Vicki Huntington - Comments On EIS Completeness For Roberts Bank Terminal 2

Roberts Bank Terminal 2 Project
Environmental Impact Statement Comments on Completeness

April 30 June 15, 2015
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
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
Rationale

Issue
the EIS Guidelines)
explanation for why
elevated causeway
option was discarded.
Reference
to EIS
Rationale
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.
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.
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.

Issue
the EIS Guidelines)
EISG Section 3.2
TOC pg. 3
The scope of the
assessment does not
clearly indicate what
the significance of
effects will be.
EISG Section 3.2
TOC pg. 3
The scope of the
assessment is lacking
in detail on mitigation
measures.
Reference
to EIS
Rationale
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.
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)
More species need to be included in the subcomponent 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. 8-3 811))
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.
Appendix
8-B

Issue
the EIS Guidelines)
Reference
to EIS
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
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.

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.

TOC pg. 5
Spatial boundaries for
each VC not clearly
identified.

TOC Pg. 5
Inadequate
information regarding
how spatial
boundaries were
considered with ATK.
Volume 2
8.1.3
(pg. 8-11)
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.
Table 8-3
(pg. 8-12)
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
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.
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.

Issue
the EIS Guidelines)
TOC Pg. 5
Temporal boundaries
consultation.
EISG Section 3.3.3
TOC pg. 5
Inadequate
description of
temporal boundaries
for temporary
worksites
EISG Section 4.2
TOC pg. 6
Inadequate
description of
potential project
effects and mitigation
measures to address
them.
EISG Section 4.2
TOC pg. 6
Study strategy and
methodology;
Aboriginal peoples
Reference
to EIS
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.
Rationale
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
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.
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.
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

Issue
the EIS Guidelines)
Reference
to EIS
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.
EISG Section 4.2

TOC pg. 6
Study strategy and
methodology
Volume 5
32.2.5;
Pg. 32-98
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
Justify the assumption that CRA fisheries

regulatory regime, harvest quotas, and fisheries
policies will remain unchanged to 2018.
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.
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.
This assumption is identified as such in 32.2.5, but it is not justified
as required.
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

Issue
the EIS Guidelines)
Reference
to EIS
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.

Issue
the EIS Guidelines)
EISG section 4.4.3
TOC pg. 7
Inadequate list of
other projects in the
area.
EISG section 4.5

TOC pg.7
Presentation and
organization of the EIS
EISG section 4.5

Presentation and
organization of the EIS
EISG Section 6.1

TOC p.9
Inadequate
assessment of the
interrelationships
between the biophysical environment
and people
Reference
to EIS
Volume 2
8.1.9.1
(pg. 8-22
to 8-27)
Inclusion of other major projects in the area.
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.
Volume 2
7.2-B-53
Clarify what footnote 1 in comment 146 is

referencing.
Volume 1
3.3
(p. 3-4)
Provide a more thorough assessment of how the

natural environment, people and communities
interact.
Rationale
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.
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.
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.
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.

Issue
the EIS Guidelines)
EISG section 6.1
TOC- pg. 8
Inadequate
description of land
and water lot area
requirements
EISG Section 6.2
TOC pg. 9
The EIS does not
discuss implications of
government
policies/initiatives
EISG Section 6.4

TOC p.9
Inadequate liability
insurance description
Reference
to EIS
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.
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.
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.
Rationale
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.
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.
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-seashipping 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.

Issue
the EIS Guidelines)
EISG section 7.1
TOC pg. 11
Major future
infrastructure project
not included.
Reference
to EIS
Volume 1
Figure 4-1
The map should be expanded to include the

Massey Tunnel and the future Massey Tunnel
Replacement Project.
EISG Section 7.1

TOC pg. 10
Inadequate cargo
traffic descriptions
Volume 1
Figure 428, 4.4.2,
Appendix
4-D
A more thorough description of cargo traffic

that will be passing through RBT2.
EISG Section 7.2

TOC pg. 12
Inadequate
description of postconstruction clean-up
and on-site grounds
reclamation
EISG Section 7.2
TOC pg. 12
Inadequate
description of how
project activities could
affect wetlands
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.
Volume 3
17.3
(pg. 17-5)
Details on what the wetland ecological function

assessment will entail and when it will occur.
Rationale
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.
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
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.
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.
10

Issue
the EIS Guidelines)
Reference
to EIS
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.
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.
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.
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.
11

