Can hundreds of scientists, including federal government scientists, all the major environmental groups in Canada, fisheries experts, birders, wildlife experts, marine mammal researchers and watchers all be wrong? Can the major Canadian port operator be wrong?

Can all these people and groups be wrong? Can PM Trudeau’s cabinet (acting as Governor In Council) be right when it approved the Roberts Bank Terminal 2 (RBT2) project stating it is “justified in the circumstances”? 

There is still time to right this wrong. RBT2 still needs a fisheries act authorization.
Write to Fisheries Minister Lebouthilier DFO.Minister-Ministre.MPO@dfo-mpo.gc.ca and tell her not to give RBT2 the fisheries act authorization it needs. 

Science, facts and evidence demonstrate RBT2 will denigrate sensitive intertidal habitat critical for the survival of migratory and other shorebirds, with the negative effects cascading all the way up the food web impacting pacific salmon, other fishes, crabs and southern resident killer whales (SRKW). Government scientists told the federal government repeatedly RBT2’s significant adverse environmental effects will be immediate, permanent, continuous, and irreversible and cannot be mitigated. Other scientists independent of government, as well as environmental groups and first nations leaders all agree. 

In approving RBT2 the federal cabinet misled Canadians. At no time have they explained what is justified in the circumstances. Is the path towards extinction for SRKW, the further degradation of salmon stocks and crabs, declines in migratory bird species towards extinction, all justified in building another container terminal on the last remaining natural large intertidal bank in the Fraser Estuary?  

The federal cabinet never looked at the RBT2 economics and they ignored the significant adverse environmental effects. Why? What was it that caused these cabinet ministers to go against all the environmental evidence? Why did they ignore the economics? Is there something being hidden from the public?  Why has the federal cabinet never said exactly what is justified in the circumstances?

Are there entities that stand to gain influencing cabinet ministers in ridings held by cabinet ministers? Why did Ministers Wilkinson, Sajjan and Champagne all support RBT2 going against all the scientific evidence? Why did Minister Qualtrough, the MP for Delta, not oppose RBT2?

When governments make decisions based on science, facts and evidence, having respect for the environment, Canadians can expect our ecosystems and biodiversity to survive and once again thrive.

For more information visit www.againstportexpansion.org 
or email info@againstportexpansion.org

The Trudeau federal cabinet (acting as governor in council) approved the Roberts Bank Terminal 2 Project in April 2023 as “justified in the circumstances” despite the mounds of evidence that this project will be an environmental catastrophe. 

How can the Trudeau government be trusted when it continues to ignore science, national and international environmental and other groups? Here is what the government’s own scientists told the federal cabinet:

“Environment and Climate Change Canada characterizes the Project's residual adverse impacts on biofilm due to predicted changes in salinity as potentially high in magnitude, permanent, irreversible, and, continuous. ECCC's confidence in the EIS's predictions is characterized as low (IBID). In particular, impacts to biofilm could potentially implicate the long-term viability of Western Sandpipers as a species (IBID). ECCC similarly characterizes impacts to Western Sandpipers as potentially high in magnitude, permanent, irreversible, and continuous”.

(see https://iaac-aeic.gc.ca/050/documents/p80054/121632E.pdf). 

Science, facts and evidence led the following groups and entities to all oppose Roberts Bank Terminal 2.

BC NATURE

https://bcnature.org/roberts-bank-3/

GEORGIA STRAIT ALLIANCE

https://georgiastrait.org/press/roberts-bank-terminal-2-opposition-demands-answers-from-governments-on-expansion/ 

RAINCOAST CONSERVATION

https://www.raincoast.org/2023/07/science-protecting-biodiversity-fraser-river-estuary/

https://www.raincoast.org/2023/05/legal-challenge-federal-government-terminal-2/ 

BIRDLIFE INTERNATIONAL

https://www.birdlife.org/news/2020/12/16/waterfowl-winter-refuge-fraser-river-delta-risks-being-lost-forever/

https://datazone.birdlife.org/site/factsheet/boundary-bay--roberts-bank--sturgeon-bank-(fraser-river-estuary)-iba-canada

BIRDS CANADA

https://www.birdscanada.org/federal-government-fails-to-protect-birds-and-biodiversity-with-rbt2

https://www.facebook.com/watch/?v=649261319449556 

WILDERNESS COMMITTEE

https://www.wildernesscommittee.org/news/conservation-groups-are-back-court-protect-southern-resident-killer-whales-devastating-impacts

NATURE CANADA

https://naturecanada.ca/news/press-releases/roberts-bank-terminal-2-opposition-demands-answers-from-governments-on-expansion/?

ILWU

https://bc.ctvnews.ca/longshore-union-sides-with-environmental-groups-opposed-to-delta-terminal-expansion-1.6441720

LUMMI FIRST NATION

https://www.cascadiadaily.com/2023/jun/07/lummi-nation-canada-failed-to-fulfill-duties-in-bc-terminal-project/

FRIENDS OF THE SAN JUANS

https://sanjuans.org/?s=Roberts+Bank+Terminal+2

UNION OF BC INDIAN CHIEFS

https://www.ubcic.bc.ca/ol_roberts_bank_terminal_2_development_approva

AGAINST PORT EXPANSION IN BC

https://www.againstportexpansion.org/news/#RBT2%20-%20both%20an%20economical%20and%20environmental%20disaster 

LETTER FROM 12 SCIENTISTS 

https://fraserestuary.scienceletter.ca/press/

https://fraserestuary.scienceletter.ca/resources/

https://fraserestuary.scienceletter.ca/letter/

The scientists said it best:

“If the recovery of Canada’s endangered and iconic wildlife is a priority for the government of Canada, as stated, then it must reject the proposed Terminal 2 project”. 

So why did the Trudeau cabinet ignore all this evidence and every major environmental group when it approved RBT2?

Ask the politicans.

Write to:

Prime Minister Trudeau pm@pm.gc.ca
Environment Minister Guilbeault - ec.ministre-minister.ec@canada.ca
Trade Minister Ng - Mary.Ng@international.gc.ca
Global Affairs Minister Joly melanie.joly@international.gc.ca
Fisheries Minister Diane Lebouthillier DFO.Minister-Ministre.MPO@dfo-mpo.gc.ca

Sandpipers' Last Supper is a documentary now in production. It tells the story of the Western Sandpiper’s (WESA) long distance migration and the biofilm in the mud on Roberts Bank that is critical to the WESA survival.

Read about the film here, those involved and how you can help.
https://sandpiperbiofilm.com/

"Justified in the Circumstances" is how Trudeau's federal cabinet gave its approval for the Roberts Bank Terminal 2 (RBT2) project, ignoring its own government scientists who have proven, along with independent scientists, expert in wetlands and wetlands ecology, that the significant adverse environmental effects will be catastrophic They documented their findings in peer-reviewed science journals, characterizing the RBT2 negative impacts as immediate, permanent, continuous, irreversible and unable to be mitigated. 

It is in nobody's interest that RBT2 gets built at a cost likely to exceed $6 billion and making it the most expensive terminal development anywhere in the world. Well almost nobody:

• Certainly not the shorebirds, salmon, other fishes, Orcas, and other wildlife that rely on the Roberts Bank mud for their very survival.
• Not Canada's trade that has better cheaper alternatives to get goods to market.
• Not the longshoremen that stand to lose jobs.
• Not those living close by that will experience even more noise, air and light pollution.
• Not residents and tourists using area highways that will experience even more traffic congestion from ever increasing port semi trailer trucks moving containers in and out.

But there are some who will benefit, including those:

• Who financed and built warehouses on the now paved over rich farmland adjacent to Roberts Bank

• Who will bid to develop the huge new main made island, its cranes and lighting infrastructure, expanded roadways and rail and later operate it, some of which are likely to bid include Chinese government-owned entities.

The most important thing you can continue to do is to raise awareness of the federal government's ridiculous approval of the Roberts Bank Container Terminal 2 (RBT2) project.

Tell your friends, neighbours, work colleagues. Get them to write the federal government and insist that the RBT2 project be scrapped. Write to:

         Prime Minister Trudeau pm@pm.gc.ca
         Environment Minister Guilbeault  ec.ministre-minister.ec@canada.ca
         Trade Minister Ng Mary.Ng@international.gc.ca
         Global Affairs minister melanie.joly@international.gc.ca

Here are some pointers for your email:

Dear Prime Minister and Ministers:

In April 2023 you approved the Vancouver Fraser Port Authority (VFPA) Roberts Bank Terminal 2 (RBT2) project as "justified in the circumstances", even though you acknowledged that the project will result in significant adverse environmental effects.

Can you please explain your justification for the RBT2 project when:

1. It has been proven there is no need for additional container terminal expansion in Vancouver, where there is in excess of 2 million containers (TEUs) spare capacity today.
2. Federal government expert advisors have stated – do not add any more container terminal capacity in Vancouver until Prince Rupert’s container terminal growth has been maximized.
3. Prince Rupert, two sailing days closer to Asia, with a year round ice free port, easy uncongested entrance into the port (unlike Vancouver), and superior access to Eastern Canada and US markets, has expansion ready to go when the market warrants it by providing up to 5 million in additional container terminal capacity at less than half the cost of RBT2 and few environmental concerns.
4. By the time construction starts and RBT2 is completed its cost will have ballooned to over $6 billion, making it the most expensive container terminal development anywhere in the world.
5. Marine access to Vancouver ports via Juan de Fuca and Georgia Strait is already congested and will get worse with additional vessel transits for the Trans mountain Pipeline as well as two LNG terminals.
6. Vancouver port vessel transits pass right through feeding grounds and critical habitat for the already endangered Southern Resident Killer Whales (SRKW) that will result in more vessel noise, more vessel strikes and lead to further deaths of the SRKW already supposedly protected under the Species at Risk Act.
7. With the majority of VFPA container shipments destined for or originating in Eastern Canada and the US the already congested rail and highway routes through the Fraser Canyon and the Rocky mountains simply cannot handle more containerized traffic.
8. Your government scientists provided you with internationally validated scientific proof that RBT2 will result in negative impacts that will be immediate, permanent, continuous, irreversible and unable to be mitigated. 
9. That science predicted RBT2 would destroy the biofilm that supports hundreds of thousands of shorebirds who will lose access to the vital nutrients in the unique biofilm of Roberts Bank and as part of the intertidal food web will have disastrous effects all the way up the food chain.
10. Those same scientists provided you proof that the VFPA plans to mitigate negative biofilm impacts by re-creating biofilm is not feasible and cannot be done on the scale necessary to replace that which will be lost. Yet you then made that as one of your mitigation conditions.

All of this negates any "justified in the circumstances",

I call on you Prime Minister and your cabinet to recognize RBT2 is neither environmentally nor economically justified and I demand you withdraw your approval for the Roberts Bank Terminal 2 project.

And please send copies of your emails to APE at saynotot2@gmail.com.

The Roberts Bank Terminal 2 project is not only an environmental disaster. Economically it spells trouble for Canada as well. 

Justified in the circumstances (the federal cabinet’s rational for approving it) despite significant adverse environmental effects that cannot be mitigated is only part of the disaster. 

The project, if it is ever built, is going to cost in the region of $6 billion, making it the most expensive greenfield container terminal project (on a per container basis) worldwide. But the long term impacts on Canada's economy are the real issue.

RBT2 is the engine that will deliver more Chinese imports into Canada. That means lower productivity for Canadian businesses, fewer manufacturing jobs and great reliance on a vast range of goods that could and should be manufactured in Canada. In turn that means less skilled job opportunities for Canadians. 

Why are we facilitating increased trade with China when it:

• Interferes in our elections
• Spy’s on our governments
• Steals trade secrets and patents
• Supports Russia’s illegal war in Ukraine by buying embargoed Russian oil and supplying them with goods and material used in their war effort
• Harasses and threatens MPs, as well as Canadians and immigrants of Chinese origin
• Applies anti competitive subsidies that then undercut Canadian manufactured products
• Imposes unilateral tariffs, sanctions and embargoes on Canadian exports for no other reason than retaliation. 
• Trespasses on other countries exclusive economic zones and ignores the Permanent Court of Arbitration in The Hague. 
• Wilfully violates WTO trade rules.

Look at the percentage of Chinese imports through the port of Vancouver. China is the ports’ top importer of containerized cargo with 2.5 times more tonnes imported than all other countries combined and representing 2/3 of all imports. 

 Containerized exports to China are 1/3 of what is imported. 

 Why did the Canadian government approve the construction of a new container terminal that will:

• Eliminate more Canadian manufacturing jobs?
• Put more Canadian manufacturers out of business?
• Compete unfairly?
• Help China to give more support for Russia’s war against Ukraine when Canada is spending millions in support of Ukraine?

RBT2 makes no environmental nor economic sense. 

The federal and BC governments must withdraw their project approval, thereby promoting more investment in Canada and Canadian manufacturing and creating more skilled jobs for Canadians.
Tell:
 - Prime Minister Trudeau pm@pm.gc.ca,
 - Enviroment Minister Guilbeault, ec.ministre-minister.ec@canada.ca
 - and MP For Delta, Minister Carla Qualtrough carla.qualtrough@parl.gc.ca

that you want cabinet to revisit its approval for RBT2, based on negative economic impacts for Canada and environmental damage to one of Canada's most important biodiversity areas.

Ecojustice, representing Georgia Strait Alliance, David Suzuki Foundation, Raincoast Conservation Foundation, and Western Canada Wilderness Committee, is in federal court trying to stop the inevitable wildlife destruction were the Roberts Bank Terminal 2 project in Delta BC to ever be built. 

https://www.wildernesscommittee.org/news/conservation-groups-are-back-court-protect-southern-resident-killer-whales-devastating-impacts

In particular this project negatively impacts a critical food source for millions of migratory and other shorebirds, puts wild salmon stocks at further risk and as well may push the already endangered Southern Resident Killer Whales towards extinction.

The Trudeau government's environmental hypocrisy was on full display in the federal court on Tuesday June 25 2024, when according to media reports Attorney General of Canada and Ministry of Environment and Climate Change lawyer Jon Khan told a Vancouver Federal Court that legal arguments raised by four environmental groups ignore the enforcement of 370 mandatory conditions that came with the port expansion’s approval.

Khan told Federal Justice Christine Pallotta that the federal government’s decision was a “discretionary one based on the widest considerations of policy and public interest.”

That public interest includes wider economic benefits — like improving supply chain resilience and boosting international trade — and should lead the court to agree the port expansion approval was “justified in the circumstances,” he said.

“Only the governor-in-council, not this court, is equipped to evaluate such considerations,” Khan told the court.

The government’s hypocrisy comes into play when their lawyer mentions the 370 mandatory conditions that came with the port expansion’s approval.

The problem with these conditions is not only that very few of them have any teeth, but in addition the measures frequently call for minimizing, mitigating or reducing potential effects. In other instances federal government scientists have already proven the measures proposed will not work. Here are a few examples of the ineffectual application of these conditions:

        #5. Light mitigation. The current terminal's lighting already causes problems for surrounding residential areas and as well to wildlife. Complaints are always rebuffed with the explanation that workplace rules require certain levels of lighting. RBT2 adds even more lighting and light pollution will only get worse.

         #7 Offsetting plan(s) related to the alteration, destruction or disturbance of fish habitat, and death of fish. What if the offsetting and further mitigation doesn’t work and the already declining salmon stocks are in even more trouble?

         #8 Economically feasible technologies for reducing underwater noise. What if these don’t work or are not economically feasible? Furthermore these conditions fail to take into consideration the additional vessel traffic from other projects such as the Tilbury LNG terminal and the Trans Mountain pipeline. Underwater noise and its detrimental effects on the Orcas will only get worse.

         #9 No net loss of wetlands. Compensation for wetland loss has not worked up to now and there is no reason to indicate this project will be different.

         #10 Protecting migratory birds and avoid harming, killing or disturbing them. One of its key provisions is to create habitat to compensate for what will be lost. Environment Canada scientists have proven and demonstrated that it is not feasible to create habitat on the scale necessary to replace what will be lost.

What the federal government’s lawyer also failed to mention is that the West Coast supply chain has plenty of spare capacity today, with alternatives for container terminal expansion elsewhere in BC when Canadian trade conditions need it - Prince Rupert for example – where, unlike Roberts Bank, there are few if any environmental issues.

Prince Rupert’s container terminal, two sailing days closer to Asia, has been steadily expanding and is ready to add as much as another 5 million in container terminal capacity when the market needs it. Therefore there is simply no justification to add more container terminal capacity in Vancouver, endangering critically important environmental ecosystems. 

The Governor in Council mentioned by the lawyer is Trudeau's federal cabinet. That Trudeau cabinet ignored its own scientists who told them  “Project-induced changes to Roberts Bank constitute an unmitigable species-level risk to western sandpipers, and shorebirds more generally,”

https://www.nationalobserver.com/2022/02/01/news/feds-quashed-damning-scientific-conclusions-about-port-expansion-birds

These government scientists along with other independent scientists expert in wetlands and wetlands ecology have told the Trudeau government repeatedly that building Roberts Bank Terminal 2 will result in significant adverse environmental effects that will be immediate, continuous, permanent, irreversible and cannot be mitigated. 

Despite this the Trudeau cabinet approved the project as "justified in the circumstances".

This project has been panned by the international media, the latest being two articles in the Seattle Times:

https://www.seattletimes.com/seattle-news/climate-lab/extinction-risk-to-southern-resident-orcas-accelerating-as-researchers-raise-alarm/ 

https://www.seattletimes.com/seattle-news/climate-lab/can-a-tiny-shorebird-stop-the-massive-expansion-of-a-container-port/ 

The UK Guardian Newspaper and the New York Times have also published articles critical of the port expansion.

Not only that but even Canada’s environment commissioner has harshly criticized the federal government’s efforts to help species at risk as “slow and lacking”. Commissioner Jerry DeMarco said poor implementation and application of laws meant to protect species at risk left the job of defending vulnerable species to advocacy groups. 

Canada is yet again in an international embarrassing situation resulting from the Trudeau government’s appalling record in failing to protect endangered environmental ecosystems.

“Can a tiny shorebird stop the massive expansion of a container port?"

That is the title of an excellent Seattle Times article about the Roberts Bank Terminal 2 project which you can read here:

https://www.seattletimes.com/seattle-news/climate-lab/can-a-tiny-shorebird-stop-the-massive-expansion-of-a-container-port/

Here also is a pdf version.

561cbd74-8389-440e-9fa0-e837b2594b28.pdf

In the Seattle Times article the Vancouver Fraser Port Authority (VFPA) states that the port has “plans in place to avoid, monitor and — if required — mitigate any potential impacts stating “This includes locating the terminal in sub-tidal waters, away from sensitive shorebird stopover habitat”.

It is irrelevant that the man made island may be away from sensitive shorebird habitat. It is not where it is but what it does.  As Dr. Elner says, “what are the birds telling us?”

The man made island is already planned to be in sub-tidal waters. But that man made island causes significant adverse environmental effects to the shorebirds' habitat by changing the water temperature and tidal flows and dampening the effects of the fluctuations from salt to fresh and back to saltwater on each tide change. That dampening weakens the salinity oscillation and the diatoms in the biofilm are then no longer shocked into generating rich omega 3 fatty acids. 

Importantly those diatoms impact the intertidal food web, providing essential nutrients all the way up the food chain, from the smallest crustacean all the way up to the largest marine creatures - the whales.  Build that man made island and you weaken the food web such that wildlife populations continue to decline potentially towards species extinction.  It is wilful ignorance and refusal to accept the science that is the crime here. 

Equally the other VFPA mitigations are just as flawed. Government scientists and other independent experts in wetlands and wetlands ecology have proven that omega 3 rich biofilm cannot be created to the extent necessary to compensate for the RBT2 environmental damage. The Brunswick Point biofilm has unique properties and suggesting that biofilm can be created elsewhere, on another bank for example, is flat-earth thinking.

Please share this widely and keep writing to the federal government who have the power to stop this project if we keep the pressure on.

You can write to:

- Steven Guilbeault the federal environment minister at ec.ministre-minister.ec@canada.ca
- MP for Delta Carla Qualtrough carla.qualtrough@parl.gc.ca
- George Heyman BC environment minister at ENV.Minister@gov.bc.ca

One of the conditions (10.4) of approval for the Roberts Bank Terminal 2 (RBT2) project was that the Impact Assessment Agency Canada (IAAC) establish an Independent Scientific Body to provide advice on what are the baseline conditions for the biofilm and salinity on Roberts Bank, to review how the Vancouver Fraser Port Authority (VFPA) plans to monitor them and what impacts RBT2 will cause to biofilm, salinity and Western Sandpipers, as well as to establish threshold exceedences. 

IAAC has now set up the Scientific Body and established its terms of reference. Chaired by Ottawa’s Chief Science Advisor of Canada (who by the way reports to Minister Champagne, an avowed supporter of RBT2) the Body’s has five members in addition to its chairperson. All five of the members are professionals in their field, with three of them coming from universities outside of Canada, one from University of Ottawa and one from University of Calgary. 

You can read the terms of reference here:
https://iaac-aeic.gc.ca/050/evaluations/document/155471

And its membership here:
https://iaac-aeic.gc.ca/050/evaluations/document/155469

In addition to work performed by these five experts the scientific body is permitted to call in external consultants.

The VFPA has long been trying to duck science-based monitoring because they well realize RBT2 will result in significant adverse environmental effects that cannot be mitigated. So if this independent body is allowed to do its work without interference finally RBT2 will be assessed using credible peer reviewed science.

But the question has to be asked, why is Ottawa still spending taxpayer funds on RBT2?

The Roberts Bank Terminal 2 (RBT2) project has no entity bidding to build it, no operator wanting to run it, yet Ottawa is still spending taxpayer funds supporting the project. 

How much will all this work cost? The scientific body has a 36-month term. How much are the five professionals going to be paid? What is the budget for external consultants? With the recent debacle over the $59 million ArriveCan project can we expect Ottawa to better control these costs?

More importantly, why would these five independent professionals, all experts in their field, not come to the same conclusion that government scientists have already proven – being the science, facts and evidence show RBT2 will cause environmental degradation to the intertidal food web that will be immediate, continuous, permanent, irreversible and immitigable?

Furthermore why is the scientific body starting its work when there is no economic justification for RBT2 to ever be built?

The VFPA container volumes declined by over 12 percent year over year, handling fewer containers in 2023 than in 2022 and lower than any year all the way back to 2016. Furthermore full container loads were lower in 2023 than in every year all the way back to 2011 – 12 years of declining container trade volumes.

The fully laden container volume increase between 2009 and 2023 approximates to the 600,000 TEU increase in DP World’s Centerm terminal expansion last year, thus VFPA has as much spare container terminal capacity today as it did years ago.

There is no justification for RBT2 now, nor will there ever be in the future.

If the cost of this independent scientific body is what it will take to abandon the Roberts Bank Terminal 2 project it will have been worth it. But it would be far better if the federal cabinet finally recognized it made a huge mistake in approving the VFPA Roberts Bank Terminal 2 project last year and shut it down, forever. 

THE Narwhal has just published an article on the latest developments, including an update on the two court cases. Read it here:

https://thenarwhal.ca/roberts-bank-terminal-2-explainer/

Canada’s Commissioner for the Environment continues to highlight the ongoing failure of the federal government’s conservation and climate change commitments. Why is this so? Because repeatedly the federal government – and its Environment Minister Steven Guilbeault - ignore science, facts and evidence and bow to corporate pressures to approve environmentally damaging industrial developments. 

Nowhere is this more evident than the federal government’s approval of the Vancouver Fraser Port Authority’s (VFPA) Roberts Bank Terminal 2 (RBT2) project, which they approved almost a year ago (with the BC provincial government approving it several months later). 

The government ignored science, facts and evidence put forward by its own scientists, environmental groups and international experts in wetlands and wetlands ecology, all demonstrating that RBT2 will result in significant adverse environmental effects that cannot be mitigated, destroying wetlands and the intertidal food web relied on by millions of migratory and other shorebirds, as well as salmon, other fishes and marine mammals.

This debacle of a government approved project proposes to add container terminal capacity to a port complex whose volumes declined by over 12 percent year over year, handling fewer containers in 2023 than in 2022 and lower than any year all the way back to 2016. Furthermore full container loads were lower in 2023 than in every year all the way back to 2011 – 12 years of declining container trade volumes.

The approximately 600,000 full loaded container increase between 2009 and 2023 is about the same as the Vanterm terminal's expansion last year. 

VFPA relies on fiction to create its forecasts – claiming that its port complex would see 5 percent volumes increases year over year. The reality is VFPA has not increased its volume of loaded containers for 12 years. And during that time VFPA added almost one million to its container terminal capacity.

VFPA does not have a developer for RBT2 nor an operator, yet it is still proposing to spend over $6 billion of taxpayer funds to build another container terminal that Canada will never need, requiring the federal government to spend even more money on environmental studies and research with no economical or environmental justification.

Loys Maignon's, Canadian Society of Environmental Biologists BC Director, article "Does Science Matter in Canada's Business-minded Fantasy Conservation Policies?" 

Does_Science_Matter_(RBT2).pdf

Read the Nov. 20 community voices article in the Salish Current 

https://salish-current.org/2023/11/20/proposed-roberts-bank-terminal-2-looming-environmental-disaster/

And then send it to your contacts!

It is hard to believe the many failures made by the Federal and BC Governments in approving Roberts Bank Terminal 2.

RBT2_NOT_Justified_and_the_Damage_It_Will_Do.pdf

Here is a list of fundamental errors made in approving this disastrous project:

1. Ignored the science and concerns from its own government scientists.
2. Understated the negative impacts on intertidal biofilm and ignored altogether the scientifically proven salinity trigger that causes diatoms in biofilm to become rich in omega 3 and fatty acids.
3. Ignored the warnings of potential population declines for iconic migratory bird populations, especially the Western Sandpiper, perhaps towards species extinction.
4. Failed to understand that the significant adverse environmental effects will lead to further declines in already endangered Southern Resident Killer Whales, potentially towards extinction.
5. Ignored the fact that the man made island negatively impacts crabs as well as juvenile salmon transitioning from river to ocean.
6. Ignored the negative impacts to First Nations cultural and fishing practises.
7. Approved mitigation measures aimed at recreating biofilm that is lost due to the man-made island, even though government scientists have proven it is impossible to recreate biofilm on the scale necessary to replace that which will be lost.
8. Misread, or ignored altogether, weaknesses in the overall container trade picture and its future growth on the Canadian West Coast.
9. Failed to recognize that the cost of building RBT2 - estimated at $3.5 billion but likely to increase to between $4-6 billion by the time it is completed - makes it the most expensive greenfield port development anywhere in the world and likely economically unsustainable.
10. Refused to acknowledge there are more sustainable, less environmentally damaging, less expensive alternatives that are capable of delivering all the additional container terminal capacity Canada needs within the same time frame as RBT2. 

The inescapable conclusions to be drawn include:

From and environmental perspective:
Canadian government scientists portray RBT2’s adverse environmental effects on intertidal biofilm as immediate, permanent, continuous, irreversible and unable to be mitigated. The RBT2 approval will result in the upset of the natural chemistry over Roberts Bank and the quality of its unique intertidal biofilm will be inexorably destroyed. 

This will have devastating consequences, resulting in a cascading failure of the estuarine ecosystem, up to and including commercial crab and salmon species, eulachon, already endangered southern resident killer whales, as well as migratory and other shorebirds. 

This catastrophe has all along been the major concern for government scientists as well as many independent scientists expert in their field.

From and economic and trade perspective:
The Vancouver Fraser Port Authority is pushing ahead with RBT2 despite Vancouver’s declining container volumes. Total container traffic was down by more than three percent in 2022 versus 2021. Worse yet 2022 full container loads were down by nine percent compared to 2021. In fact there were fewer loaded containers handled by the Port in 2022 than in every year all the way back to 2013. 

That dismal picture continues in 2023.  Total container volumes for the nine months to September 2023 are off by over 17 percent, with full imports falling by 19 percent compared to the same period in 2022. Major shipping lines are laying off staff and forecasting significant drops in container volumes.

The Port of Vancouver is losing US container traffic (as much as 25 percent of its total volumes). More and more US containers are going by the all water route direct to US Gulf and East Coast ports. That trend will continue because it is cheaper and faster for shipping companies to get their goods to market. This is a fundamental and permanent change.

Better container terminal expansion alternatives:
The Deltaport Berth 4 and Prince Rupert container terminal expansions can deliver much more terminal capacity than RBT2 within the same time frame, privately funded, at less cost and without the significant adverse environmental effects.

Dear Against Port Expansion Community Group Supporters and Members of the Public:
October 13, 2023

Governments Have Betrayed The Environmental Values of the Fraser Estuary

As Executive Director of Against Port Expansion Community Group I write to you, APE Supporters and Members of the Public after reflecting on Victoria’s approval of Roberts Bank Terminal 2 (RBT2), which effectively ends attempts to stop RBT2 within the federal and provincial legislative framework established to carry out environmental assessments and make decisions.

Read the full letter here:

Governments_Have_Betrayed_The_Environmental_Values_of_the_Fraser_Estuary_APE_Website.pdf

Is the Federal Government serious about implementing the Roberts Bank
Terminal 2 Conditions for Approval
By Roger Emsley Executive Director Against Port Expansion Community Group

August 31 2023 

The July 11 article in Business in Vancouver https://biv.com/article/2023/07/does-port-vancouvers-35-billion-terminal-2-have-plankton-problem identifies a meaningful and important condition of approval that the Vancouver Fraser Port Authority may find difficult to meet in its quest to build Roberts Bank Terminal 2 (RBT2). However, the big question remains: is the Federal Government serious about implementing the Roberts Bank Terminal 2 Conditions for Approval? Not so much, it seems, from the latest two postings on the Impact Assessment Agency’s public website.

https://iaac-aeic.gc.ca/050/evaluations/document/152826

Of all the 370 conditions of approval there is one that could prevent RBT2 being built. Condition 10.4 requires the Impact Assessment Agency of Canada to establish an independent scientific body whose role is to monitor potential adverse environmental effects on biofilm resulting from salinity changes caused by the RBT2 project. If baseline thresholds are exceeded during monitoring for at least 36 months after Terminal 2’s east basin containment dyke is built, three mitigation options kick in: biofilm creation, infrastructure redesign or infrastructure removal.

But what exactly is an independent scientific body?  To be truly independent Canadians expect this expert body to be independent of both the Port of Vancouver and of the federal government. However if Canadians are expecting a truly independent scientific body that is not going to happen.

It turns out that the federal government’s Chief Science Advisor will lead the independent body.  How arms length is the Chief Scientific Advisor from the RBT2 issue? Not at all. That position reports to the Minister of Innovation, Science and Industry, François-Philippe Champagne. He is one of the ministers in Cabinet who supported RBT2. So not independent!

If the Chief Scientific Advisor and the team created to carry out the work find the project has compromised the biofilm, such that it exceeds the baseline thresholds, what then? Which of the three mitigation options will kick in? Will the Minister to whom the advisor reports opt for redesign or infrastructure removal given he supported the RBT2 approval?  Unlikely. 

Although biofilm creation will most likely be the chosen option, both government scientists and truly independent experts in wetlands and wetlands technology agree that there is no area large enough to compensate for the quality and quantity of biofilm in the Fraser River Estuary and Delta that would be destroyed by RBT2. Further, any biofilm creation program will undoubtedly be doomed as no one has ever re-established quality functioning biofilm. 

If the independent scientific body were truly independent, rather than reporting to one of the key ministers who supports RBT2, this 10.4 condition for approval would have posed a meaningful trigger as to whether RBT2 is built.  But as it is now the Port of Vancouver will look for a work around, trying in vain to recreate the biofilm that will have been lost such that the project can continue. 

Ultimately, RBT2 will upset the natural chemistry over Roberts Bank and the quality of the intertidal biofilm will be inexorably wrecked. This will have devastating consequences resulting in a cascading failure of the estuarine ecosystem, up to and including commercial crab and salmon species, southern resident killer whales as well as migratory and other shorebirds. This catastrophe has all along been the major concern for government scientists as well as many independent scientists expert in their field. 

There is one final irony in the appointment of the Chief Science Advisor to head up the independent scientific body. The mandate for this role includes “providing advice on creating process to ensure that scientific analyses are considered when the Government makes decisions”. Yet the government ignored its own scientists when it approved RBT2!

If the federal government is serious about environmental protection and if its conditions for RBT2 approval are to have any meaning at all, then this independent scientific body must be truly independent - not reporting to one of the RBT2 supporters in government.

-30-

The federal cabinet’s approval of Roberts Bank Terminal 2 (RBT2) is not the end of the story. The provincial government has still to give its approval and there are many justifiable reasons for them to say no to RBT2. 

First off the BC government should be asking why did the federal cabinet give its approval. Cabinet discussions in Canada – unlike many democracies - are kept secret so we will perhaps never know what caused the cabinet to ignore its own government scientists and approve a project whose significant adverse environmental effects will result in severe degradation of the last remaining bank largely unaltered by human intervention and hugely productive. 

Leaked information from the cabinet discussions indicate Ministers Guilbeault, Murray and Qualtrough (also MP for Delta where the devastation is to take place) opposed RBT2. Amazingly Wilkinson – who was previously environment minister -supported RBT2, as did Ministers Champagne, Sajjan and Alghabra.

But on the assumption that only the Port of Vancouver can solve Canada’s supply chain problem - dubious though that is - there are three fundamental questions that the BC government should be asking prior to making any decision: 

1. Why did the federal cabinet ignore its own scientists whose science, published in peer-reviewed science journals and supported by experts independent of the Port and government indicates RBT2 will have devastating consequences for the estuary’s intertidal food-web critical for the wildlife and biodiversity that is the essence of the ecosystem. These scientists all maintain the same concerns, predicting RBT2 will destroy the productivity of the bank by removing fatty acid rich intertidal biofilm resulting in a cascading failure of the estuarine ecosystem, up to and including commercial crab and salmon species plus migratory shorebirds.
2. Why is it better to build a greenfield container terminal (Roberts Bank Terminal 2) at a cost likely to exceed $6 billion, when a Canadian company is proposing an alternative to add capacity to an existing terminal (Deltaport Berth 4) in the same location, in the same timeline, providing similar expansion capacity at less than half the cost and with much less environmental degradation? Added to that why bar existing BC terminal operators from bidding on RBT2, thereby letting in foreign entities perhaps with Chinese backing to build and operate it?
3. Why build any more container terminal capacity in Vancouver at all, where the marine, road, rail and logistics infrastructure is already congested, and when an existing terminal operator in Prince Rupert wants to add even more capacity at much less cost and with no environmental effects, which in addition will reduce vessel transit by two days and provide much needed employment in an area that needs it?

The opposition to RBT2 is immense and growing:

• Two major unions (ILWU and BCGEU) along with 15 major environmental groups (at their Crab Park press conference June 14) in a united front are calling on the BC Government to withhold the certificate for RBT2 under the Environmental Assessment Act.
• The Union of BC Indian Chiefs – in their open letter to Federal and Provincial Environment Ministers are calling for an immediate pause of RBT2 development.
• There are two legal actions (Ecojustice and Lummi Nation) both challenging the RBT2 approval.

That opposition is not going away, nor are government and other scientists that oppose RBT2. 

So let’s get the BC Government and the MP for Delta to give us answers.

Email Honourable David Eby, Premier premier@gov.bc.ca
and MP Carla Qualtrough carla.qualtrough@parl.gc.ca

Please copy saynotot2@gmail.com

When First Nations endorse and support industrial projects that are damaging to our environment and negatively impact all those living nearby or who are otherwise effected, then all Canadians and those calling Canada home have a right to know why First Nation supported these projects.

Such is the case with the environmentally damaging and uneconomic Roberts Bank Terminal 2 project in Delta BC. Why did a number of First Nations endorse and support this project, signing beneficial participation agreements with the project’s initiator, The Vancouver Fraser Port Authority? Did this support influence the federal government when they subsequently approved the project, even while recognizing that RBT2 is likely to cause significant adverse environmental effects?

With The Union of BC Indian Chiefs subsequently publishing a letter on July 12 opposing the Roberts Bank Terminal 2 (RBT2) Project, the question needs to be asked:  did the many First Nations that have signed participation agreements with the Vancouver Fraser Port Authority and supported the Roberts Bank Terminal 2 Project realize the significant adverse environmental effects that will result, especially to biofilm, which cannot be mitigated?

