The Tankers Are Already Here — Before Canada Adds Supertankers, B.C. Must Demand the Truth About What We Are Breathing
What the existing Trans Mountain tanker fleet is discharging today, what another million-barrel-a-day pipeline could add tomorrow, and who should pay for the protection, monitoring and cleanup
When most people hear the words oil pipeline, they picture a steel pipe buried in the ground.
But the pipeline does not end at the shoreline.
The oil must be stored in tanks, pumped through a marine terminal and loaded onto ships. Those ships must travel through coastal waters, manoeuvre into port, wait at anchor, remain tied to a loading berth and then leave through the Salish Sea.
During much of that time, they are burning fuel.
They are discharging:
carbon dioxide;
nitrogen oxides;
sulphur oxides;
fine particulate matter;
black carbon; and
volatile organic compounds.
Some of these pollutants are inhaled by people living and working around ports and shipping routes. Some react in the atmosphere to form additional fine particles and ground-level ozone. Some return to the land, rivers, estuaries and ocean through wet and dry atmospheric deposition.
This story focuses on those atmospheric discharges and their connection to human health, freshwater, marine habitat, salmon and Southern Resident killer whales.
It is not a complete accounting of the pipeline’s greenhouse-gas footprint, spill risk, construction damage, terminal stormwater, tank-farm emissions or the consequences of eventually burning the exported oil.
Those issues matter enormously, but the air pollution from the tankers is large enough to deserve its own honest accounting.
The basic question is simple:
What are the tankers putting into our air now, what could another pipeline add, and are governments actually measuring and controlling the complete pollution load?
The existing pipeline has already changed the Salish Sea
The Trans Mountain Expansion entered commercial service on May 1, 2024. The expanded system has nominal capacity to move approximately 890,000 barrels of petroleum products per day.
During the first three months of 2025, Trans Mountain reported loading 74 vessels at Westridge Marine Terminal, including a then-record 29 vessels during March. On April 2, 2026, the company loaded its 500th Aframax tanker since the expanded system entered service. Westridge was designed to accommodate as many as 34 Aframax tankers and three barges per month. (Trans Mountain)
Even Environment and Climate Change Canada now states plainly that TMX increased Westridge’s tanker-handling capacity from approximately five to 34 tankers per month, “resulting in greater air pollution emissions.” The federal government says its pre-expansion monitoring can be used in the future to determine whether pipeline operations changed local air quality. (Canada)
That comparison should not be left sitting on a government website.
It should be performed publicly, independently and continuously.
We reconstructed the record tanker month
Veins of Life Watershed Society reconstructed tanker activity associated with Westridge during March 2025.
Trans Mountain reported 29 vessels loaded during its accounting period. Our reconstruction of Pacific Pilotage Authority movements identified 30 loaded tanker departures during the calendar month. The difference appears to result from calls whose arrival, loading and departure crossed reporting dates.
Rather than assuming a tanker stopped polluting when its main propulsion engine stopped, our screening included:
local transit;
manoeuvring;
anchorage time;
auxiliary generators;
boilers; and
time alongside the loading terminal.
We applied the U.S. Environmental Protection Agency’s established port-emissions methodology for ocean-going vessels. That methodology treats propulsion engines, auxiliary engines and boilers as separate sources and accounts for the ship’s operating mode. (Canada)
Our March 2025 screening estimate
| Pollutant | Approximate amount |
|---|---|
| Carbon dioxide — CO₂ | 6,530 tonnes |
| Nitrogen oxides — NOx | 61 tonnes |
| Sulphur dioxide — SO₂ | 4.1 tonnes |
| Fine particulate matter — PM2.5 | 1.54 tonnes |
| Black carbon | 30 kilograms |
| Combustion-related VOCs | 3.7 tonnes |
These are modelled screening estimates, not measurements taken directly from every tanker stack.
That distinction must remain clear.
But modelled does not mean imaginary. Emission inventories are routinely used by governments and ports where direct stack measurements are unavailable. The purpose is to establish a credible order of magnitude, identify the important sources and determine where direct measurements are needed.
Our reconstructed activity included approximately:
664 tanker-hours in local movement and manoeuvring;
460 tanker-hours at anchor; and
1,320 tanker-hours alongside Westridge.
The result that deserves the most public attention is this:
Approximately 71% of the CO₂ in our model came from auxiliary engines and boilers—not from the main engines moving the tankers.
A tanker sitting still is not necessarily a tanker that has stopped polluting.
Its electrical systems still require power. Pumps, ventilation, navigation equipment, safety equipment, accommodations and other systems remain in use. Boilers may be required for cargo and shipboard operations.
The federal government’s own Salish Sea shore-power study estimates that full use of at-berth control by tankers could reduce tanker CO₂ emissions at berth by approximately 51%, NOx by about 47% and sulphur oxides by about 54% in its 2027 scenario. The reductions are lower than for some other vessel classes because tanker boilers may continue operating even when auxiliary electricity is supplied from shore. (Canada)
In everyday language: about 18,000 cars for one month
Thousands of tonnes of carbon dioxide are difficult for most people to picture.
Using the U.S. EPA average of approximately 4.29 tonnes of greenhouse-gas emissions per gasoline passenger vehicle per year, our estimate of 6,530 tonnes works out to approximately:
18,000 passenger vehicles operating for one month.
That is only a scale comparison. A tanker and a passenger vehicle do not emit the same mixture of pollutants or create the same exposure pattern.
Large marine engines can emit substantial amounts of NOx and fine particles in concentrated corridors, around anchorages and beside terminal communities. Cars spread their emissions across thousands of kilometres of road.
