Roberts Bank Terminal 2 Project

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Attachment Roberts Bank Terminal 2 Project - Tsawout Letter of Support

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Tsawout First Nation
  • Reference number: 3559
  • Submitted: 2023-01-09 - 2:11 PM
  • Please see the attached submission
  • Attachment included
  • 0 TSAWOUT FIRST NATION December 14, 2022 Impact Assessment Agency of Canada 160 Elgin Street, 22nd floor Ottawa, ON. K1A 0H3 Dear Sirs/Madams, Re: Roberts Bank Terminal 2 Project Environmental Assessment I am writing on behalf of the Tsawout First Nation ("Tsawout") to advise that Tsawout supports and consents to the Vancouver Fraser Port Authority's proposed Roberts Bank Terminal 2 Project, a marine container terminal which is subject to assessment for environmental effects. Tsawout understands that the location of the proposed marine terminal and the container ships travelling to and from the terminal are within our asserted traditional territory. Tsawout acknowledges and agrees that it is satisfied with the mitigation measures provided by Vancouver Fraser Port Authority in respect of the environmental effects of the Roberts Bank Terminal 2 Project and associated marine shipping, agrees that there has been adequate consultation and accommodation of its Aboriginal and treaty rights, title and interests for the Project and associated marine shipping and further consents to and supports the granting of each and every certificate, authorization and permit necessary for the Project and associated marine shipping. If you have any questions regarding this letter, please do not hesitate to contact me at Sincerely, Chief Harvey Underwood cc Minister of Fisheries, Oceans and the Canadian Coast Guard Minister of Environment and Climate Change Canada Minister of Transport Robin Silvester, President and CEO, Vancouver Fraser Port Authority Virginia Crawford, Impact Assessment Agency of Canada Jessie Hannigan, British Columbia Environmental Assessment Office Office hours: Mon.-Fri., 8:30 am ...
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Attachment Vancouver Fraser Port Authority response to ECCC comments on biofilm and western sandpipers

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of the Vancouver Fraser Port Authority
  • Reference number: 3558
  • Submitted: 2022-11-14 - 3:58 PM
  • Please see the attached submissions
  • Attachment included
  • Roberts Bank Terminal 2 Project Executive Summary – A collaborative and appropriately designed approach to protect western sandpipers November 14, 2022 Vancouver Fraser Port Authority Roberts Bank Terminal 2 Project | Executive Summary – A collaborative and appropriately designed approach to protect western sandpipers 2022-11-14 | Page 1 Executive Summary Background This submission is the Vancouver Fraser Port Authority’s (port authority) response to the submission from Environment and Climate Change Canada (ECCC), dated October 26, 2022 (CIAR #3557) regarding the Roberts Bank Terminal 2 project (RBT2, project). In this submission, the port authority synthesizes the available information, including ECCC’s feedback, related to the assessment of potential effects of the project on western sandpiper to support project decision-making. This submission also provides further comments, reflecting consideration of ECCC’s feedback on the potential conditions that can be imposed to address any potential adverse effect of the project on western sandpipers. The port authority is advancing the project as part of its mandate under the Canada Marine Act to enable Canada’s trade through the Port of Vancouver. RBT2 is a critical investment in marine-side port infrastructure on the west coast of Canada comprised of a new three-berth marine container terminal, a widened causeway to accommodate additional road and rail infrastructure, and an expanded tug basin to accommodate expanded tug operations. The project is in Delta, British Columbia, and proximate to Tsawwassen First Nation. Indigenous knowledge has been embedded into the development of the project, and it will support Indigenous ...
  • Attachment included
  • November 14, 2022 Mr. Terrence Hubbard President Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor, Place Bell Ottawa, Ontario K1A 0H3 Re: A collaborative and appropriately designed approach to protect western sandpiper: Response to comments of Environment and Climate Change Canada Dear Mr. Hubbard: The Vancouver Fraser Port Authority (the port authority) is pleased to provide our response to Environment and Climate Change Canada’s (ECCC) submission dated October 26, 2022, regarding the Roberts Bank Terminal 2 project (RBT2). With the implementation of the measures described in this response and previous submission (dated June 10, 2022 CIAR #3553)—including mitigation considered by the review panel, additional measures proposed after the review panel report, and the additional conditions developed in consultation with Indigenous groups—we are confident that any potential effects of the project on western sandpipers can be effectively mitigated and, if they occurred, would not be significant. With container trade on Canada’s west coast growing faster than forecasted, globally-based supply-chain challenges that Canadians are experiencing today are a preview of made-in-Canada supply-chain problems ahead. We, as a country, must deliver the capacity needed for this essential sector that supports Canadians’ access to imports they use every day, as well as Canadian farmers and other exporters in accessing global markets. Developed under the port authority’s public interest mandate, RBT2 will provide timely container capacity on Canada's west coast, ensure greater supply-chain competition, and protect Canada's trade sovereignty. Indigenous knowledge has been embedded into the ...
  • Attachment included
  • Roberts Bank Terminal 2 Follow-up Program November 14, 2022 A collaborative and approporiately designed approach to protect western sandpipers 2022-11-14 | Page i Contents 1. Introduction ............................................................................................................................................. 1 1.1 Background and context for this response.............................................................................................. 1 1.2 Overview and structure of this submission .......................................................................................... 2 2. A comprehensive approach .................................................................................................................... 3 2.1 Mitigation ............................................................................................................................................. 4 2.1.1 Measures to be implemented by the port authority ........................................................................ 4 2.1.2 Response to ECCC comments on biofilm creation ........................................................................ 5 2.2 Follow-up: the importance of an appropriately designed approach .................................................... 7 2.2.1 Consultative approach to incorporate Indigenous and scientific advice ........................................ 7 2.2.2 Reliance on leading indicators ....................................................................................................... 7 2.2.3 Robust baseline .............................................................................................................................. 8 2.2.4 ...
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Attachment From Environment and Climate Change Canada re: Comments on the project