Environment and Climate Change Canada (ECCC) scientists were never allowed the opportunity to explain to First Nations the importance of biofilm and the salinity trigger that is so important to wildlife on Roberts Bank. The Port of Vancouver held workshops with First Nations, to which Environment and Climate Change Canada were excluded, to sell their version of biofilm science - and it was false. These workshops skewed the science on biofilm. The Port could not and never will accept the salinity trigger as the driver of the richness in the diatoms in biofilm that is critical to all wildlife that relies on Roberts Bank. To do so would undermine their case that the RBT2 man made Island will not negatively affect the biofilm that migratory and other shorebirds rely on and is the underpinning of the intertidal food web. 

It appears the workshops’ prime purpose was to sell the Port’s skewed science on biofilm.  And it is the science on biofilm and it’s influence on the intertidal foodweb that links the concerns of all the groups fighting to stop RBT2, whether it is because of the Orcas, the salmon, the crabs, the migratory and other shorebirds or anything else. It is also worth noting that one of the concerns of the International Longshore & Warehouse Union (ILWU) is that they do not want to be working at a container terminal that they now believe to have negative environmental consequences. 

The science surrounding biofilm is relatively new. (See attached paper PREDICTED EFFECTS OF THE ROBERTS BANK TERMINAL 2 (RBT2) DEVELOPMENT ON WESTERN SANDPIPERS)

The traditional view had been that the birds were feeding on a variety of organisms in the wetland mud flat on Roberts Bank. But then international and Canadian experts in wetlands and wetland ecology realized that the birds were vacuuming up the rich substances in the mud, that being the unique biofilm found in certain areas of the Roberts Bank mudflats. This was especially true with Western Sandpipers who with their specialized tongues fringed with spines and a mucous coating ingest the biofilm. That led to understanding as to why the biofilm became rich just at the time the birds arrived on their northward migration along with the spring freshet. The salinity trigger, alternating salt and fresh water flowing over the mudflats with each tide, shocks the diatoms into producing poly unsaturated fatty acids rich in omega 3 and provides the birds with the fuel they need to build strength for their journey to their arctic breeding grounds. Equally important it is that same richness in the biofilm that supports the salmon, the crabs, the orcas, in fact all wildlife that rely on Roberts Bank. 

Leading that research are scientists like Bob Elner, Mark Drever and several others with their research published in peer reviewed science journals. That understanding continues with studies ongoing including in universities in the US and Canada. It is worth noting that the science the Port relies on has never been peer reviewed. Furthermore international experts such as Professors Baird and Beninger have shown that the Port’s science is flawed. 

Would First Nations have been so willing to sign these participation agreements if they had realized the importance of biofilm? Would they have accepted the Port’s false notion that biofilm can be recreated to replace that which will be lost as a result of RBT2, if they had heard the evidence from ECCC scientists and others that it is impossible to recreate biofilm on that scale and nowhere else in the world has it ever been done?

 Building Roberts Bank Terminal 2 means:

• Crab populations will decline, 
• Salmon stocks will continue to fall,
• Migratory shorebirds will no longer have access to rich biofilm, not be as healthy when they reach the breeding grounds and will possibly decline further to the point of species extinction,  
• The three Orca pods will continue to decline in numbers, 

All because the federal government ignored the ECCC documented and published science, facts and evidence (supported by experts independent of the Vancouver Fraser Port Authority), that the impact of RBT2 on wildlife will be immediate, continuous, permanent, irreversible and cannot be mitigated.

Certainly no First Nation wishes to see this happen to Roberts Bank recognized as:

1. A BC Wildlife Management Area and providing critical wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada. 
2. A Key Biodiversity Area
3. An Important Bird Area in Danger by Birdlife International
4. A Western Hemisphere Shorebird Reserve Network Site of Hemispheric Importance.

Perhaps now, with the Union of BC Indian Chiefs opposing RBT2, the provincial government will do what the federal government failed to do:

1. Review the science facts and evidence
2. Realize the significant adverse environmental effects that cannot be mitigated
3. Understand that BC has in excess of 2 million spare container capacity sufficient to last until the 2030s
4. Recognize there are other less environmentally damaging port expansion projects in Prince Rupert and Vancouver that can deliver more container terminal capacity in the 2030s when needed.
5. Realize that RBT2 cannot solve supply chain congestion because rail routes through the Fraser Canyon are at capacity
6. Refuse to approve RBT2

PREDICTED_EFFECTS_OF_THE_ROBERTS_BANK_TERMINAL_2_(RBT2)_DEVELOPMENT_ON_WESTERN_SANDPIPERS.pdf

Wednesday June 14 Crab Park Vancouver

Roberts Bank Terminal 2 opposition demands answers from governments on expansion: Environmentalists, communities, and unions stand together

The battle to save Roberts Bank and the Fraser Estuary from industrial degradation is far from over. Groups opposed to Roberts Bank Terminal 2 are warning the BC government against giving its approval.

Here are a few of the submissions:

BBCC_Submission_to_B.C._EAO,_June_2023.pdf

GCCS_Comment-re-RBT2_2023-06-08.pdf

NOT_JUSTIFIED_IN_THE_CIRCUMSTANCES.pdf

Read the attached paper written by Susan Jones, Director Boundary Bay Conservation Committee.

It demonstrates how industrial projects including RBT2 are devastating the Lower Fraser River and its estuary.

RBT2_approval_devastating_to_lower_Fraser_River_and_Estuary.pdf

April 20 2023 will be labelled as a bad day for the environment in Canada's history. On that day the Trudeau government decided the significant adverse environmental effects that will result from the Roberts Bank Terminal 2 Project are justified in the circumstances.

This government approved RBT2 on two falsehoods by ignoring:

1.The concerns of their own scientists. Environment and Climate Change Canada scientists have repeatedly stated that " ..... the changes predicted as a result of the Roberts Bank Terminal 2 Project, as currently designed, would likely constitute an unmitigable species-level risk to Western Sandpipers, and shorebirds more generally"

2.The actual number of containers being handled by Vancouver area ports, demonstrsting there is plenty of spare container terminal capacity at present. The Minister of Transport (April 20 2023) stated Vancouver will run out of container terminal capacity by the late 2020s. Yet actual full container loads handled by Vancouver terminals are lower today than they were in 2013. Furthermore total container volumes for the first quarter 2023 are down by 15.3% compared to the same period in 2022. 

Groups opposed to Roberts Bank Terminal 2

Internationally recognized scientists
Letter from scientists regarding Roberts Bank Terminal 2

Salish Sea Institute, Western Washington University
https://iaac-aeic.gc.ca/050/evaluations/proj/80054/contributions/id/57756

Lummi Nation
Can This Tribe of ‘Salmon People’ Pull Off One More Win?

S’ólh Téméxw Stewardship Alliance (STSA)
RBT2 Conditions Feedback 

Tsleil-Waututh Nation
Tsleil-Waututh Nation (TWN) comments on RBT2 

International Longshore Workers Union Canada (ILWUC)
Open Letter to Government Regarding Roberts Bank Terminal 2

Sacred Lands Conservancy
RBT2 threatens salmon, our orca relations, and Indigenous life ways and livelihoods 

Swinomish Indian Tribal Community, Suquamish Tribe, and Tulalip Tribes
Comments on Roberts Bank Terminal 2 Potential Environmental Assessment 

Unitarian Church of Vancouver
UCV Opposes the Roberts Bank Terminal 2 Project

BCIT Rivers Institute 
Letter from scientists regarding Roberts Bank Terminal 2 

City of Delta
City of Delta, Council Report Jan 4, 2022

City of Richmond
Richmond joins Delta in opposing T2 

Birds Canada and Nature Canada
Roberts Bank: Ottawa should reject a terminal expansion that puts human and environmental health at risk 

Raincoast Conservation Foundation, Georgia Strait Alliance, David Suzuki Foundation, and Wilderness Committee
Terminal 2 expansion threatens orcas, salmon and climate action – Ecojustice

Friends of the Earth US
Friends of the Earth US activist comments on Roberts Bank T2 proposed project 

Rivershed Society of BC
Comments on Terminal 2

The Waterbird Society
Comments on RBT2 

OrcaLab
Please reject Roberts Bank terminal expansion proposal

Against Port Expansion in the Fraser Estuary (APE)
Against Port Expansion in Delta 

Garden City Conservation Society
Garden City Conservation Society

White Rock and Surrey Naturalists Society
Roberts Bank Terminal 2 Project 

Western Hemisphere Shorebird Reserve Network
Comment Letter on the Fraser River Delta Port Development

PenderPod
PenderPod is a community organization on Pender Island dedicated to honouring, protecting and defending the Natural Environment of the Salish Sea

BC Nature
https://bcnature.org/take-action/

Boundary Bay Conservation Committee 

http://actionintime.ca/wp-content/uploads/2022/02/irreversible_harm_to_fraser_estuary.pdf

Fraser Voices
https://iaac-aeic.gc.ca/050/evaluations/document/132516

Wild Bird Trust of BC
https://mailchi.mp/wildbirdtrust/spring-opening-coastsalishplantnursery-20194592?e=bc5da82e9a

And Many Thousands of Canadian Citizens

Canada doesn't need any further Port Expansion on Roberts Bank. Here is why.

One of the many devastating effects of the Roberts Bank Terminal 2 project is that on crab harvesting. Harvesting crabs in the Fraser Estuary has been done for generations. Now the Vancouver Fraser Port Authority's project puts all that at risk.

See the recent video by Steven Stark, president Salish Sea Indigenous Guardians Association (SSIGA), who is also a member of Tsawwassen First Nation, recently posted on the PortWatch website https://portwatch.ca.

https://portwatch.ca/news/f/tsawwassen-first-nation-member-steven-stark---rbt2-concerns

In March 2022 the SSGIA had requested from the Impact Assessment Agency Canada a Regional Assessment of Cumulative Effects in the Salish with a focus on port development, in particular Roberts Bank Terminal 2 and the GCT Berth 4 project.

That request received a great deal of support from many groups, including the BC Environmental Assessment Office as well as APE. However the IAAC turned down the request.

A cumualtive effects assessment for the whole of the Salish Sea has never been done properly. Certain entities don't want one done because it would expose the magnitude of damage that port and industrial development is doing to the Salish Sea.

OF THE PEOPLE

FOR THE PEOPLE

BY THE PEOPLE

SO MANY PEOPLE AGAINST ROBERTS BANK TERMINAL 2

This excerpt from the full article in Business in Vancouver December 19, 2022 says it all: 

"Demand growth for container cargo movement measured in 20-foot-equivalent units (TEUs), according to Lars Jensen, CEO of Denmark’s Vespucci Maritime, “has dropped off a cliff.” 

https://biv.com/article/2022/12/updated-choppy-fiscal-seas-ahead-container-carriers-and-terminals-2023

Since RBT2 is now before cabinet, acting as Governor in Council,  it is more than likely they are being bombarded with statements from Vancouver Fraser Port Authority CEO Robin Silvester to the effect that to save Canada’s trade from descending into the abyss it is critical for RBT2 to receive approval. 

Certainly in the public domain CEO Silvester continues to promote the fiction that West Coast Canada is about to run out of container terminal capacity. Here are just a few of several 2022 statements from CEO Silvester:

“With continued growth, West Coast terminals are expected to run out of capacity by the mid-to late-2020s”. (Pacific Maritime Magazine)

Canada’s largest port could run out of container capacity in as soon as five years, exacerbating domestic and global supply chain issues, according to Robin Silvester, president and chief executive officer of the Vancouver Fraser Port Authority. (BNN Bloomberg)

“We foresee needing the capacity for Terminal 2 by the mid-to-late 2020s. We can’t imagine getting that capacity ready now until 2031 or 2032. We could start running out of capacity on the west coast and we hope we’ll be in the position to have Terminal 2 clearly underway, moving forward, ready to come in to relieve those capacity constraints,” (Delta Optimist) 

"If we consider our short- and long-term challenges at Canada's largest port, the solutions are in fact the same," Silvester said. "To provide resiliency in the face of supply-chain disruptions and to be able to support long-term growth from a position of strength, we need to continue building capacity, efficiency and resiliency throughout the port and its supply chains. Roberts Bank Terminal 2 is an essential part of that.” (Port of Vancouver September 22 2022)

CEO Silvester’s  claims that the Port of Vancouver is averaging a 5 percent annual growth are equally false. The actual compound annual growth rate (CAGR) for the ten years up to the end of 2021 is less than 3 percent. Full 2022 container volumes - to November - handled by the Port of Vancouver are down by 8 percent compared to 2021 and by 8.3% compared to 2019, the last full year prior to the pandemic.

Of course RBT2 should be denied approval based on the science and environmental issues alone, but knowing that certain members of cabinet, incredulously, are in favour of proceeding with RBT2 it is also important they be aware that the $3.5 billion (anticipated to balloon past $4.0 billion) project will be an economic disaster that the federal government will wear.

Not only that it is worth repeating that there are expansions underway at other Canadian west coast ports, such that Canada will have plenty of container terminal capacity for decades to come without ever building the environmentally destructive and prohibitively expensive RBT2.  

The Port of Prince Rupert is completing its expansion of the Fairview terminal such that its capacity will increase to 1.8 million TEUs by 2023. In addition the Port also announced plans earlier this year to build an innovative second container terminal, adding another 2 million TEUs of capacity.  

Prime Minister Trudeau has stated publicly (Soul of the Fraser Film Nov. 2022) that RBT2 will be assessed based on the science. Cabinet has that science from the Environment and Climate Change Canada scientists and clearly that is science the environmental assessment must be based on, not the self-serving, flawed science being promoted by the Vancouver Fraser Port Authority.

Cabinet (acting as Governor in Council) has all the information it needs to make a decision on RBT2. There is no need for further delay. As we end 2022 let’s therefore hope the Governor in Council very soon makes the decision to deny approval for RBT2 and put an end to this long running saga.

The Vancouver Fraser Port Authority made a big mistake when it attempted to push back and deflect the many thousands of opposing submissions for the Roberts Bank Terminal 2 project. When it posted its rebuttals in June 2022 to the many thousands of opposing submissions it provided the opening government scientists needed to demonstrate to the Environment Minister and the Federal Cabinet that RBT2 must be denied approval.

So on October 26 2022 Environment and Climate Change Canada (ECCC) scientists responded to the two prior submissions from the Vancouver Fraser Port Authority, 

ECCC posted on the Impact Assessment Agency Canada (IAAC) registry for T2 its comprehensive rebuttal to the VFPA claims that the RBT2 project is environmentally sustainable 

See https://iaac-aeic.gc.ca/050/evaluations/proj/80054/contributions/id/58872

The ECCC scientists are not permitted to recommend RBT2 be rejected outright and denied approval, so they have gone as far as they can - as far as they are allowed to - in expressing their concerns about RBT2. All they can do – and have done – is to state that the only way to reduce the negative impacts is a project redesign. VFPA has been given every opportunity to propose a project redesign, but clearly it has no intention to do so.

.

Despite all of this VFPA continues in its own dream world, constantly advertising on TV, radio and other media, promoting RBT2 as a necessary and environmentally benign project.

The actual container statistics demonstrate:

• West Coast container trade continues to languish in the doldrums, with a ten year plus cumulative compound annual growth rate (CAGR) of less than 3 percent
• VFPA actual volumes for the first three quarters of 2022 are lower than the same period in 2021, with full container volumes off by over 9 percent
• VFPA actual full container volumes ytd 2022 are lower than prior to the pandemic in 2019, off by 9 percent.
• West Coast Canada will not run out of space by the mid to late 2020s as Mr. Silvester keeps suggesting. Port operators have proven there is over one million in west coast spare container capacity, sufficient to meet Canada's trading needs into the 2030s.

Expansions already planned and being implemented in Vancouver and Prince Rupert will provide additional container capacity by the time the market requires it in the early 2030s such that the disastrous $4 billion plus RBT2 will never be needed.

With the expert advice from the ECCC scientists, who have proven beyond any doubt that the significant adverse environmental effects caused by RBT2 will “constitute an unmitigable species level risk to Western Sandpipers, and shorebirds more generally”, the federal environment minister and cabinet have all they need to make their decision and deny approval for Roberts Bank Terminal 2.

To help the government do the right thing and deny approval please send an email to the Environment Minister ec.ministre-minister.ec@canada.ca.

Order your free tickets here

https://www.eventbrite.com/e/soul-of-the-fraser-screening-north-delta-centre-for-the-arts-tickets-458771847947

The clock is ticking for RBT2. The federal government has to make a decision soon on whether to approve a major industrial development on Roberts Bank. Yet there is a fundamental disconnect within the Federal Government’s environmental policies.  

On the one hand the federal environment minister just announced - with pride - that Canada is one of the first countries to adopt the Key Biodiversity Area (KBA) standards nationally, with the Fraser River Estuary already identified as one of Canada’s critical places for nature and one of the first sites to be certified as a KBA.
https://kbacanada.org/site/?SiteCode=BC017

On the other a crown agency of the federal government - the Port of Vancouver - is lobbying hard to get approval for Roberts Bank Container Terminal 2 (RBT2). They want to build a second container terminal on a 164-hectare man made island right in the middle of the newly certified KBA. Not only that but In addition the same crown agency wants to put a second cruise ship terminal in the lower reaches of the Fraser River. How ridiculous is that?

The government’s own scientists, supported by internationally acknowledged experts in wetlands and wetland ecology, have proven beyond any doubt that the RBT2 development will cause significant environmental impacts, described by Environment and Climate Change Canada scientists as “permanent, irreversible, and, continuous”. 

Is the federal government serious as they claim about protecting nature and halting biodiversity loss? Because if they are there is no way they can support the Key Biodiversity Area concept and standards, yet still approve Roberts Bank Terminal 2 and/or a second cruise ship terminal.

How can Canada on the one hand pride itself as one of the leaders in protecting biodiversity and giving increased protection to ecosystems and wildlife species whilst at the same time approving environmentally dangerous projects such as Roberts Bank Terminal 2?

Approving any further industrialization of the lower Fraser and its estuary is in direct conflict with the aims and objectives of the Key Biodiversity Area program.

The Fraser Estuary KBA is an area critical for wildlife and biodiversity. It is an important stop for migratory birds on the Pacific Flyway. These Port of Vancouver developments threaten the values of the KBA. Degradation and over exploitation of natural resources are significantly reducing the biological diversity and integrity of recognized and important ecosystems such as the Fraser Estuary and River.

The Fraser estuary and its ecosystem is already at an environmental tipping point. It already has a ferry terminal, a coal (soon also to be potash) terminal and a three-berth container terminal. It simply cannot withstand any more port and industrial development. 

It is now up to the federal government to “walk the talk”, support the principles of the KBA program in Canada and deny approval for Roberts Bank Terminal 2 as well reject a second cruise ship terminal. To do anything other than deny approval for these proposed projects in the Fraser River and Estuary would be hypocritical for the federal government and will result in international embarrassment for Canada.

Science Facts and Evidence Ignored in the Quest for RBT2
By Roger Emsley Executive Director Against Port Expansion August 31, 2022

Science facts and evidence are the casualties from the years long quest by the Vancouver Fraser Port Authority (VFPA) to build a second container terminal in the Fraser Estuary on Roberts Bank (RBT2):

A. Science:

• Roberts Bank – one of the most important stops on the Pacific Flyway for migratory birds – recognized as one of the top Important Bird Areas in Canada and home to critical wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada. 
• The reason – the rich source of polyunsaturated acids in biofilm on Roberts Bank, which RBT2 will denigrate, is essential for millions of migratory and other shorebirds, as well as other wildlife, that rely on that biofilm. 
• Compelling science – developed over many years by Canadian and international scientists, expert in wetlands ecology which VFPA ignores.
• That science proves the salinity trigger causes the richness of the diatoms in biofilm, where pulses of fresh water from the river oscillate with the tidal salt water to shock the diatoms into producing nutrients essential for the birds and other wildlife. RBT2 changes tidal flows and water temparature disrupting that salinity trigger; reducing the richness of the biofilm, thereby no longer providing the essential food source for millions of birds.
• That science does not fit with the VFPA quest for RBT2, so they ignored the science and developed their own flawed version to fit with their desired solution.

B. Facts

Misleading statements and information by VFPA, claiming:

• Lack of terminal capacity as early as 2025.  In fact there is over one million spare container capacity as of 2022. Forecasts indicate there is sufficient capacity into the 2030s by which time expansions in Vancouver and Prince Rupert will increase west coast terminal capacities to 10-11 million containers without ever building RBT2.
• RBT2 required because of forecasted container volume increases. VFPA consistently underperforms against its forecasts.
• Supply chain issues are caused by lack of terminal capacity.  These are not caused by terminal capacities but rather lack of warehouse space and shortage of industrial land in the lower mainland
• RBT2 will cost $3.5 billion. VFPA consistently underestimates costs to build RBT2. With an expected construction start of 2024 or later costs will balloon to over $4 billion not the $3.5 billion figure VFPA claims.

C. Evidence

Never introduced and/or the Review Panel refused to hear:

• Port truck traffic and the resulting congestion on highways
• Rail delays and container transit times because of rail congestion through the Fraser Canyon
• Alternatives to Vancouver - Prince Rupert - their Terminal capacities and their expansion plans. Prince Rupert is two sailing days closer to Asia, has few environmental effects and a much easier less congested rail route East.
• Viewpoints and concerns from US indigenous groups that were never given proper consideration.
• Failure to include ECCC scientists when engaging with First Nations, thereby providing those First Nations with invalid science regarding biofilm.

VFPA CEO Silvester says: “There is no other project anywhere near the finish line.… Terminal 2 is a project we developed in the public interest rather than in the interest of a single shareholder.” “By growing the necessary container terminal capacity and building Roberts Bank Terminal 2 at Canada’s largest port, we unlock greater opportunities for Canadians, connecting businesses — big and small — to the global economy”.

 Misleading:

1. If T2 gets approved it is likely a foreign entity will operate it. And Silvester thinks this is in Canada’s interest? Where is the justification?
2. It is NOT in the public interest to use taxpayer funds to build RBT2 when it is private investment that will expand existing terminals in Vancouver and Prince Rupert, providing all the volume necessary to meet Canada’s trading needs.
3. No other project near the finish line? Not true. DP World is already expanding its Vancouver and Prince Rupert container terminals. Global Container Terminals (GCT) is building out Deltaport and is set to expand its inner harbour terminal. DP World is readying plans to build a second terminal in Prince Rupert, all with private investment.
4. DP World and GCT expansions are nearer the finish line than RBT2, which if approved won’t start construction until at least 2024, taking 7 years or more to build, by which time it’s cost will have ballooned past $4 billion.
5. VFPA’s full container throughput declined 13% in the first half of 2022 versus the same period in 2021. 2022 volumes are flat compared to 2019. There is over a million spare container terminal capacity in West Coast Canada. At current rates of trade expansion this will serve Canada’s trading needs into the 2030s by which time the already announced expansions will be ready. West Coast Canada will have 11 million container terminal capacity without ever building the mega expensive T2. 

VFPA CEO Silvester says: “The project has gone through the highest level of environmental review in Canada: a federally designated review. It’s had a public hearing to hear all the perspectives, all the factual information that we put forward about environmental impacts and the ways we would mitigate all the concerns of stakeholders. The federal minister had some further questions, and we’ve responded in full. Everyone has had a chance to comment on those responses. Now, the project needs to go forward to government for a decision. We are very firmly of the view that this project can be delivered without adverse environmental effects.”

6. VFPA insisted the Panel terms of reference exclude impacts beyond the port footprint. Therefore the Panel refused to hear about negative impacts such as increased road and rail traffic causing congestion on highways, snd rail bottlenecks through the Fraser Canyon.
7. The federally appointed review panel identified a number of areas where RBT2 would result in significant adverse environmental effects and was uncertain whether mitigation will rectify the negative effects in a number of these. Precautionary principle: –if the risk is unknown, the outcome uncertain, then do not proceed.
8. Environment and Climate Change Canada (ECCC) scientists have said consistently and repeatedly T2 will result in significant adverse environmental effects that cannot be mitigated. Major Canadian and international environment groups, including Birds Canada, WHSRN, Audubon, Birdlife International, BC Nature, Nature Canada all have the same concerns.
9. International scientists with expertise in wetlands ecology whose research has been published in peer-reviewed journals share the ECCC science concerns.  All oppose T2. The environmental review panel noted many areas of significant adverse environmental effects and could not conclude with certainty that all these could be addressed and effectively mitigated.
10. Silvester keeps pushing the VFPA science, which unlike the ECCC and international scientists has never been published in peer-reviewed science journals. International scientists expert in wetlands ecology criticized the VFPA science, identifying a number of critical flaws in the VFPA science.
11. VFPA is proposing mitigation measures, whereby they plan to replace the biofilm habitat lost as a result of RBT2, but ECCC science has proven that biofilm habitat cannot be replaced on the scale necessary.
12. VFPA has held workshops with First Nations on biofilm and biofilm replacement. VFPA invited DFO to these workshops but specifically excluded the federal regulators - ECCC scientists - the body with expertise in this field. VFPA has consistently ignored the ECCC science because it does not fit with the flawed science they are promoting.
13. VFPA are now involving First Nations in promoting alternative sites for biofilm recreation with no scientific underpinning nor validation from experts in wetlands and wildlife ecology independent of the VFPA. Why does VFPA continue to ignore and bypass ECCC scientists, who with their international colleagues have spent years understanding biofilm and what is and is not possible in terms of re-creating that which industrial projects have destroyed?

It has been suggested involving Indigenous Groups into “ biofilm restoration” is a VFPA ploy without the groups being appraised of ECCC science and so far VFPA is getting away with ignoring ECCC science. 

Conclusion:

Three cities Delta Richmond White Rock, major Canadian and international environment groups, expert scientists port operators, and thousands of citizen scientists and others all oppose this project. The science is overwhelming. The decision is clear. DENY APPROVAL FOR RBT2.

Reprinted from Maritme Magazine

The Vancouver Fraser Port Authority (VFPA) continues to perpetrate two myths concerning RBT2:

• Project-induced salinity changes are unlikely to cause a significant adverse environmental effect on biofilm and western sandpipers, and any residual uncertainty can be addressed through conditions requiring follow-up and adaptive management
• Vancouver is likely to run out of container terminal capacity as early as the mid 2020s and the supply chain congestion is caused by lack of terminal capacity. 

Neither is true. 

1. For Biofilm and Western Sandpipers:

On June 10 VFPA put in its latest submission on Biofilm and Western Sandpipers to Terence Hubbard, President Impact Assessment Agency of Canada. In it VFPA refutes the Environment and Climate Change Canada (ECCC) science, evidence and facts. VFPA claims incorrectly that:

• Any salinity changes caused by RBT2 are minor and well within the range of seasonal variation.
• Adaptive management and follow up will effectively mitigate any minor adverse environmental effects.
• Biofilm can be re-created on a massive scale sufficient to replace biofilm lost as a result of RBT2.

None of this is true. VFPA uses the same data they have used previously to support its claim that the project will not affect the salinity trigger. ECCC in a previous submission see: https://www.againstportexpansion.org/uploads/images/file_view/Highlighted_RBT2_ECCC_comments_on_final_IR_response_final.pdf
reviewed the proponent’s studies in 2016, 2017, and 2018 (Hemmera et al. 2019) and found the VFPA conclusions invalid. ECCC demonstrated that RBT2 would result in changes to salinity sufficient to significantly reduce biofilm quality and quantity, stating RBT2 will result in:

• “the disruption of the salinity trigger responsible for shocking marine-type diatoms into high fatty acid production
• changes in community composition of diatoms in biofilm from marine to freshwater types that will produce lower amounts of fatty acid
• an unfavorable spatial shift in the centre of the distribution for biofilm towards sandier substrates where biofilm would be inaccessible for foraging Western Sandpipers due to tongue morphology
• all causing a reduction in the biomass of available biofilm, resulting in lower abundance of food for shorebirds during the critical migration period.”

 ECCC then states:

“Therefore, the Proponent’s conclusion that salinity changes resulting from the project will not adversely affect biofilm and migratory shorebirds is inconsistent with the established ecology of biofilm and with the results of the Proponent’s own studies”.  

Regarding the large-scale re-creation of biofilm habitat capable of supporting shorebirds, based on ECCC’s review of studies undertaken by VFPA and their citation of restoration at other sites it is clear there is an absence of mitigation options for Roberts Bank. ECCC research has concluded there are no alternate sites for the construction of a large-scale mudflat and the re-creation of biofilm in the Fraser Estuary. All alternative sites have sandier substrates and/or different hydrological regimes.  

VFPA has repeatedly cited the restoration of biofilm at a site in Japan, yet the evidence shows the area where biofilm was re-created was small, much smaller than that attributed by VFPA. As ECCC has stated these do not provide evidence of the recreation of mudflats with equivalent functional values for Roberts Bank.

As for adaptive management ECCC states:

“Considering ECCC’s view that project effects on biofilm and Western Sandpipers would be immitigable, immediate, and irreversible, ECCC suggests that an adaptive management approach would not provide an appropriate solution to remediate what ECCC continues to anticipate would be the adverse impact of the project on biofilm and western sandpipers”. 

2. For the potential to run out of container capacity by the mid 2020s:

 There is currently over a million TEUs spare terminal capacity on the BC West Coast.  Yet despite this the (VFPA) insists as recently as June 10:

“ With container trade growing faster than forecasted globally-based supply chain challenges that Canadians are experiencing today are a preview of made-in-Canada supply-chain problems ahead if, as a country, we don't deliver the capacity needed. Designed under our public interest mandate, Roberts Bank Terminal 2 will provide timely container capacity on Canada's West Coast, ensure greater supply chain competition, and protect Canada's trade sovereignty”. 

VFPA continues to live in its own dream world. Growth faster than forecasted?  Q1 2022 saw VFPA container volumes drop by over 10% compared to the 2019 pre-pandemic levels. For the first five months of 2022 full container volumes are down by almost 15 percent. Total containers (TEUs) handled for the same period are off by close to 10 percent and that includes 414,000 empty container moves.

Yet VFPA pushes the same old fairy tale that their $3.5 billon plus RBT2 project is needed now because Canada will soon run out of west coast container capacity. How can the public rely on government agencies when they continue to misrepresent the facts in this way?

Supply chain issues, to the extent they exist, are the result of lack of warehouse and logistics space in the Lower Mainland and that is because there is a shortage of industrial land. In the strange ways Vancouver Fraser Port Authority management think the solution to that is to sacrifice precious BC agricultural land for more port expansion, meaning BC would need to import food products from the likes of China. Yes, unbelievable as it is the Port CEO Silvester once said “the Agricultural Land Reserve is emotionally but not economically important to the region and more must be done to ensure land is available for industry.”

A second factor is the rail bottleneck going East - aka Fraser Canyon. Grain and other bulk shipments are often delayed by rail container traffic. The southern rail route is heavily congested and as the 2021 floods proved vulnerable.

25% of the total traffic is US container traffic that Canada handles - with no economic value to Canada – is discretionary and is of little economic value to Canada. 

The solution is of course obvious to all - but it is not one that VFPA management are interested in. 

It involves diversifying container trade by using the expanding Prince Rupert terminals. Its port operator, DP World, is investing $ millions in expanding the current Fairview Terminal and will soon start on a second terminal on South Kaien Island. Prince Rupert capacity will expand by over 2 million TEUs a year. Add that to current expansion in Vancouver and the west coast will have 10.5 - 11 million TEU capacity, sufficient to handle Canada’s trade for decades to come without ever building RBT2.

The Proof? 2021 west coast actual volumes in TEU = 4.74 million. At a growth rate of 3% to 2030 and 2% beyond west coast volumes by 2040 will be 8.2 million TEUs versus a planned capacity of 10.5 - 11.0 million TEUs, WITHOUT EVER BUILDING RBT2. Where do the percentage increases come from - THESE ARE VFPA’s NUMBERS. And if the US traffic were taken out then by 2040 west coast volumes would be about 6 million TEUs.

So why is the federal government still allowing VFPA to progress the project? 

Answer - vested interests. 

Stakeholders such as the Canadian and foreign entities that have invested in warehouse and logistics infrastructure and plan to build more want a return on their investment. Add to that the foreign port operators that see an opportunity to make a lot of money building and operating RBT2 at no risk to themselves.

VFPA has an extensive lobby in Ottawa and is prepared to do anything to get its project approved. They have supporters inside cabinet - the Transport Minister and the Trade Minister are two of several. Potentially add in the Prime Minister who incredulously wants to repair Canada/China relations and increase trade with them - evidenced by his creation of an Indo-Pacific Advisory Committee with the likes of China lovers such as Barton and Pettigrew as key advisors. This appears to be one of several reasons RBT2 is still in the frame.

Will the federal government buy into the VFPA fairy tales and sacrifice the Roberts Bank ecosystem, or will they finally deny RBT2 project approval? It is time for the federal government to say NO to RBT2. It is well past time.

Against Port Expansion in the Fraser Estuary Community Group

June 19, 2022.

The Garden City Conservation Society has recently sent an excellent analysis of the Terminal 2 project to the federal Environment Minister and Cabinet. As a sequence of illustrated topics, it is clear and readable.

Read it here:
stoprbt2_enablesuccess_gccs.pdf

They suggest the project is “a train wreck on the verge of happening” and that it needs to be stopped to save the Roberts Bank ecosystem from further degradation.

The submission is organized into a number of topics and is the most comprehensive and fulsome analysis yet of the disastrous RBT2 project and why it must never be approved.

Why is it that bureaucrats in Ottawa believe it is OK to hide science from the public view? Are they directed to do so by their political masters, or by the Prime Minister’s office? 

In the early part of 2022 government scientists submitted two commentaries on Roberts Bank Terminal 2 to their bosses in Ottawa. But these have never appeared anywhere in the public domain. 

One was a commentary on the draft conditions for RBT2. The other was a commentary on the VFPA produced biofilm guidance manual. The scientists identified many errors and invalid conclusions in both documents.  

On the draft conditions for approving RBT2 the scientists point out the many shortcomings. In particular they identified a major error, whereby the proposed conditions suggested biofilm re-creation on a major scale that the scientists have repeatedly proven couldn’t possibly work on the scale required. In addition the scientists point out that once project approval is given should mitigation measures fail there is no means to stop the project and prevent large-scale environmental degradation. The draft conditions have also attracted a lot of negative comment on the RBT2 registry from a number of well-qualified respondents. 

On the biofilm guidance manual, apparently developed by port staff and/or their contractors, government scientists identified the many flaws in the Port’s understanding of biofilm. For example the manual fails to recognize it is the salinity trigger that causes the biofilm to produce large amounts of essential long-chain polyunsaturated fatty acids and only during the spring season, when large volumes of fresh water wash over the mudflats. 

MP Richard Cannings raised this very issue of science muzzling on February 7 2022 in the House. Why is it still ongoing? 

The MP for Delta has been asked to get copies of these two documents, but thus far her office has failed to get them from the powers that be in Ottawa. 

This is not a new problem. In 2012 government scientists investigated the presence of a virus, which had been found in both farmed and wild salmon. Kristi Miller-Saunders, a federal biologist authored a study demonstrating that this virus was infecting both farmed and wild salmon. But as the UK Guardian Newspaper revealed in March 2022 successive federal governments, including the Trudeau government, kept the study hidden and ignored its recommendations. It took a ten-year battle with the federal government and a freedom of information request before the federal information commissioner ordered the study to be released. 

Where is Canada’s law and order and good government? Where is Canada’s transparency and accountability if the federal government can choose to hide government scientists’’ findings it doesn’t like?

Wondering when to expect a decision on Roberts Bank Terminal 2?

By now a decision on the RBT2 project should have been made. After eight years of studies, assessments, public hearings and comment periods a decision is overdue. The science, facts and evidence are compelling, RBT2 will result in significant adverse environmental effects that cannot be mitigated. There is no economic justification – RBT2 is not needed now and never will be. 

There is no shortage of terminal capacity now, or for the future. Terminal capacity is being added in Vancouver and Prince Rupert, sufficient to handle Canada’s trading needs for years to come. Container volumes in Vancouver area ports for Q1 2022 were 10 percent lower than the same period in 2021 and lower for the equivalent period in 2019, prior to the pandemic.

The federal government’s decision pause has been lifted. The final round of public commentary – with thousands of opposing submissions – closed March 15.

But where is the decision? You may well ask.  A wall of silence has descended on this project. The federal government appears to be in no hurry to make a decision.

However the Vancouver Fraser Port Authority (VFPA) has not given up. Despite the absence of a project approval they are working to identity a contractor to build a new landmass and marine structures, and a terminal operator to build, equip, and operate the terminal.  

In Mid May VFPA is playing host to the World Ports Conference to be held in Vancouver, where they will again be promoting RBT2.

The VFPA lobby in Ottawa is also hard at work. There are numerous ads promoting RBT2 in the media - print, radio, television, electronic, webcasts, billboards. Several of these are aimed directly at the politicians with ads in two journals as well as a billboard near parliament hill – see the attached recent examples. 

RBT2_Advertizing.pdf

The Vancouver Fraser Port Authority is now adopting a new strategy and gearing up for a fight. It maintains many of the adverse environmental effects that will result from RBT2 are beyond its care and control (marine shipping, up stream Fraser River, road and rail traffic through the lower mainland and into the interior). They make that very clear in their recent submission to the Impact Assessment Agency Canada, by pinning the responsibility on governments. 

If the decision does not go their way VFPA may be gearing up for court action – one federal government agency suing another?!!! 

Equally concerning is that Transport Canada has come out in favour of RBT2, with the Department of Fisheries and Oceans also being somewhat supportive. 

In brief this is the project status as of mid May:

• VFPA responded to the last round of public comments on April 22 with part one of its commentary on the opposition. It provided a supplement to the part one submission on May 13. On its face the part one response contains little new and is rather a repeat of the assertions and myths that VFPA has been peddling for a long time.
• The part two VFPA submission, coming soon, will be their response to the biofilm concerns.
• VFPA might be able to address  the issues concerning Southern Resident Killer Whales, salmon etc. VFPA does not have an answer to the biofilm issue and the salinity trigger, but continues to peddle its flawed science in the hope it can convince the decision makers. RBT2 lives or dies on the biofilm issue.
• Since the 2020 Review Panel Report eight new science papers have been published in peer-reviewed journals supporting the Environment and Climate Change Canada (ECCC) scientists’ concerns about the negative effects of RBT2 on the intertidal food web and the biofilm, a critical source for millions of migratory and other shorebirds as well as many other wildlife species. 
• Major organizations have come out opposing RBT2 on environmental grounds, including Birds Canada, Nature Canada, Raincoast Conservation, Western Hemisphere Shorebird Reserve Network, BC Nature, Audubon.
• Global Container Terminals continues to push its Deltaport Berth 4 alternative and takes every opportunity to criticize VFPA and RBT2.
• DP World has significant container terminal expansion in the works both in Vancouver and Prince Rupert. 
• Several key documents are missing from public view. ECCC scientists have written two commentaries, one criticizing the draft conditions and the other on the VFPA biofilm manual. These are hiding somewhere in Ottawa. Also missing - a “whole of government” response to RBT2. 
• VFPA continues to promulgate the myth that BC is out of container terminal capacity, despite assertions to the contrary by the terminal operators. There are government committees discussing supply chain congestion and trade logistics and it is clear RBT2 is in the frame of these discussions.
• Canadian and foreign interests have invested in warehouse and logistics infrastructure, assuming that RBT2 would be approved. They want a return on their investment.

We need constant and ongoing pressure on the ECCC minister and on cabinet. 

Write to:
Environment Minister ec.ministre-minister.ec@canada.ca
MP for Delta              carla.qualtrough@parl.gc.ca
Transport Minister   TC.ministeroftransport-ministredestransports.tc@tc.gc.ca
Fisheries Minister     min@dfo-mpo.gc.ca

The Party’s Over – It’s Time to Call it a Day

The final round of public comment on the Vancouver Fraser Port Authority’s (VFPA) Roberts Bank Terminal 2 (RBT2) project closed March 15 2022.

The party is over. After 13 years of submissions, reviews and public hearings It is time now for the federal government – Cabinet (Governor in Council) - to make a decision under the governing legislation CEAA 2012 Section 52. To paraphrase the legislation:

• Section 52 subsection (2) - If the decision maker (Minister of Environment and Climate Change Canada ECCC) decides that RBT2 is likely to cause significant adverse environmental effects then it is must be referred to the Governor in Council (Cabinet) to determine whether those effects are justified in the circumstances.
• The Governor in Council may then decide:

• (a) that the significant adverse environmental effects that the designated project is likely to cause are justified in the circumstances; or
• (b) that the significant adverse environmental effects that the designated project is likely to cause are not justified in the circumstances.

We know RBT2 is likely to cause significant adverse environmental effects – the Review Panel said so; government scientists have said so; many independent scientists and experts in wetlands and coastal ecology have said so,.

RBT2 cannot be justified in the circumstances. There are already announced alternatives that can deliver additional container terminal capacity when the market warrants it sufficient to meet Canada’s trading needs for decades to come. These alternatives will do less environmental damage, will be much cheaper and provide more effective, sustainable terminal capacity.

The responsible ministry (ECCC) has stated many times over the decision will be made based on the science, evidence and the facts. All three of those already determine that RBT2 must be denied approval. 

The science, facts and evidence are overwhelming:

• ECCC scientists and other independent researchers in wetlands and coastal ecology have produced powerful additional evidence in at least five new studies published in international peer-reviewed scientific journals that further demonstrate how RBT2 will affect both biofilm quality and quantity over the entirety of Roberts Bank as well as threaten the entire species of Western Sandpiper (Calidris mauri) in a manner that cannot be mitigated.
• Hundreds of other scientists and biologists have opposed RBT2 citing similar science and evidence.
• Major national and international environmental organizations have weighed in opposing RBT2, including: Nature Canada, Birds Canada, Birdlife International, Western Hemisphere Shorebird Reserve Network, BC Nature, Audubon Society, BC Rivers Institute, Nature Vancouver, Raincoast Conservation, David Suzuki, Ecojustice, Boundary Bay Conservation Society, Garden City Conservation Society, Canadian Parks and Wilderness Society, citizen scientists.
• University Professors from UBC, SFU, Western, UNBC, Physicians, Vancouver Coastal Health, The cities of Delta, Richmond and White Rock, The Salish Sea Institute, First Nations, US Indigenous groups, Members of Parliament, are all opposed to RBT2
• Existing terminal operators are demonstrating how other terminal expansions already in the planning phase can meet expected trading needs.

 There is more than enough science, evidence and facts to deny RBT2 approval.

But despite all that the VFPA is refusing to give up. On March 15, the day the final public comment period closed VFPA wrote to the Minister ECCC stating they will be responding to all the opposing submissions and providing further clarification in the weeks to come.

When is this going to end? When will VFPA finally accept the party is over and it is decision time? 

Let’s hope the Minister does the right thing and says no more submissions. But if he does accept further submissions then government agencies, scientists, environmental groups, indigenous groups, the public must all have opportunity to review and respond. 

Which part of NO does the Port of Vancouver not understand?

A final decision on the Vancouver Fraser Port Authority (VFPA) Roberts Bank Terminal 2 (RBT2) Project is very close. The Federal Government recently extended the public comment period and are asking for comments from the Public, prior to making a decision to:

• approve with mitigation, or 
• to recognize the signifcant adverse environmental effects that cannot be mitigated, but to"justify it in the circumstances", or
• to deny approval. 

LET US MAKE SURE THE DECISION IS TO DENY APPROVAL. 

MARCH 15 2022 WAS THE DEADLINE. COMMENTS ARE NOW CLOSED, BUT:

• WRITE TO THE ENVIRONMENT MINISTER
  ec.ministre-minister.ec@canada.ca
• WRITE TO YOUR MP. IF YOU LIVE IN DELTA WRITE TO MP CARLA QUALTROUGH carla.qualtrough@parl.gc.ca
• PSOT ON FACEBOOK, WRITE TO THE MEDIA

Here is a letter template for you to use.

RBT2_Public_Letter_Jan_2022_0.docx

Once you have your letter:

• Copy and paste  it into your email
• Sign it with your name and address
• Insert the date
• Email it to the addressees or media

Want more information? look at this Powerpoint.

Roberts_Bank_Terminal_2__March_2022.pptx

Do not be fooled. The Port is using extensive PR campaigns to convince the public that their science is solid. On the surface it looks like a good story, but beware. Here are the facts:

1. The Port Authority’s just released additional information does not alleviate the environmental concerns. It does not resolve the substantive issues raised by Environment and Climate Change Canada (ECCC) scientists.
2. Environment Canada scientists have proven RBT2 related changes will disrupt the salinity trigger that shocks marine type diatoms into high fatty acid production, thus negatively impacting the quality and quantity of biofilm available to migrating shorebirds.
3. No other sources of biofilm are available.
4. VFPA says biofilm habitat can be created but the scientists and peer-reviewed studies show biofilm cannot be created on a scale necessary to compensate for what will be lost.
5. RBT2 related changes are immediate, irreversible, continuous and cannot be mitigated.
6. The government drafted conditions for approval will allow RBT2 to proceed with no means to stop it when mitigation fails.
7. Nothing can then prevent wildlife population declines – perhaps towards species extinction - when biofilm quality and quantity is impacted.
8. Yet there is a faction in Ottawa that appears to want this project approved, regardless of the science. 

The draft conditions as written are essentially meaningless. Basically VFPA is required to consult monitor mitigate follow up and report. There is no stopping or changing the project even if bird populations show declines, and/or ultimately go extinct. 

• Where is the action in the monitoring and follow up if mitigation measures don’t work?
• What happens if any of the "conditions imposed by Ottawa fail? Once the project is approved there is no way of stopping the project or the environmental degradation and wildlife declines
• Nowhere in the conditions does it require work or the project to stop.

From a business standpoint the natural disasters this year - wildfires and floods - have proven beyond a doubt that this southern trade corridor is fragile and it is foolhardy to pump even more container traffic through an already congested corridor that even when infrastructure repairs are made will still be exposed to natural disasters and events that will cause further damage and close rail and road routes in and out of BC. There is a viable alternative - Prince Rupert. VFPA and some factions in Ottawa know expanding Prince Rupert is the better way to satisfy Canada’s trading needs but they still refuse to recognize it.

Will RBT2 be approved?

Not if the Environment Minister and the federal cabinet are to retain any credibility when it comes to environmental and wildlife care and protection.

While the negative effects of RBT2 on trophy species such as salmon and Orca in the Salish Sea, as documented in a letter from a group of concerned scientists, are indeed alarming, there is an even more important connection; that being between RBT2 and its disruption of the entire food web in the Fraser River Estuary. 

Environment and Climate Change Canada (ECCC) researchers, in their submission to the Canadian Impact Assessment Agency Registry - (Environment and Climate Change Canada (ECCC) Review of Information Request 2020-4: Biofilm and Effects to Migratory Birds, and Appendix IR2020-4-A - Registry # 2282) - inform that the rich fields of intertidal biofilm on Roberts Bank that are depended on by an entire species of migratory shorebirds will be irretrievably crippled by RBT2; that same biofilm is also responsible for generating the fatty acid nutrients relied on by other shorebirds, crabs, the commercial crab harvest, fish, including salmon, and, yes, Orcas. 

Fundamentally, RBT2 threatens to put a permanent stake in the heart of Roberts Bank that drives the productivity and biodiversity of the whole Fraser River estuary. 

The richness of intertidal biofilm on Roberts Bank is exactly why it is a major stop on the Pacific Flyway for migratory birds. It is also why that wildlife management area is identified as providing “critical wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada”.

It is for all these important reasons that the approval for Roberts Bank Terminal 2 must be denied by the federal government.

Although weeks ago Environment and Climate Change Canada (ECCC) scientists had critiqued the new Vancouver Fraser Port Authority (VFPA) final submissions and sent them to Ottawa, they were not appearing on the Canadian Impact Assessment Agency registry for RBT2. Then the Transport Canada submission appeared, but still nothing from ECCC.

Federal MPs from the NDP were looking for them as well and on February 7 they stood in the House to ask why they were not being released and asked the Environment Minister to stop muzzling government scientists. Several days later the ECCC submission went up on the registry. 

Predictably they were very critical of the VFPA science assertions. In their submission ECCC scientists have maintained the position – RBT2 will result in significant adverse environmental effects that cannot be mitigated.

Here is a summary of the ECCC concerns:

• The Project would still result in a reduced population viability for the Western Sandpiper, and will likely constitute an unmitigable and irreversible species-level risk to Western Sandpipers.
• Predicted changes to salinity as a result of RBT2 will likely result in a reduction in the quality and quantity of marine-type diatoms in intertidal biofilm that provide essential nutrients for Western Sandpipers during their long-distance migration to their breeding grounds
• Reductions in salinity oscillations on Roberts Bank resulting from RBT2 can be expected to reduce the availability of prey for foraging shorebirds.
• The Port Authority’s conclusion that salinity changes resulting from the project will not adversely affect biofilm and migratory shorebirds is inconsistent with the established ecology of biofilm and with the results of the Proponent’s own studies.
• No proof that loss of function of productive biofilm habitat can be mitigated by large-scale re-creation of biofilm habitat capable of supporting shorebirds.
• Project effects on biofilm and Western Sandpipers would be immediate, continuous, irreversible, and unmitigable.
• An adaptive management approach would not provide an appropriate solution to remediate what would be the adverse impact of the project on biofilm and western sandpipers.

Read the full ECCC submission here

Highlighted_RBT2_ECCC_comments_on_final_IR_response_final.pdf 

It has been nothing but bad news recently for the VFPA Roberts Bank Terminal 2 (RBT2) project. 

Submissions opposing RBT2 have been pouring into the Canada Impact Assessment Agency’s registry, now numbering in the hundreds.

Last week the Canadian National Observer published an article, later picked up by the Toronto Star “Environment Canada warned port expansion puts shorebirds at risk but feds withheld final comments from review panel”

https://www.thestar.com/news/canada/2022/02/01/environment-canada-warned-port-expansion-puts-shorebirds-at-risk-but-feds-withheld-final-comments-from-review-panel.html

Then on February 7 Richard Cannings NDP MP for South Okanagan – West Kootenay stood in the house during question period to raise the issue of scientists’ muzzling with respect to this project.
Here is how this was recorded in Hansard:

44TH PARLIAMENT, 1ST SESSION
EDITED HANSARD • No. 025
CONTENTS
MONDAY, FEBRUARY 7, 2022

Mr. Richard Cannings (South Okanagan—West Kootenay, NDP):      Mr. Speaker, two weeks ago, my NDP colleagues and I wrote a letter to the Minister of Environment about the Roberts Bank terminal 2 project on the Fraser River delta. We pointed out that critical information gathered by the minister's own scientists has been hidden from the public in the assessment process. The information showed that this project would result in irremediable damage to the local environment and endanger the species living there. Would the minister stop muzzling scientists, make this information public and extend the consultation process?

Hon. Jonathan Wilkinson (Minister of Natural Resources, Lib.):      Mr. Speaker, as my hon. colleague knows, this process has been an ongoing environmental assessment for the past number of years. It has proceeded through a whole range of different phases. It is now in the process of coming toward a decision. Certainly we will be considering all of the science, including science with respect to migratory birds, the impacts of noise and other issues that have arisen throughout the course of the process and on which the panel has provided information.

Then on February 8, 2022. Maritime Magazine published a report “Infrastructure upgrades at Port of Prince Rupert amid supply chain challenges”.

https://maritimemag.com/en/infrastructure-upgrades-at-port-of-prince-rupert-amid-supply-chain-challenges/?utm_source=rss&utm_medium=rss&utm_campaign=infrastructure-upgrades-at-port-of-prince-rupert-amid-supply-chain-challenges

The article goes on to describe expansions of Prince Rupert’s container terminal, stating:

“The Phase 2B expansion of the Fairview Container Terminal is a response to the rapid growth in container traffic that Prince Rupert has achieved over the last five years. The first stage of the expansion is now 50 per cent complete and will be finished in July 2022, increasing capacity at the Fairview Container Terminal to 1.6 million TEUs, making it the second-largest container terminal in the country. 

The second stage of the expansion is set to be completed in late 2024 and will see the terminal’s capacity grow to 1.8 million TEUs. In addition to the hundreds of construction jobs created by the expansion, it will have a significant permanent economic impact on Prince Rupert, Indigenous communities, and the surrounding region. The Phase 2B expansion will ultimately result in 300 additional full-time equivalent (FTE) positions at DP World’s Fairview Container Terminal”. 

Prince Rupert's terminal expansions:

• two sailing days closer to Asia, 
• easier and faster rail access to the rest of Canada and the US, 
• with almost no environmental impacts,
• and much cheaper per TEU than RBT2 will ever be, 

Means RBT2 is not needed now and never will be.

With the proven environmental degradation to Roberts Bank if RBT2 were to be built, perhaps now the federal government will finally deny project approval. 

A final decision on the Vancouver Fraser Port Authority (VFPA) Roberts Bank Terminal 2 (RBT2) Project is very close. The Federal Government are asking for comments from the Public, prior to making a decision to approve with mitigation, or to deny approval. 

LET US MAKE SURE THE DECISION IS TO DENY APPROVAL. 

ONLY FOUR WEEKS LEFT – FEBRUARY 13 2022 IS THE DEADLINE 

NOW IS THE TIME:

• START WRITING TO THE ENVIRONMENT MINISTER 
  ec.ministre-minister.ec@canada.ca
• GET YOUR COMMENTS OPPOSING RBT2 ON THE IMPACT ASSESSMENT AGENCY CANADA (IAAC) WEBSITE.
• SEND YOUR COMMENTS OPPOSING RBT2 TO conditions@iaac-aeic.gc.ca

Here is a letter template for you to use. RBT2_Public_Letter_Jan_2022.docx

• Copy and paste it into your email
• Sign it with your name and address
• Insert the date
• Email it to conditions@iaac-aeic.gc.ca

Do not be fooled. The Port is using extensive PR campaigns to convince the public that their science is solid. On the surface it looks like a good story, but beware. Here are the facts:

1. The Port Authority’s just released additional information does not alleviate the environmental concerns. It does not resolve the substantive issues raised by Environment and Climate Change Canada (ECCC) scientists.
2. Environment Canada scientists have proven RBT2 related changes will disrupt the salinity trigger that shocks marine type diatoms into high fatty acid production, thus negatively impacting the quality and quantity of biofilm available to migrating shorebirds.
3. No other sources of biofilm are available.
4. VFPA says biofilm habitat can be created but the scientists and peer-reviewed studies show biofilm cannot be created on a scale necessary to compensate for what will be lost.
5. RBT2 related changes are immediate, irreversible, continuous and cannot be mitigated.
6. The government drafted conditions for approval will allow RBT2 to proceed with no means to stop it when mitigation fails.
7. Nothing can then prevent wildlife population declines – perhaps towards species extinction - when biofilm quality and quantity is impacted.
8. Yet there is a faction in Ottawa that appears to want this project approved, regardless of the science. 

The draft conditions as written are essentially meaningless. Basically VFPA is required to consult monitor mitigate follow up and report. There is no stopping or changing the project even if bird populations show declines, and/or ultimately go extinct. 

• Where is the action in the monitoring and follow up if mitigation measures don’t work?
• What happens if any of the "conditions imposed by Ottawa fail? Once the project is approved there is no way of stopping the project or the environmental degradation and wildlife declines
• Nowhere in the conditions does it require work or the project to stop.

From a business standpoint the natural disasters this year - wildfires and floods - have proven beyond a doubt that this southern trade corridor is fragile and it is foolhardy to pump even more container traffic through an already congested corridor that even when infrastructure repairs are made will still be exposed to natural disasters and events that will cause further damage and close rail and road routes in and out of BC. There is a viable alternative - Prince Rupert. VFPA and some factions in Ottawa know expanding Prince Rupert is the better way to satisfy Canada’s trading needs but they still refuse to recognize it.

Will RBT2 be approved?

Not if the Environment Minister and the federal cabinet are to retain any credibility when it comes to environmental and wildlife care and protection.

Why Did Ottawa Withhold its Roberts Bank Terminal 2 Project Closing Submission? 

Environment And Climate Change Canada did prepare a closing submission for the Roberts Bank Terminal 2 Project Environmental Assessment Panel. But at the last moment Ottawa decided not to submit it. Here is what happened.

In 2019 after the Roberts Bank Terminal 2 hearings were completed the Federally appointed Environmental Assessment Panel asked for closing submissions, before writing its final report and recommendations. The Panel specified they were looking for a summary of each participant's position regarding the project. They also made it clear no new information was to be included in that submission.

Many submissions were made and posted to the registry, but a significant one was missing. There was no closing submission from Environment and Climate Change Canada.

This was very strange, given that ECCC had major concerns with the RBT2 project. Where was ECCC? 

It took an Access to Information (ATIP) request to the Federal Government to find out why. In fact ECCC scientists had prepared a response and submitted it to their bosses in Ottawa. It went through several iterations and was all ready to go but, immediately before the Panel deadline, an ADM Major Ports Steering Committee meeting on August 20 2019 decided to withhold Environment Canada's Closing Submission. 

This left the Vancouver Fraser Port Authority’s closing submission to go unchallenged. In their submission they took the opportunity to disparage and try to discredit the Environment Canada science in multiple places in their closing submission (#2045 August 26 2019 – e.g. pages 234 and on). 

Through the ATIP process a copy of the final ECCC Closing Submission was finally obtained, much after the Panel had submitted its final report. It is attached in its entirety.  

ECCC_Closing_Panel_Submission_RBT2.pdf

Here is an extract of the ECCC closing submission in relation to the RBT2 impacts on Shorebirds and Biofilm:

“Based on ECCC’s review of the scientific literature, Project related changes to the salinity regime would impact the quality and quantity of biofilm available to shorebirds. These changes are likely to include:

• The disruption of the salinity trigger responsible for shocking marine type diatoms into high fatty acid production;
• Changes in community composition of diatoms in biofilm from marine to freshwater types that may produce lower amounts of fatty acids;
• An unfavourable spatial shift in the centre of the distribution for biofilm towards sandier substrates where biofilm would be inaccessible for foraging Western Sandpipers due to tongue morphology; and
• A reduction in the biomass of available biofilm, resulting in lower abundance of food for shorebirds during the critical northward migration period.

Based on ECCC’s review of the current scientific literature, including the studies undertaken by the Proponent, ECCC remains concerned there are no practical mitigation measures available to address the large scale impacts of changes to biofilm on Roberts Bank.”

Later in the same submission, and regarding VFPA’s assertion that it is possible to recreate biofilm on a large scale, ECCC states: 

“ ECCC is of the view that it is not currently possible to recreate mudflats with similar sediment characteristics and biofilm fatty acid productivity as the Roberts Bank area”

Finally in the concluding statement of the ECCC closing remarks they state: 

“ECCC continues to conclude that predicted Project-induced changes to Roberts Bank constitute an unmitigable species-level risk to Western Sandpipers and shorebirds more generally”. 

Not only does the ECCC submission demonstrate that VFPA’s assertions on biofilm and shorebirds are false, it also destroys their assumption that there can ever be a workable adaptive management approach when the effects are deemed to be  immediate, irreversible and unmitigatable. 

By now publishing the withheld ECCC comments it sends a strong statement that the federal regulators must now take the ECCC position on RBT2 into full consideration.  

By doing so the Federal government has no choice but to deny approval for Roberts Bank Terminal 2. 

November 30 2021

 The devastating fires this past summer in Lytton and now the flooding in the Fraser Valley and Southern BC have laid bare the absurdity of Vancouver Fraser Port Authority’s (VFPA) plans to build a second container terminal on Roberts Bank and add another 2.5 million of container (Twenty foot equivalent –TEU) capacity in Vancouver.   

The loss of life, homes, and livelihoods from the most recent catastrophic flooding is a tragedy.  

But there is another disaster that could and should have been expected. That is the damage to vital road and rail links that has resulted in total disruption of Canada’s west coast trade routes. Every time a natural disaster like this occurs, it takes several weeks for roads and rail track to be repaired and for railroads to re-start operations. It takes even longer to clear the backlog and get normal operations resumed.  The impact to Canada's economy of these road and rail outages is massive. This time around it is even worse. Port congestion was already causing supply chain disruption. BC access to the rest of Canada will be impeded for months. Damage to Highway 5 – a major trade corridor - is extensive and it will be a long time before it is re-opened. The southern rail route through the Fraser Canyon and over the Rockies, used by the Port of Vancouver, was already heavily constrained prior to this latest disaster.

In spite of this constant threat to the Canadian economy, VFPA plans to focus even more of Canada's trade through the Port of Vancouver, rather than diversifying and balancing container capacity in Prince Rupert.  What good is another 2.5 million of container capacity in Vancouver if the railway linkage to Eastern Canada and the United States (where most of the containers will go) is repeatedly disrupted?

The federal government was warned 10 or more years ago, when it commissioned an expert panel to study port expansion. Diversify our trade corridors; don’t funnel everything through the Port of Vancouver, is what the experts recommended. Maximize the Port of Prince Rupert, they recommended, before adding further port infrastructure in Vancouver. But the federal government ignored it and let the VFPA - a crown agency - continue to expand, subsidizing them in the process. Now we are paying the price. It is time to stop this. 

There is a proposal for a new container terminal in Prince Rupert that would more equally balance container-handling capacity between Vancouver and Prince Rupert.  If there is a disruption on the rail lines leading into Vancouver, ships could be diverted to Prince Rupert.  But if all of the new container capacity is built in Vancouver, ships will just have to wait at anchorage until the railway blockage is repaired (and longer until the backlog is cleared).

If, or more likely now when, there is another disruption on rail lines in and out of BC there will be two major ports each capable of handling large volumes of container traffic if one is compromised.

Will the Canadian government finally wake up to this risk and tell the VFPA the next phase of container capacity must be built in Prince Rupert, in order to mitigate this risk that occurs when roads snd railway lines leading into Vancouver are disrupte 

The federal government must tell the Port of Vancouver - no more port expansion; Roberts Bank Terminal 2 will not be built. 

For more information visit www.againstportexpansion.org 
or email Roger Emsley at info@againstportexpansion.org

Update December 14 2021

The MV Zim Kingston is in Nanaimo where crews are unloading the remaining damaged contianers

https://www.kuow.org/stories/burned-out-cargo-ship-makes-it-to-port-105-of-its-shipping-containers-don-t

A serious and concerning accident occurred on October 22 2021. The container vessel ZIM Kingston, which was headed to dock with a full load of containers to a berth at Deltaport on Roberts Bank, was caught in heavy seas close to the southern tip of Vancouver Island. Our sympathy is with the vessel's owner and its crew.

Initial reports indicated 40 containers went overboard. It now transpires 109 containers went into the sea and are now drifting northwards up the coast of the island. Some containers have been tracked floating northwest of Vancouver Island towards Haida Gwaii, low in the water so a real hazard to other shipping. At least one container has been seen up on the rocks at Cape Scott. The coast guard says that while some metal containers have been reported on shore, others are expected to sink to the ocean bottom.

After the containers went overboard the vessel came into Georgia Strait and is now anchored off Victoria BC. Containers on the vessel caught fire soon after anchoring and have been on fire for five days with no signs of abating.  Most of the crew were evacuated. Coast Guard and other vessels are close by attempting to extinguish the fires

This is the kind of accident that could decimate wildlife and despoil habitat in Canadian waters. With the vessel congestion through Juan de Fuca Strait and into the Georgia Strait this may happen again in the future. If such an accident were to happen in the Georgia Strait between the mainland and Vancouver Island the effects on wlidllife and important ecosystems will be devastating. This is why there can be no further port expansion in the Fraser Estuary. This is why Roberts Bank Terminal 2 must be denied approval

MP for Delta Carla Qualtrough was re-appointed to the federal cabinet on October 26 2021.

She has previously spoken out against the Roberts Bank Container Terminal 2 (RBT2) project that is now in the final stages of environmental assessment. The government will make a decision in the near future to approve, approve with mitigation, or deny approval. We must make sure it DENIES APPROVAL.

We now need Cabinet Minister and MP Carla Qualtrough to act on her concerns. Here is part of what she wrote on September 19 in a letter that is published on the APE website:
 "I am of the strong opinion that port expansion cannot be at the expense of the environment. As you know, I have followed this file very closely over the years and have been firm in my position that I am not convinced that the adverse and cumulative environmental impacts of the RBT2 Project can be adequately mitigated"

So now we need her to act on what she said and ensure the cabinet acts to deny approval of RBT2.

Write to the Hon Carla Qualtrough at carla.qualtrough@parl.gc.ca and ask her to voice her concerns in cabinet and parliament. Ask her to make sure RBT2 is DENIED APPROVAL. Send a copy of the email to the Minister Environment and Climate Change Canada - Steven Guilbeault - at ec.ministre-minister.ec@canada.ca. Ask both for a response to your letter.

Please also send a copy to saynottot2@gmail.com

Five Questions concerning the Roberts Bank Terminal 2 Project were sent to federal election candidates as follows:

1. If elected will you speak up and publicly oppose approval of RBT2? Yes or No.
2. Government scientists have said if built RBT2 will result in immediate, irreversible, continuous, negative environmental effects that cannot be mitigated. Do you agree and endorse their scientific conclusion? Yes or No.
3. The Lower Fraser and Estuary has lost 80 percent of the natural habitat to port and industrial development. Will you support action to protect what remains of the natural habitat? Will you commit to making Roberts Bank a national marine protected area with no further port development on Roberts Bank? Yes or No.
4. The Salish Sea - Juan de Fuca Strait, Georgia Strait and Puget Sound - are choking from ever increasing commercial vessel transits. Will you support placing an annual cap on the number of commercial vessel transits through Canadian waters to better protect wildlife species and their habitat? Yes or No..
5. Canada’s trading needs will be well satisfied for decades to come with the already announced expansions of container terminal capacity in Prince Rupert as well as expansions of existing Vancouver area terminals, without ever building Roberts Bank Terminal 2. Do you support maximizing terminal expansion potential at Prince Rupert? Yes or No.

• Monika Dean NDP
  No Response 
• Hong Yan Pan Independent
  

  1. Yes 
  2.  Yes, as long as it is evidenced based report e.g. peer reviewed high quality research. I appreciate indigenous people consultation is also included in the decision making process. 
  3. Yes 
  4. Yes 
  5. Potentially yes, I need to do separate research to answer some questions e.g. what are the environmental impacts to Prince Rupert? Especially, what are the emergency measures to prevent oil spill from the containers in case of major earthquakes in the Prince Rupert area?

• Carla Qualtrough Liberal Party
  Responded Sep 19 2021 as follows:

Dear Roger,

I am writing this letter in response to your questions to candidates in the
2021 with respect to the RBT2 Project.

To begin, please be assured that while I recognize the key role that
Deltaport plays in our economy and global trade, I am of the strong opinion
that port expansion cannot be at the expense of the environment.

As you know, I have followed this file very closely over the years and have
been firm in my position that I am not convinced that the adverse and
cumulative environmental impacts of the RBT2 Project can be adequately
mitigated.

In the 2019 election we were awaiting the Environmental Assessment
Panel’s findings, which were published in March 2020. The findings were
very concerning and reinforced my position. As you know, the federal
Environment Minister subsequently wrote to the Port in August 2020
requesting further information and the Port has not as of yet responded.

The City of Delta and the City of Richmond have also expressed their
opposition to the Project in light of the Panel’s findings, and have written to
the Prime Minister to request that the project not be approved.

Rest assured that I am very committed to following the science and
listening to the experts when it comes to this project as well as to ensuring
that we protect and restore the Fraser River Estuary. I believe that Delta
can benefit significantly from our specific Liberal platform commitments to
restoring and enhancing wetlands: to a Fresh Water Strategy that will
restore the Fraser River Estuary; and to advancing the Pacific Salmon
Strategy.

I also think that our community will benefit from the ongoing port
governance review being conducted by Transport Canada. The “What We
Heard Report” that was published highlighted the need to assess and
manage the negative impact of port development, as well as strategically
managing ports along the West Coast.

Additionally, the work being done to re-constitute a multi-jurisdictional
Fraser River regional coordinating body modelled after the previous
FREMP is very important. I am also very fond of the recently announced
Burrard Inlet Environmental Science and Stewardship Agreement between
the Government of Canada and the Tsleil-Waututh Nation that will
coordinate stewardship activities and scientific research and analysis in
Burrard Inlet. This Agreement includes a $20 million investment over ten
years to maintain the Burrard Inlet Environmental Science and Stewardship
Fund. I think a similar model could serve the Fraser River well, and have
spoken to the Environment Minister about exploring this post-election.

If re-elected, my approach moving forward will be to continue to convey
what I am hearing from constituents and municipal leaders; to follow the
science and expert advice; to be both critical and open-minded in
assessing new information; to ask the tough questions; and to not back
down on my areas of concern.

In closing, I have very much appreciated working with you over the last six
years. I look forward to continuing to work together in the future.

Sincerely,

Carla Qualtrough

• Garry Shearer Conservative Party
  No Response 
• Jeremy Smith Green Party of Canada
  No Response  
• Paul Tarasenko Peoples Part of Canada
  No Response  

Thanks to (Melody) Hong Yan Pan who thoughtfully and after doing her own reserach was the first candidate to answer. Thanks to Carla Qualtrough for also responding.

Attention: Supporters of the Roberts Bank ecosystem and its wildlife -  now the election is over and MP Carla Qualtrough has been re-elected please hold her to what she said in her response above. Write to MP Qualtrough at carla.qualtrough@parl.gc.ca.

Emails went out to the following Federal Election Candidates in Delta BC:

• Monika Dean NDP
• Hong Yan Pan Independent
• Carla Qualtrough Liberal Party
• Garry Shearer Conservative Party
• Jeremy Smith Green Party of Canada
• Paul Tarasenko Peoples Part of Canada

Whilst the federal election call disrupted the decision process for the RBT2 project, residents of Delta wanted to know the candidates' position on the Roberts Bank Terminal 2 Project.

This election was an opportunity to ask candidates about RBT2. In the 2019 election we got a lot of waffle. This time around we needed specific answers. No more vague answers and promises.  

Here are the five key questions sent to the candidates:

1. If elected will you speak up and publicly oppose approval of RBT2? Yes or No.

2. Government scientists have said if built RBT2 will result in immediate, irreversible, continuous, negative environmental effects that cannot be mitigated. Do you agree and endorse their scientific conclusion? Yes or No.

3. The Lower Fraser and Estuary has lost 80 percent of the natural habitat to port and industrial development. Will you support action to protect what remains of the natural habitat? Will you commit to making Roberts Bank a national marine protected area with no further port development on Roberts Bank? Yes or No.

4. The Salish Sea - Juan de Fuca Strait, Georgia Strait and Puget Sound - are choking from ever increasing commercial vessel transits. Will you support placing an annual cap on the number of commercial vessel transits through Canadian waters to better protect wildlife species and their habitat? Yes or No..

5. Canada’s trading needs will be well satisfied for decades to come with the already announced expansions of container terminal capacity in Prince Rupert as well as expansions of existing Vancouver area terminals, without ever building Roberts Bank Terminal 2. Do you support maximizing terminal expansion potential at Prince Rupert? Yes or No.

Candidates Responses will be posted as they are received.

 As further background: 

• A three person federally appointed review panel published its report on RBT2 and submitted it to the federal government in March 2020.
• In August 2020 the federal Minister of Environment asked for additional information on the project, delaying the project decision until that information is supplied.
• The VFPA committed over a year ago to submit the additional information requested to the Minister of Environment by this summer. With that information the Minister would then decide whether to grant approval or deny it.
• Summer is pretty well over but still VFPA has not submitted the additional information. Were they waiting, hoping that the election call would delay the process? 
• Once the additional information is published there will be a further round of public consultation and then the federal government will announce its decision – either to deny project approval, or to approve with mitigation.

The Against Port Expansion Community Group, which is not political, is one of over 40 groups that are opposed to the RBT2 development. The cities of Delta, Richmond and White Rock are equally opposed and have registered their opposition with the federal government. 

Roberts Bank is globally significant wetland habitat for millions of migratory and other shorebirds and waterfowl, in addition to herons, salmon, crabs, marine mammals, including endangered orcas, and other wildlife species, that all rely on the wetlands habitat. There is no other site in Canada that supports the diversity and number of birds found in winter on Roberts Bank. Approval for Roberts Bank Terminal 2 must be denied.

If you receive information from any candidates please send it to saynotot2@gmail.com.  

One of the Worst Environmental Assessments – Ever 

The Environmental Assessment for the Vancouver Fraser Port Authority's Roberts Bank Container Terminal 2 project has been ongoing for eight years. It has been a monumental failure:

• Failure to recognize the environmental importance of Roberts Bank at the mouth of the Fraser Estuary. This site should never have been chosen in the first place.
• Environmental assessment carried out under legislation brought in by Stephen Harper’s government in 2012, with fewer, less stringent protections for natural habitat, and flawed review procedures with too many loopholes.
• A heavily flawed environmental assessment by a federally appointed Review Panel, with the Port Authority having far too much sway over how the assessment was carried out.
• No cumulative effects assessment, despite significant industrialization of the Lower Fraser and estuary, with a number of port and industrial projects already under development and more planned.
• Failure to recognize independent and peer-reviewed science when considering the effects of the terminal’s man-made island on biofilm.
• Government scientists’ concerns, muzzled, downplayed, and given insufficient recognition and weight in the Panel’s decision making
• No recognition of the precautionary principle. 
• No risk analysis of vulnerable or endangered wildlife species, such as salmon, the southern resident killer whale, western sandpiper.
• No analysis of the Salish Sea’s navigation channels to determine their practical capacity in terms of vessel movements, by day, month or year.
• No impact and effects analysis of increased road and rail traffic required to service the new terminal, with the negative effects on communities in the Lower Mainland, including increased air, noise, and light pollution that threatens human health and cannot be mitigated.
• Refusal to recognize the federal government report that determined no further port expansion to take place in Vancouver until Prince Rupert’s expansion potential has been maximized.
• No independent analysis of the Port’s claims that Canada is running out of west coast container terminal capacity, especially given the concrete evidence that significant terminal expansions are being planned in Prince Rupert that obviate the need for the Roberts Bank terminal.
• Far too much weight given to mitigation and offsite habitat offsetting with no evidence these will be effective or in any significant measure compensate for the environmental damage done to the Roberts Bank ecosystem.
• Failure to assess sub tidal wetlands and cumulative effects on wetlands and wetland functions, including the failure to properly assess shorebirds, shorebird habitat and the importance of biofilm to the food web
• Failure to recognize the significant risk, where federal government scientists warned as far back as 2005 that this development will break the chain of the Pacific Flyway for migratory birds.
• Abrogation of federal government commitments to protect wetland habitats and functions.
• The Vancouver Fraser Port Authority is out of control with the federal government taking a laissez faire approach to its oversight.

The Vancouver Fraser Port Authority claims - without any evidence in support -  this project is in the public interest. This despite three cities - Richmond, Delta and White Rock - having expressed opposition to the project with the federal government, as well as over 40 environmental and other groups that also oppose building another container terminal on Roberts Bank.

All this and more is contained in this report

Multiple_Failures_in_the_Environmental_Assessment_of_The_Roberts_Bank_Container_Terminal_2_Project.pdf

Read also this recent Boundary Bay Conservation Committee report sent to the federal and provinical governments as well as mayors in Metro Vancouver.

Irreversible_Harm_to_Fraser_Estuary.pdf

Why Minister Wilkinson, Environment and Climate Change Canada saw the need to request additional information from the Port of Vancouver remains a mystery. The evidence is compelling – The Roberts Bank Terminal 2 project will result in significant adverse environmental effects that cannot be mitigated. The Review Panel said that. Government scientists said that. Peer-reviewed science, published in recognized science journals, says that. Independent experts in wetlands and wetland functions have said that. 

With the federal government having turned down a container port expansion project in Quebec on environmental grounds there are now compelling reasons to reject Roberts Bank Terminal 2. 

It is time for the federal government to act and state: 

“ Building Roberts Bank Terminal 2 presents potential significant direct and cumulative adverse environmental effects on Roberts Bank and in the Fraser Estuary. The Project is not justified in the circumstances and therefore project approval is denied”.

For how much longer is the Port of Vancouver going to continue spinning misinformation that Roberts Bank Terminal 2 is environmentally sustainable and is the only solution to satisfy Canada’s container trading needs?

 At its recent Annual General Meeting the Port of Vancouver continued with its misinformation regarding the environmental impacts of it’s Roberts Bank Container Terminal 2 (RBT2) project and the business need for more container capacity on the Canadian West Coast.

In answer to this question at the meeting:
“The Fraser estuary is on the bank of collapse, several new research studies in the media are demonstrating it. Why is the port of Vancouver persisting with its $3.5 billion plus environmentally disastrous RBT2 when both B.C. container terminal operators GCT and DP World have proposed environmentally sustainable terminal expansions?"

The Port Senior Management responded that the terminal would be built in deep water well away from shores and habitats. That is irrelevant. 

By building this huge man made island - the size of 250 football fields - they will alter tidal flows, water temperature and salinity. It is the salinity and its fluctuations that produce the fatty acid rich diatoms in the biofilm on the mudflats that is an essential food source for millions of birds and other wildlife. That man-made island lessens the fluctuations in salinity and the biofilm will no longer have the richness and the polyunsaturated fatty acids and Omega 3 that the birds need. This could well lead to the extinction of the Western Sandpipers that rely on it when they stop to refuel on their way to their arctic breeding grounds. 

In answer to another question:
“The impacts of a future potential RBT2 development on the ecosystem within the Salish Sea will be devastating. How is the Port reconciling this reality against its intention to continue with its pursuit of the new terminal?”

Port senior management stated that the additional information they are preparing for the Environment Minister shows that this project can be built and operate in ways that can mitigate environmental impacts. They went on to state: “By the time terminal 2 is complete, we are going to be leaving a legacy of environmental benefits behind as a result of the project”.

Nonsense!

The government’s own scientists are insistent, stating this project will result in significant adverse environmental effects that cannot be mitigated. They told the Environmental Assessment Panel the project’s impacts on biofilm  “are anticipated to be high in magnitude, permanent, irreversible, and continuous”. In other words, immitigable

There is no point in the Port providing more of its paid-for consultants’ developed science to the Minister. None of that science has been published in peer-reviewed science journals and much of it runs counter to the scientific community’s findings that the Fraser Estuary is part of an already observed and wider biodiversity collapse in the Salish Sea, driven by projects like Roberts Bank Terminal 2. 

Port senior management continue to misinform the public, policy makers and politicians In terms of a business need for RBT2. Port senior management claims RBT2 is the only project to meet Canada’s needs by the end of the 2020s. 

That is patently false information.  

At a recent presentation DP World, the operator of the Vancouver Centerm, Fraser Surrey Docks and Prince Rupert container terminals stated they will:

      1. Continue to operate the Fraser Surrey Docks container terminal beyond 2023 (The Port says the terminal will decline because of limitations in the River).

       2. By 2022 finish expansion of the Centerm Terminal to provide 1.5 million Container (TEU) capacity.

        3. By 2023 expand Prince Rupert's Fairview Terminal to provide 1.8-million (TEU) capacity. 

       4. Between 2028 and 2030 bring a second terminal (On South Kaien Island) into operation giving Prince Rupert container capacity in excess of 5 million TEUs. 

Taken together and adding in Global Container Terminals capacities at Deltaport and Vanterm in the inner harbour, West Coast Canada will have in excess of 10 million container terminal capacity by 2030. The Port of Vancouver’s own recently updated forecast shows West Coast Canada terminals will handle between 7.5 to 8.8 mill TEUs by 2045. Therefore there is clearly no need to build RBT2 at the huge cost of $3.5 billion plus whilst devastating the natural habitat and the Roberts Bank ecosystem in the process.

The federal government and cabinet must now recognize the only responsible action is to reject the Roberts Bank Terminal 2 project, thereby preserving this ecosystem and wildlife habitat essential for the survival of 102 species at risk of extinction, plus over 2 billion juvenile salmon, and the 1.4 million migratory birds that visit this stop on the Pacific flyway every year. 

Read these two documents to understand why the Fraser Estuary is on the brink of collapse and why RBT2 is not needed - ever

The_Fraser_Estuary_is_on_the_Brink_of_Collapse_May_2021.pdf

Save_tax_dollars_and_Fraser_estuary.pdf

The Fraser Estuary is threatened with even more habitat destruction.

A new presentation has just been released. It describes the Fraser Estuary and Roberts Bank, the habitat, ecology, environment and the threats and environmental degradation that it faces. View it here

APE_-_Fraser_Estuary_Threats_March_2021.pdf

Canada and Britsh Columbia announce new Nature Agreement.

https://www.newswire.ca/news-releases/canada-and-british-columbia-launch-development-of-a-new-nature-agreement-851016797.html

In announcing this agreement here is what Minister Wilkinson Environment and Climate Change said:

"We live in a province with unique species and ecosystems found nowhere else in the world. Protecting and promoting the recovery of threatened species is a responsibility and requires action based on collaboration. The British Columbia–Canada Nature Agreement will ensure we are working with our federal counterparts, Indigenous nations, and others to define new approaches that are supported by science and Indigenous knowledge. These first pilot projects will strengthen habitat protection for the threatened species which depend on it, such as the Spotted Owl, and help build a systemic approach to protection of biodiversity." 

So let's all hope he follows through and as part of building a "a systemic approach to protection of biodiversity" that he also rejects the Roberts Bank Terminal 2 project.

To help him achieve that send him an email to: ec.ministre-minister.ec@canada.ca and copy in BC Minister George Heyman at ENV.minister@gov.bc.ca

50 years ago on Feb. 2 the Ramsar Convention came into effect, to highlight the importance of wetlands to the plsnet and human well-being.

In 2012 The Fraser Estuary received the designation as a wetland of international importance under the Ramsar Convention.

Will it remain a wetland of international importance if Roberts Bank Terminal 2 is built? Not likely.

Is The Vancouver Fraser Port Authority’s Roberts Bank Terminal 2 (RBT2)
environmentally sustainable?

Answering just one question determines if RBT2 should be approved. The question - are the significant adverse environmental effects that will result from building RBT2 fully mitigable?

On August 24 2020 Environment and Climate Change Canada Minister Jonathan Wilkinson acknowledged, “ …that even taking into account mitigation measures the Review Panel determined that significant adverse effects to fish and fish habitat, including species at risk, human health, and current use of lands and resources for traditional purposes, among others were likely”. So is RBT2 mitigable? Is the project environmentally sustainable?

Not according to many who say NO, including:

1. Environment and Climate Change Canada (ECCC) scientists. In reports and published papers in independent internationally peer-reviewed scientific journals submitted to the Environmental Assessment Review Panel the scientists said the project’s impacts on biofilm (a critical food source for million of shorebirds) “are anticipated to be high in magnitude, permanent, irreversible, and, continuous”. In other words unmitigable. 
2. ECCC scientists also rebutted the Port’s claim that biofilm can be created, stating, “there are no accepted techniques to remediate for functional biofilm for shorebirds on intertidal mudflats”, nor enough other available habitat to replace what will be lost if RBT2 is built, therefore mitigation for this habitat loss is not possible.
3. The Canadian Wildlife Service, state Western Sandpipers have been declining at 2 percent a year and the entire species risks extinction if RBT2 is built.
4. Forty or more environmental and other groups including BC Nature, Birds Canada and Nature Canada have all registered opposition, stating RBT2 will result in significant adverse environmental effects that cannot be mitigated.
5. The cities of Richmond and Delta, both of whom voted to oppose RBT2.
6. Major international environmental organizations such as BirdLife International (which lists the Fraser Estuary as an “Important Bird Area” in danger) and the Western Hemisphere Shorebird Reserve Network.
7. Recently published UBC research states the Fraser Estuary is on the brink of collapse and 102 species are at risk of extinction. (Conservation Science and Practice Journal)
8. Internationally recognized scientists (Professors Pat Baird (SFU) and Peter Beninger (University of Nantes), experts in ecosystem function, have vigorously challenged the Port science – the Port science has never been published in an independent peer-reviewed scientific journal.
9. Georgia Strait Alliance and Ecojustice state the Southern Resident Killer Whales are subjected to increasing levels of underwater noise plus a lack of Chinook salmon that put them at increased risk of extinction, made much worse as a result of RBT2.
10. Raincoast Conservation and Rivers Institute (M.Rosenau) state RBT2 will impede the ability of juvenile salmon to access rearing habitat in the estuary and increase the risk of predation as the juveniles navigate around the port causeway, Deltaport and now (if built) RBT2.

If not mitigable then is RBT2 otherwise justifiable? Is an additional terminal needed on Roberts Bank because West Coast Canada is running out of terminal capacity as VFPA claims? Not according to the statistics. Despite claims of record growth VFPA’s 2019 and 2020 volumes have remained basically flat compared to 2018. Its twelve-year compound annual growth rate is below 3 percent. Global Container Terminals and DP World are both adding capacity in Vancouver. DP World has plans for a large expansion at Prince Rupert, all this giving the West Coast potential capacity of 10 million container’s (TEUs), sufficient to accommodate Canadian trade for decades to come without ever building RBT2.

On December 9 2020 MP Paul Manly presented e-petition 2828 to the House of Commons asking government to deny approval for the Roberts Bank Terminal 2 project.
In doing so he made the following statement:

"Mr. Speaker, it is an honour and privilege to table e-petition 2828, which has 1,861 signatures.

     The petitioners are concerned about the Vancouver Fraser Port Authority proposal to build another container terminal at Roberts Bank, creating a massive new man-made island the size of 150 football fields.

    The petitioners call upon the Government of Canada to maintain the environmental integrity of the Roberts Bank ecosystem for migratory birds, the endangered southern resident killer whales and other wildlife. They ask the government to deny approval of the Roberts Bank container terminal 2 project".

Watch the petition being presented here:

HoC_Sitting_No._46_15-22-17.mp4

Which part of NO does the Port of Vancover not understand?

NO to Roberts Bank Terminal 2:

• Said the city of Delta
• Said the city of Richmond
• Said almost 2000 Canadians who signed the House of Commons Petition
• Said Birds Canada, BC Nature, Birdlife International, Western Hemisphere Shorebird Reserve Network, David Suzuki Foundation, Raincoast Conservation, Georgia Strait Alliance, Nature Canada, amongst the 40 environmental and other groups opposed to RBT2.
• Said Environment and Climate Change Canada (ECCC) scientists, stating that “ECCC characterizes the Project's residual adverse impacts on biofilm due to predicted changes in salinity as potentially high in magnitude, permanent, irreversible, and, continuous”. These same scientists told the Review Panel that “ECCC's confidence in the ( Port’s) Environmental Impact Statement's predictions is characterized as low. In particular, impacts to biofilm could potentially implicate the long-term viability of Western Sandpipers as a species (IBID). ECCC similarly characterizes impacts to Western Sandpipers as potentially high in magnitude, permanent, irreversible, and continuous”.

It does not get any cleaner than that.

Canadians asked Prime Minister Trudeau, Minister of Environment Wilkinson and Members of Cabinet - please now do the right thing:

• Protect the unique Roberts Bank environment, 
• Protect birds, fishes, Southern Resident Killer Whales and other wildlife that all rely on the natural habitat and wetlands of Roberts Bank,
• Prevent species degradation from further port development,
• Prevent harm to residents living near Roberts Bank, 
• Prevent further traffic congestion caused by port truck traffic, 
• Stop the Port spending $4 billion of taxpayer funds, and

Tell Vancouver Fraser Port Authority the RBT2 project is cancelled.

What did they do? Nothing!! The Environment Minister in his response to the petition states:

" Once the Minister is satisfied that the requested information (from the Port) has been provided, the federal timeline will resume. The Port Authority’s responses to the information request will be posted to the Canadian Impact Assessment Registry. The Impact Assessment Agency of Canada (the Agency) will then host a public comment period and seek input on the Port Authority’s responses. Additionally, the Agency will post the draft potential conditions online—a document outlining conditions that the Proponent must comply with to move forward with the Project. The public will be invited to submit comments on this document as well. The next step will be for the Minister to make decisions on the signiVcance of effects under CEAA 2012. The decisions will be based on science, facts and evidence, and informed by meaningful Indigenous consultation".

The Globe and Mail contains an excellent article on the dire straits of the Fraser River and its Delta.

Opposition to the Vancouver Fraser Port Authority's Roberts Bank Terminal 2 project continues to grow.

The House of Commons Petition has over 1400 signatures with more being added everyday. That opposition is countrywide - eight Provinces and two Territories.

More than twenty groups, some with thousands of members, have voiced their opposition to RBT2.

Many have written to the Federal Government. Here is a recent letter from the Vancouver Unitarians. Their letter, addressed to the Prime Minister as well as the Environment and Transport Ministers, was also sent to all Vancouver area MPs.

RBT2_Vancouver_Unitarians_Letter_in_Opposition.pdf

The House of Commons Petition can be signed here.

If you have not yet signed it, please do so before the deadline.

We now know the Federal Government chose to withhold a letter that was intended to go to the Review Panel for Roberts Bank Terminal 2 (RBT2). It contained key information that summarised the government scientists' concerns, summarized as:

"Environment and Climate Change Canada (ECCC) continues to conclude that predicted changes to Roberts Bank constitute and unmitigable species-level risk to Western Sandpipers, and shorebirds generally and that therefore the only way to be confident of avoiding the impacts on biofilm and shorebirds from these geomorphological processes is with a Project Redesign"

That draft letter was already written and sent to a meeting of the Assistant Deputy Ministers Major Ports Steering Committee on August 20, six days before the deadline for submitting closing remarks to the Panel. After that meeting it appears the letter and the government scientists’ concerns were buried. 

The federal government made a fundamental error in not submitting that letter to the Panel and as a result they appear to have misled the Panel.

Furthermore, the environmental assessment for Roberts Bank Terminal 2 has not met the provisions of the Canadian Environmental Assessment Act.

Not only that but the Environment Minister paused the decision process on August 24 and is asking the Port for more information. Surprisingly the Minister is asking the Port to update its own science model, despite the fact that both ECCC and independent scientists have labelled the Port science as flawed. But more importantly, the Minister is not asking for more data for the areas where the Panel indicated it did not have answers. For example the Panel was unable to conclude whether or not the negative effects to Western Sandpipers will be significant. Plus the Panel was unable to determine the effects on polyunsaturated fatty acids despite these being a critical food source for millions of shorebirds, fishes and other wildlife.

Why is the Minister not asking these questions? Is he concerned the answers will scuttle the RBT2 project?

Business in Vancouver published an article on September 25 entitled

" Delayed decision hasn't cooled the container terminal fight"

Read the article on the Business in Vancouver website here:

https://biv.com/article/2020/09/delayed-decision-hasnt-cooled-container-terminal-fight

 This article:

Delayed_decision_hasn’t_cooled_container_terminal_fight_-_Transportation_|_Business_in_Vancouver.pdf

highlights the real and unanswered environmental concerns with the RBT2 project. Equally it demonstrates there are other more economical and sustainable ways to meet future terminal capacity demands when such demand arises, which given that the Vancouver area ports’ container volumes are in decline, whilst Prince Rupert is planning to significantly expand its terminals, may not be for many years to come.

With the City of Delta – the host city for this project - now also firmly opposed to RBT2 and as these previously hidden documents reveal, the federal government now really has no choice. 

It must deny approval for Roberts Bank Terminal 2, because they have in front of them, as now does the public, science and facts from their own scientists supported by independent science that proves this project is fundamentally flawed and cannot go forward.

New Access-to-Information findings reveal yet another federal government cover-up, this one involving the Roberts Bank Terminal 2 (RBT2) project.

In August 2019, the Review Panel asked government agencies, stakeholders and the public to submit closing remarks, prior to them closing the record on the RBT2 project and retiring to write their report and recommendations. The panel made it very clear these final submissions not contain any new information, but rather a summation of key findings and recommendations. 

Environment Canada answered the call, as did many others, including the Vancouver Fraser Port Authority (VFPA). Whilst many submissions made it through to the Panel, one was missing and that was Environment Canada’s. 

Read the final draft of Environment Canada's RBT2 missing submission here

Release_package_A-2019-02039.pdf

So, who in Ottawa decided to withhold the scientists’ submission and why?  Was it someone in the Environment Ministry; someone in the Transport Ministry; was it senior Ottawa bureaucrats; was it the Prime Minister‘s office, or was it someone else? 

This Access to Information request reveals a damning summary of the RBT2 project. Authored by Environment Canada, it underlines the scientists’ concerns, one being that RBT2 constitutes an unmitigable species-level risk to Western Sandpipers and shorebirds more generally. That submission would have provided the Review Panel a different picture, showing that Environment Canada scientists were right all along in stating that the RBT2 will result in significant adverse environmental effects that cannot be mitigated. It would clearly demonstrate RBT2 is extremely damaging to the Robert’s Bank ecosystem. Armed with that report the Panel could well have recommended that the RBT2 project approval be denied.

This newly released material reveals Ottawa bureaucrats attempting to influence the Environment Canada scientists, with clear evidence those proposing a number of changes were trying to alter or dumb down the scientists’ recommendations. In one change they say references to scientific material are not permitted, which is not true. In another they question whether certain mitigation needs to be operational and tested prior to construction. When the Environment Canada scientists refused to back down someone in Ottawa made the decision that this Panel submission was too damaging to the project to go forward and therefore decided to bury it. 

The Government's closing submission was all ready to go. As the release package shows the letter to the Panel, dated August 20 was written and was to be discussed at an Assistant Deputy Ministers Major Port Projects Steering Committee.

The letter concludes: 

Read the APE Press Release of Sept. 16 here:

APE_Press_Release_-Sep_16_2020.pdf

APE has recently put its name and logo on a new video produced by Nature Canada

https://drive.google.com/file/d/1EscIbc_uFX1q_hvsJzx3yTkipOOhhwaK/view

As you can see Nature Canada is urging us to ask Ottawa to focus on the environment in plans for Canada's recovery, stating, "you can't have a plan for the economy if you do not have  plan for the envrionment". It calls on Ottawa to invest in nature and urges us to hold Ottawa accountable.

Nature Canada is asking you to write to your MP using this link

https://e-activist.com/page/63926/action/1?ea.tracking.id=websitebutton

The intent of the letter is also to gauge which MPs are supportive of a green recovery. With Team Trudeau having prorogued parliament this is very timely. At the end of September there is to be a new speech from the throne, where we should expect specific moves to promote a green recovery.

One of those should be to deny approval of RBT2 and I encourage you to include that in your letter. Also take the oportunity to send a copy to the PM at pm@pm.gc.ca, and to the Envrionment Minister at ec.ministre-minister.ec@canada.ca.

We are trying out a new logo - see below. Tell us what you think by emailing info@againstportexpansion.org.

Just last week the City of Delta voted to oppose RBT2 and to write the Prime Minister asking him to reject the Port of Vancouver's proposed second container terminal on Roberts Bank. Here is the Delta Optimist's report of that decision:

https://www.delta-optimist.com/news/delta-to-ask-trudeau-to-reject-port-expansion-1.24173980

The Port was not thrilled, but Delta has since received a lot of support for the stand it is taking. 

The Decision on Roberts Bank Terminal 2 – Next Steps. 

We know from comments made by Vancouver Fraser Port Authority (VFPA) CEO Robin Silvester and Vice President Duncan Wilson, as well as other credible sources, that Ottawa is about to release “Draft Conditions” for Roberts Bank Terminal 2 for First Nations consultation and public comment. 

What does that mean?

The Impact Assessment Agency Canada (previously known as the Canadian Environmental Assessment Agency) is the lead agency and has been working with various government ministries to develop a document detailing conditions under which RBT2 might be approved. It appears VFPA staff has been “helping” in developing these draft conditions. Indications are that federal bureaucrats have been scrambling to come up with a host of soft conditions so RBT2 can be put across as having no immitigable environmental effects.

Therefore, we now expect the draft conditions may include:

• Untested ways in which the negative environmental effects from RBT2 might be mitigated, including the high quality biofilm on Roberts Bank that is an irreplaceable food source for millions of migratory and other shorebirds as well as other wildlife.
• Identifying other areas where biofilm exists without regard to shorebird needs and hypothetical methods in which biofilm can be created, perhaps with the assistance of First Nations. 
• Further steps to protect the already endangered Southern Resident Killer Whales, by, for example, more vessel speed limitations as well as attempts to reduce vessel (propeller) noise.
• Increased steps to protect Chinook salmon stocks.
• Generic ways to protect migratory birds especially Western Sandpipers.
• Initiatives for monitoring effects and further research as the project progresses – all after the horse has left the stable.
• Fisheries Act authorization, which it appears VFPA has already applied for.

 All this is leading up to providing the Environment Minister with information to aid in his decision-making. 

The Decision – to be made by November 23 2020

The Minister is on record as stating “My decision will be also be based on science, facts and evidence, informed by meaningful indigenous consultation and serve the public interest”. He must make a determination as to whether RBT2 is likely to cause significant adverse environmental effects. Given the Panel Report statements this may well be the case. If so, the Minister must refer it to the Governor in Council (federal cabinet) to determine whether the effects are justified in the circumstances. This is where these draft conditions then become important. The Transport Minister and perhaps other cabinet members will certainly be pushing for approval subject to the conditions. And VFPA will definitely state that they will abide by all of them, even though history shows that in practise some will be later watered down or ignored all together.

In parallel with this the BC Environmental Assessment Office will conduct its own assessment, using five pillars for evaluating the potential adverse effects of RBT2, namely the environmental, economic, social, heritage, and health effects that may occur during the life of the project. However, it appears BC will not make a decision until after the Federal decision is announced. 

Actions to take now - before it is too late

• Write your MP https://www.ourcommons.ca/members/en asking them to oppose RBT2 on environmental grounds.
• Write to the Environment Minister ec.ministre-minister.ec@canada.ca opposing RBT2.
• Write your MLA asking them to oppose RBT2 on environmental grounds.
• Ask the Metro Vancouver Board to oppose RBT2.
• Urge local groups that you belong to oppose RBT2.
• Write letters to newspapers and engage the media.

Once these draft conditions are made public, watch for a vigorous scientific review and comment from environmental groups. We are not going to allow the government to trade-off the huge negative ecological effects for an unnecessary second container terminal on Roberts Bank. 

Susan Jones on behalf of the Boundary Bay Conservation Committee has written to both the Federal and Provincial Governments identifying crtical gaps in the RBT2 Panel Report.

Read the letter here:

Letter_from_BBCC_on_RBT2_Review_Panel_Report_0.pdf

Do you want to STOP RBT2?

Will the federal government rely on science and facts in its decison on the Port of Vancouver's proposed Roberts Bank Terminal 2 project?

That is the stark choice. Does the government rely on Environment Canada science, supported by independent peer-reviewed scientists who are respected internatinally? Or do they accept the Port's paid for science, which has never been peer-reviewed and is not supported by any sicentists or science-based organizations that are indpendent of (i.e. not paid for or under contract to) the Port. There is nothing wrong with the Port's data. It is the self-serving manner in which they have interpreted it. They decided on the answer that they wanted from the science and them twisted interpretation of the data to get the results that they needed. They then compounded that error by suggesting that the biofilm that the project will destroy can be "created". This despite the fact there are no expamples of "biofilm creation" of the size and magnitiude of what the Port is suggesting. Even the Federal Review Panel stated that :
"There exists considerable uncertainty around the possibility that loss of productive biofilm habitat could be mitigated by the large-scale re-creation of biofilm habitat capable of supporting shorebirds, including appropriate bottom sediment characteristicsand salinity conditions."

The latest issue of Scientific American carries an article about Roberts Bank:

"Slimy mudflat biofilm feeds migratory birds - and could be threatened."

https://www.scientificamerican.com/article/slimy-mudflat-biofilms-feed-migratory-birds-and-could-be-threatened/?WT.mc_id=send-to-friend&fbclid=IwAR0yPhbqF9tJ6gorN9Z4nXnyQKLYMXTaZz3mf7r1lVmSr4nUwgDP6wOIVZQ

The independent science is overwhelming. The scientific perspectives expressed in the article state what has been said many times over by scientists independent of the Port of Vancouver

The federal government can no longer ignore the obvious. Roberts Bank must be protected from any further industrial/port development. If the current government is serious about protecting important wetlands then it must deny approval for the the container terminal project.

To do otherwise will bring Canada international embarrassment and condemnation. Roberts Bank by the way is a Ramsar wetlands site of international importance and the Port project would degrade that site. Canada is a signatory to this UN treaty. It needs to uphold the treaty’s values and say no to Roberts Bank Terminal 2.

Please tell Minister Wilkinson at email ec.ministre-minister.ec@canada.ca to listen to science and deny approval of RBT2.

Need help with a letter? Here is a word version ready for you to send, or amend as you wish:

Letter_to_Federal_Ministers_Opposing_RBT2_June_2020.docx 

How Desperate Is the Port?

Out of the blue, the Vancouver Port Authority just released a newsletter and video about biofilm on Roberts Bank. Why now?

http://www.robertsbankterminal2.com/news-updates/western-sandpipers-return-to-roberts-bank-this-spring/ 

Seemingly the Port is alarmed that neither the public, environmental organizations, scientists, nor decision-makers are buying into their story that Roberts Bank Terminal 2 (RBT2) will not result in significant adverse effects to Western Sandpipers that rely on fatty acids from biofilm as they make a refuelling stop on their long northward migration to their breeding grounds.

The Port’s newsletter and video contain nothing new but conveniently omit that the Review Panel agrees with Environment and Climate Change Canada (ECCC) that biofilm mitigation is not possible.  The Port’s messages conflict directly with findings of federal government scientists as well as independent internationally recognized experts. For example, while the Port claims that the project will result in a direct loss of less than 0.1% of biofilm on Roberts Bank they are ignoring the probability of losing all bird-friendly biofilm on Roberts Bank by removal of the salinity trigger responsible for fatty acid production, critical to Western Sandpipers and many other shorebirds.

The federally-appointed Review Panel is on record as stating:

 1). “The (RBT2) proposed offsetting plan, totaling 29 hectares, is not sufficient to compensate for the reduction in productivity associated with the habitat loss of 177 hectares at Roberts Bank”, and 

 2). “The Panel agrees with ECCC that mudflat creation at Roberts Bank is unproven as a mitigation measure for biofilm and as such cannot be considered feasible until best practices can be developed”.

Federal government scientists as well as independent experts fundamentally disagree with the Port’s consultants and their latest newsletter and video. ECCC has consistently maintained that offsetting high quality biofilm habitat is not feasible and advised that only a project redesign could avoid adverse effects on shorebirds that will inevitably result from changes in biofilm fatty acid production. 

Professor Peter G. Beninger (Université de Nantes), internationally recognized authority on biofilm, with over 100 peer-reviewed publications as well as the definitive book on mudflat ecology, stated at the public hearings: “He was of the opinion it was not yet possible to confidently understand how the Project would affect biofilm relative to all nutritional sources of importance to shorebirds, due to limited knowledge of mudflat ecology.”

Dr. Patricia Baird (Kahiltna Research Group), internationally recognized and author of numerous peer-reviewed papers on birds, also presented at the public hearings. As the Panel Report states Dr. Baird said “that many studies had shown that the Polyunsaturated Fatty Acids (PUFAs) in freshwater diatoms were less concentrated than in marine diatoms and that, unlike what the Proponent had stated, not all PUFAs were similar. She mentioned that the Proponent had keyed out diatoms only to genus and stated that the Proponent should have focused on diatom species. Dr. Baird stated that freshwater diatoms would not produce the high concentrations of EPA and DHA on which shorebirds depend.” 

The newsletter mentions that the Port is completing a biofilm habitat construction manual. This is a "red herring" as it cannot be compiled without further research towards maintaining fatty acids from biofilm and merely supports the Port position that PUFA are not important and won’t be impacted. Current "Best Practices" is to leave the current biofilm as it is and unimpaired by RBT2. 

The Port commitment to work with government and to carry out further research, monitoring and follow-up is meaningless if done after permission to build is granted. Given the probability that follow-up research further confirms there will be a significant adverse effect to the entire species of Western Sandpiper, then Canada will have an internationally embarrassing problem, because as ECCC have repeatedly stated the negative effects will be “immediate, continuous and not mitigable”.

The opinions expressed in the video by Mr. Rourke and Professor Ydenberg cannot be considered independent since both are working for the Port. Their views run counter to experts independent of the Port who presented to the Review Panel. These independent positions are supported by a suite of peer-reviewed studies, two of which have recently published in major scientific journals. ^1,2

The newsletter and video appear nothing more than a blatant attempt to influence agencies debating a fair decision on the project. The Port – a federal Crown Agency – is out of line in attempting to compromise the decision making process. 

Independent and federal science versus Port science – which should Canadians trust? The decision on RBT2 must be based on science and facts. The choice is clear. Decision makers must rely on credible independent science rather than non-peer reviewed and self-serving Port science. 

1. Peak Abundance of Fatty Acids From Intertidal Biofilm in Relation to the Breeding Migration of Shorebirds” (Frontiers in Marine Science Feb 2020) 

https://www.frontiersin.org/articles/10.3389/fmars.2020.00063/full

 2. Natural History Observations that Transformed Shorebird Ecology (Ecosphere Naturalist Journal May 2020)

https://esajournals.onlinelibrary.wiley.com/doi/epdf/10.1002/ecs2.3133

The RBT2 Review Panel released its report on March 27 2020 and sent it to the Environment Minister. 

This new report provides the only complete story on Roberts Bank Container Terminal 2 and its environmental assessment by Federal Review Panel.

RBT2_Environmental_Issues_Feb_2020.pptx.pdf

In this report you will find:

• The misinformation put out by VFPA on its market performance (poor) and its inaccurate projections for future volumes (missed the last five forecasts).
• Market realities and a flawed business case for RBT2 (there is no business case - at $3.5 - $4.0 billion it would be the most expensive terminal anywhere in the world).
• The unique Roberts Bank Environment, its values and how RBT2 will destroy it.
• New independent peer-reviewed science that the Panel has not seen. It validates what Environment Canada has been saying all along. RBT2 will result in significant adverse environmental effects that will be immediate, continuous, and cannot be mitigated.
• The fatally flawed partisan non-peer reviewed VFPA science is thereby debunked.
• Details of the negative environmental impacts on birds, fishes, crabs, Orcas and humans.
• A listing of the large number of groups and entities that are opposed to RBT2.
• The mishandling by the Panel of the environmental assessment, its failure to exercise authority and its bias towards VFPA.
• The political interference that has plagued the assessment all the way through.
• Conclusions - details that demonstrate that RBT2 must never be built.
• Reference links to the science, and reports.

If you find this disturbing then tell Jonathan Wilkinson, the Environment Minister. Call his North Vancouver Constituency Office 604 775 6333. Or email him at 
ec.ministre-minister.ec@canada.ca

A new peer-reviewed study, by internationally recognized experts in wetland ecology, (now published in Frontiers in Marine Science in relation to the importance of biofilm for the breeding migration of Shorebirds) has confirmed what Environment Canada scientists have been saying all along. The ecosystem integrity of Roberts Bank risks being destroyed by further port development.

Read the new study here

Frontiers_in_Marine_Science_Intertidal_Biofilm_Frb_2020.pdf

The choice is very clear. Let the Vancouver Fraser Port Authority build a second container terminal on Roberts Bank and watch one of the richest and most important ecosystems for migrant and wintering waterbirds in Canada be destroyed. Or protect this important stopover site on the Pacific Flyway by preventing any further port or industrial development on Roberts Bank.  

Throughout the environmental assessment of the Roberts Bank Terminal 2 Project (RBT2) these Environment Canada scientists have battled the Port Authority’s partisan non-peer reviewed science that has sought to downplay the environmental impacts. The fear has been that the Port Authority’s influence in Ottawa would override Environment Canada concerns. 

No longer. This new study, on the importance of biofilm for the breeding migration of shorebirds, validates the work done by Environment Canada scientists. They were right all along. If RBT2 is built it is likely to result in the significant degradation of one of the most important ecosystems, in terms of birds and biodiversity, in the whole of North America. As the scientists have repeatedly said, RBT2 will result in significant adverse environmental effects that cannot be mitigated.

When the Review Panel report is published - expected in a matter of weeks - the Minister of Environment will need to address two questions:
1. Will RBT2 result in significant adverse environmental impacts that cannot be mitigated? Clearly the answer is YES.
2. Is RBT2 in the national interest, sufficient to override the environmental issues that would result if RBT2 were built? That answer is a definite - NO. 

Will Environment Minister Jonathan Wilkinson do the right thing? Will he live up to the government’s commitment to protect internationally recognized wetlands? Or will he bow to the Port Authority’s desire for a new container terminal, even though there is no business case?

Write to him at ec.ministre-minister.ec@canada.ca and tell him to reject the Roberts Bank Container Terminal 2 project.

SEVEN THINGS WE KNOW ABOUT 
ROBERTS BANK TERMINAL 2 (RBT2)
AND CAN PROVE

1. The internationally recognized Roberts Bank ecosystem is critical for wildlife on a massive scale.

2. Environment Canada scientists and independent experts believe any further port development on Roberts Bank risks significant adverse environmental effects that will be immediate, continuous and cannot be mitigated.

3. Environment Canada scientists have been muzzled by Ottawa and prevented from fully explaining their concerns to the RBT2 Environmental Assessment Panel.

4. The RBT2 proponent, Vancouver Fraser Port Authority – a crown agency – has discredited and disparaged Environment Canada scientists.

5. The RBT2 Environmental Assessment Panel has refused to consider alternatives to RBT2 that are safer, less environmentally damaging and will cost less than half to develop.

6. With current west coast Canada container capacity expansions already underway there is neither need nor business case for RBT2 for many years to come.

7. The Vancouver Fraser Port Authority,  confident that RBT2 will be approved, is already going to tender for the RBT2 developer and operator, even before the Panel renders its decision.

You can find more detail and information on these topics by reviewing the other news items and the information about RBT2 on our website. 

Please email  if you have questions to info@againstportexpansion.org

Are you aware of the recent report on air pollution/quality and the prime cause - diesel polluting trucks. 

Today the Roberts Bank Terminal 2 Environmental Assessment Panel announced that it has closed the public record and will no longer accept any further submissions. During this last phase the Panel will now develop and submit its final report, likely to be delivered to the federal Environment Minister by the end of 2019. 

Whilst many individuals, groups and agencies submitted their closing remarks to the Panel, there was one that was missing.  There are no closing remarks from Environment and Climate Change Canada (ECCC).  The ECCC scientists certainly prepared their closing remarks, underlining their concerns that RBT2 will result in significant adverse environmental effects that cannot be mitigated. However the Panel never got to see these. Why, because it appears senior federal bureaucrats were intent on derailing the final definitive scientific statements from Environment and Climate Change Canada (ECCC) to the Panel. 

So somewhere in Ottawa a decision was made.  None of the federal agencies would submit closing remarks – except one, the Vancouver Fraser Port Authority (VFPA). Thus the VFPA submission, which aims to minimize and discount the environmental impacts, goes unchallenged.

This is just the latest of a number of political interferences. Throughout the RBT2 process federal bureaucrats have muffled ECCC research findings and recommendations while the reports from the paid VFPA's consultants promoting RBT2 have been under no such censure. We have even tried the Freedom of Information route to uncover this interference, but 11 months after making the FOI request we have received nothing.

The RBT2 environmental assessment was supposed to be transparent and fair. It was neither.

The Panel received 39 closing remarks from individuals, environmental groups and others. 34 expressed outright opposition to the project and three identified significant concerns. One submission was from the proponent (also containing three consent letters from First Nations) and only one, from the BC Chamber of Commerce, supported the project. 

Not only that but the VFPA closing remarks take direct aim at ECCC. Rare for one government agency to criticize another one, VFPA tries to discredit and disparage the ECCC scientists. Three of a number of examples of disparaging and negative statements about ECCC in the VFPA closing remarks include:

“The VFPA’s position is that ECCC’s description of the changes in salinity on Roberts Bank that will result from the Project as ‘an overall regime shift’ is a strong mischaracterization”
and;
"The VFPA submits that ECCC has not been scientifically objective in its review of the VFPA studies and assessments”.
and; 
“It is in this context of the history outlined above that the VFPA asks that the Review Panel treat the evidence of CWS, that there would be a “species-level risk” to WESA as a result of the Project due to impacts to biofilm, with a high degree of caution and scepticism. Due to ECCC’s demonstrated lack of consistency on this issue, it would be inappropriate to rely fully on ECCC’s conclusions.” 

The key issue revolves around internationally cutting-edge revelations about the special types of diatoms in biofilm on the mud of Roberts Bank - now understood to be the irreplaceable source of essential fatty acids and energy for an entire shorebird species, the Western Sandpiper, and other wildlife, including salmon, whose level of richness is unique to Roberts Bank. Government scientists have consistently shown that if the project were to go ahead there will be irreparable changes to the Roberts Bank diatoms in the biofilm, with diatoms and fatty acid production being immediately impacted. 

APE and Boundary Bay Conservation Committee are pushing back.

Read their reports here:

 Abandon_Roberts_Bank_Terminal_2_Project_in_Delta_BC_Sep_10_2019.pdf

Political_interference_spells_disaster_for_the_Fraser_River_Estuary_in_Delta_B.C._16.pdf

Then take action. The environment is a top issue in the federal election. Talk to the candidates running in your riding about this project and how its assessment has been undermined.

The Fraser River Delta is one of British Columbia’s most vital habitats for migratory shorebirds, and the site of a major discovery about how shorebirds feed. BirdLife International has now joined in opposing the Vancouver Fraser Port Authority's proposed project to add a second container terminal on Roberts Bank in British Columbia.

Birdlife International is a global partnership of conservation organisations (NGOs) that strives to conserve birds, their habitats and global biodiversity, working with people towards sustainability in the use of natural resources. 

Birdlife International is recognized as the world leader in bird conservation. 

The next step with this project is for the Review Panel to send a report and recommendations to the Federal Government. It will be a huge international embarrassment for Canada if the federal government were to do anything other than stop the project.

To add your voice to the opposition go here to sign this petition.

https://www.birdlife.org/worldwide/news/canada-delta-danger-trading-port-expansion

Action in Time warns of irreversible environmental impacts to the Fraser River Estuary and Salish Sea if a massive man-made island is built for a Shipping Terminal at Roberts Bank.

Common Ground Terminal 2 newspaper Press Quality.pdf

1. RBT2 Rationale is Heavily Flawed 

The underlying problem with the RBT2 environmental assessment is the myth that the environment, the economy and communities need to be in balance. This is the so-called sustainability factor. 

The way that the CEAA Panel is carrying out the review is compounding the problem. The Panel appears to believe that all it needs to do is to review the purpose of the project and not the need. Furthermore the Panel appears to believe that its review must focus solely on Roberts Bank, without looking for better more cost effective alternatives elsewhere (Prince Rupert). This approach is inexorably flawed. 

By using this flawed approach the Panel is failing to ask the following key questions:

1. Is there a risk of environmental degradation if RBT2 is built?
YES. End of story for a new port on Roberts Bank. 
2. Does Canada need to increase container capacity for its trading needs? 
YES 
3. Since Roberts Bank is no longer in the picture where else is port expansion possible? Prince Rupert, primarily, and also expanding other existing container terminals. 
4. What else should Canada be doing to further its container trade objectives? Limit and start to reduce the transhipment of US container traffic through West Coast Canada ports. This US traffic adds little or nothing to Canada’s economy. 
5. Are communities impacted by container ports and the resultant road and rail traffic? YES. Light pollution, air pollution, noise pollution, traffic congestion, rail accidents. 

It is not in Canada’s national interest to build a container terminal whose capacity is not needed and whose environmental and community damage will be significant.

2. RBT2 Assessment Update

Vancouver Fraser Port Authority (VFPA) has rushed to get all its responses into the Review Panel of the Canadian Environmental Assessment Agency, so as to be ready for an expected Public Hearing that may come in a few months, (April?).  

The Panel received a mass of additional information from the VFPA and requested public comments on the sufficiency of this information.  This comment period closed on February 8 2019. Submissions from the public, First Nations and regulatory authorities are very critical and identify many areas where VFPA has failed to provide sufficient information. A number of public comments have shown that VFPA has provided incorrect information and misleading information. Equally VFPA has dodged certain areas such that some important information is missing altogether. Will the Panel recognize that much more information is needed, or will political considerations take precedence such that they proceed to a public hearing anyway?

3. Environmental Issues
Roberts Bank is Canada’s major stopover on the Pacific Flyway, with millions of migrating birds travelling over 3 continents, including 20 countries. The estuary and surrounding watershed supports Canada’s largest populations of wintering waterfowl, shorebirds and birds of prey with global and local recognition: 

• Designated by BirdLife International as an Important Bird Area (IBA). It is the most significant IBA out of 597 sites in Canada. 
• Highest designation by the Western Hemisphere Shorebird Reserve Network (WHSRN) as a Hemispheric WHSRN Site.
• Declared a Provincial Wildlife Management Area (WMA) and recognized to have the highest concentration and bird diversity anywhere in Canada
• Declared as a UN Ramsar site by the International Convention on Wetlands. Shockingly Canada would not include Roberts Bank in the RAMSAR site even though the fresh water/salt water blending area is key to the rich ecosystems. 

The Project will harm the fragile estuary with habitat loss and destruction, as well as noise, light, water, and air pollution. The losses cannot be effectively mitigated.  

A central issue is that of biofilm, a food source vital to western sandpipers, VFPA claims “...the Project is not predicted to result in significant adverse effects on biofilm or affect the availability or quality of food available to northward migrating WESA”. This comes from captive consultants paid for by VFPA. This totally ignores the concerns of independent experts and importantly submissions to the Panel from Environment and Climate Change Canada that identify impacts to the Roberts Bank wetlands and wildlife as severe, immediate, irreversible and immitigable. 

The widened causeway required for RBT2 will cover over a significant area of biofilm. 

RBT2 is also a serious issue for juvenile salmon. The juveniles hide in the eelgrass and shallows of Roberts Bank as they transition from river to ocean. Juvenile salmon need the shallows and are repeatedly pushed into deep water by all the causeways and training walls in the delta. By building this huge - 460 acres - RBT2 pod and expanded causeway, and because there are no culverts in the port causeway, the salmon are forced to swim around these obstacles and are more exposed to predators and other dangers. Chinook salmon are already in decline and are a critical food source for the endangered Southern Resident Killer Whales (SRKW). VFPA has been asked repeatedly to install culverts in the Deltaport causeway and have refused to do so citing cost and feasibility – both false. With the RBT2 widened causeway installing culverts gets even more expensive.  

Increased vessel traffic through the Salish Sea is already a concern for the endangered SRKW. The vessel noise, possibilities of collision are all contributing factors to a decline in the SRKW population. The Salish Sea cannot take any more vessel traffic. 

4. No Business Case

VFPA has never produced a business case. Many times they have been asked, but never have they produced a document that any normal business entity would rely on to justify a project of this magnitude. Instead they keep repeating the myth of a coming “container crunch”. These are taxpayer assets and funds being invested in a multi-billion dollar project with no indication of the expected return on investment. If this were anything other than a government agency there would have been a proper business case identifying the capital investment, gross and net revenues, return on investment, plus a full risk analysis. 

VFPA  is promoting  the myth of a ‘container crunch’ in the near future, i.e. not enough capacity in Western Canada for all the expected container traffic. VFPA has a full-blown PR campaign to mislead government, stakeholders and the public. Numerous articles to this effect are in the media and on the Port website, claiming incorrectly that the west coast will run out of container space by the mid 2020s.   THERE IS NO CAPACITY CRUNCH ON CANADA’S WEST COAST. THERE IS PLENTY OF CAPACITY NOW AND MUCH MORE COMING ON STREAM. 

VFPA consistently underperforms against its forecast increases in container traffic. It has missed every one of its last five forecasts and its cumulative annual compound growth rate languishes at 3 percent. Prince Rupert’s container volumes have doubled in the last five years, with its volumes increasing 12 percent in 2018 alone. 

With expansions under way or in place at two of Vancouver’s existing container terminals and a third one expected to start soon, plus ongoing expansion at Prince Rupert, there is no shortage of container capacity. In fact Prince Rupert has the potential to grow to as much as 4 – 5 million containers (TEUs) if the market requires it.  

Prince Rupert has seen its container volumes grow by double digits whereas Vancouver languishes in the three percent range. Prince Rupert is two sailing days closer to Asia, has faster, less congested and easier rail access to the east and has very few environmental issues when compared to Vancouver. 

RBT2, if built, would be the most expensive container terminal project anywhere in the world. Expansion at Prince Rupert can add container capacity equivalent to RBT2 for half the cost. 

Rail traffic in and out of Vancouver is a big issue. The rail route east through the Rockies is heavily congested. Grain and potash shippers are complaining that their products are being delayed. More oil is being moved by rail. Too many accidents on this route have already occurred. Likewise Port trains have been involved in recent tragic accidents at grade level crossings in the Lower Mainland. This southern route simply cannot handle the huge increases in containers were RBT2 to be built.  

Presently VFPA in total handles 3.4 Million containers (TEU) per annum, + 1.0 Million for Prince Rupert, total West Coast 4.4 Million TEU.  If total West Coast Canada container traffic expands by 3- 4 % per annum, (generous in view of past history), it will grow to 8.2 Million by 2040, still far less than future capacity of 10 – 11 million if the total build out is required.  AND ALL THIS WITHOUT RBT2. 

Furthermore as much as 25 percent of containers handled are US origin or destined, bringing little or no economic advantage. US traffic can be re-routed via US ports. 

5. Community Issues

VFPA, with its desires to build RBT2, ignores real community issues. 

• Traffic congestion caused by port container trucks is significant, especially in the morning and evening rush hours. The lower mainland road system cannot handle huge increases in port road traffic. 
• Rail traffic through the lower mainland is an issue. Community roads are blocked many times a day with trains crossing at grade level. There have been three recent road/rail accidents in recent weeks with fatalities. 
• Light pollution is an issue. RBT2 will add light intensity to an area that already suffers from light pollution. 
• Air pollution is an issue, with port trucks and trains dumping increased levels of harmful emissions into urban and rural areas. 
• Anchorages for vessels waiting for harbour space has become a significant issue in the Gulf Islands.

 6.    Why is RBT2 a non-starter?

• The public is opposed;
• Aboriginal groups are opposed;
• Existing terminal operators are opposed;
• Project benefits are overstated; no cost benefit analysis;
• The port of Prince Rupert is better placed for Canada’s container terminal expansion and to satisfy Canada’s trading needs;
• Prince Rupert and Vancouver area ports will have plenty of capacity out to 2040 and beyond;
• RBT2 environmental impacts are significant, immediate, permanent and not able to be mitigated;
• Community impacts – traffic congestion, light, noise and air pollution - are significant.
• Cumulative effects are being ignored;

7. Bottom line - RBT2 is neither needed nor justified.

No Economic Reasons for Roberts Bank Container Terminal 2 (RBT2)

                  September, 2018

There is no economic justification for the Roberts Bank Terminal 2 Project (RBT2) which will destroy globally-significant Fraser River estuary habitats that support migrating salmon, resident orcas and millions of migratory birds at Canada’s crucial stopover of the Pacific Flyway. 

The Vancouver Fraser Port Authority (VFPA), known as the Port of Vancouver, is strongly lobbying the Government of Canada to let them dredge and fill 445 acres of waterlot in the estuary for an island and expanded causeway to double container capacity with 3 new berths. The stated reasons and purpose of Terminal 2 are not supported with evidence of accurate forecasts, capacity and demand.  

Currently, a federal Review Panel is examining the Environmental Impact Statement (EIS) for the Project.  The economic information in the EIS is incorrect and misleading as VFPA business forecasts are not being realized and B.C. ports are already expanding capacity to handle container traffic demand.  

The container business is reported in TEUS, “twenty-foot equivalent units”, which means each unit is equivalent to one twenty-foot container.

Unfortunately skewed statistics are being presented to the federal government in the EIS and in a 2017 Transport Canada Report.  They are ignoring a report from three transportation experts advising:
“…policy makers develop container capacity in Prince Rupert before making investments in Vancouver”…and further that: “…a systematic approach be taken to achieve an understanding of port capacity before a conclusion is reached that a particular port must necessarily be larger.” 

In 2016, the Port of Vancouver secretly submitted an information brief on the RBT2 Project to Canada’s Members of Parliament in an attempt to bypass due process,“Welcome to our first newsletter, written exclusively for a government audience.” 

http://www.portvancouver.com/wp-content/uploads/2016/10/2016-09-28-Briefing-Note-RBT2-Facts.pdf?utm_medium=email&utm_campaign=Government%20newsletter%201&utm_content=Government%20newsletter%201+CID_e2d26a81e33a994c50a06e8f2ee5a58f&utm_source=Email%20marketing%20software&utm_term=Read%20our%20briefing%20note

Documented statistics and information can be found in a submission to the Review Panel by the Boundary Bay Conservation Committee. 

https://www.ceaa-acee.gc.ca/050/documents/p80054/125387E.pdf

One of the wildlife casualties, if Roberts Bank Terminal 2 (RBT2) were to be built, is likely to be the Western Sandpiper, so we have banded together with the Citizens Against Port Expansion Group (www.noterminal2.ca), and a number of others to produce a new video to raise the profile of the plight of the sandpipers.

Here is the video:

https://www.youtube.com/watch?v=8IrQXoGoGjM

The Western Sandpiper could become collateral damage if Vancouver Fraser Port Authority (VFPA) receives permission to construct a new second container terminal at Roberts Bank in Delta (RBT2). A key issue is BIOFILM, a slimy goop that Western Sandpipers feed on. Roberts Bank is a major stop on the Pacific Flyway for the migrating sandpipers on their journey to the arctic where they breed each year.

Roberts Bank, with its:

• Bird Life International designation as a Global Important Bird and Biodiversity Area. 
• Western Hemisphere Shorebird Reserve Network designation as a site of Hemispheric Importance (only eight such sites exist in the whole of the Americas).
• BC Government designation as a Wildlife Management Area - "providing crucial wintering grounds for the highest number of waterfowl and shorebirds anywhere in Canada".
• Worldwide recognition as a site of natural abundance and biodiversity, one of the most significant such areas in the Americas and worldwide

- is under threat from further port expansion. Studies have shown that Roberts Bank’s unique biofilm will be significantly degraded by the construction and operation of RBT2, putting the millions of shorebirds and other wildlife species that rely on this rich ecosystem at risk. For sandpipers the results would be devastating.

No biofilm equals no food for the birds and no future.

Vancouver Fraser Port Authority and its consutants disagree. Its consultants suggest that the negative impacts to the biofilm can be mitigated. Not true. Environment and Climate Change Canada (ECCC) scientists have stated major concerns with the RBT2 development, saying that “… the impacts on Biofilm will be permanent, irreversible and continuous”. Many other groups also share The ECCC viewpoint.

The negaitve impacts go well beyond the Western Sandpipers. Millions of other shorebirds, the Orcas, salmon, herring, crabs, eulachon, several species at risk and other wildife will also be impacted.

There is simply to much risk. The precautionary principle must apply. RBT2 must be abandoned.

Delta MP and Minister Carla Qualtrough unveiled new Canada Post stamps celebrating some of Canada's bird species at the opening of the Bird Festival and International Ornothilogical Congress on August 20.

The festival and congress are a real opportunity to display the wonders of our region's birds and diversity to the many international visitors . 

Visitors will be enjoying a number of tours during the Congress that will include visits to Roberts Bank and Brunswick Point where hundreds of thousands of shorebirds stop to feed and refuel during their northward and southward migrations.

The opening commenced with a wonderful parade of birds starting at Stanley Park and  ending at Jack Poole Plaza.

Much is wrong with RBT2 – time to tell the Panel 

The federally appointed Review Panel (the Panel) established to review the Roberts Bank Terminal 2 Project (RBT2) proposed by the Vancouver Fraser Port Authority (VFPA) is asking for input. The panel wants to know if VFPA has now provided sufficient information for this project to proceed to the public hearing phase. 

Answer – No, far from it. The information provided thus far fails to provide an independent, reasoned, science-based rationale sufficient to determine that the RBT2 project will not cause significant harm to the Roberts Bank ecosystem should the project be approved. In fact it is just the reverse. There is a high degree of uncertainty that VFPA has failed to address. 

So, now it is your turn. Make sure you have your say. Tell the Panel and your MP.
Here is how: 

1. Write Your MP.

2. Write to the Panel: 
Panel.RBT2@ceaa.gc.ca

What is deficient with the VFPA Environmental Impact Statement for RBT2? Despite the 15- 20,000 pages of material submitted by VFPA thus far they are still deficient in dealing with key issues, including: 

1. Biofilm impacts and the very survival of certain shorebirds and other wildlife species are central to the whole RBT2 development. VFPA and its paid consultants are trying to tell us that RBT2 will not impact the biofilm that is critical to the very survival of shorebirds, the Western Sandpiper in particular. The Port’s responses on this issue are self-serving and biased. Environment and Climate Change Canada (ECCC) disagrees with the Port’s findings and conclusions. ECCC has been very specific – not only are they not satisfied with the Port’s answers on species at risk impacts, they totally disagree with the Port on biofilm impacts. They state:
 “In particular, impacts to biofilm could potentially implicate the long-term viability of Western Sandpipers as a species. ECCC similarly characterizes impacts to Western Sandpipers as potentially high in magnitude, permanent, irreversible, and continuous”. 
An independent international biofilm experts has this to say “At this point in time, and well into the foreseeable future, our knowledge of the (mudflat) ecosystems is so limited that anyone who says that the port construction will not compromise Roberts Bank is talking through his hat”. He goes on to state:”
 … it is obvious that the shorebirds will be compromised right off the bat, and the specific microbial characteristics will also be changed as a function of the sedimentary changes which will undoubtedly occur due to altered current regimes.  How those will cascade up to the other living levels is simply not known.   ….. deciding to go ahead with the terminal project is a huge ecological gamble, and once it's built, there's no going back”. 
Damning condemnations. Add to that the fact that the widened port causeway will cover over significant areas of biofilm and it is clear the Port’s conclusions on this important issue are suspect.

2. Changes in salinity. The Department of Fisheries and Oceans has stated that the information put out by the Port and its consultants thus far is insufficient to support the conclusions reached by the Port. There is absolutely no certainty in terms of environmental impacts and a lot of confusion. Without a high degree of clarity on the issue of salinity, there is no way in which a reasoned science-based decision can be made at this time 

3. Shorebird populations are in decline. Here is what the New York Times reported recently:
 “A worldwide catastrophe is underway among an extraordinary group of birds — the marathon migrants we know as shorebirds. Numbers of some species are falling so quickly that many biologists fear an imminent planet-wide wave of extinctions.”
The Canadian Wildlife Service reported recently, advising that with Western Sandpipers the 2017 season had the lowest number of Western Sandpipers on record since 1991. They went on to state that the overall trend from 1991 to 2017 indicates a decline of -2%/year (P = 0.09). Does the Port agree with this – no. They state that the Western Sandpiper population is stable. 

4. Roberts Bank. Over ten years ago Environment Canada stated that further port development at Roberts Bank risked breaking the chain of the Pacific Flyway. The Port ignored this and is trying to go ahead anyway. The Port has thus far refused to comment on comparisons between the East Asia/Australasia Flyway, where there have been huge declines in shorebird populations due to port and industrial development, and the Pacific Flyway. Why won’t the Port address this point. 

5. The Precautionary Principle, enshrined in Canada’s environmental regulations. Basically the principle is “better safe than sorry”. Therefore this principle states that where there are threats of serious irreversible damage from a development, such as RBT2, and lack of scientific certainty then the project should not proceed. To proceed risks serious environmental damage as already stated by Environment Canada. If RBT2 is built and the damage occurs this will be a serious international embarrassment to Canada. So again better safe and sorry – don’t build RBT2. 

6. Other Wildlife and Endangered Species. The potential for serious or irreversible damage, plus lack of full scientific certainty goes well beyond shorebirds. The environmental health of Roberts Bank is critical for juvenile salmon, herring, crabs, Great Blue Herons and the endangered Southern Resident Killer Whales.  

7. Do we need another container terminal? No. The current expansions now in progress at existing lower mainland container terminals plus those at Prince Rupert, as well as other capacity increases in the planning stages, are sufficient for Canada’s trading needs for many years to come. RBT2 risks damaging the prospects of existing terminals and adds container capacity that will flood the market. Current stakeholders are opposed to this project which if built would be the most expensive container terminal development in the world.  

Make sure you have your say. 

Once again in spring 2018 The community groups Citizens Against Port Expansion (CAPE) and Against Port Expansion (APE) celebrated the return of the Western Sandpipers - familiarly known as Peeps - to Roberts Bank in Delta BC.

The Peep In this year was held April 28 at Brunswick Point on Roberts Bank Dyke Delta BC.

Later in the year July/August  you can view them as they migrate south for the winter. Drive west down River Road through Ladner. Park at the end of the road and walk along the dyke.

Link to map:

https://www.google.com/maps/place/Brunswick+Point+Trail/@49.0658999,-123.1484303,16z/data=!4m5!3m4!1s0x5485e15dfafc7b4f:0x234438b1179c6d70!8m2!3d49.0682183!4d-123.15198 

NO BIOFILM MEANS NO BIRDS 

Let's send a clear message to the Port and the regulators.

ABANDON RBT2

Keep up the pressure to stop the Port of Vancouver destroying this major wildlife habitat on Roberts Bank

Bird Studies Canada has just released a news brief "Birds Make Headlines in BC", authored by James Casey, Fraser Estuary Program Manager, Bird Studies Canada

Here is the news release

For those who follow local news in British Columbia, it would seem that birds have been cropping up a lot so far in 2018. The International Ornithological Congress and Vancouver International Bird Festival are still five months away, but we are already starting to see a number of stories featuring these promising events!

The increased attention on birds is also highlighting some serious issues around the management of birds and bird habitat. For example, Environment and Climate Change Canada recently voiced concerns about risks to Western Sandpipers and other birds posed by the proposed Terminal 2 expansion on Roberts Bank. This was closely followed by an opinion piece by Nature Canada and the University of Victoria Environmental Law Centre on the inadequacies of Canada’s Migratory Bird Convention Act, which is intended to protect migratory birds and their habitats.

But, it hasn’t all been bad news. We also saw the City of Surrey reach out to inform the community about its long-term Climate Adaptation Strategy. The strategy includes options for maintaining bird and wildlife habitat in the face of rising sea levels. You can visit the Coastal Flood Adaptation Strategy page to learn more or weigh in on options for the Mud Bay area.

The province is also taking feedback on how to modernize the management of the Agricultural Land Reserve, which may be of interest to those living in the Lower Mainland. If you would like to see bird and biodiversity values taken into consideration, now is the time to express your views.

Lastly, the City of Delta recently announced that it has developed a Bird and Biodiversity Strategy, emphasizing that Delta – along with the local governments of Richmond, Surrey, and Whiterock; and Tsawassen First Nations – manages the most important piece of bird habitat along the Pacific Coast of North America.

Conserving the Fraser River Estuary Important Bird and Biodiversity Area is a huge responsibility, and an area in which our governments have often fallen short. Because of poor past performance, the Fraser Delta now faces a number of major proposals that undermine the health of the estuary, and are leading to the destruction of bird habitats in ways that could have population-level effects. If you care about birds and the healthy ecosystems they represent, now is a good time to connect with your elected officials and tell them how important the health of the Fraser is to you.

The Roberts Bank Terminal 2 project is likely to open for public comment in only a couple of months. However, it is important to remember that it is likely the federal cabinet that will decide whether the project will proceed, so you may wish to contact your Liberal MPs now if you have comments or concerns about this project. This summer’s barbeque circuit will provide more opportunities to urge MPs across the country to ensure favourable outcomes for birds, and a healthy, functioning environment for future generations. Taking action to maintain the health of the Fraser Estuary is a good place to start.

Bird Studies Canada conserves wild birds through sound science, on-the-ground actions, innovative partnerships, public engagement, and science-based advocacy.

To find our more about Bird Studies Canada please visit

https://www.birdscanada.org/index.jsp

The Federal Panel conducting the environmental assessment of the Roberts Bank Terminal 2 project (T2) had recently asked advice of Environment Canada as to whether the description of the potential adverse effects of building T2 on migratory birds and the mitigation measures proposed by the Vancouver Fraser Port Authority (VFPA) were appropriate. The panel wanted to know if Environment Canada agreed with the VFPA, that if mitigation measures were implemented then there would be no residual effects to coastal birds.

Last week Environment Canada responded to the Panel, stating in part:

“Environment and Climate Change Canada maintains that there is insufficient, science-based information to support the Proponent's finding that the Project would not adversely impact intertidal biofilm and consequently, migratory shorebirds in general, and the Western Sandpiper species in particular. ECCC characterizes the Project's residual adverse impacts on biofilm due to predicted changes in salinity as potentially high in magnitude, permanent, irreversible, and, continuous. ECCC's confidence in the EIS's predictions is characterized as low (IBID). In particular, impacts to biofilm could potentially implicate the long-term viability of Western Sandpipers as a species (IBID). ECCC similarly characterizes impacts to Western Sandpipers as potentially high in magnitude, permanent, irreversible, and continuous.”

A damning response, that as reported yesterday in the Vancouver Sun by columnist Larry Pynn, strikes a potential deathblow to the T2 project:.

http://vancouversun.com/news/local-news/environment-canada-strikes-potential-death-blow-to-ports-2b-container-expansion-at-roberts-bank

As Roger Emsley stated in the Vancouver Sun and Province article if the ECCC response "... were a torpedo, I’d say the … port has been holed below the water line,” He then went on to say “We clearly have an environment at Roberts Bank that is fragile, that cannot withstand any more port development, and, finally, Environment Canada has come out with a definitive statement that should stop this project in its tracks.”

And so, should the T2 project be stopped? YES. Years ago Environment Canada stated that any further port expansion at Roberts Bank could break the chain of the Pacific Flyway. Mr. Silvester (CEO of VFPA) and his management team have consistently ignored that advice and moved forward to propose a new port development slap bang in the middle of Roberts Bank, one of the most Important Bird Areas in the whole of North America. 

The port authority has done nothing to protect the mudflats and wetlands that are critical to the very survival of millions of shorebirds. T2 is also detrimental to the survival of the endangered Southern Resident Killer Whales, to salmon, herring, crabs, eulachon and other wildlife species.

Not only that but Canada’s trading needs can be and are being satisfied by expansion at existing container terminals. VFPA ignores the port of Prince Rupert, even though it has almost unlimited expansion potential - at less than half the cost of T2, without many of the environmental issues.  If built T2 would be the most expensive greenfield port development in the whole world.

It is time the Vancouver Fraser Port Authority recognized that this project is not going to be approved and stopped wasting any more taxpayer funds.

If you are interested in reading the full Enironment Canada response you can view it here

http://www.ceaa-acee.gc.ca/050/documents/p80054/121632E.pdf

China has just announced a plan to halt all business related land reclamation and development projects along its coast.

The Vancouver Fraser Port Authority's plans to add a second container terminal on Roberts Bank, slap bang in the middle of a major migration stop-over area on the Pacific Flyway, will deliver yet another blow  to millions of waterfowl and shore birds. Light pollution is one of a number of reasons the Port is so detrimental to Fraser Estuary wildlife. The lights on Roberts Bank have increased enormously in the last few years. Port lights shine much brighter than other lighting in the area. Lighting impacts from Deltaport are bad enough. The additional light pollution from Terminal 2, coupled with the Port's refusal to bury the powerlines along the port causeway, puts millions of birds at even greater risk.

There is a new paper just published on light pollution impacts

http://onlinelibrary.wiley.com/doi/10.1111/ele.12902/abstract

The below article by Anne Murray provides more detail on light pollution.

Effects of Light Pollution on the Environment of the Fraser River Estuary

By Anne Murray

 The Fraser River estuary, including areas of Delta both within and outside the dykes, is a major migration stop-over and wintering area on the Canadian west coast for about 5 million birds. Waterfowl, shorebirds and song birds pass through on migration along the Pacific Flyway, travelling between the Arctic and temperate latitudes, and many also stay for the winter in the wetlands and farm fields of the estuary. Internationally-established criteria rank the estuary as the top site in the whole of Canada for number and diversity of birds, under the Important Bird Areas program. The Fraser Delta qualifies as a Wetland of International Importance under a United Nations designation (“Ramsar site”) and as a hemispheric site for shorebirds under yet another international program.

The Canadian Wildlife Service has conducted numerous surveys from the 1970s onwards, showing how waterfowl and shorebirds use wetlands and agricultural land in the Delta. These studies have been augmented by those of conservation and naturalist organizations, such as Ducks Unlimited and the Vancouver Natural History Society, which also regularly surveys bird of prey populations. The Fraser Delta is the most important wintering area in Canada for diversity and numbers of raptors, such as eagles, hawks, falcons and owls. The Delta Farmland and Wildlife Trust has also clearly demonstrated the importance of farmland to raptors, ducks, geese, swans and song birds, while experienced birders frequently find rare birds among the more than 320 species recorded here. In addition, Delta has significant populations of mammals, amphibians and important fish species.

Excessive night lighting emanating from settled areas has increased dramatically in the last few decades and has become a major issue here in the Fraser River estuary. Much night lighting is proven to be inefficient, unnecessary and expensive light pollution. Typically across North America, one third of all artificial lighting shines upwards or sideways, wasting $1 billion a year in energy costs and causing significant environmental and sociological effects. Sky glow is at its worst during periods of rain and fog, conditions that prevail markedly in the Fraser delta during winter.

Artificial light disrupts the natural cycle of daylight and darkness, that activates hormonal regulation of many human and wildlife biological functions. Darkness stimulates the production of melatonin, a hormone that is a key factor in circadian rhythms like sleep cycles and body temperature, blood and urine chemistry, immunity to disease and seasonal behaviour patterns. True darkness is needed for biological activities ranging from deer giving birth, to owls hunting successfully. Overexposure to light at night triggers abnormal behaviours and conditions, effects that may damage entire food chains. Greenhouse lights, for example, have already been observed to change the way some predators hunt, a phenomenon that could eventually alter the balance of nature in the ecosystem. Bright lights at night disorient flying birds and moths and are particularly dangerous for the hundreds of bird species that migrate at night. They are drawn to the light, becoming confused and blinded and collide with structures or fall to the ground exhausted. Tens of thousands of song birds die every year, crashing into floodlit smokestacks, transmission towers or other lighted buildings; the death toll from night lighting is calculated to be over 100 million birds a year across North America. A reduction in some moth populations has been linked to excessive light kills, and although this issue has not been studied in Delta, there are many insect-eating species that would be affected by moth declines. Aquatic species are also at risk from bright lights near the water. Normal salmon migration has been observed to peak during the darker nights of the monthly lunar cycle, making these fish particularly vulnerable to artificially bright nights.

From a human perspective, light pollution severely affects our quality of life and disrupts our activities, including the ancestral right to gaze at the beauty of stars and planets in the night sky. Studies are proving “lights out ~ live longer”, as evidence is found of hormone-related health problems linked to artificial daylight, including breast cancer, pineal gland disfunction and depression. Citizens everywhere are beginning to protest the loss of the night. Delta and British Columbia can learn from other communities across North America how to set about regulating night lighting.

 The science is unquestionable. Migratory birds occurring in Delta are an international and legal responsibility for which we are the stewards, and dark skies are an important contributory factor to the sustainability of their populations. Not only the health of birds, but also that of humans, other animals and perhaps the whole ecosystem is at stake.

Fewer and fewer Western Sandpipers, means we must do more and more to protect them.

 “Here is your country. Cherish these natural wonders, cherish the natural resources, cherish the history and romance as a sacred heritage, for your children and your children's children. Do not let selfish men or greedy interests skin your country of its beauty, its riches or its romance.” Theodore Roosevelt

The count of Western Sandpipers passing through Roberts Bank in the spring of 2017 was the lowest on record since annual counts began in 1991. This spring the estimates suggest only 190 thousand birds migrated through Roberts Bank.

The Western Sandpiper, one of the Western Hemisphere’s most abundant shorebirds, uses Roberts Bank in British Columbia, specifically Brunswick point, as a critical stop over site during spring migration, while on the move to nesting grounds in western Alaska and southern Siberia from their overwintering areas stretching from California to Peru. A large percentage of the entire species of Western Sandpipers uses Roberts Bank, where they graze the fatty-acid rich biofilm (unique to the area) to fuel their next leg on the way to their breeding grounds. Sadly the Roberts Bank site is under threat, as a result of the Port of Vancouver’s proposal to build a second container terminal, effectively industrializing the whole area.

Peak counts of Western Sandpiper have been over 1 million birds (in 1994), but typically they range between 90 to 170 thousand birds around the end of April. Spring 2017 saw a maximum daily count of Western Sandpipers at 40 thousand birds.  Population estimates of Western Sandpipers typically range between 400 to 640 thousands, with a huge estimate in 1994 of 1.8 million birds, which is more than half of the estimated total number of Western Sandpipers in the world.

Not only are the Western Sandpipers at risk. Millions of shorebirds rely on Roberts Bank and the Fraser Estuary, as do juvenile salmon, southern resident killer whales, crabs, herring, eulachon and sturgeon.

The precautionary principle must apply. Independent science is clear that there is too much at risk. We must stop those “greedy interests” from the further industrialization of Roberts Bank. The damage would be irreversible and mitigation impossible. There simply is no compensatory habitat for shorebirds. The Roberts Bank Container Terminal 2 Project is not sustainable. It must be stopped – now.

A new paper has recently been published, authored by our sister group, Citizens Against Port Expansion - CAPE

Unwanted_and_Unnecesary_jan8_2018.pdf

This paper was used in recent meetings between APE and CAPE members and MP for Delta, Carla Qualtrough and as well with Green Party MLA Adam Olsen. We are also going to be using it in meetings with other elected representatives to publicise the stupidity of proceeding with the Roberts Bank Container Terminal 2 Project.

A recent CD Howe Institute research report recommends that the Federal Government restrict Canadian port authorities (read Vancouver Fraser Port Authority) from investing risk capital and instead rely on private capital to finance expansion.

But that is not all that the report says. For one thing it disputes the VFPA assertion that their revenues are not taxpayer monies. Since port properties and the revenues they earn from them are Canadian assets then indeed these are taxpayer monies.

