Against Port Expansion in the Fraser Estuary BC

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