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Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility Consultation Summary Report Prepared by: Kirk & Co. Consulting Ltd. June 2015 Public Comment Period May 4 – May 19, 2015
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Page 1: Consultation Summary Report - Fraser Surrey Docks 24... · Consultation Summary Report Prepared by: ... On August 21, 2014, ... Surrey Leader • New Westminster NewsLeader ...

Fraser Surrey Docks LPConsideration to Amend Permit No. 2012 – 072

Direct Transfer Coal Facility

Consultation Summary Report

Prepared by:

Kirk & Co. Consulting Ltd.

June 2015

Public Comment Period May 4 – May 19, 2015

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About Kirk & Co. Consulting Ltd. Kirk & Co. is a recognized industry leader in designing and implementing comprehensive public and stakeholder consultation and engagement programs. Utilizing best practices, consultation and engagement programs are designed to maximize opportunities for input. Kirk & Co. independently analyzes and reports on public and stakeholder input.

The views represented in this report reflect the priorities and concerns of respondents. They may not be representative of the views of the public and other stakeholders as a whole because respondents self-selected into the public comment period, and therefore do not reflect a random sample.

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Table of Contents

1. Introduction ...............................................................................................................................4

1.1. Consideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility ............................. 4

2. Public Comment Period – May 4 – 19, 2015 .................................................................................4

2.1 Purpose – Public Comment Period ............................................................................................... 4

2.2 Notification ................................................................................................................................... 4

2.3 Participation .................................................................................................................................. 6

2.4 Methods ........................................................................................................................................ 6

2.4.1 Discussion Guide and Feedback Form .................................................................................. 6

2.4.2 Agency Meeting .................................................................................................................... 7

3. Results .......................................................................................................................................8

3.1 Key Themes – Feedback Form, Written Submissions and Local Government Submissions ......... 8

3.2 Key Themes – Agency Meeting ................................................................................................... 24

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1. Introduction

1.1. Consideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility

On August 21, 2014, Fraser Surrey Docks LP was granted a permit by Port Metro Vancouver that gives it conditional approval to build and operate a Direct Transfer Coal Facility within its existing lease area.

Fraser Surrey Docks (FSD) is considering applying to amend its existing permit. The proposed amendment would allow FSD to load coal directly from the facility to ocean-going vessels (OGVs). Using OGVs would allow FSD to eliminate or reduce the number of barges required. The proposed amendment to the existing permit would have no impact on the volume of coal permitted to be shipped through FSD, which is 4 million metric tonnes per year.

More information about FSD’s consideration to amend Permit No. 2012 – 072 can be found at www.fsd.bc.ca/amendment.

2. Public Comment Period – May 4 – 19, 2015

2.1 Purpose – Public Comment Period

The purpose of the public comment period, held May 4 to May 19, 2015, was to provide an opportunity for the public and stakeholders to review the proposed changes to the existing permit, and specifically for FSD to seek comments on the proposed scope of the studies associated with the amendment under consideration.

These studies included the Human Health Risk Assessment (HHRA), Environmental Impact Assessment (EIA), Air Quality Assessment (AQA), Marine Risk Assessment, Environmental Management Plan (EMP), Water Management Plan, Fire Safety Plan, and Spill Response Plan.

The input received during the public comment period has been summarized in this report and will be considered by FSD, along with information provided by technical experts, as part of the consideration to apply for an amendment to the existing permit.

Should FSD submit an application to amend the existing permit, a second round of public consultation will be undertaken. Round 2 Public Consultation would focus on the proposed project design associated with the submitted amendment application for Permit No. 2012 – 072 and the results of the studies.

2.2 Notification Notification of opportunities to participate in the public comment period included the following:

• Notification Emails: 115 emails were sent to stakeholders (local governments, environmentalorganizations, health authorities, MLAs and others) on May 4, 2015, with information about thepublic comment period.

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• Phone Calls: Phone calls were made to stakeholders (local governments, environmentalorganizations, health authorities, MLAs and others) to inform them of the public commentperiod, as follow-up to the email notification.

• Newspaper Advertising: Advertisements ran in the following community newspapers betweenMay 6 and May 14, 2015:

• Online Advertising: Online notification advertisements ran from May 4 to May 19, 2015, on thefollowing sites, with the following results:

• Surrey Leader: 9,904 ad impressions• New Westminster Record: 6,446 ad impressions

• Postcard Mailer: 9,077 households in Surrey and New Westminster received a postcard thatinformed recipients of ways to participate in the public comment period. The postcards weresent during the week of May 4, 2015, to households near FSD.Maps illustrating where the postcards were delivered can be found in Appendix A.

• Website: Notification of the public comment period and a button linked to the Discussion Guideand online Feedback Form were displayed on Fraser Surrey Docks’ home page (www.fsd.bc.ca)from May 4 – 19, 2015; a link to a page with information about the amendment(www.fsd.bc.ca/amendment) was also displayed on the home page.

Publications Dates • Surrey Leader• New Westminster

NewsLeader• Burnaby Now• New Westminster Record• Delta Optimist

Wednesday, May 6 and Wednesday, May 13

• Surrey Now• Richmond News• Peace Arch News

Thursday, May 7 and Thursday, May 14

Publications Circulation per insertion Burnaby Now 45,526 New Westminster Record 15,735 Delta Optimist 17,050 New Westminster NewsLeader 61,261 Richmond News 46,728 Surrey Now 117,720 Surrey Leader 82, 530 Peace Arch News 37,510

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• Social Media: Notification was sent from FSD’s Twitter account (@FSDocks) beginning May 4,2015, and at relevant times throughout the public comment period to remind the public andstakeholders of the opportunity to submit feedback.

• Information Bulletin: On May 4, 2015, an information bulletin was sent to regional andprovincial media to advise them of the public comment period.

2.3 Participation

A total of 51 submissions were received during the public comment period. A summary of the input received can be found starting on page 8.

• Online Feedback Form: 23 received• Written Submissions: 22 received• Local Government Submissions: 5 received• Agency Meeting: 1 meeting

2.4 Methods

Materials, including the Discussion Guide and Feedback Form, and the scope and rationale documents specific to each study, were made available online at www.fsd.bc.ca/amendment beginning on May 4, 2015. Feedback was collected through the following methods:

2.4.1 Discussion Guide and Feedback Form A Discussion Guide provided an overview of the proposed changes to the existing permit. The Discussion Guide and Feedback Form invited comment from the public and stakeholders regarding the proposed scope of eight key studies relevant to the amendment:

• Human Health Risk Assessment• Environmental Impact Assessment• Air Quality Assessment• Marine Risk Assessment• Environmental Management Plan• Water Management Plan• Fire Safety Plan• Spill Response Plan

The Discussion Guide was available for download, and an online version of the Feedback Form was

available at www.fsd.bc.ca/index.php/amendment during the public comment period.

A copy of the Discussion Guide and Feedback Form can be found in Appendix B.

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2.4.2 Agency Meeting

A meeting was requested by the Fraser Health Authority and was held on May 15, 2015.

Representatives of FSD attended the meeting, along with a meeting recorder from Kirk & Co. Prior to and during the meeting, agency representatives were provided with the Discussion Guide and the scope and rationale documents for each study, and were encouraged to submit input during the public comment period. Representatives of FSD provided information about their consideration to apply for an amendment, focusing on the proposed scope of studies relevant to the amendment. Agency representatives were invited to ask questions and provide feedback during the meeting. Key themes from this meeting are summarized in Section 3.2 on page 24.

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3. Results

The following provides a summary of the key themes from submissions received from online feedback forms, written submissions (emails and letters), and the agency meeting during the public comment period from May 4 to 19, 2015. As much as possible, the language expressed by respondents has been retained in the key themes.

3.1 Key Themes – Feedback Form, Written Submissions and Local Government Submissions

The results received through the online Feedback Form, written submissions and local government submissions are categorized according to Feedback Form questions shown below. This summary of key themes reflects the comments provided by respondents. The accuracy of the information in the comments below has not been confirmed. FSD will respond to the comments provided by respondents through a consideration memo, which will be posted prior to or concurrent with an amendment application, if FSD chooses to proceed.

The number of respondents commenting on a key theme is noted in brackets. The number of comments may exceed the total number of respondents commenting, as respondents may have commented on more than one topic.

1. Human Health Risk Assessment (HHRA), which will be completed by SNC-Lavalin Inc. (Environment& Water)

An overview of the proposed scope of this study can be found on page 7 of the Discussion Guide, andthe original study can be found at www.fsd.bc.ca/amendment.

Please provide comments on the proposed scope of the Human Health Risk Assessment associatedwith Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

Respondents provided the following comments related to the proposed scope of the HumanHealth Risk Assessment:

• The HHRA is too narrow; all potential adverse impacts included in this study must beaddressed for the entire transport route and FSD’s site, including: (9)

o The route of ocean-going vessels (OGVs), at least out to the open oceano The entire route that coal trains would travel from the U.S. border to FSDo Project-related emissions from equipment on-siteo The cumulative impacts of industry in the area, including newly approved and

pending projects that will impact the South Arm of the Fraser River

• There are concerns about air pollution and poor air quality from airborne pollution and coaldust, and its impacts on human health, including: (7)

o Concern regarding allergies, asthma, and cancero Potential impacts on the environment, plants, animals and homes

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• Economic, health and quality of life impacts from noise or traffic associated with increasedrail transport and increased activity at the terminals should be considered (4)

Respondents also stated the following related to the proposed scope of the Human Health Risk Assessment:

• That there has not been a Human Health Risk Assessment that has reviewed the cumulativehealth risks of industry in the area (1)

• Support for the proposed scope of the study (1)• That the review of the study by multiple experts is good (1)• That Golder Associates identified a number of minor errors throughout the HHRA

document; these errors should be corrected in the updated HHRA (1)• That it would be appropriate to re-evaluate conservative assumptions about the hazard

quotient and recalculate risks, or to identify these elevated predictions as an item thatshould be addressed in the AQA (1)

• That the air quality and noise impact areas for the HHRA require amendment to includeRichmond residential areas and a redefinition of air quality parameters specific to marinevessel operations in the South Arm of the Fraser River (1)

• That the updated HHRA should include input from the health authorities (1)

Respondents also provided the following comments, not directly related to the scope of the Human Health Risk Assessment, for the amendment under consideration:

• There are known health risks associated with the loading and shipping of coal (2)• This proposal will increase open-car coal train traffic through residential communities, which

raises concerns about the health impacts of coal dust, diesel exhaust, and nighttime noisefrom train whistles, as well as the potential impacts of vibration from heavy coal trains tohomes closest to rail lines (2)

• Concerns about the impacts on public health (1)• The supporting documents for the original project permit regarding operational noise and

vibration were dismissed (1)

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2. Environmental Impact Assessment (EIA), which will be completed by SNC-Lavalin Inc.(Environment & Water)

An overview of the proposed scope of this study can be found on page 8 of the Discussion Guide,and the original study can be found at www.fsd.bc.ca/amendment.

Please provide comments on the proposed scope of the Environmental Impact Assessment(EIA) associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No.2012 – 072:

Respondents provided the following comments related to the proposed scope of theEnvironmental Impact Assessment:

• The environmental impacts associated with the shipment of coal from FSD need to bere-evaluated with broader scope, including impacts on areas outside of the immediateenvironment, including: (9)

o Fish habitato Wetlandso Forestso Threatened or endangered specieso The shorelineo The greater cumulative carbon impacts of burning coal

• There are concerns about a potential increase in operational and construction noise relatedto the proposed amendment, and respondents stated that noise impacts from trains andships should be considered in the updated studies and in mitigation commitments (7)

• Risks associated with the cumulative increase in shipping traffic in the region should beconsidered, including: (5)

o Risks of accidents and oil and/or coal spills, threatening listed endangered species,fishing, tourism and recreation industries, Friday Harbor Marine BiologicalLaboratories and property values

o Impacts to recreational boaterso Threats to endangered salmon and orca (including noise impacts)o Impacts to recreational and commercial shellfish fisherieso Invasive species introduced through increased ballast water dischargeso Damage to wetlands and waterways from construction and developmento Ocean acidification

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Respondents also stated the following related to the proposed scope of the Environmental Impact Assessment:

• Support for the proposed scope of the study (1)• Impacts from contaminant spills of the coal product may include: (1)

o Smotheringo Toxicity from polycyclic aromatic hydrocarbons (PAHs)o Substrate changeo Accumulation

o

Water quality degradation• The EIA should be made available to the public and should be written in lay terms (1)• There should be an analysis of the following activities related to the proposed amendment:

(1)Anchoring for queuing and/or bunkeringVessel traffic related to tug assists and any bunkering-related vessel traffic

• Concerns that FSD has stated that no reassessment is required, and concerns that, without acloser look at the impacts on these areas and others, there is no confidence in FSD’sconclusions (1)

• The current areas of impact for the EIA require amendment to include Richmond’sforeshores and the provincially designated wetlands that constitute the South Arm IslandsWildlife Management Area (1)

• The air quality parameters for the EIA must be redefined specific to increased marine vesseloperations in the South Arm of the Fraser River (1)

• The EIA must take into account cumulative impacts of newly approved and pending projectsthat will impact the South Arm of the Fraser River; further accessory effects of increaseddredging (if required) to accommodate the large OGVs must also be included (1)

• A clear definition of types of coal and sources must be included in the EIA and PMVcertificate, and should clearly outline the Proponent responsibilities and tasks to amend thecommodity type or source (1)

Respondents also provided the following comments, not directly related to the scope of the Environmental Impact Assessment, for the amendment under consideration:

• Concerns that, although FSD has stated that “the project is not likely to cause significantadverse environmental effects, the words “not likely” and “significant” are cause forconcern. This respondent stated that any degree of impact is unacceptable (1)

• Any coal in FSD’s facility will impact the environment (1)

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3. Air Quality Assessment (AQA), which will be completed by Levelton Consultants Ltd.

An overview of the proposed scope of this study can be found on page 9 of the Discussion Guide,and the original study can be found at www.fsd.bc.ca/amendment.

Please provide comments on the proposed scope of the Air Quality Assessment (AQA)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 –072:

Respondents provided the following comments related to the proposed scope of the AirQuality Assessment:

• There are concerns about the impacts of poor air quality on human health, such as allergiesand asthma, from airborne pollution and coal dust, and from impacts on the environment,including climate change and pollution (6)

• Air quality impacts associated with releases of coal dust from trains transferring andtransporting coal in the region, from terminals, or from OGVs should be considered in thescope of the study (4)

• The proposed scope of the Air Quality Assessment should: (3)o Include information on how many cars form each traino Include information on where coal will be stored if not loaded immediately onto a

ship; this is an air quality concerno Link to the Environmental Impact Assessmento Consider upstream and downstream impacts

Respondents also stated the following related to the proposed scope of the Air Quality Assessment:

• The AQA should include data from Westshore Terminals, which loads directly to ships (1)• There needs to be more attention paid to the air quality and the coal dust created when

railcars offload (1)• Support for the proposed scope of the study (1)• Performance-based measures and ongoing monitoring must be included in the dust control

measures on-site and in adjacent areas. Particulate, NOx, VOC, CO and CO2 analysis relatedto OGV power sources (while in transit and while docked) must be included in the analysis,and put into context of regional cumulative impacts of other approved and proposedprojects in the lower Fraser River (1)

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Respondents also provided the following comments, not directly related to the scope of the Air Quality Assessment, for the amendment under consideration:

• FSD should handle commodities that they have experience with, especially because thermalcoal can spontaneously combust if stockpiled, which could release toxic smoke that cancause serious and immediate health impacts (2)

• There are concerns about air quality impacts from: (2)o Coal dusto The consumption of coal abroad

• As the volume of coal shipped through FSD will stay the same, there is no change to theissue of coal dust (1)

• Loading coal directly to ships instead of barges will reduce problems with coal dust (1)• Results from ongoing dust monitoring conducted by terminals and municipalities are

encouraging and demonstrate that the industry’s continuing efforts at dust mitigation areworking (1)

• FSD should consider the health and safety of residents of Annieville and Royal Heights (1)• Agricultural goods loaded/unloaded in the same port are liable to be contaminated with

coal dust (1)

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4. Marine Risk Assessment, which will be completed by DNV (Det Norske Veritas)

An overview of the proposed scope of this study can be found on page 10 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.

Please provide comments on the proposed scope of the Marine Risk Assessment associatedwith Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

Respondents provided the following comments related to the proposed scope of the MarineRisk Assessment:

• The proposed scope of the Marine Risk Assessment is inadequate and flawed, because ofthe inability to mitigate constant cumulative industrial impacts on the marine environment,including: (2)

o Increased ballast water discharges and associated risk of introducing invasivespecies

o Oil spillso Vessel noise (especially as it affects the southern resident killer whales)o Anchoring for queuing and/or bunkeringo Vessel traffic related to tug assists and any bunkering-related vessel traffic

• The permit should include a rigorous review of the risk and consequences of all accidentsand spills of any kind along the route and potential adverse impacts, including a discussionof: (2)

o The owners, operators and crews of project vesselso An assessment of the risk of all types of project-related vessel accidentso The types and volumes of propulsion fuel that would be carried by project-related

OGVso The safety-communication systems and equipment that would be on board each

project-related vessel and how it would be maintainedo Rescue protocols and maritime accident response infrastructure along the route to

open oceano Operational discharges of oil from project-related vesselso Who would pay costs for all impacts resulting from a project-related accidento Increases in the number of vessels transiting through the Salish Seao The introduction of additional bunker-fuelled Panamax vessels to the Fraser River

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Respondents also stated the following related to the proposed scope of the Marine Risk Assessment:

• Support for the proposed scope of the study (1)• Questions about the impacts of deep water vessels anchoring, including: (1)

o Impacts on shellfish, crab and nursery fish throughout the whole project areao The diameter of impact on and damage to the sea flooro The current anchorage patterns are for all oil tankers, tar sands bitumen ships, and

proposed coal shipso Impacts on fisheries throughout the anchoring area if the sea floor is often displaced

• New marine risk models must include cumulative impacts of newly approved and pendingprojects that will impact the South Arm of the Fraser River, including the recently certifiedVAFFC Jet Fuel Terminal project, the George Massey Tunnel Replacement project, and LNGterminal expansion at Tilbury (1)

• Any dredging of the Fraser River or other seaway modifications must be identified in theMarine Risk Assessment, and in turn be referred to in the EIA (1)

• Request for more information regarding the ultimate limits on OGV size that can beaccommodated at FSD, including questions about: (1)

o The factors (draught, basin size, river dynamics, etc.) that limit the ability toaccommodate ships larger than Panamax (i.e., 12 m draught, 32 m beam, 290 mlength)

o Any further modifications of the Fraser River required, particularly at the GeorgeMassey Tunnel location, to accommodate Panamax vessels, or larger vessels beingcontemplated

o Current or future plans to dredge the Fraser River to a depth of 18 metres• The study needs to completely re-evaluate impacts (1)

Respondents also provided the following comments, not directly related to the scope of the Marine Risk Assessment, for the amendment under consideration:

• The use of OGVs rather than barges is safer because it will decrease vessel movements andtherefore decrease risk of an accident, and because OGVs will require pilots, which will adda level of marine safety (6)

• The destruction of our food chain and of the marine environment would have a huge globalimpact; investments should instead be made into clean energy projects (2)

• The safety record of deep sea marine traffic on the Fraser River is exemplary (1)

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5. Environmental Management Plan (EMP), which will be completed by Soleil EnvironmentalConsultants Ltd.

An overview of the proposed scope of this study can be found on page 11 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.

Please provide comments on the proposed scope of the Environmental Management Plan(EMP) associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No.2012 – 072:

Respondents provided the following comments related to the proposed scope of theEnvironmental Management Plan:

• The scope of the Environmental Management Plan should be broader to include: (2)o Analysis beyond the proposed loader to see if there is something that would better

reduce coal dusto The cumulative impacts of newly approved and pending projects that will impact

the South Arm of the Fraser River, as they relate to the new type of Panamax vesselbeing proposed

• There should be containment and catch basins on the dock face (1)

• Support for the proposed scope of the study (1)

Respondents also provided the following comments, not directly related to scope of the Environmental Management Plan, for the amendment under consideration:

• The Environmental Management Plan is flawed because: (2)o Mitigation statements to manage risk are unable to mitigate global environmental

impactso The proposed project would ensure that public dollars are used to construct a

flawed project• The project is close to environmentally sensitive areas like Burns Bog (1)• There is a lack of confidence in Environmental Management Plans and the ability to

adequately manage emergencies, given the oil spill in English Bay in 2015 (1)• There are concerns about the impacts on the environment (1)• There are concerns about the potential effects on marine life and wildlife (1)

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6. Water Management Plan, which will be completed by Omni Engineering Inc.

An overview of the proposed scope of this study can be found on page 11 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.

Please provide comments on the proposed scope of the Water Management Plan (WMP)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 –072:

Respondents provided the following comments, not directly related to the scope of the Water Management Plan, for the amendment under consideration:

• Support for the proposed scope of the study (2)

• The scope of the Water Management Plan should be widened, because: (2)o It neglects to deal with FSD’s contribution to the destruction of the environment,

including damage to air, the river system and human healtho It should include a review of submissions received during Metro Vancouver’s public

comment period related to FSD’s waste discharge permit application

• The study needs to completely re-evaluate impacts (1)

• A request for further information regarding the feasibility for treatment of FSD’s sitewastewater through Metro Vancouver’s Annacis Island Wastewater Treatment Plant (1)

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Respondents provided the following comments related to the proposed scope of the WaterManagement Plan:

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7. Fire Life Safety Plan, which will be completed by Hatch Mott MacDonald

An overview of the proposed scope of this study can be found on page 12 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.

Please provide comments on the proposed scope of the Fire Life Safety Plan associated withFraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

Respondents provided the following comments related to the proposed scope of the Fire LifeSafety Plan:

• Support for the proposed scope of the study (2)

• The Fire Life Safety Plan is flawed because we are unable to mitigate such risks to the environment, and because the plan will not be effective in stopping fires and preserving life/safety (1)

• The revision of the Fire Life Safety Plan is good; however, there are outstanding questions,including: (1)

o Whether Delta and Surrey Fire Departments will assist in fire responseo Whether a more accessible route will be provided for emergency access to FSD

Respondents also provided the following comments, not directly related to the scope of the Fire Life Safety Plan, for the amendment under consideration:

• FSD should not stockpile thermal coal, due to problems with spontaneous combustion (1)• Concerns about potential impacts to the environment from a fire, including pollution (1)

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8. Spill Response Plan, which will be completed by Fraser Surrey Docks LP

An overview of the proposed scope of this study can be found on page 12 of the DiscussionGuide, and the original study can be found at www.fsd.bc.ca/amendment.

Please provide comments on the proposed scope of the Spill Response Plan associated withFraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

Respondents provided the following comments related to the proposed scope of the SpillResponse Plan:

• There is a lack of confidence in the Spill Response Plan because: (2)o It is unable to mitigate spillso The containment of the oil spill in English Bay in 2015 was inadequate

• Impartial experts, especially those who have experience with larger port management,should assist with the review (1)

• The plan must now account for the handling of bunker fuels typically used by Panamaxvessels, any accessory activities (such as bunkering of docked ships), and impacts over theentire length of the South Arm of the Fraser River (1)

• The plan must account for an increase in vessel movements of up to 80 return-trip vesselmovements and the greater consequence of a potential marine accident involving OGVs,rather than tug and barge (1)

• The risk and response evaluations must be put into context of other newly approved andpending projects in the South Arm of the Fraser River that will result in a significant increasein OGV transits (1)

Respondents also provided the following comments, not directly related to the scope of the Spill Response Plan, for the amendment under consideration:

• Increased shipping and its accompanying risk of a major rail or marine spill could adverselyimpact the environment, economy and quality of life of the Salish Sea (3)

• There is a lack of confidence in this kind of plan’s effectiveness (1)• All OGVs are required to have an agreement with WMRCC who will respond to any incident

involving a release of fuel oil; there have been no fuel oil releases that the Pilotage Authorityis aware of while under the conduct of a Fraser River Pilot (1)

• If there were no use of coal, there would be no spill (1)

June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 19

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9. Additional Comments

Please provide any additional comments on the proposed application to amend Permit No.2012 – 072:

Respondents provided the following comments:

• Opposition to the project (23)o General opposition to the projecto Concerns that the facility would be built in a densely populated areao Opposition to export of coal in several U.S. stateso Concerns that the facility will only benefit producers and customers of coal, not the

local communityo Local municipalities and Metro Vancouver are opposed to the export of coal in the

Fraser River area

• Concern regarding the coal industry’s impacts on the environment, including carbonemissions, climate change and pollution, and the fact that it is an industry that is already indecline (11)

• Concern with the process, including the approval process, and a lack of meaningful publicconsultation, including: (7)

o Concerns about the short notice for the public comment period (which includeda major holiday weekend)

o Concerns that the notification postcard was not received by many residents of thearea

o Requests for a longer consultation period on the permit amendment application inorder to review material

o A need for FSD to properly consult the Mayor and Councillors of New Westminstero Concerns that the solicitation of public comments occurred before all of the studies’

updates have been completedo General concerns about the permit processo A request that an independent Medical Health Officer be involved in the final

decisiono Concerns about the lack of public input and the lack of a public health assessment of

American thermal coalo Concerns that, once the studies are complete, Port Metro Vancouver and FSD

should conduct a public information meeting on the amendment application toensure the public has the opportunity to fully understand the implications of theproposal

• Opposition to the proposed amendment (6)o General opposition to the proposed amendmento Concerns that the final project will be monstrous compared to the original

considerations (e.g., larger volumes of coal and greater impacts on the surroundingenvironment) despite supporting the original application

June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 20

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• Support for the proposed permit amendment (3)

• Reiterated original support for the project, due to: (3)o The substantive and comprehensive research and professional reviews of the project

planso The changes related to the amendment that will reduce marine traffic, reduce dust

impacts, improve the industrial footprint and reduce water runoff from theoperation

• Concern whether FSD will listen to concerns raised in this comment period (3)

• The monetary benefits of FSD’s Direct Transfer Coal Facility do not offset the cost to theenvironment or communities (2)

• Concerns about having more coal and ships near the Fraser River and on FSD’s site (2)

Respondents also provided the following comments expressing concern about the environmental impacts of the project: • If George Massey Tunnel is replaced with a bridge, FSD will begin exporting larger volumes

of coal on bigger vessels, which will mean increased adverse impacts from more coal trains through communities, more noise, diesel exhaust and coal dust, and more ship traffic in the Salish Sea (1)

• Tourism is a very valuable industry in San Juan County, and there are concerns aboutimpacts on the Salish Sea’s human residents and thousands of different species (1)

• People should use clean energy like solar or wave power (1)• Concern regarding tailings ponds; also, having a transfer facility on the Fraser River should

not be allowed (1)

Respondents also provided the following comments related to health concerns: • The project will have significant physical and mental health risks from light and noise

pollution (1) • Concerns about the health risks of coal dust (1)• The project seems to be a short-term decision that rests on the illusion of economic benefit,

while diminishing health and well-being of the community and increasing costs for thehealth care system (1)

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Respondents also provided the following comments related to coal dust: • From the perspective of a resident of New Westminster, the project should not proceed,

and coal dust travelling from FSD across the Fraser River and into the home is undesirable(1)

• The efficacy of techniques for minimizing coal dust is questionable, especially given theinability to contain dust from other export goods and there are concerns that suchtechniques are very costly and unlikely to be implemented (1)

• The increased risk of fire from the amount of coal dust is too great (1)• FSD should pick whichever method minimizes coal dust (1)• There are concerns about air quality from airborne pollution and coal dust, and potential

impacts of poor air quality on human health, such as allergies and asthma (1)

Respondents also provided the following comments related to the project and the proposed amendment:

• Proposals to ship coal from ports along the U.S. west coast have met resistance, and it isquestionable that this project would be permitted in B.C. (1)

• Concerns about the potential impacts on property values (1)• Concerns about long-term impacts on residents, including quality of life concerns (1)• Coal is important because it is a major economic driver in British Columbia, and it powers

homes, businesses and communities in 40% of the world (1)• Rail is the most fuel-efficient means of transporting goods and commodities; coal trains are

treated to ensure that coal dust is contained as trains pass (1)• Any proposed changes to the existing permit must clearly identify the number and size of

OGVs, since it is unclear whether the Discussion Guide identifies the project as having thepotential for 80 OGVs (160 vessel movements/transits) or 40 OGVs (80 vesselmovements/transits) (1)

• A full and complete study should be required that covers the environmental impacts andhealth concerns related to the project in consideration of the amendment (1)

• The risks to public health, the environment, and water quality are not in the public interest(1)

