Roberts Bank Terminal 2 Project Environmental Impact Statement Comments on Completeness April 30 June 15, 2015

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1 Participant: Susan Jones Organization (if applicable): Boundary Bay Conservation Committee General Comments: Comments on Marine Vegetation, Coastal Birds and Fish These Chapters fail to meet the requirements of an. They use language of environmental assessment requirements but they uniformly fail to provide scientific evidence to support their conclusions. The documents are full of expectations based on descriptions. Modeling is presented as facts rather than hypotheses. The science they reference is not peer-reviewed or published. Scientific papers that have been peer-reviewed and published by world experts are not incorporated into the. Cumulative effects from past projects are not included as required. The use of components and sub-components cannot be accepted as representative of whole interactive, interdependent ecosystems. All the Chapters report negligible residual effects or no residual effects. Scientific reports and information from experts have not been consulted. Monitoring, mitigation, Environmental Management Plans are promised but they lack credibility as they are supposed to occur after the Project is approved. There is no transparency and the public will never know much about any followups. Most of the Chapters ramble on without substance or clarity. Comments on Completeness of Information in the Use of Hypotheses on biofilm to present unsubstantiated conclusion that there will be no net loss of biofilm Biofilm Hypotheses based on insufficient data, sample testing, and subjective modeling must not be used to create conclusions that do not correlate with peer-reviewed, published scientific papers from experts around the world. Hypotheses are being presented as evidence. The public has a right to know that the consultants report includes disclaimers. The disclaimers make no guarantees or warranties as to the accuracy or completeness of this information. The Consultants disclose the lack of evidence but this information is not included for the public. The Canadian Environmental Assessment Agency and federal and B.C. Agencies should not have permitted this hypothetical information to be presented as facts. This is misleading to the public who cannot be expected to wade through pages of verbiage presented as science. There needs to be 1

2 productivity The Executive Summary of one report states: the statistical analyses were conducted using data that were collected for purposes beyond the scope of assessing biofilm sampling distribution and frequency may have been insufficient to fully account for the natural temporal and spatial variability known to occur at Roberts Bank. Conclusions regarding the physical factors of biofilm growth at Roberts Bank are limited to the available data and associated assumptions of collection methodologies. Provide information informing the public that the marine vegetation and the numerous species it supports face serious risks. As the Terminal 2 Project impacts a large area with internationally-significant interactive ecosystems which are interdependent, CEAA and the agencies have a duty to protect these habitats and must not participate in dispersing information that leads to deceptive interpretation. quality control on consultants reports. It is the job of paid government experts to present accurate information to the public. Otherwise the government agencies are actively participating in misleading the public. The Guiding Principles require that projects are considered in a careful and precautionary manner Presenting hypotheses as facts contravenes the Guiding Principles, the Precautionary Principle and the Core Values of the International Association of Public Participation. The process must not be turned into a bureaucratic formality. The information must be objective, not subjective. Opinions and hypotheses are not evidential proof that there will be no harm to the environment. This is particularly important in this as it is a major stopover of the Pacific Flyway which is already stressed by numerous factors. Critical concerns must not be toned down in overall conclusions. 2

3 Include more specific information such as. Provide accurate and updated information on biofilm Biofilm Published April 14, 2015 Major estuarine stopover locations supporting biofilm are often strategic places for transport, industrial and residential development. Such developments can significantly change the extent and quality of estuarine ecosystems by altering hydrology and sedimentation, converting habitats, and introducing pollutants or invasive species. Each of these factors could potentially affect biofilm quality, abundance and distribution. An understanding of the extent and degree to which migratory shorebirds use biofilm is therefore necessary, to assess the possible impacts of development, and to help guide design and management. These sections have not used up-to-date science and knowledge. The needs to include information which identifies the complexities of interactive, interdependent environmental processes at Roberts Bank and the potential for major destructive impacts. Biofilm Overview The first sentence needs to be replaced due to inaccuracy. Is the next paragraph correct? The references used are from recent reports commissioned by Port Metro Vancouver. There appears to be 5 different Worley Parsons reports with strongly-worded disclaimers on one of the reports. Information and sources are confusing. This prevents meaningful public or Agency comments. North American studies are not limited. This paragraph needs to recognize and identify recent work in the last 7 to 8 years by local scientists who have published peer-reviewed papers. There have been peer-reviewed scientific papers providing this information more accurately. CEAA should not permit these kinds of omissions. CEAA and the Agencies should review this section for accuracies as the references are unpublished reports that have not been reviewed by experts. 3

