McLean,Robyn [CEAA] Jeffrey,Barry [PYR] Rifkin,June Yoo [PYR] · 2014-07-21 · From: McLean,Robyn...

From: McLean,Robyn [CEAA]To: Jeffrey,Barry [PYR]Cc: Rifkin,June Yoo [PYR]Subject: Federal Authority Advice Record Request - Roberts Bank Terminal 2 ProjectDate: September 24, 2013 7:45:00 PMAttachments: Roberts Bank Terminal 2 FAAR (EC).docx

Barry, On behalf of the Canadian Environmental Assessment Agency (the Agency), please find attached theFederal Authority Advice Record (FAAR) for the Roberts Bank Terminal 2 Project (the Project). TheProject is a new three berth marine container terminal located at Roberts Bank in Delta, B.C.proposed by Port Metro Vancouver. Please note that the Agency announced the comment periodon the summary of the project description on Monday, September 23, 2013. The link to the fullproject description and summary is below. Project description: https://www.ceaa-acee.gc.ca/050/document-eng.cfm?document=94519Summary of the project description: https://www.ceaa-acee.gc.ca/050/document-eng.cfm?document=94520 As per section 11 of the Canadian Environmental Assessment Act, 2012, the Agency requests thatyou review the project description and complete and return the attached FAAR by no later thanOctober 15, 2013. Please let me know if you have any questions. Thank you, Robyn McLean Project Manager | Gestionnaire de projets Canadian Environmental Assessment Agency | Agence canadienne d'évaluation environnementale 410-701 West Georgia Street | 410 701 rue Georgia ouestVancouver, BC V7Y 1C6Telephone | Téléphone: 604-666-9344 Facsimile | Télécopieur: 604-666-6990Email | Courriel: [email protected] of Canada | Gouvernement du Canada

P Please consider the environment before printing this email.

mailto:/O=EC/OU=VANCOUVER/CN=RECIPIENTS/CN=MCLEANRmailto:[email protected]:[email protected]:[email protected]

410 - 701 West Georgia StreetVancouver B.C. V7Y 1C6

410 - 701 rue Georgia ouestVancouver (C.-B.) V7Y 1C6

September 24, 2013Agency File No.: 005455

Barry Jeffrey

Environmental Assessment and Marine Programs

Environment Canada

401 Burrard Street

Vancouver, BC V6C 3S4

Dear Mr. Jeffrey:

SUBJECT: Determination of Environmental Assessment Requirement for the

Proposed Roberts Bank Terminal 2 Project (the Project) Port Metro Vancouver

Please respond by October 15, 2013 using the attached form.

On September 20, 2013, the Canadian Environmental Assessment Agency (the Agency) accepted a project description for the Roberts Bank Terminal 2 Project. The Project meets the definition of a designated project under the Canadian Environmental Assessment Act, 2012 (CEAA 2012), and in accordance with section 10 of CEAA 2012, the Agency is determining whether an environmental assessment of the Project is required.

As per section 11 of CEAA 2012, the Agency requests that you review the attached project description and provide the following information, analysis and advice with respect to your departmental mandate.

1. Indicate whether the potential environmental effects identified in the project description have been adequately characterized.

2. Identify any additional potential adverse environmental effects (as defined in s.5 of CEAA 2012) of the Project that are not identified in the project description.

3. Identify the potential for your department or agency to exercise a power or perform a duty or function related to the Project and the potential for environmental effects to be associated with that power, duty or function as per subsection 5(2) of CEAA 2012.

4. Identify any specialist or expert information or knowledge in your possession that would be relevant to the environmental assessment of the Project, should it be required.

5. In order to determine application of section 128(1) of CEAA 2012, please specify whether your department or agency previously determined that an EA was not required or took a course of action in relation to the Project under the former Canadian Environmental Assessment Act.

Thank you for your timely consideration of this request. Should you require additional information, I can be contacted at [email protected] or (604) 666-9344.

Sincerely,

Robyn McLean

Project Manager, Pacific and Yukon Region

Federal Authority Advice Record Response due by: October 15, 2013

Roberts Bank Terminal 2 Project – Port Metro Vancouver

Agency File No.: 005455

Department/Agency:

Environment Canada

EA Contact Name:

Telephone:

Address:

Fax:

Email:

1. Based on your review of the project description, are the potential environmental effects that have been identified in that document appropriately characterized? |_| Yes |_| No

Please attach additional information that your department / agency considers relevant, including specific references to adverse environmental effects on areas of federal jurisdiction as described under section 5 of CEAA 2012.

