Public service announcement, received from Susan Jones.

Please Act by June 8^th for Roberts Bank, Fraser River Estuary

A Notice from the B.C. Environmental Assessment Office (EAO) is asking for public comments on the Roberts Bank Terminal 2 Project (RBT2).

The federal government approved the RBT2 Project on April 20, 2023.  The environmental assessment was a harmonized process meaning the environmental assessment by the federal government also served as a B.C. assessment.  Under a signed substitution agreement, the B.C. Government agreed to one assessment.  However, the assessment requires approval by both the federal government and B.C.

B.C. has not yet approved the assessment and is asking for public input on provincial materials summarizing the assessment and commenting on implications for BC assessment requirements.

Please submit comments even though Premier Eby has recently publicly stated support for RBT2.  This is definitely inappropriate, discouraging, and disturbing.

DATE
Please send in your comments to the provincial government by Thursday, June 8, 2023

SEND TO
The BC EAO online where you can comment directly or attach a prepared submission. Go to the following link and click on Submit Comment. EPIC (gov.bc.ca)

The Notice does not provide an email address, but if you have trouble online, you could probably send an email to the BC EAO Office: Tracey Janes, Project Lead, Roberts Bank Terminal 2: tracey.janes@gov.bc.ca

INFORMATION
LINK: EPIC (gov.bc.ca)  If you scroll down the page, the BC EAO has asterisks beside 3 documents for public comment.

Send in your opinion and your comments.

Possible Points:
Provincial interests are not fully addressed in the B.C. Draft Summary Assessment Report:

1.   The B.C. Report claims satisfaction that adverse effects related to provincial jurisdiction have been adequately addressed.  However, the Report fails to disclose that major factors of provincial responsibility were not assessed:

a)       subtidal wetlands
b)      cumulative effects on wetlands
c)       cumulative effects on the estuary and Salish Sea
d)      accountability to the B.C. Wildlife Management Area
e)       importance of biofilm to the health of the Fraser River Estuary
f)        17 bird species listed on the Species at Risk Act or by the Committee of Endangered Wildlife in Canada (COSEWIC)
g)      cumulative effects assessment of all shorebirds (only 2 species of 50 were assessed)
h)      level of public concern
i)         accountability to designations; agreements; policies; and legislation

Other major factors were not sufficiently assessed:
a)       serious threats to human health from pollution affecting the lower mainland and the Salish sea
b)      light and noise pollution that cannot be mitigated
c)       loss of fish and fish habitat
d)      effects on endangered chinook salmon and endangered southern resident killer whales
e)       ‘threatened White Sturgeon’
f)        ‘threatened Barn Owl’
g)      loss of agricultural land

2. The B.C. Draft Summary Assessment Report fails to flag the fact that the environmental assessment fails to provide scientifically proven, identifiable mitigation measures

The B.C. Report states practical means have been identified to reduce any potential adverse effects of RBT2 to provincial jurisdiction. 

Practical means are supposed to represent mitigation to address the harm RBT2 will cause to the ecosystems of the estuary and Salish Sea.  No credible, identifiable, scientifically-proven measures have been provided in the environmental assessment even though the Canadian Environmental Assessment Act (CEAA 2012) clearly states that an environmental assessment must include: “19(1)(d) mitigation measures that are technically and economically feasible and that would mitigate any significant adverse environmental effects of the designated project.”

The mitigation measures in the federal and provincial reports call for plans, consultations, monitoring and adaptive measures.  These are tools, not mitigation.

3. RBT2 will cause unmitigable, irreversible, permanent residual effects on wetlands.  Both the B.C. and federal assessment agencies have failed to flag the failure of RBT2 to protect wetlands which include listed species.

Federal and B.C. Government scientists documented concerns of serious, unmitigable effects on wetlands. They advised RBT2 will cause large-scale habitat destruction; death of fish; change in geomorphological processes; ongoing loss of wetlands and wetland functions; degradation and fragmentation of vegetation; alteration of sedimentation; and impacts on listed species.   They advised these effects could not be effectively mitigated as it is not technically feasible to recreate the estuarine habitats.

4.  Claimed Economic Benefits of RBT2 are misleading and the Project will harm existing operations

The Draft Summary Assessment Report states the Review Panel reported that RBT2 will benefit the container business by increasing container terminal capacity; supporting competitiveness; and providing operational and spin-off jobs.  This information is misleading as the west coast of Canada is increasing container capacity at Vancouver terminals and at the Port of Prince Rupert.  There is ample current and planned capacity for decades, without RBT2.

The touted spin-off jobs are already activated with current operations.

The International Longshore & Warehouse Union – Local 502 submitted concerns of job losses resulting in unemployment in the transport sector and revenue losses in local communities.

The current operator at Deltaport, Roberts Bank, Global Containers Inc., is also vehemently opposed to RBT2 and advises that RBT2 will negatively impact their business.

5. Draft Summary Assessment Report omits to include level of public concern

Thousands of submissions have expressed opposition to RBT2 and concern for the health of the Fraser River Estuary and Salish Sea.

Public comments have not been meaningfully incorporated.  This contravenes the ‘International Core Values for the Practice of Public Participation.’

6.  Resources or values in the Fraser Estuary and Salish Sea will not longer be available for future generations

The Draft Summary Assessment Report acknowledges some of the harm RBT2 will cause at Roberts Bank but fails to identify all effects and the implications to the health of the Fraser River Estuary and Salish Sea ecosystems.  Under the heading, ‘Resources of Values that May no Longer be Available for Future Generations’:  

The EAO acknowledges that there could be potential impacts to resources or values of importance to current and future generations. As described in the Panel Report, RBT2 would require the conversion of approximately 168.1 ha of intertidal and subtidal habitat on Roberts Bank in the Fraser River estuary, an ecologically productive and sensitive area of coastal British Columbia

The wording, “could be potential impacts” does not being to correlate with the concerns raised by government and independent scientists, as well as the Review Panel, that warned effects will be high in magnitude, permanent and irreversible for:

Wetlands and wetland functions
Juvenile chum and Chinook salmon
Biofilm and western sandpipers
Ecology of the estuary
Fish habitat
Effects on human health from air pollution
Noise pollution
Greenhouse gas emissions