The comparison simply helps people understand that 6,530 tonnes of CO₂ in one month is not a trivial amount. (US EPA)
And CO₂ is not the pollutant of greatest immediate concern when asking what nearby communities are breathing.
What are people actually breathing?
Fine particulate matter
PM2.5 consists of particles approximately 2.5 micrometres or smaller. These particles can travel deeply into the lungs and some components can enter the bloodstream.
Exposure is associated with respiratory and cardiovascular illness, asthma symptoms, chronic bronchitis, heart attacks, hospital admissions and premature death.
Health Canada estimates that above-background air pollution involving PM2.5, nitrogen dioxide and ozone contributed to approximately 15,300 premature deaths annually across Canada, including approximately 1,900 in British Columbia, using the population and exposure data available for that assessment.
Those national figures are not deaths attributed to tankers. They show why every avoidable increase in air pollution matters.
Health Canada found robust evidence of health effects at very low concentrations and no evidence of a population-wide threshold below which additional PM2.5, nitrogen dioxide or ozone exposure suddenly becomes harmless.
In plain English:
Below an air-quality objective does not mean risk-free. Lower pollution is still better.
Health Canada also cautions that its estimates likely understate the full health burden because not every pollutant or health effect can presently be quantified. (Canada)
Nitrogen oxides and VOCs
Nitrogen oxides are created by high-temperature fuel combustion. They contribute directly to nitrogen dioxide exposure and react with other compounds to produce ground-level ozone and secondary PM2.5.
Volatile organic compounds also participate in the chemistry that creates ozone and organic aerosols.
This means the pollution released from a ship’s stack does not remain chemically frozen in the form in which it left the engine. The atmosphere transforms it.
Black carbon
Black carbon is produced by incomplete combustion and forms part of the fine-particle mixture. It affects health, absorbs solar energy and contributes to warming.
A regional annual PM2.5 average does not automatically reveal a short, concentrated black-carbon or ultrafine-particle plume moving from a tanker toward a particular neighbourhood.
To establish that, monitoring must be close enough to the source, fast enough to detect short events and linked to wind direction, vessel identity and operating activity.
A regional monitor is not a source investigation
This is a lesson we have encountered repeatedly in our water-quality and public-health work.
A program normally answers the narrow question it was designed to answer.
A recreational-beach program measuring fecal-indicator bacteria does not automatically tell swimmers whether the sediment contains PAHs, PCBs, petroleum hydrocarbons, metals or endocrine-disrupting chemicals.
A regional PM2.5 station does not automatically tell a neighbourhood how much pollution came from the tanker that was operating beside it.
A ship’s certificate does not tell the public how many kilograms of PM2.5 or black carbon that vessel released during its port call.
An ambient result below a broad objective does not identify the source, determine the added exposure or establish that no health effect occurred.
That is the gap between monitoring conditions and investigating pollution.
And it is one of the largest gaps in the present tanker discussion.
The pollution does not stop at the shoreline
Air pollution and water pollution are often treated as separate subjects because different departments administer them.
The environment does not recognize those departmental boundaries.
Sulphur dioxide and nitrogen oxides can react with water, oxygen and other chemicals in the atmosphere. The resulting compounds can be carried back to the ground and water through rain, snow, fog, dust and dry deposition.
Environment and Climate Change Canada’s Georgia Basin–Puget Sound assessment found higher sulphur deposition near marine shipping routes and major population centres.
Of 72 freshwater lakes assessed within the airshed:
20% had a pH below 6, a level at which negative biological effects are expected; and
18% received sulphur deposition above their ecological critical loads.
The report also identified areas where sulphur and nitrogen deposition exceeded levels beyond which harmful effects may be expected in sensitive soils and ecosystems. (Canada)
Nitrogen deposited into freshwater, estuaries and coastal waters can add to nutrient loading. In systems already receiving nutrients from wastewater, agriculture, stormwater and septic sources, added nitrogen can contribute to algal growth, changes in food-web composition and oxygen depletion.
That does not mean one tanker can be blamed for the condition of a particular lake, creek or estuary.
It means atmospheric emissions are one more pressure acting on ecosystems that already receive contamination from many sources.
The atmosphere is part of the watershed.
Fresh water becomes salt water
Rain falls on roads, rooftops, industrial lands, farms, port facilities and tank farms.
It carries pollutants into ditches, storm drains, streams and rivers.
The Pacific Salmon Foundation describes stormwater as a major pathway by which oils, brake dust, tire particles, fertilizers, pesticides and other contaminants reach waterways and coastal environments. Stormwater is commonly discharged without treatment. (PSF Marine Science Program)
The VOLWS–Pacific Salmon Foundation review, Lower Fraser River Stormwater Management: Implementation Methods, Barriers and Solutions in the Metro Vancouver Region, examined the uneven regulations, municipal practices, resource limitations and implementation barriers affecting salmon habitat in the Lower Fraser.
The practical lesson was the same one we are now applying to tanker emissions:
It is better to control pollution at its source than to document it after it has entered the environment.
Stormwater, atmospheric deposition and industrial discharges eventually converge in the Fraser estuary and Salish Sea.
Salmon cross these bureaucratic boundaries during their lives. They depend on freshwater streams, estuaries, nearshore habitat and marine food webs.
Pollution in one part of that system cannot always be assigned neatly to a single dead fish, a failed salmon run or one sick whale.
That is precisely why prevention and cumulative-effects assessment are necessary.
Southern Resident killer whales face the combined result
The federal government identifies three primary threats to Southern Resident killer whales:
physical and acoustic disturbance from vessels;
reduced prey availability, particularly Chinook salmon; and
environmental contaminants. (Canada)
An expansion of tanker traffic can intersect with all three.
Noise and disturbance
Transport Canada says vessel noise and physical disturbance can interfere with the whales’ ability to find food and communicate. In 2026, Ottawa increased the required approach distance for Southern Resident killer whales to 1,000 metres and retained speed-restricted and vessel-restricted zones. (Transport Canada)
A new oil terminal serving hundreds of additional one-way tanker passages cannot be assessed as though those vessels will travel through an otherwise empty ocean.
The assessment must include:
existing commercial shipping;
Westridge tankers;
ferries;
cruise vessels;
bulk carriers;
container ships;
tugboats;
pilot vessels;
recreational traffic;
approved future port developments; and
the proposed VLCC fleet.
Prey
Southern Residents depend heavily on Chinook salmon.
Chinook depend on productive freshwater, estuarine and marine habitats and the smaller organisms beneath them in the food web.
Protecting whales while allowing pollution sources affecting salmon habitat to remain poorly measured is not a complete recovery strategy.
Contaminants
Persistent, bioaccumulative and toxic contaminants can build up in living tissue and become more concentrated as they move through the food web.
Long-lived apex predators such as killer whales are particularly vulnerable. Federal contaminant work identifies potential effects including impaired reproduction, weakened immune function and neurological harm. (Canada)
We are not claiming tanker exhaust alone caused the Southern Residents’ decline.
The evidence does not support that statement.
We are saying that an endangered population already threatened by vessel disturbance, insufficient prey and contamination should not be exposed to another major industrial shipping source without a complete, funded and enforceable cumulative-effects program.
Canada has regulations—but they do not answer every question
It would be incorrect to say oil tankers in Canadian waters are unregulated.
They are subject to the Canada Shipping Act, 2001 and the federal Vessel Pollution and Dangerous Chemicals Regulations, which incorporate important MARPOL air-pollution requirements.
The regulations address:
nitrogen-oxide engine standards;
sulphur content in marine fuel;
exhaust-gas cleaning alternatives;
crude-tanker VOC management plans;
incineration;
fuel quality and records;
air-pollution certificates; and
visible smoke. (Department of Justice Canada)
These rules have produced real improvements, particularly through reduced fuel-sulphur levels and progressively stronger NOx standards for newer engines.
But look at what they do not provide.
A valid certificate is not an emissions inventory
An air-pollution certificate tells an inspector that the vessel and its equipment meet applicable certification requirements.
It does not tell a resident:
the kilograms of NOx released during that port call;
the mass of PM2.5 discharged at anchor;
the black carbon released while manoeuvring;
the plume concentration reaching shore;
the emissions from the ship’s boilers;
the quantity of hydrocarbon vapour released while loading crude; or
the cumulative pollution from every vessel that month.
A visible-smoke rule is not PM2.5 monitoring
Canada’s regulations generally prohibit smoke darker than density number 1, but allow density number 2 for an aggregate of up to four minutes in a 30-minute period.
That may be useful for identifying obvious smoke.
It is not a direct measurement of PM2.5, ultrafine particles or black-carbon mass. (Department of Justice Canada)
Engine standards do not erase older vessels
NOx requirements become progressively stronger depending on engine date, speed and applicable emissions tier.
That means two tankers completing the same voyage can have very different NOx emissions.
The age, engine model, installed power, control equipment, operating load and maintenance condition all matter.
Counting tanker calls without identifying the vessels is therefore not enough.
Canada’s broader environmental laws also matter
The Canadian Environmental Protection Act, 1999 defines a substance as toxic for the purposes of the Act where it enters or may enter the environment in quantities, concentrations or conditions capable of harming the environment, biological diversity, the life-supporting environment or human health.
That does not mean ordinary tanker exhaust automatically constitutes a CEPA offence. It means Canada has a statutory framework for investigating and managing harmful substances and cumulative exposure conditions. (Department of Justice Canada)
The Fisheries Act prohibits unauthorized deposits of deleterious substances into water frequented by fish or places where those substances may enter such water. Section 37 provides information-gathering powers where proposed or existing activities may kill fish, damage fish habitat or result in deleterious deposits. (Department of Justice Canada)
The Species at Risk Act requires federal decision-makers issuing certain authorizations that may affect critical habitat to consider the effects, examine reasonable alternatives and require all feasible measures to minimize the impact. (Department of Justice Canada)
The Impact Assessment Act allows binding conditions requiring mitigation, follow-up and, where considered appropriate, adaptive management. (Department of Justice Canada)
These laws have teeth.
But laws do not monitor stacks, collect samples, inspect vessels, analyze sediment or issue enforcement orders by themselves.
They require:
people;
laboratories;
field equipment;
stable funding;
independent science;
political willingness; and
public reporting.
British Columbia also has authority—but not complete control
The proposed pipeline would be interprovincial, and international shipping and vessel emissions are primarily federal matters.
British Columbia cannot simply rewrite federal marine-emission rules on its own.
However, B.C. is not powerless.
Its Environmental Assessment Act allows provincial assessment certificates to include enforceable conditions, with administrative penalties and prosecution available for non-compliance. (BC Laws)
Under the Environmental Management Act, Metro Vancouver has authority to prohibit, regulate, control and prevent discharges of air contaminants within the regional district, particularly from land-based and terminal sources. (BC Laws)
British Columbia also establishes ambient objectives for PM2.5, nitrogen dioxide, sulphur dioxide and other contaminants.
But the Province itself explains that these objectives are non-statutory unless written into a regulation, permit or approval.
They are guidance for decisions—not automatically enforceable source limits and not permission to pollute up to a maximum number. (Government of British Columbia)
That distinction matters.
An ambient objective is not a vessel-specific emissions cap.
A regional average is not a terminal fence-line limit.
And neither one replaces direct source measurement.
The enforcement problem is not that no laws exist
The larger problem is fragmentation.
Transport Canada regulates ships.
Environment and Climate Change Canada deals with air pollution and toxic substances.
The Canada Energy Regulator regulates interprovincial pipelines.
DFO administers fish and fish-habitat protections.
The Impact Assessment Agency administers project conditions.
British Columbia issues provincial environmental authorizations.
Metro Vancouver regulates many regional air-contaminant sources.
Ports control lands and operating requirements.
Municipalities manage local infrastructure and stormwater.
Health agencies deal with population-health programs.
Everyone owns a piece.
That can leave no single body clearly responsible for answering the public’s most basic question:
What is the total pollution load, where did it come from, who must reduce it, and who verifies that the reduction happened?
The Government of Canada itself defines cumulative effects as environmental changes caused by multiple interactions among human activities and natural processes that accumulate across space and time. It acknowledges that an individual action may appear minor while the combined effect becomes significant. (Canada)
Yet the federal Salish Sea Marine Emission Reductions Program—created specifically to investigate cumulative marine-vessel emissions and reduction options—was completed in March 2025.
Temporary research is useful.
It is not the same thing as permanent regulation, monitoring and enforcement. (Canada)
Government capacity is being reduced while the workload grows
Environment and Climate Change Canada’s 2026–27 departmental plan identifies planned reductions of approximately:
$237 million in 2026–27;
$244 million in 2027–28;
$283 million in 2028–29; and
approximately 837 full-time-equivalent positions by 2028–29.
The plan identifies sunsetting or declining funding connected to initiatives including the Oceans Protection Plan, strengthened environmental protection and impact assessment. (Canada)
Transport Canada’s planned staffing decreases from approximately 6,434 FTEs in 2026–27 to 5,350 in 2028–29. (Transport Canada)
DFO plans spending reductions rising from approximately $54.5 million in 2026–27 to $193.8 million in 2028–29, with approximately 551 fewer FTEs anticipated by 2028–29. Budget documents say DFO intends to wind down some research and monitoring, scale back certain program capabilities and reduce formal reviews of some lower-risk projects. (Pêches et Océans Canada)
British Columbia’s 2026 budget proposes reducing the broader provincial public sector by approximately 15,000 FTEs over three years, including about 2,500 positions in the core B.C. Public Service, largely through attrition and voluntary departures. (BC Budget 2026)
These documents do not say that every lost position will be a pollution inspector, scientist or fish-habitat officer.
We should not misrepresent them.
They do establish that departments responsible for environmental assessment, monitoring, fisheries, marine safety and pollution control are being expected to operate with fewer overall people and resources while governments simultaneously promote more pipelines, ports and marine traffic.
Ottawa has also proposed more than $258 million over five years for whale protection, including a new Salish Sea noise-monitoring and management program and ongoing funding thereafter for Southern Resident killer-whale protection. That is important and should be acknowledged. (Canada)
But temporary or general program funding cannot substitute for a legally secured, project-specific, lifetime monitoring and enforcement commitment.
Other jurisdictions are going further
California requires control during the vessel visit
California’s Ocean-Going Vessels At Berth Regulation requires each regulated vessel visit to use an approved emission-control strategy for the duration of the visit, subject to defined exceptions and alternatives.
Tankers at regulated Los Angeles and Long Beach terminals became subject to the requirement in 2025. Tankers at all other regulated California terminals become subject on January 1, 2027.
California also requires vessel-visit reporting, including for vessel types not yet subject to emissions-control requirements. (California Air Resources Board)
That is a major difference in regulatory philosophy.
Canada largely asks whether the ship’s engine, fuel and certificates comply with applicable standards.
California increasingly asks:
Why should that vessel continue emitting at berth when technology can reduce the pollution?
The European Union regulates fuel intensity
FuelEU Maritime applies progressively tighter limits to the average greenhouse-gas intensity of energy used by large ships calling at European ports.
The required reduction begins at 2% in 2025 and increases to 80% by 2050.
From 2030, container and passenger ships at specified European ports must use shore power or an alternative zero-emission technology while at berth.
That obligation does not currently cover every tanker, and it should not be presented as though it does.
But Europe is regulating the emissions intensity of the energy ships use rather than relying exclusively on engine certification and voluntary port incentives. (Mobility and Transport)
Canada has already studied the solution
The federal Salish Sea shore-power study concluded that shore power or equivalent controls could materially reduce at-berth tanker emissions.
But Canada has not adopted a California-style general requirement compelling oil tankers at B.C. terminals to control their at-berth emissions on every regulated visit.
We have studied the problem.
The missing step is turning the study into enforceable source control. (Canada)
Now another million-barrel-a-day pipeline is being advanced
The proposed West Coast Oil Pipeline is in the early stages of federal review.
The official Major Projects Office description says Alberta is proposing an approximately 1,250-kilometre interprovincial pipeline, with 11 pump stations, receipt and delivery tank terminals and a marine facility at a deepwater port in southern British Columbia.
Its proposed capacity is one million barrels of crude oil per day.
The precise route and marine-terminal location remain undetermined.
The Major Projects Office is considering whether the project should be listed in the national interest under the Building Canada Act. Ottawa says it intends to give notice in the Canada Gazette by October 1, 2026 if it plans to list the project. (Canada)
The official project page says Trans Mountain Corporation, the Alberta Petroleum Marketing Commission and Pembina Pipeline Corporation would form an ownership group. Trans Mountain would design, permit, construct and operate the project.
