Against Port Expansion in the Fraser Estuary BC
APE (Against Port Expansion in the Fraser Estuary BC) is a group of concerned citizens who recognize that plans for container terminal expansion on Roberts Bank (RBT2) will see the loss of globally-significant wetlands and habitat (classified as a Globally Significant Important Bird and Biodiversity Area - IBA) for migratory birds, shorebirds, waterfowl, salmon, herring, crabs and orca whales; degradation of the quality of life for thousands of Lower Mainland residents; and the industrialization of prime agricultural land.
RBT2 Public Hearing - Get Involved
If you wish to participate you can send in a written submission and/or make an oral presentation during one of the public hearing sessions. However you must register.
- Please do not register as a member of APE, because APE will register separately. So please register as a member of the public or of the group that you represent. Also note it appears that they are trying to group members of a group together.
- Here is some suggested wording for Q9
- I LIVE IN DELTA AND OR I USE THE BRUNSWICK POINT DYKE REGULARLY. THE ADDITION OF TERMINAL 2 WILL NEGATIVELY IMPACT ME, THE WETLAND HABITAT, THE WILDLIFE ATTRIBUTES OF THE AREA AND THE LIVABILITY OF THE REGION.
- Here also is some suggested wording for Q10 - What will you present
1. ENVIRONMENTAL AND OTHER IMPACTS AND CONCERNS THAT ARE IMPORTANT TO ME
2. IMPACTS TO MIGRATORY BIRDS AND SHOREBIRDS AND POTENTIAL HARM TO THE PACIFIC FLYWAY
3 IMPACTS FOR SALMON AND ORCAS
4. COMMUNITY IMPACTS AND LIVABILITY OF THE REGION
5. ALTERNATIVES THAT SHOULD BE CONSIDERED
These are ideas only, feel free to use or amend as you wish.
Flawed Rationale for RBT2
1. RBT2 Rationale is Heavily Flawed
The underlying problem with the RBT2 environmental assessment is the myth that the environment, the economy and communities need to be in balance. This is the so-called sustainability factor.
The way that the CEAA Panel is carrying out the review is compounding the problem. The Panel appears to believe that all it needs to do is to review the purpose of the project and not the need. Furthermore the Panel appears to believe that its review must focus solely on Roberts Bank, without looking for better more cost effective alternatives elsewhere (Prince Rupert). This approach is inexorably flawed.
By using this flawed approach the Panel is failing to ask the following key questions:
1. Is there a risk of environmental degradation if RBT2 is built?
YES. End of story for a new port on Roberts Bank.
2. Does Canada need to increase container capacity for its trading needs?
3. Since Roberts Bank is no longer in the picture where else is port expansion possible? Prince Rupert, primarily, and also expanding other existing container terminals.
4. What else should Canada be doing to further its container trade objectives? Limit and start to reduce the transhipment of US container traffic through West Coast Canada ports. This US traffic adds little or nothing to Canada’s economy.
5. Are communities impacted by container ports and the resultant road and rail traffic? YES. Light pollution, air pollution, noise pollution, traffic congestion, rail accidents.
It is not in Canada’s national interest to build a container terminal whose capacity is not needed and whose environmental and community damage will be significant.
2. RBT2 Assessment Update
Vancouver Fraser Port Authority (VFPA) has rushed to get all its responses into the Review Panel of the Canadian Environmental Assessment Agency, so as to be ready for an expected Public Hearing that may come in a few months, (April?).
The Panel received a mass of additional information from the VFPA and requested public comments on the sufficiency of this information. This comment period closed on February 8 2019. Submissions from the public, First Nations and regulatory authorities are very critical and identify many areas where VFPA has failed to provide sufficient information. A number of public comments have shown that VFPA has provided incorrect information and misleading information. Equally VFPA has dodged certain areas such that some important information is missing altogether. Will the Panel recognize that much more information is needed, or will political considerations take precedence such that they proceed to a public hearing anyway?
3. Environmental Issues
Roberts Bank is Canada’s major stopover on the Pacific Flyway, with millions of migrating birds travelling over 3 continents, including 20 countries. The estuary and surrounding watershed supports Canada’s largest populations of wintering waterfowl, shorebirds and birds of prey with global and local recognition:
- Designated by BirdLife International as an Important Bird Area (IBA). It is the most significant IBA out of 597 sites in Canada.
- Highest designation by the Western Hemisphere Shorebird Reserve Network (WHSRN) as a Hemispheric WHSRN Site.