VFPA has committed $863 million of what it claims are its own funds in container terminal expansion. These are in fact taxpayer funds. As the report notes "While it is true that these are not direct tax dollars, this money could instead be returned to the Federal Government and devoted to other projects. So taxpayers are investing in the project". So despite what VFPA keeps trying to claim, the monies being invested in the Roberts Bank Container Terminal 2 (T2) expansion are taxpayer monies.

 Not only that but the report suggests that Ottawa "... should cast a critical eye on the proposed  T2 expansion project". In the same report the institute also indicates that if private capital is unwilling to finance the project - when they have financed other terminals throughout Canada and the world - this suggests that future demand is too uncertain for T2 to earn reasonable returns.

Does this sound familiar? It should be, this is what APE has been saying for several years. Add this to the potential for  significant environmental damage if T2 were to go ahead and these seem to be a good reasons for Ottawa to direct VFPA to abandon T2 and save tax payer monies that can then be invested better elsewhere.

If you agree then please write to the MP for Delta, the Right Hon. Carla Qualtrough at Carla.Qualtrough.C1A@parl.gc.ca

A new submission to the Canadian Environmental Assessment Agency Review Panel for Roberts Bank Container Terminal 2 has been submitted and is now on the CEAA website. The following is that submission.

Having attended the recent Vancouver Fraser Port Authority (VFPA) annual general meeting, 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. See the below attachment:containing detailed information on container volumes and forecasts:.

Statistics_Demonstrate_No_Need_for_Roberts_Bank_Container_Terminal_2_June_11_2017__3_.pdf

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 in the 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 short-listed 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 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 2020. 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 CEAA Review Panel for T2 aware that VFPA have embarked on sampling and analyzing biofilm on Roberts Bank? This renewed effort - over a year after the Port 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 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 semi-trailer 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.

A new paper has just been released entitled "Let the Fraser Live"
The Port of Vancouver has numerous projects along the Fraser River and in the Estuary which are industrializing one of the most important rivers and estuaries in the world.

This document is a call to action!

let-the-fraser-live_march12_20171.pdf

The only way governments are going to listen is if they are bombarded by emails from their constituents.

Therefore we encourage you to write to your MP and other elected officials.

The Roberts Bank Container Terminal 2 Project in the Fraser Estuary is not needed

The Port of Vancouver proposes to build a 3-berth Container Terminal 2 on a man-made island at Roberts Bank, Delta, British Columbia.  The project requires dredging and filling in 445 acres of ecologically- important waterlot in the Fraser River estuary to add 2.4- million TEUs of container capacity.  (TEU = Twenty-foot container equivalent unit)

The project will do irreparable damage to the unique Roberts Bank ecosystem which supports Canada’s highest concentration of migratory birds, the world’s most famous salmon river, as well as endangered species such as southern resident killer whales, white sturgeon and eulachon.  These amazing assets are at risk of extinction.  Basically it is the remaining wetland habitats of the Fraser River estuary that need preserving, at least the 20 % fragment that is still intact.

Three main reasons why Container Terminal 2 should not be built: 

 1)  Growth in the Container business at Port of Vancouver, at least the Canadian-bound portion, has been flat now for several years, and is likely to stay that way for many years.

 2)  Past forecasts of said growth by the Port have been consistently over enthusiastic; actual container traffic since 2007 never reached even the lowest-case projected levels.    Therefore the business case for building another huge container terminal simply doesn’t hold water.

 3)   Roberts Bank is critical to the survival of huge numbers of migratory birds on the west coast of North America, i.e. it contains mudflats which are unique on the West Coast and cannot be replicated anywhere else in the area.   Some of this precious habitat has already been destroyed by previous developments (Tsawwassen ferry terminal and existing Deltaport).    Terminal 2 will destroy much of what is left.

 1)    Growth of Container trade

The Container trade is only important to Canada’s economy, if the said containers either contain Canadian goods, (exports), or are goods intended for the Canadian market, i.e. imports we need.    Containers coming from Asia to the USA, or the reverse, are of marginal economic benefit to Canada, and if they require additional terminals that contribute to the destruction of valuable ecosystems, such as Roberts Bank, are hardly worthy of our support.

It is revealing to separate out the Canadian container trade from the US trade.   Port of Vancouver has conveniently lumped the two together to bolster its overall numbers, in a futile effort to justify expansion at Roberts Bank.   In the past, the US trade was not all that significant to Canadian ports, but due to the recent labour disputes, it has (temporarily) assumed a much greater importance.  

                                                                                                                                                                (Estimate)

Sources: OSC 2014 Report, Table 8.1 (2007-2013 data)                                                          

PMV, CEO, Robin Silvester: “Port’s stats indicate solid growth”, Delta Optimist, Aug, 26, (2015 US share)

PMV: Statistics Overview 2015

Financial Post, August 18, 2015, K.Owram

http://business.financialpost.com/news/port-metro-vancouver-expects-to-retain-business-following-u-s-ports-labour-dispute

Financial Post, August 18, 2015: Port Metro Vancouver expects to retain business following U.S. ports labour dispute:

“For planning purposes, Port Metro Vancouver assumes that approximately 15 per cent of its container business is destined for the U.S., but that number is currently closer to 25 per cent and CEO, Robin Silvester suspects 20 per cent may be a more accurate assumption going forward.”

This graph also shows that Canadian-bound TEU at Port Vancouver have been essentially flat since 2007 with a small decrease in recent years.

The 2016 total container business through Vancouver has decreased 6.4% as of May, (y-on-y), probably reflecting recent loss of US trade. (US have reported sharply higher container trade this year).

http://www.portvancouver.com/wp-content/uploads/2016/05/Container-Statistics-–-Year-to-date-May-2016.pdf

2)    Past Forecasts not borne out by actual container statistics; distortion of existing container capacity

The Port of Vancouver consistently understates actual port capacity and overestimates forecast growth.  As we all know, the container business grew rapidly in the years when it was being established, so the port deliberately includes statistics from a long time ago, to inflate the current situation – stating:

“Since 2000, Port Metro Vancouver has seen container growth of 7.1 per cent per annum.”

Of course that’s true, but it’s also ancient history; the container trade matured about 8 years ago and the business has levelled off since then. 

Since 2007 the Compound Annual Growth Rate (CAGR) has only been 2.54 %, and even that modest increase is mostly due to this temporary US trade, which is now being retrieved by the US ports.    Stripping out this US trade, we see that the all-important Canadian trade is actually down slightly since 2007, (before the financial crisis 2008-2009 temporarily distorted all stats). 

Compound Annual Growth Rate for Canadian trade since 2007 is now slightly negative at -0.35% as of 2015, hardly a case for building Terminal 2.

 Port of Vancouver Container Business

The Port of Vancouver states maximum container capacity at Canada’s West Coast ports (Vancouver and Prince Rupert), will be 6 million TEU by 2020, whereas documented information reveals capacity will actually be 8.2 million, even without the Roberts Bank Container Terminal 2. 

Canada’s West Coast Container Capacity by 2020

The total 2015 container business for the Ports of Prince Rupert and Vancouver was 3.8 million TEU. (Vancouver: 3 million TEU and Prince Rupert: 776,412 TEU)

By 2020, the combined ports of Vancouver and Prince Rupert will have enough capacity to more than double the current B.C. container business without a second terminal at Roberts Bank.  This provides time for better planning and heeding the recommendations from a 2008 Transport Canada Advisor Report that recommends:

“…policy makers develop container capacity in Prince Rupert before making investments in Vancouver” and further that: “…a systematic approach be taken to achieve an understanding of port capacity before a conclusion is reached that a particular port must necessarily be physically larger.”

(Strategic Advisors Report, Asia Pacific Gateway and Corridor Initiative Report and Recommendations, 2008; Burghardt, DeFehr and Turner)   http://www.apgci.gc.ca/StrategicAdvisorReport.html

3)    Critical value of Roberts Bank ecosystem

Roberts Bank has international significance of as a vital feeding area for:

-           migratory birds of the Pacific Flyway on their incredible journey from South America to the Arctic, and back again

-          more than two billion juvenile salmon coming down the Fraser River

-          endangered Southern Resident Killer Whales (Orcas) in Georgia Strait and beyond

The mudflats at Roberts Bank provide a unique feeding area for upwards of 600,000 migrating Western Sandpipers and 200,000 Dunlin, migrating over thousands of miles from the tropics to the Arctic every year.  These tiny shorebirds perform a miracle every year completing this exhausting long distance trip, that is one of the true spectacles of nature.

They rely on the rich nutrients found in biofilm in the mudflats at Roberts Bank.  The area is unparalleled on the West Coast due to the perfect mix of reduced salinity, nutrients from the Fraser River, low tides, and warmer spring temperature which provide the perfect conditions for tiny diatoms to produce omega-3 fatty acids just as the sandpipers migrate through this area. 

Without these mudflats, the whole migratory flock, including one of the most important Western Sandpiper flocks in the world, could never make it to the Arctic, and thus would cease to exist on the West Coast.    This would a tragedy.

References:  Sources of Information for container capacity at Vancouver and Prince Rupert

 a)      Deltaport Capacity: 3,000,000 TEU by 2020

 Projections of Vessel Calls and Movements at Deltaport and Westshore Terminals

Deltaport Terminal Road and Rail Improvement Project (DTRRIP), November 28, 2011

Pages 21; 22; 24; 26; 40; 41

http://www.robertsbankterminal2.com/wp-content/uploads/Projections-of-Vessel-Calls-and-Movements-at-Deltaport-and-Westshore-Terminals.pdf

Environmental Assessment Report, Deltaport Terminal Road and Rail Improvement Project; Hemmera; November, 2012, bottom of page 276 (Scrolled 299/450)

http://www.portvancouver.com/wp-content/uploads/2015/03/the-environmental-assessment-report.pdf

Deltaport: 2,100,000 TEU prior to Road and Rail Improvement Project

Transport Canada: Pacific Coast Container Terminal Competitiveness Study - TP 14837E, Hanam Canada Corporation; March 2008;  Page 36 (Scrolled 54/106)

https://www.tc.gc.ca/eng/policy/report-research-ack-tp14837e-menu-1671.htm

Terminal Systems Inc. Global Business; Local Interests; September 2007

b)      Centerm Capacity: 1,800,000 TEU by 2020

Container Capacity Improvement Program, Update November, 2014; page 3

http://www.robertsbankterminal2.com/wp-content/uploads/PMV-Container-Capacity-Improvement-Program-Update-November-2014.pdf

c)       Vanterm Capacity: 850,000 TEU by 2020

Global Containers Canada, Company Profile, Page 7/15

http://www.tocevents-americas.com/images/Presentations/Chris_Ng.pdf

d)      Fraser Surrey Docks Capacity: 150,000 TEU by 2020

Roberts Bank Terminal 2 Project: Meeting Canada’s Trade Demand; Project Rationale; Page 21

http://www.robertsbankterminal2.com/wp-content/uploads/RBT2-Project-Rationale-March-2015.pdf

e)      Prince Rupert Port Authority Capacity: 2,400.000 TEU by 2020

Journal of Commerce; CMA CGM gain slots to Prince Rupert, capping busy year for port, Bill Mongelluzo, November 19, 2015

https://www.joc.com/port-news/international-ports/port-prince-rupert/cma-cgm-gains-slots-prince-rupert-capping-busy-year-port_20151119.html

The Fraser River and Estuary is one of the most important areas in the whole of North America for its environmental diversity. It is recognized globally for its biodiversity and for the millions of shorebirds and other wildlife that it supports.

You would expect that an area so environmentally significant would have the highest level of protection that a nation can bestow on it.

And you would be dead wrong.

Various mega projects involving port and industrial development put the Fraser at risk. In fact the Fraser River and Estuary are at a tipping point.

The Boundary Bay Conservation Committee has recently published a report – “Save the Fraser Delta from Mega Projects”. This landmark report explains in detail the projects that are being planned and the environmental risks that result. Read the Full report here:

Fraser_River_Estuary_and_Mega_Projects_April_22_2016_A.pdf

And then write to your MLA, your MP, the Prime Minister your Premier and other politicians and demand that they support an independent multi disciplinary science based study of each of these projects and their associated risks.  

Finally a Liberal MP from the Federal Government is speaking out about the abuse of power at Port Vancouver. Read the Vancouver Sun article of April 15 2016:.

http://vancouversun.com/news/local-news/peschisolido-port-of-vancouver-must-adjust-to-changed-government-in-ottawa

Thank you MP Joe Peschisolido (Steveston-East Richmond) for stating the concerns that many of us have held for a long time about the way Port Vancouver carries out its business. Yes the Port rides roughshod over community concerns.  This is all about an unaccountable, unresponsive federally appointed agency. This is all about an agency – i.e. Port Vancouver – that has massive powers and yet is answerable to nobody.  This is all about a Port that can ignore significant environmental issues and amazingly has the power to make decisions on all kinds of projects for which the Port stands to gain financially. This is not how any government agency should be operating.

It is refreshing to see a local MP state that the Port is going to have to change the way it operates and for its powers to be cut back. This is the REAL CHANGE that many of us voted for. This was one of the core issues in the removal of the previous government.

Now what we really need is for the Federal Government to put in place a multidisciplinary, independent, science-based study to properly assess all the industrial projects that are being proposed for the Lower Fraser River and Estuary. Top of mind is Port Vancouver’s unsustainable plans for a second container terminal on Roberts Bank. This has been labelled already as the most damaging of all the projects which Port Vancouver has got its fingers into.

"The twin signatures of this era have been the mass export of products across vast distances (relentlessly burning carbon all the way), and the import of a uniquely wasteful model of production, consumption, and agriculture to every corner of the world (also based on the profligate burning of fossil fuels). Put differently, the liberation of world markets, a process powered by the liberation of unprecedented amounts of fossil fuels from the earth, has dramatically sped up the same process that is liberating Arctic ice from existence.” 
― Naomi Klein, This Changes Everything: Capitalism vs. The Climate

An excellent article by Larry Pynn in the March 21 Vancouver Sun explains why Port Metro Vancouver’s plans for a second container terminal on Roberts Bank put that whole world class ecosystem at risk from environmental degradation.

 Read the full Vancouver Sun article here: http://www.vancouversun.com/health/tiny+algae+could+block+metro+vancouver+roberts+bank+container/11798022/story.html

In the printed version of this article there is also reference to Otto Langer’s  report and a copy of the map of the Lower Fraser River and its estuary outlining the planned developments – most threatening of which is T2 - that will create a threat to fish and wildlife populations and our quality of life in this region and for all Canadians.

On the Map below number 1 is Roberts Bank Terminal 2 and the threat level is highest at 10

 You can view the full report by Otto Langer by clicking here http://www.againstportexpansion.org/uploads/images/file_download/Threats_to_and_Corrective_Actions_for_the_Lower_Fraser_River_March_15_FINAL_2016_.pdf

As usual PMV was quick to downplay the potential impact of T2 but, unlike PMV’s own studies, this is independent science and therefore not influenced by the result that PMV wants so that it can prove that the environment is not at risk from the T2 project.  PMV also makes the ridiculous assertion that there will still be plenty of biofilm for the migratory birds, completely ignoring the fact – as independent research has shown - that what is important is a special combination of light, salinity, nutrient and temperature factors which create the conditions to enrich the biofilm and produce the fatty acids that the birds require. These factors will change as a result of T2 and put the Western Sandpiper migration at risk.

As has been said many times “listen to what the birds are telling us”.

The Lower Fraser River and its Estuary: Conservation Steps Needed to Protect and Sustain Fish and Wildlife and Our Quality of Life.
An Urgent Action Plan for the New Trudeau Government
By Otto E. Langer MSc Fisheries Biologist. March 15 2016

The Lower Fraser River and estuary has been through tremendous development over the past 160 years that has greatly altered its ability to support fisheries and wildlife. Presently a series of projects are proposed when Canada has greatly diminished laws to properly assess these projects and protect the environment. Projects of greatest negative impact concern in order of priority are:

1. Roberts Bank Terminal 2 project (greatest risk)
2. New Richmond – Delta Bridge.
3. Jet Fuel Project.
4. PMV habitat banking program
5. Kinder Morgan bitumen pipeline project
6. Increased water temperatures.
7. Fortis LNG Facility on Tilbury Island
8. Gravel mining in fish habitat areas
9. Flood control initiatives
10. River dredging for flood control and construction sand
11. Port expansion to Mission.
12. Increased shipping traffic in the estuary.
13. Surrey Fraser Dock coal export facility
14. 4th runway for Vancouver International Airport (lowest risk at this time).

 An urgent action plan for the new government must include:

1. Port Metro conflict of interest between development and environmental protection must be resolved.
2. Make PMV accountable to public and local government.
3. Restore pre-2012 conditions back to CEAA, Fisheries and NWPA Acts.
4. Restore DFO will and capacity to do the job.
5. Address climate changes/ temperature issues affecting the Fraser.
6. Re-establish a Fraser River Estuary Management type organization.
7. Re-establish the federal role in environmental assessments in the Lower Fraser.

Otto Langer recently sent this report to the Prime Minister, key ministers in the Federal Government and selected politicians at the provincial and regional level urging them to take action to save the Fraser River and Estuary. To read the  full report and recommendations click here

Threats_to_and_Corrective_Actions_for_the_Lower_Fraser_River_March_15_FINAL_2016_.pdf

We also encourage you to write to your federal member of parliament, your MLA and your local council expressing support for these recommendations and urging governments at every level to start acting upon them.

  March 1st, 2016 Georgia Strait by Anne Murray

During the decade of the Harper government, many important environmental programs and safeguards were dismantled. Government scientists were unable to speak up about issues, environmental laws were weakened, and important working groups were terminated.

Notable among these was the multi-agency Fraser River Estuary Management Program (FREMP), which, together with the Burrard Inlet Environmental Action Program (BIEAP), was responsible for such tasks as baseline mapping of estuary habitat and coordinating project-review applications.

When the doors closed at the FREMP-BIEAP offices on March 31, 2013, after 28 years of operation, the role of coordinating project reviews was handed to Port Metro Vancouver (PMV), the leading proponent of development in aquatic habitat in the Lower Mainland. It was a classic case of the fox looking after the hen house, with the potential for strong conflicts of interest.

PMV, also known as the Vancouver Fraser Port Authority, is the largest port in Canada and is accountable to the minister of transport, under the Canada Marine Act. It manages more than 16,000 hectares of water, over 1,000 hectares of land, and about 350 kilometres of shoreline, from Roberts Bank and the Fraser River to Burrard Inlet.

Its mandate includes planning, real estate, safety, project environmental review, permitting, and infrastructure development designed to facilitate trade through Canada’s west coast gateway. The Port is not concerned with the overall, cumulative effects of development on the Fraser estuary’s world-class fish and wildlife, and it is only required to pass the bureaucratic thresholds of environmental assessments under the Canadian Environmental Assessment Act 2012.

PMV’s lead role as review coordinator was meant to be temporary, “until a new form of partnership was developed and launched”. Three years later, the port corporation still holds the coordinator position while simultaneously driving many major building projects in the Fraser Delta. The B.C. government is taking a hands-off approach to environmental assessment, despite several areas of provincial jurisdiction that should be addressed. Some projects are even sliding through without proper federal or provincial environmental reviews.

It is high time to form a new multi-agency coordinating body to take over responsibility for the environmental protection of all habitats and wildlife in the Fraser River Delta, estuary, and adjacent waters. The Fraser is the world’s greatest salmon river, and it is in the top 50 heritage rivers globally. The estuary is critical habitat for fish and wildlife: a BirdLife International Important Bird Area, host to internationally significant flocks of birds migrating on the Pacific Flyway and Canada’s largest wintering habitat for waterfowl and birds of prey, and a regular foraging area for endangered southern resident orcas.

Without independent oversight, these amazing assets are at risk of extinction.

The timing is particularly urgent, with a newly elected federal government just finding its feet, coupled with the out-of-control proliferation of major projects under consideration. These include: PMV’s three-berth Terminal 2, which will double the size of the Roberts Bank container port (currently undergoing a federal environmental assessment panel review); the $3.5-billion bridge replacement for the George Massey tunnel, which will be designed to accommodate tankers moving to upstream terminals; the proposed WesPac Tilbury Marine Jetty project, currently under B.C. Environmental Assessment Office review; and a fourth runway for Vancouver International Airport that could intrude into Sturgeon Banks.

Other new projects on the Fraser River include: the Surrey-Fraser Docks direct-transfer coal facility; a Vancouver Airport Fuel Facilities Corporation (VAFFC) fuel-delivery system approved for the South Arm of the Fraser in Richmond; and the major expansion to FortisBC’s Tilbury liquid-natural-gas (LNG) facility that was approved by B.C. government order-in-council without an environmental assessment.   

Not only do these megaprojects undergo incomplete environmental assessments, they also lack transparent and credible cost-benefit analyses. Although they are portrayed as benefitting the Canadian economy, millions of tax dollars fund the required infrastructure while the public is excluded from planning and evaluation processes. The results are contracts that guarantee long-term financial benefits to vested interests.

Delta farmland, already heavily impacted by sprawling housing developments, industrial-size greenhouses, and the purchase of Agricultural Land Reserve (ALR) land for speculative purposes, is disappearing under blacktop. The South Fraser Perimeter Road, now Highway 17, facilitated traffic flow into the heart of delta farmland and further fragmented the agricultural land base. The price of farmland is well beyond the reach of most active farming families, who, typically, rent many of the fields they work. Irreplaceable transitional habitat and farmland of Burns Bog were also destroyed as the highway cut through unprotected bog lands. 

Roberts Bank was designated as a Wildlife Management Area (WMA) in 2011, 16 years after Boundary Bay and Sturgeon Banks achieved WMA status. Included were 8.770 hectares, but more than 2,200 hectares of equally important habitat were omitted, presumably to allow for non-WMA uses in future. Similarly, designation as part of the Fraser Delta Ramsar Site, or Wetland of International Importance, has to date been withheld for Roberts Bank.

More than 1,600 hectares of Delta farmland were expropriated by the provincial government in 1968-69 for port industrial purposes. These Roberts Bank back-up lands were leased to farmers until the late 1990s, at which point some of the lands were offered to farmers for buy-back.

The remainder of the lands were transferred to the Tsawwassen First Nation as part of their treaty settlement in 2009 or were added to the existing rail right of way by B.C. Rail as part of the Deltaport Terminal Road and Rail Improvement Program. Over the past five years, many hectares of the former back-up lands have been optioned or changed hands, as speculative investments driven by port development. PMV as a federal entity may use ALR land for non-farm uses.

The Tsawwassen First Nation has partnered with major developers to construct two megamalls on their once fertile farmland and wildlife habitat near Roberts Bank, and further hectares are being developed for industrial infrastructure and housing. Much of Richmond has already been developed for housing and commercial uses; now some of the remaining farmland along the South Arm of the Fraser River has been purchased outright by PMV.

PMV’s CEO, Robin Silvester, has made it clear that he views the Agricultural Land Reserve as “emotionally but not economically important” to the region and that more should be done to make industrial land available. This viewpoint is contradictory to those who recognize the importance of growing fresh food close to our population centres, especially in view of climate change and food-security concerns.

In 1988, a jet-fuel facility project on the river in Richmond was rejected by an environmental-panel review on the grounds that highly toxic and flammable fuels posed an unacceptable risk to public safety. Yet in 2014, a jet-fuel offloading, storage, and transfer facility and connecting pipeline to Vancouver International Airport were approved by the provincial government for PMV-leased land on the banks of the Fraser River in Richmond. Environment Canada and Fisheries and Oceans Canada played no role in the assessment process, for which PMV was the key federal participant.

The Fraser estuary is in deep trouble. The integrity of every hectare of this once magnificent wildlife habitat is threatened by the many cumulative developments. The rich farmland of the delta, the best growing area in Canada, is rapidly being speculated out of existence. With a land-use agenda driven by transportation and port interests, the low-lying delta lands of the estuary need a moratorium and a plan. If the Fraser River salmon and the shorebirds of the Pacific Flyway are to survive, we must have a true consideration of all the cumulative impacts of these ports, airports, industrial complexes, housing developments, rail lines, highways, and bridges.

A new coordinating multi-agency group is needed to address the environmental challenges of the Fraser River estuary and its surrounding lands and waters. Port Metro Vancouver should no longer have lead authority over environmental reviews and approvals. A stronger, more effective Fraser River Estuary Management Program (FREMP) would be backed with realistic financial support, adequate staff, and the power to ensure meaningful environmental assessments on all large projects. Its responsibility would be nothing less than the ongoing survival of the area’s native wildlife and the habitats needed to support them.

In the 1990s, Environment Canada created the Fraser River Action Plan. Environmental-quality programs were initiated to clean up pollution, monitor the health of the river, and study such issues as sedimentation transport and its environmental implications in the lower Fraser. Detailed scientific reports were produced and distributed, and annual status reports gave information on achieving targets.

In 1993, “A Living Working River”, a management plan for the Fraser River estuary, was prepared by the Fraser River Estuary Management Program (FREMP). It aimed to improve environmental quality in the estuary while providing economic-development opportunities and sustaining the quality of life in and around the estuary. Despite work on biodiversity conservation and some habitat acquisitions in the next 20 years, this overall vision and coordinated action has now been lost; economic-development opportunities are being fast-tracked while estuarine habitats and quality of life are continually degraded.

In the early 2000s, even the provincial government was interested in producing annual reports on environmental trends in B.C., including biodiversity, climate change, toxic contaminants, water, and human health. It was not long before staff were fired and departments closed. The demands of energy and the rush to become a “gateway” to the world took priority over environmental concerns.

A comprehensive environmental-sustainability plan, based on the cumulative effects of all proposed development projects, is urgently needed to protect the ecological integrity of the Fraser River estuary and the wildlife that depend on its habitats. The best means of achieving this overall perspective and regulatory role is the creation of a new and stronger Fraser River Estuary Ecological Management Program.

Anne Murray’s books on Delta’s natural and ecological history, A Nature Guide to Boundary Bay and Tracing Our Past, a Heritage Guide to Boundary Bay, are available in local stores or from www.natureguidesbc.com/. She blogs at www.natureguidesbc.wordpress.com/.

Port Metro Vancouver Year End 2015 Statistics – a Lacklustre year, Is this the Beginning of a Long Term Trend?

Port Metro Vancouver (PMV) just released its 2015 annual statistics overview. Whilst the report itself is factual there are some questionable statements in the accompanying press release, such as:

1. Growth - “In the last five years, the port has grown by the equivalent of the annual volume of Canada’s second largest port – the Port of Montreal,” continued Robin Silvester. “And we anticipate that growth to continue at about the same rate over the next five years, despite the current slow-down.”

Yes but ……. Total cargo growth in Vancouver between 2006 and 2015 has been 7.2% (not per year, but TOTAL!) whereas growth in Montreal for the same 2006-2015 period has been 23.5%, so the only reason PMV can make that claim is because Vancouver is so much bigger, and by carefully picking the base year (the 2009 crisis when volumes in Vancouver tanked) they paint a rosier picture than the reality.  Furthermore if overall growth continues at this historic rate (less than 1% per annum between 2006 and 2015), then the case for any new terminals (containers or otherwise) – i.e. Roberts Bank T2 – is weak to non existent. 

2. Record Setting ??? - “This is the port’s third consecutive year of strong cargo volumes, with new records set in the container, potash, and grain and agri-product sectors.”

Hardly record setting. Container cargo tonnage is the key figure and it only increased by 2 percent. In Vancouver imports are the real driver of container volumes and laden imports only increased by 2 percent in terms of units or 3 percent in TEUs (twenty-foot equivalents). These are not great numbers -  certainly not record setting. And considering that the US labour issues in 2015 caused an increased diversion of US traffic to Canadian ports it confirms that Canadian container growth is stalled. PMV’s consultant had projected that PMV would handle over 3.15 million TEU in 2015. Actuals were more than 100,000 less – the need for T2 is not there, yet PMV keeps plowing ahead with this project.

Some other numbers of note – (i) empty outbound containers increased by 31 percent over 2014. This is likely due to the China slowdown which is hurting exports to China; (ii) bulk metric tonnage is down 1 percent (a decline of about one million metric tonnes); (iii) break-bulk metric tonnage is down by 3 percent; and (iv) the 7 year Compound Annual Growth Rate for all container metrics - inbound, outbound or total - are all at or less that 3 percent. (The figure Mr. Silvester is using of 5 percent growth includes empty containers – which of course are of no value). Record setting – not so.

Several analysts in the transportation sector are talking about the new normals for container traffic. The suggestion is that future growth in container volumes could be well below 5 percent. Another point analysts are making is that being a terminal operator in the future does not look too rosy, with falling profit margins and rising capital and operating expenditures.

All this demonstrates that the $3.5 billion plus second container terminal on Roberts Bank is just not needed – now nor any time in the foreseeable future. With expansion planned for existing Vancouver terminals plus at Prince Rupert’s container port, all of British Columbia’s container ports have capacity to handle CANADIAN container volumes for many years to come, – WITHOUT BUILDING ROBERTS BANK TERMINAL 2.

When Global News ran its piece on Jan. 14 about the Minister of Transport's visit to Vancouver, there was little detail on exactly what it was that Port Metro Vancouver wanted. However once you see the news release from the Vancouver Board of Trade (VBOT).

https://www.boardoftrade.com/news/45-news/2016/633-news-release-vbot-urges-federal-government-to-invest-in-b-c-infrastructure

It becomes all too clear. Port Metro Vancouver is now looking to taxpayers to help fund the Roberts Bank Terminal 2 Project.

Now the VBOT are to be congratulated on ensuring that BC gets its share of infrastructure funding from the Federal Government - but certainly not for Roberts Bank Terminal 2 (T2)!

What is not mentioned is that already planned expansions at West Coast container terminals will almost double container capacity by 2020, giving Canada enough west coast container terminal capacity without the need for T2. Deltaport as well as the Centerm inner harbour container terminal are adding about 1.3 mill containers (TEUs - twenty foot equivalent units). Prince Rupert's container terminal is also expanding in two phases and that will add another approx. 1.5 mill containers (TEUs). Thus the west coast container terminals in Canada will likely be adding close to 3 million containers (TEUs) in capacity by 2020. At annual growth rates of 3 or even 4 percent there is more than enough capacity to satisfy Canada’s trade objectives out to 2030 at least, especially considering that PMV is handling significant volumes (750,000 in 2015) of US containers, which adds nothing to the Canadian economy.

PMV has always claimed that T2 will not involve any taxpayer funds. Imagine the outrage in Delta and other communities - not to mention Global Container Terminals and DP World who are both funding their own expansions - when they find out that taxpayer dollars might be invested in PMV's T2. Here is a project whose business case appears very weak and that will likely result in huge risks to the Roberts Bank ecosystem - the most important ecosystem in Canada in terms of its abundant wildlife and biodiversity. And now PMV wants to get access to taxpayer funds to build T2. Go figure!

Global News ran a news item last night

http://globalnews.ca/news/2452933/questions-raised-over-funding-for-new-massey-bridge/

In the news item it was reported that Port Metro Vancouver Management took Minister of Transport the Hon. Marc Garneau out on a tour of the Vancouver harbour to give him some ideas on how to spend some of the billions of dollars in infrastructure promised in the fall election campaign.

And it’s been made perfectly clear to the minister that the port should be his top priority.

This generated concerns about the potential for taxpayer funds being used to fund a new container terminal on Roberts Bank.

Here is a letter sent yesterday to Marc Garneau MP, Minister of Transport marc.garneau@parl.gc.ca

Dear Sir,

I was alarmed at the information in the January 14 2015 broadcast by Global News:

“The minister heard Wednesday that a top priority is the Roberts Bank Terminal 2 project at the mouth of the Fraser River in Delta.”

I sincerely hope that you will properly research the claims made by Port Metro Vancouver that a new container terminal is needed at Roberts Bank.  To this date there has been no business case for this project.  There is no Feasibility Study and no Cost/Benefit Analysis.  Other Container Terminal Operators and employees do not want this Project to proceed as it will create unnecessary competition that will negatively impact existing business.  I am concerned that you are being lobbied by Port Metro Vancouver, and ministry bureaucrats of the previous government, and that the information you are hearing is incomplete and inaccurate.

Transportation experts have advised the previous Liberal Government that:: “policy makers develop container capacity in Prince Rupert before making investments in Vancouver.”(Strategic Advisors Report, Asia Pacific Gateway and Corridor Initiative Report and Recommendations, 2008; Burghardt, DeFehr and Turner)

B.C. has ample capacity to handle increases in container trade.  Vancouver, with current and planned upgrades (excluding Terminal 2) will be able to handle 5 to 5.5 million TEUs; current business is around 3 million TEUs.  The Port of Prince Rupert (cheaper, less environmental damage) is expanding and will be able to handle 1.3 million TEUs.  Plans for another terminal will increase capacity to 2.5 million TEUs.  So B.C.’s west coast will be able to handle container business growth that is significantly more than double the current business.  This will not happen for decades, if ever.

You mention in the news clip that: “There is a long list and there are long lists right across the country so we’re going to be looking at all of them and deciding on where is it the most important for us in order to make our trades flows as efficient as possible because it has a big effect on the economy of the country,”

Please do not be misled by the claims of Port Metro Vancouver.  Please note that the main importance to the Canadian economy is the Bulk and Break Bulk shipping which accounts for 82% of the shipping tonnage through Port Metro Vancouver.  The products shipped (exported) in Bulk and Break Bulk are the mainstays of the Canadian economy, i.e. our products such as grains, minerals, lumber, pulp, etc.   These products truly do sustain thousands, perhaps even  millions, of jobs throughout Canada.

The Container business on the other hand, is basically an import business, bringing in manufactured goods for the most part, which sustain millions of jobs in the countries that send us those goods, and some jobs in our retail sector.   It’s nice to get these iPad’s, Mercedes car, Panasonic TV’s, etc. but let us not confuse this with job creation in Canada.  Infrastructure and land requirements for the container business are prohibitively costly to taxpayers. 

Container shipping into Canada grew nicely for a while, (during the ‘fledgling’ years), but isn’t growing at all now.   Instead it is the new business of importing goods into the USA via Canada which is growing, and this doesn’t create any jobs at all, outside of the waterfront/railways connected to PMV.

And it is doing irreparable damage to our scarce and vital farmlands and globally- significant Fraser River delta, just to bring in/out containers for the Americans. Infrastructure and land requirements for the container business are prohibitively costly to taxpayers.  While Port Metro Vancouver will be responsible for finding the financing for the new Terminal, the related infrastructure costs fall to the taxpayer who have already spent over $10 billion, and counting, on the Asia-Pacific Gateway.  Your Government has stated funding for infrastructure is a priority.  Please do not waste more valuable tax dollars on infrastructure for the Vancouver container business.  

As you learned during the election, the Harper Government scuppered the environmental assessment process leading to a highly flawed process.  This is the case for the Roberts Bank Terminal 2 Project.  Lawyers have advised that the Environmental Impact Statement (EIS) for the Roberts Bank Terminal 2 fails to adequately address impacts, particularly cumulative effects, on the endangered Southern Resident Killer Whales and fish species.  Concerns have been submitted by the World Wildlife Fund, the US Environmental Protection Agency, Metro Vancouver and several local municipalities.  The EIS fails to include vital scientific information on the unique importance of Roberts Bank to millions of Western Sandpipers and other shorebirds.   

Your Government promised to stop this violation of due process.  We are counting on you to ensure that current environmental assessments do not proceed under the flawed process.  Directives from the new Government could order the Canadian Environmental Assessment Agency to strictly apply legislation such as credible science, credible cumulative effects assessment, impacts beyond the T2 Project footprint, sincere evaluation of Species at Risk, and inclusion of globally-significant wildlife.    

Sincerely,

Susan Jones

Hardly a day goes by without the media reporting on the decline in world trade. Recently we have seen articles about layoffs at major shipping lines, orders for new container vessels being cancelled and global slowdowns in trade growth, to name just a few.

Many of the articles say this is not a blip and point to a long-term slowdown. They talk about trade falling off a cliff. Of course much of this is as a result of significant slowdowns in the Chinese economy, which nobody is forecasting will pick up any time soon.And then along comes Port Metro Vancouver announcing that its container trade to the end of June increased by eight per cent compared to the same period in 2014.

So what is going on? Is Canada not seeing the same trade effects as everywhere else? Perhaps we need to delve into the stats a little deeper. Is the eight per cent increase accounted for by Canadian containers or is this increase accounted for by the fact the port is moving more and more U.S. containers, which, by the way, add little or nothing to the Canadian economy?