Trans Mountain describes itself as a federal Crown corporation. (Canada)
That creates an important institutional issue.
Ottawa would have a relationship with the project through its Crown corporation while federal departments and regulators would also be responsible for assessing, authorizing, monitoring and enforcing it.
That dual role is not automatically improper.
It does make independent science, transparent decision-making and a strong firewall between commercial promotion and environmental regulation essential.
A deepwater terminal changes the vessel scale
Westridge principally accommodates partially laden Aframax tankers.
A new deepwater terminal could potentially accommodate Very Large Crude Carriers—VLCCs, commonly called supertankers.
A VLCC can generally carry approximately 1.9 million to 2.2 million barrels of crude oil. (U.S. Energy Information Administration)
At one million barrels per day, the pipeline would deliver approximately 30 million barrels during an average month.
Depending on cargo size and loading efficiency, that could mean roughly:
14 to 16 loaded VLCC departures every month.
Because each loaded departure requires an inbound ballast voyage, that represents approximately:
330 to 380 additional one-way VLCC passages every year.
Each loaded vessel could carry approximately 300 million to 350 million litres of crude oil.
Fewer vessels than Westridge does not necessarily mean a minor environmental footprint. Each VLCC would have greater installed power, larger auxiliary demand, substantial boiler loads and a much larger cargo inventory.
What the future emissions could look like
Because the terminal has not been designed and the future vessels do not yet exist, nobody can truthfully provide an exact emissions inventory.
We therefore constructed three screening scenarios.
They are not government forecasts and should not be described as predictions.
The 1.0-million-barrel case uses the official proposed throughput with lower-emission operating assumptions.
The 1.1-million and 1.2-million-barrel cases are VOLWS sensitivity tests showing what happens if throughput, vessel calls, waiting time, engine age or emissions controls differ from the best-case assumptions.
| Screening scenario | Loaded VLCCs per month | CO₂ per month | NOx per month | PM2.5 per month | Passenger-vehicle CO₂ equivalent |
|---|---|---|---|---|---|
| 1.0M bbl/day—lower-emission case | ~14 | ~2,900 t | ~12 t | ~0.7 t | ~8,100 vehicles/month |
| 1.1M bbl/day—central sensitivity | ~17 | ~5,100 t | ~32 t | ~1.2 t | ~14,300 vehicles/month |
| 1.2M bbl/day—stress sensitivity | ~19 | ~9,600 t | ~125 t | ~2.3 t | ~26,900 vehicles/month |
The large NOx range is intentional.
NOx can change dramatically depending on:
engine tier;
vessel age;
installed power;
selective catalytic reduction;
engine load;
exhaust temperature;
manoeuvring time;
anchorage time; and
whether auxiliary and boiler emissions are controlled.
A simple tanker count can therefore conceal a very large difference in pollution.
The existing tankers would not disappear
A second pipeline and terminal would not necessarily replace Westridge.
If Westridge continued operating near its March 2025 record level while the future project operated around our central sensitivity case, the combined tanker activity would screen at approximately:
11,600 tonnes of CO₂ in one month.
That is approximately the same CO₂ scale as:
32,500 passenger vehicles operating for one month.
Again, this is a carbon comparison—not a claim that tankers and cars produce identical pollution.
And the calculation remains incomplete.
It excludes:
escort tugboats;
pilot launches;
spill-response vessels;
terminal machinery;
construction equipment;
tank-farm heating and pumping;
road and rail traffic;
fugitive terminal leaks;
crude-loading vapours;
scrubber washwater;
ballast-water impacts;
the tankers’ overseas voyages;
downstream combustion of the oil; and
accidental releases.
The tanker numbers are the beginning of the environmental account—not the total.
What is not being properly recognized or dealt with
The present system still does not consistently give the public clear answers to several fundamental questions.
1. Actual vessel-by-vessel emissions
We do not receive a public record showing the measured or reconciled mass of CO₂, NOx, SOx, PM2.5, black carbon and VOCs released by each tanker during its Canadian port call.
2. At-berth pollution
Canada has studied shore power and alternative controls, but there is no California-style general requirement compelling every oil tanker at a B.C. export terminal to control auxiliary and boiler emissions during every visit.
3. Cargo-loading vapours
Combustion VOCs are not the same as hydrocarbon vapours displaced from tanks and cargo spaces while crude oil is loaded.
The public needs separate accounting for:
vapour generated;
vapour captured;
vapour recovered;
vapour destroyed;
fugitive releases;
system downtime;
bypasses; and
emergency venting.
4. Ultrafine particles and black carbon
Regional PM2.5 measurements do not automatically reveal short tanker plumes, ultrafine-particle exposure or black-carbon concentrations in nearby communities.
5. Atmospheric deposition
Ship exhaust can return to land and water, but there is no permanent tanker-specific deposition network showing how much sulphur, nitrogen, metals or combustion particulate is reaching Burrard Inlet, the Fraser estuary and other receiving environments.
6. Cumulative limits
Each vessel can comply individually while the combined airshed and ecosystem continue receiving more pollution.
Compliance with a vessel certificate is not the same thing as compliance with a cumulative environmental carrying capacity.
7. Automatic source investigation
An elevated ambient reading does not automatically produce a source investigation, vessel inspection, operational change or emissions reduction.
8. Long-term funding
Short-term studies and temporary grants can disappear while the pipeline, terminal and vessels continue operating for decades.