4 The fact that not all biofilm is equal is of major importance to this topic. Ecological Value of Biofilm Resilience of Biofilm Page Page Natural Variability and Resilience of Biofilm at Roberts Bank Vital information on the ecological value of biofilm is missing. Provide more information from world experts as this section misses critical information such as the fact that density and quality of biofilm are important. Published experts explain how biofilm is complex and variable. The density and quality determine its potential as food source. Experts report that Roberts Bank is the number one site for density and quality of biofilm. This is the area where the Project will destroy 2.5 ha of the best biofilm. Request scientific verification of the conclusion about the resilience of biofilm. The conclusions are based on unpublished reports. One of the reports is prefaced with a disclaimer about technical data. There is not sufficient evidence. This does not comply with the Precautionary Principle. Information in the contradicts information from peer-reviewed, published experts. Biofilm Consumption and Variable Diet Composition of Western Sandpipers (Calidris mauri) during Migratory Stopover Catherine B. Jardine, Alexander L. Bond, Peter J.A. Davidson, Robert W. Butler, and Tomohiro Intertidal biofilm distribution underpins differential tidefollowing behavior of two sandpiper species (Calidris mauri and Calidris alpina) during northward migration Ariam Jim_enez a, b, Robert W. Elner c, Corinna Favaro a, Karen Rickards a, Ronald C. Ydenberg a, * There are other reports which should be incorporated here. The Disclaimer is attached to the Technical Data Report on Biofilm Physical Factors: makes no guarantees or warranties as to the accuracy or completeness of this information. Page v of document and 5/232 The Executive Summary Page 7 admits sample sites may have been insufficient the statistical analyses were conducted using data that were collected during for purposes beyond the scope of assessing biofilm 4

5 Other published papers describe the complexity and variability of biofilm. It is unacceptable for Port Metro Vancouver to write conclusions without scientific proof. A Report with disclaimers does not provide this proof. Effects on Biofilm of turbidity from construction and operation Effluent Discharge Potential Effects Productivity Loss of Biofilm at Roberts Bank Page Page Biofilm Direct Loss or Mortality Request scientific information here. These are unsupported blanket statements which contradict studies by experts. Provide information on threats to biofilm such as coastal development, hydrodynamic processes and grazing pressures from invasives. Provide information on the potential effects of pollution and chemicals on biofilm. Provide information on the potential for a chain reaction of consequences from the changes to the biofilm ecosystems at Roberts Bank Provide more information on location of biofilm and the importance of the area where there will be a direct and permanent loss of the biofilm. Disclose the fact that the biofilm heavily used by Sandpipers is located along a sandbar that stretches parallel to the Causeway. The main feeding area of biofilm will be severely impacted with a loss of 2.5 hectares. Unsupported conclusions on a matter of such great importance are disturbing. Subjective summaries are unacceptable. Information published by experts should be incorporated. Adverse cascading trophic interactions could be triggered by direct competition between higher vertebrates and invertebrates, leading to decreases in biofilm availability as a food for shorebirds, potentially contributing to population-level declines (Clark and Butler 1999). The widening of the Causeway has the potential to destroy the main feeding area of the Western Sandpipers. This would be a severe loss of productive habitat for migratory birds, not just the Western Sandpipers. This is a major risk to the international significance of this stopover of the Pacific Flyway. 5

