I would like to add my voice to that of the many residents of Delta

251 Pages·2014·11.94 MB·English

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From:
To: Roberts Bank [CEAA]
Subject: Environmental Review of Terminal 2 Proposal
Date: November 30, 2013 7:01:48 PM
I would like to add my voice to that of the many residents of Delta who are urging you to hold a full
panel review of Port Metro Vancouver`s Terminal 2 proposal. Persons with more scientific expertise
than myself have, I am sure, provided extensive reasons why the most detailed and comprehensive
review of this project is needed. I would like to mention a few of the issues I believe are most
compelling from my perspective as a recently retired financial and economic analyst.

Only a few years ago there were only two container berths at Roberts Bank. When the third birth
was added the cumulative impact of planned development was not considered as the prospective
Terminal 2 project was ruled irrelevant as it had not been `formally` proposed at that point, even
though it was no secret that it was in the planning horizon of the port. If Terminal 2 goes ahead it
must be seen as a tripling of previous capacity, not just a doubling from current capacity with the
recent completion the third berth. This of course means at least three times the environmental
impact already absorbed by the Fraser estuary and surrounding area from an already problematic
level of development.

It is this sort of sleight of hand, transparent as it is, that creates cynicism among residents about
both the proponent and regulatory bodies. Only a full panel review can hope to restore any
confidence regarding the impartiality and objectivity of the process.

Furthermore, the environmental impacts of the Terminal 2 proposal which cannot be minimized or
mitigated must be weighed against the claimed or potential economic benefits. Given the
importance and fragility of the whole area that will be affected these benefits would have to be
extremely significant to justify the risks entailed in this development. Therefore it is essential that
the assumptions, expectations and forecasts of the proposal be subjected to the most
comprehensive and objective examination by experts and critics.

Residents of Delta are well aware that the Terminal 2 proposal is part of an extensive package of
developments connected like dominoes across the region. Anticipated expanded capacity at the
port was a major part of the justification for the South Fraser Perimeter Road. Plans for a huge
development of logistics and storage centres on protected farmland were revealed when secret
options to purchase were exposed. A potential commercial real estate bonanza all along the SFPR
has been trumpeted by the industry; the list goes on and on. Any attempt to obscure or minimize
the connectedness and cumulative impact of the totality of prospective industrial development
south of the Fraser will be met with the scepticism and opposition it deserves.

I therefore urge you to uphold your responsibilities to the citizens of BC and provide the greatest
possible scope and opportunity for the review and determination of the full implications of the
Terminal 2 project.

Sincerely,
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From:
To: Roberts Bank [CEAA]
Subject: Panel Review for Terminal 2
Date: November 30, 2013 3:35:12 PM
Please, please, please do a full Panel Review for this project.

We live on Tsawwassen Beach and see the devastation daily this port has caused :
- we now have piles of dead seaweed wash in at high tide, this never happened before the ocean floor
was gutted for terminal 1.
- we used to have crystal clear water lapping up on the beach it is now seldom that it even looks clean.
- where do the tiny salmon hide without a healthy bay for shelter?
- we always fished in front of the coal port but since terminal 1 the fish do not swim there.
- when out fishing we often saw killer whales but since terminal 1 it is very seldom we see any
- we often find dead jelly fish and dead starfish on the beach this too was not so before terminal 1.
-on a quiet night at low tide Awe can hear the low drone of the tankers tied up for days with third world
motors running.
- we cannot see the air pollution and can only imagine what this air is doing to our lungs.

Terminal 2 will in all probability increase all of these at least 2 fold. Why on earth would you accept the
PAM assessment as fact?
Do a proper independent assessment; that is what you exist for - Care for this beautiful planet.