What B.C. should demand before one metre of new pipe is built
Interprovincial pipelines and international shipping fall largely under federal jurisdiction.
But British Columbia does not have to treat a federal project announcement as a completed environmental decision.
To the full extent of its lawful authority—and through binding federal-provincial agreements—B.C. should make its support and provincial authorizations conditional on the following requirements.
These conditions must be secured before construction, not promised after the project has become inevitable.
A. What must begin now—before route and terminal decisions are locked in
1. One cumulative assessment for the whole system
The project scope must include:
the pipeline;
pump stations;
tank farms;
terminal;
construction;
dredging or pile-driving;
stormwater and groundwater;
terminal air emissions;
tankers;
tugboats;
pilot vessels;
anchorages;
emergency-response fleets;
decommissioning; and
the cumulative interaction with Westridge and existing Salish Sea marine traffic.
The project cannot be divided into convenient pieces so that every individual component appears small.
2. A real no-project and alternatives assessment
The assessment must examine:
the no-project alternative;
alternative routes;
alternative terminal locations;
alternative cargo and vessel sizes;
alternative loading systems;
alternative throughput;
low-emission terminal designs; and
options that avoid or reduce critical-habitat exposure.
A preferred route chosen for commercial reasons should not become the environmental baseline before alternatives are independently tested.
3. A multi-year baseline beginning before land clearing
At least two complete seasonal cycles—and preferably three years—of independent baseline data should be collected before major construction begins.
The baseline must cover:
PM2.5;
ultrafine particles;
black carbon;
NO₂;
SO₂;
ozone precursors;
VOCs and selected hazardous air pollutants;
atmospheric deposition;
precipitation chemistry;
surface water;
groundwater;
stormwater;
sediment;
intertidal habitat;
salmon habitat and use;
underwater noise;
marine mammals; and
community health exposure.
The federal pre-TMX air work shows why before-and-after information matters. It should be expanded into a permanent operational system rather than treated as a completed research exercise. (Canada)
4. Indigenous-led and jointly governed monitoring
Indigenous Nations whose rights, territories and marine resources may be affected must receive durable capacity funding and a direct role in:
baseline design;
sampling;
traditional and Indigenous knowledge;
data interpretation;
compliance monitoring;
emergency planning;
enforcement referrals; and
restoration decisions.
Equity participation in a project does not remove the Crown’s duty to protect rights or eliminate the need for independent environmental oversight.
5. An independent human-health impact assessment
The assessment must examine short- and long-term exposure for communities along the pipeline, near storage terminals, beside the marine terminal and beneath the shipping plume.
It should include:
children;
older adults;
people with asthma or cardiovascular disease;
outdoor workers;
Indigenous harvesters;
lower-income communities;
cumulative exposure from existing industrial sources; and
the effects of short pollution peaks, not just annual averages.
Health authorities must participate as investigators and reviewers, not merely receive finalized modelling after the project has been approved.
B. What must be secured before construction authorization
6. A Salish Sea Pipeline and Tanker Environmental Assurance Fund
The proponent should be required to capitalize an independent, bankruptcy-remote trust before construction.
The fund should be financed through:
a substantial upfront security;
an annual inflation-indexed charge per barrel transported;
a fee for every tanker call;
additional charges for anchorage time and higher-emitting vessels; and
federal contributions supporting independent public science and enforcement.
The fund must not be controlled by the proponent.
Its governance should include affected Indigenous Nations, British Columbia, federal regulators, independent scientists, public-health expertise and community representation.
It should pay for:
baseline monitoring;
independent laboratories;
compliance audits;
public-health studies;
source investigations;
spill and pollution response;
habitat restoration;
long-term ecological monitoring;
closure; and
post-closure remediation.
The money must not lapse at the end of a government fiscal year or disappear into general revenue.
7. Financial security beyond the existing $1-billion pipeline requirement
Major oil pipelines transporting at least 250,000 barrels per day are generally subject to a $1-billion absolute-liability limit and corresponding financial-resource requirements for unintended or uncontrolled pipeline releases.
That is important, but it is not a complete lifetime assurance package for tanker emissions, terminal contamination, underwater noise, ecological monitoring, chronic pollution, closure or decades of restoration. (Canada Energy Regulator)
Financial security should be based on independently costed worst-credible scenarios, including:
a major marine spill;
shoreline oiling;
terminal contamination;
long-term sediment remediation;
fishery and harvesting losses;
habitat restoration;
emergency public-health monitoring;
insolvency;
abandonment; and
climate-driven changes in response conditions.
The amount must be inflation-indexed and reviewed regularly.
8. Binding source-control design—not voluntary promises
Before construction, project designs should be required to provide:
closed industrial drainage;
full secondary containment;
separation of clean and contaminated stormwater;
treatment before discharge;
leak detection;
automatic shutoffs;
vapour recovery;
continuous fence-line hydrocarbon monitoring;
electrified terminal equipment;
low-emission pumps;
no routine venting or flaring;
zero routine discharge of untreated industrial stormwater; and
documented plans for extreme rainfall, wildfire smoke, sea-level rise and power failure.
Source control must be engineered into the facility.
It cannot depend on future good intentions.
9. Public ownership of the environmental data
All project-funded monitoring data should be public in near-real time, including:
raw data;
validated data;
detection limits;
calibration records;
laboratory reports;
QA/QC results;
model inputs;
model code where practicable;
vessel identity;
AIS positions;
operating mode;
wind and weather;
exceedances;
equipment failures;
enforcement referrals; and
corrective actions.
The proponent should not own, delay or selectively publish the information needed to determine whether the project is causing harm.
