Against Port Expansion in the Fraser Estuary BC

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 the BC Government'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. This environmentally disastrous, unnecessary and uneconomic project can still be stopped. Read the letter to find out what you can do to stop the Fraser Estuary from breaching its environmental tipping point.

Read the full letter here:

Governments_Have_Betrayed_The_Environmental_Values_of_the_Fraser_Estuary_APE_Website.pdf

West Coast BC, specifically the environmentally significant Roberts Bank ecosystem in the City of Delta is going to become a major industrial port complex.

My research and analysis of recently published material, including MOUs, plus discussions with interested parties leads me to conclude Roberts Bank Terminal 2 is going to get built, with project start likely in early 2028.

The federal and provincial governments are willing to sign the death certificate for the Roberts Bank ecosystem so Roberts Bank, BC’s most important wildlife management area, can get another huge container terminal even though:

ü  The market doesn’t need more capacity (container traffic is flat, the BC west coast has plenty of spare terminal capacity for years to come)

ü  The ecosystem cannot handle it resulting in significant adverse environmental effects that will be immediate, continuous, permanent irreversible and immitigable (Federal Government Scientists)

ü  It provides critical wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada

ü  It is a major stop on the Pacific flyway for migratory birds, especially the Western Sandpiper that will be compromised resulting in significant population declines with the potential to lead to species extinction.

ü  The already endangered Southern Resident Killer Whales will have more difficulty in their feeding and breeding grounds adjacent to the port complex

And on top of all that degradation Roberts Bank has been designated as the tidewater terminal for an Alberta Oil pipeline.

The recently announced provincial and federal strategy, that is the shaky foundation for all of this, is political. Overall it makes no strategic common sense.

Despite that I anticipate the Major Projects Office will soon declare RBT2 a nation-building project. Its final federal approvals, including the Fisheries Act authorization will be rushed through. Significant environmental issues and concerns will be brushed aside. The federal government is likely to either ignore or fudge the 370 federal conditions attached to RBT2, including the all-important condition 10.4 – whose aim is to protect the biofilm critical to migratory birds. The federally appointed Scientific Advisory Group will be sidelined.

Terramarine Consortium (Flatiron, Dragados, Van Oord, Aecon and Carlson Construction) has been awarded the build component. Global Container Terminals will be the terminal operator.

The central issue is Canada’s trading needs and how best to meet them, not whether Canada should be expanding its oil production and export capabilities, along with LNG and other natural resources. That horse left the barn a long time ago. Couple that with the fact that despite the Port of Vancouver’s appallingly poor container port performance record (it sits near last in the 2025 Container Port Performance Index), and its failure to live up to its own projected volume increases, Vancouver is going to get another container terminal in the wrong place, at a huge cost and years before additional container terminal capacity is needed, plus now also an Alberta oil terminal.

The Federal/ Provincial MOU and $10 billion plus in federal funding

Let us look at what this really is – a crazy $10 billion investment, rife with politics and expediency. And it is a lot more than that. The Alberta pipeline estimated cost ranges from $35 billion to $44 billion (Remember TMX overran its estimate by $billions). Of that $35 billion, Ottawa (you the taxpayer) are providing 50%, Alberta 40%, and private (Pembina) 10%. 

That $10 billion investment (and it will likely cost all of that and more), to pay for Roberts Bank Terminal 2 (RBT2), makes it the highest cost terminal per container anywhere in the world and a project that will be a permanent money loser, whose terminal capacity can be provided at half the cost at an alternative geographical location, better able to deliver increased container terminal capacity when it is needed, with far better and faster access to major markets. 

Half way through 2026 West Coast Canada has plenty of spare container terminal capacity. The Port of Vancouver’s container volumes remain flat. It has lost nearly all of the US container traffic that it used to handle. In 2025 it handled 3.8 mill. Containers versus the 3.4 mill it handled in 2018, seven years ago. Its ten-year Compound Annual Growth Rate hovers at as mere 2.15%. Despite all that Vancouver will get another container terminal and the federal government will pay for it. Not only that but there are non-government investors ready to build that terminal capacity elsewhere, yet not one investor has so far been willing to pour money into RBT2. 

And then on top of that, Carney and Eby are ready to sacrifice, essentially writing off, an ecosystem that is the most important wildlife area on the B.C. West Coast, rich in biodiversity and providing critical wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada, not to mention that the area is vital feeding and breeding grounds for the already endangered Southern Resident Killer Whales as well as the Fraser River juvenile salmon, Dungeness crabs and other wildlife that has nowhere else to go. 