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Environment and Climate Change Canada
  • Reference number: 3557
  • Submitted: 2022-10-26
  • Please see the attached submission
  • Attachment included
  • October 26, 2022 1 Roberts Bank Terminal 2 Project Environment and Climate Change Canada (ECCC) Response to the Proponent’s Public Comment Period Submissions Summary Environment and Climate Change Canada (ECCC) has reviewed two recent submissions provided by the Vancouver Fraser Port Authority (the Proponent) on April 22, 2022 (Part 1 submission, CIAR #3546) and on June 10, 2022 (Part 2 submission, CIAR #3553). The Proponent’s submissions respond to the proposed draft conditions and public comments provided during the public comment period for the Roberts Bank Terminal 2 Project (the Project). The Proponent’s Part 1 submission addresses comments on wetlands and wetland offsetting, and species at risk. The Part 2 submission responds to comments on biofilm, salinity and migratory birds, including the Western Sandpiper. In preparing this response, ECCC has relied on data from all available sources, including local studies, peer-reviewed research, and the studies conducted by the Proponent. The Proponent’s Part 2 submission proposes a phased approach to construction. ECCC acknowledges that in theory, an appropriately designed phased approach could help reduce the likelihood that the species-level impact to the Western Sandpiper identified by ECCC experts would occur. Based on the details of the current proposal, however, it is not clear that the proposed approach will address the population level risk to Western Sandpiper. In order for ECCC to be able to assess the ability of the proposed approach to be effective, ECCC needs to understand the reversibility of any impacts; the scientific model that would inform the phased approach, and the choice of monitoring indicators, etc.; the ...
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Attachment Roberts Bank Terminal 2 Project - Songhees Letter of Consent

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Songhees Nation
  • Reference number: 3556
  • Submitted: 2022-10-25 - 11:12 AM
  • Please see the attached submission
  • Attachment included
  • Songhees Nation September 28th, 2022 Impact Assessment Agency of Canada 160 Elgin Street, 22nd floor Ottawa, ON. K1A 0H3 Dear Sirs/Madams, Re: Roberts Bank Terminal 2 Project Environmental Assessment I am writing on behalf of the Songhees Nation (“Songhees”) to advise that Songhees supports and consents to the Vancouver Fraser Port Authority’s proposed Roberts Bank Terminal 2 Project, a marine container terminal which is currently being assessed for environmental effects. Songhees understands that the location of the proposed marine terminal and the container ships travelling to and from the terminal are within their asserted treaty and asserted traditional territory. Except in the case of a marine shipping accident, disaster or malfunction, such as a sinking, spills, containers going overboard from a vessel, or damage to marine resources caused by such accident, disaster or malfunction, that is in relation to the Project or marine shipping associated with the Project, Songhees acknowledges and agrees that it is satisfied with the mitigation measures provided by Vancouver Fraser Port Authority in respect of the environmental effects of the Roberts Bank Terminal 2 Project and associated marine shipping, agrees that there has been adequate consultation and accommodation of its Aboriginal and treaty rights, title and interests for the Project and associated marine shipping and further consents to and supports the granting of each and every certificate, authorization and permit necessary for the Project and associated marine shipping. If you have any questions regarding this letter, please do not hesitate to contact me by email at . Sincerely, ...
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Attachment Roberts Bank Terminal 2 Project - Tsartlip Letter of Support

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Tsartlip First Nation
  • Reference number: 3555
  • Submitted: 2022-10-18 - 12:29 PM
  • Please see the attached submission
  • Attachment included
  • Tsartlip First Nation October 3, 2022 Impact Assessment Agency of Canada 160 Elgin Street, 22nd floor Ottawa, ON. K1A 0H3 Dear Sirs/Madams, Re: Roberts Bank Terminal 2 Project Environmental Assessment I am writing on behalf of Tsartlip First Nation (“Tsartlip”) to advise that Tsartlip consents to the Vancouver Fraser Port Authority’s proposed Roberts Bank Terminal 2 Project, a marine container terminal which is currently being assessed by the Impact Assessment Agency of Canada under reference number 80054 (the “Project”). Tsartlip’s consent is limited to authorizations and approvals for the Project and associated marine shipping as currently being assessed, and related permitting processes (including but not limited to the issuance of a Fisheries Act authorization, a permit under the Species at Risk Act, and any provincial certificate, permit or authorization that may be necessary for the Project). Tsartlip does not object to the Project proceeding on the basis of compensation and opportunities offered by the Vancouver Fraser Port Authority and agreed to by Tsartlip, including payments on signing of a mutual benefits agreement and payments on approval of the Vancouver Fraser Port Authority Board of Directors making a final decision authorizing construction of the Project. On this basis, we acknowledge that Tsartlip has been adequately consulted and accommodated respecting potential impacts of the Project and associated marine ...
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Attachment Roberts Bank Terminal 2 - Invitation for Public Comment.

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Mary Judith Stockdale
  • Reference number: 3550
  • Submitted: 2022-05-05
  • Please see the attached submission.
  • Attachment included
  • ÍrlAy 0 5 2022 Impact Assessment Agency Canada 160 Elgin Stree! 22Floor Otüawa, Ontario KIA 0H3 conditions@iaac-aeic. gc. ca subject Roberts Bank Terminal 2 - rnviøtion for public comment. I am opposed to the proposed Roberts Bank Terminal 2 (RBT2) project. The additional information provided by the vancouver Fraser Port Authority (vFpA does not resolve the substantive issues raised by Environment and climate change canada (ECCC) scientists. The environmental assessment conditions as drafted do not protect the Roberts Bank ecosystem nor the wildlife. ECCC and other independent scientists have provided compelling evidence that the project will affect both biofilm qualiiy and quantity on Roberts Bank, threaten the entire western^ sanápiper species and negatively impact other wildlife. Furthermore I have major concerns with the potential draft conditions: . why are warnings from the government's own scientists beingignored? : ' why do the draft conditions ¿ßsume biofilm quality and availability will not be damaged when ECCC science ,horm they will? - why assume mitigation will be possible if damage is detected when it will be too late to prevent the damage? . why, if mitigation measures fail, are there nó provisions in the draft conditions, to elther stop the project, or to prevent environment¿l úamage to Roberts Bank wetlands and the wildlife that relies on them? . why (in section 10.2) do the draft conditions propose biofilm can be created when scientists have said it is not possible on the scale required? ' why ignore Review panel concerns about project effects on polyunsaturated fatty acid production in biofihn, which is a 2022-02-28,7..04 PM påge j of 2 h tt ps://bcnat ure. orglwp -conte nt/u ptoa d s/2 ...
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Attachment Present container terminal capacity is sufficient for CANADIAN cargo

  • Roberts Bank Terminal 2 Project
  • Author: private submitted by Dirk Peters
  • Reference number: 3547
  • Submitted: 2022-04-26 - 11:16 PM
  • Besides the numerous environmental problems highlighted by other commentators it needs to be pointed out that the economic benefits are overstated by the Vancouver Port Authority. The project documents show a timeline where the Canadian Westcoast will run out of container capacity unless Roberts Bank 2 is built. This is a distorted picture for two reasons: 1) A large part of Vancouver's import traffic and an even larger portion of Prince Rupert's import traffic is destined for customers in the United States. If Canadian freight would be prioritized (and US transit cargo only accepted after our domestic needs are met) then out transport needs could be met for many more years without disruptive new greenfield developments. The additional capacity would be beneficial to the shareholders of CN and CP because they could expand their market share in the United States but it does nothing for the rest of Canada that would justify the negative enviromental impact. 2) There is plenty of unused container capacity in Halifax NS, Saint John NB and soon also in Montreal. Since most of the cargo from East Asia is ultimately destined for Ontario, Quebec and the US Midwest the traffic growth can also be routed via these ports. Yes, the distance between Vancouver and China is shorter than from the East Coast however the pandemic has shown that importers have learned to live with longer transit times and supply chains are switching more and more from China to South East Asia and India, which can be served faster via the Suez Canal and Halifax. 

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Attachment Roberts Bank Terminal 2

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Warren Fenton
  • Reference number: 3548
  • Submitted: 2022-04-21
  • <personal information removed> Surrey,BC  <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 ...

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Attachment Expansion project must be rejected

  • Roberts Bank Terminal 2 Project
  • Author: Azriel Ferro
  • Reference number: 3542
  • Submitted: 2022-04-12 - 8:05 PM
  • I am writing from Australia I am urging the federal government to reject the Roberts Bank Terminal 2 expansion project.  The Impact Assessment Agency report has found that RBT2 will have significant adverse and cumulative effects on the South Thompson River and Lower Fraser ocean-type Chinook salmon populations. The federal review panel also determined that terminal expansion would create a large barrier to juvenile Chinook salmon wanting to migrate to eelgrass beds. In combination with adverse effects from acoustic and light disruption, these effects would be ‘high in magnitude, local in extent, permanent in duration and irreversible’.  The panel also found that the project would adversely affect food availability for Southern Resident killer whales, which will be magnified due to the nutritionally-stressed state of the whales. The panel concluded that the effects  would be ‘regional in extent, permanent in duration, irreversible and continuous’. The panel acknowledged that the Salish Sea is already too noisy for Southern Resident killer whales, and that the marine shipping associated with the Project would result in significant adverse effects on the population.  Importantly, there is a lack of evidence demonstrating that habitat mitigation offsets the negative effects incurred by development projects. In fact, a study done by Lievesley et al. (2016) found that only 33% of the Port’s own habitat offsetting projects obtained their intended goals, and a Canada-wide study by Quigley and Harper (2006) determined that 50% of fish habitat mitigation projects were not compensating for damages on a 1:1 ratio. This lack of quantitative ...

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Attachment RBT2 is not a sensible project from an environmental, social, or legal standpoint

  • Roberts Bank Terminal 2 Project
  • Author: Spencer S
  • Reference number: 3541
  • Submitted: 2022-04-12 - 6:31 AM
  • This project is problematic from an environmental, social, and regulatory perspective. Environmentally, the offsetting plan that VFPO have in place is woefully inadequate relative to the amount of development that RBT2 would entail. Socially, no local stakeholders support RBT2, including the City of Delta, the Tsawwassen First Nation, and the union representing dock workers. Any claims that this project has local support lack credibility, based on the published statements by the vast majority of local stakeholders. Legally, this project could be challenged on several grounds. It is set to be constructed on federal territory that overlaps with the critical habitats of multiple endangered species; therefore, it would violate the Species at Risk Act. The fact that it falls within the traditional unceded territory of the Tsawwassen First Nation also creates potential legal hazards. The Tsawwassen First Nation signed a treaty with BC in 2009. If the cumulative negative impacts that RBT2 is predicted to have on Tsawwassen cultural practices occur, then the Nation may have grounds to take legal action based on the recent precedent set by the Blueberry River First Nation. This project should be dead in the water, especially since the Port of Prince Rupert has development plans that could also meet Canada's needs to expand shipping capacity without destroying irreplacable biofilm habitat or threatening the place that has the highest diversity of birds in Canada. At the very least, approval of this project should be postponed until the impact assessment for the Deltaport Berth 4 project has been completed. That project is predicted to have less than half the footprint of RBT2 while providing ...

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Attachment FW: RBT2 Conditions (Maa-nulth)

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Maa-nulth First Nations
  • Reference number: 3544
  • Submitted: 2022-04-04
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Please see the attached submission. 
  • Attachment included
  • Huu-ay-aht First Nations ׀ Ka:'yu:k't'h'/Che:k'tles7et'h' First Nations Toquaht Nation ׀ Uchucklesaht Tribe Government ׀ Yuułuʔiłʔatḥ Government – Ucluelet First Nation02026742 THE FIRST NATIONS OF MAA-NULTH TREATY SOCIETY 5091 Tsuma-as Drive Port Alberni V9Y 8X9 Phone: (250) 724-1802 ♦ Fax: (250) 724-1852 Website: www.maanulth.ca April 4, 2022 Impact Assessment Agency of Canada Crown Consultation Operations Directorate Attention: Stephen Fitzpatrick, Senior Consultation Analyst Via Email: Stephen.Fitzpatrick@canada.ca Dear Mr. Fitzpatrick: Re: Roberts Bank Terminal 2 Project Response to Federal Information Request and Draft Federal Conditions We write in response to the draft federal conditions and the Vancouver Fraser Port Authority’s (the “Port’s”) response to the federal information request for the Roberts Bank Terminal 2 Project (the “Project”). We previously communicated our preliminary comments on these documents to your colleagues and are following up with our final comments, as discussed with those colleagues. IR Response We do not have any further comments on the Port’s response to the federal information request. Our comments on the response are reflected in our letters to the Port dated June 8, 2021 and June 14, 2021. We will forward your team copies of those letters under separate cover, in case you have not yet seen them or been informed of their contents. Draft Conditions Our comments on the draft conditions are as follows:  We remain concerned with the characterization of the Maa-nulth First Nations (“Maa-nulth”) as marine shipping-only impacted Indigenous groups (condition 1.24) with the result ...
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Attachment RBT2 Conditions feedback

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of S'ólh Téméxw Stewardship Alliance (STSA)
  • Reference number: 3538
  • Submitted: 2022-03-23
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Please see the attached submission.
  • Attachment included
  • Roberts Bank Terminal 2 Impact Assessment Draft Conditions Feedback Introduction This document contains technical feedback, communicated via the People of the River Referrals Office (PRRO). It is based on a technical review of the proposed conditions in relation to the project description, the review panel conclusions, and the review panel recommendations. PRRO also sought advice from external experts, including wildlife biologists and Indigenous law experts. On behalf of the STSA, we have previously submitted an integrated cultural assessment of the RBT2 project proposal. That submission remains a reference for understanding Stó:lō cultural and ecological needs, attachments, and relational connections within S’ólh Téméxw (Stó:lō territory). This review of the draft conditions focuses on three aspects: 1) The limitations of the specific recommendations in terms of ecological protections. 2) The extent to which the draft conditions as a whole protect and affirm Stó:lō cultural rights, particularly in line with Federal and Provincial commitments to the UN Declaration on the Rights of Indigenous Peoples (UNDRIP). 3) The need for a shared Indigenous governance approach to major projects in one of the most complex overlapping jurisdictions in Canada, including the establishment of a First Nations Environmental Impact Assessment Council to advance a true whole of government approach. Limitations of the specific recommendations The “no-net-loss” (NNL) approach to mitigation is advocated by the province of British Columbia. This approach should be the foundation of IAAC and BC EAO approaches to mitigating impacts from major proposed works. The draft conditions do not meet the ...
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Attachment Re: Roberts Bank Terminal Expansion

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Berni Claus
  • Reference number: 3549
  • Submitted: 2022-03-17
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • The Honourable Steven Guilbeault   Minister of Environment and Climate Change       and       Terry Hubbard President, Impact Assessment Agency of Canada       Re: Roberts Bank Terminal Expansion       How many more Panels, Studies, and Agency/CEAA/FEARO Reviews, and Ministerial Decisions are needed before the continuing expansion of the Terminal and the environmental impacts are stopped at Roberts Bank?       As a former member and Secretary of the Roberts Bank Environmental Review Committee (RBERC) in the 1990s, I am well aware of the environmental impacts from the terminal and it’s expansion. The original Environmental Review Panel in 1979 recommended that the full port expansion at Roberts Bank not proceed of the then much smaller terminal. Yet expansion proceeded, and today is much more that had ever been envisioned.        ...

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Attachment RBT2

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Charles Vaughan
  • Reference number: 3539
  • Submitted: 2022-03-17
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  •     To the Impact Assessment Authority: I am opposed to Roberts Bank Terminal 2.It is an unacceptable development which would have profound negative impacts on an environment already stretched to the limits of tolerance.It threatens millions of shorebirds dependant on the estuary, and threatens the remaining salmon populations and orcas which feed on salmon.The planet is already labouring under a biodiversity crisis. It would be immoral and unethical to permit this development to proceed.Cancel this proposal now. Yours sincerely, Charles Vaughan, <personal information removed>, Black Creek, BC
  • Attachment included
  • To the Impact Assessment Authority: I am opposed to Roberts Bank Terminal 2. It is an unacceptable development which would have profound negative impacts on an environment already stretched to the limits of tolerance. It threatens millions of shorebirds dependant on the estuary, and threatens the remaining salmon populations and orcas which feed on salmon. The planet is already labouring under a biodiversity crisis. It would be immoral and unethical to permit this development to proceed. Cancel this proposal now. Yours sincerely, Charles Vaughan, , Black Creek, BC, <personal information removed> <personal information removed>

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Attachment Submission to Roberts Bank Terminal 2 Project 80054

  • Roberts Bank Terminal 2 Project
  • Author: Administrator on behalf of Joachim Ruether
  • Reference number: 3531
  • Submitted: 2022-03-17
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • 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 ...

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Attachment Please reject the Vancouver Fraser Port Authority's Terminal 2 expansion project.

  • Roberts Bank Terminal 2 Project
  • Author: Britni Wige
  • Reference number: 3490
  • Submitted: 2022-03-16 - 9:13 PM
  • I am urging the federal government to reject the Roberts Bank Terminal 2 expansion project.    The Impact Assessment Agency report has found that RBT2 will have significant adverse and cumulative effects on the South Thompson River and Lower Fraser ocean-type Chinook salmon populations. The federal review panel also determined that terminal expansion would create a large barrier to juvenile Chinook salmon wanting to migrate to eelgrass beds. In combination with adverse effects from acoustic and light disruption, these effects would be ‘high in magnitude, local in extent, permanent in duration and irreversible’.    The panel also found that the project would adversely affect food availability for Southern Resident killer whales, which will be magnified due to the nutritionally-stressed state of the whales. The panel concluded that the effects would be ‘regional in extent, permanent in duration, irreversible and continuous’. The panel acknowledged that the Salish Sea is already too noisy for Southern Resident killer whales, and that the marine shipping associated with the Project would result in significant adverse effects on the population.    Importantly, there is a lack of evidence demonstrating that habitat mitigation offsets the negative effects incurred by development projects. In fact, a study done by Lievesley et al. (2016) found that only 33% of the Port’s own habitat offsetting projects obtained their intended goals, and a Canada-wide study by Quigley and Harper (2006) determined that 50% of fish habitat mitigation projects were not compensating for damages on a 1:1 ratio. This lack of quantitative ...

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Attachment Terminal expansion: significant adverse effects

  • Roberts Bank Terminal 2 Project
  • Author: Ann Bredin
  • Reference number: 3370
  • Submitted: 2022-03-16 - 3:58 AM
  • Terminal expansion will result in significant adverse and cumulative effects on threatened Chinook salmon populations, from the Lower Fraser and South Thompson watershed. Moreover, this construction will pose serious adverse and cumulative effects on the endangered Southern Resident killer whales through the destruction of legally protected critical habitat, reduced prey availability and an increase in underwater noise.These effects cannot be adequately mitigated or offset by measures proposed by the Port of Vancouver. Therefore, the recovery of these species/populations is not compatible with approval of project. The Minister of Environment Canada and Climate Change must reject this project.

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Attachment Please reject the RBT2 expansion

  • Roberts Bank Terminal 2 Project
  • Author: Emily Clark
  • Reference number: 3369
  • Submitted: 2022-03-16 - 2:56 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Along with thousands of others, I am writing to emphatically oppose the Roberts Bank Terminal 2 expansion. The science is clear that this project will inflict unacceptable and irreversible destruction to the Fraser River Estuary and Salish Sea ecosystems. These ecosystems are of global ecological significance, connecting food webs and essential migratory routes spanning 20 countries. Over one hundred imperilled species are at risk of extinction if cumulative pressures continue to intensify. Offsetting on such a scale is untenable. The predicted consequences of the expansion are overwhelming, and although the impacts will be felt most acutely in British Columbia the burden will be carried by all Canadians for generations to come. Please reject this project. Emily Clark

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

  • Roberts Bank Terminal 2 Project
  • Author: Ian Peace
  • Reference number: 3368
  • Submitted: 2022-03-16 - 2:56 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • 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 ...