It is certainly strange that for a media release at the end of November the port chooses to use the end of June as a measure when it has container statistics all the way to the end of October. In fact at the end of October, for the year 2015, the statistics show the number of full containers handled by Port Metro Vancouver only increased by 2.1 per cent over the same period in 2014. These same statistics also show that the number of empty containers shipped - for which nobody makes any money except the shipping lines - is up a full 26 per cent for the 2015 year to date.

So is Canada seeing similar trade impacts as the rest of the world? Of course. Existing West Coast container ports not only have spare capacity today, but in the next five years are expanding to increase their capacity by as much as 70 per cent. With global trade in freefall, indications of a long-term trend and plenty of spare West Coast port capacity, there certainly is no need whatsoever for Port Metro Vancouver to consider building a second container terminal at Roberts Bank.

In fact Port Metro Vancouver quietly reduced its container growth forecast. Until recently it was saying that container volumes would double in the next 10 to 15 years. Recently they changed that and now state volumes will almost double in the next 15 years. That is a significant reduction but, given the realities of world trade, it is still unrealistic. It is time Port Metro Vancouver conceded that Canada does not need T2 to satisfy its trading needs in the foreseeable future

As you are likely aware the Environmental Impact Statement for the Roberts Bank Container Terminal 2 (T2) project was released to the public in April. However, here we are 7 months later and there is still no opportunity to comment on its sufficiency and technical merit.

Therefore deciding that we have waited long enough we have now written and published a report entitled “Port Metro Vancouver’s Roberts Bank Container Terminal 2 Is Not Sustainable – It Must Never Be Built”.
Read the full report here:

 Port_Metro_Vancouver_T2_Development_Is_Not_Sustainable_Nov_2015_.pdf

The report reviews this project and finds it lacking in terms of its sustainability - being a balance between the economic, environmental and socio -community aspects. We will be filing this report with the Canadian Environmental Assessment Agency as soon as we are permitted to do so.

Conservation of important wildlife habitat is an international responsibility and Canada is falling short. Roberts Bank sits on the Pacific Flyway and is one of only six major stopping places where waterfowl and shorebirds pause to feed on their long journey between Central and South America and their Arctic breeding grounds. Loss of habitat and disturbance by port development on Roberts Bank is already having an impact on birds, waterfowl, fishes, whales and other wildlife. This second container terminal would be the tipping point. It cannot be allowed to proceed.

It is bad enough that the Port would consider a second container terminal in this highly significant environmental area, used by millions of shorebirds, by salmon, by whales and many other wildlife species. It is equally concerning that the business case for this container terminal is weak. It simply cannot be justified because there is plenty of spare current container port capacity as well as large expansions at existing container terminals coming on stream in the next five years that will increase container terminal capacity on the West Coast of Canada by about 70 percent. Not only that but the Port seems intent on poaching more US bound containers (which adds nothing to the Canadian economy) despite the fact that neighbouring US ports have lots of spare capacity - with Seattle/Tacoma ports planning to increase from 3.5 million containers to 6 million by 2020. In short the West Coast has enough container capacity for many years to come without building this hugely risky second container terminal.

There are some significant questions about this project:

1. Why does the Port insist on building greenfield container capacity on environmentally sensitive land?

2. Why is the Port putting Roberts Bank at risk by building a second container terminal on Roberts Bank, when:

• The three existing container terminals in Vancouver – Deltaport, Centerm and Vanterm all have spare capacity.
• All three Vancouver terminals have plans for expansion that will add even more capacity. Deltaport is already expanding, shortly to add 600,000 containers of capacity (Twenty foot Equivalent Units – TEUs). Centerm has plans in the short term to add between 600,000 and 800,000 TEUs of capacity. And Vanterm also has medium term plans to expand.
• Prince Rupert’s Fairview container terminal is undergoing an expansion that will add an additional 500,000 to 750,000 TEUs. Plus there are further expansion plans being considered, by adding a third berth, which will bring additional capacity of up to 700,000 TEUs.
• Taken together the Canadian West Coast container terminal expansions will bring online a further 2.4 to 2.9 million TEUs by 2020, without this Roberts Bank second container terminal. Adding this to the current spare capacity, there is more than sufficient container capacity to meet Canada’s trading needs for many years to come. Why therefore does the Port not recognize that a second container terminal is not needed now or in the foreseeable future and should not be built?

3. Why does the Port not address the recommendations in the 2008 Federal Government Report (Strategic Advisors Report, Asia Pacific Gateway and Corridor Initiative Report and Recommendations), especially the key recommendation that “…policy makers develop container capacity in Prince Rupert before making investments in Vancouver” and further that: “…a systematic approach be taken to achieve an understanding of port capacity before a conclusion is reached that a particular port must necessarily be physically larger.”

4. Why does the Port continue to handle more and more US containers (upwards of 750,000 TEUs for the year 2015), which adds little or nothing to the Canadian economy, when US west coast ports have the capacity to handle these US containers? Seattle/Tacoma container terminals, currently handling 3.4 million TEUs, plans to expand to 6 million TEUs by 2020 and want to take back the US container traffic that Port Metro Vancouver  has poached

These and many other questions remain unanswered.

George Massey Tunnel Replacement Project Review

By Douglas George Massey son of the late George Massey after whom the tunnel was named. August 24, 2015

Recognizing that the Provincial Government is determined to replace the George Massey Tunnel with a high level bridge in the Fraser River Delta, I would like to provide the public with a few facts that I researched from publications over the life span of the tunnel.

Why was a tunnel built instead of a bridge in the first place?

 Here is some background and answers:

A tunnel was chosen because of the geology of the lower Fraser River delta.

The lower Fraser River Delta comprised of Richmond, Sea Island, Delta, Queensborough, Pitt Meadows, South Surrey and Vancouver, started to form about 10,000 years ago, just after the Ice Age when the upper Fraser River Basin consisting of 234,000 km² (57,822,658 acres) or (90 square miles) was covered in ice. The sea was as far inland as Pitt Lake and extended 15-23 km (9-14 miles) westward into the Gulf of Georgia. When the ice melted off the upper Fraser basin, the materials of sand, gravel and clay flowed into the Gulf of Georgia at the rate of 3400 cm³/S (120,069 cubic feet per second) creating some 1000 km² (247,105 acres) of delta, with depth of anywhere from 500 m (1500 feet) to 1000 m (3000 feet), above bedrock.

Bogs and marshland were formed. The materials within them were rich in nutrients and energy, supporting the greatest salmon bearing river in the world and largest population of wintering wildfowl. Dikes were built to contain the materials, creating the most productive agricultural lands in Canada, doing  this took up about 80 % of the Fraser delta, leaving only 20% to support the ecosystem of the Lower Fraser River. According to a Sediment Management in Lower Fraser River document of March 30, 2010, the natural flow of sediments down the Fraser River must be maintained in order to support that ecosystem and any premature removal of these materials whether it is sand or gravel must be continuously monitored to insure the survival of that ecosystem.

The George Massey Tunnel was designed and built by Christiani &Nielson Corporation from Denmark, the same people who built the Maas tunnel in Rotterdam, Netherlands 1937-1942. The difference was that the Maas tunnel had a tube for bicycles and pedestrians whereas our tunnel did not, even though it was proposed in 1947.

George Massey Tunnel was completed in 1959 at a cost of $16,600,000 which is just over $35 million in today’s dollars. The George Massey tunnel was built on 600 meters (1969 ft.) of sediment (sand) on top of bedrock as there was insufficient footing for a high level bridge.

Building the Maas River Tunnel proved to be more attractive financially than a bridge because the cost of building a bridge high enough would be prohibitive in order to avoid hindering the passage of ships to and from the largest port in Europe, Rotterdam. Port Metro Vancouver is calling for a 65 meter (213 feet) high bridge instead of the design proposed of 57 meters (187 feet).

In 2006 seismic upgrading of the George Massey Tunnel was completed at a cost of $20 million dollars. It consisted of making the 6 tunnel sections into one steel reinforced tube, attached to the ventilating towers on either side of the Fraser River. This would insure that the tunnel would not collapse if the underlying layer of sand was to liquefy. The pumping and emergency power systems were upgraded as well. In addition in 2009 an early warning system called “Shake Alarm” was installed on the George Massey Tunnel capable of detecting earthquakes with seconds to minutes of warning time, designed to close the gates at either end of the tunnel so that no one can enter if a dangerous quake was inbound, and those already inside can exit as normal before any shaking or movement begins.

Further improvements costing another $17 million were scheduled for the George Massey Tunnel that would have improved the seismic protection around the approaches and the replacement of the ventilating equipment, but were cancelled when the government announced a new bridge crossing. A bridge that was to be 57 meters (187 feet) high, built on footings on top of 600 meters (1969 feet) of sand over bedrock, right near the present tunnel. One would have to ask how much safer this would be for a bridge, when studies showed that liquefaction would remove the sand from under the tunnel leaving it with no support despite being seismically upgraded.

The Alex Fraser Bridge is anchored on bedrock on one side of the Fraser River and supported on sand on the other side, leaving it also vulnerable to seismic liquefaction. In 1959 a Fraser Delta Geology: Hazard Assessment study by the provincial government stated that seismic upgrading was needed for all construction in the Fraser Delta, even the highways leading to our river crossings would be subject to seismic movement. To date there is no direct measurement of seismic vulnerability of the Fraser delta from strong motion recording.

The George Massey Tunnel was built below the Fraser River bottom and has at low water 33 feet (10m) over 1400 feet on either side of middle of channel and 42 feet (12.8 meters) over 700 feet over the middle of channel. At the time it was built it was deeper than all navigable river channels in the world.

Dredging of the Lower Fraser River to 11.5 meters with a minimum 2 hour window year round currently costs Port Metro Vancouver $15 million a year; they recoup only $10 million by selling the sand to cement makers and road builders. To deepen the Lower Fraser River to the 13.5 meters (44 feet) proposed by the Provincial Government was estimated as a onetime cost of $175 million, which does not include the increased costs to maintain this depth. The provincial government did not mention the cost of removing the George Massey Tunnel or the lowering of any existing utility crossings.  Nor was there any mention of the reinforcing of the dikes of Richmond and Delta.

In 2007, the provincial government (Pacific Gateway Strategy Action Plan) advocated the removal of the George Massey Tunnel and to deepen the Lower Fraser River channel to 13.5 meters (44 feet) so they can create a deep sea shipping channel and make the Lower Fraser River into a deep sea port facility right up to and beyond New Westminster. In order to recoup the costs of dredging to maintain the deeper channel, they proposed to reclaim marshland around the present islands in the Fraser and build more islands at the mouth of the Fraser for industrial purposes.  All this despite the fact that Port Metro Vancouver says that the George Massey Tunnel presently does not protrude above the Fraser River bed and the Steveston cut is more of a problem and the cost of removing the tunnel, lowering existing utilities and deepening the river would be extensive and potentially cost prohibitive.

In a report called “Sediment Management in Lower Fraser River on March 20, 2010” it stated “Sediment removal that is not properly planned and/or executed can have immediate and serious adverse effects on fish population” and there should be a long term management programme initiated before additional sediment is removed by gravel or sand dredging.            

The grade through the George Massey Tunnel is only 1:30 while the grade on the new bridge at 57 meters (187 feet) high is 5:0. The lower grade of a tunnel rather than a bridge would result in less fuel consumption for commuters. BC Hydro has recently announced that it is already seeking a new river crossing for the present transmission line that runs through the George Massey Tunnel and supplies power to Richmond, Delta and other parts of Greater Vancouver. This will result in greater expense to taxpayers.

The George Massey Tunnel built in 1959 has many years of life left regardless of what the Provincial Government wants us to believe. In 2006 the provincial government spent $20 million for seismic upgrades, and installed a seismic “shakeproof” early warning seismic system, and planned to spend another $20 million for further upgrades to the ventilation and seismic upgrading around the approaches. In comparison, the Maas tunnel that was built in 1937-42 using the similar construction materials and methods of construction will be spending millions of dollars on a large scale renovation that will start in 2017 and conclude in 2019 to meet modern tunnel standards.

One would think that if the Dutch are willing to spend millions to renovate their 75 year old tunnel that the additional upgrades proposed the George Massey Tunnel, being only 55 years old, could still be upgraded and last for many more useful years and retain and maintain a close tie with the business and residential core of Richmond.

In conclusion, my point is that it would seem that building another modern tunnel near the present one would be faster and safer to build. All parts could be built and purchased locally, have minimal disruption to the Fraser River and a greater resistance to seismic activity, than a high level bridge.

Further Richmond Council have stated that they would like to keep the tunnel and use it for another purpose, and they were opposed to any dredging to make the river deeper because of the ramifications it would have on the Fraser River’s ecosystem that supports the fish and wildfowl of the Fraser River, agricultural land and as well create the need for extensive dike reconstruction.

It is ironic that this and previous Richmond Councils were also the strongest supporters when my father George Massey was advocating a new crossing to the extent they installed a monument on their side of the tunnel recognizing George Massey’s achievement.

My reference sources are as follows:                     

1. Proposed Crossing of the Fraser River at Ladner, B.C. by Christiani & Nielsen Corporation, April 10, 1947.
2. Sustainable Dredging Program of the Lower Fraser River, Aug. 7, 2007.
3. Fraser River Dredging (Fraser Port Authority) Aug. 7, 2007#4. Fraser Delta Geology Hazard Assessment Nov. 1995
4. Sediment Management in Lower Fraser River, March 20, 2010
5. Sedimentary environments post glacial history of Fraser Delta, March 18, 1983
6. Journal of Commerce Sept 7, 2009 article British Columbia’s Massey Tunnel was a cutting-edge endeavor.
7. Vancouver Sun article May 22, 2025 Port Metro wants Massey bridge higher to allow biggest LNG tankers: documents.
8. Article T&T North America march 2006: Seismic upgrade for Massey Tunnel
9. Delta Geology: Hazard Assessment November 1995 in the BC Professional Engineer.
10. Article George Massey Tunnel by Buckland & Taylor February 2015.
11. Letter from Port Metro Vancouver July 2015.
12. Article on Shakealarm June 2015 from Wikipedia.
13. Articles Maas tunnel; Rotterdam Wikipedia March 10, 2011
14. Sedimentary environments and postglacial history of the Fraser Delta and the lower Fraser Valley, March 18, 1983.
15. Article by Kenaidan Contracting Ltd. Re: Seismic upgrade George Massey Tunnel.
16. Massey Tunnel Project article April 16, 2013 by Richmond Garden City Conservation.
17. Sediment Management in Lower Fraser River March 30, 2010.
18. Articles on construction, maintenance and replacement George Massey Tunnel June 9, 2015 WIKI 2- Wikipedia Republished.
19. Vancouver Port Authority, Roberts Bank Container Expansion Coastal Geomorphology Study-Appendix C November 2004.
20. Article Business Vancouver April 21, 2014. Plan for deeper dredging in Fraser River could have high environmental price.
21. Request for proposal Fraser River annual maintenance dredging, August 18, 2010
22. Article Richmond Review Aug. 13, 2015 Province keeps Richmond in dark

Port Metro Vancouver’s (PMV) Robin Silvester continues to use smoke and mirrors to try and justify that the environmental destruction of Roberts Bank is necessary to handle Canadian cargo, but the Port’s own statistics (to the extent that they are willing to share them) simply don’t add up.

The 2014 Overseas Shipping Consultants Market Study prepared for PMV showed that in 2008 (the year before the Financial Crisis), PMV handled 2.34 million TEU of Canadian cargo.  By Mr. Silvester’s own admission in the Aug 26 Delta Optimist article, US Rail volumes will account for 25% of PMV’s total throughput in 2015.  Based on July 2015 statistics, PMV will handle 3.06 million TEU in total this year, so the US Rail volumes (25%) will represent over 765,000 TEU, meaning PMV will be handling about 2.295 million TEU of Canadian traffic in 2015.  This is LESS than the 2.34 million TEU of Canadian cargo that PMV handled way back in 2008!

 TEUs (container volumes)

Sources:
Overseas Shipping Consultants 2014 Report – table 8.1
Robin Silvester – Delta Optimist Article Aug 26 2015
PMV 2015 Container Statistics – annualized for 2015

And yet, despite these hard statistics showing that there has been 0% growth in Canadian traffic through PMV between 2008 and 2015, Robin Silvester claims in the article that “the underlying Canadian growth is above the four per cent we're looking at”.

PMV appears to be trying to create the illusion of a business case, but it is not working. If you look at the facts the business case simply doesn’t exist. 

Against Port Expansion opposes the T2 project because of the massive environmental damage that will be inflicted on Roberts Bank, but our group is willing to go “toe to toe” with PMV and Robin Silvester to prove to the Canadian public that aside from the massive environmental damage that this project would cause, there is simply no economic need for this project for decades to come, if ever.

To read the Delta Optimist Article click here

http://www.delta-optimist.com/news/port-s-stats-indicate-solid-growth-1.2040818

We have just published our latest newsletter.

Included in the newsletter is further information on the progress of the Federal Enivonmental Assessment, a critique of Port Metro Vancouver's Enivonmental Impact Statement for Roberts Bank Terminal 2 and further information on where T2 container volumes might come from were this new terminal ever to be built.

 Read it here.

APE_Newsletter_Jul_2015.pdf

It is becoming increasinlgy evident that the expansion of Port Metro Vancouver's container business is mostly coming from the movement of US containers - both inbound and out bound. Without this US traffic Port Metro Vancouver (PMV) simply cannot justify builiding a second container terminal on Roberts Bank.

A recent letter in the Delta Optimist highlighted this. http://www.delta-optimist.com/news/goods-through-deltaport-headed-to-u-s-1.1981775

As the letter points out handling US containers does nothing for the Canadian economy. In delving deeper into this topic what we find is that in 2015 West Coast Canadian Ports will handle over one million US containers, with Port Metro Vancouver handling the majority of these US containers. Furthermore PMV's business case for building a second container terminal is partly justified on the handling of even more US containers than they are today. This finding is supported by a number of articles in industry journals.For example one recent article in "Canadian Shipper" states the following:

“According to a study of U.S. West Coast port volumes by UK-based firm Ocean Shipping Consultants, Vancouver has joined Prince Rupert as a major competitor to the Puget Sound ports of Tacoma and Seattle for U.S. imports. U.S. importers are rapidly moving more containers through Port Metro Vancouver and to Chicago and the upper Midwest, dealing another blow to the ports of Seattle and Tacoma.  The share of Vancouver’s containerised imports moving to the U.S. expanded from 7.5 per cent in 2008 to 22.9 per cent in 2013, according to Newark’s Journal of Commerce." 

PMV's handling of US containers hurts US ports, such as Seattle and Tacoma that would love to be handling this business. It does nothing for the Canadian economy.

What does all this tell us. If Port Metro Vancouver stuck to its mandate "To facilitate Canada’s trade objectives, ensuring goods are moved safely, while protecting the environment and considering local communities" and.focused its efforts on handling Canadian containers then there would be no need to build a second container terminal on Roberts Bank.

One of the many failures in Port Metro Vancouver’s Environmental Impact Statement for Roberts Bank Terminal 2 is its incomplete and heavily flawed analysis of the potential impacts on the unique biofilm that is present on Roberts Bank and is a critical food source for millions of migratory birds and shorebirds.

It appears from the work that Port Metro Vancouver (PMV) carried out in this area that they identified the outcome that they wanted to portray and then built a series of hypotheses to support that outcome. Thus the PMV research is nothing more than “decision based fact making”.

The many PMV failures in carrying out a robust assessment of the importance of the Roberts Bank biofilm are becoming all too clear. Notably a number of submissions to the Canadian Environmental Assessment Agency (CEAA) on the RBT2 environmental assessment identify and document a flawed and incomplete environmental assessment. Perhaps one of the more important submissions (June 15 2015) comes from Environment Canada (http://www.ceaa.gc.ca/050/documents/p80054/101866E.pdf) who state 
" ... that recent work on Roberts Bank by international scientists has provided new information on the nature of the intertidal diatom community at the time of the spring breeding migration of Western Sandpipers. The global population of Western Sandpipers, a migratory bird, is dependent on the habitat found in the Roberts Bank area. This new information may better explain why these shorebirds (and likely other migratory bird species) concentrate at this site, as opposed to other sites in the Fraser River delta. Further, the occurrence, abundance and nutritional value of these diatoms may have broader implications across trophic levels in relation to ecosystem productivity of the Fraser River Estuary. This new information casts reasonable doubt on some of the Proponent’s key conclusions with respect to biofilm and migratory birds as presented in the EIS.".

Furthermore Environment Canada notes that “It is unclear how changes in coastal geomorphological processes relating to tidal currents and sedimentation rates over the upper intertidal of Roberts Bank will affect biofilm productivity including in relation to the recently identified diatom".

Not only that but in reviewing PMV’s Environmental Impact Statement they appear to have lumped diatoms into "marine" and "freshwater", which based on other research papers that are available seems to greatly oversimplify the complexities of the Roberts Bank system and is a further indication that their analysis is incomplete.

PMV is also ignoring the potential changes to Roberts Bank that may result from them building a huge man-made island including, habitat loss, direct impacts such as footprint scour, and channel formation; indirect impacts such as sediment distribution and sediment grain size. Many of these were identified by the Port’s own working groups but then brushed aside. One of their technical working groups, commenting on assessment of potential impacts on shorebird populations,  went as far as to state that it was not feasible to carry out such an assessment. What did PMV do with this information – they ignored it.

Several recent scientific papers that have recently been published all talk to the importance of the biofilm on Roberts Bank.

In one:  “Intertidal biofilm distribution underpins differential tide-following behaviour of two sandpiper species during northward migration” ( http://www.sfu.ca/biology/wildberg/NewCWEPage/papers/JimenezetalECSS2015.pdf )    published in the “Estuarine, Coastal and Shelf Science Journal” – an international multidisciplinary journal, the research shows the critical importance of Roberts Bank in supporting internationally significant populations of migratory shorebirds and Western Sandpipers in particular.

Key points in the paper include:

• Western sandpipers and dunlin follow ebbing tides while foraging on stopovers.
• Tide following foraging behaviour is stronger for dunlin than western sandpipers.
• Western sandpiper foraging distribution matched biofilm availability. (meaning that this is their preferred food despite other options being available)
• Biofilm, an energy source for shorebirds, merits conservation consideration.

As the paper documents, shorebird species rely on habitats like Roberts Bank, yet these species are becoming increasingly threatened by industrial development, such as the massive Port Metro Vancouver Terminal 2 development.

In another: “Biofilm Consumption and Variable Diet Composition of Western Sandpipers (Calidris mauri) during Migratory Stopover” (http://www.ncbi.nlm.nih.gov/pmc/articles/PMC4397082/) it notes that major estuarine stopover locations supporting biofilm are often strategic places for transport and other industrial developments (as of course is the case for Roberts Bank). The paper goes on to note that there are a number of important factors to be considered where biofilm is known to exist, because biofilm is such an important food source at key stopover and feeding sites. It is therefore critical to identify the impacts on these important feeding sites in terms of what further industrial development means and indeed whether it should even be allowed. 

What does all this tell us? PMV needs to start over with its analysis of biofilm on Roberts Bank; to engage renowned and independent international experts in the field; and to develop a well researched study that will help to determine whether there should be any further industrial development on Roberts Bank.

Unless and until this is carried out there is no point in convening an Environmental Assessment Panel for Roberts Bank Terminal 2.

This video was sent in by one of our supporters.

 J_Pod_Whales_at_proposed_PMV_T2_site_20150608_103955_208555144972917_0.mp4

It shows a southern resdient killer whale from Jpod swimming with its baby.The Orcas regularly feed on and hunt spring salmon and chum salmon from spring to fall in the area where T2 would be. The new terminal will be another obstacle to their routine and the migration of salmon up the river. 

Of course the new proposed terminal will also destroy crab habitat, obstruct their feeding and migration patterns and take away some of the fishing grounds used by commercial fishermen due to further navigational closures.

Enjoy this while you can. If T2 goes ahead we may never see this again

Two research papers recently prepared for both the Against Port Expansion Community Group and B.C. Nature, by the University of Victoria Environmental Law Centre, address two of the major environmental and wildlife issues with the Port Metro Vancouver Terminal 2 project: migratory birds and marine species..

 The first, dealing with migratory birds, is entitled “Bringing Roberts Bank Migratory Birds to the Forefront of Environmental Assessment”. Because migratory birds are an undeniable central feature of Roberts Bank and the Fraser River Estuary as a whole, this becomes one of the key issues when it comes to deciding whether T2 is likely to cause significant adverse environmental effects. The environmental value and health of Roberts Bank as a migratory bird habitat has already irrevocably shifted. In fact Environment Canada in 2005 stated that they:
“… are concerned that the chain of the Pacific Flyway could be broken for shorebirds at some point given the ongoing economic development in the Delta. This constitutes a major risk for Canada's environmental reputation and the economic and social benefits derived from wildlife.” PMV appear to be conveniently ignoring that statement. No comparable site on the flyway exists on the Pacific coast between Alaska and California. No other site in Canada supports such a diversity and number of birds in winter.

 If T2 were to go ahead there is indeed a possibility that the chain of the Pacific Flyway could be broken.

Read the paper here:
Bringing_Roberst_Bank_Migratory_Birds_to_the_Forefront_of_Environmental_Assessment_Jan_2015_0.pdf

The second research paper is entitled “Questionable Treatment of Marine Shipping in the Environmental Assessment of the Terminal 2 Project”. This deals with the second major issue, being to what extent the expansion in marine shipping will add to the already significant impacts on marine species.

Over 100 marine species in the Salish Sea (Strait of Georgia, Gulf Islands, San Juan Islands, Puget Sound and Strait of Juan de Fuca) are listed as endangered, threatened, special concern or are candidates for listing by at least one of four jurisdictions (governments of Canada, BC, USA and Washington State). PMV would like us to believe that they will be able to ignore these impacts during the environmental assessment. That is not going to happen. Canada’s Minister of Fisheries and Oceans has categorically stated that any impacts on the endangered Southern Resident Killer Whales will be assessed, including as a result of the increased number of container vessels that will be required to feed T2. As well, both First Nations and US tribes’ traditional rights and interests in coastal and marine areas stand to be significantly affected. The T2 project may also adversely affect and infringe on constitutional rights.

Read the paper here: Questionable_Treatment_of_Marine_Shipping_in_the_Environmental_Assessment_of_the_Terminal_2_Project.pdf

We will be presenting both these papers to the Review Panel when it convenes. In the meantime we are also using the papers to identify a number of shortcomings in the PMV Environmental Impact Statement.

According to the Executive Summary for the Roberts Bank Terminal 2 project (page 75) PMV says "Therefore the Project in combination with past projects and activities that have been carried out, and certain and reasonably foreseeable projects that will be carried out, would result in a continued significant cumulative effect to the Southern Resident Killer Whales" Despite this and the fact that T2 will bring 260 more vessels right through the critical Orca habitat PMV plans to go ahead anyway.

This topic was recently aired on CBC's Power and Politics. See the video https://m.youtube.com/watch?v=5EMSf-DPPtM

Scientists fear for the future of the Southern Resident Killer Whales - as documented in a Post Media news item in late 2014.

http://www.calgaryherald.com/news/metro/Endangered+killer+whale+found+dead+Strait+Georgia/10443916/story.html

The Georgia Strait Alliance https://georgiastrait.org/ programs and intiatives are working  towards the protection and recovery of species at risk - both our southern resident killer whales as well as many other species at risk.   Please do support them in their work.

So PMV is planning to push ahead with T2, in effect saying that because the Orcas are already impacted it is OK for them to increase the vessel traffic right through their habitat and impact the Orcas even more. This even though Orcas are listed and protected as a species at risk under the federal Species at Risk Act.

That is irresponsible. Write to Port Metro Vancouver CEO Robin Silvester and tell him so. Also perhaps ask him why PMV declined to be interviewed on CBC and what thay are trying to hide. Email him at Robin.Silvester@portmetrovancouver.com

A large group of supporters showed up to the Second Annual Peep-In at Brunswick Point in Delta to celebrate the return of the Western Sandpipers and to send Port Metro Vancouver a very clear message - STOP PLANS TO DEVELOP CONTAINER TERMINAL 2 ON ROBERTS BANK

Watch the video http://not2.ca/second-annual-peep-in/

This is the new Against Port Expansion Poster

LESS THAN 1% ANNUAL GROWTH IN CANADIAN VOLUMES

Port Metro Vancouver (PMV) is pushing for a 2^nd massive container terminal in the Fraser River Estuary despite the fact that PMV container volumes are showing only very slow growth in recent years.

PMV claims container volumes will double over the next few years and nearly triple by 2030, reflecting an expected annual growth of 5% to 7% annually.  However, from 2007 to 2014, container growth averaged only 2.2 percent per year.  At this rate, it will take 32 years to double the current business and published information shows that PMV already has this capacity.

Whilst the large majority of containers moving through PMV are Canadian origin or destination, the important factor to note is where the recent growth is coming from. As the graph below demonstrates, most of this modest growth is due to USA containers being funnelled through the port with little economic value to Canada.  There has been a miniscule 0.7 percent annual growth in Canadian import/export containers through PMV since 2007, certainly nothing to justify the huge, intrusive Terminal 2 project in an incredibly important and sensitive environment.

Note: CAGR percentages below are each expressed as a percent contribution to the overall

In the last few years, Canadian international trade, particularly in western Canada, has settled into the current pattern, whereby we import much of our needs for manufactured goods from overseas, (in containers), and export our natural resources in bulk form.  Prior to 2007, there was a rapid increase in container traffic as the business was new and getting established.  This led to the false premise that such growth would continue indefinitely.   Port Metro Vancouver (PMV) is still using this premise to justify another giant container terminal.

However, the container business at Port Metro Vancouver (PMV) matured around 2007.  Canadian-destined TEU import volumes from here on in can only be expected to roughly match the general increase in Canadian GDP, which is typically about 2.0 - 2.5 percent per year.  This is a far cry from the 6% to 7% per year that PMV is using in its projections.

Port Metro Vancouver TEUs Showing US and Canadian Volumes

The majority of growth in Canadian container volumes is being handled at the Prince Rupert Port Authority (PPRA).  In 2014, container shipping through PPRA was up 15 percent from 2013, handling 640,000 TEUs with about half of these volumes for Canadian destinations, the rest to the USA.  In March, 2015, PPRA announced a $200 million expansion at the Fairview Container Terminal to increase capacity by 60 percent.  Prince Rupert has the advantage over PMV of being 2-3 sailing days closer to Asian markets.  PPRA also has the critical advantage of connecting Canada directly to the US Gulf Coast, on a less congested line (via the Canadian National Railway and its extensive connections in the US Midwest) thereby avoiding the punitive US Harbour Taxes on the West Coast and the high cost of union dock labor unrest.

The future for increased container shipments through the Prince Rupert Authority looks bright indeed, but not so for Port Metro Vancouver, which basically is facing a saturated market for containers in Canada, and no particular advantage with the US volumes which have grown to 15 percent of PMV’s container trade in the last 2 years.  In any case, port expansion to handle import/export containers for the Americans will do little for our economy, and tragically it will cause irreparable damage to our scarce and vital farmlands and the Fraser River delta.

Over-estimating projected growth and understating current capacity, Port Metro Vancouver plans to dredge the estuary and construct a 284-acre island for a 3-berth container terminal in the Fraser Estuary, all the while claiming no accountability to the environmental effects beyond the areas it manages.  This astonishing attitude contradicts the very purpose of the Canadian Environmental Assessment Act and Canada’s responsibility to cumulative effects, species at risk, migratory birds, and wild salmon. 

Federal, provincial and local governments continue to pour tax dollars ($8 billion and counting) into the Vancouver Asia-Pacific Gateway infrastructure to facilitate the container business which is only 18 percent of the port’s tonnage compared to 82 percent for Bulk and Break-bulk shipping.   Not only are the products exported in Bulk and Break-bulk vital to the Port, but, more importantly, they are the mainstays of the economy of Western Canada with products such as coal, grains, mining products, fertilizers and wood products.  These products truly do sustain thousands, nay millions, of highly paid jobs throughout Canada.

The Container business on the other hand, is basically an import business, bringing in mostly manufactured goods which sustain millions of jobs in the countries that send us those goods, and some jobs in our retail sector, mostly minimum wage unfortunately.   It’s nice to get these iPad’s, Mercedes cars, Panasonic TV’s, etc. but let us not confuse this with job creation in Canada.

Some Break-bulk products are now being shipped out in containers as exports from PMV, giving a misleading impression of the importance of container shipping for these vital Canadian products.   The use of containers is convenient as empty containers have to be shipped back to the countries of origin.  So filling them with Break-bulk products is a good way to do this, especially if the shipment rates for such ‘empty’ containers are near zero.  There is no business case for this export trade, except that containers must be recycled somehow, no matter what the cost.  This leads to a false impression of overall growth. 

Therefore the use of empty containers for exports may be desirable for getting rid of huge and unsightly piles of steel boxes, but it is not profitable to Canada, and should not be used to destroy the Fraser River Delta, the most important biological environment on the BC coast, from almost any perspective.

We may ask several pertinent questions:
1)      Why are the federal and provincial governments supporting a totally unnecessary terminal which will destroy globally-significant habitat?
2)      Why are billions in taxes being spent on the Vancouver Pacific Gateway Strategy to provide infrastructure to move and store containers thereby choking up Metro Vancouver ports, roads, railways and industrial lands?
3)      As time goes on and the PMV Canadian container business fails to grow as predicted by the proponents, will the new terminal then be used for other purposes such as fuels? (As happened a few years ago, with the failed grain terminal at Roberts Bank.   The first two container berths at Deltaport were built without any environmental assessment.  If the second container terminal is built, the environmental damage will have occurred and other options, such as fuel, could arise.)

*Note 1: Prior to 2008, the Fraser River Port Authority reportedly separately from the Vancouver Port Authority (VPA).  The current Vancouver Fraser Port Authority (commonly called Port Metro Vancouver) was created in January, 2008, through the amalgamation of the Vancouver Port Authority, the Fraser River Port Authority and the North Fraser Port Authority.

References:

1. Container Traffic Forecast Study – Port Metro Vancouver, June, 2014
Ocean Shipping Consultants; pages 57, 59, 81, 82, 207, 208, 209 and 193
http://www.robertsbankterminal2.com/wp-content/uploads/Port-Metro-Vancouver-Container-Traffic-Forecast-Ocean-Shipping-Consultants-June-2014.pdf 

2. Port Metro Vancouver Container Forecasts, July 2013: Ocean Shipping Consultants, pages 175 &178
http://www.robertsbankterminal2.com/wp-content/uploads/Port-Metro-Vancouver-Container-Traffic-Forecast-Ocean-Shipping-Consultants-July-20131.pdf

3. Facts and Stats Port Metro Vancouver:  Container Stats Monthly 2008-2014, 2014 Statistics Overview
http://www.portmetrovancouver.com/about/factsandstats.aspx

4. Pacific Gateway Strategy: (March 4, 2014 - Data provided to Bloomberg BNA by the B.C. Government http://www.bna.com/canadas-west-coast-n17179882593/ 

5. Prince Rupert to expand port’s container cargo capacity: Fairview Terminal operator committed to $200 million project that will increase capacity 60%.
http://www.biv.com/article/2015/3/prince-rupert-expand-ports-container-cargo-capacit/

6. Journal of Commerce, February 12, 2015, Vancouver sees 4% TEU Growth in 2015 after record-setting 2014
http://www.joc.com/port-news/international-ports/port-metro-vancouver/vancouver-sees-4-percent-teu-growth-2015-after-record-setting-2014_20150212.html

 7, 2008 Port Metro Vancouver Economic Impact Study, January 12, 2009 by InterVISTAS, pages 9 & 69
http://www.portmetrovancouver.com/docs/default-source/about-facts-stats/2009-01-12_Intervistas_-Port_Metro_Vancouver_Economic_Impact_Study_FINAL_REPORT.pdf?sfvrsn=0

8. Port Metro Vancouver: Port Growth & Development:  Land Use Plan Update, Background Paper, page 8
http://www.portmetrovancouver.com/docs/default-source/default-document-library/background-paper-1---port-growth.pdf

9. Transport Canada, March 2008: Pacific Coast Container Terminal Competitiveness Study TP 14837E Prepared for: Policy Integration and Research Branch, Strategic Policy Directorate Policy Group by Hanam Canada Corporation, Victoria, BC page 36
http://www.tc.gc.ca/eng/policy/report-research-ack-tp14837e-menu-1671.htm

10. Global Containers Inc.  A publication by TSI in 2006/2007 announced that the new Third Berth would increase capacity to 2.1 million TEUs. (Slide Presentation: page 17)

11. Worley Parsons Canada, November, 2011: Projections of Vessel Calls and Movements at Deltaport and Westshore Terminals  - Deltaport Terminal Road and Rail Improvement Project (DTRRIP) pages 22, 24 and 41
http://www.robertsbankterminal2.com/wp-content/uploads/Projections-of-Vessel-Calls-and-Movements-at-Deltaport-and-Westshore-Terminals.pdf

12.  Deltaport Terminal, Road and Rail Improvement Project, page1 http://www.portmetrovancouver.com/docs/default-source/projects-dtrrip/pmv-dtrrip-project-update---july-2014.pdf?sfvrsn=2

The latest scientific paper on biofilm feeding by shorebirds on Roberts Bank, jointly-authored by a team from Simon Fraser University and Environment Canada, has just been released in the January 2015 edition of the “Estuarine, Coastal and Shelf Science Journal” – an international multidisciplinary journal.