2. Do you expect any additional potential adverse environmental effects of the Project that are not listed in the project description that would be of importance to your department or agency? |_| Yes |_| No


3. (a) Would your department or agency be required to exercise a power or perform a duty or function related to the Project to enable it to proceed? |_| Yes |_| No

If yes, please specify the Act of Parliament and identify the potential environmental effects associated with that power, duty or function as described under section 5(2) of CEAA 2012.

(b) Has your department or agency already exercised the above-noted power or performed a duty or function to allow the proposed Project to proceed in whole or in part? |_| Yes |_| No

4. Is your department or agency in possession of specialist or expert information or knowledge that would be relevant to the conduct of an environmental assessment of the Project? |_| Yes |_| No

Specify as appropriate:

5. (a) Did your department or agency determine under the former Act that an EA of the Project was likely not required? |_| Yes |_| No

(b) Has your department or agency taken an EA course of action decision under paragraph 20(1)(a) or (b) or subsection 37(1) of the former Act in relation to the Project? |_| Yes |_| No

Print Name of departmental / agency responder

Signature

Title of responder

Date

Please respond to the above questions by October 15, 2013 via email at [email protected]. Thank you.

410 - 701 West Georgia Street Vancouver B.C. V7Y 1C6

410 - 701 rue Georgia ouest Vancouver (C.-B.) V7Y 1C6

September 24, 2013 Agency File No.: 005455 Barry Jeffrey Environmental Assessment and Marine Programs Environment Canada 401 Burrard Street Vancouver, BC V6C 3S4 Dear Mr. Jeffrey: SUBJECT: Determination of Environmental Assessment Requirement for the


Please respond by October 15, 2013 using the attached form. On September 20, 2013, the Canadian Environmental Assessment Agency (the Agency) accepted a project description for the Roberts Bank Terminal 2 Project. The Project meets the definition of a designated project under the Canadian Environmental Assessment Act, 2012 (CEAA 2012), and in accordance with section 10 of CEAA 2012, the Agency is determining whether an environmental assessment of the Project is required. As per section 11 of CEAA 2012, the Agency requests that you review the attached project description and provide the following information, analysis and advice with respect to your departmental mandate.







mailto:[email protected]

Sincerely, Robyn McLean Project Manager, Pacific and Yukon Region

Federal Authority Advice Record Response due by: October 15, 2013 Roberts Bank Terminal 2 Project – Port Metro Vancouver Agency File No.: 005455

Department/Agency: Environment Canada

EA Contact Name: Telephone:

Address:

Fax:

Email:

1. Based on your review of the project description, are the potential environmental effects that have been identified in that document appropriately characterized? Yes No


2. Do you expect any additional potential adverse environmental effects of the Project that are not listed in the project description that would be of importance to your department or agency? Yes No


3. (a) Would your department or agency be required to exercise a power or perform a duty or function related to the

Project to enable it to proceed? Yes No


(b) Has your department or agency already exercised the above-noted power or performed a duty or function to allow the proposed Project to proceed in whole or in part? Yes No

4. Is your department or agency in possession of specialist or expert information or knowledge that would be relevant

to the conduct of an environmental assessment of the Project? Yes No

Specify as appropriate:

5. (a) Did your department or agency determine under the former Act that an EA of the Project was likely not required? Yes No

(b) Has your department or agency taken an EA course of action decision under paragraph 20(1)(a) or (b) or subsection 37(1) of the former Act in relation to the Project? Yes No

Print Name of departmental / agency responder Signature

Title of responder Date


From: Rifkin,June Yoo [PYR]To: McLean,Robyn [CEAA]Subject: EC response - T2 FAARDate: October 16, 2013 6:43:02 PMAttachments: 2013 10 16 Roberts Bank T2 FAAR Attachment.pdf

2013 10 16 Roberts Bank Terminal 2 FAAR_EC_UNSIGNED.pdfImportance: High

HI Robyn, As per my voice-mail – apologies for the delay. Please find EC’s FAAR response in the attd. I willfollow this up with a signed version….hopefully tomorrow morning. Thanks, June
mailto:/O=EC/OU=VANCOUVER/CN=RECIPIENTS/CN=YOO-RIFKINJmailto:[email protected]

1

Attachment I Federal Authority Advice Record - Additional Information for Question #1 Roberts Bank T2 Project - Environment Canada

Potential effects on wildlife values including migratory birds

The following effects on wildlife values including migratory birds have not been recognized or adequately characterized in the project description:

• Section 4.0 Federal Involvement – Financial Support and Legislative Requirements: o The applicability of the Migratory Birds Convention Act and regulations as well as

the Federal Policy on Wetland Conservation has not been recognized.

• Section 5.1.2.2 Federal Protected Areas: o While the Alaksen National Wildlife Area is described as a Ramsar Site, it should

also be recognized that in September 2012, large areas of the Fraser River estuary - Sturgeon Bank, South Arm Marshes, Boundary Bay, Burns Bog Ecological Conservancy Area, and Serpentine – were also designated as part of the Fraser River Delta Ramsar Site described at http://www.ramsar.org/cda/en/ramsar-documents-list-anno-canada/main/ramsar/1-31-218%5E16491_4000_0__.

• Table 9 - At-Risk Coastal Birds Species that Potentially Occur within the Project Area:

o The following federally listed species should also be recognized: Red Knot (Calidris canutus roselaari type, Threatened [Species at Risk Act {SARA}]) and Short-eared Owl (Asio flammeus, Special Concern [SARA]).

o The following species assessed by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) should be recognized: Buff-breasted Sandpiper (Tryngites subruficollis, Special Concern) and Horned Grebe (Podiceps auritus; Special Concern).

o The Western Grebe (Aechmophorus occidentalis) should be acknowledged as a COSEWIC candidate species (July 2011).

• Table 10 - Terrestrial Wildlife Species at Risk that Potentially Occur in the Region:

o The following federally-listed species should also be recognized: Northern Red-legged Frog (Rana aurora, Special Concern [SARA]); Oregon Forest snail (Allogona townsendiana, Endangered [SARA]); Band-tailed Pigeon (Patagioenas fasciata, Special Concern [SARA]); Olive-sided Flycatcher (Contopus cooperi, Threatened [SARA]); Peregrine Falcon (Falco peregrinus anatum, Special Concern [SARA]); Western Screech Owl (Megascops Kennicottii kennicottii, Special Concern [SARA]): and, Western Painted Turtle, Pacific Coast population (Chrysemys picta, Endangered [SARA]). Additional species with the potential for occurrence in the region (Marbled Murrelet and Northern Goshawk, for example) have not been included given prevailing very low quality habitat conditions, although murrelet occurrence in the regional marine environment should not be over looked.

2

o The following COSEWIC-assessed species should be recognized: Barn Swallow (Riparia riparia, Threatened) and Little Brown Bat (Myotis lucifugus; Endangered).

o The following COSEWIC re-assessed species should be recognized: Barn Owl (Tyto alba; Threatened).

o The Audouin’s Night-stalking Tiger Beetle (Omus audouini) should be acknowledged as a COSEWIC candidate species (July 2011).

o Provincially listed species with the potential to occur within the region include the American Bittern, Green Heron, Caspian Tern, and Purple Martin.

Effects of potential Disposal at Sea Activities on the Environment In terms of proposed disposal at sea activities, potential environmental effects include • Re-suspension of sediments, potential release of persistent contaminants and alteration of

water and sediment quality. • Increased contaminant uptake and bioaccumulation for marine species • Changes in habitat quality influencing the abundance and distribution of marine vegetation,

invertebrates, and contributing to higher tropic levels (e.g., fish and birds), • Physical alteration of tidal flats and delta foreslope in the immediate area of the Project • Indirect changes to the characteristics of existing processes and physical environment

including changes in tidal flows and patterns, formation or modification of tidal channels, changes in sediment deposition and erosion, scour induced by modified waves and tidal currents near the Project, and the formation of a wave shadow over the part of the tidal flats

• Direct and indirect mortality of vegetation species, alterations in species distribution and composition

• Direct mortality or damage to marine invertebrates, direct loss of marine invertebrate habitat, • Transboundary sediment dispersion during dredging

However, further clarification on aspects of the following specific project components are required in order to better understand the scale and magnitude of the potential environmental effects, and the potential regulatory responsibilities of Environment Canada under the Canadian Environmental Protection Act 1999, CEPA 1999, Section 127(1). Disposal at Sea Site Reference is made in the project description to disposal at sea via submarine pipeline at an ‘approved’ disposal location. Based on previous discussions with the Proponent, it is understood that a site is being sought in close proximity to the project location for disposal of fine sediments in suspension. Disposal at sea activities, including site assessment/selection, should be specifically recognized as a project component taking into account the following considerations: • There is no existing site within the vicinity of the project location that could be considered for

proposed disposal activities, and potential locations for a disposal site have not been identified by the Proponent

3

• If disposal at sea is demonstrated by the Proponent to be the appropriate management option, potential disposal sites must be identified and characterized to facilitate an understanding of the potential impacts on the receiving environment.

