Comment in opposition to RBT2 Project

Hello,

I am a tidal marsh ecologist and consultant who has more than 10 years of experience working in Fraser River Estuary tidal marshes. My work in the estuary has included biofilm research at Roberts Bank, numerous vegetation and species-at-risk related projects, and a master’s Thesis that revealed the undetected invasion of non-native cattail in the estuary. Most relevant to this conversation is my role as co-author and researcher in a 2016 report on tidal marsh compensation in the estuary (Lievesley, 2016), which has been heavily cited throughout the review process, and my recent role as lead author of a scientific report on created tidal marshes in the estuary, in collaboration with Ducks Unlimited Canada (Stewart et al., 2022). Based on my qualifications and high familiarity with tidal marsh creation projects in the FRE, I believe I have valuable expertise to offer to this conversation.

Though I acknowledge the significant time and energy placed into this application by the proponent, I wish to express my opposition to the RBT2 Project for the following reasons:

1. Though measures are being taken to reduce offset uncertainty through additional contingency offsets, adaptive management etc., there is ample evidence that marsh creation efforts to date vary widely in their long-term success (if we are willing to define success beyond the confines of compliance). Many existing created tidal marshes suffer from aging infrastructure, novel invasive species, and recession, all of which occurred after the project’s predetermined compliance monitoring period. In our recent study (Stewart et al., 2022), we found that marsh recession is common in 51% of the 78 sites we assessed, accounting for >23,000 m² of lost tidal marsh. We suggest these losses are linked to factors such as Canada Goose herbivory (an unresolved issue with no permanent solution to date) and boat wake, but it is likely the result of several issues that are poorly understood and lack any formal investigation to date.
2. The sheer quantity of habitat proposed in the offset plan, which appears to be a counter to outcome uncertainty, represents more area than all the current compensation/offset projects in the estuary combined. This includes projects that are unprecedented in size in the estuary. Based on the legacy of habitat compensation to date, including recent projects, I am concerned that the resources required to effectively manage and maintain these projects is vastly underrated, and little accountability will exist to ensure their functioning into the long-term, particularly in an urban estuary where stressors and stochastic events abound. Many of the legacy sites in the estuary are suffering from forms of degradation, and in some instances, they are disproportionately occupied with invasive species, thus adversely serving as seed sources to neighbouring natural marshes. This includes the few large sites in the estuary that exceed 2 ha in size. This long-term negligence of projects is highly problematic, and warrants caution before more than doubling the amount of compensation/offset habitat in the estuary.
3. I have significant concerns about disturbing habitat (e.g., removing logs) and creating novel habitats (e.g., habitat creation projects) in the Canoe Pass area without proper consideration of invasive cattail. This species has been overlooked by managers for decades, and it now occupies an estimated 5% of tidal marsh habitats, with highest concentrations in the outer estuary (Stewart, 2021). Studies by myself and other researchers have recently found that native plant diversity and abundance plumets in these cattail-invaded zones, along with the abundance of chironomids, an important food source for salmon (Lee, 2021). Disturbed and created habitats appear most vulnerable, including habitat creation projects which were found to be 5 x more proportionately occupied than natural marshes (Stewart, 2021). The Canoe Pass site is located next to the second largest infestation of cattail in the estuary (see attached map), and I am greatly concerned for this oversight.
4. The term “intertidal marsh habitat” is frequently used to describe valuable fish habitat, but I question whether there have been proper local investigations that quantify which habitat characteristics (e.g., elevations, channels, location in the estuary) and plant species provide these benefits. To date this blanket approach to “intertidal marshes” has justified tremendous oversights in how we value marshes, design marshes, and how we respond to aggressive non-native species that can colonize and displace native marsh communities. I am concerned that without a foundation of research many of these sites will continue to be created with status-quo assumptions that in my opinion, lack quantifiable supporting data.

In light of the above points, as well as those expressed by concerned experts of neighbouring fields, please reject the proposed Roberts Bank shipping expansion.

Works Cited

Lee, Jan Jakob. ‘The Impacts of Exotic Typha on Benthic Invertebrate Communities in the South Arm of the Fraser River Estuary’. Master’s Project. Burnaby: Simon Fraser University & British Columbia Institute of Technology, 2021.

Lievesley, Megan, Daniel Stewart, Rob Knight, and Brad Mason. ‘Assessing Habitat Compensation and Examining Limitations to Native Plant Establishment in the Lower Fraser River Estuary’, 2016. https://www.cmnbc.ca/wp-content/uploads/2018/11/Assessing-Habitat-Compensation_2016Appendix-I-IV.pdf.

Stewart, Daniel. ‘Undetected but Widespread: The Cryptic Invasion of Non-Native Cattail (Typha) in the Fraser River Estuary’. Master’s Thesis, University of British Columbia, 2021. https://open.library.ubc.ca/soa/cIRcle/collections/ubctheses/24/items/1.0397016.

Stewart Daniel, Hennigar Daniel, Ingham Robyn, Balke, Eric. 2022. Factors influencing the persistence of created tidal marshes in the Fraser River Estuary. Ducks Unlimited Canada, Surrey, British Columbia, Canada.