Then to cap it all, Carney and Eby, with assistance from Smith, plan to make Roberts Bank home to tidewater for Alberta’s pipeline, which will need back up lands for oil storage tanks and other infrastructure when the land to support that simply doesn’t exist. And just like RBT2 not one private investor is interested. These are bad investment decisions, worse than any other government misstep in a long time, replete with political expediency and a false consensus.

The issue is and always has been the environmental and economic balance - how to achieve the best result economically with the least disruption and degradation to the environment and key ecosystems.  Regrettably that is a discussion that neither the federal nor provincial governments are interested in having. And when you read about this year’s wildfires in the Fraser Canyon, think about what that does to the movement of goods by road and rail (75 percent of what the Port of Vancouver handles). It is not just the Fraser Canyon. The rail route over the Rockies has to handle some of the steepest ascents and descents, significantly worse that the Northern rail route East out of Prince Rupert.

Pipeline to Tidewater 

As for the pipeline, from a pure economic strategy, a majority of experts favour the pipeline going to tidewater in the north. Why? Because deep-water terminals in the north and their deep and wide shipping channels can easily handle ultra-large crude carriers and offer significantly shorter sailing distances (1-2 days) to Asian markets as well as providing a much needed economic and jobs boost to Northern communities. Furthermore harbour navigation and pilotage is drastically different in Prince Rupert vs Vancouver.  Prince Rupert’s harbour entrance is exceptionally wide with a deep-water depth of 35 metres. Oil tankers require only two hours of pilot navigation to reach open waters. Contrast that with Vancouver where navigation in and out of harbour has to contend with congested waterways, shallow channels and speed restrictions. The pilotage time for Vancouver is more than twice that of Prince Rupert.

The myth of an oil tanker ban in the North should have been exploded a long time ago. Large container ships ply that very route, safely, in and out of Prince Rupert everyday. Not true, for the route to the Pacific via the Salish Sea and Juan de Fuca, where there have been several accidents, the most serious being the MV Kingston that dumped hundreds of containers over the side, caught fire and deployed its garbage along the shores of Vancouver Island.

The route to the Pacific via Salish Sea and Juan de Fuca Strait is already heavily congested. Over 8,000 large commercial vessels transit each year. That volume is about to grow significantly - two LNG terminals, more TMX oil traffic, significant increase in container traffic from RBT2, more cruise ships. In terms of oil alone, the new Alberta pipeline will deliver one million barrels of oil a day. TMX, once fully expanded and optimized, has the capability to deliver another 1.2 million barrels of oil a day.

So, in total, the Port of Vancouver may expect in the future to export 2.2 million barrels of oil a day. How much more traffic can this congested waterway handle? Can the Southern Resident Killer Whales survive this onslaught?

The ultimate irony is that oil tankers sail through the exact same Northern waters anyway – Alaskan oil moving south to Washington State. Analysts maintain modern oil tankers have an excellent safety record and the ban is nothing more than an unscientific political blockade This has nothing to do with what is the safest - it is all about political expediency. The reasons for a tidewater terminal in the south - politically realistic and expedient, are to appease Eby, and prevent First Nations causing more problems over mineral extraction, generally bowing to First Nations who have beneficial participation agreements with VFPA and are looking forward to an ongoing revenue stream from RBT2 and whatever else gets built. There is nothing wrong in principal with beneficial participation agreements, but they must be balanced against the cost of environmental degradation – how much environmental capital is being expended and what is the impact on wildlife species, population declines, the possibility of species extinction, when that wildlife has nowhere else to go?

Then there is the talk of social license. Whose exactly? There is a key phrase running through all of this - Beneficial Participation Agreements. This applies to each and every one of these projects. Who wins is clear. The losers? The environment, wildlife species, taxpayers and South Delta residents.

What continues to surprise me is the minimal ruckus and ripples from NGOs, environmental groups and the general public. Have they given up, realizing that nothing they say or do will stop the environmental degradation and wildlife loss? It is significant that Guilbault resigned from the federal government over this whole issue and still there was minimal reaction.

