environmental permitting) should be interpreted by the Panel as a clear message that T2 is not required.

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1 I attended the recent Vancouver Fraser Port Authority (VFPA) annual general meeting and I am concerned and confused with some of their messaging and the information provided at that meeting. Some of what was said at that meeting by their senior management appears to run counter to information in the Roberts Bank Terminal 2 (T2) Environmental Impact Statement. At the AGM the VFPA stated that their vision is to be the world s most sustainable port. I cannot speak to their other port operations, but in terms of their container operations sustainable they are not. Sustainability has three pillars: Economy, Environment and Socio-Community. 1. Economy: They were challenged at the meeting about their container forecasts. They keep claiming that their forecasts are accurate but their own statistics demonstrate this is not the case. The attachment to this provide detailed information on container volumes and forecasts. These give a clear indication that VFPA continually overstates future container volumes - of course to try and justify the construction of a second container terminal on Roberts Bank. In fact if we look at the total picture for Canada West Coast container terminal capacities (see attachment) we see that by 2020 or thereabouts the West Coast will have added another 3 million in container capacity (TEUs), giving a total capacity on the west coast of more than 8 million TEUs. When we compare that with the actual volumes handled on the West Coast in 2016 of 3.7 million TEUs (of which VFPA handled only 2.9 million), this demonstrates that T2 is not needed in the foreseeable future. In fact VFPA management in answering questions at the AGM admitted that they are now delaying the need for T2 until the end of the next decade. Clearly there is no business case. VFPA always claimed that they would only move forward with this project if the private sector (i.e. operators) viewed it as viable. But: 1. It is now 2 years since the Request for Qualification process started (June 2015) and almost 1.5 years (end Jan 2016) since the shortlisted parties were announced and VFPA has still not identified a private investor that is willing to undertake the project. 2. VFPA claimed that they would finalize the selection of the Terminal Operator by end 2016 (not achieved) and have selected the Infrastructure Developer by the end of 2017 (process not even launched yet). Why is VFPA continuing to spend millions of dollars on a process for which no private entity has ever indicated serious interest? This lack of interest seriously undermines VFPA's claim that T2 is actually necessary. Terminal operators around the world regularly invest (and seek out their own environmental permitting) in projects where there is a demonstrable requirement for additional capacity. The lack of operators even willing to bid for this project (even with VFPA doing the

2 environmental permitting) should be interpreted by the Panel as a clear message that T2 is not required. Furthermore the admission at the AGM that VFPA relies on handling significant volumes of US containers for its forecasts identifies a further risk when viewing what is happening at US west coast ports. Seattle Tacoma volumes are up 8 percent and Los Angeles/Long Beach up 7.5 percent, much higher than VFPA container growth. Seattle Tacoma are on a rapid expansion path and will have a 6 million container capacity by This is another clear indication that a T2 that relies on significant US volumes is not likely to succeed. 2. Environment Then there is the question of environmental damage. At the AGM VFPA ducked questions on the potential damage to the Roberts Bank ecosystem. Is the Panel aware that VFPA have embarked on sampling and analyzing biofilm on Roberts Bank? This renewed effort - over a year after they supposedly completed their environmental assessment - is ineffectual and much too late. Oddly only now are they waking up to the need for analyzing samples for biofilm diatom species composition and their critical nutritional (Omega-3 - fatty acid) value to shorebirds. Years after the VFPA proposed adding a second container terminal in the heart of the richest and most diverse estuary in the whole of Canada are they suddenly realizing the perils. Why now? - Because seemingly, thanks to independent science, they are aware that the public and other agencies (including the Review Panel?) have cottoned onto the huge risk that T2 could endanger an entire species of migratory shorebirds, western sandpipers, as well as undermine commercial salmon fisheries and other wildlife. Equally why use consultants paid by the port to carry out this complex work, when there are plenty of renowned independent researchers here in Canada, Japan and Europe that could give an independent assessment at less cost? As we have seen previously, in-house studies paid for by the VFPA are not going to give anything other than a self-serving perspective. There are an increasing number of published peer-reviewed scientific papers that demonstrate just how important biofilm is to shorebirds and how this particular biofilm is sensitive to the changes in salinity and currents that would be created by T2. Not only that but if built T2 and its widened causeway would cover over part of this important biofilm. The Review Panel's decision should be clear: the removal of the omega-3 content of this unique biofilm is either the nail in the coffin for T2, or for Western Sandpipers. Current Port efforts are a forlorn hope that they can somehow show that T2 will not cause the degradation that we know is likely to be the case. The precautionary principle has to be applied, this international migratory bird and wildlife area is much too important to risk its degradation by port development. Last but not least the endangered Southern Resident Killer Whales (SRKW) are known to be in serious trouble. Their numbers have decreased by 7 in the last year