6 Potentially devastating impacts to interactive, interdependent ecosystems at Roberts Bank Biofilm Direct Loss or Mortality Changes in Water Quality Provide scientific information in this section as this section is theoretical and ignores important scientific information that has been published over the past few years. The comments in this section raise serious questions about the dramatic changes in water quality. The impacts to the interactive processes are potentially devastating. This section discloses that the Project will have major impacts to the interactive ecosystems due to changes in water quality in the immediate vicinity and far beyond. The needs to include information which identifies the complexities of interactive, interdependent environmental processes at Roberts Bank and the potential for major destructive impacts. This is a major risk to the all of the marine vegetation at Roberts Bank and beyond. Short-term loss of biofilm could lead to permanent loss Modeling is a tool, not evidence Page Pages to Because of the resilience of biofilm at Roberts Bank (WorleyParsons 2014e), potential decreases in productivity due to changes in salinity are predicted to be short term in nature. Provide sufficient scientific evidence for this statement which is difficult to comprehend and which contradicts the earlier information in this section. Reword this section as Modeling is a tool, not evidence. Just what is being revealed here? This information needs to be challenged. It is based on some questionable tests leading to assumptions. This section does not provide the technical information needed for the public to participate in a meaningful way. It does not adhere to the Precautionary Principle. CEAA and the Agencies should not let this slip by as there is a potential for the permanent loss of the most abundant and nutritious biofilm. It is inaccurate to assume this modeling provides evidence to support the conclusions in this section. Modeling is a tool that collates information and makes some calculations. The outcome of modeling is only as good as the information that was provided to the model. 6

7 Negative impact of the Project on biofilm Need to provide expert information on effects of industrial development on biofilm. Page Summary of Potential Projectrelated Effects to Biofilm Productivity Page Summary of Potential Projectrelated Effects to Biofilm Productivity Provide scientific evidence to support the statements: changes in biofilm productivity are not anticipated as a result of RBT2. And overall the Project will not negatively influence biofilm production. Provide proof of the following statement: Due to the relatively recent understanding of biofilm to science, previous examples of observed effects of similar (to RBT2) industrial development to biofilm are not available. Hence there is no precedence to support the predictions made here. World experts are publishing peer-reviewed papers citing threats posed by coastal developments to complex biofilm processes. It is insulting to world experts, CEAA, the Agencies and the public to make statements without consulting available information and expertise. Just to state there are multiple lines of evidence is inaccurate. Lines of evidence have not been established. The Proponent has ignored scientific studies from experts and commissioned studies and reports which do not provide peer-reviewed scientific evidence to support the thesis that there will no changes to biofilm productivity. This kind of presentation is unacceptable and CEAA should have requested more accurate information prior to seeking public input. The accuracy of this statement needs to be challenged by CEAA and the Agencies. In the first place, there have been at least 6 construction developments at Roberts Bank which are previous examples. In 2010, it was admitted that the Deltaport Third Berth Project has resulted in loss of marine vegetation and degradation of the intercauseway: Notwithstanding the parameters related to mitigating the impacts of the DP3 project, this continuing habitat loss and erosion of mudflat, biofilm and eelgrass features is a defacto port-development aretefact. ( acquired through Access to Freedom of Information 7

8 Mitigation 11.7 Residual Effects Cumulative Effects This section claims the practice of avoidance, offsetting and reduction will mitigate the loss of biofilm. It doesn t make sense to claim loss of 2.5ha of biofilm and then state it will be mitigated by these practices. These are words without evidence. The Summary of Mitigation Measures includes an Environment Management Plan with vague claims. These planned measures must be clarified and substantiated with credible science. The science is missing and the Precautionary Principle is not being applied. Provide scientific information from qualified experts. Do not accept hypotheses as facts. Apply the Precautionary Principle. Provide information on the cumulative effects of past projects. The public deserves scientific-based information outlining the effects of past project on marine vegetation including, but not limited to: The Ferry Terminal and developments there over time The Coal Terminal The Deltaport Terminal Road and Rail Improvement Project Deltaport Third Berth The loss of the location of the highest quality biofilm cannot be mitigated. Many interactive processes and conditions create this biofilm. The impacts have been identified as significant and the simplistic hypothesis that the fresh water biofilm will balance the ecosystems has no scientific basis or evidence. CEAA and the Agencies would be remiss to accept these claims which contravene published information. The Precautionary Principle needs to be applied. Unpublished Consultants Reports are not sufficient evidence. There is no quality control on consultants reports so CEAA and the Agencies owe it to the public interest to ensure that scientific evidence is provided, as is required by the Precautionary Principle. The conclusions are hypotheses. Information from 2010, Government expert: Notwithstanding the parameters related to mitigating the impacts of the DP3 project, this continuing habitat loss and erosion of mudflat, biofilm and eelgrass features is a defacto port-development aretefact. ( acquired through Access to Freedom of Information) 8