This new and important research clearly demonstrates – once again – the critical importance of Roberts Bank in supporting internationally significant populations of migratory shorebirds and Western Sandpipers in particular.

Key points in the paper include:

• Western sandpipers and dunlin follow ebbing tides while foraging on stopovers.
• Tide following foraging behaviour is stronger for dunlin than western sandpipers.
• Western sandpiper foraging distribution matched biofilm availability. (meaning that this is their preferred food despite other options being available)
• Biofilm, an energy source for shorebirds, merits conservation consideration.

As the paper documents, shorebird species rely on habitats like Roberts Bank, yet these species are becoming increasingly threatened by industrial development. A prime example of this is Port Metro Vancouver’s plans to build a massive man-made island on Roberts Bank for a second container terminal.

Based on the study that lead to the publication of this research paper, it is clear that the intertidal biofilm that is present on Roberts Bank plays an important role in shorebird diets – the western sandpiper in particular. Daily averages of more than 100,000 sandpipers concentrate at Roberts Bank during the northward migration. The paper specifically recommends that environmental assessments for coastal development and conservation strategies for shorebirds need to explicitly consider the physical and biotic processes that produce and replenish biofilm. The conservation implications are clear. The environmental quality of biofilm rich stop-over sites must be maintained so that biofilm availability for shorebirds remains adequate. Therefore there has to be a major conservation priority to safeguard the Roberts Bank habitat, thus ensuring that biofilm availability. What does that involve - no more port development, no more land reclamation for industrial uses.

In related news the country of Panama has just announced new legislation which will protect a key area of wetlands in the Bay of Panama, home to migratory shorebirds including the western sandpiper. Under the new law, already in effect, construction is banned in a 210,000 acre stretch of the Bay of Panama.

If Panama can do it why cannot Canada?
Port Metro Vancouver – are you listening?

 If you wish to access the full research paper please follow this link:
http://www.sciencedirect.com/science/article/pii/S027277141400417X

Alternatively if you would like a copy then please email us at info@againstportexpansion.org

Port Metro Vancouver finally released its 2014 year end container statistics. No wonder they took so long – the actual containers handled (TEUs – Twenty Foot Equivalent Units) came in well below their latest forecast. As recently as June 2014 PMV had been projecting an annual increase of over 6 percent to almost 3 million TEUs. However 2014 actually ended with them handling just over 2.9 million TEUs, a one year shortfall of almost 90,000 TEUs. In fact as recently as 2011 they were forecasting they would handle almost 3.3 million TEUs in 2014. So even having reduced their forecasts they still fell short. Still that did not stop the Port spin machine kicking into high gear, claiming in the media that 2014 was a record year.

In fact PMV’s own recently-published figures show that there was zero growth in full container shipments in 2014. Even adding in the movement of empty containers, PMV only recorded a 3 percent annual growth over 2013 - and nobody makes money shipping empty containers. What the Port fails to mention is that their 2014 figures were bolstered by the handling of increased US container traffic, as a result of the labour disruptions at US West Coast ports. If it had not been for that bonus they might well have seen a year over year decline in container traffic.

In the last six years PMV has missed its forecast increase each and every year. The actual 6 year compound annual growth rate for total containers is running at 2.63 percent and for full containers at 2.82 percent. Many factors including a repatriation of manufacturing jobs to North America indicate that going forward all PMV can expect is a 4 percent annual growth – perhaps 5 percent at best.

This is supported by recent industry forecasts – including from one of the major shipping lines - suggesting that going forward an annual growth of between 4 and 5 percent is realistic. Despite that PMV has been claiming recently that they will record increased container volumes each and every year going forward of between 6 and 7 percent. How are they going to do that when the last six years show that their compound annual growth is less than 3 percent?

Meanwhile the Port of Prince Rupert has had healthy growth, recording a 15 percent year over year increase for 2014. Prince Rupert container port is in the midst of a phased expansion that will add significant container capacity, sufficient to satisfy Canada’s trading needs for many years to come.

 It is time that Port Metro Vancouver stopped the game playing and admitted that a second container terminal on Roberts Bank is not needed now or in the foreseeable future.

The YouTube clip from Citizens Against Port Expansion tells the story.

https://www.youtube.com/watch?v=W7X03gdr_D0

January 18 2015

Watch this new video by Citizens Against Port Expansion

https://www.youtube.com/watch?v=YS5Kavle1uo

Cliff Caprani outlines what we are up against in the months ahead as we work to stop Port Metro Vancouver from building a second container terminal on a huge man-made island in Georgia Strait.

Port Metro Vancouver (PMV) has had a habitat banking program for some years. The concept works like this -  they select an area that they decide they can “improve” and then carry out work on that location. The sole purpose of this program is for PMV to build up credits that it can use to offset damage that it does to the environment in other locations – such as if it were to get permission to build a second container terminal on Roberts Bank.

There is nothing wrong with the concept but there is plenty wrong with the way PMV executes. Recently there has been little or no oversight or control by government agencies, nor does PMV take account of community concerns. A good example was the log clearing that they carried out in Boundary Bay. For this project there was no community consultation, nor did they listen to experts on salt marsh ecology that said it was best to leave the logs where they were. Instead they moved in and destroyed an area that was a valuable food source for raptors and other birds of prey. By removing the logs they also killed off all the voles and other small critters that lived in and under the logs. This destroyed a valuable source of food for the winter of 2013 for the owls, and other birds of prey.

Also, as a result in 2014 it made the salt marsh much more accessible. People were able to tramp over the salt marsh, ride bikes and ATVs and do further damage to what became a fragile environment. Then in late 2014 the first major winter storm brought back the logs, seaweed and other debris, doing even more damage to what is now a fragile environment.

The pictures below tell the tale

2015 is going to be a pivotal year in our fight to stop Port Metro Vancouver from building its Terminal 2 project on Roberts Bank. It is going to take a lot of effort to stop T2,

but we can do it!!

Please read our January Newsletter below which contains:

• A review of the key evidence that we have assembled and what it will take to stop T2.
• A summary of the stages of the upcoming Federal Panel Review, what to expect and how you can participate.
• An update on PMV’s disastrous habitat banking project at Boundary Bay, where the recent winter storm brought back logs and debris.
• A look at PMV’s public relations campaign and “spin” as they attempt to fend off criticism of T2.
•  A heads-up on our plans for holding a second annual “Peep-In” in April – to celebrate the return of the Western Sandpipers as they migrate north
• A look into the murky world of federal politics and recent changes to legislation that may help PMV get around provisions in the Species at Risk Act.

APE_Newsletter_Jan_2015.pdf

A recent report by the conservation group Birdlife International lists Roberts Bank as one of four important bird areas in Canada in danger.

 " You've got intensification of agriculture happening, expanding urban development, expanding port development and infrastructure, recreational pressures, shipping pressures, you have all this happening together," said Andrew Couturier, who works with Bird Studies Canada, one of BirdLife International's partners.

 This is the very area where Port Metro Vancouver plans to build a second container terminal, with the potential to further damage an area that is noted as being one of the richest and most important ecosystems for migrant and wintering shorebirds in Canada.

 We cannot let this happen. Tell Port Metro Vancouver that it must not do any further damage to Roberts Bank.

 Read the full report on threats to Roberts Bank 

http://www.birdlife.org/datazone/sitefactsheet.php?id=11056

Did you attend either one of Port Metro Vancouver’s recent small group sessions? If so you will recall that participants questioned the economics and justification for building a second container terminal (T2) on Roberts Bank, even though the meeting topic was environmental mitigation. Participants expressed concern regarding the accuracy of the 2014 Ocean Shipping Consultants container forecast and requested that additional information be made available regarding the justification and need for the Project, including a business case and container forecast information from alternate sources.

 If you thought for a moment that as a result Port Metro Vancouver (PMV) would set up a separate consultation session to discuss the economics and justification, think again. PMV is steadfastly refusing; therefore there will be no opportunity to discuss this before they produce their Environmental Impact Assessment.

 Why do you think this might be? Could it be because the justification for a second terminal is very weak? Could it perhaps be because they are underperforming against their latest forecast, which they have done with every recent forecast that has been produced? Could it be because a good part of their justification relies on moving more and more US containers, which adds no value to the Canadian economy? Or is it that they know T2 – which will be a semi automated terminal with fewer jobs - will need to attract business away from other Vancouver area container terminals: information that they do not want to put out there?

 What we do know is that:

1. Their most recent forecast has been significantly reduced (by 600,000 at the 2025 level), yet they will still underperform against that forecast in 2014.
2. China is experiencing a major downturn in their economy which maybe means a much slower growth in imports into Canada.
3. The US economy is growing and continuing to repatriate manufacturing from overseas countries, lessening the need for imports via container.
4. US ports are investing in new infrastructure and have strategies to ensure US containers are handled in the USA, lessening the leakage to West Coast Canadian ports.
5. Container imports are not likely to grow much faster than Canada's GDP growth - currently in the 2 - 3 percent range.
6. Existing terminals in Vancouver have plans to expand and Prince Rupert is already expanding.
7. PMV still maintains it will triple the containers it handles by 2030. That means they would need to expand by close to 7 percent each and every year out to 2030. Not going to happen.

 What this means is there is no business justification to build T2. PMV's container growth estimates are likely to top out in the 3-4 percent range for the foreseeable future. And at that level of growth Canada's west coast ports have sufficient capacity in operation now or planned to come online without ever needing to add a second container terminal at Roberts Bank.  

 If Port Metro Vancouver believes otherwise then they should agree to hold separate consultation sessions so that participants can better understand and ask questions dealing with the whole justification for T2.

November 21 2014

Social and environmental values for one of the most important ecosystems in North America– The Fraser River and Estuary – are under threat and Port Metro Vancouver is at the root of all of these threats. 

Four massive projects taken together threaten the Fraser River and its estuary in a worse way than at any time in recent history. Proposed projects include; a jet fuel offloading terminal for Vancouver Airport; an adjacent 80 million litre tank farm; a new coal export terminal that includes barging coal down river; and a massive second container terminal on Roberts Bank. 

The risks are twofold. The actual construction of these projects will destroy existing valuable ecosystems that support massive marine and bird life. And an accident – a fuel spill, a container vessel sinking – could wipe out entire species, of invertebrates, salmon, orcas, and migratory and shorebird populations. 

Couple all of these with the recent dismantling of environmental regulations and the emasculation of key agencies – Environment Canada and Department of Fisheries and Oceans – and the end result is that if Port Metro Vancouver gets the go ahead for all these projects, it will be to the detriment of communities and important ecosystems all along the Fraser and its estuary. 

This is not about nimbyism or anti-trade sentiments. There are alternatives. Suggestions for handling jet fuel deliveries to the airport in a more sustainable manner were discarded. Inland container terminals that would make existing ports more productive are discounted by Port Metro Vancouver. Port Metro Vancouver is in denial that maximizing port expansion at Prince Rupert to handle future growth in container traffic is a better option. 

For more detail on some of these threats read the October 15 2014 paper by Otto Langer – Fisheries Biologist and Aquatic Ecologist. Fraser_River_Values-Sandheads_to_Annacis_FINAL2_Nov_15__2014.pdf

November 17 2014

Several new international studies have just been published in a special issue of the Journal of Sea Research, an international and multidisciplinary periodical on marine research. These studies, written by international experts in the field of scientific research, relate to biofilm ecology in tidal flats.

There are 17 articles in the special issue, presenting research from the "International Symposium on Trophic Significance of Microbial Biofilm in Tidal Flats", which took place in France in 2011. At last, the international scientific community is waking up to the critical importance of biofilms in the coastal environment. The special issue is the first comprehensive overview of scientific research related to microbial biofilm ecology on tidal flats. Articles include accounts of general biofilm spatio-temporal dynamics, physical and chemical aspects of biofilm export, the trophic role of biofilms in tidal flat ecosystem functioning, and the biofilm-mediated ecosystem services provided by tidal flat ecosystem to humans. The findings highlight both the technical complexity and major role that biofilms play in the functioning, productivity, health and biodiversity of nearshore ecosystems. In addition they speak to the dynamic nature and inherent fragility of biofilm. A major conclusion is that pluri-disciplinary studies linking physics, chemistry, ecology (from molecules to communities) and human activities in coastal zones are needed to achieve real understanding.

Regrettably none of these experts were invited to participate in the Port Metro Vancouver (PMV) Technical Advisory Groups studying the potential impact on Roberts Bank from building T2. As a result the studies that have been conducted on Roberts Bank are nowhere near the standards exhibited at the 2011 symposium and the understanding is severely lacking compared to their European counterparts. This therefore brings into question the overall worth of the work carried out by PMV thus far on biofilm.

What these new studies also show is that coastal ecosystems rank today among the most endangered ecosystems in the world due to human activities. Among wild populations, 48% of shorebird species are declining due to the degradation and loss of habitats anywhere along their flyway. A recent report by the World Wildlife Federation - the “Living Planet Report” - complements this view by suggesting that “… more than 10,000 representative populations of mammals, birds, reptiles, amphibians and fish, has declined by 52 per cent since 1970. Put another way, in less than two human generations, population sizes of vertebrate species have dropped by half. These are the living forms that constitute the fabric of the ecosystems which sustain life on Earth – and the barometer of what we are doing to our own planet, our only home. We ignore their decline at our peril.”

One such ecosystem is Roberts Bank on the Fraser River Delta, recognized internationally as a critical stepping-stone for millions of shorebirds migrating along the Pacific Flyway. Roberts Bank supports rich biofilm pastures as well as associated crustacean, mollusc and other invertebrate resources that are the food for Sandpipers and numerous other migratory birds. Alarmingly Port Metro Vancouver’s new container terminal T2, on Roberts Bank, severely jeopardizes this internationally important ecosystem. In particular, the construction of T2 may fatally impact the biofilm. The widened port causeway for T2 would not only be built over and destroy a large area containing biofilm, but the T2 man-made island would likely change tidal flows and currents over Roberts Bank that sustain the remaining biofilm. Removing such an essential food source could doom the entire species of Western Sandpiper as well as other shorebird species.  

The risks to Roberts Bank from Port Metro Vancouver’s container terminal expansion are too severe. We simply cannot afford to risk the destruction of migratory and shorebird feeding grounds on Roberts Bank by development of a second container port.

As the World Wildlife Federation says: “By taking more from our ecosystems and natural processes than can be replenished, we are jeopardizing our very future. Nature conservation and sustainable development go hand-in-hand. They are not only about preserving biodiversity and wild places, but just as much about safeguarding the future of humanity – our well-being, economy, food security and social stability – indeed, our very survival.”

Let’s heed the warning – and say no to T2.

It does not matter what time of year, Roberts Bank is in constant use by many species of birds and waterfowl. September 15 2014 there were a thousand shorebirds, mostly Black Bellied Plover using the NW Corner Roberts Bank Causeway, along with over 500 waterfowl . They lined the edge of the salt marsh  right the way up the Western Causeway in an area that would be covered with  an expanded port causeway and rail tracks if T2 goes ahead. Stop Port Metro Vancouver from destroying critical shorebird habitat - SAY NO TO T2

Have you seen the slick TV ads telling us how Port Metro Vancouver is providing shore power for cruise ships to cut down on pollution?

The Vancouver Sun ran an article on August 19 telling us that less than one third of the cruise ships are actually using it.

http://www.vancouversun.com/travel/Most+cruise+ships+tapping+into+Vancouver+shore+power/10129179/story.html

One cruise line then advised that it has shore power connectivity but the Port assigns them a berth where the connection is on the wrong side!

Locally one Delta Resident wrote in the Delta Optimist, suggesting that Port Metro Vancouver treats Deltans as second class citizens:

http://www.delta-optimist.com/deltans-are-second-class-citizens-1.1320236

Pollution from ocean going vessels – both cruise ships as well as the many freighters docking in Vancouver area ports – are indeed a significant source of pollution. The pollution problem is actually much worse than Port Metro Vancouver would have you believe. Only a few of the cruise ships use shore power, and PMV does not even provide it at their other terminals, despite repeated requests to do so.  As usual they have many excuses.

In any case, by our estimate cruise ships represent only about 3% of the total ship-days in port, so if only 1/3 of the cruise ships, (and none of the other ships) are using shore power, it means about 99% of the ships tied up in the port are using their own diesel engines, likely burning dirty diesel fuel (Bunker C).

The extent of this problem can be gauged by looking closely at the statistics provided by Metro Vancouver on the sources of pollution in the Metro air shed, (emitters).Metro Vancouver says that on average, 10% of all air pollution is caused by ships.   This average is derived by including Carbon Dioxide (CO₂) as one of the pollutants, but CO₂ isn’t a health risk in the usual sense, and is nearly all contributed by other sources, e.g cars and industry, not ships.  In other words CO2 won’t give you cancer or emphysema. 

There is a huge amount of CO₂ generated in the air shed, in tonnage terms compared to the other real pollutants.  It therefore skews the average to make ships look relatively benign, and thus we arrive at the 10% figure.   But if we take out CO₂ from the average, the  percentage contribution of ships to the real pollution situation gets much worse:

• The serious and major pollutants in the Metro Vancouver air shed include NOx, Diesel Particulate Matter and Sulphur Dioxide. 
• Ships contribute now, respectively 14%, 38% and 79% of these key pollutants, obviously much more than the 10% figure widely quoted
• These three pollutants are all serious health risks, right now.    They cause smog, which is bad enough, but they also lead to serious illnesses such as lung cancer, bronchitis, emphysema, cardiovascular diseases, you name it.    The list goes on and on….
• Reading the medical literature on the health risks of these pollutants is a sobering experience and should be a wake up call to port inhabitants in any major port where these monstrous diesel engines are allowed to idle for days on end.
• Bad as this is, the percentage contribution is only going to get worse in future, up to double that, due to various factors.
• Most other segments of society are now closely regulated, i.e. forced to decrease air pollution all the time, (industry, cars, trucks for instance), but not Port Metro Vancouver, which is totally unregulated and continues to pollute our atmosphere. 
• Port Metro Vancouver plans to bring in many more vessels, (all burning dirty diesel fuel while in our port), including:
  • Coal ships to Fraser Surrey Docks
  • Oil Tankers to Kinder Morgan
  • More container ships to Roberts Bank

Bottom line - we have a serious health risk in Metro Vancouver coming from ships, far more than we are being told.The only way to reduce this problem is to require – perhaps even regulate -that shore power must be implemented at all Port Metro Vancouver sites, not just the cruise ships, which are a minimal part of the problem anyway.

Tell Port Metro Vancouver to stop polluting our air shed. You can tell them here:

http://porttalk.ca/port-talk-consultations

Is this Port Metro Vancouver pulling the wool over our eyes? Here is the thread:

The Delta Optimist has had a recent flurry of editorials and letters recently published and concerning Port Metro Vancouver’s proposed Roberts Bank Terminal 2. It started with an editorial about the concept of inland terminals as a way to spare farmland in Delta from industrial development:

http://www.delta-optimist.com/opinion/inland-port-to-spare-farmland-1.1211305

This was then followed by a letter suggesting the Port start listening to community views:

http://www.delta-optimist.com/inland-port-idea-would-be-way-for-pmv-to-stop-lip-service-and-actually-listen-to-community-1.1260883

There then came a response from PMV’s Vice President Peter Xotta :

http://www.delta-optimist.com/more-than-inland-port-required-1.1267104

This then prompted two more letters:

The first disputes the stats he puts out on container volumes and job creation numbers:

http://www.delta-optimist.com/disputing-the-stats-on-container-traffic-and-forecasted-job-creation-1.1303197

The second says T2 is not needed and challenges the Port's notion that container traffic will double in 10 to 15 years, suggesting that Prince Rupert is better placed to handle West Coast container expansion:

http://www.delta-optimist.com/t2-not-needed-save-farmland-and-habitat-instead-1.1303195

Finally recent comments by PMV CEO Robin Silvester about the number of jobs T2 will create (also mentioned by Mr Xotta although he uses numbers that are different than Mr.Silvester) prompted Cliff Caprani from Citizens Against Port Expansion to craft this short video.

** DON'T MISS THIS - IT IS A GOOD ONE!!

 https://www.youtube.com/watch?v=0BoDWbQ4b7w

It challenges Port Metro Vancouver to explain the conflicting, confusing and over inflated  job creation numbers that they are putting out.

Speaking about International Migratory Bird Day in the BC Legislature on May 7 2014, MLA for Delta South, Vicki Huntington, highlighted the importance of Roberts Bank as a unique ecosystem. She reminded the House that on Roberts Bank "One of the world's greatest migrations takes place on our doorstep, a doorstep that is in danger of becoming a doormat". She went on to point out that a rare intertidal biofilm situated right on Roberts Bank sustains the world's population of Western Sandpipers.

She then went on to indicate that now competing interests, such as Port Metro Vancouver's proposed container terminal expansion on Roberts Bank, threaten to destroy this ecosystem. Suggesting to the Legislature that Delta South is without parallel in British Columbia in terms of its natural wonders, with Roberts Bank in particular being designated under the United Nations Ramsar Convention as wetlands of international significance, she said "Enough is Enough!" and  called on the legilsature to protect the vital ecosystem that is Roberts Bank .

View Statement by Vicki Huntington in the BC Legislature

https://www.youtube.com/watch?v=Ne1Gg5xI3Ww&list=UUhPMNoXA2dHnHsYD3f-5Ndg

No Business Case for a Second Container Terminal in the Fraser River Estuary

 Port Metro Vancouver (PMV) is moving forward with a Canadian Environmental Assessment for a second Container Shipping Terminal (T2) with three berths adjacent to Deltaport at Roberts Bank.  The $3 billion Terminal 2 will add three million TEUs (twenty-foot container equivalent units) of capacity.  To justify this massive project, the port is publicizing exaggerated forecasts claiming its container traffic will triple by 2030.  This translates into a Compound Annual Growth Rate (CAGR) of 6.3% per year.  It is an unrealistic forecast considering the fact that the last 5 years (2008 – 2013) have shown a CAGR of 2.54%.

PMV Container Growth Forecasts - Click Here For a Printable Copy

PMV has consistently understated capacity and overstated projected container volumes in order to push for container expansion at Robert Bank.  The Port is now repeating this misrepresentation to justify their Terminal 2 (T2) project.  PMV is ignoring the capacity and potential for expansion at Prince Rupert Port in spite of a Government Report (Strategic Advisor Report, Transport Canada, 2008) advising that expanded container capacity should be developed in Prince Rupert before investing in Vancouver.

Economically, it defies logic to spend about $3 billion ($1,000 per TEU of capacity created) for a new terminal to expand container capacity at Port Metro Vancouver when Prince Rupert estimates it will cost about $650 million to expand its capacity by one and a half million TEUs ($433 per TEU of capacity).

Considering that less than a third of PMV container throughput is destined for southern BC, 50% to 60% of B.C. container business can be handled by either Port Metro Vancouver or Prince Rupert Port.

More importantly, ports in Seattle, Tacoma and Los Angeles compete with B.C. ports for US container business. About 20% of PMV and 50% of Prince Rupert container business is bound to the US.  PMV will have to massively increase its share of rail volumes to the US market in order to fill up the proposed T2 project.  Recent rail congestion suggests that this will be extremely unlikely, and PMV has done no studies to suggest that the Canadian railways could handle this additional volume, particularly in conjunction with increased capacity in Prince Rupert and demands of grain, oil, and other domestic cargo movements. 

PMV is planning to spend about $400 million just for the approval stages of the new Terminal 2 (T2).  The Port then plans to enter into contracts that will expose PMV to annual contingent liabilities of well over one $100 million to guarantee payments to the company that will construct T2.  All of this is being done so that PMV can generate congestion on Canada’s roads and railways to increase the movement of containers to the US.

It makes no business sense to spend billions to dredge and fill globally-significant habitat in the Fraser River estuary when the combined container capacity of PMV and Prince Rupert Port can easily accommodate several decades of Canadian container trade.   Where is the accountability?

For a detailed analysis click here

See the May 23 Delta Optimist Opinion Piece by Ian Robertson

http://www.delta-optimist.com/opinion/growing-port-doesn-t-appear-to-be-answerable-to-anyone-1.1072298

Western Sandpiper Migration Under Threat from proposed Port Metro Vancouver Expansion on Roberts Bank

Port Metro Vancouver is in denial. They refuse to recognize the importance of Roberts Bank and its unique biofilm which is critical to the very survival of the Western Sandpiper species. Their staff are constantly trying to downplay the importance of the biofilm, suggesting that there are other food sources - Nonsense. They make comments such as “We are committed to ensuring that any potential impacts of the project to the environment generally, including shorebirds, are avoided or mitigated."  How exaclty do they think they can mitigate the destruction of the Western Sandpiper species?

Read the May 2 Vancouver Sun article and video by Margaret Munro National Science Writer Post Media News. Migrating Shorebirds - The Sticky Issue

Read also the newly released report on Western Sandpipers - High Risk of Environmental Degradation on Roberts Bank

See photo by Terry Carr of the spectacle of the Western Sandpiper migration

APE - Against Port Expansion - hosts a Peep-In at Roberts Bank in Delta B.C.

APE held a very successful Peep-In on April 21 at Roberts Bank in Ladner (South Delta) to celebrate the unique spectacle of the Western Sandpiper Migration.

Close to one hundred people came out to see the Western Sandpipers. This major annual migration event at Roberts Bank is one of the most important in the whole of Canada. At its peak there are tens of thousands of birds in huge flocks in the air, swooping in to feed and slurping on the biofilm as they build up their strength before continuing on their journey. This has to be witnessed to understand its importance. This area has to be saved from any further industrial or port development – the entire species depends on it.

Roberts Bank is a critical stop on the Pacific Flyway. There are few such stopping places for the Western Sandpipers on their long journey from South America, where they have spent the winter, all the way north to Western Alaska. Yet this is where Port Metro Vancouver plans to build a second container terminal. If this port development were to go ahead it will likely damage this critical ecosystem and in particular the unique biofilm on Roberts Bank. It is this biofilm that Western Sandpipers rely on at Roberts Bank as a critical food source during their stopover in their migration north to the breeding grounds.

The Peep-In – which may well become an annual event – sent a clear message to Port Metro Vancouver: We will not allow you to destroy this valuable habitat.

The dependence of so many birds on the critical habitat on Roberts Bank underscores its importance. The mudflats and biofilm on Roberts Bank must be protected as a feeding and roosting site, securing it from disturbance and any further port development.

See Global News Report - Opponents of deltaport expansion meet in Ladner

See Georgia Straight Article -  Anne Murray - Sandpipers Threatened - Port Metro Vancouver

News March 7 2014

An article in the South Delta Leader suggests there is no way of knowing if Terminal 2 would be the final expansion on Roberts Bank - according to Cliff Stewart of Port Metro Vancouver. Does this mean Delta can expect an oil terminal as well, for example? How much more environmental damage are they planning for Roberts Bank?

In the same article Cliff Stewart is quoted as saying "If you go back and look at the environmental assessment of the Third Berth Project you will see T2 as it was understood at that time and you will see the effects of that assessment."

Trouble is the opposite is the case. The cumulative impact assessment of Deltaport Third Berth should have included T2. But Port Metro Vancouver successfully pulled it out of the assessment process, saying that the cumulative effects of T2 were unknown and speculative.

February 2014

Opponents of port expansion at Roberts Bank are pleased the issue is getting some national play.

Green Party Leader Elizabeth May tabled a petition in the House of Commons last week calling on Parliament to stop further port expansion in the Fraser River estuary in Delta. She said the petition comes from more than 1,000 B.C. residents opposed to constructing a massive second container terminal at the mouth of the Fraser.

Read Article

Port Metro Vancouver cited for ‘greenwashing’ in contentious habitat restoration works on Boundary Bay

South Delta residents are planning to rally at Boundary Bay Tuesday morning to protest the start of salt marsh restoration work by Port Metro Vancouver that includes the removal of logs to improve fish habitat.

Residents feel there is no need for the Boundary Bay shoreline to be restored, and are concerned that the port is conducting the work as part of a “habitat banking” program to improve certain areas and offset destruction associated with port development, which could include the planned federal Terminal 2 container expansion project at Roberts Bank.

“This is ‘greenwashing’, just to make them look good in the public eye,”

Read Article

Port Metro Vancouver has put Roberts Bank Terminal 2 back on the agenda. They have got to be stopped as soon as possible. A second container port out on Roberts Bank will severely damage or perhaps even destroy this ecosystem. Join us in voicing opposition as loud as you can.

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Recently received information suggests that Port Metro Vancouver (PMV) will soon formally launch the Roberts Bank Container Terminal 2 (T2) project. Typically in the past PMV waits until a time when they think people will not notice – such as mid summer or over Christmas...

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An open letter to provincial Transportation and Infrastructure Minister Shirley Bond...

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Geography, some historians say, is destiny. If so, Vancouver as a West Coast port may be destined for some leaner times.

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Latest Port Container Volumes and Forecasts show there is no need for Robert's Bank Terminal 2.

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If longtime Richmond councillor and farmland advocate Harold Steves is correct, the municipality of Delta that we know today is as dead as a doornail.

Goodbye Delta as we know (and like) it?

Look to Richmond to see how rampant development hurts

BY BRIAN LEWIS, THE PROVINCE JANUARY 21, 2010

If longtime Richmond councillor and farmland advocate Harold Steves is correct, the municipality of Delta that we know today is as dead as a doornail.

"Delta is on the verge of the very same dramatic changes that have occurred in Richmond," he warns.

Even if only half of what Steves predicts actually happens, the days of Delta being a rare example of reasonably balanced land use are numbered.

To many, Delta is seen as a mini version of Britain, where many people and a modern, thriving economy are supported -yet the wide-open spaces and food-producing farms are also preserved.

This is the delicate balance that Richmond lost through unchecked residential and industrial development that began in the late 1950s and roared through the next two decades like a Klondike gold rush.

In those days, Richmond never met a developer it didn't like.

However, the forces now at work in Delta are slightly different from those that created the gridlocked Richmond we see today.

It is port development at Deltaport and throughout much of the municipality that is pushing the big changes now approaching Delta.

Port Metro Vancouver, the federal agency that has power to override provincial, regional and local zoning as well as the Agricultural Land Reserve, is steadily expanding its influence south of the Fraser River in a quest for its Holy Grail -- expanded container trade with Asia that it believes will double in the next decade.

Others aren't so sure of that and cite offsetting factors such as widening of the Panama Canal and expansion of U.S. ports on the West Coast. Or they point to our own new port at Prince Rupert, which is closer to Asia than the Lower Mainland.

But even if that growth occurs, critics question why the port and our provincial government insist on paving over some of Canada's best farmland to make it happen by building the $1.1-billion South Fraser Perimeter Road that will link Deltaport to Hwy. 1 near Barnston Island.

Both the Fraser River and existing railways could be used to ship most Deltaport containers inland for continental distribution, Steves notes.

Steves says the real issue here involves far more than building a four-lane freeway for container trucks. It's really about converting huge amounts of farmland into industrial property to support the port.

"Already, the industrial-land developers are lining up along the SFPR for the kill," Steves warns. He says numbered companies linked to industrial developers are buying up farmland along the freeway, especially where it's close to the river near Burns Bog or on Barnston Island.

Steves also points to the port's recent purchase of the 92-hectare Gilmore Farm in Richmond, which it plans to use for future expansion. This farm, the SFPR and No. 8 Road in Richmond align with Boundary Road in Burnaby and could accommodate another bridge across the Fraser River.

Finally, as Steves suggests, because so much industrial land near the river is being converted to residential and commercial uses, the port and its land-hungry industrial partners are targeting the only low-cost land that's left -- the farms.

blewis@theprovince.com

As published in The Delta Optimist:

I'd like to thank the premier for taking the time to provide his thoughts and views about the Delta South riding. Sadly, his staff and certain cabinet ministers have misinformed him when it comes to container ports and port expansion. The facts are that once the third berth expansion at Deltaport is complete, B.C. will have sufficient port capacity for at least the next 12 to 15 years, without any further expansion at Lower Mainland ports.

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VANCOUVER — Canada's ports face challenging months ahead as a global slump in shipping and weakening economies cut into traffic coming in and out of cities such as Vancouver, Montreal and Halifax.

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A Letter to Washington State Governer from Point Roberts Based Lifeforce Foundation

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On January 21, 2008, David Emerson (the then Minister for Gateway) released a Strategic Advisors Report on the Asia Pacific Gateway Initiative. Authored by three prominent business leaders who were appointed by Emerson, the report made a number of sensible recommendations concerning Canada’s west coast container ports. Amongst those recommendations: We recommend that policy makers develop container capacity in Prince Rupert before making any investments in Vancouver beyond what have been announced to date.

Port Metro Vancouver is trying to ignore this and is quietly proceeding with its plans for Terminal 2.

Read Article

See what comments and concerns Environment Canada had in 2005 when they reviewed the original Deltaport Third Berth environmental assessment application.

Click here for a reference list (by page number) to locate just some of the very critical concerns raised by Environment Canada.

Port Metro Vancouver are ignoring warning signs that the Deltaport Third Berth Project is already damaging the environment and the fragile ecosystem of Roberts Bank. The first annual Adaptive Management Strategy Report – produced by consultants paid by Port Metro Vancouver – admits that there are elevated nutrient levels in the inter causeway area. The same report also owns up to the fact that third berth construction caused the formation of new drainage channels. Both of these have the potential to result in significant impacts in the inter causeway area. Elevated nutrient levels can result in eutrophication – whereby an algal bloom, reduces dissolved oxygen in the water when dead plant material decomposes and can cause other organisms to die. Environment Canada in its 2005 review of the Deltaport Third Berth Project warned that If it does occur the state of eutrophication is predicted to result in such massive environmental change between the causeways that there would be public outrage as well as agency embarrassment on an international scale.

Read APE's Analysis of the report
Port Metro Vancouver's Adaptive Management Strategy Report

Read up on the upcoming events, summary of this month's news articles and more in this edition of the APE Update.

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A couple of quick things... Click on the following link.

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Gateway air quality promises running on empty. Feds call Gateway Program air quality studies inappropriate and misleading: Study of transit solutions required.

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APE organizers are pleased to announce that, as a result of a donation from one of our supporters, we've been able to appoint an Executive Director – something we had wanted to do but lacked the funds to provide for.

Roger Emsley has agreed to fill that role and has taken up the position as of August 1, 2007.

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Please read the press release for information for and update on VPA's investigation of improper ocean disposal related to the DP3 and BCTC transmission line:

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Two million profit in less than a year for SFPR Properties!

In 2005, land speculators earned $2 million profit in less than a year when the B.C. Government purchased their industrial properties for the South Fraser Perimeter Road. The same profits are not being paid to homeowners whose homes are being expropriated for the road in North Delta and Surrey.

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Just taking a moment to bring you up to speed on APE's activities before summer sets in and your time is taken up with beaches, barbeques, lakeside vacations and all that other fun stuff.

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Rafe Mair has written a great article in The Tyee on the South Fraser Perimeter Road which he describes as a Monster road in Delta which runs over local rights. He slams the environmental assessment process as occurring after the decision was already made.

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A.P.E. members meet with four provincial cabinet ministers in Victoria to discuss concerns about expanding the Deltaport container facility.

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May 23 - Followup Letter to Gordon Campbell

Hundreds of people came out to the STOP Gateway Rally on March 31st to voice their opposition to the provincial government's Gateway Program.

Rally speakers included radio personality Rafe Mair, Delta-Richmond East MP John Cummins, Delta Councillor Vicki Huntington, Adriane Carr of the Green Party, and David Chudnovsky, NDP's Transportation Critic.

More info
Watch Video
Pacific Gateway Strategy Plan

On March 13th, 2007, Delta Mayor Lois Jackson made the following presentation to the Standing Senate Committee on Transport and Communications (TRAN).

Presentation
About the Standing Senate Committee on Transport and Communications

Connecting dots creates picture by Ian Robertson (Delta Optimist, September 2006)

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