Putting all of this together, South Delta, Roberts Bank and the surrounding lands will develop into an industrial behemoth. Drive south from Vancouver into Washington State if you want to see what South Delta will look like when these projects are built. Take a run down to and through Anacortes. Talk to Ferndale residents as to how they feel about Cherry Point. Take a look at the massive tank farms. Those Washington State oil terminals handle just over 600,000 barrels of oil a day. Roberts Bank, when in full production, will handle 50 percent more than that. Just imagine what South Delta’s tank farms and related infrastructure will look like, together with a massive container terminal complex as well as a coal terminal.

The Roberts Bank BC Wildlife Management Area and its rich biodiversity as well as the wildlife it supports that has nowhere else to go will not survive this onslaught. The landslide agriculture and liveability of South Delta will be changed forever and not for the better.

This nation building investment makes no strategic common sense.

Should the Carney government have any inclination to fund the Roberts Bank Terminal 2 project, either from the Infrastructure funding in the Nov. 4 budget or through one of the federal agencies or bodies that funds projects, it must understand one fundamental. RBT2 is not economically viable. The federal government must never agree to fund any portion of it.  

It is not a “nation building” project, it should never have weaselled its way onto the major projects list. It has been mired in controversy for years and condemned on environmental grounds by major national and international entities concerned about environmental damage and the potential for wildlife species declines towards extinction. Over and above that it is an economically unviable project and a huge pit into which to pour funds, without any prospect of ever getting a reasonable return on investment.

Consider these facts:

1.  The Vancouver Fraser Port Authority (VFPA) has never updated its years old project cost estimate of $3.5 billion. Given the increases in labour and material costs, engineering estimates now suggest it will take another $ 5 billion or more. That is today’s dollars. Construction will not start for another three years at least. By that time RBT2 will likely cost in excess of $10 billion, making it the most expensive Greenfield container terminal ever built and with the highest cost per container to operate.
2. VFPA container volumes are stagnant. This is not a healthy expanding operation. The information on its website is incorrect. It handled 3.4 million containers (TEUs) in 2024, the same as it handled four years earlier in 2020. VFPA has consistently under performed against its container forecasts. It fudges its performance metrics in its press releases and on its website: “Strong historical container trade growth at the Port of Vancouver with a compound annual growth rate of 4% between 2000 to 2024” says the Port’s website. Total annual container volumes (TEUs) from its own website - 2020 3,467,521; 2021 3,678,952; 2022 3,557,294; 2023 3,126,599; 2024 3,473,822. That is most certainly not a 4% CAGR. Its actual compound annual growth rate is less that 3 percent measured over the last fifteen years. The 4 year actual CAGR 2020 to 2024 is 0.5% The numbers show its volumes in 2024 were up only slightly compared to 2020. It handled a measly 2 percent more containers in 2024 than it did in 2019 and 2018 - six years ago.
3. Close to 50 percent of containers it handles are empty. It handled fewer laden containers - i.e. actual goods inside - in 2024 than it did all the way back to 2017
4. It has one of the worst port performance records for container terminals. VFPA container terminals rank at 347 out of 348 ports in terms of efficiency. This is not a well run efficient operation worth investing $10 billion or more of government funds.
5. There is plenty of spare container terminal capacity on the West Coast - in excess of 2 million TEUs. Canada’s trading needs are well covered and more container capacity will not be needed for years to come. When more is needed Roberts Bank is the worst place to add it. The environment cannot handle it; shipping lanes are already congested; the Fraser Canyon cannot handle additional container trains; lower mainland highways are congested with port truck traffic; RBT2 adds even more vessel traffic to Juan de Fuca Strait and the Salish Sea, already over burdened with new Trans Mountain and LNG vessel traffic. 
6. Government scientists have repeatedly stated that building RBT2 will cause significant adverse environmental effects to the Roberts Bank ecosystem that will be immediate, continuous, permanent, irreversible and unable to be mitigated. These adverse effects will cause harm to southern resident killer whales, migratory and other shorebirds, fish and fish habitat, crab populations, and may lead to species extinction.
7. In a July 12, 2023, open letter based on UBCIC Resolution 2023-37, the Union of British Columbia Indian Chiefs (UBCIC) expressed strong opposition to the Roberts Bank Terminal 2 (RBT2) project, citing insufficient consultation, irreversible environmental damage, unaddressed cumulative effects, and violations of Indigenous Title and Rights. The letter urged federal and provincial governments to immediately pause development. There are other court cases trying to stop RBT2.
8. VFPA continues to ignore the science, claiming that the negative environmental effects will be benign and habitat can be replaced, without any proof to support this contention and in direct conflict with scientists' findings based on proven research published in peer reviewed journals.