9 These are known to have impacted marine vegetation yet no cumulative effects impacts have been provided to the public. As a matter of fact, no information has been made public. There is no evidence that the Precautionary Principle has been applied to these projects. There is no evidence to show that the Terminal 2 Project will not act cumulatively with historical changes to Roberts Bank to cause irreversible damage to Valued Ecosystem Components of international significance. In fact, the information provided in this section appears to point out that irreversible damage is likely. As for monitoring, the Project Reporting Updates from the Port s consulting firm, have been characterized by a government agency as grossly incomplete (despite repeated input over the last two years) ( acquired through Access to Freedom of Information) How many more government experts share these concerns? The public has been denied important relevant information. The public interest and due public process is denied. Lip service is being paid to the Precautionary Principle and due public process. References References There is no evidence that the Precautionary Principle has been applied to these projects. Provide information on which references have been peer reviewed and published. Many of the references are studies commissioned by the Proponent. They may be observation reports versus scientific studies. Government Agencies should have reviewed this prior to presenting it to the public. There are omissions here some that the public can identify but the Agencies should know more. The public has to apply for Habitat Compensation Plans through Access to Freedom of Information. As it turns out, the follow-up to the compensation plans is a flurry of s between Agencies. Specific completion reports, if they exist, are not available to the public. References that are based on observations and assumptions are very different from scientific studies that have been peer reviewed and published. The public and the Agencies need to know whether conclusions are based on scientific evidence or consultant opinions. There is a big difference. Additionally, the references commissioned by the Proponent should be disclosed. There is no quality control on consultant s reports. They are not subject to peer review. Environmental Consulting is a big 9

10 Agencies need to advise the proponent that important studies are missing from this set of references. business and there is naturally a strong self-interest in underplaying environmental impacts. These references need updating and important, more recent references need to be identified and applied. Two such references: Biofilm Consumption and Variable Diet Composition of Western Sandpipers (Calidris mauri) during Migratory Stopover Catherine B. Jardine, Alexander L. Bond, Peter J.A. Davidson, Robert W. Butler, and Tomohiro Submitted May, 2014 and published online, April 14, 2015 Eelgrass Section 11: Marine Vegetation and any other section that deals with eelgrass Intertidal biofilm distribution underpins differential tidefollowing behavior of two sandpiper species (Calidris mauri and Calidris alpina) during northward migration Ariam Jim_enez a, b, Robert W. Elner c, Corinna Favaro a, Karen Rickards a, Ronald C. Ydenberg a, * Please apply relevant comments above on biofilm to the sections on eelgrass. Include information that eelgrass is among the most productive of coastal ecosystems. Include scientific information on the whole system of eelgrass in the area to avoid fragmentation and piece-meal destruction. Include specific impacts from the Deltaport Third Berth Project. Include scientific information on the cumulative Credible expertise is required to complete the information on eelgrass. It is hoped that CEAA scientists and the Agencies will apply due diligence on this topic. Both species of eelgrass have declined in the intercauseway over the last 25 years. 10

11 effects of the T2 Project and provide specific information on how these effects will act cumulatively with the Deltaport Third Berth and historical changes to eelgrass beds. What will be the cumulative impacts on Valued Ecosystem Components of international significance? Apply the Precautionary Principle. Coastal Birds Food Web Disclose information from the section on Marine Vegetation that identifies big changes at Roberts Bank. These changes cannot occur without impacting the Food Web. Impacts described in Marine Vegetation need to be incorporated into the impacts on the Food Web. Shorebird Diet The information cited in this section omits scientific information in recent papers by world-renowned experts that do not support the thesis suggested here. Questionable modeling is presented as facts even though the information contradicts the peer-reviewed published works of experts. There is blatant salesmanship in this section trying to make a case that Canoe Passage is vital so destroying 2.5 hectares of biofilm at Roberts Bank is okay. Presenting this information as scientific evidence to support questionable hypotheses is unacceptable and should not be accepted by CEAA. CEAA needs to advise the Proponent that the work of experts needs to be included and considered. The Precautionary Principle needs to be applied. 11