3 alone. The moves taken by the Port such as its echo program are insignificant and ineffective when compared to the plight of this endangered species. T2 and its related vessel operations will cause the SRKW further stress, will further endanger their main food source, and there is every likelihood that this species will go extinct. That would be a real feather in VFPA's cap. 3. Socio Community At the AGM VFPA admitted that there are still more numbers of empty port semitrailer rigs than there should be moving to and from its container terminals. The reality is that Lower Mainland communities, Delta and Richmond in particular, simply cannot handle any more trucks on the roads. It is port trucks that are a significant cause of massive line ups and traffic congestion, for example at the George Massey Tunnel. Delta and Richmond cannot absorb the thousands of additional truck trips that T2 will generate. VFPA has failed totally in investing in alternatives to container trucking to and from its terminals. They have done nothing to promote short haul rail or short sea shipping and continue to be lukewarm to the concept of inland terminals, such as the one at Ashcroft in BC. In fact at the AGM the VFPA CEO said that they want more port-trade enabling land close to its terminals and expressed concern that some distribution and logistics operations are moving to places like Calgary because there is a lack of port industrial land in the Lower Mainland. This is exactly what should be happening. There is no need for distribution and logistics centres to be located adjacent or close to marine terminals. Ports elsewhere in the world understand this why is it so difficult for VFPA to understand? Is it simply empire building at community expense? Time for the Port to wake up to independent modern science, withdraw their doomed Roberts Bank T2 application and make amends for their eco-destruction elsewhere in the delta. Time for the Port to start walking their talk and assume the new mantle of sustainable environmental leadership that Canadians expect. Roger Emsley < address removed> This and any attachment(s) may contain confidential and/or proprietary information and is solely for the attention of the intended recipient(s). If an error in its addressing or transmission has misrouted this , please immediately notify the sender. If you are not the intended recipient you should delete this and may not save, copy, distribute or in any other way make use of the information that is contained or attached.

4 There is No Need for a Second Container Terminal at Roberts Bank, B.C. June 11, 2017 Port of Vancouver Lowest Case Container s Are Not Being Realized The Vancouver Fraser Port Authority, known as the Port of Vancouver, claims there is a pressing need for investment for additional container capacity at the Port of Vancouver just to keep pace with projected growth demand. Six studies from 2006 to 2016 consistently present inflated growth forecasts. Even the lowest case forecasts are not being met as shown in the Table below. Year Port of Vancouver Container Traffic Studies, Lowest Case s and Actuals Deltaport CSR 2006 Worley Parsons 2011 OSC 2012 OSC 2013 OSC 2014 OSC 2016 Actual Total TEUs million TEUs million TEUs million TEUs million TEUs million TEUs million TEUs million TEUs Sources of Data: Deltaport Third Berth Project: Comprehensive Study Report (CSR), July 5, 2006 page 37. Preliminary Container Traffic Projections for PMV, 2011 to 2030, WorleyParsons, May 27, Page 10/15 PMV Container s, Ocean Shipping Consultants Report, 2012, Page Container Traffic Study, Ocean Shipping Consultants Report, 2014, page Shipping-Consultants-June pdf Container Traffic Study, Ocean Shipping Consultants Report, 2016, page

