Editor’s Note: This is part of a series of posts focused on environmental humanities and public engagement. These posts emerged from a workshop held at Memorial University of Newfoundland’s Nexus Centre for Humanities and Social Science Research in May 2018 called, “Environmental Humanities in the Public Realm.” Click here to read the entire series.
Humanities and social science research are relevant to public policy debates concerning environmental issues. This includes historical research. What role historical research should play or how it should be used in environmental public policy debates, however, needs further consideration from scholars, policy experts, and community activists. Should environmental history research be informed by contemporary environmental politics? To what extent can we look at the past for indicators of future actions, events, or outcomes? Should environmental history strive for a form of objectivity and impartiality from contemporary politics? Is this even possible?
Environmental history has had a complicated relationship with environmental advocacy.[1] The origins of this sub-discipline of history in North America are rooted in the emergence of the modern environmental movement of the late twentieth century. Activism concerning environmental issues inspired historians to explore the reciprocal historical relationships among people and the rest of nature. Over the past forty years, the field of environmental history has changed and arguably moved away from its roots in environmentalism.[2] Historians have grown more reluctant to draw immediate connections between their environmental research and environment advocacy.
Still, history can usefully inform environmental policy and there appears to be a need for historical analysis in the case in Canadian oil pipeline politics. As Imre Szeman recently wrote, “Over the past decade, pipelines have entered political discussion and debate as never before, becoming one of the most visible points of social conflict over infrastructure and logistics.”[3] Indeed, he correctly highlights the degree to which political conflict over oil pipelines in Canada has emerged as a national concern with global implications. Szeman, however, errs in identifying this as a recent phenomenon: “Until recently, pipelines have not played a role in politics in large part because they were, on the whole, as socially invisible as they were physically distant and out of sight, neither encountered by the public in daily activity nor featured in their social imaginaries.”[4] While, as he writes, “Pipelines were never meant to be involved in politics,” the construction, operation, maintenance, and regulation of oil pipelines in Canada has always been directly implicated in politics. The scale and character of those politics have changed and historical analysis can explain some of those changes.
Historical scholarship can provide knowledge of past practice, experiences, and legacies of oil pipeline development in Canada. The legacies of more than sixty years of long-distance oil pipeline development have an influence on contemporary decision-making and politics. For instance, historical analysis can contextualize the recent conflict among the provincial governments of BC and Alberta, the Canadian government, environmental and Indigenous activists, and Kinder Morgan over the twinning of the Trans Mountain Pipeline. The legacies of pipeline construction and regulation can also help to explain why the Canadian government approved the proposed twinning of the Trans Mountain Pipeline and the replacement and expansion of Enbridge’s Line 3 pipeline.[5] Historical research can also provide insight into the performance of Canada’s long-distance oil pipelines and some of their environmental effects.
My own current research on the history of Canada’s system of long-distance oil pipelines shows some of the ways in which environmental history scholarship can intersect with the public realm and be mobilized in public policy debates. It also reveals some of the challenges that such public engagement poses for academic research in the environmental humanities and social sciences.
What is Canada’s Record of Oil Pipeline Spills?
I started my research on the history long-distance oil pipelines in Canada in 2011 with a seemingly simple historical question: What is Canada’s record of oil pipeline spills? In April of that year, Plains Midstream Canada, a major liquid hydrocarbon pipeline company, suffered a massive onshore oil spill on the NPS 20 Rainbow Pipeline in northern Alberta. A crack in a weld sleeve resulted in the release of approximately 4.5 million litres of crude oil into the surrounding muskeg environment both on and off the right-of-way. The conclusion to the Energy Resources Conservation Board (ERCB) investigation into the pipeline failure found:
- “Plains failed to fully assess the history of the pipeline, failed to identify the risks posed by the application of Type B sleeves used for corrosion repair, and did not have measures in place to monitor and inspect the repairs.
- Plains failed to have adequate practices in place for backfill placement and compaction for excavated pipeline sections where Type B sleeve repairs were present and for unique soils conditions such as muskeg. The ERCB concluded that inadequate backfill and compaction likely contributed to stresses on the circumferential fillet weld that failed.
- The excessive size of the release resulted from failure to have proper leak detection alarm response procedures in place, lack of operator training, and lack of supervisory oversight and involvement in decisions to restart the pipeline after a leak detection shutdown.”[6]
The conclusions were damning.
In the immediate aftermath of the spill, Alberta’s environment minister, Rob Renner, told reporters “sure there are incidents from time to time, but I would put our record up against any other.”[7] The trouble was that Canada’s record of oil pipeline spills was not easy to find. How many oil pipeline spills had occurred in Alberta and the rest of Canada? How often did such pipeline failures occur? What caused these incidents? None of this basic information about the historical record of oil pipelines was immediately available.
My research began with a survey of publicly available online data on pipeline failures and other incidents from the ERCB and the National Energy Board (NEB). ERCB (now Alberta Energy Regulator) is responsible for regulating all pipelines within the borders of the province of Alberta, Canada’s largest oil and gas producer. NEB regulates all oil and gas pipelines that cross international and interprovincial borders. In 2011, both respective regulators published information about pipeline incidents on their websites but did so in a manner that made it difficult to export and compile the data. Pipeline incident data was included in annual reports and field inspection reports, typically published as PDFs that covered a period of time back to 1990. I extracted as much information from these reports as possible to construct a record of pipeline incidents. I also looked to the historical newspaper record. Digitized newspaper archives allowed me to search for keyword terms including, “oil spill,” “pipeline spill,” “oil leak,” and “pipeline leak” to see if there was a deeper history of onshore oil pipeline spills than what was available in the online reporting of ERCB and NEB. The newspaper archive included evidence of oil pipeline spills dating back to the 1950s but could not provide a comprehensive record of oil pipeline spills in Canada.
Nevertheless, the results were revealing. Canada did indeed have a record of oil pipeline spills for almost the entire history of the construction and operation of long distance oil pipelines. Data from ERCB reports indicated that between 1990 and 2005, the province of Alberta suffered 4,769 pipeline releases of hydrocarbon liquids (mainly crude oil and synthetic crude oil). The more recent past suggested the continuation of oil pipeline spills in the province with ERCB data showing 109 crude oil pipeline failures and 1,538 failures on multi-phase pipelines between 2006 and 2010 for a staggering grand total of 27.7 million litres of liquid hydrocarbons spilled.
In 2012, NEB data was more challenging to gather. I acquired copies of NEB annual reports dating back to 1965, which included total numbers of pipeline incidents. These included any leaks, breaks, malfunctions, and other incidents pipeline operators reported to the board. Overall, between 1965 and 2012 pipelines regulated by the NEB experienced 2,690 failures. The data from NEB annual reports, however, was too broad. It did not distinguish between incident types and it did not provide spill volumes. I had to work directly with records from the NEB library in Calgary where I acquired a complete database of pipeline incident reports from 1961 to 1996. With this database, I was able to get a more granular understanding of the record of oil spills on Canada’s trunk pipelines. The two largest pipeline systems, the Trans Mountain and the Interprovincial had rather lengthy records of on-shore spills. Between 1961 and 2013, Trans Mountain reported 81 liquid hydrocarbon spill incidents to the NEB, an average annual rate of 1.53 spills. The total spill volume was 5,799,700 litres of crude oil. Interprovincial also had a record of numerous oil pipeline spills. From 1962 to 1996, Interprovincial reported 190 oil spills to the NEB (average annual spill rate of 5.43) with a total spill volume of 51,194,840 litres of liquid hydrocarbons. These data also included location information, which allowed me to map the locations of all the spills that occurred along the Interprovincial in that same period. These research findings are significant and they began to answer the initial question that started this project. The next step was to determine how to publish these findings.
Open Online Publishing
Because this research project started as an effort to answer a historical question in response to a contemporary environmental issue, I decided to publish my findings with an open online publication. The research itself illustrated the inaccessibility of public information about Canadian oil pipeline performance. Minister Renner could easily issue his challenge to compare Canada’s pipeline performance record to other places around the world, but making such comparisons was not an easy matter. Therefore, the data that I acquired and compiled, I believed, should be published in an accessible manner open to all interested readers.
I published my initial findings with ActiveHistory.ca, a web publication dedicated to connecting “the work of historians with the wider public and the importance of the past to current events.”[8] ActiveHistory.ca publishes all articles under Creative Commons licenses (Attribution-NonCommercial-ShareAlike 2.5 Canada). Creative Commons is a non-profit organization founded in 2001 by the Center for the Public Domain and Lawrence Lessig, professor of law at Harvard University. The organization develops legal and technical infrastructure to facilitate the creation and sharing of information. It provides simple licenses that publishers can use to easily communicate copyright information and facilitate open access and sharing. By publishing my research with ActiveHistory.ca and simultaneously publishing the same work on my own website (http://seankheraj.com), I could rapidly disseminate my research findings in a manner that made them accessible to anyone interested in taking up the Minister’s challenge.
Open, online publishing was the key to my public engagement with Canadian pipeline policy. Historians occasionally find their work referenced in writing outside of scholarly publishing, but these occasions are rare.[9] Because I published my preliminary research findings with an open online publication, they began to quickly circulate among different constituencies with an interest in oil pipeline policy who were able to easily find and freely access this research. Without any intervention on my part, I began to see references to my web articles appear in other academic work, government reports, and the evidence submitted by ordinary citizens to the regulatory bodies considering new pipeline proposals.
It is not unusual for scholarly research to appear in the citations of academic journal articles, book chapters, dissertations and theses. However, the speed with which my open web publications began to appear in other scholarly work was much quicker than is typical for academic publishing.[10] For example, I published one of my first web articles on the history of oil pipeline spills in Alberta in June 2012.[11] By the following year, Wilfrid Greaves made reference to it in an article in Journal of Canadian Studies/Revue d’études canadiennes about environmental security discourses surrounding Canada’s bitumen sands and new oil pipeline proposals.[12] Also in 2013, Larissa K. Stendie, a masters student at University of Oslo’s Centre for Development and the Environment, made use of that same web article in her thesis on the Northern Gateway Pipeline and joint review panel process.[13] Another example comes from a September 2015 issue of Resilience: A Journal of the Environmental Humanities in which editor, Cheryl Lousley highlighted the value of open web publishing for environmental humanities scholars looking to disseminate their research widely and rapidly to address contemporary issues. She noted the Network in Canadian History and Environment (NiCHE) and its web publishing platform as an example of a digital tool that “has enabled these historians to act as fast responders to contemporary events.” She specifically cited an article I had published on the history of oil spills in Burrard Inlet in April 2015 on the NiCHE website as one such fast response.[14]
Researchers advising policy makers took up my open web publications even more rapidly than academics. One month after I published a web article on the history of oil pipeline spills in Alberta, Tim Williams, from the Parliamentary Information and Research Service, included a reference to my research in a Canadian parliamentary brief about environmental considerations concerning pipelines.[15] Less than a year later, this research was cited and discussed in a study of the economic, social, cultural and environmental effects of the oil and gas industries for the Gisborne District Council in New Zealand.[16]
Print and radio news media made the most extensive use of my research on oil pipeline spill history by drawing from articles published on ActiveHistory.ca, the NiCHE website, and my own website. Shortly after publishing one of my first web articles with ActiveHistory.ca, Stephen Hume, a columnist from Vancouver Sun, contacted me for an interview to follow up on my research findings.[17] Over the next few months, several more newspaper and radio journalists reached out for comments and interviews resulting in the further dissemination of my research.[18] Other journalists simply quoted my online articles. For instance, Tadzio Richards published an extensive article on oil and gas pipeline spills in Alberta Views in October 2013.[19] Engaging with print and radio news media through interviews became a second channel for the public mobilization of my historical research on oil pipelines in Canada. Since 2012, I have given more than forty interviews to print and radio news media outlets about Canadian oil pipeline history.
Perhaps the most surprising place I found references to my research in the public realm was in the writing of ordinary citizens and environmental advocacy groups. A month after publishing a lengthy article on Alberta’s oil pipeline spill history on ActiveHistory.ca, the DeSmogBlog Project, an anti-global warming advocacy publication, cited this article to show the daily frequency of pipeline incidents.[20] Several personal blogs and other web articles linked to my open publications on oil pipeline spill history. Intervenors in public hearings on new pipeline proposals made reference to my online articles and interviews that I gave in newspapers. For instance, in August 2012, Michael English, a retiree from Vancouver, wrote a letter to the Joint Review Panel on the proposed Enbridge Northern Gateway Pipeline that cited my research based on the interview I gave to Hume in Vancouver Sun.[21] In another letter to the Joint Review Panel, Victoria Frodsham, a North Vancouver resident directly cited my research and specific spill rate figures from my open web articles.[22] On the same issue, a woman named Laura Winter printed a copy of one of my web articles from my own website and sent it to the Joint Review Panel.[23] David Anson, another retiree from White Rock, BC, included a newspaper clipping with an interview I gave to Peter O’Neill from Financial Post and made reference to my comments on the history of oil pipeline spills in a letter to the NEB concerning the expansion of the Trans Mountain Pipeline.[24] The Chippewas of the Thames First Nation submitted documents to the NEB that included references to my ActiveHistory.ca articles.[25]
Expert Evidence
Through open online publishing and interviews with print and radio news media, I was able to indirectly engage with public policy issues concerning oil pipeline development. I became directly involved in public policy, however, as an independent expert for the City of Vancouver’s intervention in the Trans Mountain Pipeline Expansion Project. As the city put it in its written statement to the NEB, I was commissioned to write a review of “the historical operations of the Trans Mountain Pipeline and provide an assessment of the oil spills and other incidents relating to the existing facilities.”[26]
My review took the form of an eighty-six-page historical background report outlining the history of the Trans Mountain Pipeline from 1947 to 2013.[27] This report included an overview of the origins of the pipeline, its regulatory approvals, parliamentary oversight, its operations history, a quantitative history of oil spills and other incidents, and some analysis of the relationship between the pipeline operator and environmental concerns. The City of Vancouver published this report as an appendix in its written evidence submitted to the NEB in May 2015. It was also published on the city’s website and made freely available for download.
