-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
1
Participant: Vicki Huntington, MLA
Organization (if applicable): Member of the Legislative Assembly
for Delta South General Comments: For completing this form the
following acronyms were used: EISG = Environmental Impact Statement
Guidelines TOC = Table of Concordance Comments on Completeness of
Information in the EIS
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 2.4 TOC pg. 1 Other alternatives to causeway
construction not considered
Volume 1 5.4.2 (p. 5-15) Figure 5-5
Other alternatives to the causeway design, such as a suspension
bridge to minimize impact on ecologically sensitive tidal flats. If
not other alternatives, a thorough explanation of why other
alternatives were not considered.
As this will be one of the projects major impacts on an
ecologically sensitive area, more alternatives should be
considered. E.g., a suspension bridge design now exists for the
terminal design at Lulu Island (Pacific Northwest LNG) in order to
minimize effects on eelgrass and fish habitat. The environmental
conditions in Roberts Bank are similar, yet there appears to have
been no consideration of such a possibility.
EISG - section 2.4 TOC pg. 1 Lack of evidence to support choice
in terminal construction
Volume 1 5.4.1.3 (pg. 5-14)
A more detailed description on why other alternatives to the
construction of the terminal were discarded.
The construction of the terminal itself is the largest impact on
the marine environment. While the proponent has considered the
possible use of a floating structure and a pile and deck structure,
they do not give adequate evidence as to why these options were
discarded.
EISG section 2.4 TOC pg. 1 Inadequate
Volume 1 5.4.2 (pg. 5-15)
A more detailed explanation on why the elevated structure option
for an expanded causeway was discarded.
The proponent argues that the overall construction costs made
the elevated causeway option not viable but gives no further
explanation on what those costs were or how much they differed
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
2
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
explanation for why elevated causeway option was discarded.
from the preferred option. The proponent should include data to
support this position to improve the credibility of the EIS.
EISG section 3.1 TOC pg. 2 Lack of detail for approach
channels.
Volume 1 4.1, 4.2.1, 4.2.3 (pg. 4-1 to 4-16) Fig 4-4 Fig
4-26
More detail is needed on the maps showing the approach channel
for the marine terminal. More detail is also warranted in the
description of the approach and exit channels.
This is a clear requirement of EIS guidelines. The included
figures and description do not provide enough detail.
EISG section 3.1 TOC pg. 2 Question on the construction
schedules.
Volume 1 17.1 (pg. 17-2)
Explanation of whether or not terminal construction and widened
causeway construction will also only occur in the scheduled windows
of time in order to minimize the impact on salmon and crabs.
The proponent says it will follow this practice for the dredging
occurring for the project, but it does not discuss fill operations
in this context. There needs to be clarification or a reference in
the table of concordance to where this information can be found in
the EIS.
EISG Section 3.2 TOC - pg. 3 The scope of assessment does not
clearly highlight what effects will extend beyond the scope of the
project.
Volume 2 8.1.3, 8.1.1 (pg. 8-1 8-12)
A clearer description and explanation of what possible effects
will extend beyond the scope of the project. Or a reference to
where this information can be found in the EIS.
This is a clear request from the EIS guidelines and has not been
adequately addressed in these two sections. There is nothing
written on what the actual effects will be or where the reader can
find this information. The section needs to include a reference to
where this information can be found and the table of concordance
needs to be updated.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
3
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Section 3.2 TOC pg. 3 The scope of the assessment does not
clearly indicate what the significance of effects will be.
Volume 2 8.1.7-8.1.9 (pg. 8-18 8-21)
A reference to other areas of the report that answer the EIS
guideline requests.
These sections of the EIS do not clearly indicate where the
actual significance of effects can be found. The process is
outlined in detail but the results are not referred to.
EISG Section 3.2 TOC pg. 3 The scope of the assessment is
lacking in detail on mitigation measures.
Volume 2 8.1.6 (pg. 8-18)
A reference to other areas of the EIS that answer the EIS
guidelines and a modification of the table of concordance.
According to the table of concordance, the reader should be able
to find the mitigation measures that are technically and
economically feasible. This section simply states they were
considered but gives no detail as to where the reader can find that
information. The section needs to include a reference to where this
information can be found and the table of concordance needs to be
updated.
EISG Section 3.3.1 TOC pg. 4 Some valued components (VC)s are
missing.
Volume 2 Table 8-2 (pg. 8-10) Appendix 8-B
More species need to be included in the sub-component section of
Marine Invertebrates.
There are many species of crab that local First Nations harvest
that are not solely Dungeness Crab. In addition there is no mention
of the potential for sea cucumber harvesting that could be impacted
from the project. The Valued Component of Marine Invertebrates
should be expanded to include these other species.
EISG Section 3.3.1 TOC pg. 4 It is unclear if valued components
were incorporated after aboriginal consultations.
Volume 2 8.1.2 (p. 8-3 8-11)) Table 8-2 (pg. 8-10)
Refer to consultations with Aboriginal peoples and how those
consultations affected the selection of valued components. A
reference to where this information can be found is necessary.
There is a stated requirement for the EIS to develop its VCs
based in part on public and Aboriginal consultations. This section
of the EIS (as referenced in the table of concordance) does not
show where this information can be found or how it affected the
selection of VCs.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
4
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG - section 3.3.2 TOC Pg. 5 Spatial boundaries
consultation
Volume 2 8.1.3 (pg. 8-11)
More detail on what type of public consultation occurred. Or a
reference to where this information can be found in the EIS.
The guidelines state that the proponent is advised to consult
with government departments and other stakeholders. The details of
what type of consultation occurred and with whom are unclear in
this section. This is a clear requirement that needs further
information, or the section needs to include a reference to where
this information can be found, and the table of concordance needs
to be updated accordingly.
EISG - section 3.3.2 TOC Pg. 5 Inadequate description of project
setting
Volume 2 8.1.4 (pg. 8-15)
More details are needed to address the relevant environmental
effects of the project. Or a reference to where this information
can be found in the EIS.
This section does not reference where the information on the
project setting can be found to address the relevant environmental
effects of the project. The section needs to include a reference to
where this information can be found, or the table of concordance
needs to be updated.
EISG - section 3.3.2 TOC pg. 5 Spatial boundaries for each VC
not clearly identified.
Volume 2 8.1.3 (pg. 8-11) Table 8-3 (pg. 8-12)
Specifics for each Valued Component (VC) in table form of the
spatial boundaries used. Or a reference to where this information
can be found in the EIS.
This section does not clearly indicate what the spatial
boundaries will be for each VC. It states that each VC will have
clear spatial and temporal boundaries but fails to provide any.
This information is either missing or the table of concordance
needs to be updated to reflect where the information can be
found.
EISG - section 3.3.2 TOC Pg. 5 Inadequate information regarding
how spatial boundaries were considered with ATK.
Volume 2 8.1.3 (pg. 8 -11) Table 8-3 (pg. 8-12)
More information on how spatial boundaries are being defined in
relation to Aboriginal traditional knowledge (ATK) as well as
cultural considerations. Or a reference to where this information
can be found in the EIS.
This section does not clearly indicate how the spatial
boundaries have considered Aboriginal traditional knowledge. The
table of concordance references a section that only briefly
references its possibility. This is a clear requirement and should
be addressed. Or this section needs to reference where the
information can be found in the EIS and the table of concordance
needs to be updated accordingly.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
5
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG - section 3.3.3 TOC Pg. 5 Temporal boundaries
consultation.
Volume 2 8.1.3 (pg. 8-11)
More detail is needed on how traditional and community knowledge
has factored into the proponents decision on temporal boundaries.
Or a reference to where this information can be found in the
EIS.
This section does not provide any details on how temporal
boundaries accounted for traditional or community knowledge. This
needs to be addressed or this section needs to include a reference
to where this information can be found, or the table of concordance
needs to be updated.
EISG Section 3.3.3 TOC pg. 5 Inadequate description of temporal
boundaries for temporary worksites
Volume 2 8.1.3 (pg. 8-11)
More details are needed on the specific temporal boundaries for
the decommissioning of temporary worksites. Or a reference to where
this information can be found in the EIS.
This section of the EIS does not reference where more
information on the temporal boundaries can be found. The section
itself provides few details on the various temporal boundaries. The
section needs to include a reference to where this information can
be found and the table of concordance needs to be updated.
EISG Section 4.2 TOC pg. 6 Inadequate description of potential
project effects and mitigation measures to address them.
Volume 2 8.1.5-8.1.8 (pg. 8-16 to 8-19)
More information is needed on both the effects likely to arise
and the mitigation measures that will be applied to the project as
a whole.
This section of the EIS explains how these matters will be
looked at but does not provide any examples or reference to any
other parts of the EIS where the information can be found. The
section needs to include a reference to where this information can
be found and the table of concordance needs to be updated.
EISG Section 4.2 TOC pg. 6 Study strategy and methodology;
Aboriginal peoples
Volume 5 32.2.4.1; 32-31; 27.0; 27-C
A study of crabs discarded for black contamination found under
the shell after cooking, documenting possible causes.
The EIS reports TFN concerns about crab contamination where
black material is found under the shell, its presence not known
until the crab is cooked and cracked open. The proponent examined a
number of crabs, including those with visible black lesions on the
outside of the shell. However, the proponent appears to have only
solicited crabs with visible exterior black material for further
study, not those that were discarded after cooking due to internal
contamination (27-C-64). Furthermore, the
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
6
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
proponents collected crabs from Roberts Bank did not exhibit
abnormal black material internally (27-C-52), and the testing done
therefore did not examine the stated concern. Additional research
should be performed on specimens with internal contamination
identified after cooking, in order to determine if the explanations
of cuticle damage and bacterial contamination hold true for those
specimens. The proponent also notes that it is currently working
with Aboriginal groups to further investigate blackened crab
observations in the Roberts Bank area. This statement indicates the
research is incomplete and the baseline data on crab contamination
is inadequate.
EISG Section 4.2 TOC pg. 6 Study strategy and methodology
Volume 5 32.2.5; Pg. 32-98
Justify the assumption that CRA fisheries regulatory regime,
harvest quotas, and fisheries policies will remain unchanged to
2018.
This assumption is identified as such in 32.2.5, but it is not
justified as required.
EISG Sections 4.3, 3.3.1, 12.1.2 Integration of EA, Aboriginal
and public consultation information; valued components; cumulative
environmental effects
Volume 2 7.3-B-3; 7.3-A-3; 15.3.1
An Agricultural Impact Assessment. Assessment should include
proponents land use plan and the projects effects on the proponents
acquisition of agricultural land for industrial use.
According to the proponent, The Project does not require the use
of agricultural land, therefore an Agricultural Impact Assessment
was not undertaken. The proponents stated requirement for an
additional 2,300 acres of industrial land by 2025 indicates that an
Agricultural Impact Assessment is required. The proponent has
avoided examining an agricultural VC by stating that the project
does not require the use of agricultural land, but residents and
local and provincial government representatives have commented that
agriculture will be affected
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
7
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
as a result of this project, with consequent impacts on bird and
wildlife habitat, food production, and the labour market. Examples
of birds that rely on agricultural lands include dunlin (10-B-44),
American wigeon (10-B-48), herons (15-29), and raptors (15-35).
Agricultural habitat is included in the spatial boundary definition
for coastal birds (15-8), and agricultural receptors are identified
in the HHRA (27-A Appendix B-50). 105 hectares of ALR land are
within the land and water use LAA (26-12). The CEAAs Cumulative
Effects Assessment Practitioners Guide advises proponents to use
professional judgement to achieve an optimum balance between the
minimum required by legislation and ideal goals when determining
the scope of an assessment. The exclusion of agriculture does not
reflect best practices. Furthermore, the EIS guidelines encourage
the proponent to integrate public consultation outcomes into the
consideration and mitigation of environmental effects. It has not
done so in this instance. The concerns raised by the public and
local governments are dismissed by the proponent in its response
that the intermodal yard will not be located upland. However, the
project is inextricably linked to the potential development of
agricultural lands, as supported by the proponents land use plan
and its existing agricultural holdings in Richmond. An Agricultural
Impact Assessment is necessary for this project, which will lead to
incidental activities affecting agricultural land and cumulative
effects on agriculture.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
8
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 4.4.3 TOC pg. 7 Inadequate list of other projects
in the area.
Volume 2 8.1.9.1 (pg. 8-22 to 8-27)
Inclusion of other major projects in the area. Table 8-8 is
insufficient in its current form. The table fails to list the
Wespac/Fortis LNG plant expansion and Marine Jetty project, the
Lehigh Hanson cement expansion, and any projects in Washington
State other than the Cherry Point project.
EISG section 4.5 TOC pg.7 Presentation and organization of the
EIS
Entire EIS
EIS documentation in an unlocked PDF format, and a PDF that
combines all EIS report documents, including appendices but
excluding the executive summary, title page, and figures, in a
single searchable PDF.
According to the EIS guidelines, the proponent must provide
copies of the EIS and its summary in an unlocked, searchable PDF
format. Attempting to combine the numerous pdf documents into a
single document using Adobe Acrobat (in order to simplify keyword
searching of specific issues) results in an error message that the
file is protected. Please enter a Permissions Password. The files
should be unlocked as required, and a master pdf provided, in order
to aid individuals in searching the documentation.
EISG section 4.5 Presentation and organization of the EIS
Volume 2 7.2-B-53
Clarify what footnote 1 in comment 146 is referencing.
It is unclear what is included in the footnote. There is an
extra period before the next sentence, and there is a black line at
bottom of page, but there is no apparent footnote.
EISG Section 6.1 TOC p.9 Inadequate assessment of the
interrelationships between the bio-physical environment and
people
Volume 1 3.3 (p. 3-4)
Provide a more thorough assessment of how the natural
environment, people and communities interact.
There is little on the historical importance of the area, the
importance of tourism that relies on the environment, the fishing
industry, the numbers of birders, farming, etc. This is an
important component of assessing the interactions between people
and the environment. If it is found elsewhere in the EIS a
reference to that section needs to be included.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
9
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 6.1 TOC- pg. 8 Inadequate description of land and
water lot area requirements
Volume 1 3.3.3 (pg. 3-8) fig 3-7
Increased descriptions of the amount of land required both for
permanent and temporary use. Or a reference to where these can be
found in the EIS.
While the land and water component areas are given in table 4-1,
there are no specific details on the land or water that will be
used for temporary purposes. Maps showing the area of the project
(fig. 3-7) should be improved by showing exactly how much land or
water is in each parcel.
EISG Section 6.2 TOC pg. 9 The EIS does not discuss implications
of government policies/initiatives
Volume 1 Appendix 6-B
More information is needed on the implications of the various
government policies, resource management, planning, or study
initiatives pertinent to the project as they relate to the
project.
The EIS guidelines clearly state that the implications of these
policies/initiatives should be discussed, but the EIS fails to do
so. It references policies/initiatives but fails to discuss their
implications. For example, the Federal Bird Conservation Strategy
is only mentioned in the references of section 15 (pg. 15-139). Its
implications are therefore not discussed.
EISG Section 6.4 TOC p.9 Inadequate liability insurance
description
Volume 1 1.3.3.1 (p. 1-8).
Provide a description of what liability coverage will be
included in General Liability and Wrap-up Insurance. Explain what
level of damages are covered by the insurance.
An accident in the ecologically sensitive region of Roberts Bank
could be quite costly and have lasting impacts. The guidelines
state that the EIS needs to include insurance and liability
management related to the project, but there is currently an
inadequate description. General liability coverage is too
vague.
EISG section 7.1 (TOC pg. 10) Failure to include information
about a potential short-sea-shipping warf.
Volume 1 5.4.4.1 (p.g 5-19)
Any information the proponent has in what a future
short-sea-shipping wharf may entail. Its design, construction, and
purpose.
The proponent explains that the Tug Basin location is located
where it is because of the potential of a future short-sea-shipping
wharf (pg. 5-19). This indicates that the project could be extended
off the western side. As such the information around that possible
extension should be included.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
10
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 7.1 TOC pg. 11 Major future infrastructure project
not included.
Volume 1 Figure 4-1
The map should be expanded to include the Massey Tunnel and the
future Massey Tunnel Replacement Project.
The Massey Tunnel replacement project is a major infrastructure
project that is significant to the flow of traffic in the region
and thus, significant to the operation of the port and transport of
goods in the region. It should be included on this map and its
implications assessed.
EISG Section 7.1 TOC pg. 10 Inadequate cargo traffic
descriptions
Volume 1 Figure 4-28, 4.4.2, Appendix 4-D
A more thorough description of cargo traffic that will be
passing through RBT2.
The EIS guidelines ask that cargo traffic (including type,
tonnage, and storage time in the terminal for goods handled) be
described. In reviewing these sections there is little information
on the type of goods and storage time anticipated in these
sections. This needs to be addressed or the section needs to
include a reference to where this information can be found and the
table of concordance needs to be updated.
EISG Section 7.2 TOC pg. 12 Inadequate description of
post-construction clean-up and on-site grounds reclamation
Volume 1 4.4.1 (pg. 4-19)
Information on how post-construction clean-up will occur
including timelines and processes. Information on how on-site
grounds reclamation will occur, particularly for temporary
construction infrastructure.
There are no details in how on-site ground reclamation will
happen or what it will consist of in this section. This is
particularly important for temporary construction infrastructure
that will be decommissioned. This needs to be addressed or the
section needs to include a reference to where this information can
be found and the table of concordance needs to be updated.
EISG Section 7.2 TOC pg. 12 Inadequate description of how
project activities could affect wetlands
Volume 3 17.3 (pg. 17-5)
Details on what the wetland ecological function assessment will
entail and when it will occur.
The proponent claims that there is no need for a Wetland
Compensation Plan with this project and instead notes that it will
do a wetland ecological functions assessment. In fact, the
assessment is necessary to see if there is a need for a Wetland
Compensation Plan. That there is no Wetland Compensation Plan seems
to be a significant omission. The proponent does not give adequate
information surrounding how the assessment will be conducted, or
its timeline.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
11
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Section 8 (TOC- p.13) Lack of definition or criteria for
technically and economically feasible,
Volume 1 Section 5.2.1, 5.2.2 (pg. 5-3 to 5-4)
Define technically and economically feasible for each
alternative means. Provide the actual criteria (i.e., data,
statistics, graphs, professional comments, etc.) for the public in
determining the economic and technically feasible alternative means
and how they apply and dont apply for each alternative means.
Each alternative means does not go into enough depth for how
they are or are not technically or economically feasible. A
concrete definition or criteria would be appropriate for the public
to understand why an alternative means was discarded.
EISG Section 8 (TOC pg. 13) Lack of comparison of effects
between alternatives to RBT2.
Volume 1 Section 5.3, 5.4, 5.5 (pg. 5-3 to 5-26)
Provide a comparison of the effects or impacts that would be
caused by the alternatives to the project.
It is crucial for the proponent to include comparison charts of
all the effects that could occur from the nine alternative means
provided, in order to fully appreciate the scope of each respective
possibility. The EIS guidelines ask for a comparison of the effects
between the project and any alternative means, but alternative
means are currently written off before any comparison on the
effects is given.
EISG Section 8 Inclusion of other VCs in consideration of
alternative means.
Volume 1 Section 5.6.1 (pg. 5-27)
Provide the other ten VCs in the analysis of the alternative
means of carrying out the RBT2 project.
There are 16 key valued components and it is inappropriate and
inadequate to simply consider only six of those VCs. The VCs
mentioned in the EIS include: coastal birds; human health,
including noise and air quality intermediate components; marine
fish; marine invertebrates; marine mammals; and marine vegetation.
The proponent mentions that leaving out the other VCs does not
diminish their importance within the main Project assessment. Since
this is a major project with many cumulative effects, the other VCs
should be included in the effects criteria for identifying the
effects of technically and economically feasible alternative means
of carrying out the project.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
12
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Section 8 (TOC pg. 13) Alternatives to RBT2 not
discussed.
Volume 1 Section 5.3 (pg. 5-4 to 5-11)
Provide studies on Port Albernis Transshipment Hub (PATH) as an
alternative to the project. Or give a thorough explanation of why
it was not included as part of an alternative means of carrying out
the project. In Appendix 7.2-B the proponent simply states it is in
the early stages of proposal and thus is not considered. This is
not sufficient as the project could substantially change the
dynamics of container flow in the region.
Port Alberni and its potential as a regional trade hub is only
mentioned in passing in an appendix. The PATH project could impact
the forecast predictions that underpin the need for the project.
The city of Port Alberni is serious in its bid to be a new regional
container hub. They have sent delegations promoting the idea to
various ports and municipalities.
EISG Section 8 (TOC pg. 13) Alternatives to RBT2 not
discussed.
Volume 1 Section 5.3, 5.4, 5.5 (pg. 5-3 to 5-26)
Provide studies on Ashcroft terminal as a viable alternative to
the project. Or give a thorough explanation of why it was not
included as an alternative means of carrying out the project. The
description given for why it was not included found in Appendix
7.2-A is insufficient. There is no discussion of how the project
could change the dynamics of container flow and reduce the
forecasted demand which underlies this project.
The Ashcroft Inland Terminal is a serious project that aims to
restructure the flow of container goods passing through the Lower
Mainland. It has support from a wide array of public officials and
strong community support. If the Ashcroft project moves forward it
could substantially change the dynamics of forecasted container
demand; consequently, it deserves a stronger explanation.
EISG Section 8 (TOC pg. 13) Inadequate explanation of why
Deltaport expansion not considered.
Volume 1 Section 5.3.1.1 (pg. 5-5)
Provide a more thorough explanation of why additional expansions
of Deltaport were [not] considered feasible whereas the project is
a preferred means despite concern of environmental effects.
According to the EIS (pg. 5-5), No additional expansions were
considered feasible as early feedback from regulatory agencies on
the potential environmental effects of a Deltaport Terminal
expansion within the inter-causeway area suggested that the
potential environmental effects were unacceptable by regulators. An
explanation of how these effects were more detrimental than the
current RBT2 proposal is warranted.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
13
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG - Section 8 (TOC- pg 13) Alternative sand storage areas
Volume 1 5.5.2 (pg. 5-22)
More detailed information on why other alternative locations
were not considered for temporary sand storage.
Only one possible sand storage alternative location was
identified and then discarded as it was too small. The EIS should
explain why alternative locations were not considered and whether
or not there is a possibility of a floating storage system.
EISG section 9.1.1 TOC pg. 14 Unable to find a map of the
ecological land classification used.
Volume 3 Section 11 (pg. 11-1 to 11-125)
An explanation of how the process of ecological mapping of
aquatic vegetation was incorporated into the EIS. An exact
reference to where the ecological mapping of aquatic vegetation
types can be found is needed.
In searching through this section a map showing ecological land
classification was not found. A reference to where this mapping can
be found is needed as it is a clear requirement of the EIS
guidelines.
EISG section 9.1.1 TOC pg. 14 Unable to find a map of the
ecological land classification used
Volume 1 Section 3.0 (pg. 3-1 to 3-12)
An explanation of how Terrestrial Ecosystem Mapping was used in
the EIS. An exact reference to where this use of Terrestrial
Ecosystem Mapping can be found is needed.
It is unclear if the proponent used Terrestrial Ecosystem
Mapping as was required in the EIS guidelines. An exact reference
to where the reader can see this use of Terrestrial Ecosystem
Mapping is needed.
EISG Sections 9.1.1, 18.1 Methodology
Volume 5 32.2.4.2; pg. 32-46
Data on the habitat of qmin and the projects likely effects on
qmin if it occurs within the LAA or RAA.
The Musqueam First Nation reports that qmin is only available in
the Musqueam study area. The EIS does not comment on the habitat of
qmin or the projects likely effects on qmin. According to the EIS
guidelines, marine and terrestrial vegetation at regional and local
scales should be defined.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
14
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 9.1.2 TOC pg. 15 Missing compounds of potential
concern.