• Environment Canada strives to minimize the number of active disposal at sea sites so that potential impacts associated with disposal at sea activity are spatially limited and monitoring efforts are focused and effective. In those cases where use of an existing site is not operationally feasible or other issues may preclude its selection as the most appropriate disposal at sea site, new candidate disposal sites must be identified and characterized. Disposal sites should be selected to minimize the impact on the marine environment, including interference with other uses of the sea.

• The project is located within Southern Resident Killer Whale Critical Habitat. Species at Risk Act tests must be satisfied for any proposed disposal activity in Critical Habitat.

Berth Pocket The Project Description indicates that the berth pocket will be dredged to approximately 20 m below existing seabed, then densified and backfilled to a level of 11.6 m below existing seabed, or a depth of 18.4 m at lower low water level. Dredgeate will be transported via cutter section dredge/pipeline and placed in containment dykes. The Table 3 Summary of Project Components and Activities does not reference “backfilling” of dredged materials as previously described in section 2.3.1 of the Project Description. Clarification on backfilling or movement of material throughout this phase of construction activities is required. Marine Terminal – Three berth wharf structure The Project Description identifies the need to dredge, densify, and backfill sediments in the caisson trench, located adjacent to the berth pocket. The purpose of this activity is to remove in situ low permeability and loose, sandy silts. Dredgeate will be transported via cutter section dredge/pipeline and placed in containment dykes. The following uncertainties important to understanding potential project impacts are noted: • Figure 8 illustrates the general layout of caisson wharf structure but it does not identify the

dredge cut associated with the construction of the caisson trench. • The Table 3 Summary of Project Components and Activities does not reference ‘backfilling’

as previously described in section 2.4.1.2 of the Project Description. Clarification on backfilling or movement of material throughout this phase of construction activities is required.

• The Project Description indicates that a temporary 1.5m thick layer of crushed rock (192,000 m3) will be placed at the bottom of the trench to act as a cap to filter outflow of fines produced during the vibro-densification process. Further information is needed regarding the extent of expected outflow of fines produced during this activity, and whether additional mitigation measures will need to be considered to control suspended sediments.

4

Marine Terminal – Land Development The Project Description estimates the total volume of dredging of the berth pocket and caisson trench to be 4.2 million cubic metres. Dredging would be performed using cutter suction dredge, and then transported hydraulically through a pipeline and placed within the containment dykes. Unusable, fine sediments remaining in suspension (approximately 600,000 m3) would require disposal at sea via submarine pipeline at an approved disposal at sea location. An additional 10.5 million cubic metres of sand sourced from maintenance dredging on the Fraser River is also required for fill, and would involve use of a temporary transfer pit. • No details have been provided regarding the anticipated concentration of fine sediments that

will be remaining in suspension and potentially disposed of at sea. • In previous discussions with the Proponent, feedback was requested regarding a potential

salt marsh project adjacent to the terminal footprint, which would assist in settling fines prior to potential disposal at sea. Environment Canada requests clarification on whether this particular activity is still considered a viable option.

• Table 3 in the Project Description references ‘dredging of underwater temporary transfer pit for terminal fill and preload’. Further clarification on volume and expected grain size characteristics of the material proposed for the transfer pit is required. Additional information on overall dimensions and height of transfer pit at various capacity scenarios is also needed.

• The Project Description states that the transfer of sand from the temporary transfer pit to fill sites will occur via a separate dredge and temporary pipeline. Surplus suspended sediments would potentially require disposal at sea via submarine pipeline. Additional information regarding the nature, extent and timing of the ‘separate’ dredge, subsequent placement of fill, and potential disposal at sea activities is needed

• The Project Description indicates that containment dykes are not lined but will have a filter layer of gravel to minimize seepage of fines from the retained fills. Additional information regarding grain size characteristics of fill material and estimates for seepage of fines from the containment dykes is needed.

