Roberts Bank Terminal 2

Reference Number

<personal information removed>


<personal information removed>

              Dear Minister Guilbeault:

                               I am writing concerning the pending decision regarding the proposed expansion of the Roberts Bank Terminal 2 in the Fraser River estuary in Delta BC. I understand that I am writing outside of the designated timeline for formal comments on the Draft Terms and Conditions associated with the Environmental Assessment certificate normally prepared for projects of this nature within the federal impact assesssment process but that is because I don not believe that "normal " terms and conditions are sufficient for this decision. The Impact Assesment Agency has done a commendable job in developing these measures but in this case they will not be sufficient . This is a project that is predicted to have permanent unmitigable impacts on key valued ecosystem components such as shorebirds and migratory salmon. It is clear from the submissions of others (the letter from local scientists a few weeks back,Birds Canada ,BC Nature ."APE" etc) that the science supporting proceeding with this project is unclear and a high degree of uncertainty remains about whether proposed mitigation measures will prevent significant permanent adverse effects from ocurring.

                             I retired as an Environmental Assessment practitioner in 2012. I had significant experience in cumulative effects assessment ,follow-up and adaptive mangament and process and policy implications of major  project reviews such as this one. I also worked on a project that evaluated the environmental consequences of building and abandoning artifical islands in the Canadian Beaufort Sea. In 2017 I grew up on the banks of the Fraser River and returned to BC's lower mainland after almost 40 years in 2017.  joined a local Naturalists Club (Delta Naturalists) to rediscover the area and  discovered massive change and a severely stressed ecosystem in the lower Fraser ,the delta and estuary and adjacent Salish Sea.


                          The propsed RBT2 project is simply too much for the current ecosystem. A precautionary approach dictates that where there is significant uncertainty .the development not proceed unless science through adaptive management can show that impacts can be managed. Ecological sustainability of a project depends upon proper application of follow -up and adaptive management.(see Mackenzie Gas Project Environmental Assessment Review Written Submission Joint Review Panel General Hearing Theme 6: Project Alternatives, Cumulative Impacts, Project Net Effects and Trade-offs after Enhancement, Mitigation and Follow-up Topic 14a: Environmental (Biophysical) Management Plans, Monitoring and Follow-up Programs May 2-4, 2007 Monitoring and Follow-up Programs April 12, 2007   ) But this no longer applies when a species (eg. western sandpiper;chinook salmon) is at risk of being elimnated from the ecosystem. Extinction can not be mitigated.  Until it can be unequivably  shown with sound science  that biofilm and other key aspects of the estuary can be maintained without undue harm ; this project should not proceed .

                     Also , the Draft Terms and Conditions refers to the need for Regional Cumlative Effects Assessment reviews to be completed on the lower Fraser River,Delta and Estuary and the Salish Sea. As one of the early pioneers  and proponents of this approach to environmental assessment I would heartily agree . However these need to be completed before any approval is granted . Further ,the  Ports Modernization Review currently mandated to Transport Canada should include a Strategic sector level Environmental Assessment (SEA)  of the need for ports expansion  on the west coast . Perhaps there are better alternatives to this facility at this location. This SEA should also include consideration of  life cycle cumulative effects of greenhouse gas emissions associated with the production ,shipping and handling  and secondary transportation of goods coming into those ports. There is a need to consider how continuing to operate super container ports attects Canada's ability to move towards a zero carbon future and to ensure a just transition to a more positive climate future than we presently have. Importing plastic-based goods from overseas and exporting coal may be undertakings that require further scrutiny and if these actions are no longer desirable in the future .maybe port expansions are also no longer necessary.



                       I am hopeful that this letter may still be able to be coinsidered in your deliberations with Cabinet colleagues . I urge you to determine that the approval of this project (deemed to have  permanent significant unmitigable effects )not be deemed to be " acceptable under the circumstances ".



                                                                                                               Thank you for your consideration.


                                                                                                                                Yours sincerely. 

                                                                                                                                          Warren Fenton

Submitted by
Administrator on behalf of Warren Fenton
Public Notice
Date Submitted
Date modified: