Against Port Expansion in the Fraser Estuary BC

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