Volume 2 Section 9.2.4.1 (pg. 9.2-6)
The inclusion of other forms of sulphur oxides (rather than just
sulphur dioxide) in the list of contaminants. Or a rationale for
why other sulphur oxides are not included.
The EIS guidelines specifically note SOx as a set of
contaminants to be included. However the proponent only includes
the use of one SO2.
EISG section 9.1.2 TOC pg. 15 Emissions sources not included in
Air Study Modeling.
Volume 2 9.2.6 (pg.9.2-1 to 9.2-80) Appendix 9.2 A
Inclusion of other major sources of air pollution and
contaminants in the assessment of current and future air
quality.
The EIS did not include major sources of emissions in the
regions such as the HeidelbergCement plant and the Fortis gas
plant. Both of these projects are also planning expansions that
could impact overall air quality but neither are accounted for in
this assessment.
EISG section 9.1.2 TOC pg. 15 Air quality, noise, lighting and
climate
Volume 1 1.3.3.2; Pg. 1-11
Provide a cross-reference to an up-to-date resource for current
and past noise levels at Roberts Bank.
The EIS refers to live online noise monitoring that is available
to the public. The EIS notes that the Delta monitors are not
streaming live as of March 1, 2015. These are the most relevant
monitors to the T2 expansion project. In lieu of live streaming, a
cross-reference to a resource where current and past noise levels
at Roberts Bank are available should be provided.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.5A
A complete analysis for all subjects for those waters and marine
beds south of the ferry causeway and adjacent to Point Roberts,
USA.
The Guidelines require a sediment transport model for the
regional and local project areas. The existing port and causeway
divert the Fraser River plume away from these areas. The diversion
will be exacerbated by the proposed RBT2. These waters and marine
beds are part of the southern Roberts Bank and the shoreline,
sediment transport, marine vegetation and habitat value have been
visibly impacted over the long term.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
15
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.5A Section 4.1
Examination of bed shear stress and surface sediments on the
tidal flat south of ferry causeway and adjacent to Point Roberts,
USA.
The guidelines require regional modelling and proposed RBT2 will
have a further long term impact on fate of sediment.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 9.5.6 9.6.6
Proponent should do multi-seasonal baseline survey of
bathymetry; tides and currents; velocities; waves; other
hydrodynamic process; sediment transport and erosion patterns,
including long shore drift and sediments sinks of waters and marine
beds south of the ferry causeway and adjacent to Point Roberts,
USA.
The guidelines require data for regional as well as local areas.
Regional data is missing.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 1 9.5.5.2 (pg. 9.5-7) Appendix 9.5A
Proponent should show sediment characteristics both between and
south of causeway and a discussion of long term impacts.
RBT2 likely to further influence this area. Proponent notes a
diminished influence from the Fraser River plume. That plume has
been diverted by existing terminal. The cumulative impacts of RBT2
should be noted and explained in this context.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A (pg. 37)
An assessment on the implications of having higher amounts of
arsenic and copper than the CCME guidelines suggest.
While the report notes that the concentrations of
2-methylnaphthalene exceed the CCME ME ISQG guidelines, there is no
discussion on the implications of this phenomenon. How will the
project impact current levels?
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
16
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A (pg. 47)
An impact assessment of the reduction in the deposition of silt
and clay in the inter-causeway area, and south of the ferry
causeway, and an analysis of how this project will impact on future
deposition of silt and clay in that area.
The proponent notes that there is less potential for the
deposition of silts and clays from the Fraser River due to the
existing causeways. The project is likely to exacerbate that
effect. An impact assessment highlighting how sediment deposition
in the area has changed due to the two causeways and how the impact
of this project will likely exacerbate the change.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A (pg. 50)
An assessment of observed decreases in the percentage of sand
adjacent to Roberts Bank Terminals. An environmental analysis of
how this loss of sand has impacted the environment.
The proponent notes the decrease in sand is consistent with
scouring effects from current regimes as influenced by the
terminals. The proponent should explain the environmental impacts
that this decrease of sand has caused in the area and explain how
the project could exacerbate this trend.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A (pg. 50)
An assessment of the long term impact of the decrease in fines
in the inter-causeway area.
The proponent notes an overall increase in percent sands and
decrease in percent fines in inter causeway area may have arisen as
a reflection of the lower delivery of fines resulting from
construction of causeway. The long term impacts of this change
should be characterized as per EIS guidelines.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A (pg. 81)
An assessment of why the PCB concentrations were much higher in
the Roberts Bank area than in the Georgia Straight a decade
ago.
The proponent notes that the higher findings of PCB
concentrations, in comparison to previous samplings, were probably
attributable, in part, to the closer proximity to the mouth of the
Fraser. This is not a suitable assessment of why PCB concentrations
are higher and what this could mean for changing trends in the
local study area.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
17
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A Section 5.0 (pg. 82)
Water quality studies for regional and local areas south of
ferry terminal and Point Roberts, USA.
EIS guidelines require a regional and local area survey at a
minimum. To omit areas south of ferry terminal in all evaluations
is a failure to observe guidelines.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A Section 5.5.1 (pg. 92)
Data on salinity south of causeway and into Point Roberts,
USA.
EIS guidelines require a regional and local area
characterization of salinity. This is not done outside of the local
study area.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A Section 5
Assessment of impacts of differences in water column north of
terminal and that of the inter causeway area. Similarly, water
column analysis should be undertaken south of ferry terminal and at
Point Roberts, USA
EIS guidelines require a regional and local area
characterization of water columns. This is not done outside of the
local study area.
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A
A cumulative impact assessment of how the existing terminal has
impacted mudflat growth and deterioration as well as an assessment
of how the project will impact mudflat trends.
One third of Roberts Bank has been altered by the Deltaport
diversion of the Fraser River plume. The diversion will increase
with RBT2. Guidelines require analysis of long term fate of
sedimentation.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
18
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG 9.1.3 TOC pg. 15 Coastal Geomorphology
Volume 2 Appendix 9.6A
More data and a more thorough assessment of tidal flat
erosion.
EIS requires characterizations of hydrology and sediment
regimes. The impact of RBT2 will be greatest on the tidal flats and
a complete assessment of the impact on productivity and receiving
environment should be required.
EISG section 9.1.4 TOC pg 16 Insufficient description of
invasive plant species.
Volume 3 11.2.1 (pg. 11-5)
A more thorough description of English cordgrass as well as a
description of other non-native eelgrass species. A summary that
there are no other invasive plant species (if that is the case)
should also be provided.
The EIS guidelines note that the EIS should include a
description of invasive plant species. Only one species is
mentioned and its description is minimal.
EISG section 9.1.4 TOC pg. 16 No locations given for the sources
of groundwater discharge and recharge areas.
Volume 2 9.1.2 (pg. 9.1-11)
The actual location of groundwater discharge and recharge
areas.
The EIS guidelines ask for the locations of discharge and
recharge areas; however, the EIS simply describes the process and
fails to give any actual locations.
EISG section 9.1.4 TOC pg. 16 A description of groundwater flow
patterns and rates is missing
Volume 2 9.1.2 (pg. 9.1-11
The rates of groundwater flow in the region. A clear requirement
of the EIS guidelines is for a description of groundwater flow
patterns and rates. The patterns are generally described (although
not in much detail) and there is no information on the actual rate
of flow provided.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
19
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 9.1.5 TOC pg. 17 Migration routes not clearly
indicated or mapped.
Volume 2 & 3 9.5.6, 11.5 (pg. 9.5-1) (pg. 11-11 to 11-45)
Figures 11-2, 9.5-13
Maps highlighting the migration routes for fish in the area.
These sections did not provide a map indicating migration routes
for fish as the EIS guidelines ask for. There needs to be a
reference as to where this information can be found.
EISG section 9.1.5 TOC pg. 16 Inadequate attention paid to the
Cohen commissions findings.
Volume 3 13.2.1 (pg.13-7).
The findings of the Cohen Commission need to be more thoroughly
incorporated into the description of the baseline salmon population
and associated habitat.