12 Shorebird Habitat Selection Include information from world experts who have published peer-reviewed papers on this topic. It is critical to this as the migration of sandpipers and dunlin heavily depend on the biofilm at Roberts Bank. Recent studies indicate that the area planned for destruction contains the best quality biofilm providing the most nutritious food supply for sandpipers and dunlin. Include specific information in this section on dunlin and sandpipers and their reliance on biofilm. Cite information from the following study which identifies Roberts Bank as the number one site with the highest proportion of biofilm in the diet. The Proponent presents a complete bias in this section in an effort to ignore world experts on biofilm and sandpipers. There is an attempt in this section and the section on biofilm to present Canoe Passage as the best site for sandpipers and dunlin. This is done to deflect the loss of 2.5 hectares of the best quality and density of biofilm at Roberts Bank. This loss cannot be mitigated. Effects on coastal birds will not be negligible Negligible Effects Biofilm Consumption and Variable Diet Composition of Western Sandpipers (Calidris mauri) during Migratory Stopover Catherine B. Jardine, Alexander L. Bond, Peter J.A. Davidson, Robert W. Butler, and Tomohiro Submitted May, 2014 and published online, April 14, 2015 Widening of the Causeway and building an island in the estuary will impact coastal birds. It is erroneous to state otherwise. This section is seriously flawed as it fails to identify valued ecosystem components that are critical to the interactive, interdependent systems at work here that provide feeding and resting areas. Changes to one area impact the whole area. CEAA needs to request that the Proponent revise this section and identify the serious impacts and implications of those impacts The same subjective type of information was presented in the environmental assessment of the Deltaport Third Berth and comments of concern by federal and provincial agencies were TOTALLY IGNORED. This same cavalier process must not be repeated. It ignores due process and the Precautionary Principle. 12

13 Changes in Water Quality will impacts interactive ecosystems at Roberts Bank Salinity Residual Cumulative Effects Note that there is admission here that changes in water quality may influence the productivity of the coastal birds sub-components. Then the seriousness of the potential impacts is side-lined with questionable modeling. This section needs to be scientifically challenged. The work of consultants, commissioned by the Proponent, is not quality controlled. It is not peer-reviewed and it is not published scientific documents. Therefore, reports from consultants must be challenged when they are used to presents hypotheses as facts. Some of the referenced reports come with disclaimers stating there are no guarantees of accuracy or completeness. This raises flags that CEAA needs to address. The impacts from the change in water quality could alter all the interactive, interdependent environmental processes at Roberts Bank. This is a very serious issue. Residual Project-related effects are anticipated to be limited to the permanent loss of subtidal foraging habitat for diving birds. The Project is not anticipated to result in a significant residual adverse effect to coastal bird productivity. These statements are contradictory nonsequitur. This effect is not anticipated to significantly affect coastal bird sub-component productivity or long term viability and we know this how? Many sub-standard reports were accepted by CEAA for the environmental assessment of the Deltaport Third Berth. This should not be repeated in this. It appeared during the of the Deltaport Third Berth that CEAA and the Agencies were working for the Proponent against the public. This is the perception as all input was disregarded. CEAA and the Agency bosses rubber- stamped the Project even though their own experts raised serious concerns. The lawyers from the Department of Fisheries and Oceans even advised the port how to avoid a full cumulative effects assessment. They assisted the port in writing a letter to achieve this purpose. This kind of bias must not influence this process. The public should not have to wade through pages of unsubstantiated claims by consultants who are paid by the Proponent. This is the lack of due process and failure to provide technical information so that the public can provide input in a meaningful way. The Precautionary Principle is missing. The Boundary Bay Conservation Committee raised the issue of the failure of the Deltaport Third Berth environmental assessment with the seriously flawed 13