Issue
the EIS Guidelines)
Reference
to EIS
EISG Section 8
(TOC pg. 13)
Alternatives to RBT2
not discussed.
Volume 1
Section 5.3
(pg. 5-4 to
5-11)
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)
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 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.
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.
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.
Rationale
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.
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.
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.
12

Issue
the EIS Guidelines)
Reference
to EIS
EISG - Section 8
(TOC- pg 13)
Alternative sand
storage areas
Volume 1
5.5.2
(pg. 5-22)
Rationale
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 q min and the projects

likely effects on q min 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.
13

Issue
the EIS Guidelines)
EISG section 9.1.2
TOC pg. 15
Missing compounds of
potential concern.
Reference
to EIS
Rationale
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.
14

Issue
the EIS Guidelines)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Reference
to EIS
Rationale
Volume 2
Appendix
9.5A
Section 4.1
Examination of bed shear stress and surface

sediments on the tidal flat south of ferry
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
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
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Volume 2
Appendix
9.6A
(pg. 37)
Proponent should show sediment characteristics

both between and south of causeway and a
discussion of long term impacts.
An assessment on the implications of having

higher amounts of arsenic and copper than the
CCME guidelines suggest.
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.
While the report notes that the concentrations of 2methylnaphthalene exceed the CCME ME ISQG guidelines, there is
no discussion on the implications of this phenomenon. How will
the project impact current levels?
15

Issue
the EIS Guidelines)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Volume 2
Appendix
9.6A
(pg. 47)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Volume 2
Appendix
9.6A
(pg. 50)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Volume 2
Appendix
9.6A
(pg. 50)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Volume 2
Appendix
9.6A
(pg. 81)
Reference
to EIS
Rationale
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.
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.
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.
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.
16

Issue
the EIS Guidelines)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Reference
to EIS
Volume 2
Appendix
9.6A
Section 5.0
(pg. 82)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Volume 2
Appendix
9.6A
Section
5.5.1
(pg. 92)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Volume 2
Appendix
9.6A
Section 5
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Volume 2
Appendix
9.6A
Rationale
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.
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.
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.
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.
17

Issue
the EIS Guidelines)
EISG 9.1.3
TOC pg. 15
Coastal
Geomorphology
Reference
to EIS
Rationale
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 nonnative 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.
EISG section 9.1.4
TOC pg. 16
A description of
groundwater flow
patterns and rates is
missing
Volume 2
9.1.2
(pg. 9.111)
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.
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.
18

Issue
the EIS Guidelines)
EISG section 9.1.5
TOC pg. 17
Migration routes not
clearly indicated or
mapped.
EISG section 9.1.5

TOC pg. 16
Inadequate attention
paid to the Cohen
commissions findings.
EISG section 9.1.5

TOC pg. 17
Inadequate
description of
predator-prey
interactions for
identified fish
populations.
Reference
to EIS
Rationale
Volume 2
&3
9.5.6, 11.5
(pg. 9.5-1)
(pg. 11-11
to 11-45)
Figures 112, 9.5-13
Volume 3
13.2.1
(pg.13-7).
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.
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.
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.
19

Issue
the EIS Guidelines)
EISG Sections 9.1.5,
9.1.8
TOC pg. 17, 19
Fish and fish habitat;
Aboriginal peoples
EISG Section 9.1.5

TOC pg. 17
Fish and fish habitat
Reference
to EIS
Volume 5
32.2.4.2;
Pg.32-48;
17-C-3
Volumes 3
&5
32.2.4.2;
32.2.4.10;
16.6.1.2;
(pg. 32-95;
16-44)
Rationale
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.
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.
20

Issue
the EIS Guidelines)
EISG- Section 9.1.5;
9.1.8
(TOC pg. 17, 19)
Fish and fish habitat;
Aboriginal peoples
EISG Section 9.1.6

(TOC pg. 17) Birds,
wildlife and their
habitat
EISG Section 9.1.6

(TOC pg. 17) Birds,
wildlife and their
habitat
EISG Section 9.1.6

(TOC pg. 17) Birds,
wildlife and their
habitat
Reference
to EIS
Rationale
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.
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.
Statistics on the usage levels of Blue- and Redlisted 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.
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.
Volume 3
10.1
(Pg. 10-2)
Volume 3
Appendix
15-A
(Pg. 10-2;
10-3; 10-4)
21

