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    Informed Comment

    Angus Matthews
    Mountains of plastic from failed synthetic playing fields aren't being recycled.
    EARLY IN AUGUST Early in August the Greater Victoria School District replaced the prematurely failed artificial turf playing field at Oak Bay High. Initially it’s hard to understand why synthetic fields are required, especially when you consider the surface is composed of 12.7 tonnes of petroleum-based turf carpet with 40 tonnes of tiny thermoplastic elastomer pellets spread on top.
    Can 52 tonnes of plastic possibly be better than a real grass field?
    Upon closer examination it becomes apparent these fake fields are actually essential to the all-weather, all-season needs of burgeoning local sports programs. In addition to use by school students, Bays United Football Club has 1,600 enthusiastic local participants age five to sixty who use this particular field for over 2,000 hours each year. Natural fields simply could not withstand this intensity of use.
    If one is prepared to accept that premise, there is an additional factor that is truly unacceptable. These fields have short lifespans and must be replaced every 8 to 10 years.
    In addition to the Oak Bay High field, the City of Victoria is replacing the worn-out synthetic field at Topaz Park next year. These two local fields will be added to 750 other end-of-life fields that are replaced each year in North America. This represents a mountain of carpet. There is no recycling facility on this continent.

    The scrapped, prematurely-failed playing field carpet at Oak Bay High. (Photo by Angus Matthews) 
    This is where the “don’t ask, don’t tell” part comes in. The School District and the City have either not asked or won’t tell where and how the carpet is actually being recycled. (The pellets can be reused.) The manufacturer that replaced the failed Oak Bay High field on warranty reports that they transfer the turf to a Vancouver company who ships it to Asia for recycling. The recycling company apparently provides a certificate that seems to satisfy the School District. But there is no real information about a location, process, or facility where the recycling takes place. No address, no photos, no proud evidence of having done the environmentally responsible thing. It’s not even clear what country the facility may be located in. They have variously stated China, the Philippines or Malaysia. How can our school board and city council condone shipping discarded plastic turf thousands of kilometres across the Pacific to become an unknown burden in a developing country?
    Europe also has a huge problem managing synthetic turf. Zembla TV, a Netherlands-based investigative journalism program, exposed the synthetic turf industry’s dirty big secret. In a 2018 documentary, their team followed truckloads of synthetic turf to giant, unregulated, turf mountain stockpiles instead of the promised recycling facilities. There is only one known recycling facility for synthetic turf and its located in Denmark, not across the Pacific.
    The Synthetic Turf Council is the industry advocacy and standards organization. In their 2015 report entitled “Removal, Recovery, Reuse and Recycling of Synthetic Turf,” it states, “In fact, when compared to the $30-60,000 cost of landfilling an 80,000 square foot sports field, it is unlikely that the cost of transporting the synthetic turf and/or infill farther than 200 miles will be considered feasible. Therefore, it will be important to investigate all of the reuse, recycling, and power generation options in the region.”
    The CRD’s Hartland landfill may be the only responsible disposal site in this particular case. For the future there is another option. Before buying another plastic field, tell—don’t ask—the synthetic turf industry to resolve their disgraceful lapse in environmental responsibility.
    Angus Matthews is a retired college administrator who discovered plastics from the Oak Bay High field in nearby Bowker Creek in October 2019.

    Pam Madoff
    June 16
    Victoria City staff are challenging Old Town planning principles and policies. Is that opening the door for more aggressive proposals like those submitted for the Northern Junk Properties?
    ON JUNE 11th, 2020 Victoria City Council considered an application for the redevelopment of the 1860’s buildings, commonly known as the Northern Junk Properties, on Wharf Street, south of the Johnson Street Bridge. The proposal would see four storeys added to each of the one-storey heritage buildings. This is not an approach that is supported by the adopted standards for heritage restoration and rehabilitation where the goal is to showcase the authenticity of heritage buildings. Nor is this approach supported in the City’s 2019 “Old Town Design Guidelines.” 

