Against Port Expansion in the Fraser Estuary BC

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.

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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.

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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.