Sincerely,
Dr Moe and Elinor Attalla
.
Delta, BC,
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Terminal Two letter sent October 15, 2013 - via email to [email protected]

October 15, 2013

B.C. Great Blue Heron Society
P.O. Box 307
Merville, B.C.
V0R 2M0

Roberts Bank Terminal 2 Project
Canadian Environmental Assessment Agency
410-701 West Georgia Street
Vancouver, BC V7Y 1C6
Ladies and Gentlemen:
On behalf of our Society’s directors and members, we are writing to urge you in the strongest of
terms to implement an Independent Panel Review for the Environmental Assessment of
Terminal 2 at Roberts Bank in Delta, B.C. This proposal is located in the estuary of the Fraser
River, one of the most important estuaries in the world for migratory birds. As you are aware,
there is no significant bird sanctuary in the area, and widespread development of farmland in the
estuary is encroaching on remaining habitat for five million birds and other global wildlife
populations. Great Blue Herons are particularly at risk in the estuary now, as their numbers are
dropping, probably due in large part to habitat loss.
It is Canada’s international disgrace, and an abrogation of our global responsibility, that we have
not put into place permanent protection for the Fraser River delta habitat, as outlined below:
UN RAMSAR designation as internationally critical wetland UNPROTECTED
Named Western Hemispheric Shorebird Reserve UNPROTECTED
Named Most Important Migratory Bird Site in Canada
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(Bird Life International) UNPROTECTED

Contains the three most significant Important Bird Areas
(IBAs) in Canada (out of 597 sites) UNPROTECTED

Only habitat in Canada for 5 million migratory birds from
over twenty countries UNPROTECTED

Only habitat in Canada for world population of Western Sandpipers UNPROTECTED
Canada’s most important wintering habitat for water birds UNPROTECTED
Canada’s most important wintering habitat for shorebirds UNPROTECTED
Canada’s most important wintering habitat for birds of prey UNPROTECTED
Habitat for last Canadian breeding population of barn owls UNPROTECTED
Habitat for 310 bird species (46% of Canadian land bird species) UNPROTECTED
Home of the world’s greatest salmon run UNPROTECTED
Largest eelgrass beds on Canada’s west coast
(critical for fish, crustaceans and birds) UNPROTECTED

Habitat for over 90 species of fish in key life stages
(Marshes and intertidal spawning and nursery areas) UNPROTECTED

Feeding ground of Canada’s Endangered Orca
(south coast population) UNPROTECTED

Feeding ground of Threatened transient west coast Orca population UNPROTECTED
Home of endangered Fraser White Sturgeon (living up to 170 years
and reaching half a ton) UNPROTECTED

This estuary continues to be unprotected and obviously still considered ‘open for business’,
despite a host of regulations and conventions that the federal government purports to offer
protection for our wildlife and ocean creatures:

• Canadians Fisheries Act
• Canadian Migratory Birds Convention Act of 1994
• Canadian Environmental Assessment Act
• Canadian Species at Risk Act
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• Canadian Department of the Environment Act
• Convention on Biological Diversity
• Federal Policy on Wetland Conservation
• North American Waterfowl Management Plan
• GVRD Livable Strategic Plan and Green Zone
• Georgia Basin Ecosystem Initiative
• Georgia Basin Action Plan
• The Ramsar Convention
• National Recovery Strategy for Southern Resident Orcas.
Since this internationally important Fraser River estuary is largely unprotected, it is absolutely
imperative that we have an INDEPENDENT REVIEW PANEL consider this project. That the
federal government is even considering this project when the habitat and creatures of the estuary
are without permanent and meaningful protection, is in itself an indicator of its inability to
properly monitor the consideration of such a project.
Thank you for your attention to our Society’s concerns for B.C.’s Great Blue Herons, and of
course, all the other wild creatures of B.C.’s air, land and water.

Sincerely yours,
B.C. GREAT BLUE HERON SOCIETY

Gillian Anderson
Chair
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SUBMISSION TO CANADIAN ENVIRONMENTAL ASSESSMENT AGENCY ON ROBERTS BANK TERMINAL
2 PROJECT

December 6, 2013

Roberts Bank Terminal 2 Project
Canadian Environmental Assessment Agency
410 - 701 W. Georgia St.
Vancouver, BC
V7Y 1C6
[email protected]

Comments on the Draft Environmental Impact Statement (EIS) Guidelines for the Roberts Bank
Terminal 2 Project

BC Nature (Federation of BC Naturalists) is the provincial voice for naturalists, representing 53 member
clubs in British Columbia. Our motto is “know nature and keep it worth knowing”.