The EIS guidelines specifically note that particular attention
should be paid to the findings of the Cohen Commission. The EIS
references it only in passing.
EISG section 9.1.5 TOC pg. 17 Inadequate description of
predator-prey interactions for identified fish populations.
Volume 3 12.5, 13.5, 14.5 (pg. 12-12 to 12-31) (pg. 13-20 to
13-60) (pg.14-23 to 14-43)
A more thorough description of predator-prey interactions for
fish populations in the area. Particularly during spawning or
juvenile stages.
These sections of the EIS do not give a description of
predator-prey interactions (except for killer whales and sea
lions). More is needed to satisfy the EIS guideline
requirements.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
20
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Sections 9.1.5, 9.1.8 TOC pg. 17, 19 Fish and fish habitat;
Aboriginal peoples
Volume 5 32.2.4.2; Pg.32-48; 17-C-3
Separate sections, statements, and/or data addressing the
projects likely effects on sea urchin and sea cucumber populations
and current and potential harvesting. Where effects on sea urchins
and sea cucumbers are currently anonymized under the category
epifaunal grazers, specific information for sea urchins and sea
cucumbers should be identified.
The Musqueam First Nation state that for any and all resources
currently unavailable, there is a desire to harvest these resources
again. Musqueam have also stated that forced changes in diet, for
example as a result of food avoidance, may be a contributing factor
in the overall health of community members. There is no readily
available information on the current status of sea urchins and sea
cucumbers in the report, or the projects likely effects on the
same, despite the Musqueam First Nations stated interest in
harvesting these species. Where information is present, it is
lumped into the category epifaunal grazer, making it difficult to
determine the projects effects on sea urchins and sea cucumbers
specifically. There appears to be no consideration of changes to
harvesting potential and consequent socio-economic effects related
to sea urchin and sea cucumber populations, despite the stated
potential decrease in epifaunal grazer biomass.
EISG Section 9.1.5 TOC pg. 17 Fish and fish habitat
Volumes 3 & 5 32.2.4.2; 32.2.4.10; 16.6.1.2; (pg. 32-95;
16-44)
A description of the lifecycle and key habitat features of
groundfish, with a particular focus on dogfish and ratfish. A
detailed explanation of how the project will affect the populations
of these two species and the mitigation measures that could be
used.
The EIS notes that the project is expected to negatively impact
the productive potential of groundfish. The Musqueam express a
desire to catch ratfish and dogfish; the Tsawwassen First Nation
harvests dogfish; and the Hwlitsum report past or present fishing
of dogfish in the project area. The desire to harvest/continue
harvesting ratfish and dogfish by three First Nations should ensure
that the EIS includes the projects expected effects on these
species and a description of their habitat. Very little information
is provided on these two species in the EIS.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
21
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG- Section 9.1.5; 9.1.8 (TOC pg. 17, 19) Fish and fish
habitat; Aboriginal peoples
Volume 5 32.2.4.2 (pg. 32-52)
Identify effects of existing projects on whales feeding habits
and respond to Musqueam First Nations statements about changes in
whales feeding habits.
The Musqueam First Nation says whales cant access Roberts Bank
to feed properly. The effects of existing projects on whale feeding
habits should be clearly identified in response to the stated
concerns, with identified mitigation measures as needed.
EISG Section 9.1.6 (TOC pg. 17) Birds, wildlife and their
habitat
Volume 3 15.7.2 (pg. 15-77)
Characterization of the way existing artificial light affects
bird distributions at the project site.
Some of the sub-headings addressing artificial light (e.g.,
minimising effects from artificial light) do not mention how those
issues affect bird distributions at the project site.
EISG Section 9.1.6 (TOC pg. 17) Birds, wildlife and their
habitat
Volume 3 10.1 (Pg. 10-2)
Statistics on the usage levels of Blue- and Red-listed
terrestrial wildlife species mentioned.
Occasional use by these species is not defined. The EIS
guidelines require a characterization of other wildlife and their
habitat that could be impacted by project activities using existing
data, supplemented by surveys as appropriate. No data on their
usage levels are provided, making it impossible to corroborate the
proponents conclusions.
EISG Section 9.1.6 (TOC pg. 17) Birds, wildlife and their
habitat
Volume 3 Appendix 15-A (Pg. 10-2; 10-3; 10-4)
A list of all potential or known species at risk that may be
affected by the project (flora and fauna).
The list provided in appendix 15-A only includes bird species.
The Pacific water shrew and the northern red-legged frog are
identified as occasional users of land potentially affected by the
project. Six marine mammal and four marine fish species at risk are
identified elsewhere as well. According to the EIS guidelines, they
must be included in a master list of all species at risk that may
be affected by the project.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
22
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Section 9.1.6 (TOC pg. 17) Birds, wildlife and their
habitat
Volume 3 11.5.4.4 (pg.11-32)
A quantitative study of the consumption of biomat by
waterfowl.
Data on the consumption of biomat by waterfowl are necessary to
establish the importance of biomat and the consequences of any
project effects.
EISG Section 9.1.6 (TOC pg. 17) Birds, wildlife and their
habitat
Volume 3 11.5.5.3; 11.6.3.5; (pg. 11-37; 11-81)
Large-scale field study or similar to improve determination of
the projects likely effects on biofilm.
The proponent states that biofilm is resilient and able to
return to a highly productive assemblage once optimal conditions
return, but adds that there is no precedence to support the
predictions made about the projects effects of biofilm because
there are no observed effects of similar projects. This information
gap has large implications for determining the significance of the
projects environmental effects.
EISG Section 9.1.7 TOC pg. 18 Human environment
Volume 4 26.5.3.2; 26.5.4.2; 26.6.4; 26.7.4
The projects effects on the Roberts Bank WMAs existing
management objectives.
The proponent states that the effects on activities in the
Roberts Bank WMA will be limited, because Other areas of the WMA
are available for users; marine access to the northern portion of
the WMA will be available; and activities currently take place
within the WMA despite the existing terminal activities. The
proponent has not adequately justified its assumptions or provided
detailed information on the current management objectives of the
WMA and how each may be affected.
EISG Section 9.1.7 TOC pg. 18 Human environment
Volume 4 24.5.4.1 (pg. 25-18)
Data on the level of trail use for walking, running, and cycling
within the LAA and RAA.
The number of recreational users within the LAA and RAA
determines in part the magnitude of the projects effects on
recreation. The level of use for other recreation activities (e.g.,
hunting and windsport) are provided.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
23
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Sections 9.1.7; 12.1.2 TOC pg. 18; 28 Human environment;
cumulative environmental effects
Volume 4 27.6.1.4; 3-A (pg. 27-44)
Consideration of how pressures to develop agricultural land
resulting from the project will affect the current use of lands and
resources for traditional purposes.
Section 27.6.1.4 does not acknowledge the proponents stated
desire in its land use plan to acquire 2,300 acres of property to
develop as industrial land. As noted elsewhere in the EIS, a high
percentage of Delta land is ALR land. Agriculture is considered to
be an activit[y] contributing to existing conditions (3-A 2).
Agricultural lands surrounding the project were historically
included in plans for Port development, and it is reasonably
foreseeable that the project would lead to development on these
lands. According to the CEAAs Cumulative Effects Assessment
Practitioners Guide, Best practice suggests that effort should be
made in identifying actions if there is reason to believe they may
occur, yet are not overly hypothetical. The industrialization of
2,300 acres of land is a reasonably foreseeable incidental effect
that will alter the current use of lands for food.
EISG Section 9.1.7 TOC pg. 18 Human environment
Volume 4 20.6.4.1 (pg. 20-40)
The economic development effects assessments consideration of
potential project-related effects should include likely pressures
on agricultural lands as a result of project.