    Artist's rendering of Reliance Properties proposal for the Northern Junk Properties, which City council recently declined to send to a public hearing
    City staff, in supporting the application, stated that: “The current Official Community Plan moves away from taking an ‘archival’ approach to heritage within Old Town and sets out a vision to create a living and breathing Old Town, where buildings, old and new, are occupied, vibrant and are actively contributing to the liveability and well being of the community as a whole.’” 
    This statement suggests that prior to the current Official Community Plan being adopted in 2012, projects that had been developed in Old Town, over many decades, had not achieved these goals while, at the same time, respecting and responding to the principles related to heritage conservation and rehabilitation. 
    This is a very puzzling conclusion since Victoria’s Old Town is considered one of the most vibrant, desirable, diverse and attractive areas of the city where people are able to live, work and recreate. In addition, it enjoys an international reputation for the quality of its heritage buildings and their sensitive rehabilitation—all achieved while respecting and responding to the principles associated with heritage preservation, rehabilitation and adaptive reuse. 
    Over many years, often at times when few, if any, residential units were being built in downtown Victoria, housing projects were consistently being developed, through the conversion of heritage buildings, or infill developments, in Old Town. These units range from non-profit housing to seniors’ housing to apartments and condominiums. Not only do these buildings provide housing on their upper floors but their main floor spaces house retail, restaurant or entertainment venues, all contributing to the vitality and liveability of the neighbourhood. In addition, they were developed in compliance with City policies. 
    The fact that the Northern Junk buildings have sat in a derelict state for an unprecedented period of time was also used as an impetus to move the proposal forward. Factually this is not correct as prior to the City developing heritage policies, incentives, etc, dating back as far as the 1970s, there were many buildings in Old Town that had sat under-utilized for many decades. Supported and encouraged by the City’s commitment to its architectural heritage, one by one, we saw new life being brought to these buildings. 

    Reliance Properties drawings of the existing 1860 buildings on the site
    The Northern Junk buildings, part of a long-held portfolio of properties owned by one family, would likely have been rehabilitated many years ago, if they had been made available for sale earlier. When the properties were made available for sale, circa 2008, the first site to be redeveloped was the Morley’s Soda Works building located in Waddington Alley. Purchased by Le Fevre and Company at the then market rate, it was in a state of serious dilapidation with its roof in a state of collapse and trees growing up through the building. It was in a more deteriorated condition than the Northern Junk buildings. Yet Morley’s was rehabilitated and redeveloped into housing by this for-profit developer, with a modest one-storey roof top addition added, barely visible from its land-locked location. 
    Jon Stovell, the president of Reliance Properties, the current owner of the Northern Junk properties, expressed surprise and frustration when Council referred the current application back to staff, rather than advancing it to a Public Hearing. The instruction from Council was to bring the proposal more in line with the “Design Guidelines for Old Town.” What are the factors that have led to this frustration? A lack of clarity on the part of City Council and the Planning Department? A lack of vision on the part of the developer in terms of what would constitute an appropriate and welcomed development of the site? A lack of clarity on whether, or not, the City-owned lands to the north of the site would be made available to the developer? 
    One only has to leaf through some of the proposals brought forward by Reliance to come to the conclusion that a vision is lacking. A proposal that included the City-owned land resulted in a development comprised of 126,000 square feet. The current proposal, excluding the City lands, amounts to 44,434 square feet. Another concept saw a 12-storey tower (where 5 storeys is the maximum permitted ) constructed on the City lands. All of this begs the question, how much is enough to make the project economically viable? 
    The question that is also being asked is why are we seeing the Old Town planning principles and policies challenged in such dramatic ways recently. Other than the controversial 1989 development of the Eaton Centre projects in Old Town, both new construction and rehabilitation, have moved forward successfully over many decades. Some have attributed these new challenges to Victoria being identified as ripe for development for non-local companies. Could it be that the more aggressive approach brought to land use issues in Vancouver, for example, has made its way across the water? Could it be that the confrontational, and challenging, style that has seen success in Vancouver is being tested here? Could it be that City Council and the Planning Department have not provided clear guidance, supported existing planning principles and pointed out that Victoria has a successful formula, and an enviable track record, in supporting developments that “enhance the city and create a living and breathing Old Town where buildings, old and new, are occupied, vibrant and are actively contributing to the liveability and well being of the community as a whole.” 
    As a community activist, Pam Madoff was elected to Victoria City Council in 1993. She served for 25 years, advocating for quality architecture and urban planning, arts and culture and heritage restoration and rehabilitation.   She continues to do all of these things—without having to sit through Council meetings.

    Michael McEvoy
    The Office of the Information and Privacy Commissioner has released its report on the extent to which public bodies are meeting the requirements of Section 71 of the Freedom of Information and Protection of Privacy Act. The text below has been excerpted from that report. There's a link to the report at the bottom of this page.
    IT IS OFTEN SAID that information is the oxygen of democracy. To that end, we desperately need a hyperbaric chamber that will boost our access to information systems in a way that improves the accountability of public bodies.
    Public institutions work hard to fulfil the legal obligations under the Freedom of Information and Protection of Privacy Act (FIPPA). I also know that, at times, they face challenges in doing so. The recent onset of COVID-19 is one of those challenges. And yet the pandemic itself is a good illustration of why access to information is so important. The public want to understand how their institutions are responding to the crisis, and ultimately hold those institutions accountable for their actions.
    So how can government work to ensure an effective and efficient access to information system? One way is to get ahead of the issue by not waiting for citizens to ask for records. This is especially the case where certain types of records are frequently requested. Public bodies can save themselves and the public time by proactively disclosing these records in a deliberate and obvious manner. Proactive disclosure is especially relevant during times like the current COVID- 19 pandemic.
    This idea of proactive disclosure is more than just a helpful suggestion or a best practice. It is a legal obligation under the Freedom of Information and Protection of Privacy Act (FIPPA).
    FIPPA was amended in 2011 to require public bodies to create categories of records that are proactively disclosed to the public. Both creating such categories and clearly communicating their existence to the public are critical components of meeting this statutory obligation.
    The question posed by this investigation report is, “What have public bodies done to make good on this obligation?” In some cases, progress has been made. In other instances, not much. In general, much more needs to be done.
    This report follows several other proactive disclosure reports from my office that explained both the necessity and the means for public bodies to be open and transparent. This report makes a fuller accounting of what public bodies are actually doing, providing a clearer roadmap for future action. I hope all public bodies will find it to be of assistance.
    Michael McEvoy is the Information and Privacy Commissioner for BC. The full Investigation Report on Section 71 is below: IR 20-01 S. 71 report June Final.pdf

    Michelle Connolly
    BC's minister of forests refers to forests as "feedstock." Why does he use an agricultural term to describe a forest?

    A new logging road under construction in the Inland Rainforest (Photo by Taylor Roades)
    IN Nineteen Eighty-Four, George Orwell describes a dystopian society in which language is used to control people. In Orwell’s fictional world, vocabulary is constrained and new words are created in order to simplify and manipulate people’s understanding of the world around them. Orwell suggested that the well-known connection between language and worldview could also be used to manage human behaviour.
    Not having worked in industrial forestry, it was only three years ago that I started hearing the word “fibre” used instead of “forest” with confusing frequency. This word appears on industry and government websites and it is used regularly by timber company representatives. Last week, BC Minister of Forests Doug Donaldson described the lands he is in charge of as “feedstock” in my community newspaper. One could be forgiven for thinking that the timber industry, with the Province’s help, is attempting to replace the notion of a forest—and everything that word means —with vague abstractions.
    The term fibre conjures up Metamucil, while feedstock summons the mental image of food for livestock. Why are government and industry employing these euphemisms, rather than just saying forest? The purpose is two-fold: to change how we view these complex living systems and to prevent us from acting to defend them.
