Dear Sirs,
Thank you for the opportunity to comment on the Draft Terms of Reference ( http://www.ceaa-acee.gc.ca/050/documents/p80054/99854E.pdf ) for the panel that will be charged with conducting a public environmental assessment of the Roberts Bank Terminal 2 Project ( http://www.ceaa-acee.gc.ca/050/details-eng.cfm?evaluation=80054 ). My comments are as follows:
The description of the Project should, as was the case for the CEAA/NEB Joint Review Panel review of the Northern Gateway Pipeline Project, include marine transportation routes as an integral component of the project, equal in significance to the terminal itself. The reason for this expanded definition of the project is that the Roberts Bank Terminal 2 Project would reportedly involve over 1000 additional transits of the Salish Sea annually by container ships. This massive increase in container vessel traffic could have a devastating impact on Southern Resident Killer Whales, an endangered species under Canada’s Species at Risk Act, and whose critical habitat straddles the proposed marine transportation routes for the project. In addition to the increased threat of noise, ship strikes and atmospheric pollution coming from the container ships, a spill of Bunker C fuel oil from any one of these ships could have a catastrophic impact on these orcas, which are a veritable icon of the Pacific Northwest.
I also note with interest that the Draft Terms of Reference for the project review stipulate that hearings should be held in a manner that offers any interested party an opportunity to participate in the environmental assessment. This clause should be clarified so as to define the manner in which interested parties will be allowed to participate in the review. Specifically, interested parties should be allowed to submit Letters of Comment as well as make Oral Statements to the Panel, as was the case for the afore-mentioned Northern Gateway Project review. Moreover, the concept of “interested parties” should be broadly defined , and not restricted to include only those who have proven to the Panel that they might be directly affected by the project. Similarly, the proponent should not ( as was the case with the Trans Mountain expansion project review ) be allowed to comment on individual applications from members of the public and NGOs to participate in the review; this matter should be left entirely to the Panel to decide, based solely on the stipulations of the Terms of Reference.
In addition, the Draft Terms of Reference for the project review propose that public hearings be held in “area(s) in closest proximity to the Project”. Assuming the final Terms of Reference include marine transportation routes as part of the project definition ( as requested above ), then at the very least public hearings should be held in Victoria and the southern Gulf Islands, which are both located along the shipping route which the additional container vessel traffic will travel. Victoria, Sidney and Sooke, taken together, are also the principal base for the Salish Sea whale watching fleet, which could see significant adverse economic impacts should an oil spill wipe out the local killer whale population. Residents of southern Vancouver Island and the southern Gulf Islands should not be forced to travel to Vancouver or other parts of the Lower Mainland in order to have their voices heard. Instead, they should be able to address the Panel in their local communities.
Finally, given the proposed terminal’s close proximity to the US border- not to mention the bi-national nature of the proposed marine transportation route, our American neighbours, including government agencies such as the EPA, should be given ample opportunity to participate in all phases of the public review, for, in the final analysis, this project could affect them almost as much as it does us Canadians.
In short, I would like to see the Terms of Reference for the Roberts Bank 2 Terminal Project public review panel fleshed out, so that the Panel that is eventually appointed conducts a review that is as inclusive and broad as possible, that includes not just the terminal but also the related marine transportation routes, and that involves a broad cross section of the public rather than just a narrow spectrum of those living in close proximity to the proposed terminal.
Sincerely,
Gerald Graham, Ph. D.
Victoria