10. A strict regulator–owner firewall
Because Trans Mountain is a federal Crown corporation and is identified as a prospective project owner, designer, permit applicant, builder and operator, the federal government must establish a clear separation between:
commercial project promotion;
shareholder interests;
environmental assessment;
scientific review;
inspection;
enforcement; and
public reporting.
The proponent must not select the final reviewers of its own work or control the independent monitoring body.
C. What must be operating before the first barrel reaches the terminal
11. Vessel-by-vessel emissions accounting
Every tanker call should produce a public emissions record containing:
vessel name and IMO number;
flag and year built;
deadweight tonnage;
main-engine and auxiliary-engine specifications;
engine tier;
control equipment;
fuel type and sulphur content;
bunker-delivery records;
time underway;
time manoeuvring;
time at anchor;
time at berth;
auxiliary and boiler fuel use;
CO₂;
NOx;
SOx;
PM2.5;
black carbon;
VOCs; and
any use or discharge from exhaust-gas cleaning systems.
This should be reconciled against AIS, pilotage, terminal and fuel records.
12. Direct measurement—not modelling alone
Models are useful, but a project of this scale should include:
periodic stack testing;
remote plume sensing;
independent fuel sampling;
portable and fixed black-carbon monitoring;
ultrafine-particle monitoring;
fence-line VOC measurement;
aircraft, vessel or mobile monitoring where warranted; and
random unannounced inspections.
Model predictions should be corrected using measured emissions from the actual fleet.
13. Mandatory at-berth emissions control
The terminal should not merely be shore-power ready.
Compatible vessels should be required to connect and use it.
Where tanker boilers or other systems cannot be electrified, the proponent should provide approved equivalent controls capable of achieving defined emission reductions.
Requirements should include:
mandatory connection time;
maximum allowable auxiliary-engine use;
controls for boiler emissions;
Tier III-equivalent NOx performance where technically achievable;
verification under low-load conditions;
public reporting of every non-connection; and
penalties that cost more than non-compliance saves.
California has already established the basic principle that regulated tanker visits must control their at-berth emissions. Canada should not approve a new terminal built to a weaker standard. (California Air Resources Board)
14. Complete cargo-vapour accounting
The terminal should continuously account for:
crude volume loaded;
vapour generated;
vapour captured;
vapour recovered;
vapour destroyed;
residual emissions;
fugitive leakage;
system downtime;
bypasses;
pressure releases; and
emergency venting.
Reported capture efficiency must be verified through direct testing—not accepted solely from equipment design claims.
15. No open-loop scrubber washwater
A project promoted as modern infrastructure should not be allowed to transfer air pollution into the ocean by discharging exhaust-gas scrubber washwater.
Ottawa has already identified scrubber washwater in Southern Resident killer-whale critical habitat as a contaminant concern and proposed progressively prohibiting the discharge. B.C. should demand a complete prohibition along the project’s tanker route and in associated anchorages and terminal waters. (Canada)
16. Just-in-time arrival and strict anchorage limits
Tankers should not arrive days early and burn fuel at anchor because a berth, cargo or terminal is not ready.
The operating plan should include:
just-in-time scheduling;
maximum anchorage durations;
escalating charges for avoidable delay;
emissions limits at anchor;
emergency exemptions only where justified;
public explanation of every extended anchorage; and
automatic operational review when delays become routine.
17. Binding underwater-noise and whale-protection limits
The project must have a cumulative noise budget—not merely voluntary participation in slowdowns.
Conditions should include:
vessel-specific underwater-noise certification;
maximum source levels;
quiet-vessel procurement standards;
speed restrictions;
whale detection;
automatic slowdowns or departure delays;
limits during important feeding periods;
tug and escort-vessel noise controls;
independent hydrophone networks;
public AIS-linked noise data; and
authority to curtail operations when protection thresholds cannot be met.
18. Automatic response and stop-work triggers
Monitoring without consequences is simply observation.
Conditions must specify what happens when data show:
elevated PM2.5 or black carbon;
unexpected VOC releases;
source-specific NO₂ or SO₂ peaks;
vapour-control failure;
untreated stormwater discharge;
contaminated sediment movement;
excessive underwater noise;
repeated whale interaction;
fish mortality;
habitat damage; or
model predictions that consistently understate measured effects.
Triggers should produce automatic action:
investigation;
source tracing;
reduced throughput;
vessel delay;
equipment shutdown;
corrective work;
independent review; or
suspension of the relevant operation.
The proponent should not be allowed to study an exceedance indefinitely while continuing unchanged operations.
D. What must continue for the full life of the project
19. A permanent independent enforcement unit
The project should fund the cost of inspections and technical support through cost-recovery fees, but the inspectors must work for and answer to government—not the company.
Ottawa must maintain sufficient independent:
Transport Canada inspectors;
ECCC enforcement officers;
DFO fish-habitat and pollution staff;
Impact Assessment Agency compliance officers;
laboratory scientists;
air-quality specialists;
toxicologists;
marine-mammal scientists; and
data analysts.
Industry should pay the project-specific regulatory costs.
The federal government must guarantee the institutional independence, staffing and legal authority.
20. Lifetime monitoring—not a five-year study
Monitoring should continue:
throughout construction;
throughout operation;
through major expansions or throughput changes;
during decommissioning; and
after closure for as long as contamination or ecological effects persist.
The post-closure term should be based on independent risk assessment, not an arbitrary date selected for financial convenience.
21. Regular independent review and tighter future standards
Every five years, an independent science panel should review:
new health evidence;
new emission-control technology;
fleet changes;
cumulative traffic;
climate conditions;
monitoring results;
habitat trends;
salmon status;
whale recovery; and
whether current limits remain protective.