In this submission, we outline our concerns regarding environmental impacts at the Roberts Bank Terminal
2 site and ancillary developments, and also our concerns along the marine shipping route between the
terminal and the open ocean.

DEFICIENCIES

The draft EIS guidelines for the Roberts Bank site are deficient in a number of respects. These include the
need for a larger study area and for a Joint Review Panel assessment to be undertaken.

The scope of the draft EIS Guidelines does not cover the marine shipping route. We consider this to be a
serious oversight that needs correction. The increased large ship traffic attributable to the project will
significantly increase current environmental concerns along the route.

CEAA must recognize the profound changes in wildlife habitat at Roberts Bank and the Fraser Estuary
over the years. The wetlands here, now a mere fraction of their former extent when Europeans arrived in
the early 1800s, form part of the Pacific Flyway for migrating birds, which stretches from the far north of
Canada to the tip of South America. The development of Roberts Bank Terminal 2 might well be the
tipping point for these unique wetlands, and for the Pacific Flyway itself.

The draft guidelines do not cover the marine shipping route at all. We consider this to be a serious
oversight, to be corrected. The increased large ship traffic attributable to the project, estimated to be up to
an additional thousand or more transits of the route every year, will significantly increase environmental
concerns. These include:

BC Nature 1620 Mt. Seymour Road, North Vancouver, BC V7G 2R9
T: 604.985.3057 F: 604.985.3059 www.bcnature.ca email: [email protected]
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 First Nations concerns, including those of the Lummi Nation who have legal rights in the U.S. to
protection and restoration of salmon habitat.

 Increased possibility of oil spills from container ships carrying heavy loads of fuel for their voyage
across the Pacific Ocean.

 Increased disturbance to the endangered Southern Resident Killer Whales.

 Increased pressure on other marine species listed as endangered, threatened or of special concern
in the U.S. and Canada.

 Introduction of invasive species.

 Effect on quality of life and tourism in the Gulf Islands and San Juan Islands.

 Impacts on North America's largest fishing grounds in the Aleutian Islands, an area notorious for
adverse marine weather.

CONCERNS RELATED TO THE ROBERTS BANK SITE

1. Cumulative Impacts
At our annual general meeting in May 2009, a resolution passed unanimously to urge the federal
government to advise Port Metro Vancouver that any further expansion of Deltaport was unacceptable due
to the cumulative environmental impact of additional expansion when combined with previous
developments in this ecologically critical area. Roberts Bank and the Fraser Estuary have suffered
overwhelming losses in their ecological values since the arrival of Europeans in the early 1800s.

2. Ecosystem Impacts
Deltaport is situated on Roberts Bank in the very centre of the Fraser Estuary ecosystem. The importance
of this ecosystem has been recognized under the following designations:
 Ramsar Site (United Nations Wetland of International Importance)
 Globally significant Important Bird Area (IBA), under BirdLife International, with the greatest
number of bird species reaching global population thresholds of any IBA in Canada
 Hemispheric site in the Western Hemispheric Shorebird Reserve Network
 National Wildlife Area and provincial Wildlife Management Areas

Roberts Bank lies at the mouth of the Fraser River, which has Canada’s largest salmon runs. The Bank is also
habitat for marine mammals, including the endangered southern resident population of killer whales,
humpback whales, grey whales, two species of sea lion, and two species of porpoise, among other species.
The expansion of the terminal and causeway for BC Ferries, the operation of the coal port and sequential
expansions of the existing container terminal have already resulted in massive disturbance of the
ecosystems of Roberts Bank.
In 1979, an independent panel review of port development stated:

"From the point of view of estuarine ecology, the Panel has concluded that the potential impacts on
the Fraser River estuary, of which Roberts Bank is part, are too great to recommend that the port
expansion be approved as proposed. The extent and ecological significance of the Fraser River
estuary, particularly its use by fish and wildlife, make it unique in North America. A major salmon
fishery depends on its preservation as do hundreds of thousands of migratory birds."
BC Nature 1620 Mt. Seymour Road, North Vancouver, BC V7G 2R9
T: 604.985.3057 F: 604.985.3059 www.bcnature.ca email: [email protected]