Publishing a report as an independent expert in a NEB hearing was considerably different than open online publishing as an academic. First, the evidentiary standards were more rigorous. The city reviewed drafts of my report to ensure that I adequately cited all of my evidence and included a clear statement about my methodology and sources. I also had to include an extensive biography and CV to outline my expertise. The formatting had to meet the expectations of the hearing itself so that other intervenors and the applicants could easily make reference to specific lines on specific pages of the report. Most importantly, I needed to be clear about all the sources used in the report and be prepared to support my arguments in the event that I was called as a witness for questioning at the hearing (this never ended up happening).
The most significant differences between open online writing and serving as an independent expert in a NEB hearing were the roles of impartiality and advocacy. NEB hearings are judicial proceedings and, as such, they share similarities with the proceedings of a court of law in Canada. Independent experts appear before the NEB and provide expert reports to the board in a manner that is similar to that of an expert witness in a trial. As Gwynneth C.D. Jones notes, “Although an expert is hired and paid for by a party, the Canadian expert’s role and duty is to serve ‘the Court’ in achieving the appropriate outcome of the trial.”[28] Expert witnesses in Canadian courts have a duty to provide impartial evidence and must not advocate for any party in the matter. The same was true in the case of the NEB hearing on the proposed expansion of the Trans Mountain Pipeline. Although the City of Vancouver commissioned me to write a report for its intervention, I was not an advocate for the city. I was also prohibited from advocating for Kinder Morgan, the pipeline operator. My report had to convey impartial, objective evidence concerning the history of the Trans Mountain Pipeline.
As a historian, there was an additional layer of impartiality at play in my role as an independent expert in this NEB hearing. Because my expertise was in historical analysis, my report was not intended to be prescriptive. It was retrospective. That is to say, a historical background report could present evidence of the past performance of this pipeline, but it could not reasonably make claims concerning future performance. It also could not make definitive statements about the wisdom of the proposed expansion. The report could only contextualize the proposal using historical evidence. For example, the report showed the throughput deliveries on the Trans Mountain Pipeline from 1953 to 1992. It showed that the peak year of deliveries on the pipeline occurred in 1974 with an average of more than 350,000 barrels of oil shipped per day. This was below the maximum possible throughput capacity of 410,000 barrels per day. The proposed expansion of the pipeline would double the pipeline capacity, making the possible throughput more than 800,000 barrels of oil per day. My report could definitively show that in the period from 1953 to 1992, the pipeline never reached its historic maximum throughput capacity and that the proposal to ship double the volume of oil would be unprecedented. Historical evidence made it clear to what extent the proposed expansion was novel.
My report also showed evidence of the spill record of the Trans Mountain Pipeline, documenting all oil spills reported to the NEB from 1961 to 2013. While the spill history of the pipeline could not be used as evidence to predict future oil spills, it could be used to explain past causes and patterns. The causes of oil pipeline spills reported to the NEB since 1961 were variable with no particular cause standing out as predominant. Instead, oil spills occurred in an unpredictable fashion, the result of human error, hardware failures, and other unforeseen circumstances. The implication of this historical finding was that it might undermine claims of future mitigation strategies. Because the historical record showed no discernable pattern of causes for oil pipeline spills, mitigation planning to prevent future spills might not be able to adequately address the unexpected incidents that have led to spills in the past.