The proponents discussion of Potential Effect #3 Consistency
with Economic Development Plans references the Metro Vancouver
Regional Growth Strategy, 2011. That document includes Strategy
2.3, Protect the supply of agricultural land and promote
agricultural viability with an emphasis on food production. The
proponent should discuss the potential project effect of
industrializing agricultural land in Metro Vancouver to support its
land use plan.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
24
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
9.1.8; 9.1.5; 12.1.2 Aboriginal peoples; fish and fish habitat;
cumulative environmental effects
Volume 5 32.2.4.1; 32.2.4.2; 32.2.4.3; 32.2.4.4; (Pg. 32-35;
32-61; 32-72; 72.2-B-32; 72.2-B-35; 13-8)
An assessment of eulachon within the forage fish sub-component,
and a socio-economic assessment of the projects likely effect on
eulachon recovery, particularly in light of current, past, and
desired harvesting of eulachon in the Roberts Bank area.
The Tsawwassen First Nation believe the project could be a
possible tipping point for eulachon; the Musqueam note
opportunities for harvesting are limited; the Semiahmoo state that
eulachon was a fish species that was once consumed; Tsleil-Waututh
Nation notes that they harvested eulachon; the CNA note that the
area once supported eulachon; and the Hwlitsum report that the
effects of the ferry terminal and contamination in the Roberts Bank
area have affected their ability to harvest eulachon. The EIS must
provide baseline conditions related to socio-economics, physical
and cultural heritage and current use of lands and resources for
traditional purposes. The EIS currently ignores eulachon because of
their rarity in the Roberts Bank area. The cumulative effect of the
project on possible eulachon recovery needs to be considered, given
its socio-economic importance to multiple First Nations. By
comparison, the proponent acknowledges a continued significant
cumulative effect to southern resident killer whales.
EISG Sections 9.1.8; 9.1.7; 9.1.3; 12.1.2 Aboriginal peoples;
human environment; coastal geomorphology, seismic hazard and
geotechnical stability; cumulative environmental effects
Volume 5 32.2.4.1; (pg. 32-42)
A quantitative and qualitative review of the socio-economic
effects of existing and project-related sediment buildup.
The Tsawwassen First Nation says Changes to current flows and
sediment buildup over the past 20 years are the reason that Canoe
Passage has become difficult to transit other than at high tide.
They also report that Canoe Passage has become narrower, meaning
that fewer fishing vessels are able to fish in the area at any one
time. The socio-economic effects of sediment buildup do not appear
to be considered in the EIS.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
25
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG - Section 9.1.8 TC pg 19 Aboriginal peoples
Volume 5 32.2.4.7; 32.3.2.2; (pg. 32-85; 32-140)
A statement on how the project could affect: saltwater and
freshwater interaction; a northerly shift in freshwater; and
biofilm and biomat locations and coastal bird habitat.
The Lyackson First Nation raised these concerns, which are not
acknowledged or addressed in section 32.3.2.2.
EISG - Sections 9.1.8; 9.3; 4.2 Aboriginal peoples; noise and
vibration; study strategy and methodology
Volume 5 32.2.4.7; (pg. 32-86; 32-141)
Reports on the study of noise on Leeyqsun. The Lyackson First
Nation reports an irregular low-frequency noise and associated
vibration at Leeyqsun. They believe the source of the noise and
vibration is from the screws of large vessel traffic. The EIS
reports that noise from the project will not travel that far, and
that the proponent has been working with Lyackson to determine the
source of the noise and vibration. The EIS must contain a balanced
presentation of the issues and a statement of the proponent's
conclusions when the proponents findings differ from traditional
knowledge. The research findings on noise on Leeyqsun should be
included to ensure they support the findings presented in 9.3.
EISG Sections 9.1.8; 12.1.2 Aboriginal peoples; cumulative
environmental effects
Volume 5 32.2.4.7; 32.2.6; 32.2.9; 32.3.2.2; (pg. 32-86; 32-100;
7.2-B-61; 32-122)
The cumulative effects of the project on the quality and
availability of marine resources for asserted and desired use by
Aboriginal peoples.
The Lyackson First Nation reports a change in taste to marine
resources due to existing pollution, and calls the inter-causeway
area a dead zone. The projects role in exacerbating these concerns
is not acknowledged or addressed in section 32.3.2.2. The proponent
says it does not have to assess cumulative effects on the ability
of Aboriginal groups to exercise their asserted or established
treaty or Aboriginal rights (7.2-B-61); only Current Use effects
are listed for the Musqueam First Nation, for example. However, the
guidelines require that Other information or factors of importance
to Aboriginal groups be reflected as necessary. Concerns about how
cumulative effects are applied to impacts to
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
26
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
Rights were raised by at least eight First Nations (7.2-B-61).
Stating that the Project is not expected to contribute to
cumulative effects affecting Aboriginal peoples is
disingenuous.
EISG Section 9.1.8 TOC pg. 19 Aboriginal peoples
Volume 5 32.2.4 (pg. 32-22)
Include statements on Aboriginal peoples reliance on garden
produce.
The EIS must include information on Aboriginal peoples reliance
on country foods, which the EIS notes includes garden produce
(6-4). Garden produce is not mentioned in 32.2.4.
EISG Section 9.1.8 TOC pg. 19 Aboriginal peoples
Volume 5 32.2.4.2; 29-F; (pg. 32-56)
Explicitly include more vessel interactions as an effec[t] of
changes to the environment on Aboriginal peoples.
The Musqueam First Nation reports increasing vessel traffic has
led to more vessel interactions, loss of fishing gear, and safety
concerns. This effect should be explicitly listed as a potential
effect in Appendix 29-F, along with mitigation measures, residual
effects, significance, and cumulative effects.
EISG Section 9.1.8 TOC pg. 19 Aboriginal peoples
Volume 5 32.2.6 (pg. 32-99)
Document the effects of the project on traditional and desired
use of marine resources by Aboriginal peoples.
The EIS must include Other information or factors of importance
to Aboriginal groups. The focus on current use in 32.2.6 ignores
the potential socio-economic effects of the project on Aboriginal
peoples who are looking to engage in new or increased aquaculture
or harvesting practices identified in section 32.2.4, as well as
those who no longer harvest all the marine resources they have
traditionally used due to cumulative environmental effects of
existing projects. The project may affect the availability and
quality of fish and bivalve populations, which could limit
opportunities for Aboriginal peoples looking to engage in
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
27
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
traditional use practices or for those groups who have stated
they would like to engage in new aquaculture projects. The EIS
references harvesting closures due to contamination numerous times,
which are used as a reason not to assess the projects effects on
their current use (32-126). In addition, the EIS reports on what
Aboriginal peoples consider a dead zone. This section should
acknowledge and examine the effects of the project on traditional
and desired use of marine resources.
EISG Section 9.1.8; 12.2.2 TOC pg. 19, 28 Aboriginal peoples;
cumulative environmental effects
Volume 2 & 5 7.2.2.5; 7.2-A-7; 32.2.9; (pg. 8-22;
32-122)
Include the proponents stated intention to acquire and develop
2,300 acres of land for industrial use in the projects cumulative
effects assessments.
The proponent has stated the Vancouver Gateway will need
approximately 2,300 additional acres by 2025 to meet increasing
cargo demand in its land use plan. This acquisition is a reasonably
foreseeable development that should be included in all
considerations of cumulative effects. Other projects included in
the EIS are those that have been publicly announced and for which
information regarding project scope and timing is publicly
available. The intended acquisition of 2,300 acres of land has been
publicly announced, and the scope (2,300 acres) and timing (by
2025) are known as well. Additionally, the Summary of Aboriginal
Group Issues and Interests notes that Aboriginal peoples identified
addressing cumulative effects from the Project and other past,
present, and future (reasonably foreseeable) projects as a key
issue. The proponent says it incorporated TFNs economic development
plans, including a list of projects and associated details for
consideration in the Projects cumulative effects assessment. The
proponent also says it included its own land use plan when
determining upcoming projects (8-22), but it has not included this
significant portion.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
28
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
To cite an example where the environmental effects assessment is
insufficient without its inclusion, the proponent states that the
year 2025 represents the greatest potential change in annual
predicted emissions associated with the Project (9.2-11). 2,300
acres of land in the region are set for acquisition and development
by 2025, for which the stated predictions and cumulative effects
assessments do not account. The land acquisition is not listed as a
reasonably foreseeable project or activity that could contribute to
effects on air quality (9.2-B). The omission of this future
development undermines the EIS. Project construction will not be
completed until 2023, during which time these 2,300 acres of land
will have been acquired to support the project. The EIS is
incomplete in its current form, and this information gap would
prevent the Review Panel from undertaking its technical review.
