Need to Better Protect Southern Resident Killer Whales from a Catastrophic Marine Oil Spill Associated with Roberts Bank Terminal 2 Expansion

Should this Project proceed, which I sincerely hope it does not, a significant increase in commercial shipping activity would result in the Salish Sea- critical habitat for endangered, SARA-protected Southern Resident Killer Whales. The cumulative effects of shipping activity from this Project, as well as Trans Mountain Tanker Terminal expansion and other expansion projects within the Port of Vancouver, pose an existential threat to these orcas- an iconic symbolic of the Pacific Northwest. A catastrophic marine oil spill associated with either a Project-related or Trans Mountain-related vessel could essentially wipe out these endangered orcas overnight. 

For this reason, I propose that Section 19.1.1 in 19- Accidents and Malfunctions ( Pages 44-47 ) be reworded as follows:

"consider sensitive time periods for vulnerable species found in the vicinity of the Designated Project, including its construction and operation ( including Southern Resident Killer Whales, juvenile salmon and migratory birds ); and, in the case of Southern Resident Killer Whales, whenever they are present in the Southern Strait of Georgia, as determined by the Canadian Coast Guard's Marine Mammal Desk in Sidney, suspend all incoming and outgoing shipping activity associated with the terminal until such time as these whales have left the area." 

Sincerely,

Gerald Graham, Ph. D.

On Scene Commander for Marine Oil Spill Response