5 The Vancouver Fraser Port Authority (commonly called the Port of Vancouver) presents Figure 2-4 in the Environmental Impact Statement of the Roberts Bank Container Terminal 2 Project, page The figure is a graph of BC west coast container forecasts and capacity. The source of information is documented as Ocean Shipping Consultants, There is no table or properly identified data. A similar graph, copied below, is presented on the website of the Port of Vancouver. It is an updated version of the EIS graph from the Ocean Shipping Consultants Report, Both reports show outdated information on capacity as there have been expansions, upgrades and improved efficiencies at the BC west coast ports. The planned expansion at Centerm is 900,000 TEUs which is not accurately shown on the port graph. Also, the Prince Rupert expansion, identified as Stage 2, is planned to add 1.05 million TEUs for a total capacity of 2.4 million TEUs. The following graphs and tables show actual container business on the B.C. West Coast and ongoing expansions and upgrades which will provide sufficient container capacity for decades without constructing the expensive Roberts Bank Container Terminal 2. 2

6 million TEUS B.C. West Coast Container Capacity and Actual TEUs Terminal 2 Centerm Expansion and Prince Rupert Phase 2 Prince Rupert Phase 2 North & Deltaport Rail Prince Rupert Actual TEUs Port of Vancouver Actual TEUs Capacity according to Port Vancouver with Terminal 2 Documented Capacity without Terminal 2 Sources of Data: Prince Rupert: Evolution from remote fishing port into critical container shipping, Fig.2 Port of Vancouver, Reporting, Statistics and Resources, Overview West Coast Capacity According to Port of Vancouver with Terminal 2, 2016 Container Traffic Study, Ocean Shipping Consultants, 2016, Page 113, Table Canada s West Coast Container Capacity by 2020 Without Terminal 2 Sources documented in Appendix A Terminal TEU Capacity Expansions and Improvements TEU Capacity Deltaport 1,400, , , , ,000 3,000,000 Vanterm 850, ,000 1,000,000 Centerm 900, ,000 1,800,000 Fraser Surrey 150, ,000 Vancouver Total 3,300,000 5,950,000 Prince Rupert 500, ,000 1,050,000 2,400,000 West Coast Total 8,350,000 3

7 The container business at the Port of Prince Rupert Port is growing rapidly showing a Compound Annual Growth Rate (CAGR) of 20.5% since it opened in 2008 to Year Prince Rupert Actual TEUs During the same 8 years, the container business in Vancouver grew at a CAGR of 2.05%. The Vancouver container business grew rapidly at a CAGR of 10.73% from 2000 to 2007 when the container business was becoming a new method of shipping worldwide. Since 2007, the Vancouver container business has levelled showing a CAGR of 1.82% in the last 9 years. Table: Vancouver Container Business (TEUs) Year Vancouver Port Authority TEUs Fraser River Port TEUs Total TEUs Vancouver Fraser Port Authority The container traffic forecast reports, commissioned by the Vancouver Fraser Port Authority, forecast an unrealistically- high growth rate for the Vancouver container business when compared to actual growth of the past 8 years (2.05%). The forecasts of the 2016 Container Traffic Study by Ocean Shipping Consultants (OSC) show Compound Annual Growth Rates of 3.3% to 5.11% for the next 14 years (2016 to 2030): CAGR: 3.32% Base Case CAGR: 4.04% High Case CAGR: 5.11% Even at the Growth, which is not being realized, Vancouver has sufficient capacity until The Vancouver Fraser Port Authority claims the planned Container Terminal 2 will be needed by As shown on the graph below, even at a CAGR of 3.5 %, more container capacity at Vancouver will not be required for decades. 4

8 Container Business s and Capacity at the Port of Vancouver, June, 2017 million TEUs Container Growth s and Capacity at the Port of Vancouver Ocean Shipping Consultants Report 2016 Compared with Actual TEUs and Documented Capacity Terminal Actual Documented Capacity Without Terminal Capacity claimed by Port OSC 2016 s OSC 2016 Base Case s OSC 2016 High Case s Actual TEUs Documented Capacity Capacity according to Port CAGR 3.5% growth Table: Container Business s and Capacity at the Port of Vancouver Year OSC 2016 Low Case OSC 2016 Base Case OSC 2016 High Case Actual Total TEUs Compound Annual Growth Rate of 3.5% going forward Capacity according to published information without T2 Capacity according to Port Vancouver With T