Issue
the EIS Guidelines)
EISG Section 9.1.6
(TOC pg. 17) Birds,
wildlife and their
habitat
Reference
to EIS
Volume 3
11.5.4.4
(pg.11-32)
A quantitative study of the consumption of

biomat by waterfowl.
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)
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.
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.
Large-scale field study or similar to improve

determination of the projects likely effects on
biofilm.
Rationale
Data on the consumption of biomat by waterfowl are necessary to

establish the importance of biomat and the consequences of any
project effects.
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
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.
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.
22

Issue
the EIS Guidelines)
EISG Sections 9.1.7;
12.1.2
TOC pg. 18; 28
Human environment;
cumulative
Reference
to EIS
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.
Rationale
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.
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 projectrelated effects should include likely pressures on
agricultural lands as a result of project.
The industrialization of 2,300 acres of land is a reasonably

foreseeable incidental effect that will alter the current use of lands
for food.
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.
23

Issue
the EIS Guidelines)
9.1.8; 9.1.5; 12.1.2
Aboriginal peoples;
fish and fish habitat;
cumulative

9.1.7; 9.1.3; 12.1.2
Aboriginal peoples;
human environment;
coastal
geomorphology,
seismic hazard and
geotechnical stability;
cumulative
Reference
to EIS
Volume 5
32.2.4.1;
32.2.4.2;
32.2.4.3;
32.2.4.4;
(Pg. 32-35;
32-61; 3272; 72.2-B32; 72.2-B35; 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.
Volume 5
32.2.4.1;
(pg. 32-42)
A quantitative and qualitative review of the

socio-economic effects of existing and projectrelated sediment buildup.
Rationale
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; TsleilWaututh 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.
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.
24

Issue
the EIS Guidelines)
EISG - Section 9.1.8
TC pg 19
Aboriginal peoples
Reference
to EIS
Rationale
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.

12.1.2
Aboriginal peoples;
cumulative
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
25

Issue
the EIS Guidelines)
Reference
to EIS
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
26

Issue
the EIS Guidelines)
EISG Section 9.1.8;

12.2.2
TOC pg. 19, 28
Aboriginal peoples;
cumulative
Reference
to EIS
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.
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.
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.
27

Issue
the EIS Guidelines)
Reference
to EIS
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.
28

Issue
the EIS Guidelines)
EISG Section 9.2
TOC pg. 20
Potential or
established Aboriginal
and treaty rights and
related interests
Reference
to EIS
Volume 1
Appendix
7.2-B
Responses from government on key comments

and concerns identified by Aboriginal peoples.
Rationale
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.
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.

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.

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.
29

Issue
the EIS Guidelines)
Reference
to EIS
Rationale
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.

TOC pg. 23
The QRA was not done
for all potential
marine accidents.
Volume 5
30.4 (p.3012)
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 wellmaintained 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.

11.1.1; 18.1
Effects of changes to
the environment;
methodology
30

Issue
the EIS Guidelines)
EISG- section 10.1.4
TOC pg. 23
The spill response
plans are not yet
developed.
Reference
to EIS
Rationale
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.
EISG section 10.1.5

TOC pg. 23
There is a lack of
probability patterns
for how the
environment will
affect the project.
EISG section 11.1.1
TOC pg. 25
Follow-up Program is
inadequate for Orange
Sea Pens
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.
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 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.
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.
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.
31

Issue
the EIS Guidelines)
EISG section 11.1.1
TOC pg. 25
Unclear how the
proponent will ensure
the compliance of
contractors.
Reference
to EIS
Rationale
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 subcontractors 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 subcontractors 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.
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 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.
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.
32

Issue
the EIS Guidelines)
EISG section 11.3
TOC pg. 26
Summary of public
discussions.
Reference
to EIS
Rationale
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.
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 11.4

TOC pg. 27
Summary of public
discussions.
Volume 5
33.5
(pg. 33-20)
Appendix
33-A
The Follow-Up Program Document.
EISG Section 12.1.1;

12.1.2
Residual
environmental effects;
cumulative
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
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.
33

Issue
the EIS Guidelines)
EISG Section 12.1.2
TOC pg. 28
Project description;
cumulative
Reference
to EIS
Rationale
Volume 5
32.2.4.1
(pg. 32-28)
Proponent should state its intention for parcels

beside the Roberts Bank causeway.
EISG Section 12.1.2

Cumulative
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.
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).
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
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 predisturbance conditions. The brief description of human uses of
the region in the 1800s is insufficient (3-4).
34

Issue
the EIS Guidelines)
EISG Section 12.1.2
Cumulative
Reference
to EIS
Rationale
Volume 3
14.10; 14A;
(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.