• Concern about railcar topping agent in FSD’s wastewater that will be discharged to thesewer system (1)

• If there is an accident at FSD, other ports will suffer (1)• Cutting down marine traffic from 8 barges to 1 OGV is misleading (1)• This seems like a bait-and-switch technique (1)• B.C. businesses face opposition based primarily on aversion to carbon-based products, but

these groups do not heed the fact that coal is a legal, legitimate product that has been safelyshipped through B.C. ports for decades (1)

• The direct transfer from train to OGVs presents an increased logistical risk related to thetiming of coal arrival and ship availability; this respondent stated opposition to thestockpiling of coal at this facility (1)

• If coal must be transported, the United States should transport their own product (1)

June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 22

• Supportive of FSD’s ongoing commitment to further air, water and human health studiesand expressed confidence in FSD’s ability to meet or exceed Port Metro Vancouver’s criteria (1)

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• Request for access to the same details provided to the various contractors (like SNC-Lavalin)about the specifics of the amendment, as more information would be helpful to the publicin giving more feedback on the scope of the studies (1)

• Opposition to the original application for proposed expansion of coal exports at FSD until:(1)

o An independent third-party Health Impact Assessment has been completedo Port Metro Vancouver holds formal public hearings regarding the proposed project

at FSD• A report (as an appendix to the respondent’s submission) outlines concerns with FSD’s

original proposal, including the scope of the environmental impact assessment, stormwatermanagement, dust control, noise control, erosion and sediment control, flood risk, healthimpact assessment and consultation with staff (1)

• The Port Authority lacked the authority to issue the Permit to FSD or to make adetermination under s.67(a) of the Canadian Environmental Assessment Act (1)

• With or without an amendment to the permit, a key outstanding requirement is thedevelopment of a final Air Quality Management Plan and the submission of a final MetroVancouver Air Quality Permit application (1)

• Request to Metro Vancouver for the involvement of the Independent Interagency ReviewCommittee in this process (1)

June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 23

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3.2 Key Themes – Agency Meeting

The following are key themes from FSD’s meeting with the Fraser Health Authority on May 15, 2015. As much as possible, the language expressed by participants was retained in the key themes.

Meeting Key Themes Fraser Health Authority May 15, 2015 9:15 a.m. to 10:15 a.m.

ATTENDEES • Chief Medical Health Officer, Fraser

Health Authority (FHA)• Medical Health Officer, Fraser Health

Authority• President and CEO, Fraser Surrey Docks

LP (FSD)• Senior Project Specialist, SNC-Lavalin

Environment (SNC)

NOTE TAKER • Kirk & Co. (Meeting Recorder)

Agency representatives noted the following:

• That the concerns expressed by the Fraser HealthAuthority are not specifically related to the proposedamendment, but rather to the overall scope of thestudies that have been undertaken

• That the original Human Health Risk Assessment (HHRA)was satisfactory, and that the scope of study beingundertaken for the HHRA in consideration of theproposed amendment is acceptable, but that a fullHealth Impact Assessment is recommended

• That a Health Impact Assessment would be mutuallybeneficial, in terms of looking at all factors, identifyingpotential future risks and mitigation, and providing abalanced approach for moving forward

• That a project such as this could have impacts beyondthe scope of the footprint, and without that dataavailable, it is difficult to reassure community concerns

• That Fraser Surrey Docks is studying what is within thescope set out by Port Metro Vancouver

• That the Fraser Health Authority was interested inreviewing the assessment of ocean-going vessels as partof the consideration to apply for an amendment, interms of both marine risk and emissions

• That the Fraser Health Authority would consult withMetro Vancouver for their opinion on the adequacy ofthe air quality monitoring undertaken

June 2015 Fraser Surrey Docks LP Consideration to Amend Permit No. 2012 – 072 Consultation Summary Report 24

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Consultation Summary ReportAppendix A