    If forests can be rebranded as stands of consumable objects (which the terms fibre and feedstock achieve), then the work of obtaining social license to destroy them has already been done. If an ecosystem is merely feedstock for a pellet plant, what on Earth else would you do with it? If a tree falls in a fibre, no one will hear it because it doesn’t exist.
    Natural forests, including those that have burned or are full of decay fungi, provide food and medicines and mitigate floods. Forests also store and sequester carbon in soil and plant tissues, and old forests are particularly good at this. Beetle-killed forests provide critical structures for wildlife.
    The founding belief of modern forest management—that natural forests are a commodity—is among the root causes of declining ecosystem health in B.C. Under this belief system, old growth is in the way of plantations that can provide a predictable flow of wood and revenue. Burned or beetle-killed forests are waste. Paired with corporate control over public lands, the conceit that people can and should manage complex ecosystems has led us to where we are today.
    Emerging research confirms that BC’s productive old-growth forest is all but gone. Companies are being awarded licenses to cut down remaining primary forests to feed pellet plants. The Council of Forest Industries, whose member companies have levelled most of the economically valuable old growth on the coast and in the interior, are demanding that the province set aside the remainder in a “working forest landbase” (read: make available for logging), according to their Smart Future report. 
    As a part of their ongoing efforts to ensure continued access to BC’s last primary forests, those in power are trying to reduce these ecosystems to objects so that the public won’t fight for them. We will not abide lies of omission that obscure the truth of what natural forests are and we won’t stop defending them. Natural forests will always be more than fibre or feedstock; and in nature, there is no such thing as waste.
    Michelle Connolly, MSc, Conservation North, Prince George

    Michelle Connolly surveys a clearcut in the Inland Rainforest. Old growth cedars in the interior are often considered “waste” by the forestry sector. (Photo by Mary Booth)

    Hilary Thomson
    Newly planted vegetables at Duck Creek Farm
    AS THE GROWING SEASON RAMPS UP IN BC, it’s abundantly clear that this year will challenge farmers and food suppliers in a multitude of ways. The effects of COVID-19 will likely continue to ripple through our food systems for months, especially in urban areas where food supply chains tend to be longer and more complex. To get to our tables, many products go from farm to processing plant to large retailers; what happens when any one of those links is disadvantaged by the current pandemic?
    In Canada, farmers currently have to make tough decisions because it is difficult or impossible for them to access the labour pool of temporary foreign workers that they rely on to cultivate and harvest many of their crops. Farther afield, some countries are considering limiting their exports of certain key crops. According to Bloomberg News (March 25 2020), Kazakhstan—an important global exporter of wheat—just banned exports of the product; in a similar vein, Vietnam has put a hold on new export contracts for rice. These are just two examples of the ways that COVID-19 is stressing the food system that we all depend upon.
    I am an optimist at heart, and I have a lot of faith in the ability of our local and global community to adapt to the challenges that we will see this year. The Canadian federal and provincial governments have been acting quickly and decisively to ensure that all food supply related jobs are seen as essential services and supported as such. That said, it would be short sighted in the extreme if we didn’t consider the various ways that COVID-19 will continue to affect our food systems even once we have managed to “flatten the curve.”
    I am a farmer and writer on Salt Spring Island; the responses that I’m seeing from small farmers on the island make me optimistic that with some careful planning and creative adaptations, small farmers will be able to fill some of the gaps in our local food supply.
    Small farmers here face a different set of challenges than industrial growers. Many supply directly to restaurants, which is currently not an option. They also rely more heavily on sales outlets like farmers markets, which may be temporarily closed or have greatly reduced traffic. Here on Salt Spring, as in many other small BC towns, tourism is an important part of the economy and usually plays a significant role in keeping small farmers and artisans in business.
