The Project's significant adverse effects cannot be justified in the circumstances

Reference Number

Thank you, for inviting comments on the potential conditions under the Canadian Environmental Assessment Act, 2012. As a qualified individual, I agree with Venton and Tuytel’s conclusion from paragraph 360 “The Project’s (significant adverse environmental) effects cannot be justified in the circumstances. Significant adverse effects on federally protected endangered species cannot be justified under CEAA 2012.”


Part of the reasoning for supporting the conclusion reached by Venton and Tuytel rests on information they included in their submission below.


Paragraph 272 of the David Suzuki Foundation, Raincoast Conservation Foundation and Georgia Straight Alliance Submission. “DFO’s recent comments echo the Panel’s finding that “an objective of net overall decrease in underwater noise by commercial vessel traffic” is necessary. Drs. Scott and Val Veirs agree. Consistent with DFO’s Imminent Threat Assessment, which the Panel addressed, the Southern Residents’ survival and recovery are already jeopardized by current conditions, including the current state of Chinook salmon and existing levels of ship source noise and disturbance in critical habitat. The Southern Residents cannot tolerate increased threats; they require an improvement over status quo conditions if they are to recover from their current endangered status or even to survive over the long term. As confirmed by the Veirs’ Report, any additional impacts on prey availability or additional noise or disturbance will exacerbate the existing untenable conditions in the Salish Sea and will therefore be a significant adverse effect.”


Furthermore, peer reviewed papers from the proponent’s ECHO Program strongly suggest that the Project will reduce the ability of SRKW to survive in the Salish Sea. The mitigations examined in the July, 2021 report by Burnham, Vagle, O’neill and Trounce suggest noise may be reduced by various measures yet, there is no information in support of the adequacy of mitigations to protect RSKW from extirpation. In addition, in the 2017, report by Lacy, Williams, Ashe, et al., the main threat to the survival of SRKW is tha lack of food. Noise disturbance ranks less severe than food scarcity. In 2010, Hanson, Baird, Ford et al., found SRKW predated on Chinook Salmon returning to the Fraser River almost exclusively. Since the damage to estuaries in the region is a very serious habitat disturbance the RBT2 application should have done a better job at protecting and restoring Chinook Salmon.

Finally, if the Proponent was more serious about maximizing protection of environmental attributes, they would eliminate coal exports. That would reduce traffic some 60%.

Submitted by
Ian Peace
Public Notice
Public Notice - Public Comments Invited on Additional Information and Potential Conditions
Date Submitted
2022-03-16 - 2:56 AM
Date modified: