Submission to Roberts Bank Terminal 2 Project 80054

Reference Number

To Impact Assessment Agency of Canada, re: Roberts Bank Terminal 2 Project 80054


The minister must listen to the review panel and conclude that the environmental effects of Roberts Bank Terminal 2 are adverse and significant. The Governor in Council must not determine that the effects are justified in the circumstances.
Senior Liberal officials withheld evidence of the environmental harm the project will have. This is shameful and the project must be canceled as the environmental assessment process has been compromised.
Further harm to the Salish Sea, already at its capacity for disturbance, is not justifiable in the name of economics, especially when BC relies on a healthy Salish Sea for our economy, livelihoods, food and health.
The Port of Vancouver’s strategy to reduce harm to fish and fish habitat would only protect them from a measly 8 per cent of the current proposed project footprint. This strategy won’t have substantial benefits to fish habitat as the remaining 92 per cent will be harmed.
Habitat offsets will result in a net loss. Given that the fish species here are endangered, there cannot be additional harm to them if we want to see them recover. Offsets commonly do not achieve their goals of no net loss.
Biodiversity offsets aren’t an appropriate tool to reduce impacts of a project. Research shows that offsets can’t fulfill their promise to resolve the trade-off between development and conservation.
The Port of Vancouver says it won’t alter container vessel transits and so threats to southern resident killer whales remain unresolved. The government has committed to a worldwide pledge to halt biodiversity loss and approving this project would be in direct contradiction of that pledge.
The harm caused to communities from the deterioration of the Fraser Estuary cannot be mitigated. Harm to juvenile salmon will negatively impact communities all along the Fraser River that rely on salmon.
Increased air, noise, light, and water pollution from Roberts Bank Terminal 2 threatens human health and cannot be fully mitigated.


Yours truly,

Joachim Ruether <personal information removed>

Submitted by
Administrator on behalf of Joachim Ruether
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