Sometimes you just have to shake your head.
I certainly had to when faced with some of the farcical comments made by Port Metro Vancouver (PMV) in its extended examination of marine shipping for the proposed Terminal 2 (T2) at Deltaport.
The Environmental Assessment of T2 required Port Metro Vancouver to assess the impacts of increased marine shipping in Canadian waters beyond the Port’s “care and control.” Of course, we aren’t quite sure WHY the Port had to provide this fifteen-hundred pages of information: in the same breath, the Canadian Environmental Assessment Agency stated the marine shipping report wouldn’t be part of the decision to approve or reject the project.
In other words, the entire process was an exercise in futility before it even started. Much more than that, it’s a disgraceful shame, because marine shipping will have real environmental effects and they should absolutely be considered in the final project decision.
Here are a few of the more farcical comments in a document that has a number of Panamax-sized holes:
The Port’s review asserts container ship operators aren’t likely to know when they’ve struck an orca, which “could account for the low number of reported strikes.” The Port concludes that the risk of increased vessel strikes on orcas is therefore unlikely given “no mortalities from container ships have been reported” (8.2-31-3). Circular logic, par excellence.
Similarly, T2 container traffic “could potentially strike a humpback whale” causing injury or mortality, but their growing population in B.C. waters means it’s not a problem (8.2-35).
PMV states that if Southern Resident Killer Whales are traveling in a superpod at the time of a spill, “the population would be exposed to a potentially catastrophic effect.” That said, the Port found a lack of evidence that oil spills negatively affect orcas. It decided, however, to take a “conservative approach” and assume that orcas don’t thrive in oil spills (10-62).
The Port says we needn’t worry about the impacts of a spill on coho salmon, because a worst-case scenario spill is in May, during the high flows of the Fraser River spring freshet, and the coho run is in the fall (10-53). Of course, there isn’t an assessment of what a fall spill would mean for the coho.
A number of First Nations raised concerns that PMV’s T2 submissions were overly reliant on information that was provided during the Kinder Morgan hearings (9.5-4). A submission from the Penelakut Tribe mentions that a draft version of the report included “tables listing traditional and cultural resource use sites.” When they pointed out that key information was missing from the table, “PMV’s response was to simply remove the tables.”
On numerous occasions the Port says that it doesn’t have hard evidence to support its conclusions. It then goes on to draw conclusions. It may not be entirely PMV’s fault, because the federal environmental assessment agency instructed them to use as much existing information as possible. But when the Port says it doesn’t know what the baseline water quality levels are, or that they took an educated guess – rather than actually measuring – existing light conditions along the shipping lanes, you just have to wonder what they do with all their time and money. The review becomes meaningless without relevant comparisons to baseline data.
The saddest joke in this comedy of farce may be how meaningless it is. The Canadian Environmental Assessment Agency writes: “[T]he environmental effects of marine shipping associated with the project which is beyond the care and control of the proponent … are not environmental effects of the project for the purposes of the Minister’s decision on whether the project is likely to cause significant adverse environmental effects and will not be subject to conditions to the proponent in any decision statement issued by the Minister under CEAA 2012.”
So Port Metro Vancouver was required to provide a 1,500-page review of environmental effects that may occur in Canadian waters as a result of the proposed T2 and, because those effects are outside the Port’s “care and control,” the federal minister is forced to dismiss them when determining the project’s environmental effects.
Our new federal government has pledged to revamp our environmental assessment process. We can only hope the Terminal 2 debacle will spur some meaningful change.
Canada sure needs it.
You can find my office's full submission on the Marine Shipping Addendum here.