Government of Canada


To all high federal and provincial decision makers from Su Li

Submitted By: Su Li December 16, 2016

From Su Li, Former expert and senior environmental assessment engineer for 30 projects big budgets invested by the World Bank, Asian Development Bank, China government. 5 years buying petroleum products as buyers mandate in Vancouver, Canada.


Dear Sir/Madam, Expert Panel, Ministers, Prime Minister Justin Trudeau, Governor of Canada:
December 14 2016

Thank you very much to give me the opportunity to share my extensive knowledge and experiences to improve Environmental Assessment (EA), National Natural Resources Management, Sustainable Development Plan, or Ecological economic development plan for Canada.

I have the following urgent recommendations to improve EA(environmental assessment) , environmental protection and sustainable development , harmony and balance for economy , environment and social well beings based on my 20 years global EA conduct experiences, 10 years good university education majored in 4 different departments and 4 different universities i.e. Geography, Macro economy, crude oil and LNG purchase globally, Natural Resource Management, Biology, Ecology, Ecological Economy, Water and Biomass Resource Management as one of the best environmental assessment engineers in Canada and the world who have conducted around 30 mega projects successfully.

Environment is the only product we Canada can sell globally to other countries and ourselves between provinces from my eye because we do not have much world wide high technology and scientific industries to sell, like USA, Russian, Germany, Japan, China, France. Therefore we have to keep the best quality of our environment for ourselves, our children and great grand children. This means that we have to keep our blue sky , oceans , lakes, groundwater, surface waters, fresh and clean air, high quality agriculture, fishery, tourism , mining and robust and long term available natural resources for our sustainable development.

It is obviously that EA for some major mega projects have been failed to safeguard our environment because all of them have got approved by the consultant firms hired and paid by proponents, and all provincial and federal government authorities such as CEAA, and all expert departments such as Natural Resource , Fisheries, Transportation, Parks, Eduction and all provincial government authorities, however.

It is also clear that none political parties have enough knowledge and wisdom to lead Canada to a correct , stable, sustainable and long term prosperity track because low level , low efficiency, serious environmental pollution and ecological degradation mega pipelines, LNGs, mining, Site C and other big polluters and green house gas emitters have been approved weekly, monthly and yearly by their EAs. EA has been lost its basic function to safeguard our Canada. My suggestions to stop not working well EAs are as following :

1. EA should be conducted by registered, managed , qualified, accountable and independent specialists and firms who are paid by tax payers through governments (and proponent), but not hired and paid by proponents directly. Proponents must pay EA fees to governments , and then governments hire and pay good merit and moral standard EA conductors and their firms, just like governments pay teachers and their schools, doctors and their hospitals, polices and police 2 departments, using pubic and proponents tax payers money. The purpose of doing this is to avoid EA specialists and their firms sell their knowledge and approve bad wrong proposals in order to get paid and hired by the proponents as their employers directly.

If so, EA conductors and their firms do not have to approve all bad proposals to sell their scientific and environmental knowledge and ethical conscious , and public interests, our precious land and ocean, and they can cancel environmental badly proposals based on their pure scientific and engineering knowledge without any fear of losing jobs and firms to favour the employers / proponents because EA conductors and their firms are secured financially by tax payers through government funding as non profit organizations.

2. EA conductors must have minimum master degree education graduated from top good universities globally. It takes 6 to 7 years to get a master degree. It takes me 10 years to get 2 master degrees. Their names should be listed in the EA as an index and they should communicate with public by answering technical questions frequently like once a week. If serious misuse knowledge and cheat public is found, they will face EA society and legal challenge. Anyway , they shall be responsible for the EA results as authors of EA.

3. EA conductors themselves as individuals and their firms or companies should be responsible for any and all technical problems and obligations existing in the EA they have written legally. At the same time, CEAA and all government authorities and regulators are only liable or take minor responsibility for any and all technical problems existing in EA. It is not good for governments are involved into or sued and protested against too often by people especially Aboriginal groups. Governments shall have higher positions and deserve respect from people.

4. There are different levels of EA conductors and environmental firms who are registered , managed, qualified to conductor EA such as level A, level B , level C , level D. Different level projects can be conducted by different levels EA conductors and environmental firms, for instance, for small project whose budget is less than 1 million investment, local , and minor adverse effects on environment and its site is far away from ecological sensitive zones , EA conductors and firms of level D can conduct these kinds of EA. For medium project whose budge is from1 million to 10 millions, EA conductors and their firms of level C can conduct these kinds of EA. For big projects whose budgets are from 10 millions to 100 millions , EA conductors and firms of level B can conduct these kinds of EA. For giant projects whose budgets are from 100 millions to 10 billions and more, EA conductors and firms of level A , the highest level of EA, can conduct these kinds of projects.

5. The requirements of different level of EA conductors and their firms are different, the higher, the stricter. All EA conductors must have minimum 6 years master degree post secondary education. All EA firms shall have a professional team composed of expert , senior and junior engineer/biologist/economist/engineering analysis specialists etc. Each city can have 1 to 10 EA firms of level D, level C. Each province can have 1 to 10 EA firms of level B and level A. Canada can have 1 to 5 EA firms of level A.

6. All people who are living, studying and working in Canada, not only Aboriginal people , are public. All public should have the same rights to participate EA consultant process in all stages of EA especially in early stage of all projects simply because the adverse environmental effects can effect all residents in Canada. It is not good for Aboriginal people have so much higher rights than all the others because these generation of aboriginal people have enjoyed too much 2 more benefits than all other groups already. Their great parents, not themselves, were the owners and caregivers of the land and the oceans. Now Canada is the home for all groups! Actually God/Jesus is the owner of Canada and He asks us take care of the land, animals ,plants, environment properly, not destroy and pollute our own homes. Human beings have no rights to over exploit all of our natural resources on the surface and underground of our land and ocean. In other words, all animals, plants, rivers , lakes and ocean , stones and environment have the same rights to exist because they are made by the same creator God/Jesus.

7. EA for each project is not able to be conducted for any regional planning function or purpose. Our country, each province and each watershed should have ts own environmental plan or economy, environment and social well beings harmony development plan to guide all political parties and decision makers. I suggest we learn from China to make a 5 or 4 years economy and environment and social well beings harmony development plan. This long term plan can guide all decision makers better jobs to lead our country.

8. For a region such as BC north, and other major development zones where many industrial projects are going to happen, a total environmental capacity cumulative environmental assessment is needed to be done in 2017.

9. For each province and Canada, I am not sure whether we have an ecological economic planning department or not. The economic planning department is above all each specific department and works as an assistant for prime minister. If not, I would suggest an ecological economy department shall be established as soon as possible to lead Canada into global economy and find the best positions/sectors to sell our products and environment sustainably and globally for long term at least 100 years period benefits.

10. The purpose for this department is to guide government fulfil election promises and obligations to protect Mother Earth, the only home for all 7 billions human beings and countless numbers of wild lives who should live together harmonization with each other and with environment. The patten or structure of our current economy has to be changed to be more greener, less carbon, less pollution, high energy efficiency, more recycles and reuses, less relying on traditional dirty oil sands selling to USA, and less digging out liquified natural gas (LNG)and sell LNG to Asian, coal and all the other fossil fuel sectors, high technology, high level services and tourism, forest, fishery and agriculture.

10. Canada need study all the possibilities and feasibility of the best way to use our own crude oil locally inside Alberta, not moving them to USA and other markets outside Canada. At least one benefit w can see is that the refined gasoline from our own oil sands in Alberta can be used and sold to our own Canadian market. It is very bad and foolish that we sell low value , low price crude oil from Alberta and polluted our own rivers, lakes, ocean and mountains to USA by pipelines or trains , and then we buy much higher prices of refined petroleum products from USA . I do think that we can and we have to refine the Alberta bitumen crude oil locally and sell them to meet our own Canadian market requirements.

11. All political parities should STOP fighting to gain power and mislead 30 millions people. We must put public interests before each party's personal interest and avoid country financial bankruptcy like Grace , Span , Italy and other European countries and a broken E U.

12. CEAA shall not be the only review authority to review EA and approve it . Each EA needs 3 many independent reviewers who are not governments, and who are not Aboriginal groups, and who can review and vote to either approve or disapprove this EA. The selection of independent EA reviewers shall base on her/his academic, moral and ethical merits, 3 references from peers , 5 years EA conductor experiences , rather than give too much higher priorities to just Aboriginal people because Canada is the home for all 30 millions people, not just for First Nations NOW.

13. I do not think it is a good idea that CEAA as the authority of Federal government should be the owner or responsible party to be sued by many aboriginal groups for its wrongly approved EA. Government shall have its authority and honour and deserve respect by its own people, rather than sued very often and lost its honour to be involved into too many tensions with Aboriginal and public groups. Compared with many hard working, lower level and grassroots class colourful groups such as Chinese, black , Philippines , East European and South America groups Canadians who are the real builders, labours of our country as railway labours, nurses and home helpers, construction workers and so on Aboriginal groups have been enjoying too much benefits or over represented already. It seems that only 2% of the current population in BC is aboriginal people, but the voice from the 2% of aboriginal people are very much louder than its demography proportion . Well, as we all know and agree that a fair government shall think about all its people especially the 98% of its people' interests and gain their trusts.

14. Canada must keep its highest standard of environment, and EA shall and must have its basic and minimum function to safeguard our environment , which means EA should and has to stop and cancel all serious pollution and ecological degradation , green house gas emitters mega fossil fuel projects such as Pacific Northwest Liquified Natural Gas project, Kinder Morgan Pipeline Expansion Project, Site C, etc, and adjust the Environmental Assessment Act 2012 and 2016 to meet new era and globalization green era. All fossil fuel LNGs and pipelines and crude oil shall be banned or very carefully limited developed in the future to avoid destroying and suicide sacrificing our own land , ocean, and environment , the only product we can sell globally.

15. Canada is very painful to transform economy pattern to be more greener, more healthier, more environmental friendly , but we have to change and accept the pains and make adjustment for economy structure, and the sooner the better.

16. In order to have a better sustainable prosperity future for all Canadians, Canada must have a long term 50 or 100 years plan for harmonizing economy , social and environment sustainable development . This plan is a guide for all political parties in power , and it will lead Canada for a long long time future to avoid elected parties in power repeat the same wrong dirty and short sight and suicide development pattern. As we have seen that Liberal party Prime Minister Mr Justin Trudeau has noting new to lead our economy but just repeat the same wrong environmental badly economy policy with Conservative Prime Minister Steven Harper.

17. Stop saying and use military troops to fight against environmental protesters.

18. Promote and increase funding to financially support independent EA conductors and their firms and independent EA reviewers, All level EA firms , EA reviewers, and let public participate into EA as early as possible to avoid lost trusts from people. It is a common sense that whoever get people's trusts and hearts, whoever have a better and longer period time of governments. 4

19. Let all ministers , Prime Minister rethink its wrong leaderships to approve and promote too many wrong, serious pollution and ecological degradation mega projects which will hurt our Mother Nature and all people and our great grand kids significantly. History and our grand children will blame us because we have over exploited all natural resources and have left a serious polluted land and water for which they can not survive.

20. Let us pray God/Jesus and our 30 millions Canadian peoples forgiveness, wisdom to protect all high level decision makers hearts from significantly environmental badly approvals for so many mega projects. These high level decision makers are prime minister Mr. Justin Trudeau, all relevant ministers, CEAA , Provincial ministers, premiers , all government expert EA reviewers, and all EA conductors hired and paid by the proponents.

21. The 36 billions investment Patronas or Pacific Northwest Natural Gas project in BC must be stopped because the following reasons:
21.1: the project proposal does not have any economic and market analysis. It is really very weird that this kind bad quality proposal can be approved and can fool all our provincial and federal government reviewers and experts, and all minister decision makers, except me.

21.2: The market demand information from the project proposal, media and government are wrong and misleading public since 2012 to now. The global economy is very slow to recovery from recession. The market of Asian demand for LNG is going down and almost full because other big LNG sellers such as USA, Russian, Australia , Iran, African countries, OPEC countries have been there many years and good relationships with key buyers such as China have been established. In 2012 , USA LNG Pacific coast exporters had to burn all LNG because of weak and full domestic and global demand. As we know that after the natural gas is dig out from underground, it can not be put back , and it has to be burned to keep union jobs and keep its going on production. In summer of 2014, Russian has signed a 30 years LNG sell and buy contract with China. Japan's economy is recovering quite slowly. The purchase ability of other countries in Pacific Rim is very limited. Patronas, the Malaysia state owned oil company is just a middle man.

21.3: Our CIF prices of LNG from Lelu Island, BC to Asian ports are much higher than that of LNG's from Russian. Therefore it does not make sense for Asian buyers such as China, Japan, Korea, Taiwan, Thailand to buy our much expensive LNG. Patronas , the state owned oil company of Malaysia, is just a middle buyer, not the end buyers of our BC and Canada LNG at all.

21.4: Our knowledge about LNG production , its unit price and its adverse environmental effects are very limited and hided by the EA conductor and the proponent purposely. The project should not at the Lelu Island and the Flora Bank because it will destroy the Mouth of Skeena River ecosystem. As a result of its 5 years construction and 30 years production, BC people does not have much salmon fish to eat and fishery industry will disappear. The risks of earth quack , Tsunami, and other natural and human being factors disasters are not mentioned at all in its EA. The project must not locate at Lelu Island and the mouth of Skeena River, the second biggest river in BC.

21.5. The significant adverse effects of the fracturing LNG wells in the up stream lake basins which is around 2500 km away from the pacific marine export facility is minimized and hided by the tricky proponent intentionally because the proponent has divided the mega 36 billions investment project into 3 different project i.e. The Pacific Northwest LNG marine export project, Prince Rupert Gas Transmission project, LNG wells project . One of the biggest adverse environmental effect for these 3 parts mega project is the toxic chemicals injected into the wells which will pollute our ground waters,5 surface rivers, and soils and plants, and animals through 10 times accumulation food chains into human beings , and result in cancer , deformity and other health diseases for people and wild lives who live along the Skeena River corridor.

21.6 It is not worth to dig out and sell 2 trillions cubic feet natural gas just to get around 2000 full time jobs in its 30 years on going phase. The cost of cleaning polluted underground water, rivers and lakes, soils are much higher than millions tax paid by Petronas. It takes 10,000 years to let polluted groundwater purified naturally. The cost to clean brown soils is very high. The net gain ecologically is much less than net loss. It is not a fair and good trade at all.

Thank for your time and reading. Love from Su Li.

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