    Farmers now have to find alternate sources of income to ensure the survival of their business. Many are starting a CSA program this year, or expanding existing ones: Community Supported Agriculture is a sales model in which people pay upfront for a weekly share of farm produce—the influx of money at the start of the growing season provides a guaranteed income for the farmer, and the customer benefits from a consistent supply of fresh local produce all season long. Duck Creek Farm on Salt Spring has expanded their CSA from 22 to 80 members, and may continue to accept new members if their crops do well. Down the road, the Hastings House Country Hotel farm—which usually provides organic vegetables for the hotel restaurant—is considering starting a CSA to share their produce with local consumers while the hotel is closed.
    Online programs also offer a valuable sales outlet that many farmers (and consumers) are making use of for the first time. SPUD.ca, for example, is a BC and Alberta based business that curates local, organic food directly from producers; customers put in an online order and the food is delivered to their door. SPUD, like most other food delivery services, is currently experiencing an unprecedented amount of business.
    On Vancouver Island, the Cowichan Online Farmers Market, which delivers produce to Duncan and Victoria, saw a dramatic increase in orders in late March—so much so that they are hiring employees and expanding their business model (The Tyee, April 9 2020).
    On Salt Spring, the website Local Line is being used for the first time by a plethora of local farmers. The website is designed to help farmers market their produce directly to consumers: they input their available inventory, and customers can order online with an option for contactless pickup or delivery.
    These are just a handful of examples of existing delivery programs that provide a direct connection between farmers and consumers. None are new, but all are experiencing a massive surge of popularity as their services help maintain the essential connection between people and food, in this case local food.
    As well as working to increase access to local food right now, many farmers on Salt Spring are thinking about how to increase food security in the near future. Duck Creek Farm, for example, has plans to increase their fall and winter storage crops, such as beets and carrots. They are also making plans to save seeds this year for the first time, with the expectation that seeds will be either scarcer or more expensive next year.
    Increased government funding is also helping support growers in their work. Salt Spring Island Community Services has secured enough funding for additional staff to expand their one-acre farm plot, which provides fresh fruits and vegetables for the local food bank. The food bank currently serves about 100 people a week, and the expectation is that that number will rise dramatically this year as people who are prevented from working due to COVID-19 struggle to make ends meet.
    As of right now, we are all reacting as best we can to the COVID-19 crisis. The challenges are far from over, but we are already starting to see the potential seeds of lasting change as people from every industry, government department and the community put their heads together to respond and adapt. I’m optimistic that our collective response will be not only reactive, but also proactive. This is not the first time that the world has been rocked by a global crisis, and nor will it be the last. We have an opportunity to build lasting connections that can strengthen our communities against future challenges as well.
    First and foremost on my mind is the ever-present and growing challenge of climate change. Much like the current pandemic, climate change transcends borders and has the potential to greatly impact our global food supply chains. The effects of climate change—which include increasingly severe droughts, increased risk of flooding, and more changeable weather patterns, to name just a few—already affect growers around the world and those effects are only going to increase. If we take one thing from this pandemic, let it be the remembrance that local food security is important for the long-term resilience of our communities as the effects of climate change threaten food supplies in years to come.
    COVID-19 has sparked a growing support for farmers as we remember the importance of the service they provide: whatever is happening in the world, we all need to eat. Increased funding and more active consumer support for local growers are two trends that I see right now that make me optimistic for the future of food in Canada. Seeing farmers work hard to fill any gaps in our local food system, to save seeds for next year and to diversify their business models is also an inspiration. This pandemic is unquestionably disrupting many lives for the worse, but it also seems to be galvanizing actions that can benefit our communities in the long run if we continue to appreciate their value.
    Hilary Thomson is a farmer and writer based on Salt Spring Island. When not digging in the dirt, she and her partner can be found traveling the Pacific Coast by sailboat. Her work can be found online at 48 North Magazine, Waterborne Magazine and Bootsnall Travel Website.

