine percent (9%) for a spill of 5.0 million or more litres estimated for the Northern Gateway project out of Kitimat.  The TMX probability of at least one spill in 50 years increases to 19% when spills of any size are considered.  These probabilities over a 50-year operating window are clearly unacceptable. Concerned Professional Engineers (CPE) does not have access to the model that Kinder Morgan’s experts Det Norske Veritas (DNV) used to predict the probability of spills but believe that this model should be made available and a completely independent analysis of the spill risk should be carried out.

We also want to point out that there has not been an analysis done of the potential for a collision of a fully loaded or an empty Aframax-type tanker with either the First or the Second Narrows bridges, particularly with the present Second Narrows railway and highway bridges. If these bridges were to be built after implementation of the TMX project, they would have to satisfy the safety standards for vessel collision prescribed in the Canadian S6 Highway Bridge Code.  The requirements of S6 should not be disregarded because the bridges are already there.  The Aframax is a medium-sized crude tanker with a dead weight tonnage (DWT) ranging between 80,000 and 120,000 Tonnes and a length of 245 metres.  The regional economic consequences of bridge(s) damage (or collapse) following a collision accident cannot be over-emphasized; whether the collision triggers a spill or not.  The history of collisions of vessels with these bridges needs to be carefully analyzed and re-evaluated with regard to the proposed TMX traffic.  This review should include the number of times the railway bridge has been knocked out of service for a considerable amount of time and the number of times that it has had to be completely replaced.  We believe that when this analysis is done, the risks will probably be considerably higher than those stated by Kinder Morgan’s experts.

We find that the risk of collision is highly dependent on the effectiveness of tugboats.  Thus, the proponents should have presented a detailed modelling of the interaction dynamics of the system tanker-tugboats, showing the degree of control that the tugboats can achieve under different scenarios.  We are aware for example, that similar studies have been carried out by the City of Seattle for tanker traffic in Puget Sound and by San Francisco for similar traffic in Northern San Francisco Bay.  We find that the proponent’s assessment of effectiveness of tugboat assistance is based on subjective input and not on a quantitative evaluation.  As such, it falls short of the needs associated with the risk analysis for a project with high consequences.

We ask therefore, that prior to NEB deciding on whether or not to give approval to the project, they should consider the above points and demand results from corresponding studies, analyses and modelling in order to carefully review them.

As stated at the beginning of this letter, CPE believe that the export of resources is a vital part of our economy.  However, we also believe that we have to carry out this export in the safest way possible.  Allowing the TMX through Burrard Inlet from its present terminal is not the safest alternative.  There are much safer alternative ports around the Lower Mainland that can easily connect to the proposed pipeline.  They just cost more money to build.  CPE feels that the increase in safety and the decrease in risk demands that NEB carefully evaluate the risks involved, before making a recommendation to proceed with TMX as it is presently proposed.

For further detail about our assessment of risk please see our earlier October 2014 Letter of Comment to NEB shown on our website: concernedengineers.org.

Brian Gunn, Spokesperson for CPE


Kinder Morgan Intervenor Status Denied

Click here to read Letter from NEB denying CPE official intervenor status for Trans Mountain Pipeline Project [hr] Read CPE response to denial below: Friday, April 11, 2014 To Whom It May Concern: As spokesperson for CPE (Concerned Professional Engineers) I would like to appeal the decision of the NEB to decide against including our group as Intervenors. Our … [Read more…]