14 Monitoring and Follow-Up Programs Residual cumulative effects were considered negligible What is anticipated and considered cannot be presented as factual. The opinions of paid consultants who produce unscientific, unpublished documents cannot stand as evidence of no harm to the valued ecosystem components at Roberts Bank. The potential for irreversible destruction of the varied, interactive, interdependent ecosystems at Robert Bank is high. This could lead to a loss of vital feeding areas for migratory birds of the Pacific Flyway at Canada s number one Important Bird Area. These measures have no enforcement. Agencies do not have budgets to monitor port activities. Consultants are paid by the Proponent so there is a credibility gap. The result is lip service to follow-up. selection of bird species Valued Ecosystem Components. The selection failed to adequately represent the Roberts Bank ecosystems. This led to flawed conclusions about the impact of the project. There was a lack of information on numbers of individual species of birds making it impossible to critically evaluate the information. Technical Study 6 on Waterfowl and Coastal Seabirds did not include assessment of cumulative effects The same process is being permitted here. As for monitoring, the Project Reporting Updates from the Port s consulting firm, have been characterized by a government agency as grossly incomplete (despite repeated input over the last two years) ( acquired through Access to Freedom of Information) Marine Fish Effects Assessment Importance of the Fraser River Estuary Section 13.1 Component Overview Provide more specifics here about the valued ecosystem components of the Fraser River Estuary. Provide a more detailed summary of the local and global significance of this estuary and its importance to fish populations: It is British Columbia s greatest estuary; the Fraser River is the largest stream in British Columbia. It has global recognition of the estuary as a wetland of These statements reveal the importance of the Fraser River Estuary compared to the which states: Marine fish in the Fraser River estuary are of high ecological, social, cultural and commercial value It is pathetic that a Canadian Environmental Assessment document does not recognize the 14

15 Components and Sub- Components 13.2 international significance. The Fraser River Estuary is the largest on the Pacific coast of North America (21,703 hectares). The intertidal wetlands, alone, cover roughly 17,000 hectares. The freshwater flows from the river are so great that, technically, the entire southern Strait of Georgia is an estuary. More than two billion juvenile salmon spend days, weeks or months in the estuary before going to the ocean most of any river in the world A key feature for the Fraser is that there are about 17 million tonnes of nutrient-rich sediment that pass through and deposit on the delta and into the Strait of Georgia each year (McLean and Tassone 1991). This is in addition to 2-3 million cubic meters of coarser sand. It is the largest salmon producing river along the Pacific Coast. This approach does not do justice to the 80 species of fish and shellfish that spend at least part of their life-cycles in the estuary. Include more specific information on species from an ecosystem approach. Fragmented bits of information, with doubtful scientific integrity, do not adequately assess the fish species that depend on the complex interactive and interdependent processes in the estuary. significance of the Fraser River Estuary. What is the matter with our Governments and Agencies who appear to work for Proponents rather than the public interest? Permitting the Proponent to avoid recognizing the unique values of this world-renowned river estuary is lack of due process. Isolating species, that consultants think don t need Robert Bank, is avoidance of an ecosystem approach. All the species depend on the whole ecosystem. The attempt to make a case that you can destroy a huge chunk smack in the middle of the estuary with impunity defies common sense, let alone the science of ecosystems. 15

16 Explaining why sockeye salmon is not chosen as even a representative species is ludicrous. The Fraser River is famous for sockeye salmon which rely on a healthy estuary. Existing Conditions 13.5 This section lists past projects that have created existing conditions but does not describe how those projects have affected the fish. This section needs to include the fact that migrating fish have to travel greater distances due to the obstruction of Deltaport and the ferry terminal. The flawed design failed to place culverts or similar structures that would have allowed fish to travel under the causeway instead of having to go all the way around the port. With the current route, the fish are more susceptible to predators and they lose access to near shore feeding. Red arrows show paths fish have to follow Yellow arrows show path that the fish need If the causeway had been constructed allowing water to flow underneath, it would have assisted the fish in having easier access to near shore feeding. Courtesy of Marvin Rosenau, B.SC., M. Sc, D.Phil., Aquatic Values and Concerns Regarding Habitat in the Fraser River Estuary Associated with Human Activity and Develop B.Sc., M.Sc, D.Phil ment. Parkfest 2012 B.Sc., M.Sc, D.Phil 16