- Declared a Provincial Wildlife Management Area (WMA) and recognized to have the highest concentration and bird diversity anywhere in Canada
- Declared as a UN Ramsar site by the International Convention on Wetlands. Shockingly Canada would not include Roberts Bank in the RAMSAR site even though the fresh water/salt water blending area is key to the rich ecosystems.
The Project will harm the fragile estuary with habitat loss and destruction, as well as noise, light, water, and air pollution. The losses cannot be effectively mitigated.
A central issue is that of biofilm, a food source vital to western sandpipers, VFPA claims “...the Project is not predicted to result in significant adverse effects on biofilm or affect the availability or quality of food available to northward migrating WESA”. This comes from captive consultants paid for by VFPA. This totally ignores the concerns of independent experts and importantly submissions to the Panel from Environment and Climate Change Canada that identify impacts to the Roberts Bank wetlands and wildlife as severe, immediate, irreversible and immitigable.
The widened causeway required for RBT2 will cover over a significant area of biofilm.
RBT2 is also a serious issue for juvenile salmon. The juveniles hide in the eelgrass and shallows of Roberts Bank as they transition from river to ocean. Juvenile salmon need the shallows and are repeatedly pushed into deep water by all the causeways and training walls in the delta. By building this huge - 460 acres - RBT2 pod and expanded causeway, and because there are no culverts in the port causeway, the salmon are forced to swim around these obstacles and are more exposed to predators and other dangers. Chinook salmon are already in decline and are a critical food source for the endangered Southern Resident Killer Whales (SRKW). VFPA has been asked repeatedly to install culverts in the Deltaport causeway and have refused to do so citing cost and feasibility – both false. With the RBT2 widened causeway installing culverts gets even more expensive.
Increased vessel traffic through the Salish Sea is already a concern for the endangered SRKW. The vessel noise, possibilities of collision are all contributing factors to a decline in the SRKW population. The Salish Sea cannot take any more vessel traffic.
4. No Business Case
VFPA has never produced a business case. Many times they have been asked, but never have they produced a document that any normal business entity would rely on to justify a project of this magnitude. Instead they keep repeating the myth of a coming “container crunch”. These are taxpayer assets and funds being invested in a multi-billion dollar project with no indication of the expected return on investment. If this were anything other than a government agency there would have been a proper business case identifying the capital investment, gross and net revenues, return on investment, plus a full risk analysis.
VFPA is promoting the myth of a ‘container crunch’ in the near future, i.e. not enough capacity in Western Canada for all the expected container traffic. VFPA has a full-blown PR campaign to mislead government, stakeholders and the public. Numerous articles to this effect are in the media and on the Port website, claiming incorrectly that the west coast will run out of container space by the mid 2020s. THERE IS NO CAPACITY CRUNCH ON CANADA’S WEST COAST. THERE IS PLENTY OF CAPACITY NOW AND MUCH MORE COMING ON STREAM.
VFPA consistently underperforms against its forecast increases in container traffic. It has missed every one of its last five forecasts and its cumulative annual compound growth rate languishes at 3 percent. Prince Rupert’s container volumes have doubled in the last five years, with its volumes increasing 12 percent in 2018 alone.
With expansions under way or in place at two of Vancouver’s existing container terminals and a third one expected to start soon, plus ongoing expansion at Prince Rupert, there is no shortage of container capacity. In fact Prince Rupert has the potential to grow to as much as 4 – 5 million containers (TEUs) if the market requires it.
Prince Rupert has seen its container volumes grow by double digits whereas Vancouver languishes in the three percent range. Prince Rupert is two sailing days closer to Asia, has faster, less congested and easier rail access to the east and has very few environmental issues when compared to Vancouver.
RBT2, if built, would be the most expensive container terminal project anywhere in the world. Expansion at Prince Rupert can add container capacity equivalent to RBT2 for half the cost.
Rail traffic in and out of Vancouver is a big issue. The rail route east through the Rockies is heavily congested. Grain and potash shippers are complaining that their products are being delayed. More oil is being moved by rail. Too many accidents on this route have already occurred. Likewise Port trains have been involved in recent tragic accidents at grade level crossings in the Lower Mainland. This southern route simply cannot handle the huge increases in containers were RBT2 to be built.
Presently VFPA in total handles 3.4 Million containers (TEU) per annum, + 1.0 Million for Prince Rupert, total West Coast 4.4 Million TEU. If total West Coast Canada container traffic expands by 3- 4 % per annum, (generous in view of past history), it will grow to 8.2 Million by 2040, still far less than future capacity of 10 – 11 million if the total build out is required. AND ALL THIS WITHOUT RBT2.