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Attachment RBT2 threatens salmon, our orca relations, and Indigenous life ways and livelihoods

  • Roberts Bank Terminal 2 Project
  • Author: Sacred Lands Conservancy submitted by Ellie Kinley
  • Reference number: 3366
  • Submitted: 2022-03-16 - 1:54 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • March 15, 2022 Re: the proposal for Roberts Bank Terminal 2 To the Canadian Environmental Assessment Agency: The Sacred Lands Conservancy / Sacred Sea is an Indigenous-led non-profit committed to the protection of Xw’ullemy (the Salish Sea and its rivers and waterways), and the life, sacred sites, and Treaty rights connected to and held within those waters. Our organization is headed by President Tah-Mahs (Ellie Kinley) and Vice President Squil-le-he-le (Raynell Morris), two enrolled Lummi tribal members. Tah-Mahs is also a fisherman, whose family has always fished. She has personal, first-hand knowledge of what it is like to fish amongst oil tankers and vast container ships. The Lhaq’temish people have lived on and by the Salish Sea since time immemorial. We are a Salmon People. We hold salmon to be sacred. Salmon forms the basis of our culture, traditional life ways and livelihoods. Roberts Bank Terminal 2 would disrupt and destroy critical habitat for juvenile Chinook salmon.  These salmon runs are already greatly diminished. We hear stories about how, in the time of our ancestors, the salmon were so thick you could walk across their backs. Today, we struggle to find enough fish to feed our families and make a living. Along with the threat to future salmon runs, the increase in vessel traffic alone will make it almost impossible to fish in our Usual and Accustomed fishing grounds at the Canadian / US border. This is also true for our qwe’lhol’mechen (Southern Resident Orca) relations, who likewise depend on Chinook salmon runs for survival. Currently, the Southern Resident Orcas are threatened with extinction due to ...
  • Attachment included
  • Sacred Lands Conservancy doing business as Sacred Sea An Indigenous-led 501c3 non-profit 2321 West Street Bellingham, WA 98225 www.SacredSea.org 360-305-5880 March 15, 2022 Re: the proposal for Roberts Bank Terminal 2 To the Canadian Environmental Assessment Agency: The Sacred Lands Conservancy / Sacred Sea is an Indigenous-led non-profit committed to the protection of Xw’ullemy (the Salish Sea and its rivers and waterways), and the life, sacred sites, and Treaty rights connected to and held within those waters. Our organization is headed by President Tah-Mahs (Ellie Kinley) and Vice President Squil-le-he-le (Raynell Morris), two enrolled Lummi tribal members. Tah-Mahs is also a fisherman, whose family has always fished. She has personal, first-hand knowledge of what it is like to fish amongst oil tankers and vast container ships. The Lhaq’temish people have lived on and by the Salish Sea since time immemorial. We are a Salmon People. We hold salmon to be sacred. Salmon forms the basis of our culture, traditional life ways and livelihoods. Roberts Bank Terminal 2 would disrupt and destroy critical habitat for juvenile Chinook salmon. These salmon runs are already greatly diminished. We hear stories about how, in the time of our ancestors, the salmon were so thick you could walk across their backs. Today, we struggle to find enough fish to feed our families and make a living. Along with the threat to future salmon runs, the increase in vessel traffic alone will make it almost impossible to fish in our Usual and Accustomed fishing grounds at the Canadian / US border. This is also true for our qwe’lhol’mechen (Southern Resident Orca) relations, who likewise depend on Chinook ...
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Attachment An elegy

  • Roberts Bank Terminal 2 Project
  • Author: Jeremy Schmidt
  • Reference number: 3365
  • Submitted: 2022-03-16 - 1:48 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Brunswick Point, Roberts Bank - February 13, 2022 We put the battered rowboat in the Fraswer, down a bank of sand piles thick with the debris of dead and broken reed grass, slipping it off of the muddy hummocks that soften the hardened edge of the river. It is a flood tide, but barely, and the downstream current adds to our rowing. The ripple on the water nearer to the mouth of the river proves to be nothing, but puts a chill in the air that wasn't there on the sunny roadside where we launched. It is difficult to know where the land ends and the ocean begins; we are in the long stretch of intertidal wetland that forms Roberts Bank. Ahead, a narrow passage open as we approach, between two muddy drying flats. The oars dig into the mud below the water every so often, but there is still enough to keep afloat and keep moving. The air shimmers with the calls of birds, teeming as if in the first days of exultant creation off the muddy banks of flattened marsh grasses in teh shallows of the bank. Our approach, oarlocks clanking, startles a distant flock of snow geese further out off shore, whose wings slap the water, their unsettled calls rising into the air with the mass of their merged bodies. Perched on a log in the mud clser to the mouth of the river are two bald eagles, and they remain there the whole time we are out on the bank, motionless but for their heads turning slowly from time to time.  We approach the opening of the channel onto open water, the whole of the southern Strait of Georgia stretching out north, west and south, a full half-circle of the compass. To our left, a flock of Western sandpipers stand still on an archipelago of muddy tufts, their beaks ...

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Attachment Rogers Bank Terminal 2 Project

  • Roberts Bank Terminal 2 Project
  • Author: Alex C
  • Reference number: 3364
  • Submitted: 2022-03-16 - 1:46 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • I am voting against the approval of the Rogers Bank Terminal 2 Project. I am a 25 year resident of the Lower Mainland, and my main concern is heath of the environmental destruction this project will cause.  Multiple native wildlife species are at risk, including Orcas and salmon, which are not worth losing for more mass consumer goods that we could make here.   I support other countries, and also support Canada, which is why buying local goods when possible is a great way to prevent unsustainable growth like we are currently facing on a global scale. Growth is inevitable, but how we grow is up to all of us collectively.

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Attachment Proposed Terminal 2 expansion

  • Roberts Bank Terminal 2 Project
  • Author: Jessica Meier
  • Reference number: 3363
  • Submitted: 2022-03-16 - 1:33 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Over the decades the historic Fraser River Salmon runs have dwindled before our eyes. So much of our expanding way of life on this earth has detrimental effects on other species. If we are serious about protecting species at risk, migratory birds, SRKW, and salmon, we need actions that are congruent with those promises and regulations. This would mean to deny the expansion of Roberts Bank-terminal 2 expansion as it encroaches on ecologically and biologically important areas key to species at risk's survival.

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Attachment Concerns about "significant adverse" effects on southern resident killer whales

  • Roberts Bank Terminal 2 Project
  • Author: Roberts Bank Terminal 2 Project submitted by Damian Kettlewell
  • Reference number: 3362
  • Submitted: 2022-03-16 - 1:09 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Good day, Thank you for the opportunity to submit a comment on the Roberts Bank Terminal 2 Project.  As a long term Metro Vancouver resident I have a spiritual connection to the dwindling population of our southern resident killer whales of which just over 70 remain in the wild.  Approving this expansion is not in the public interest as ensuring that our southern resident killer whales does not continue to decline and thus lead to potential extinction.  The expansion of the Port of Prince Rupert is expanding and can support additional transportation needs to support economic development and supply chain stability.  Sincerely, Damian Kettlewell

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Attachment Asking you to reject the Vancouver Fraser Port Authority's Terminal 2 expansion project

  • Roberts Bank Terminal 2 Project
  • Author: William Bamberg
  • Reference number: 3361
  • Submitted: 2022-03-16 - 12:56 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • I would like the federal government to reject the Roberts Bank expansion project. This part of the Fraser estuary is an important habitat for marine and bird life and the impact assessment has shown it will have a severe impact on salmon, orca, and bird populations, and that thee is no evidence that habitat mitigations will compensate for the damage caused.

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Attachment Against the Expansion

  • Roberts Bank Terminal 2 Project
  • Author: None submitted by Colleen Doty
  • Reference number: 3360
  • Submitted: 2022-03-16 - 12:42 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • I strongly oppose the Roberts Bank Terminal 2 Project. With threatened species such as the orca, and rapid climate change before us, it would be irresponsible for our regulatory authorities to approve the terminal expansion. We owe it to future generations not to expand the fossil fuel industry.  Colleen Doty

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Attachment Pacheedaht comments on Proponent's response to IR2020-3

  • Roberts Bank Terminal 2 Project
  • Author: Pacheedaht First Nation submitted by Virginia Mathers
  • Reference number: 3359
  • Submitted: 2022-03-16 - 12:31 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Please find attached comments from the Pacheedaht First Nation on the Proponent's response to IR2020-3 (SKRW mitigation). 
  • Attachment included
  • Pacheedaht First Nation 350 Kalaid Street Port Renfrew, BC V0S 1K0 Phone: (250) 647-5521 Fax: (250) 647-5561 March 15, 2022 Submitted online Impact Assessment Agency of Canada Pacific Yukon Region 210a-757 West Hastings Street Vancouver, BC V6C 3M2 Canada To whom it may concern: Re: Roberts Bank Terminal 2 Project (the Project) Pacheedaht First Nation Comments on Additional Information Provided by the Vancouver Fraser Port Authority (Reference number 80054) On behalf of the Pacheedaht First Nation (Pacheedaht), I am writing to provide Pacheedaht’s comments on the additional information provided by the Vancouver Fraser Port Authority (the Proponent) in response to the Minister’s Information Request IR2020-3 relating to mitigation measures for Southern Resident Killer Whales (SRKW) from the Project. Pacheedaht has very serious concerns with the Proponent’s response, both in terms of the new report by Mercator International, and also in terms of the sufficiency of the mitigation being proposed for marine shipping from the Project. These issues are addressed in turn below. 1. Mercator International Report At the outset, Pacheedaht is deeply concerned to see the Proponent once again stating that the Project will not result in any new vessels transiting the marine shipping area. The Proponent states throughout their response to IR2020-3 that the Project will have no influence on the number of vessels calling at the Port of Vancouver. They say there will instead be a spatial redistribution of those vessels’ berthing locations. As support for these statements, the Proponent cites a 2021 report prepared by Mercator International (the 2021 Mercator Report). This is not ...
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Attachment LTR PFN to IAAC on Draft Project Conditions 3.15.2022