Canadian taxpayers do not want to pay for another Mirabel. Why would Canadian taxpayers be on the hook to pay for some or all of the Roberts Bank Terminal 2 project costs,  when other companies are prepared to fund container terminal expansions at much lower build costs without government funding? Even setting aside the “significant adverse environmental effects” that the Governor in Council recognized back in 2023, the return on investment is not there. This project is not viable economically so why would Canadians want to fund it?

• Do not fund RBT2 from monies allocated in the November 4 budget, 
• Do not fund all or any part of its development costs
• Do not give it priority in the second tranche of major, "nation-building" projects to be fast tracked. 

Rather do what the federal government should have done already - tell the Vancouver Fraser Port Authority to stop RBT2 and instead collaborate with existing container terminal operators to plan and expand container terminal capacity when Canada’s trading needs require it and to do so with minimal negative environmental effects.

Roberts Bank Terminal 2 is in nobody's best interest.

Who would be crazy enough to respond to the Vancouver Fraser Port Authority's request for qualifications to build a huge man made island on Roberts Bank - one of Western North America's most important ecosystems?

https://www.infrastructurebc.com/project/roberts-bank-terminal-2-landmass-and-wharf-project/

Do these companies not realize that Roberts Bank Terminal 2 is neither an environmentally nor economically sound proposition. This is not a project that the Canadian government will want to wear when it becomes an environmental and economic disaster and an international embarrassment to Canada.Canada does not need  another Mirabel

Do those companies not realize that they will be contribuiting to the environmental degradation of a BC Wildlife Management area that "... provides critical wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada, including at times up to eight per cent of the entire North American population of Dunlins, four per cent of its Trumpeter Swans, and three per cent of its Black Bellied Plovers. American Wigeon, Northern Pintail, Mallards, Green-winged Teal, Wrangel Island Snow Geese, and Black Brant can often be seen in the thousands. In addition to shorebirds and waterfowl, Great Blue Herons, Barn Owls, Short-eared Owls, Virginia Rails, American Bitterns, Soras, Northern Harriers, Bald Eagles, Red Tailed Hawks and Peregrine Falcons are found here".

Do those companies not know that they will come under scrutiny by numerous Canadian and International environmental groups?

Do they not realize that building this project is in no ones best interest?

Here is why:

1. Not in Canada’s trading best interest.

Vancouver does not need another container terminal. It currently has four container terminals, two in the inner harbour, one on Roberts Bank in the Fraser River Estuary and one up river in Surrey. In 2024 the VFPA handled 3.47 million containers TEUs - Twenty foot equivalent units). VFPA container shipment volumes are stagnating. Volumes in 2024 are about the same as 2019, having increased by a measly 2 percent in five years.

Several of these container terminals have significant spare capacity. Port operators indicate that Vancouver has in the order of 2 million spare container capacity. Yet Vancouver is plagued by delays. 75 percent or more of Vancouver’s volumes come from or go to Midwest and eastern Canada and US markets. Vancouver handles a significant number of US containers - which adds nothing to Canada’s economy. Container import volumes headed to eastern markets and exports from those markets travel by rail through the Fraser Canyon. That rail route is heavily congested with difficult gradients through the Rockies. Adding additional container volumes from Roberts Bank Terminal 2 will make the congestion even worse.

2. Not in the Salish Sea’s best interest

The Juan de Fuca Strait and the Georgia Strait are very congested waterways. And they are going to get more so with LNG from Tilbury and elsewhere, Trans Mountain pipeline, vessel traffic as well as more cruise ship traffic. Juan de Fuca also serves vessel traffic to and from US terminals and this traffic is growing as well. Adding more ships to and from RBT2 will make the Salish Sea even more congested and more dangerous. There have been recent accidents - recall the MV Kingston for example.

3. Not in the Southern Resident Killer Whales best interest

The three SRKW pods are an endangered species at serious risk. The Haro Strait is their prime feeding ground and yet it is also a major route for vessel traffic. Vessel noise negatively impacts their communication and feeding. Vessel strikes are always a possibility with container vessels traveling at 11 knots.

4. Not in the Roberts Bank ecosystem’s best interest

Roberts Bank is a very important ecosystem for a myriad of species. The Roberts Bank biofilm is unique in its quality, quantity and physical presence. The Roberts Bank Wildlife Management area is recognized as “providing critical wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada"

Building RBT2 threatens these waterfowl and shorebirds and none more so than the biofilm that is critical to the survival of the Western Sandpiper population, Canadian Federal Government scientists have said repeatedly that building RBT2 will result in “significant adverse environmental effects which will be immediate, permanent, irreversible, continuous and cannot be mitigated”

5. Not in Delta’s nor the Lower Mainland’s best interest

Port semi trailer traffic, both those empty as well as loaded with containers, are a plague for the areas highways. Highway 17 and 99, in particular, are heavily congested with port semi trailers running to and from the existing Deltaport container terminal. Adding RBT2 will result in even more noise and air pollution from this truck traffic as well as causing even more traffic congestion.

6. Not in the current four berth Deltaport Container Terminal’s best interest.

The Deltaport operator has said that adding RBT2 with its separate inter-model rail yard will reduce the productivity of the existing Deltaport. Vancouver is already known as a laggard for its poor productivity. RBT2 will make it even worse.

7. Not in the best interest for Industrial Land

There are numerous mountains of stored containers all over Vancouver and the Lower Mainland. These stored containers remove valuable industrial land from the already scarce supply. RBT2 will add to that problem.

8. Not in Canada’s economic best interest

RBT2 is now estimated to cost $10 billion or more to build. It was already recognized as the most expensive Greenfield port development anywhere in the world. Where is that $10 billion going to come from? Certainly not from federal government coffers. Why would the federal government, already debt ridden, sanction this kind of uneconomic development when there are other more viable and less environmentally destructive alternatives? 

A message to Prime Minister Carney and the Canadian Government:
Since RBT2 is in no-ones best interest why is your government continuing to support it? Who - which interested parties - are lobbying for RBT2 to be built?

Prime Minister Carney - you must know that there is no need for more west coast container terminal capacity for years to come. And you must also know that when more is required it can be developed in Prince Rupert, where there is a port operator ready to expand that terminal and has the space to do so at less than half the cost. Prince Rupert offers a terminal that is two sailing days closer to Asia, an entry into port that has none of the congestion or risks of the Juan de Fuca and Georgia Strait and a rail route to the East that is not congested, has better grades then the southern rail route over the Rockies and is faster for container shipments to the East and from the East back to Prince Rupert.

The logical, the only realistic option that is best for Canada’s trading needs, most economic and most environmentally responsible is to expand container terminals capacity in Prince Rupert. 

The Boundary Bay Conservation Committee recently prepared and published a paper on Roberts Bank Terminal 2. Read it here:

Canada_failing_to_protect_Fraser_River_Estuary.pdf

As the paper suggests The Canadian Government is ignoring scientific evidence from government and independent experts. The Governments of Canada and British Columbia approved RBT2 based, not on science, but on “justification” for the public good. There is neither economic nor environmental justification.

As a result No one is protecting this globally-important, unique estuary.

Environmental groups challenged the approval in court.  In January, 2025, the Federal Court ruled in support of the approval stating government agencies will ensure protection through the process of conditions and permits.  These agencies do not have the funding, time, legal authority, or expertise to ensure the protection of the interactive, interdependent processes that create unique, healthy estuarine ecosystems.  Such expertise doesn’t exist.  Follow-up investigations of projects show that government agencies provide patchwork, rubber-stamp approvals with negligible enforcement. 

Furthermore there is no business case for building an island for containers in the Fraser estuary.

With the current and projected volume increases for West Coast container traffic current container terminal capacities in Vancouver and Prince Rupert are sufficient for Canada's trade requirements for many years to come. And when more capacity is required Prince Rupert has the space and capacity to add as many as 5 million TEUs, at half the cost without the environmental degradation that RBT2 will deliver.

The stated cost of RBT2 at $3.5 billion was unrealistic five years ago; an updated and more realistic cost is likely in excess of $6 billion, making it simply not economically feasible.  How ironic that public assets and tax dollars will be required to support this uneconomic Project that is not needed and that will cause irreparable damage in the globally-significant Fraser River Estuary.  

The Vancouver Fraser Port Authority still needs a Fisheries Act Authorization to proceed. They must not get it. Wildlife species including Western Sandpipers, Salmon stocks and Southern Resident Killer Whales will not survive and will go extinct if RBT2 is built.

Tell the Department of Fisheries not to approve Roberts Bank Terminal 2, because doing so violates the Species At Risk Legislation and will result in wildlife population declines to the point of potential species extinction.

Write to DFO.Minister-Ministre.MPO@dfo-mpo.gc.ca