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Submit a public comment to urge the Federal government to reject the Roberts Bank Terminal 2 expansion.
ByRaincoast Conservation Foundation February 2, 2022

The Government of Canada is currently requesting public comments to decide on whether the Roberts Bank Terminal 2 expansion project should go forward. Until February 13th, supporters like you can take action to protect the Fraser River Estuary. Please consider taking five minutes to submit a public comment. We have made it very easy for you to do so by laying out the steps and writing a suggested public comment that you can input.
Why stop the Roberts Bank Terminal 2 expansion

As a nursery and feeding ground, the Fraser Estuary connects a food web linking fish, birds and marine mammals across thousands of kilometres of the North Pacific Ocean. Even at a fraction of their former abundance, the estuary is the rearing grounds for Canada’s largest runs of Pacific salmon. It is critical habitat for endangered Southern Resident killer whales who are following adult Chinook salmon to their natal river, and there are more than 100 additional species at risk of extinction that also call the estuary their home.

The Vancouver Fraser Port Authority is proposing to double the size of its shipping terminal in the heart of the Fraser Estuary, putting further stress on an estuary that has lost more than 85% of its floodplain habitat. The existing terminal, Deltaport, is already a significant footprint in the estuary.
Submit a public comment

Steps to submit a public comment
1. Click this link.
https://iaac-aeic.gc.ca/050/evaluations/proj/80054
Scroll down and click the submit a comment button.
2. Click the submit a comment button again. Then go to log in.
3. Accept terms of use and click the continue button.
4. Click the sign-in using GCKey button.
5. Either sign in (can skip to step 9 if you already have a GCKey login) or click sign up.
6. Click I accept. Create a username.
7. Create your password.
8. Select your recovery questions and answers.
9. Click continue.
10 Input your email address, first and last name. We’ve drafted up a suggested comment below.
Suggested comment title:

Please reject the Vancouver Fraser Port Authority’s Terminal 2 expansion project.
Suggested comment:

I am urging the federal government to reject the Roberts Bank Terminal 2 expansion project.

The Impact Assessment Agency report has found that RBT2 will have significant adverse and cumulative effects on the South Thompson River and Lower Fraser ocean-type Chinook salmon populations. The federal review panel also determined that terminal expansion would create a large barrier to juvenile Chinook salmon wanting to migrate to eelgrass beds. In combination with adverse effects from acoustic and light disruption, these effects would be ‘high in magnitude, local in extent, permanent in duration and irreversible’.

The panel also found that the project would adversely affect food availability for Southern Resident killer whales, which will be magnified due to the nutritionally-stressed state of the whales. The panel concluded that the effects would be ‘regional in extent, permanent in duration, irreversible and continuous’. The panel acknowledged that the Salish Sea is already too noisy for Southern Resident killer whales, and that the marine shipping associated with the Project would result in significant adverse effects on the population.

Importantly, there is a lack of evidence demonstrating that habitat mitigation offsets the negative effects incurred by development projects. In fact, a study done by Lievesley et al. (2016) found that only 33% of the Port’s own habitat offsetting projects obtained their intended goals, and a Canada-wide study by Quigley and Harper (2006) determined that 50% of fish habitat mitigation projects were not compensating for damages on a 1:1 ratio. This lack of quantitative evidence demonstrating habitat offsetting effectiveness is critical to consider in this decision.

For birds, the estuary is of global significance and serves as a crucial stopover on migration routes stretching from South America to the high Arctic. Environment Canada concluded that the impacts from the shipping expansion increase the threats to shorebirds generally, and western sandpipers specifically, and that these risks cannot be mitigated.

The existing terminal is already a significant footprint in the Fraser Estuary. If the conservation and recovery of Canada’s endangered and iconic wildlife species are a priority for the Government of Canada, then the proposed Roberts Bank Terminal 2 project must be rejected. Rejecting the project would demonstrate federal commitment to the letter and intent of legislation like Canada’s Species at Risk Act and policies like Canada’s Wild Salmon Policy. Investments in conservation and biodiversity have also been shown to be investments in the prosperity of current and future generations.

Please reject the proposed Roberts Bank shipping expansion and demonstrate a commitment to the integrity of Canada’s biodiversity and ecosystems, on which we all rely.

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