Conclusion
Historians do have a role to play in contemporary oil pipeline politics in Canada, but one that falls within particular, limited, parameters. Open online publishing of historical analysis of pipelines can indirectly inform public policy and debate by providing findings to a wide range of constituencies of interested parties. Those parties can then mobilize historical research findings for a variety of purposes. In my experience, data and analysis of historical oil pipeline spills have proven to be of particular interest to Canadians (and some US readers) in this period of heated debates over proposed long-distance oil pipelines. Since 2012, my research has also drawn attention from print and radio news media, resulting in another mode of connecting with the public realm. Environmental historians can also play a direct role in public policy debates as independent experts in public hearings on oil pipelines. This direct role, however, requires scholars to operate in a manner that differs from the realms of open online publishing and academic publishing. Evidentiary standards and expectations of impartiality are paramount in the context of a judicial proceeding. As such, environmental historians who serve as independent experts are asked to embrace assumptions of objectivity that might otherwise be critiqued or questioned in scholarship. They must also reject forms of advocacy that they might otherwise embrace as environmental activists or industry sympathizers.
These demands for impartiality and high evidentiary standards are valuable. In my experience, the presentation of my research findings and evidence in an impartial manner helped enhance the impact of my work. All parties in the NEB hearing had to address my findings on the basis of the evidence provided rather than my subject position as an advocate for any particular party in the hearing. The result was that subsequent third parties have cited my historical background report and evidence therein to support their specific advocacy issues concerning oil pipeline development. Such expectations of impartiality might not satisfy the personal political values of a scholar in the environmental humanities, but this approach has allowed my research to more credibly engage with the public realm in a manner that has been useful to different advocacy groups.
[1] I wrote about this previously in Sean Kheraj, “Scholarship and Environmentalism: The Influence of Environmental Advocacy on Canadian Environmental History” Acadiensis, 43, no. 1 (Winter/Spring 2014): 195-206.
[2] As early as 1982, John Opie warned about the risks of too closely aligning environmental history scholarship with advocacy. See John Opie, “Environmental History: Pitfalls and Opportunities” Environmental Review 6, no. 2 (Autumn 1982): 9-11.
[3] Imre Szeman, “Introduction: Pipeline Politics” South Atlantic Quarterly, 116, no. 2 (April 2017): 402.
[4] Ibid, 403.
[5] Mike De Souza, “Trudeau approves Kinder Morgan pipeline, rejects one of two Enbridge projects” National Observer, 29 November 2016, https://www.nationalobserver.com/2016/11/29/news/breaking-trudeau-approves-kinder-morgan-pipeline-rejects-one-two-enbridge-projects
[6] Energy Resources Conservation Board, “Plains Midstream Canada ULC NPS 20 Rainbow Pipeline Failure, Licence No. 5592, Line NO. 1, April 28, 2011” ERCB Investigation Report, February 26, 2013, iii.
[7] Emily Mertz, “Alberta government addresses massive oil spill” Global News, May 4, 2011, https://globalnews.ca/news/118431/alberta-government-addresses-massive-oil-spill/
[8] Active History About Page, accessed April 17, 2018, http://activehistory.ca/about/; I also published work later on the Network in Canadian History and Environment website (http://niche-canada.org), an organization with a similar mission to that of ActiveHistory.ca but with a focus on environmental history.
[9] In Canada, there have been examples of scholars whose work on the history of Indigenous people has drawn the attention of news media, community organizations, and policy makers. For instance, see the work of Maureen Lux, James Daschuk, and Ian Mosby.
[10] A study of scholarly bibliometrics of research published between 2012 and 2016 by Billy Wong of Times Higher Education, found high rates of uncited research among humanities and fine arts scholarship. According to this study, 56.5% of history publications go uncited in the first five years after publication. See Simon Baker, “How much research goes completely uncited?” Times Higher Education, April 18, 2018, https://www.timeshighereducation.com/news/how-much-research-goes-completely-uncited#survey-answer
[11] Sean Kheraj, “The History of Oil Pipeline Spills in Alberta, 2006-2012” ActiveHistory.ca, June 12, 2012, http://activehistory.ca/2012/06/the-history-of-oil-pipeline-spills-in-alberta-2006-2012/
[12] Wilfrid Greaves, “Risking Rupture: Integral Accidents and In/Security in Canada’s Bitumen Sands” Journal of Canadian Studies/Revue d’études canadiennes 47, no. 3 (Fall 2013): 169-199.
[13] Larissa K. Stendie, “Public Participation, Petro-Politics and Indigenous Peoples: The Contentious Northern Gateway Pipeline and Joint Review Panel Process” (MPhil thesis, University of Oslo, 2013).
[14] Cheryl Lousley, “Canadian Editor’s Introduction: Political Ecologies, Public Humanities – A Report from Canada” Resilience: A Journal of the Environmental Humanities 2, no. 2 (September 2015); further examples include, Denny Brett, “Strategic Non-Renewable Resource Governance: A History of Alberta Oil Sands Royalty Regulations, Public Finances, and Global Oil Markets” (MA thesis, University of Alberta, 2015); Kathleen Raso and Robert Joseph Neubauer, “Managing Dissent: Energy Pipelines and “New Right” Politics in Canada” Canadian Journal of Communications 41, no. 1 (2016): 115-133; Kaela-May Hlushko, “Fracking Futures: Political-Ecological and Socioeconomic Realities in Southwestern Manitoba’s Oil Field” (MA thesis, University of Manitoba, 2017)
[15] Tim Williams, “Pipelines: Environmental Considerations” Parliamentary Information and Research Service (Ottawa: July 2012).
[16] Glen Greer, Michelle Marquet, and Caroline Saunders, “Petroleum Exploration and Extraction Study” Report to the Gisborne District Council, Agribusiness and Economics Research Unit (March 2013).
[17] Stephen Hume, “Pipeline spills are not the exception in Alberta, they are an oily reality” Vancouver Sun, 14 June 2012, http://www.vancouversun.com/news/Hume+Pipeline+spills+exception+Alberta+they+oily+reality/6778601/story.html
[18] See for example, Bob Weber, “Alberta pressured to include leaks in environmental monitoring plan” Financial Post, 14 June 2012; James Wood and Chris Varcoe, “Pipeline leak near Sundre takes toll on Gateway project” Calgary Herald, 17 June 2012; Audette, Trish. “How safe are pipelines?” Edmonton Journal, 6 July 2012; Nikiforuk, Andrew. “It Just Gets Worse: The NTSB’s Final Flaying of Enbridge” The Tyee, 1 August 2012, http://thetyee.ca/News/2012/08/01/NTSB-Flays-Enbridge/
[19] Tadzio Richards, “Spills and Leaks: Just how safe are Alberta’s oil and gas pipelines?” Alberta Views, October 1, 2013, https://albertaviews.ca/spills-and-leaks/
[20] Carol Linnitt, “Albertans Seek Pipeline Safety Investigation, Launch Spill Tipline” DeSmog, July 12, 2012, https://www.desmogblog.com/albertans-seek-pipeline-safety-investigation-launch-spill-tipline
[21] Letter from Michael English to Secretary to the Joint Review Panel on Enbridge Northern Gateway Pipeline, August 29, 2012 (Letter of Comment – A3A2A7), https://apps.neb-one.gc.ca/REGDOCS/File/Download/863018
[22] Letter from Victoria Frodsham to Secretary to the Joint Review Panel on Enbridge Northern Gateway Pipeline, August 31, 2012 (Letter of Comment – A2Z1L0), https://apps.neb-one.gc.ca/REGDOCS/File/Download/855057
[23] Letter from Laura Winter to Secretary of the Joint Review Panel on Enbridge Northern Gateway Pipeline, August 31, 2012 (A2Z3L4), https://apps.neb-one.gc.ca/REGDOCS/File/Download/856296
[24] Letter from David Anson to National Energy Board, December 18, 2014 (Letter of Comment – A4G1S5 on Hearing Order OH-001-2014), https://apps.neb-one.gc.ca/REGDOCS/File/Download/2585097
[25] Chippewas of the Thames First Nation, Exhibits J-N (Part 5 of 10) – A3K2Q4, https://apps.neb-one.gc.ca/REGDOCS/File/Download/996695
[26] City of Vancouver, “Written evidence of the City of Vancouver” (A4L7K6), pg. 21, https://apps.neb-one.gc.ca/REGDOCS/File/Download/2785277
[27] Sean Kheraj, “Historical Background Report: Trans Mountain Pipeline, 1947-2013” prepared for the City of Vancouver as evidence for National Energy Board hearings of Trans Mountain Pipeline Expansion Project, May 2015, http://vancouver.ca/images/web/pipeline/Sean-Kheraj-history-of-TMP.pdf
[28] Gwynneth C.D. Jones, “Documentary Evidence and the Construction of Narratives in legal and Historical Contexts” The Public Historian 37, no. 1 (February 2015): 88-94.
Sean Kheraj
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