Request Number IR1-11: FRPD309. Information Request

Transcription

1 Request Number IR1-11: FRPD309 Information Request 1. If real production data are available for the trailing arm suction hopper dredge FRPD 309, assess whether the use of this equipment would be a technically and economically feasible alternative means. Clearly state the criteria used to assess technical and economic feasibility. 2. If this alternative is considered to be technically and economically feasible, briefly assess the potential environmental effects of this alternative on valued components that could be affected by this alternative. 3. Evaluate whether the use of the FRPD 309 alternative could be considered as the preferred alternative means. VFPA Response 1. If real production data are available for the trailing arm suction hopper dredge FRPD 309, assess whether the use of this equipment would be a technically and economically feasible alternative means. Clearly state the criteria used to assess technical and economic feasibility As described in the VFPA s response to IR1-06, the alternative means analyses were conducted in accordance with the CEA Agency Operational Policy Statement (OPS) Addressing Purpose of and Alternative Means under the Canadian Environmental Assessment Act, 2012 (the current OPS). The methodology first requires an analysis of whether an alternative is technically feasible and economically feasible. An alternative needs to meet all technical criteria to be considered technically feasible, and if all technical criteria are met, then economic feasibility is considered. An effects assessment, within the scope of an alternative means analysis, is only conducted on alternatives that are deemed to be technically and economically feasible It should be noted that in the EIS and this response, the VFPA makes reference to specific pieces of equipment, such as Fraser River Pile and Dredge s (FRPD s) Columbia, FRPD309, or Titan, for the purposes of environmental assessment only (i.e., preparation of the EIS, including description of the Project). For the procurement and actual construction of the Project, the VFPA intends to allow contractors to propose and use alternative pieces of equipment, provided these pieces of equipment meet the Project s objectives, constraints, and requirements. Sufficiency Information Request #11 (IR1-11) Page 1

2 The FRPD309, FRPD s newest dredge, entered the B.C. region in late 2013 for trials, and since then has been performing the annual Fraser River maintenance dredging, thereby replacing the aging Titan. It has proven itself to be both technically and economically feasible to perform this task. The reason the FRPD309 was not considered in the EIS is simply that the FRPD309 did not exist locally when the technical analysis for the EIS was prepared. When the FRPD309 entered the local market in late 2013, the VFPA considered revising its analysis to take it into account; however, reliable production/operation data to perform a re-analysis was not available in advance of EIS preparation. As a result, the FRPD309 was mentioned in EIS Section as a potential alternative, and the construction methodologies and environmental assessments, which were based on the older FRPD Titan and an unspecified second dredge being used for reclaim dredging at the Intermediate Transfer Pit (ITP), were not changed. The incorporation into the preliminary construction schedule of older and smaller dredges provided for a more conservative environmental effects assessment The technical criteria that was considered in the evaluation of dredging equipment alternatives included the following: The equipment has sufficient dredging depth capability; and The equipment has pump ashore capability Economic criteria considered in the evaluation included equipment efficiency, in terms of both acceptability of operating costs and schedule implications With FRPD309 s pump ashore capability, large hopper size, and acceptable dredging depth capability, the FRPD309 is a technically and economically feasible alternative for use as the second dredge during sand reclamation from the ITP. Table IR in Appendix IR1-11-A summarises the feasibility analyses conducted for the FRPD309 and other dredges that were previously assessed in the EIS. 2. If this alternative is considered to be technically and economically feasible, briefly assess the potential environmental effects of this alternative on valued components that could be affected by this alternative The FRPD309 is considered a suitable alternative dredge for reclaim dredging of the ITP (replacing the second unspecified dredge). A comparison of the potential environmental effects associated with these dredges is provided in Appendix IR1-11-A: Table IR Sufficiency Information Request #11 (IR1-11) Page 2

3 3. Evaluate whether the use of the FRPD 309 alternative could be considered as the preferred alternative means Based on technical and economic feasibility, and anticipated lower environmental effects for the FRPD309 compared to other local dredges, should the FRPD309 be available for this Project, it would be considered the preferred local alternative under the current Coastal Trade Act constraint, which limits the use of foreign dredges (see IR1-09 response for the alternative evaluation of a foreign dredge). The FRPD309 has the required production capacity to meet the schedule requirement (in concert with the Columbia) as outlined in the EIS for this activity, and, since it is newer, it is assumed to be more efficient and produce less air and noise emissions than other local equipment. Appendices Appendix IR1-11-A Supporting Table Sufficiency Information Request #11 (IR1-11) Page 3

4 APPENDIX IR1-11-A SUPPORTING TABLE

5 Table IR Alternative Analysis for FRPD309 and Other Activity-applicable Dredges Alternatives Considered for Dredging Equipment Technical Evaluation Proven Use for Equipment (sufficient working depth, pump ashore capability) Economic Evaluation Construction Phase Costs Acceptable (operation cost, schedule implications) Feasibility and Supporting Rationale for Rejection of Alternative Environmental Evaluation Comparison of Potential Effects for Key Valued Components Alternative Means Analysis Conclusion Reclaim Dredging of the ITP in Concert with FRPD s Columbia Titan (without pump ashore capability) No Not applicable as not technically feasible. Not feasible, as dredgeate from the ITP requires pumping to the containment dyke areas, and without pump ashore capability this is not possible. Not applicable as not technically feasible. Not a technically feasible alternative. Unspecified second dredge (with pump ashore capability) Yes Yes Feasible Human Health Compared to the FRPD309, air and noise emissions may be higher for the unspecified second dredge (assessed in the EIS), which could be older and less efficient (i.e., generating more noise and air pollution). Marine Fish, Marine Mammals, Coastal Birds Compared to the FRPD309, underwater noise emissions may be higher for the unspecified second dredge (assessed in the EIS), which could be older and emit more noise underwater. Coastal Birds Compared to the FRPD309, noise emissions may be higher for unspecified second dredge (assessed in the EIS), which could be older and emit more noise. Least preferred alternative as air and noise emissions may be higher. This alternative was assessed in EIS (in concert with the Columbia) as no other alternative, such as the FRPD309, was locally available at the time of assessment. FRPD309 (with pump ashore capability) Yes Yes Feasible Human Health Air and noise emissions may be lower than the emissions of the unspecified second dredge. Marine Fish, Marine Mammals, Coastal Birds Underwater noise emissions may be lower than the emissions of the unspecified second dredge. Coastal Birds Noise emissions may be lower than the emissions of the unspecified second dredge. Preferred alternative as the FRPD309 has the required production capacity to meet the schedule requirement (in concert with the Columbia) as outlined in the EIS for this activity, and since it is the newest local equipment, it is assumed to be more efficient, and produce less air and noise emissions. Sufficiency Information Request #11 (IR1-11) Page 1