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.