The following is a letter from retired senior Department of Fisheries and Oceans biologist and manager Otto Langer to Port Metro Vancouver’s Sustainability Director:

Dear Mr. Desjardin – Sustainability Director – Port Metro Vancouver:

As someone that has spent 42 years of my life protecting the Fraser River Estuary I find the Port Metro Vancouver’s latest phase of its upgrading of the Roberts Bank Port facilities including the transportation infrastructure to be of great concern and is again another setback in protecting this globally significant estuary. Continued development in the Roberts Bank area and on the bank itself will reduce options for future generations to benefit from our natural environment and will again degrade the habitats of vast populations of fish, wildlife and harm public recreation and livability. Further much of the new development is dependent on encroachment on some of the best farmland in Canada and that is yet another nail in the coffin in our ability to protect our base to grow food near this large metropolitan area.

The original development of the Roberts Bank Facility in the late 1960’s was one of the greatest impacts that the Fraser River Estuary has ever suffered since the construction of the many dykes around the estuary in earlier times and after the 1948 flood. That dyke building destroyed vast habitat areas and cut off much of the estuary from what was a large and extremely productive ecosystem.

We are only now protecting a small part of the original estuary and any new development will have an incrementally larger toll on estuary health and survival. Expansion of the port facility a few years to increase coal exports and then container facilities has allowed this port facility to extend across this unique and highly productive mudflat and marsh estuarine complex like a cancer. This present proposal is not a major development but it helps set the stage for major new expansion just over the horizon.

For the concerned public to now have to face and comment on yet another round of industrial expansion is truly unfortunate especially when one considers the a state of world economic uncertainties and a present myopic drive to increase an overly exploitative phase of resource development and the export of as many raw resources as possible and then import most of our manufactured goods. The port planning seems to see no limits to future development and that should be of concern to anyone concerned about our future and quality of life.

It appears the port authority has not learned much from our history and is ignoring all signs that indicate that we must pay more attention to the issues of sustainability and respond to global warming and generally our over exploitation of the earth’s resources. I see none of that thinking in this new phase of development at Roberts Bank. The PMV seems to show little insight as related to the global picture of over development as it relates to our sustainable future as dependent on a clean and healthy environment and the protection of the limited but extremely valuable farmlands we find in this area.  The Port again seems to be driven by a development at any cost agenda and again the overall development by PMV in the estuary has to be put into its proper temporal and estuarine ecosystem context. This project is just one small impact as supported or promoted by PMV.

The above statement is not made without any foundation. The recent comments by the PMV CEO ( Mr. Silvester) in BC Business hi-lites the indifference and insensitivity and the total lack of understanding of the value of the natural environment and our agricultural land in the Lower Fraser Valley. My response to Mr. Silvester’s recent comments are attached. It is unfortunate that his comments seem to symbolize what PMV stands for and that is definitely not for future sustainability. It is indeed rather odd that Port Metro Vancouver would even have a position on staff that they call Director of ‘Sustainable Development’. Maybe that has to be defined because the Port concept of sustainability seems to leave out many aspects of the social and environmental legs of the sustainability stool. Maybe it is sustained industrial development that PMV is dedicated to.

What is most disturbing about any development at Roberts Bank is the disjointed approach PMV is taking in this new development phase at that site and indeed in the entire estuary. To make matters worse, why in earth would the Federal Government have delegated any environmental review / screening delegation under the Canadian Environmental Assessment Act (CEAA) to a port agency that is the developer that will gain financially from this development i.e. why and how can we get a proper unbiased environmental assessment when it is abundantly clear that PMV’s pro-development stance and mandate puts the Port in a total conflict of interest?

As part of the above and key to this review is the PMV ambush style of public consultation. I am informed that a few months ago Nature Vancouver invited PMV to appear at their October meeting to outline PMV expansion plans at Roberts Bank. PMV spokesperson agreed to appear some three months ago but two weeks before the event PMV backed out of the event saying their plans were not ready for public discussion. However, at about the same time the Port then listed this project for public comments and have given the public only two weeks time to respond to the planned development.

This approach should be embarrassing to any Port staff that have environmental, social sustainability or public consultation responsibilities.  This is totally unacceptable and it appears that PMV have not learned from the less than stellar environmental review PMV is conducting in harmony with the BC Environmental Assessment Office in the VAFFC Jet Fuel Delivery Proposal to ship jet fuel into the Fraser River Estuary.  In that review the PMV joint review only allowed the public 2 minutes of speaker time at the ‘public hearing’ last spring and limited written public input to a very short time period.

After protests by the public and local government, the comment period was expanded another two weeks. Despite an expedited process that was to be done about now, the public is left in the dark as to what has happened and above all doubt the sincerity and adequacy of that partnership review. Also in that project the Port is conducting the review with a more junior level of government. This is not proper when the issues related to the port, airport, fishery, navigation, wildlife, shipping, etc are all federal responsibilities. How can we trust a PMV environment assessment of any sort?