    William Pearce
    In light of new global conditions, Canada's federal government needs to rethink its commitment to build the Trans Mountain Expansion Project
    NEW FACTS HAVE EMERGED since the NEB approved the Trans Mountain Expansion Project (TMX) on May 29, 2016 which make it likely that an expanded pipeline will not be needed or will ever be used, providing compelling reasons why the federal government should push the pause button on its construction.
    There are three pipeline projects which will address Alberta’s need for pipeline capacity. The first is Enbridge’s Line 3 and additional mainline optimizations which will soon add 450,000 bbl/day. The next pipeline to be completed will be Keystone which will add another 830,000 barrels per day (bbl/day). And finally there is TMX which will add 690,000 bbl/day.
    On March 31 Premier Kenny announced Alberta would take a $1.5 billion equity stake in Keystone and provide it with a $6 billion loan guarantee to help finance the constructions costs. He stated: “We are hopeful the Trans Mountain Expansion will get done. This is our insurance policy.” In other words, he wants to ensure the Keystone is built so that if TMX is not built for any reason, Alberta producers will have their needed pipeline capacity with the Keystone.
    When the federal government decided to buy Trans Mountain and the rights to build TMX there was considerable doubt Keystone would ever be completed. The landscape has changed so much since then that premier Kenny and his government felt confident that Alberta tax dollars would be well spent to provide Keystone a financial backing that will likely guarantee completion of its construction.
    This leaves the question as to whether TMX will be needed, because if Keystone is the “insurance” for a TMX failure it is also true that if Keystone is built and built before TMX is completed, as presently scheduled, TMX will not be necessary.
    This was the conclusion of a June 2019 Report of an Evaluation of the TMX project conducted by Dr Thomas Gunton and Dr Chris Joseph of SFU. Using the Canadian Association of Petroleum Producers (CAPP) 2018 supply forecast and an “under construction” forecast based on projects that were under construction at the time of writing the report, Gunton and Joseph concluded that the construction of TMX along with the other two mentioned pipelines would create significant surplus pipeline capacity.
    In particular they concluded that a combination of Enbridge expansions and the Keystone pipeline would accommodate demand until 2035 emphasizing “there is no likely scenario” in which building both Keystone and TMX would be required before 2035.
    They went further to say that there is considerable uncertainty regarding future oil markets and oil production and that stronger climate change policies to meet our Paris commitments and new fuel regulations that would impact heavy oil demand would likely result in future oil production being lower than the CAPP estimate and that the Enbridge expansions may alone be sufficient to meet Western Canada production needs.
    That being the case it would be an irresponsible use of taxpayer‘s money to commence construction on a $12.6 billion project for which there may be no need. The federal government should stop construction now and wait and see if Keystone proceeds to completion, as most people now expect will happen notwithstanding legal hurdles that have to be overcome. To postpone the commencement of construction will not affect the ability of Alberta producers to get their product to market given the considerable extra capacity that will be provided by the Enbridge Line 3 and related projects.
    If Keystone does proceed to completion, TMX can then be shelved most likely for all time. If on the other hand in the next six months Keystone is stopped in its tracks the federal government could commence construction after doing its due diligence to ensure the pipeline is still needed and will definitely be used.
    When Gunton and Joseph concluded that Enbridge expansions alone might be sufficient to meet western producer’s needs it was before the COVID-19 pandemic. We are now realizing that patterns of human behaviour may never return to the pre-COVID “normal”, and that permanently changed patterns will lower demand for oil to much lower levels than was predicted before the crisis. Lower demand will naturally affect the amount of oil that will be produced in the oil patch.
    Lower demand for oil during COVID has had a material impact on the price of oil apart from the Saudi/Russia price war impact which saw the price go slightly below $5/bbl at one point. As this is written, which is post oil war, the price of Western Canadian Select (the benchmark of diluted bitumen produced out of the oil sands) went briefly into negative territory. The past month the price has been largely below $10. The price in Asia would be lower still because of the higher transportation costs. Experts are saying that even when we recover from the virus we may see oil priced at $20. This in turn will greatly affect oil production from the oil sands and bring into question the need for any of the three major pipeline projects.   
    All of these developments make it a real possibility that even in the long run the Enbridge expansions alone will be sufficient to meet producer needs. And if that proves to be the case TMX would have to be shelved even if Keystone never proceeds to completion.
    But let us also consider the possibility that Keystone is not built but the Enbridge expansions don’t begin to meet producer needs. Due diligence would still require the feds to assess whether, if the TMX was constructed, there would be a market for Alberta oil to justify its construction. The feds must not only be satisfied there will be a market for Alberta heavy oil but that it can be sold at a profit over the long term. Current prices will not cover the cost of production and transportation. They are not sustainable for any length of time.
    Gunton and Joseph estimated the toll costs of the TMX at $10.78/bbl based on a projected construction cost of $9.3 billion. Since the federal acquisition of Trans Mountain, construction cost estimates have skyrocketed to $12.6 billion, which would take the toll cost to $14.60/bbl($10.43US).
    It is hard to find information on shipping costs from Canada to Asia but assuming the tanker is a Very Large Crude Carrier (VLCC) the cost of shipping oil from the United States to North Asia is currently around $5US which happens to be $1.20 more than the cost of  transporting a barrel from the Middle East to North Asia. I would imagine this might be indicative as to what the costs are for Canadian shipments to North Asia.
    As to production costs, the Canadian Energy Research Institute (CERI) in its July 2019 report calculates the plant gate cost of crude bitumen for greenfield steam-assisted gravity drainage (SAGD) projects  to be $40.61 ($28.72US). Costs for mining and upgrading projects are higher. To transport bitumen to Asia, there is an additional cost to transport the bitumen to Edmonton (where the TMX commences) and to blend it with  diluents to allow the product to be piped through the TMX and then a shipping cost is required to get it across the Pacific. And this would only be done if they received a price on a sustained basis that would leave producers with a reasonable profit.
    For new projects, the Alberta government has estimated the cost of production for SAGD projects to be $50 to $80/bbl. Tech Corporation recently walked away from its proposed Frontier project citing as one of its reasons the need for oil to be $75 US. One can quickly see that Alberta producers would need a price that would be multiples of the estimated $20 post COVID-19 price. This is a pretty high bar in a world which is awash in oil with a diminishing demand for oil as we transition away from fossil fuels.
    A further problem lies with the fact that oil producers have made commitments to Trans Mountain to pay tolls to pay for the initial estimate of $7.4 b in construction costs for the TMX, but they have not made any commitment to pay for tolls to cover the estimated $12.6 billion in costs. Nor is it likely they ever will give their OK until they have the confidence the price of oil will go back to its old heights and stay there.
    This leaves the federal government in the dilemma of whether to subsidize the $5.2 billion difference which might be political suicide with a public that is seriously worried about the GHG fallout of an expanded oil sand production and the negative impact on Canada’s ability to meet Paris commitments. Even if the feds decided to subsidize the $5.2 billion difference with tolls appropriate for a $7.4 billion project Western Producers still need much higher oil prices to make their operations economically viable.
    Trans Mountain was touted as being needed to provide Alberta with access to the Asian market. One must first determine whether Asian countries want Alberta’s heavy oil when they have as their main source Middle East light crude which is a better quality oil which is cheaper to produce, cheaper to transport to Asia, and cheaper to refine. What we must ask ourselves is, given the fact Canadian producers have always had access to the Asia market with the ability to ship their heavy oil via the existing Trans Mountain pipeline, why are they not using it more than they have? Perhaps it might have to do with the fact there is little demand in Asia for Alberta’s heavy oil.
    David Huntley, a professor emeritus in physics at Simon Fraser University has been monitoring tanker traffic from Burnaby’s Westbridge Terminal for years and told Briony Penn, a writer for Focus magazine, in September 2019, that only 20 crude oil tankers have left Westbridge Terminal for China since 2014 and that most of the tankers have been headed for California. To that I would add that even though oil producers have made commitments to use 80 percent of the TMX capacity once built, no contracts have so far been signed with Asian buyers.