  • Roberts Bank Terminal 2 Project
  • Author: Pacheedaht First Nation submitted by Virginia Mathers
  • Reference number: 3358
  • Submitted: 2022-03-16 - 12:29 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Please find attached comments from the Pacheedaht First Nation on the draft conditions for the Project. 
  • Attachment included
  • Pacheedaht First Nation 350 Kalaid Street Port Renfrew, BC V0S 1K0 Phone: (250) 647-5521 Fax: (250) 647-5561 March 15, 2022 Submitted online Impact Assessment Agency of Canada Pacific Yukon Region 210a-757 West Hastings Street Vancouver, BC V6C 3M2 Canada To whom it may concern: Re: Roberts Bank Terminal 2 Project (the Project) Pacheedaht First Nation Comments on Draft Project Conditions On behalf of the Pacheedaht First Nation (Pacheedaht), I am writing to provide Pacheedaht’s preliminary comments on the draft conditions for the Project. Marine Mammals (8.1): Please see Pacheedaht’s comments on the Proponent’s response to IR2020-3, also submitted on today’s date. In our view, the measures identified by the Proponent so far to mitigate impacts to SRKW from marine shipping have not been sufficient. Marine Mammals (8.4): Pacheedaht’s strong view is that the plan to reduce underwater noise from the vessels associated with the Project needs to be completed before any decision is made in relation to the Project so that Indigenous groups, the Agency, and the Minister can assess whether it sufficiently addresses impacts to marine mammals. Furthermore, in our view the measures identified by the Proponent, Transport Canada, and DFO to address underwater noise need to be implemented at the outset of the Project, not at some later date. There are currently only seventy-four SRKW left. When it comes to protecting SRKW, the time for action is now. We know from the recent work completed by Dr. Sheila Thornton that SRKW are experiencing significant disruption to their foraging activities as a result of underwater noise, including at Swiftsure Bank. In order to ensure their ...
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Attachment Please reject the Vancouver Fraser Port Authority's Terminal 2 expansion project.

  • Roberts Bank Terminal 2 Project
  • Author: Mallori Walker
  • Reference number: 3357
  • Submitted: 2022-03-16 - 12:03 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • I am urging the federal government to reject the Roberts Bank Terminal 2 expansion project.  The Impact Assessment Agency report has found that RBT2 will have significant adverse and cumulative effects on the South Thompson River and Lower Fraser ocean-type Chinook salmon populations. The federal review panel also determined that terminal expansion would create a large barrier to juvenile Chinook salmon wanting to migrate to eelgrass beds. In combination with adverse effects from acoustic and light disruption, these effects would be ‘high in magnitude, local in extent, permanent in duration and irreversible’.  The panel also found that the project would adversely affect food availability for Southern Resident killer whales, which will be magnified due to the nutritionally-stressed state of the whales. The panel concluded that the effects would be ‘regional in extent, permanent in duration, irreversible and continuous’. The panel acknowledged that the Salish Sea is already too noisy for Southern Resident killer whales, and that the marine shipping associated with the Project would result in significant adverse effects on the population.  Importantly, there is a lack of evidence demonstrating that habitat mitigation offsets the negative effects incurred by development projects. In fact, a study done by Lievesley et al. (2016) found that only 33% of the Port’s own habitat offsetting projects obtained their intended goals, and a Canada-wide study by Quigley and Harper (2006) determined that 50% of fish habitat mitigation projects were not compensating for damages on a 1:1 ratio. This lack of quantitative evidence demonstrating habitat offsetting ...

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Attachment Roberts Bank Terminal 2 Project

  • Roberts Bank Terminal 2 Project
  • Author: Laura Pingle
  • Reference number: 3356
  • Submitted: 2022-03-16 - 12:01 AM
  • Participation notice: Public Notice - Public Comments Invited on Additional Information and Potential Conditions
  • Please do not approve this project.  The Vancouver Fraser Port Authority has submitted this application citing the importance of increasing port capacity.  I suggest that if this new terminal is approved, The Vancouver Fraser Port Authority will proceed to sell some of the land under it's jurisdiction in Burrard Inlet.  The Vancouver Fraser Port Authority will sell the land for billions of dollars to property developers in order to increase it's bottom line.  Those property developers will in turn build expensive waterfront towers.  The Vancouver Fraser Port Authority will justify the sale of it's Burrard Inlet properties by citing increased port capacity provided by the Robert's Bank Terminal 2 Project. I suspect that many of the people on the decision making panel have never visited the area where the Robert's Bank Terminal 2 Project is proposed to be built.  As a person who grew up in Delta and who now resides near the west dyke in Richmond, I see the importance of this area every day.  It seems that the importance of this area to migratory birds is not a concern of value to The Vancouver Fraser Port Authority.  It is very sad that nature is not valued to the extent that it should be valued.  Once this area no longer provides food to migratory birds, they will no longer survive.  Nature versus commerce.   I know which of these two that I value more.  Expand port capacity, if it is indeed necessary, in a more suitable area.  Remove the coal port.  Why is thermal coal from the United States allowed to be exported through this Canadian port when Washington State, Oregon and California do not allow this US ...

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