June 2015

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Sie rra Ri dge

Taylor P l

Path

Glen Crt

Six th St

Fishe r S t

Agnes S t

Lorne St

Al l i son P l

Pine Rd

Tenb

y St

L eopo l d Pl

Speen R

d

Alm

ond

Pl

Bra id St

Haze l n u t Pl

Pa thway

Nana imo St

Al len S t

Co lumb ia St

Tupper Ave

Welsh St

Dyke R

d

Sydney S t

La rson Rd

Be lmon t St

On tar io St

Brandon St

112 Ave

Lee St

Ar row Lane

Moody S t

De lest re A ve

Manit oba St

Bonson St

Bo le St

Brookes S t

Kennedy St

Mil ton St

Pr imul a P l

Chu rch i ll St

Byrne Rd

Ken t St

Noot ka S t

We lls Gray Pl

McKenzi e S t

Granv i l le St

Sapp

er S

t

D ixon St

E E ig hth Ave

Access Rd

E Co

lumb

ia S

t

Lev i S t

Manzani ta Pl

Emory S t

Clu te St N el s o n's

Cre s

E Ro

yal A

ve

Ca rneg ie S t

Hil l Ave

1 0th Ave E

Jam ie

son

C rt

10 th Ave

Access Rd

6th S t

Sinc la ir Ave

Schoo l S t

Th ir teenth S t

Spruce

Rd

Peel e St

Elmer St

113 Ave

Quad ling Ave

15 th Ave

Duf fe rin S t

Arch

er S

tKnox S t

Maple S t

Monroe Ave

Godwin Crt

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ll St

Jackson S t

Strand Ave

Debeck St

McKay

St

125A S t

Q uebec S t

Lien Rd

Sco tt StWil l iam St

Oak St

Henderson Ave

Pine St

Cornwa ll St

Thrif

t St

Houl t St

Louel len S t

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Shaw S t

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McDon ald

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Loug

heed

Hwy

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s St

Ewen Ave

Elfo rd S t

Park

Row

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Span Rd

Ward St

Sta r C res

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Colb

y St

W inth rop St

R ickman P l

Black ie St

Co ld icutt St

Gira rd Ave

B r idge St

Acce

ss R

d

Black ford S t

San gster Pl

Sp ruce St

Guilb

y St

Edworthy WayCar iboo Dr

Fau lk

ner R

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Sh i les St

C umberland Pl

Win ram Rd

Th ird Ave

Karrman Ave

Merivale S t

Fi rst St

South

F raser

Pe r imi te

r Rd

Bernatchey St

Dunlo

p S t

Endersby St

Allis

on S

t

Wal

ker S

t

Jackson Cres

Ging e r Dr

Black berry Dr

Roder ick Ave

S unse t Ave

King George B lvd

M u lbe rry P l

Grayson Ave

Su rrey S t

Shaw Ave

Vic tor ia S t

Au cklan d S t

19 th Ave

Nin th Ave

Ross D r

Napanee St

Ovens Ave

Glover Ave

Sandr ingham Ave

Hamilt on S t

Ames

s St

Blackman S t

Harv

ey S

t

S haw Ave

111A Ave

Osborne Ave

Capi lano Way

10 th Ave

De lest re A ve

Coqu it l am St

E Durham S t

12 th Ave

Wilber fo rce S t

Langley St

E Seven th Ave

110 Ave

125

St

L ive rpoo l St

Rous

seau

St

B run

e t te Ave

McInnes St

Un ited

Blvd

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125B

St

Elg in S t

St . P at rick S t

113B Ave

Cascade St

Dickenson St

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r Ave

Yarrow Pl

Cla rkson S t

C olb o rne St

Oakl and St

Olsen R

d

Sim pson St

Hosp ita l S tC hil l iw ack St

Park Cres

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18th Ave

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Gauth ie r A ve

116 Ave

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eld S

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Sapp

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n Av

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St. Andr ews St

Mo tt C re s

4th S t

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on S

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1 5 th Ave

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r St

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114 Ave

Keary S t

Albe rta St

Sou th

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er Way

124 St

C h urch il l Ave

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tr ia l

Rd

O ld Yale Rd

Tannery Rd

McBr ide Blvd

Ash St

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Timbe rla nd Rd

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Newcombe St

Aval

on Av

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amp

Ar bu tus St

Lagun a Crt

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P a t tu l lo P l

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Rich

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Er in Ave

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Mona A ve

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r y S t

Crai

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G lenb rook Dr

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tnu t

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Br idge

Rd

Garre

t t St

C anfo r Ave

124

St

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Mu sq ueam Dr

Qua ys id e D r

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Agnes S t

Bra id St

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Ri ch mo n d St

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mond

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Fu rness S t

N orth Arm

Fraser

River BridgeviewPark

HumePark

SappertonPark

BurnabyLake Park

George HLeaf Park

George DerbyConservation Area

RobertBurnaby Park

TerryHughes Park

QuennsPark

MoodyPark

New WestminsterQuay

Scott R

d

Stewardson Way

Braid St

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Columbia St

Brunet

te Ave

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Royal Ave

E Colu

mbia

St

Twelfth St

SS1

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North

Rd Hwy 1

Surrey

Coquit lam

Delta

Burnaby

NewWestminsterQueensPark

BrunetteCreek

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Sapperton

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BCFSA / RTA: V3L

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16th Ave

To

Q uee nsborough Bridge

Front St

19th Ave

Marlb

orou

gh A

ve

Graham Ave

Elgin

Ave

Audley Blvd

Twenty-Second S t

Irmin St

Carson St

Humphries Ave

12th Ave

Duncan St

Nordel Crt Modesto Dr

Ewart St

Keith St

Boyne StPatrick St

Market Cross

Arcola St

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Bran

tford

Ave

McKee St

Howes St

1st S t

Alaska

Way

Santa Monica Dr

Southpoint Dr

Eighteenth St

Gi lley Rd

Portland St

Hwy 91

McBrid e Blvd

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Pembina St

83 Ave

Nordel Way

Ash St

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Wood St

Bryant St

Stanley St

80 Ave

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Balmoral St

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Trapp Ave

Salis

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Brooke Rd

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Mary Ave

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Riverbend Dr

Hwy 91A

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Dunlop Rd86 Ave

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s Pky

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Nanaimo St

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Hamilton S t

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Westminster Hwy

Fraserwood Way

Seventh Ave

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r Per im

i ter Rd

Queens Ave

Southridge Dr

Second St

Firs t St

Salter St

London St

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South Dyke Rd

River Rd

Fourth St

North F raser Way

Edmonds St

Edinburgh St

Ewen Ave

Gille

y Ave

12th Ave

Cliveden Ave

Derwent Way

South Fraser Perimiter Road

87 Ave

Lake

view

Ave

Duffe

rin A

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River Dr

Olive

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McGr

egor

Ave

Dock

RdWiggins St

Walth

am A

ve

MacP

herso

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Quayside Dr

E Sixth

Ave

114

St

Agnes St

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dary

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Belgrave Way

Wil tshi re Blvd

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Walker Ave

Bulle

r Ave

10th Ave Tenth St

116

St

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Stewardson Way

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Sixth StEighth St

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t

Roya

l Oak

Ave

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McBride Blvd

10th AveKingsway

Hwy 91

Queensborough Bridge

Hwy 91

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North Arm

Anna

cis Channel

Gund

ersen

Sloug

h

Fraser Rive

r

SS91

Froggers CreekRavine Park

Methews CreekRavine Park

KisbeyPark MalvernPark

QuennsParkPowerhousePark

Byrne CreekRavine Park

Ron McLeanPark

AlbertCrescent

E WoodlandsVegetation Study A

AnnievillePark

NorthDelta ParkSunburyPark

WillardPark

MackiePark

RoyalHeights Park

Burnaby FraserForeshore Park

Delta NatureReserve

EastburnKelvin

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GlenbrookeNorthMiddlegate

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Audley Blvd

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Qu eens b or ough Bridge

Southpoint Dr

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Copyright © Canada Post Corporation, 2015 - This map is provided for the sole use of Canada Post customers in preparing their mail. Any other use, including resale and the use of the map as a component of another product or service, is strictly prohibited. The map is provided "as is" and Canada Post disclaims any warranty whatsoever. The map must be used only during the validity period noted and must be destroyed following the expiry of such validity period. If no validity period is indicated on the map, the map must be destroyed 30 days from the date you obtained the map from Householder Counts & Maps. All rights not expressly granted are reserved by Canada Post and its licensors.Tous droits réservés © Société canadienne des postes, 2015 - L'utilisation de cette carte est réservée exclusivement aux clients de Postes Canada pour la préparation de leur courrier. Toute autre utilisation, y compris la revente ou l'utilisation de la carte comme complément à un autre produit ou service, est strictement interdite. La carte est fournie « telle quelle » et Postes Canada décline toute garantie de quelque nature que ce soit. La carte ne peut être utilisée que pendant la période de validité susmentionnée et doit être détruite après l'expiration de ladite période de validité. Si aucune période de validité n'est indiquée sur la carte, la carte doit être détruite dans les trente jours suivant la date où vous l'avez obtenue par Nombre de chefs de ménage et cartes. Tous les droits qui ne sont pas expressément accordés dans le cadre des modalités d'utilisation sont réservés à Postes Canada et à ses concédants.

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FSA MapCarte de RTA

Copyright © Canada Post Corporation, 2015 - This map is provided for the sole use of Canada Post customers in preparing their mail. Any other use, including resale and the use of the map as a component of another product or service, is strictly prohibited. The map is provided "as is" and Canada Post disclaims any warranty whatsoever. The map must be used only during the validity period noted and must be destroyed following the expiry of such validity period. If no validity period is indicated on the map, the map must be destroyed 30 days from the date you obtained the map from Householder Counts & Maps. All rights not expressly granted are reserved by Canada Post and its licensors.Tous droits réservés © Société canadienne des postes, 2015 - L'utilisation de cette carte est réservée exclusivement aux clients de Postes Canada pour la préparation de leur courrier. Toute autre utilisation, y compris la revente ou l'utilisation de la carte comme complément à un autre produit ou service, est strictement interdite. La carte est fournie « telle quelle » et Postes Canada décline toute garantie de quelque nature que ce soit. La carte ne peut être utilisée que pendant la période de validité susmentionnée et doit être détruite après l'expiration de ladite période de validité. Si aucune période de validité n'est indiquée sur la carte, la carte doit être détruite dans les trente jours suivant la date où vous l'avez obtenue par Nombre de chefs de ménage et cartes. Tous les droits qui ne sont pas expressément accordés dans le cadre des modalités d'utilisation sont réservés à Postes Canada et à ses concédants.

The Delivery Mode names that have an asterisk (*) indicate Modes that are split between more than one (1) FSA.Les noms des modes de livraison avec un astérisque (*) indiquent des modes partagés entre plusieurs RTA.

Page 30: Consultation Summary Report - Fraser Surrey Docks 24... · Consultation Summary Report Prepared by: ... On August 21, 2014, ... Surrey Leader • New Westminster NewsLeader ...

Consultation Summary ReportAppendix B

June 2015

Page 31: Consultation Summary Report - Fraser Surrey Docks 24... · Consultation Summary Report Prepared by: ... On August 21, 2014, ... Surrey Leader • New Westminster NewsLeader ...

DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015

Public Comment PeriodConsideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility

May 4 – 19, 2015

Discussion Guide and Feedback Form

Page 32: Consultation Summary Report - Fraser Surrey Docks 24... · Consultation Summary Report Prepared by: ... On August 21, 2014, ... Surrey Leader • New Westminster NewsLeader ...

DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20151

Consideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility On August 21, 2014, Fraser Surrey Docks LP (FSD) was granted a permit by Port Metro Vancouver that gives it conditional approval to build and operate a Direct Transfer Coal Facility within its existing lease area.

FSD is considering applying to amend its existing permit. The proposed amendment would allow FSD to load coal directly from the facility to ocean-going vessels (OGVs). Using OGVs would allow FSD to eliminate or reduce the number of barges required. The proposed amendment to the existing permit would have no impact on the volume of coal permitted to be shipped through FSD (4 million metric tonnes per year).

This Discussion Guide outlines aspects of the existing permit FSD is considering applying to amend, and seeks comments on the proposed scope of studies associated with the potential amendment to Permit No. 2012 – 072.

How Can I Provide Feedback?

• Provide a written submission• Submit your Feedback Form:

• Online• By email• By mail

Reporting

• Community and stakeholder feedback willbe summarized and posted online atwww.fsd.bc.ca/amendment

Correspondence and Inquiries

• Telephone: 604 - 891-1695

• Web: www.fsd.bc.ca/amendment

• Email: [email protected]

• Mail: PO Box 2233 Vancouver Main, Vancouver, BC V6B 3W2

Page 33: Consultation Summary Report - Fraser Surrey Docks 24... · Consultation Summary Report Prepared by: ... On August 21, 2014, ... Surrey Leader • New Westminster NewsLeader ...

DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 2

Port Metro Vancouver Permit Process Port Metro Vancouver is the permitting authority for the proposed amendment.

On August 21, 2014 Port Metro Vancouver issued a Project Permit to Fraser Surrey Docks LP (FSD)for the development of a Direct Transfer Coal Facility to handle up to 4 million metric tonnes of coal, per year.

The permitting process considered environmental and technical information, as well as First Nations, municipal, agency, and community input.

In completing its federal environmental review, and as per Section 67 of the Canadian Environmental Assessment Act 2012 (CEAA 2012), Port Metro Vancouver considered the information and the proposed mitigation measures provided by FSD, along with other relevant information. Port Metro Vancouver concluded that, with the implementation of proposed mitigation measures and subject to the conditions of the permit, the project is not likely to cause significant adverse environmental effects.

Round 1Public Comment PeriodConsideration to Amend Permit No. 2012 – 072

Review of proposed changes to the existing permit and proposed scope of studies.

May 4 – 19, 2015

Round 2Public ConsultationIf FSD submits the proposed amendment, the public will be provided with an additional opportunity to review and comment on changes to the project design and on the final results of the studies.

Fraser Surrey Docks LP (FSD) is the largest employer on the Fraser River waterfront, with more than 300 full-time employees. FSD has been a major employer and contributor to local communities for over 50 years, handling over 3 billion dollars-worth of goods annually. FSD has directly contributed over 280 million dollars to B.C. communities over the last 5 years through wages, taxes and buying of local goods and services.

There will be two opportunities to provide input regarding the proposed amendment. FSD will consider your input, along with information provided by technical experts, as part of its consideration to apply for an amendment to the existing permit.

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20153

Overview of Changes Under ConsiderationConsideration to Amend Permit No. 2012 – 072 Direct Transfer Coal Facility

Fraser Surrey Docks LP (FSD) is considering applying to amend its existing permit (Permit No. 2012 – 072) that gives it conditional approval to build and operate a Direct Transfer Coal Facility within its existing lease area.

The application to amend the existing permit would have no impact on the volume of coal permitted to be shipped through FSD (4 million metric tonnes per year).

The proposed amendment would allow FSD to load coal directly from the facility to ocean-going vessels (OGVs) and would allow FSD to eliminate or significantly reduce the number of barges required. One loaded Panamax size OGV can carry approximately four train loads of coal, and the same volume as eight loaded barges (i.e. 1 OGV = 8 barges).

• The proposed amendment under consideration by FSD would increase the current size and height of the loader,allowing for direct loading to OGVs.

• Use of OGVs would replace most or all barges. If approved, FSD plans to replace all barges with OGVs, but wouldretain barging as a potential secondary option.