    As to the California market, based on 2017 data, only 3.4 percent of California’s foreign crude imports came from Canada. That same year, half of the state’s imports came from Saudi Arabia, Ecuador and Columbia which can all produce at far lower costs than Alberta.
    The bottom line is that the construction of TMX may not translate into significant sales in  Pacific markets. The evidence so far demonstrates there is very little proven interest in Alberta’s more expensive heavy oil. Further, there is considerable doubt that future oil prices will ever reach a level where it would be economic for Western Canada producers to use TMX. The feds should insist on seeing evidence of buyer contracts and foreseeable sustainable oil prices going forward before giving the green light to construction.
    In summary, it would be irresponsible for the federal government to ignore the changing landscape as outlined and proceed with construction with a project that will never be used if Keystone is completed. At the very least, TMX must be postponed to see what happens to Keystone. If Keystone is scrapped it would be irresponsible of the federal government not to exercise due diligence to ensure that not only is there a need for TMX given Enbridge expansions, but there would be a sustainable market for Alberta oil in the Pacific if TMX is built.
    William Pearce is a retired lawyer formerly employed with the BC Ministry of Attorney General. He has had a lifetime interest in environmental and global issues and is president of the Victoria chapter of the World Federalist Movement of Canada.

    Dorothy Field
    OVER THE LAST MONTHS, mayor and council, in an effort to speed up re-zoning regulations, have entered on a path that bypasses neighbourhood Land Use Committees. This is, as they see it, more efficient, and saves months of haggling with neighbours over up-zoning. It focuses on densifying “corridors,” arterial roads, rather than the health of neighbourhoods as a whole. Emphasis on these corridors sees "small urban villages" in terms of business rather than community connection and aspiration. As a community association board member, I've sat at the table while City bureaucrats tell us what they've decided rather than opening up back and forth conversations. There is much talk about “vibrant” processes and community engagement from local government. In the end, it is top down and the engagement appears to be merely window dressing.The thing is, it isn't just land use committees that are being side-lined, it is we, Victoria's citizens and residents.   All of us understand the pressures to create innovative ways to increase density, but in the process, we feel our interests, our vision, and our ideas bypassed as the City's processes unfold. Victoria is a lovely and livable city, a tourist destination, a place where many people aspire to live. However, the current push from the City seems bent on destroying what makes Victoria special. The City itself has become our official and prime development corporation. Empty Downtown towers are not a draw. Upscale condos on the former Truth Centre property are the waste of an uncommon opportunity to create a shared green space which might have been used to create "amenities" for people—a cultural centre, a nature park, or a combination of such ideas. Might the City have listened to the many people who grieved the loss of the wonderful old trees and the park-like space? Might we have talked about how to buy the property and turn it into a people place? Unfortunately, under the present process, visionary ideas will be shut down before they have a chance to be heard.   In this pandemic time, when we are all preoccupied with staying home and staying safe, I fear what City council might allow to slip through, all in the guise of progressive development. Victoria residents are full of vital ideas for how we want our city to adapt. We need to slow down and hear each other out. We do not need to decimate Land Use Committees which may indeed prolong our processes but may also give rise to ideas that are intrinsic to the spirit of our communities. They also keep citizens in the loop and allow us to have a crucial and integral part in Victoria's future.   In recent times, we've seen major developments approved, developments that are in opposition to Official Community Plans, through the use of amendments to community plans. Thus we whittle away citizens' interest and commitment to taking ownership of our neighbourhoods. I am quite sure that Mayor Helps and council want what is best for the city. If many of us are distressed by some of what’s coming down the pike, we need opportunities to talk about it, not a swift by-pass. Without that, we foster a disengaged citizenry which may play out in apathy or real anger. Neither is to be desired. Mayor and council need to remember that it is we, the people, not the developers, who have to live with their decisions.

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