EISG Section 9.1.8 TOC pg. 19 Aboriginal peoples
Volume 4 27.6.1 (pg. 27-42)
General health conditions and demographics of Aboriginal peoples
and/or updated table of concordance.
The table of concordance indicates that this information,
required by the EIS Guidelines, is included in section 27.6.1.
There is passing reference to effects on Current Use in 27.6.1.4,
but there is nothing about general health conditions and
demographics of Aboriginal peoples in 27.6.1.
EISG Section 9.1.8 TOC pg. 19 Aboriginal peoples
Volume 4 24.5 (pg. 24-10)
Aboriginal peoples recreational uses of the project area.
The EIS guidelines state: With respect to Aboriginal peoples
that might be affected by the project, the EIS will include
recreational uses of the project area. Section 24.5 does not
indicate if Aboriginal peoples participate in the listed
recreational uses, as is required per the table of concordance.
This information appears in large part in Sections 8.0 of
appendices 18-A and 18-B, but only for the Tsawwassen First Nation
and Musqueam First Nation.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
29
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Section 9.2 TOC pg. 20 Potential or established Aboriginal
and treaty rights and related interests
Volume 1 Appendix 7.2-B
Responses from government on key comments and concerns
identified by Aboriginal peoples.
The EIS guidelines note that responses to concerns raised by
Aboriginal peoples are to include government responses, as
appropriate. There are multiple cases in 7.2-B where an issue is
raised and the proponent either defers to the DFO or flags an issue
for the CEAAs attention; no responses are provided for those
issues. These answers should be solicited and included, per the
guidelines.
EISG - Section 10.1.2 TOC pg. 23 Changes to the environment not
fully measured.
Volume 5 Appendix 29-A
More information on the nature of productivity loss for
Migratory Birds. More information on how the project will affect
migratory birds is necessary.
There is little on how the project could impact migratory birds
in other ways than simply productivity loss. There are likely
impacts from light and noise that could affect navigation and
flight patterns. This needs to be discussed in more detail or an
explanation given as to why it is not considered significant.
EISG - Section 10.1.2 TOC Pg. 23 Insufficient detail on the
transboundary changes to the environment.
Volume 5 Appendices 29-B, 29-C
More information on any transboundary effects of the project.
What impacts will be felt in which areas specifically.
The EIS gives no specific areas (other than the proponents
jurisdiction) that might be impacted by this project. It does give
a list of effects that may have trasnsboundary implications but
does not highlight where these effects would occur. Specific areas
with specific impacts should be identified.
EISG -Section 10.1.3 TOC pg. 23 Insufficient explanation of how
visual resources will not be impacted.
Volume 5 Appendix 29-F
More detail on the rationale of why all of the listed effects
have been deemed insignificant, particularly on visual
resources.
It is difficult to believe the daytime visual resources will not
be negatively impacted or significant. Thus a further explanation
must be given as to why the effect will not be significant.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
30
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Sections 10.1.3; 11.1.1; 18.1 Effects of changes to the
environment; methodology
Volume 5 33.0; 32.2.4.3; (pg. 32-59; 32-60)
The likely effects of the project on the marine vegetation
aquaculture potential of the region.
The project could have economic ramifications for the potential
for marine vegetation and shellfish aquaculture. The projects
effects on aquaculture potential should be explored. In particular,
the Semiahmoo are interested in commercial sea asparagus
aquaculture. They have expressed interest in developing aquaculture
and commercial harvesting of sea cucumber. The EIS must describe
the effects of any changes the project may cause to the
environment, with respect to Aboriginal peoples, on socio-economic
conditions. It must also include policies and arrangements directed
at mitigating adverse socio-economic effects.
EISG - section 10.1.4 TOC pg. 23 The QRA was not done for all
potential marine accidents.
Volume 5 30.4 (p.30-12) Table 30-3
A Quantitative Risk Assessment for all vessel movements during
project construction and for vessel-related accidents must be
covered by a QRA.
The EIS guidelines note that the proponent will list and
identify the probability of potential accidents and malfunctions
related to the project. Yet a QRA was not done for certain
marine-based accidents. The rationale for why this was not done is
unclear. This could affect the probability of a vessel grounding in
table 30-3 (if only groundings with a spill factor are
counted).
EISG-section10.1.4 TOC - pg. 23 It is unclear what
well-maintained and regularly serviced indicates for independent
contracted vessels.
Volume 5 30.4.5 (p. 30-21)
The guidelines and rules for what is acceptable to the proponent
in defining well-maintained and regularly serviced. As this is a
precursor of a contractors project involvement there should be more
detail on what this entails.
The probability of an onboard fire or explosion while vessels
are assisting in the projects development is considered to be very
low, but the reason for this categorization is because these
vessels must be maintained and regularly serviced by their
contractors. The EIS should state the guidelines the proponent is
using to classify regularly serviced and well-maintained to allow
the review panel to evaluate them.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
31
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG- section 10.1.4 TOC pg. 23 The spill response plans are not
yet developed.
Volume 5 33.4.7 (p33-19)
Detailed contingency and response plans are needed for accidents
and malfunctions.
The EIS simply states that plans will be developed. It does not
present those plans in any detail as the EIS guidelines
require.
EISG-section 10.1.5 TOC pg.23 Climate change considerations are
not fully addressed.
Volume 5 31.2.6 (pg 3-16)
More information on how climate change may affect the project
and the projects viability into the future.
The EIS devotes two paragraphs to how climate change may impact
the project and (with the exception of sea-level rise) comes to the
conclusion (citing one article) that there are not likely to be any
major or significant changes to related weather conditions. Climate
change is likely to impact numerous environmental conditions, and
it appears to not have been given due consideration.
EISG section 10.1.5 TOC pg. 23 There is a lack of probability
patterns for how the environment will affect the project.
Volume 5 31.2 (Pg 31-1 to 31-18)
The natural events need to be considered in a more detailed
probability pattern. Additionally, an explanation of how repeated
100-year events impact the project is needed.
While the worst case effects of major weather or seismic events
are described and considered, the smaller events that may also have
an impact, particularly over time, do not receive the same
attention. Additionally, the wharf structure and terminal are not
designed to withstand a tsunami event. In the context of climate
change, bigger storms are expected on a more frequent basis. The
EIS should reflect that understanding.
EISG section 11.1.1 TOC pg. 25 Follow-up Program is inadequate
for Orange Sea Pens
Volume 5 Appendix 33-A
The EIS should, in its follow-up program, monitor the
productivity loss for orange sea pens and how effective the
transplant program has been. Currently it appears that there will
only be monitoring of the transplant sites during construction.
The orange sea pen is one of the most affected species of this
project. Thus it would seem that there needs to be an accurate
baseline as well as post-construction follow-up to measure how much
the productivity of the species has been affected.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
32
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 11.1.1 TOC pg. 25 Unclear how the proponent will
ensure the compliance of contractors.
Volume 5 33.0 (pg. 33- 1 to 33-23)
The EIS should note any penalties or fines that may exist to
ensure that contractors and sub-contractors comply with the
commitments made by the proponent in the EIS. Currently there is
only a requirement for contractors to undertake training.
The proponent gives a detailed description of its commitments
and environmental protections that will be in place but fails to
explain the mechanisms that will ensure contractors and
sub-contractors comply with the commitments of the project
proponent. The proponent should explain if contracts will be
terminated if procedures are violated, or if it will administer
fines.
EISG section 11.1.1 TOC pg. 25 System of accountability not
clearly defined.
Volume 5 33.0 (pg. 33- 1 to 33-23)
The EIS should note the responsibilities of the reviewing
agencies and the power they have (e.g., fines, permit withdrawal,
ability to shut down operations).
For example, if the proponent fails to have a prepared EMP
before construction begins, the consequences should be explained.