• It is anticipated that the use of OGVs would further mitigate the potential for fugitive dust, as coal would betransported in a closed hatch.

• The conveyance system, receiving pit and rail tracks would be shifted on site to accommodate the larger vesselloader.

• The footprint of the facility area would decrease, which would reduce the amount of rain water runoff collected.

Ocean-going Vessel

Ocean-going vessels would eliminate or reduce the number of barges required.One ocean-going vessel holds the same volume as eight barges.

1 8 Barges

=

Page 35: Consultation Summary Report - Fraser Surrey Docks 24... · Consultation Summary Report Prepared by: ... On August 21, 2014, ... Surrey Leader • New Westminster NewsLeader ...

DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 4

The following are potential shipping scenarios based on 4 million metric tonnes per year:

* Numbers represent return-trip vessel movements.

Potential Shipping Scenarios Loaded Trains / Year Loaded OGVs / Year* Loaded Barges / Year*

Current permit approval 320 0 640

25% shift to OGVs (with proposed amendment)

320 20 480

50% shift to OGVs (with proposed amendment)

320 40 320

75% shift to OGVs (with proposed amendment)

320 60 160

100% shift to OGVs (with proposed amendment)FSD’s preferred operational scenario

320 80 0

Page 36: Consultation Summary Report - Fraser Surrey Docks 24... · Consultation Summary Report Prepared by: ... On August 21, 2014, ... Surrey Leader • New Westminster NewsLeader ...

DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20155

Potential Modifications to Original Project Design:

To accommodate a larger vessel loader, the conveyance system, receiving pit and rail tracks would be shifted in order to achieve proper angles and elevations. Primary changes would be as follows:

Project Features Approved Permit Proposed Amendment Application

Volume of coal shipped 4 million metric tonnes / year No change

Mode of shipping 1,280 barge movements / year based on 640 barge return trips

Use of OGVs to replace some or all barges

Marine Vessel Loader 14.3 metre (m) outreach (length of boom) from the edge of the berth and a maximum height of 15.0m

27.4m outreach from the edge of the berth and a maximum height of 36.2m

Receiving pit and building A fabric building spanning a 17m-in-length bottom discharge pit with 125 tonne surge bin

Metal-clad building; shifted 12m east and 16m south

Receiving building and pit dimension stay the same

Wastewater settling basins A two-stage primary and secondary settling basin with an approximate capacity of 300 m3

Shifted 37m west and rotated 90 degrees counter clockwise

Dimensions for settling basins stay the same

Also included is a 560,000 litre tank for contingency storage purposes for storm events

Basins would reside under the Out Feed Conveyor for more effective use of space and water management practices

Dust mitigation Dust mitigation measures meet regulatory standards

Additional dust mitigation through use of closed hatches on OGVs, spraying of empty outbound railcars

Overall water catchment area (Facility footprint)

5,340 m2 Decreased to 3,680 m2

Estimated to reduce water runoff by 10 -15%

Rail tracks Relocation of the front gate Adjustments to the rail loop; removal of Shed 4 and no relocation of the front gate

Jobs Estimated 20-25 full-time jobs An increase of up to 20 additional full-time jobs (total of up to 40- 45 new full-time jobs) due to extra shifts required to load OGVs (based on 100% shift to OGVs)

Page 37: Consultation Summary Report - Fraser Surrey Docks 24... · Consultation Summary Report Prepared by: ... On August 21, 2014, ... Surrey Leader • New Westminster NewsLeader ...

DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 6

Studies Fraser Surrey Docks LP (FSD) is working with consultants, who are subject-matter experts, to update studies that were undertaken for the existing permit (Permit No. 2012 - 072). The updated studies will identify and analyze any potential impacts of the proposed amendment.

Studies to be updated with respect to the proposed amendment include:1. Human Health Risk Assessment (HHRA) – SNC-Lavalin Inc. (Environment & Water)

2. Environmental Impact Assessment (EIA) – SNC-Lavalin Inc. (Environment & Water)

3. Air Quality Assessment (AQA) – Levelton Consultants Ltd.

4. Marine Risk Assessment – DNV (Det Norske Veritas)

5. Environmental Management Plan (EMP) – Soleil Environmental Consultants Ltd.

6. Water Management Plan – Omni Engineering Inc.

7. Fire Life Safety Plan – Hatch Mott MacDonald

8. Spill Response Plan – prepared by Director of Engineering, Fraser Surrey Docks LP

Updated studies, as listed above, would be reviewed by Port Metro Vancouver, the regulating authority, as part of an application to amend Permit No. 2012 - 072.

FSD anticipates that Port Metro Vancouver will contract a third-party reviewer, Golder Associates Ltd., to assist in the review of the following studies:

• Human Health Risk Assessment (HHRA)

• Environmental Impact Assessment (EIA)

• Air Quality Assessment (AQA)

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20157

1. Human Health Risk Assessment (HHRA) – SNC-Lavalin Inc. (Environment & Water)

A Human Health Risk Assessment (HHRA) was undertaken for the original project design. Port Metro Vancouver referred the HHRA for review by an independent third party (Golder Associates Ltd.), prior to the approval of Permit No. 2012 – 072.

In consideration of the proposed amendment, SNC-Lavalin will undertake a review of the HHRA (July 2014) to understand the impact of the proposed amendment on health risks. Human health risk assessments are tools used to determine if people will be safe if they are exposed to substances that are in the environment, food, or consumer products. The review of the HHRA will look at a comprehensive list of substances which may be present in emissions that could arise from the proposed amendment.

The HHRA will be updated, in part, based on the results of the Air Quality Assessment (AQA) conducted by Levelton Consultants Ltd. (Levelton) for the proposed amendment. A comprehensive list of emission sources will be evaluated in the AQA including the proposed coal operations at Fraser Surrey Docks LP (FSD) (i.e. emissions from marine vessels, and fugitive dust generated from material transfer points, as well as during coal unloading and loading), and in-transit emission sources (including emissions from marine vessels on the Fraser River).

SNC-Lavalin has reviewed the HHRA and based on their understanding of the proposed amendment, determined that the following areas of the report that will require further analysis:

• The HHRA will be updated to reflect Levelton’s AQA results;

• Exposure Point Concentrations (EPCs) will be interpreted based on the updated Levelton AQA results. EPCs areused to estimate exposures to fugitive dust and combustion emissions at specific geographic locations; and,

• Risk estimates associated with exposures to the emissions will be re-calculated based on updated EPCs, and theresults of the HHRA will be reviewed and updated as necessary.

The remaining sections of the HHRA require only minor edits as they are accurately described and remain applicable with respect to the proposed amendment, such as the scope of the HHRA, project location, baseline and rail corridor EPCs and associated risk estimates.

To facilitate an update of the proposed amendment application, SNC-Lavalin will revise the July 2014 HHRA report, and summarize the revisions in a technical memorandum.

SNC-Lavalin will:

• Review the description of refinements to the project associated with the proposed amendment;

• Review the extent to which the HHRA accurately estimates human health risks, taking into account the refinementsto the project associated with the proposed amendment;

• Describe and discuss the refinements to the project associated with the proposed amendment which are materialto the HHRA; and,

• Review and analyze the extent to which mitigation measures should be updated, where applicable.

The original Human Health Risk Assessment (July 2014), and the scope and rationale documents (April 2015) provided by SNC-Lavalin in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 8

2. Environmental Impact Assessment (EIA) – SNC-Lavalin Inc. (Environment & Water)

An Environmental Impact Assessment (EIA) was undertaken for the original project design. Port Metro Vancouver referred the EIA for review by an independent third party (Golder Associates Ltd.), prior to the approval of Permit No. 2012 – 072.

In consideration of the proposed amendment, SNC-Lavalin will undertake a review of the EIA (November 2013) to update the environmental impacts and proposed mitigation measures associated with loading coal directly onto OGVs as opposed to barges.

SNC-Lavalin has reviewed the EIA and, based on their understanding of the proposed changes to the project, have determined that the following sections will require further investigation or analysis:

• Project Description

• Consultation

• EIA Methodology

• Air Quality

• Surface Water and Groundwater

• Fish and Fish Habitat

• Vegetation and Wildlife

• Lighting

• Vessel Traffic

• Recreational and CommercialFishing

• Human Health

• Cumulative effects

• Environment Management Plans

• Summary of Project Effects,Mitigation Measures andResidual Effects

• Conclusion

SNC-Lavalin will prepare a technical memorandum that will review and analyze the changes to each of the relevant sections in the EIA. The technical memorandum will discuss environmental effects and provide additional mitigation measures relevant to the proposed amendment which are not currently covered in the EIA, if applicable.

SNC-Lavalin will:

• Review the description of refinements associated with the proposed amendment to the project;

• Review the extent to which the EIA adequately describes the potential environmental impacts, taking into accountrefinements associated with the proposed amendment to the project;

• Describe and discuss the refinements associated with the proposed amendment to the project which are materialto the EIA; and,

• Review and analyze the extent to which the potential impacts and mitigations should be updated, whereapplicable.

The original Environmental Impact Assessment (November 2013), and the scope and rationale documents (April 2015) provided by SNC-Lavalin in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 20159

3. Air Quality Assessment (AQA) – Levelton Consultants Ltd.

An Air Quality Assessment (AQA) was undertaken for the original project design. Port Metro Vancouver referred the AQA for review by an independent third party (Golder Associates Ltd.), prior to the approval of Permit No. 2012 – 072.

In consideration of the proposed amendment, Levelton will update the air quality study by conducting a review of the AQA submitted for the original permit (June 2014) to evaluate the potential impacts from the proposed project changes. A comprehensive list of emission sources will be evaluated related to the refinements associated with the project in the AQA, including the proposed coal operations at Fraser Surrey Docks LP (FSD) (i.e. emissions from marine vessels, and fugitive dust generated from material transfer points, as well as during coal unloading and loading), and in-transit emission sources (including emission from marine vessels on the Fraser River).

