Sarah C. Brown

Prince Rupert, B.C.


July 19th, 2017


Kevin Jardine, ADM, Environmental Assessment Office, Victoria, BC

sent by e-mail to


Dear Mr. Jardine:

This is an official complaint about the way the EAO is failing the public in the assessment of the Aurora LNG plant proposal on Digby Island. I contend that EAO is not meeting its commitment to the public outlined in the Substitution Agreement.


Under Requirements for a Substituted Environmental Assessment Section 4b)ii one reads BC has committed to “give the public an opportunity to participate in the environmental assessment process and provide access to records in relation to the assessment, to enable the meaningful participation of the public”.

As a long-term resident of Dodge Cove, with concerns over the human health impacts that the Aurora LNG project would bring to Dodge Cove and Prince Rupert due to proximity, I would say that I have studied more information, accessed the BCEAO website, and read the posted documents much more than the average individual.

Even as well-informed as I have attempted to be, there have been and are still many deterring factors that I have noticed during this EA review. The website has been extremely difficult to navigate and to access information from, even not working many times. Information on the website has often not been able to be shared with anyone else, denying a pathway for the public to share the documents and review them easily.

The public has not been kept informed of timeline changes, was poorly notified of the suspension of the review, and of the lifting of the suspension. Also, it is unacceptable that the affected communities and other interested public parties are denied timeline extensions to review the information being put forward and are kept on strict dates (in which there is no possible way all the relevant material could be reviewed) yet CNOOC-Nexen can have extensions whenever they wish to.

The commenting public is ignored. As someone who has put forth comments, I have been dismayed at the lack of response from CNOOC-Nexen. It has taken much time to research both the project and the possible human health impacts, and then to have insipid responses from the proponent such as:

“Aurora LNG appreciates and acknowledges your concerns. Aurora LNG is undergoing a thorough, independent environmental assessment process, led by the BC Environmental Assessment Office (EAO) and involving both provincial and federal regulators, to examine all potentially adverse effects of the project and determine ways to avoid or lessen potential effects.”

How can a response such as this even be accepted by the BCEAO as a resolution to a valid concern? This response has been used widely by CNOOC-Nexen, and it shows clearly the lack of respect that both the EA review process and CNOOC-Nexen have for the commenting public.

And, finally the “Working Group” review process was secret and being hidden from the public, until June 13.  The Working Group Round 1 comments and responses posted with other additional information were published online only AFTER a formal complaint was publicly made by Josette Weir regarding the EA review and substitution process.

Now when I look to see if ROUND 2 is available yet for the public to see, it is NOT! Yet the Round 2 Working Group submissions were finalized by June 30. It seems to be a large time lag between most information and when it is posted on the BCEAO website. This time lag is unacceptable. How is the public to stay informed if the release of information has lengthy delays? How is the public to know if CNOOC-Nexen responded on the date they were supposed to?

As CNOOC-NEXEN has missed providing information at crucial dates at many different times, I am unclear as to why the EA review is still going forward.

This runaround has been part of the entire process – and it is beyond frustrating that the information is not being made available in a timely manner, in an easily accessible manner, and it is ludicrous that these games are being played by the proponent, and allowed and accepted by the BCEAO.

A fair evaluation of the Aurora LNG project has not happened, and will not happen with the EA review being biased and skewed to helping CNOOC-Nexen “fly under the radar”. The public has been denied access to information and adequate response time as part of the Substitution Agreement.

Many of the areas highlighted by Josette Weir, and requests to enhance transparancy, have not been met. I would like to see those requests met.

Why should members of the public have to monitor and ensure that the BCEAO is following up on the commitments made in the substitution process?

I would like to see the Round 2 Working Group comments posted online, and I would like to see CNOOC-Nexen’s responses to those comments (of which they were to reply by July 17).


I look forward to your reply to my letter and to the concerns I have set forth here.

The EA review for the CNOOC-Nexen Aurora LNG project should not be going forward.


Concerned Canadian Citizen and Resident of Dodge Cove

Sarah C. Brown




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