17 Expected Conditions Future Conditions with the Project This section just doesn t make sense. It is contradictory and makes unacceptable claims. A lot of statements are made here with nothing to support the strange message. This section is critical to the and yet it is basically incomprehensible. Credible scientific information is needed here, not a stream of consiousness writing tossing around the language of requirements of an. Apply the Precautionary Principle It is not acceptable to present expectations. The statements contradict reality. To state projects and activities at Robert Bank will not influence changes but the natural environment and physical processes will??????? The public deserves better than this kind of convoluted presentation of expectations??? The rationale here is the need for ethics, due process, and credible science. Future conditions Mechanisms Affecting Productivity The flawed design of Deltaport will act cumulatively with Terminal 2 to negatively impact migrating fish sending more juvenile salmon out to sea rather than allowing easy access to productive feeding grounds. This is a serious disruption to fish movement. In addition, the fish will be more susceptible to predators. Terminal 2 will act like a dam across the estuary. Courtesy of Marvin Rosenau, B.Sc., M.Sc, D.Phil Aquatic Values and Concerns Regarding Habitat in the Fraser River Estuary Associated with Human Activity and Development. Parkfest

18 Marine Species at Risk Cumulative Effects on Marine Fish Section Include section to show adherence to protection of endangered species under the Species at Risk Act : Endangered Fraser River Eulachon Threatened White Sturgeon Special Concern Green Sturgeon Show how the Precautionary Principle is being applied to protect these species. In this section, list and include specific information on cumulative effects of past developments. The effects should include, but are not limited to : Causeway blockage interfering of natural marine and Fraser River plume water Causeway blockage causing interference of natural sediment movements Causeway blockage causing interference of fish movements and salmon migrations Causeway alteration of water quality so as to interfere with the natural freshwater saltwater estuary mixing and salinity regimes. Creation of unnatural habitat and resulting in growth of exotic biota in the inter-causeway area. Loss of the Roberts Bank marsh platform due to loss of sediment replenishment Direct loss of the sub-tidal habitat in a large area and the key water column living space in the estuary. At no time was this compensated for in any manner. Compensation for such a loss is indeed near impossible. Concerns for the protection of these species at risk have not been adequately addressed. Construction of Terminal 2, widening of the causeway and impacts in the Salish Sea from Shipping will further impact the habitats of these species. They cannot be ignored. Most of the Fraser River Estuary and the Roberts Bank part is committed to, and designated, as part of the Fraser River Delta Ramsar Site, a Wildlife Management Area and a National Wildlife Refuge Alaksan National Wildlife Refuge. The high wildlife and fishery values of this area are totally incompatible with any expansion of any causeways or fill or industrial activity in this area. Developments to date on Roberts Bank have done tremendous damage to the Fraser River Estuary. That includes habitats, blockage of fish and wildlife migration, blockage of water currents and sediment transport and ongoing spills and discharges into the estuary. Despite expansion of facilities at Roberts Bank over the years, no real attempt has been made to restore lost habitat areas or compensate for the loss of habitats other than largely ineffective and token measures. To continue to cut off vital pieces of the small 18