Levelton has reviewed the AQA and, based on their understanding of the proposed amendment, determined that the following areas of the report will require further analysis:

• Source Emissions Estimation

• The key revisions will reflect the differences in the project components associated with the change from abarge loader to a ship loader, vessel emissions, and additional mitigation measures implemented for FSD’sagricultural goods handling operation.

• Modelling Methodology

• Revisions will reflect the differences in the project components associated with the change from a bargeloader to a ship loader, and changes to FSD’s agricultural goods handling operation.

• Air Dispersion Modelling Results

• Key revisions will reflect the differences in the project components associated with the change from a bargeloader to a ship loader, vessel emissions, and changes to FSD’s agricultural goods handling operation, whichwill be used to assess the potential impacts from emissions.

• In-Transit Analysis

• Revisions of combustion and fugitive dust emissions from transport on the Fraser River will be required toreflect the changes in the project components associated with the change from a barge loader to a shiploader, vessel emissions, and additional mitigation measures implemented for the agricultural goods handlingoperations. The analysis is to be re-conducted to determine potential impacts.

• Combustion Volatile Organic Carbons (VOC) Speciation

• Revisions to this section will be required to reflect the changes to combustion emission sources. The analysisis to be updated for consideration in the HHRA (SNC-Lavalin).

To facilitate an update of the proposed amendment application, Levelton will revise the June 2014 AQA report, and summarize the revisions in a technical memorandum.

Levelton’s scope of work in updating the AQA study will include the following:

• A review of the description of the refinements to the project associated with the proposed amendment;• A review of the extent to which the AQA provides a representative assessment of the potential air quality impacts,

considering the refinements to the project associated with the proposed amendment;• A description and discussion of the refinements to the project associated with the proposed amendment which

are material to the AQA; and,• A review and analysis of the extent to which the potential impacts should be updated, including changes to the

assessment methodology, where applicable.

The original Air Quality Assessment (June 2014), and the scope and rationale documents (April 2015) provided by Levelton Consultants in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 10

4. Marine Risk Assessment – DNV (Det Norske Veritas)

A Marine Risk Assessment was undertaken for the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.

In consideration of the proposed amendment, DNV will undertake a review of the Marine Risk Assessment to review the marine vessel movement and navigation risks associated with the proposed amendment of loading directly to OGVs as opposed to barges. The Marine Risk Assessment will review the navigational impacts associated with changing from barges to OGVs.

DNV has reviewed the Marine Risk Assessment and, based on their understanding of the proposed amendment, identified the following areas of the report that may require further analysis:

• Fraser Surrey Docks LP (FSD) Coal Barge Operations

• This section will be redrafted to accurately describe the Panamax size vessels that are being considered foroperations.

• Methodology and Approach

• The methodology for calculating marine accident risk remains accurate with the exception of the casedefinitions. The cases described in this section are no longer accurate based on the refinements associatedwith the proposed amendment as they describe barge movements. The new cases that are proposed foranalysis will be updated to include OGV movements.

• Risk Model Results

• A new analysis will be conducted for the operations described in the proposed amendment. Because theenvironmental and traffic data for the Fraser River is still valid for the proposed amendment, the incidentfrequency results will be adjusted based on the number of OGV movements.

The traffic data (of vessels not associated with FSD) and the environmental data and assumptions from the original risk assessment will be utilized in the updated assessment. A complete re-model of the study area is not considered necessary due to the fact that the only parameter that would be altered is the number of vessels transiting the Fraser River.

The findings of the Marine Risk Assessment review, as outlined by DNV’s scope below, will be summarized in a technical memorandum. In addition, mitigation measures will be revised to reflect the refinements associated with the proposed amendment to the project.

DNV’s scope will include the following:

• Update the potential vessel accident frequency, consequence and risk from the previous projected activity of640 barge movements to 80 OGV movements, and a range of scenarios in between;

• Linear adjustment of the accident frequency, based on the updated number of vessel movements; and,

• An update to the marine risk assessment based on the updated frequency of OGVs compared to barges.

The original Marine Risk Assessment (September 2014), and the scope and rationale documents (May 2015) provided by DNV in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201511

5. Environmental Management Plan (EMP) – Soleil Environmental Consultants Ltd.

An Environmental Management Plan (EMP) was undertaken on the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.

In consideration of the proposed amendment, Soleil Environmental Consultants Ltd. will undertake a review of the current EMP and, with Fraser Surrey Docks LP (FSD), update the plan where required. The EMP previously prepared for the original permit will be revised to reflect the proposed amendment to the permit to use OGVs.

As part of the review, Soleil Environmental Consultants Ltd. will consider if any of the proposed changes will impact the environment relative to the originally approved permit. For example, it is anticipated that a change to a taller ship loader with a covered telescoping chute will reduce the potential for fugitive coal dust. The proposed relocation of some infrastructure will require the production of new drawings for inclusion into the revised EMP.

Revisions to the current EMP will be completed and a new draft document produced for review, comment and approval by FSD with subsequent submission for review and approval to Port Metro Vancouver.

The original Environmental Management Plan (June 2013), and the scope and rationale documents provided by Soleil Environmental Consultants in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment

6. Water Management Plan – Omni Engineering Inc.

A Water Management Plan (WMP) was undertaken on the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.

In consideration of the proposed amendment, Omni Engineering Inc. will undertake a review of the Water Management Plan (August 2014, WMP) to confirm the relevance of the water management impacts due to the proposed project changes.

The updated Water Management Plan will review:

• Updated wastewater containment area and associated water volumes;

• Re-location and re-sizing of the wastewater settling capacities accordingly;

• Minor modification to the out feed conveyor spill trays; and,

• Review of vessel loading dust mitigation technology strategies.

Results of the WMP review will be summarized in a revised WMP, covering the topics within the scope of work described above.

The original Water Management Plan (August 2014), and the scope document provided by Omni Engineering Inc. in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 12

7. Fire Life Safety Plan – Hatch MottMacDonald

A Fire and Safety Plan was undertaken on the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.

In consideration of the proposed amendment, Hatch Mott MacDonald (HMM) will undertake a review of the Fire and Safety Plan (August 2014) to confirm the relevance of the fire and safety management impacts described to the proposed project changes. Further to this, HMM will conduct a full operational review to update the existing plan as a whole, bringing all aspects of the plan to relevance, and develop a Fire Life Safety Plan.

Review of the Fire and Safety Plan will:

• Undertake a complete revision of the existing Fireand Safety Plan for the proposed coal operations atFSD. The review will take into consideration:

• Planned revisions to the proposed operation(barge loader to ship loader)

• Revised operations of the loading vessels

• Summarize the requirements and regulatoryframeworks for a coal handling facility;

• Describe the hazards and consequent risks; and,

• Detail the planned design mitigation and operationalcontrols contained within the design.

Results of the Fire and Safety Plan review will be summarized in a revised Fire Life Safety Plan, covering the topics within our scope of work described above.

The original Fire and Safety Plan (RKMS, September 2012), and the scope document provided by Hatch Mott MacDonald in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment

8. Spill Response Plan – Fraser SurreyDocks LP

A Spill Response Plan for FSD’s terminal and FSD’s berth corridor was undertaken on the original project design prior to the approval of Permit No. 2012 – 072 by Port Metro Vancouver.

In consideration of the proposed amendment, Fraser Surrey Docks LP (FSD) will undertake an internal review of its existing Spill Response Plan to confirm the relevance of loading dry bulk ocean-going vessels (OGVs) described to the proposed project changes. The review will be led by Fraser Surrey Docks LP Director of Engineering and Terminal Development, with guidance from the Director of Operations and Health and Safety Officers. As FSD is a deep sea marine terminal with over 50 years of experience, no significant impacts or changes are anticipated to the existing Spill Response Plan, though this will be confirmed through a detailed review.

Results of the Spill Response Plan review will be summarized in an updated Spill Response Plan.

The original Spill Response Plan (January 2013), and the scope document prepared by FSD in consideration of the proposed amendment can be found at www.fsd.bc.ca/amendment

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201513

Frequently Asked Questions (FAQs)

1. Why is Fraser Surrey Docks LP (FSD) building a Direct Transfer Coal Facility?

• FSD is a major, multi-purpose marine terminal thatfacilitates shipping of a variety of goods includinggeneral cargo, steel, forest products, agriculturalproducts and containers.

• FSD has the capacity to handle a portion of the38 million metric tonnes of coal that are transportedthrough Port Metro Vancouver annually, and hasbeen permitted to do so following a thorough reviewprocess (completed August 2014).

2. Why is FSD considering applying to amend its existing permit to build a Direct Transfer Coal Facility?

• The proposed amendment would allow FSD to loadcoal directly from the facility to ocean-going vessels(OGVs), reducing the need for barges. OGVs havemore capacity than barges. One loaded OGV cancarry four train loads and the same amount as eightloaded barges.

• The proposed application to amend the existingpermit would have no impact on the permittedvolume of coal shipped through FSD (4 million metrictonnes per annum).

• Due to changes in commercial conditions, FSDanticipates shipping most or all of its volume byOGVs. The use of OGVs would reduce the number ofmarine vessel movements.

3. What changes would the proposed amendment include?

• The proposed amendment would increase thecurrent size and height of the barge loader, allowingfor direct loading to OGVs.

• Use of OGVs would replace most or all barges. Ifapproved, FSD plans to replace all barges by OGVs,but would retain barging as a potential secondaryoption.

• It is anticipated that the use of OGVs would furthermitigate the potential for fugitive dust, as coal wouldbe transported in a closed hatch.