Furthermore as much as 25 percent of containers handled are US origin or destined, bringing little or no economic advantage. US traffic can be re-routed via US ports.
5. Community Issues
VFPA, with its desires to build RBT2, ignores real community issues.
- Traffic congestion caused by port container trucks is significant, especially in the morning and evening rush hours. The lower mainland road system cannot handle huge increases in port road traffic.
- Rail traffic through the lower mainland is an issue. Community roads are blocked many times a day with trains crossing at grade level. There have been three recent road/rail accidents in recent weeks with fatalities.
- Light pollution is an issue. RBT2 will add light intensity to an area that already suffers from light pollution.
- Air pollution is an issue, with port trucks and trains dumping increased levels of harmful emissions into urban and rural areas.
- Anchorages for vessels waiting for harbour space has become a significant issue in the Gulf Islands.
6. Why is RBT2 a non-starter?
- The public is opposed;
- Aboriginal groups are opposed;
- Existing terminal operators are opposed;
- Project benefits are overstated; no cost benefit analysis;
- The port of Prince Rupert is better placed for Canada’s container terminal expansion and to satisfy Canada’s trading needs;
- Prince Rupert and Vancouver area ports will have plenty of capacity out to 2040 and beyond;
- RBT2 environmental impacts are significant, immediate, permanent and not able to be mitigated;
- Community impacts – traffic congestion, light, noise and air pollution - are significant.
- Cumulative effects are being ignored;
7. Bottom line - RBT2 is neither needed nor justified.
RBT2 Terms of Reference - said to be unlawful
Lawyers working on behalf of the T’Sou-ke Nation have now put in a submission, just posted to the CEAA registry (#1334), that basically says the action taken by the Minister of Environment, in limiting the terms of reference, was unlawful.
Two paragraphs in the submission sum it up:
"The effect of the unlawful exclusion is even larger in this case. Project-related marine shipping activities are likely to cause significant adverse environmental effects on southern resident killer whales in this EA as well, and there are no proposed measures to mitigate such effects. However, due to the unlawful exclusion, the Minister will not be required to consider and make that conclusion under s. 52(1) of CEAA 2012 (or to refer the Project to the Governor in Council pursuant to s. 52(2)). The net effect is that the Governor in Council will not be required to consider whether the significant adverse environmental effects that Project-related marine shipping activities are likely to visit upon southern resident killer whales can be justified in the circumstances."
"All of these considerations unequivocally establish that marine shipping is inextricably and fundamentally important to the Project. Indeed, it should go without saying that a marine terminal has no purpose outside of the context of facilitating marine shipping. Especially in light of the direction provided by the Court in Tsleil-Waututh, the inescapable legal and factual conclusion is that marine shipping is “incidental to” the marine terminal and therefore forms an integral part of the designated project to be assessed."
No Economic Reasons for Roberts Bank Container Terminal 2 (RBT2)
No Economic Reasons for Roberts Bank Container Terminal 2 (RBT2)
There is no economic justification for the Roberts Bank Terminal 2 Project (RBT2) which will destroy globally-significant Fraser River estuary habitats that support migrating salmon, resident orcas and millions of migratory birds at Canada’s crucial stopover of the Pacific Flyway.
The Vancouver Fraser Port Authority (VFPA), known as the Port of Vancouver, is strongly lobbying the Government of Canada to let them dredge and fill 445 acres of waterlot in the estuary for an island and expanded causeway to double container capacity with 3 new berths. The stated reasons and purpose of Terminal 2 are not supported with evidence of accurate forecasts, capacity and demand.
Currently, a federal Review Panel is examining the Environmental Impact Statement (EIS) for the Project. The economic information in the EIS is incorrect and misleading as VFPA business forecasts are not being realized and B.C. ports are already expanding capacity to handle container traffic demand.
The container business is reported in TEUS, “twenty-foot equivalent units”, which means each unit is equivalent to one twenty-foot container.
Unfortunately skewed statistics are being presented to the federal government in the EIS and in a 2017 Transport Canada Report. They are ignoring a report from three transportation experts advising:
“…policy makers develop container capacity in Prince Rupert before making investments in Vancouver”…and further that: “…a systematic approach be taken to achieve an understanding of port capacity before a conclusion is reached that a particular port must necessarily be larger.”
In 2016, the Port of Vancouver secretly submitted an information brief on the RBT2 Project to Canada’s Members of Parliament in an attempt to bypass due process,“Welcome to our first newsletter, written exclusively for a government audience.”
Documented statistics and information can be found in a submission to the Review Panel by the Boundary Bay Conservation Committee.