19 Dredging of adjacent mudflat areas for fill and then subsequent erosion has greatly degraded the mudflat environment to double that of the fill areas. Shallow water habitat has indeed been converted into deep water habitat unnatural in that area and generally of less overall productivity in that part of the estuary. No effort made to address water movement through the causeway as part of RBT1 development and then widened in later years. No plans in place to address that very same issue despite much more science and above all much more ongoing development at the site. Spill and coal dust problems on private property and in fish habitats. Light and noise problems affect quality of life and property values up to 10 km away. Ongoing noise 24 hours a day destroys solitude at even Point Roberts Marine Park. The further expansion of Roberts Bank port facility will probably cumulatively add to or exacerbate most if not all of the above environmental setbacks which are undermining the very survival of the Fraser Estuary as a habitat area of international significance for fish, especially salmon, and migratory bird populations. No comprehensive cumulative impact review of all works in the estuary to determine where is the remaining parts of the marshes and mudflats and sub tidal habitat areas is rather unfathomable in 2012 considering 150 years of losses and degradation in the estuary. Often when a development is proposed for yet another piece of the estuary and they run into public opposition, the developer most often says, do the fish and ducks and the environmentalist have to have everything? The simple answer is yes - the fish and wildlife should have all of what is remaining in that 80% of most key habitats have been destroyed or irreversibly degraded. Constant new development cannot be at the expense of the few remaining pristine habitat areas. If anyone including PMV and governments are serious about any form of environmental sustainability, how can any further losses of the estuary be tolerated let alone on the most compromised delta frontage area i.e. Roberts Bank. Any further expansion at this time is simply putting in an entirely new batch of nails into the coffin of salmon and wildlife and the social and food benefits humans derive from those natural wonders that greatly enhance their quality of life in an urban environment and helps define what it is to be from British Columbia. The original Roberts Bank port and expansions have 19

20 balance point in terms of development / conservation and when will we reach the tipping point and eventual overall ecological collapse in the estuary? Such a study would take years to do and is beyond the grasp and capability of PMV, MOE, EC and DFO to do. (courtesy of Otto E. Langer MSc, Fisheries Biologist/Aquatic Biologist) been the greatest environmental impacts to the Fraser Estuary since some of the original dyke alignments and jetties were put in place many decades ago. Looking at the review process PMV has initiated, one can only question why in 2015 would anyone be proposing to double the port facility and expect many of use to live under the illusion that the impact will be minimal or be compensated for and it is just a matter of going through the EA process and the permits will fall into place. The callous disregard for environmental sustainability by PMV and the governments is astonishing and above all immoral as related to our living resources that we must make a final stand to protect before it is too late. Here we are not looking at something that can be mitigated or compensated for it s a matter of certain and massive habitat permanent destruction and no consultations, environmental review or stacks of consultant studies will make it acceptable. Sugar coatings on this project will not work! The remaining parts of Fraser River estuary cannot continue to be seen as an industrial land bank or a bologna sausage where you cut off slices until our children are left with nothing more than the sausage string! Future generations will suffer as this cumulative environment debt is passed onto the next generations. Will our grandchildren know what we had in 1960 or 20

21 in 2012 by 2030? The societal memory is very short in terms of what we had and the present level of living resources continues to be represented by a moving baseline that we are fooled into believing is all that we have to maintain. Residual Effects Section There is going to be a loss of forage fish and flatfish but that s okay because they are expected to recover. And if they don t? What kind of science is this? Anyhow they are insignificant like every other impact in the whole so it s not important. We need a translation of the statement: When this residual effect is considered in combination with potential effects from other future projects and activities (that are certain and reasonably foreseeable), no residual adverse cumulative effects to marine fish productivity are predicted within the CAA. (courtesy of Otto E. Langer MSc, Fisheries Biologist/Aquatic Biologist) Non-sequitur This section is an insult to the public. Monitoring and Follow-Up Programs These measures have no enforcement. Agencies do not have budgets to monitor port activities. Consultants are paid by the Proponent so there is a credibility gap. The result is lip service to follow-up. Environment Management Plans should be included in the process, not just promised as future solutions to all As for monitoring, the Project Reporting Updates from the Port s consulting firm, have been characterized by a government agency as grossly incomplete (despite repeated input over the last two years) ( acquired through Access to Freedom of Information) Management Plans have no credibility and no means 21

22 problems. of proper enforcement. Follow-up on commitments don t work. There is no time or money for Agencies to ensure the plans are adequate or enforced. Follow-up commitments become broken promises behind closed doors which the public never hears about. There is no transparency on follow-up programs. Please add as many rows as necessary 22