• The conveyance system, receiving pit and rail trackswould be shifted on site to accommodate the largervessel loader.

• The footprint of the loading area would decrease,which may reduce water runoff.

4. Will this change the volume of coal that FSD is permitted to transport through the facility?

• The proposed amendment to the permit would nothave any impact on the amount of coal that FSDis permitted to transport through the facility. Theexisting permit is for 4 million metric tonnes of coal (4MMT) per year, and anything over this amount wouldrequire a new project review.

5. How would the proposed amendment change vessel movements on the Fraser River?

• The proposed amendment would allow FSD to loadcoal directly from the facility to OGVs, reducing theuse of barges and reducing the number of vesselmovements from the original project permit. An OGVcan carry the volume of 4 trains. In comparison, 8barges would be required to carry the same amount(1 ship = 8 barges).

• FSD anticipates shipping coal mostly or entirely byOGVs, while retaining barging as a secondary option.

6. What type of vessels would be used with the proposed amendment?

• Any vessel accommodated at FSD would be inaccordance with current size limitations for the FraserRiver. The ship loader being proposed would be ableto accommodate Panamax class vessels that wouldnot exceed 11.5 metre draft when loaded.

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7. Why is it necessary for the height of the vessel loader to be increased?

• Vessels sit much higher in the water than barges andthe loader must be able to reach over the side of thevessel into the hatch. This height will allow the vesselloader the appropriate reach to load coal directly intothe specific vessel hatch it is loading.

• The vessel loader would require a maximum heightof 36.2 metres to load coal directly into OGVs.By comparison, the gantry cranes used to movecontainers onsite at FSD are 55 metres high with theboom down, and are 82 metres high with the boomup.

8. How does this proposed amendment affect the studies that were completed for the original permit application?

• The following studies (available at www.fsd.bc.ca/amendment) will be reviewed and updated asnecessary with a supplementary technical memo orreport:

• Human Health Risk Assessment (HHRA) –SNC-Lavalin Inc. (Environment & Water)

• Environmental Impact Assessment (EIA) –SNC-Lavalin Inc. (Environment & Water)

• Air Quality Assessment (AQA) – LeveltonConsultants Ltd.

• Marine Risk Assessment – DNV (Det NorskeVeritas)

• Environmental Management Plan (EMP) – SoleilEnvironmental Consultants Ltd.

• Water Management Plan – Omni Engineering Inc.

• Fire Life Safety Plan – Hatch Mott MacDonald

• Spill Response Plan – prepared by Director ofEngineering, Fraser Surrey Docks LP

• The public will have the opportunity to review andprovide comments on the scope and results of thestudies.

• For further information on how toprovide feedback, please visitwww.fsd.bc.ca/amendment

9. What does this proposed permit amendment application mean with respect to the recent wastewater permit application to Metro Vancouver?

• The waste discharge permit application submitted toMetro Vancouver is for a maximum volume dischargerate of 5 litres per second of treated wastewater, andthis would not change as a result of the amendment.Overall, FSD’s treated wastewater would be 9,000tonnes (0.0001%) of the 172 million tonnes of regionalwastewater flowing through the Annacis Islandfacility every year, which includes a number of otherindustrial users, undergoing similar treatment.

• Wastewater from the proposed facility would first betreated onsite and discharged directly to the AnnacisIsland Treatment Facility via Metro Vancouver’s NorthSurrey Interceptor Sewer, which runs directly underthe FSD facility. As such, wastewater would be treatedto meet or exceed Metro Vancouver’s rigorousstandards protecting water quality.

10. How many OGVs currently berth at FSD per year?

• Approximately 275 OGVs called at FSD in 2014.

11. What is being done to reduce coal dust from railcars?

• The coal will be sprayed with a binding agent atthe mine site during loading to railcars. Once therailcars are loaded, a topping agent is applied to thecoal in each railcar. In addition, Burlington NorthernSanta Fe (BNSF) is constructing a re-spray station atPasco, Washington to mitigate dust. This will provideadditional dust mitigation for coal shipments enroute to FSD.

• Although FSD is not responsible for the movementof products by rail, we are working closely with themines and our rail partners to ensure dust mitigationstrategies are consistently applied.

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201515

Reference Documents The following supporting documents for the original project permit are available on the Project Updates page at www.fsd.bc.ca/amendment:

• Direct Transfer Coal Facility Project Application

• Human Health Risk Assessment (HHRA)

• Air Quality Assessment (AQA)

• Environmental Impact Assessment (EIA)

• Phase 1 Community Engagement Summary Report

• Phase 2 Engagement Summary Report

• Marine Risk Assessment

• Coal Transfer Facility Fire Safety Plan

• Preliminary Environmental Management Plan

• Air Dispersion Modelling Assessment

• Spill Response Plan

• Water Management Plan (WMP)

The following supporting documents for the original project permit are available at www.portmetrovancouver.com/en/projects/OngoingProjects/Tenant-Led-Projects/FraserSurreyDocks.aspx:

Decision Documents, including:

• Project Review Report – August 2014

• Environmental Review Decision Statement –August 2014

• Human Health Risk Assessment Third PartyReview (Golder Associates)

• Fraser Surrey Docks Direct Transfer Coal FacilityMitigation Strategy Description

• Backgrounder – About This Project and DecisionProcess

• Port Metro Vancouver Project Review Process

• Human Health Risk Assessment (HHRA)(July 2014)

• Environmental Impact Assessment PublicComments Response Memo

• Documents Referenced in the EnvironmentalReview Decision Statement (includingcorrespondence)

• Environmental Impact Assessment PublicComments Response Memo

• Fraser Surrey Docks Environmental ImpactAssessment Public Agency Comments

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 16

Feedback Form

This feedback form seeks your input regarding the scope of the preliminary studies being undertaken by Fraser Surrey

Docks LP (FSD) as part of its consideration to amend Permit No. 2012 - 072. The proposed amendment would be

made to its existing permit that gives it conditional approval to build and operate a Direct Transfer Coal Facility within

its existing lease area.

1. Human Health Risk Assessment (HHRA) completed by SNC-Lavalin Inc. (Environment & Water).

An overview of the proposed scope of this study can be found on page 7 in this discussion guide and the original

study can be found at www.fsd.bc.ca/amendment

Please provide comments on the proposed scope of the Human Health Risk Assessment (HHRA)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

2. Environmental Impact Assessment (EIA) completed by SNC-Lavalin Inc. (Environment & Water).

An overview of the proposed scope of this study can be found on page 8 in this discussion guide and the original

study can be found at www.fsd.bc.ca/amendment

Please provide comments on the proposed scope of the Environmental Impact Assessment (EIA)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201517

3. Air Quality Assessment (AQA) completed by Levelton Consultants Ltd.

An overview of the proposed scope of this study can be found on page 9 in this discussion guide and the original

study can be found at www.fsd.bc.ca/amendment

Please provide comments on the proposed scope of the Air Quality Assessment (AQA) associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

4. Marine Risk Assessment – DNV (Det Norske Veritas)

An overview of the proposed scope of this study can be found on page 10 in this discussion guide and the original

study can be found at www.fsd.bc.ca/amendment

Please provide comments on the proposed scope of the Marine Risk Assessment associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

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5. Environmental Management Plan (EMP) completed by Soleil Environmental Consultants Ltd.

An overview of the proposed scope of this study can be found on page 11 in this discussion guide and the original

study can be found at www.fsd.bc.ca/amendment

Please provide comments on the proposed scope of the Environmental Management Plan (EMP)associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

6. Water Management Plan – Omni Engineering Inc.

An overview of the proposed scope of this study can be found on page 11 in this discussion guide and the original

study can be found at www.fsd.bc.ca/amendment

Please provide comments on the proposed scope of the Water Management Plan (WMP) associated withFraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 201519

7. Fire Life Safety Plan - Hatch Mott MacDonald

An overview of the proposed scope of this study can be found on page 12 in this discussion guide and the original

study can be found at www.fsd.bc.ca/amendment

Please provide comments on the proposed scope of the Fire Life Safety Plan associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

8. Spill Response Plan – Fraser Surrey Docks LP

An overview of the proposed scope of this study can be found on page 12 in this discussion guide and the original

study can be found at www.fsd.bc.ca/amendment

Please provide comments on the proposed scope of the Spill Response Plan associated with Fraser Surrey Docks LP (FSD) proposed application to amend Permit No. 2012 – 072:

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9. Please provide any additional comments you may have regarding the proposed application to amendPermit No. 2012 - 072:

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DISCUSSION GUIDE | FRASER SURREY DOCKS LP | CONSIDERATION TO AMEND PERMIT NO. 2012 – 072 DIRECT TRANSFER COAL FACILITY | MAY 2015 21

Please submit your feedback form by May 19, 2015.

Fraser Surrey Docks LP (FSD) will consider your input, along with information provided by technical experts, as part of its consideration to apply for an amendment to Permit No. 2012 - 072.

Please provide your contact information (optional):

Name:

Organization (if applicable):

Role: (if applicable):

Address:

Postal Code:

Email:

Phone:

Any personal contact information you provide to Fraser Surrey Docks LP on this form is collected and protected in accordance with the Freedom of Information and Protection of Privacy Act. If you have any questions regarding the consideration to amend Permit No. 2012-072 Direct Transfer Coal Facility or Fraser Surrey Docks LP and/or the information collection undertaken on this form, please contact Fraser Surrey Docks LP at [email protected].

The deadline to submit feedback is May 19, 2015

You can return completed feedback forms:

Online: www.fsd.bc.ca/amendment

By email: [email protected]

By mail: PO Box 2233 Vancouver Main, Vancouver, BC V6B 3W2

For general project information:

www.fsd.bc.ca/amendment

Phone: 604 - 891-1695

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