Conditions should automatically tighten where better technology becomes reasonably available or evidence shows greater harm than predicted.
The project should not be grandfathered forever to the standards in place on the day it was approved.
22. A fully funded closure and restoration plan
From the first day of operation, the proponent should maintain enough protected financial security to:
dismantle facilities;
remove contaminated infrastructure;
remediate soil, groundwater and sediment;
restore shoreline and intertidal habitat;
monitor recovery;
manage abandoned equipment;
address long-term seepage; and
respond if the owner becomes insolvent.
Closure money should not depend on the final operator still being profitable decades from now.
Who should pay?
The allocation should be blunt and unmistakable.
The project owners and users should pay for:
project-specific baseline studies;
pollution-prevention technology;
shore power and equivalent controls;
terminal monitoring;
vessel reporting;
independent audits;
Indigenous and community participation;
emergency readiness;
source investigations;
corrective work;
cleanup;
ecological restoration;
compensation;
decommissioning; and
post-closure care.
These costs are part of operating an oil-export system—not charitable environmental extras.
The federal government should pay for and guarantee:
independent regulators;
independent public laboratories;
cumulative and transboundary science;
enforcement;
federal monitoring networks;
public-health coordination;
Species at Risk Act and Fisheries Act implementation;
long-term data stewardship; and
continued protection if the proponent fails, restructures or becomes insolvent.
Federal support should be permanent and statutory where possible—not dependent on a temporary grant program that expires halfway through the project’s operating life.
British Columbia and local communities should not be left paying for:
monitoring a federally promoted project;
replacing lost federal science;
emergency investigations;
pollution cleanup;
health studies;
habitat restoration;
firefighting and emergency response;
municipal infrastructure damage; or
long-term care after abandonment.
B.C. should recover its legitimate regulatory and monitoring costs from the proponent and insist that Ottawa fund the federal responsibilities that accompany a national-interest project.
There is already a precedent for demanding financial security
When Ottawa approved Roberts Bank Terminal 2, it imposed 370 legally binding environmental conditions and required a $150-million financial guarantee to help ensure money was available during the first three years of construction.
Those conditions included monitoring, wildlife protection, mitigation and long-term compliance obligations. (Canada)
A million-barrel-a-day pipeline, tank farm, oil terminal and VLCC system should not face weaker financial assurance.
In fact, it requires a much broader and longer-lasting package because the risk extends beyond construction into decades of air emissions, tanker traffic, spill exposure, underwater noise, contamination and eventual closure.
Polluter pays must mean more than cleaning up a spill
Canada’s pipeline liability regime recognizes the polluter-pays principle.
But pollution is not limited to a dramatic pipe rupture.
It also includes chronic and cumulative releases:
exhaust;
fugitive VOCs;
contaminated runoff;
deposition;
noise;
routine equipment leakage;
sediment disturbance;
habitat degradation; and
the slow accumulation of small effects over decades.
Polluter pays should therefore mean:
The industry pays to prevent the pollution, measure it, reduce it, investigate it, clean it up and restore the environment for the entire life of the project.
And where Ottawa advances the project as nationally important, the federal government must guarantee independent monitoring and enforcement instead of transferring those costs and risks to British Columbia.
The public deserves more than “the ships comply”
This story is not alleging that every tanker is violating Canadian law.
Many may be operating completely within the present rules.
That may be the most important point.
If dozens of tankers can legally discharge tonnes of NOx, tonnes of fine particulate pollution and thousands of tonnes of CO₂ into the same airshed every month, the public discussion cannot end with:
“The vessels comply.”
The next questions must be:
What is the combined pollution load?
What are nearby people breathing?
What is falling onto our watersheds and marine waters?
What is being added to salmon and killer-whale habitat?
What can be prevented?
Who is responsible for reducing it?
Who verifies the results?
Who pays for the next 50 years?
The air falls on the watershed.
The watershed drains into the Fraser.
The Fraser reaches the Salish Sea.
Salmon move between freshwater and the ocean.
Southern Resident killer whales depend on those salmon and on the health of the entire food web.
There is no environmental curtain separating the tanker stack from the water below it.
Before construction, B.C. should draw a clear line
British Columbia should tell Ottawa and the project promoters:
No baseline—no construction.
No independent monitoring—no approval.
No secured lifetime fund—no permit.
No enforceable emissions and noise limits—no first oil.
No public data—no claim of environmental safety.
The companies proposing and profiting from the pipeline should carry the project’s environmental costs.
The federal government promoting it as a national project should carry the cost and responsibility of independent regulation, science and enforcement.
British Columbia, local governments, Indigenous communities and future generations should not be handed the bill after the oil has been sold and the damage has been done.
Canada is considering moving another one million barrels of crude oil every day to the Pacific coast.
Before one metre of pipe is laid, one tank is built or one supertanker enters the Salish Sea, the protection, the monitoring, the enforcement—and the money to sustain them—must already be in place.
Our Position on Heavy Industry
VOLWS has a long history of working with heavy industry. We are not anti-industry or anti-oil. Petroleum will remain necessary while Canada develops practical alternatives, and we support modern Canadian refining that creates Canadian jobs and benefits Canadians first.
What we question is exporting large volumes of unrefined heavy crude—and the associated pollution and environmental liability—to other countries. If Canada continues extracting these resources during the energy transition, we should refine more of them here under strong environmental standards, retain the economic value here, and take responsibility for our pollution rather than leaving another country and another generation with the cleanup.
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