I do not know how PMV can with any degree of conscience believe they can conduct an impartial environmental review / screening process. The public and certain local governments including the City of Richmond have strongly stated that PMV cannot do environmental assessments when they benefit from the approval of the project.  Accordingly a group that is examining the joint BC EAO and PMV review of the VAFFC Jet Fuel Delivery Project has launched a petition to the Environmental Commissioner of the OAG of Canada to raise the issue of PMV’s obvious conflict of interest (attachment). This jet fuel project is very relevant in that that the conflict of interest noted in that project also is relevant here. The PMV is the wolf in charge of the sheep and that can mean the continued environmental degradation and eventual destruction of the Roberts Bank and other parts of the Fraser River Estuary.

The container and transport project now being screened is just the tip of the ice berg as related to Roberts Band port expansion. To review this part of the project in isolation of any work on the bank proper (Terminal 2) is akin to getting your foot in the door – again. This is not an acceptable review procedure in that it is obviously piecemeal and does not address the cumulative impacts of all development planned at this port facility, including the Gateway Highway Project,  as is required by the intent and spirit of the cumulative impacts provisions of CEAA. Further an environmental ‘screening’ is the lowest level of CEAA review and considering that the future of what is left of Roberts Bank natural environment and considering the impacts on the adjacent communities a higher level review (i.e.  a full Public Panel Review) is necessary.

I strongly recommend that PMV go back to square one and develop a complete proposal and an objective business case for significant expansion at this time in the face of port tonnage handled in the recent past, a realistic projection of increased port needs and relate that to the significant port development at Prince Rupert that will compete with this port. Also an objective review of the conservation future of this part of the estuary is long overdue.  Once these issues have been addressed, only then can the Federal Government, through a higher level FEARO Public Panel Review, do an objective environmental assessment that we can trust.

To date PMV has caused catastrophic damage to Roberts Bank habitats and fish and wildlife populations. Many of these populations are global in nature and truly unique and are under great pressure from past development. Further PMV has not shown that it has significantly mitigated the impacts from past development on Roberts Bank including the massive loss of habitat due to massive filling, fuel and coal dust spills, killing of wildlife by inappropriate power lines over the water directly in the paths of migratory bird populations and in the blocking of natural ocean currents, sediment transport and fish movements by the causeway.

To propose more development when past impacts have not been addressed is a way of saying that we will continue to develop regardless of environmental or agricultural or resident concerns and as we do more damage to new areas we will promise to mitigate the damage of the past. This is wishful thinking and a line must be drawn on the map because what has taken place in past development is well beyond the concept of what is sustainable development at that key estuarine habitat area.

In summary:

• The Roberts Bank Port development as started in the late 1960s has caused catastrophic impacts on Roberts Bank natural processes, habitat and fish and wildlife populations. To date, these impacts have not been properly mitigated.

• This environmental screening review of improved transport infrastructure at Roberts Bank Port Terminal is out of context with what is next planned and a proper review of what is planned for this area must be addressed as a comprehensive review of a complete package.

• A proper review that can best address the intent of CEAA must be much
  more comprehensive and done at a higher level (i.e. Public Panel Review)
  and include all planned development at Roberts Bank Port to address
  perceived needs up to 2030. Anything less than this is a piecemeal short
  term review and undermines the cumulative impacts intent of CEAA and
  the public trust.

• The stated opinions of the Port CEO in the press are bound to affect the
  thinking of all working staff at PMV including those on any
  environmental assessments conducted by PMV. Allowing an agency with a
  gross insensitivity to farmland and natural world values is bound to be
  not trusted by an informed public and that is not in the interest of the
  estuary, its life and federal responsibilities.

• PMV is in an obvious conflict of interest due to their gain if the
  project is approved and this undermines an objective and unbiased review
  and greatly lowers public trust and the possibility of maintaining
  natural values on the remaining  and undeveloped portions of Roberts
  Bank and its backup lands.

• The Federal and BC environmental agencies must draw a line on the map as
  to what government is willing and must protect in this valuable and
  essential part of the Fraser River Estuary. Continued piecemeal losses
  associated with an improvement of infrastructure such as this project
  must be put into context of what PMV has planned for this port site.

• The environmental screening as applied to this project by PMV as per
  CEAA is inadequate especially as related to how the public was informed
  and the extremely short time given to evaluate and comment on what is
  indeed taking place and about what is to next take place considering
  known PMV expansion plans and attitudes stated for natural values in the
  Roberts Bank area.

• PMV does not seem to appreciate that the Fraser River Estuary, including
  the Roberts Bank area, is an estuary of international significance and
  is one of handful of estuaries of global significance on the West Coast
  of the Americas. This alone requires an attitude of greater insight into
  how that legacy must be protected.

• The PMV should withdraw from a leading any environmental review when
  they are the primary developer and beneficiary of the approved project.
  The Federal Government must re-evaluate why and how this terrible
  arrangement was ever allowed under CEAA. This bad precedent is now
  taking place in several projects in the Fraser River Estuary and it now
  appears that the estuary is simply treated as a port that is
  unfortunately entering a new era of industrialization. This will
  incrementally harm a very rare and unique Pacific Coast natural
  environment and promote the continued loss of some of our best
  farmlands.

 Sincerely yours,

Otto E. Langer MSc

Fishery Biologist and Aquatic Ecologist

Richmond, BC.