9 Appendix A: Sources of Data Port of Vancouver Container Business s 1. Container Traffic Study Port of Vancouver, 2016 by Ocean Shipping Consultants Page 113 Deltaport, Roberts Bank and Vanterm, Burrard Inlet 2. Transport Canada: Pacific Coast Container Terminal Competitiveness Study - TP 14837E, Hanam Canada Corporation; March Productivity Centerm, Vanterm and Deltaport exceed the average productivity of container terminals in the US. Terminal Systems Inc. is adding a third berth at Deltaport to increase capacity from 1.4 to 2.1 million TEUs per year by 2009 and has ordered equipment to increase Vanterm s capacity to over 1.0 million TEUs by Norman Stark, President and CEO, TSI, May 31, Deltaport Third Berth Project, Project Overview, Port of Vancouver, June, The Deltaport Third Berth Project (DP3) was a Port Metro Vancouver and TSI Terminal Systems Inc. initiative to expand existing container operations at the Deltaport container terminal at Roberts Bank. DP3 has increased the capacity of Deltaport by up to 600,000 TEUs (twenty-foot equivalent units) by adding a third berth and 20 hectares of container storage to the existing two-berth container terminal. (Page 1/21) 4. Terminal Systems Inc. Global Business; Local Interests; September, Deltaport Terminal, Road and Rail Improvement Project (DTRRIP), Status Project status: The first component of the Deltaport Terminal, Road and Rail Improvement Project (DTRRIP) the causeway overpass was completed in November The new overpass separates road and rail traffic, improving the flow of trucks and trains accessing the terminal, reducing truck and vehicle idling and increasing safety, as well as contributing an estimated 150,000 to 200,000 twenty-foot equivalent units (TEUs) of additional capacity annually at Deltaport. Construction work to reconfigure the Deltaport Intermodal yard is currently underway and is expected to be complete by Port Metro Vancouver, Project and Environmental Review Report PER No , Global Container Terminals Canada Limited Partnership Intermodal Yard Reconfiguration, Roberts Bank, Delta, B.C. October 8, online.pdf In this second phase of DTRIPP, the new intermodal rail yard at Deltaport will enable the existing marine container terminal to handle an additional 600,000 TEU (twenty-foot equivalent units) annually 6

10 7. Environmental Assessment Report, Deltaport Terminal Road and Rail Improvement Project; Hemmera; November, 2012, bottom of page 276 (Scrolled 299/450) Emissions are calculated based on the Deltaport container terminal reaching a capacity of 3 million TEUs per year by 2020 due to Deltaport improvements (page 276) 8. Projections of Vessel Calls and Movements at Deltaport and Westshore Terminals Deltaport Terminal Road and Rail Improvement Project (DTRRIP), November 28, 2011 Pages 20, 21; 22; 24; 26; 40; 41 Deltaport-and-Westshore-Terminals.pdf Case 1: Deltaport has a sustainable capacity of 2.4 million TEU. Deltaport has maximum capacity of 3.0 million TEU in the interim years of high demand up to about Cases 2 and 3: Deltaport has a sustainable capacity of 3.0 million TEU. (Pages 21&22) Centerm 9. Container Capacity Improvement Program, Update November, 2014; page 3 Update-November-2014.pdf In May 2014, Port Metro Vancouver announced that it is considering design options to increase container capacity at the Centerm terminal in the Burrard Inlet, from its current 900,000 TEUs to as much as 1.8 million TEUs. Fraser Surrey Docks 10. Roberts Bank Terminal 2 Project: Meeting Canada s Trade Demand; Project Rationale; Fraser Surrey Docks container capacity was designed to accommodate up to 600,000 TEUs annually. Due to a combination of the river channel navigation constraints and the world market trend towards larger ships, this capacity has not been realized Fraser Surrey Docks is assumed to have an actual capacity of approximately 150,000 TEUs. (page 21) Prince Rupert Port Authority 11. Fairview Container Terminal Expansion Project Reaches 75% Milestone EFFECTIVE MONDAY, DECEMBER 12, The Phase II North container terminal expansion project, launched in the first quarter of 2015, is now more than 75% complete and is on schedule to increase annual capacity at Prince Rupert s container terminal to over 1.35 million TEUs by the third quarter of Asia Cargo News, February 4, Phase II South - This will take container capacity to 2.4 million TEUs 7