TOC pg. 29
There is no analysis of
the significance of
residual
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.

TOC - pg. 29
It is unclear if the
ecological and social
context was
adequately
implemented.
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)
A clearer definition of how the proponent will

use ecological and social context in determining
the significance of residual effects is needed.
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 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).
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.
35

Issue
the EIS Guidelines)
EISG section 18.1;
12.1.2
Economic, social,
heritage and health
factors; cumulative
EISG Sections 18.1;

12.1.2; 9.1.8
Marine vegetation;
cumulative
environmental effects;
Aboriginal peoples
EISG Section 18.1,

9.1.8
Provincial socioeconomic assessment;
Aboriginal peoples
Reference
to EIS
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.
Volume 5
32.2.4.1;
32.2.4.5;
32.2.4.6
(pg. 32-29;
32-74; 3279)
Effects of existing projects on marine vegetation

and baseline information for marine vegetation
prior to the creation of the existing Roberts
Bank terminal.
Volume 1
Appendix
7.2-B-45
Consideration of the effect of increased

container storage on visual resources in Metro
Vancouver.
Rationale
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 current and proposed physical activities, and the CEAAs
Operational Policy Statement on cumulative effects says the EIS is
supposed to provide a complete picture of the potential types
and scale of cumulative environmental effects. The EIS should
examine the effects of this expansion on economic, social,
heritage, and health factors. The current reference to the
proponents land use plan in Section 26.5.3.1 provides insufficient
detail on the relationship between the project and the desired
land acquisition.
TFN states that seaweed once grew all over and was harvested
all along the shoreline and sea asparagus once grew along the
side of the beach. In order to provide suitable baseline data for
the purposes of the EIS and cumulative effects assessment,
information is required on whether or not the seaweed loss was
caused or exacerbated by existing projects. The projects effect on
marine vegetation may have economic and social consequences.
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. This
issue is one such effect that was raised by the Tsawwassen First
Nation and the Hwlitsum First Nation.
36

Vicki Huntington - Comments On EIS Completeness For Roberts Bank Terminal 2

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Roberts Bank Terminal 2 Project

Environmental Impact Statement Comments on Completeness

Participant: Vicki Huntington, MLA

Comments on Completeness of Information in the EIS

Requested Completeness Information

EISG section 2.4

Other alternatives to the causeway design, such

As this will be one of the projects major impacts on an

EISG - section 2.4

A more detailed description on why other

The construction of the terminal itself is the largest impact on the

EISG section 2.4

A more detailed explanation on why the

The proponent argues that the overall construction costs made

Roberts Bank Terminal 2 Project

Requested Completeness Information

from the preferred option. The proponent should include data to

EISG section 3.1

More detail is needed on the maps showing the

This is a clear requirement of EIS guidelines. The included figures

EISG section 3.1

Explanation of whether or not terminal

A clearer description and explanation of what

EISG Section 3.2

Roberts Bank Terminal 2 Project

Requested Completeness Information

A reference to other areas of the report that

A reference to other areas of the EIS that

According to the table of concordance, the reader should be able

EISG Section 3.3.1

More species need to be included in the subcomponent section of Marine Invertebrates.

EISG Section 3.3.1

Refer to consultations with Aboriginal peoples

Roberts Bank Terminal 2 Project

Requested Completeness Information

EISG - section 3.3.2

More detail on what type of public consultation

The guidelines state that the proponent is advised to consult with

EISG - section 3.3.2

More details are needed to address the relevant

This section does not reference where the information on the

EISG - section 3.3.2

EISG - section 3.3.2

Specifics for each Valued Component (VC) in

More information on how spatial boundaries

Roberts Bank Terminal 2 Project

Requested Completeness Information

More detail is needed on how traditional and

This section does not provide any details on how temporal

More details are needed on the specific

More information is needed on both the effects

A study of crabs discarded for black

The EIS reports TFN concerns about crab contamination where

Roberts Bank Terminal 2 Project

Requested Completeness Information

proponents collected crabs from Roberts Bank did not exhibit

EISG Section 4.2

EISG Sections 4.3,

Justify the assumption that CRA fisheries

An Agricultural Impact Assessment. Assessment

The proponent also notes that it is currently working with

Roberts Bank Terminal 2 Project

Requested Completeness Information