The reviewing agencies are important third parties that will
presumably ensure the proponent follows the commitments made in the
EI, but the accountability framework should demonstrate to the
reader how the proponent will actually be held accountable.
EISG section 11.1.1 TOC pg. 25 Risk to the environment from a
decimated Sea Pen population.
Volume 3 Volume 5
The potential risks to the environment from a significantly
affected sea pen population need to be explained in far greater
detail.
The orange sea pen is one of the species to be most dramatically
affected by the project. However, little is known about their
ecological role except that they are considered ecosystem engineers
(p.12-28). The transplant program proposed by the proponent is a
good attempt at mitigation, but it is uncertain if it will prove
effective. If the transplant fails, the sea pen population will be
effectively decimated. The EIS guidelines clearly state that the
EIS should provide a clear and concise description of these risks
should the mitigation efforts fail. It fails to do so for this
species.
EISG section 11.1.1 TOC pg. 25 Justification for lack of
mitigation measures.
Volume 3 17.0 Volumes 4, 5
The EIS does not give a range of alternative measures for many
mitigation efforts. It simply describes the mitigation activity or
states that it was not technically or economically feasible (e.g.
subtidal sand flats pg. 17-12).
The EIS clearly states that the trade-offs between cost savings
and effectiveness of the various forms of mitigation will be
justified. Simply stating that a mitigation measure was not pursued
because it was not technically or economically feasible is not
adequate justification.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
33
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 11.3 TOC pg. 26 Summary of public discussions.
Volume Appendix 7.3-A & 7.3-B
Provide the methods used, locations, actual dates, and the
extent to which consultations changed the project designs or
mitigation measures.
These sections of the EIS do not describe the methods used,
provide the locations, or the actual dates of when the discussions
occurred. They also fail to demonstrate how these discussions
directly impacted the proponent: e.g, was the proponent doing these
things anyway, or did they do it as a response to the concerns
raised? This needs to be addressed or a reference to where this
information can be found in the EIS is needed.
EISG section 11.4 TOC pg. 27 Summary of public discussions.
Volume 5 33.5 (pg. 33-20) Appendix 33-A
The Follow-Up Program Document. The EIS alludes to a follow up
program document but does not provide it. It says it will create it
after the EIS has been submitted. However, by doing so it does not
meet the EIS guideline requirements as the follow-up program is not
described in sufficient detail.
EISG Section 12.1.1; 12.1.2 Residual environmental effects;
cumulative environmental effects
Volume 5 32.2.4.6 (pg. 32-80)
The cumulative effects assessment should examine the impact of
the existing terminals, increasing vessel traffic, and over-fishing
on fish populations and First Nation fishing activities.
The Lake Cowichan First Nation identifies these elements as
leading to concerns about interference with their fishing efforts.
It is a clear statement about current cumulative effects impacting
socio-economic activities, which would likely be exacerbated by the
project.
EISG Section 12.1.1 TOC pg. 28 Residual environmental
effects
Volume 3 14.9 (pg. 14-90)
An explanation of the definition of a significant adverse effect
to SRKWs, North Pacific Humpback whales, and Steller sea lions as
one which could jeopardise survival or recovery of the species.
The definition is narrow and should be justified in this
section.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
34
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Section 12.1.2 TOC pg. 28 Project description; cumulative
environmental effects
Volume 5 32.2.4.1 (pg. 32-28)
Proponent should state its intention for parcels beside the
Roberts Bank causeway.
Two parcels beside the Roberts Bank causeway have been
identified for transfer, assignment, or sublease from PMV to
Tsawwassen First Nation in the event they are not required for the
Project. The proponent should clarify its intention for these
parcels as part of the project. Their inclusion or exclusion would
affect the nature of the project and consequent effects on VCs
(e.g., marine fish).
EISG Section 12.1.2 Cumulative environmental effects
Volume 2 8.1.4; 8.1.9 (pg. 8-15; 8-20)
Assess the projects cumulative effects in sections 8.1.4 and
8.1.9, or update the table of concordance.
The projects cumulative effects are not assessed in 8.1.4 or
8.1.9 as indicated by the table of concordance.
EISG Section 12.1.2 Cumulative environmental effects
Volume 1 3.4; (pg.3-4) Appendix 3-A
A narrative description of the historical environmental
conditions prior to the development of the existing causeways (Port
Metro Vancouver and BC Ferries).
The EIS guidelines say The narrative discussion should include
historical data, where available and applicable, to assist
interested parties to understand the potential effects of the
project and how they may be addressed. Furthermore, the CEAAs
Operational Policy Statement on assessing cumulative effects says A
description of past environmental conditions can at times improve
the understanding of cumulative environmental effects. The CEAAs
Cumulative Effects Assessment Practitioners Guide says temporal
baselines can also include the time when a land use designation was
made, or a historical baseline of pre-disturbance conditions. The
brief description of human uses of the region in the 1800s is
insufficient (3-4).
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
35
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG Section 12.1.2 Cumulative environmental effects
Volume 3 14.10; 14-A; (pg. 14-93)
Include Wespac Tilbury Marine Jetty Project in cumulative
effects assessments, particularly for marine mammals.
The proposed Wespac Tilbury Marine Jetty Project would increase
marine traffic on the Fraser River. The project does not appear to
have been included in the cumulative effects assessment of in the
list of projects intentionally excluded from the assessment. It is
of particular importance for inclusion in the assessment of
cumulative effects on marine mammals.
EISG- section 13.1.1 TOC pg. 29 There is no analysis of the
significance of residual environmental effects.
Volume 2 8.1.7 to 8.1.9 (pg 8-18 to 8-21)
Actual analysis of the significance of residual environmental
effects should be provided.
The table of concordance notes that the reader should be able to
find a detailed analysis of the significance of adverse residual
environmental effects. While the process of how a residual effect
was determined to be significant is discussed, no examples are
given. There is no analysis or a reference to where the analysis
can be found in this section.
EISG- section 13.1.1 TOC - pg. 29 It is unclear if the
ecological and social context was adequately implemented.
Volume 2 8.1.7 to 8.1.9 (pg 8-18 to 8-21)
A clearer definition of how the proponent will use ecological
and social context in determining the significance of residual
effects is needed.
The proponent gives a vague understanding of how context will be
used in assessing the significance of residual effects. However,
the EIS guidelines state that the ecological and social context is
one of the primary elements that must be included for reaching
conclusions. Thus, the parameters of the social and ecological
context should be more carefully defined (e.g., the temporal
boundaries used to assess the context).
EISG section 13.1.1 TOC pg. 29The existence of environmental
standards, guidelines, or objectives is not given
Volume 2 8.1.7 to 8.1.9 (pg 8-18 to 8-21)
How existing environmental standards, guidelines, or objectives
of the proponent are a factor in determining the significance of
residual effects. The provision of a list of what standards,
guidelines or objectives were used in this way is necessary.
The proponent is required under the EIS guidelines to
demonstrate how the existence of environmental standards,
guidelines, or objectives will be used to help determine the
significance of residual effects and as well to use those
guidelines/standards/goals for assessing the impact and
implications of any revisions. This section says that they were
incorporated but fails to explain how or reference the section of
the EIS where this can be found.
-
Roberts Bank Terminal 2 Project Environmental Impact Statement
Comments on Completeness
April 30 June 15, 2015
36
Issue (if possible, please
include reference to the relevant section of
the EIS Guidelines)
Reference to EIS
Requested Completeness Information Rationale
EISG section 18.1; 12.1.2 Economic, social, heritage and health
factors; cumulative environmental effects.
Volume 4 26.5.3.1 (pg.26-10)
A consideration of how the Ports intention to obtain 2,300 acres
of land for industrial use by 2025 will affect economic, social,
heritage, and health issues in combination with the Project.
The EIS must include a description of the effects of the Project
on social, economic, heritage and health matters that do not arise
from changes to the environment caused by the Project. The project
will play a central role in the proponents desire to create or
acquire industrial lands as stated in its land use plan. The EIS
guidelines indicate the EIS should examine the cumulative effects
of all c