Tug basin expansion The Project Description highlights the need for dredging approximately 140,000 m3 via clamshell to approximately 6 m below existing seabed level. Dredged volume will be re-used as general fill within the terminal or the causeway with the surplus suspended sediments released via submarine pipeline to an approved disposal at sea location. Additional information is needed on the anticipated concentration of fine sediments that will remain in suspension.



EA Contact Name: June Yoo Rifkin Telephone: 604-666-7829

Address: 201 – 401 Burrard

Vancouver, BC V6C 3S5 Fax: 604-666-5928

Email: [email protected]



See Attachment I setting out information relevant to appropriately characterizing potential effects on wildlife values including migratory birds and wetlands, and the potential environmental effects of proposed disposal at sea activities.



The Project Description has not identified all the potential adverse environmental adverse effects that could be reasonably anticipated from the proposed project, including the following: • Migratory Birds and Wetlands in terms of impacts to upland wetlands and estuarine habitats and functions

(including functions that support migratory birds and species at risk). For example, a significant proportion of the Wrangel Island Snow Goose population inhabits the marshes of the Fraser River estuary, including Roberts Bank. Substantial bird populations, including shorebirds (Dunlin, Black-bellied Plover), waterfowl (American Widgeon, Mallard), Trumpeter Swan, and Great Blue Heron rely on agricultural fields, which serve as critical habitat during the winter months. The number and variety of global, continental, and nationally-significant bird populations of the region is not adequately described. The Bird Studies Canada’s IBA database is a useful reference to be consulted for such an accounting.

• Vegetation resources including species at risk in terms of alteration of drainage patterns associated with land

development, introduction of invasive species.

• Wildlife resources including species at risk in terms of disturbances, displacement and fragmentation of wildlife habitat; current account of species diversity and abundance.

• Water Quality in terms of effects on migratory birds/habitat.

• Air Quality in terms of transboundary effects. While the transboundary effects on air quality are listed in Section 6.1.9 Transboundary Effects, these effects are limited to “Air quality at Point Roberts, primarily during operations.’ Under the 1991 Canada-United States Air Quality Agreement , Canada and the U.S. committed to notify each other concerning proposals which are within 100 km of the Canada-U.S. border and if carried out could cause significant transboundary air pollution. Notification must be provided for any new air pollution source or any major modifications to existing facilities located 100 km of the border. As the proposed project is located within close proximity to the Canada/US border, appropriate technical analyses within relevant

http://www.ec.gc.ca/Air/default.asp?lang=En&n=83930AC3-1

local/regional study areas should be undertaken to determine the potential for transboundary impacts. A 30 X 30 km Local Study Area, and a Regional Study Area that encompasses the entire Lower Fraser Valley airshed, bounded by the North Shore mountains, extending east to Hope, south of the US border, and include western shipping channels is recommended to facilitate an adequate assessment of transboundary effects.

• Cumulative Effects on migratory birds, wetlands, air quality, species at risk are not reflected in the Project Description.




A Canadian Environmental Protection Act, 1999, section 127(1) permit for Disposal at Sea is likely required in relation to construction and operation of the marine terminal and associated facilities (i.e. proposed loading, transportation, and disposal of dredged or excavated materials). The potential environmental effects considered in relation to proposed disposal at sea activities are itemized in relation to response to questions 1 and 2.




Specify as appropriate: • Migratory birds under authority of the Migratory Birds Convention Act, and their associated

habitats (e.g. wetlands). • Non-aquatic species at risk under authority of the Species at Risk Act, including recovery

strategies and management plans and their related processes. • Application and implementation of the Federal Policy on Wetland Conservation to ecological

wetland communities supporting migratory birds and species at risk. • Water quality: Section 36(3) of the federal Fisheries Act, administered by Environment Canada,

prohibits the discharge of deleterious substances to waters frequented by fish, or to a place where those substances might enter such waters.

• Air quality, including transboundary effects. • Behaviour, fate and effects of spills • Climate and meteorological conditions

5. (a) Did your department or agency determine under the former Act that an EA of the Project was likely not

required? Yes No





September 24, 2013 Agency File No.: 005455

Barry Jeffrey

Environmental Assessment and Marine Programs

Environment Canada

SUBJECT: Determination of Environmental Assessment Requirement for the


Roberts Bank Terminal 2 Project – Port Metro Vancouver

Agency File No.: 005455

1

Attachment I Federal Authority Advice Record - Additional Information for Question #1 Roberts Bank T2 Project - Environment Canada

Potential effects on wildlife values including migratory birds

The following effects on wildlife values including migratory birds have not been recognized or adequately characterized in the project description:

• Section 4.0 Federal Involvement – Financial Support and Legislative Requirements: o The applicability of the Migratory Birds Convention Act and regulations as well as

the Federal Policy on Wetland Conservation has not been recognized.

• Section 5.1.2.2 Federal Protected Areas: o While the Alaksen National Wildlife Area is described as a Ramsar Site, it should

also be recognized that in September 2012, large areas of the Fraser River estuary - Sturgeon Bank, South Arm Marshes, Boundary Bay, Burns Bog Ecological Conservancy Area, and Serpentine – were also designated as part of the Fraser River Delta Ramsar Site described at http://www.ramsar.org/cda/en/ramsar-documents-list-anno-canada/main/ramsar/1-31-218%5E16491_4000_0__.

• Table 9 - At-Risk Coastal Birds Species that Potentially Occur within the Project Area:

o The following federally listed species should also be recognized: Red Knot (Calidris canutus roselaari type, Threatened [Species at Risk Act {SARA}]) and Short-eared Owl (Asio flammeus, Special Concern [SARA]).

o The following species assessed by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) should be recognized: Buff-breasted Sandpiper (Tryngites subruficollis, Special Concern) and Horned Grebe (Podiceps auritus; Special Concern).

o The Western Grebe (Aechmophorus occidentalis) should be acknowledged as a COSEWIC candidate species (July 2011).

• Table 10 - Terrestrial Wildlife Species at Risk that Potentially Occur in the Region:

o The following federally-listed species should also be recognized: Northern Red-legged Frog (Rana aurora, Special Concern [SARA]); Oregon Forest snail (Allogona townsendiana, Endangered [SARA]); Band-tailed Pigeon (Patagioenas fasciata, Special Concern [SARA]); Olive-sided Flycatcher (Contopus cooperi, Threatened [SARA]); Peregrine Falcon (Falco peregrinus anatum, Special Concern [SARA]); Western Screech Owl (Megascops Kennicottii kennicottii, Special Concern [SARA]): and, Western Painted Turtle, Pacific Coast population (Chrysemys picta, Endangered [SARA]). Additional species with the potential for occurrence in the region (Marbled Murrelet and Northern Goshawk, for example) have not been included given prevailing very low quality habitat conditions, although murrelet occurrence in the regional marine environment should not be over looked.

2

o The following COSEWIC-assessed species should be recognized: Barn Swallow (Riparia riparia, Threatened) and Little Brown Bat (Myotis lucifugus; Endangered).

o The following COSEWIC re-assessed species should be recognized: Barn Owl (Tyto alba; Threatened).

o The Audouin’s Night-stalking Tiger Beetle (Omus audouini) should be acknowledged as a COSEWIC candidate species (July 2011).

o Provincially listed species with the potential to occur within the region include the American Bittern, Green Heron, Caspian Tern, and Purple Martin.

Effects of potential Disposal at Sea Activities on the Environment In terms of proposed disposal at sea activities, potential environmental effects include • Re-suspension of sediments, potential release of persistent contaminants and alteration of

water and sediment quality. • Increased contaminant uptake and bioaccumulation for marine species • Changes in habitat quality influencing the abundance and distribution of marine vegetation,

invertebrates, and contributing to higher tropic levels (e.g., fish and birds), • Physical alteration of tidal flats and delta foreslope in the immediate area of the Project • Indirect changes to the characteristics of existing processes and physical environment

including changes in tidal flows and patterns, formation or modification of tidal channels, changes in sediment deposition and erosion, scour induced by modified waves and tidal currents near the Project, and the formation of a wave shadow over the part of the tidal flats

• Direct and indirect mortality of vegetation species, alterations in species distribution and composition

• Direct mortality or damage to marine invertebrates, direct loss of marine invertebrate habitat, • Transboundary sediment dispersion during dredging

However, further clarification on aspects of the following specific project components are required in order to better understand the scale and magnitude of the potential environmental effects, and the potential regulatory responsibilities of Environment Canada under the Canadian Environmental Protection Act 1999, CEPA 1999, Section 127(1). Disposal at Sea Site Reference is made in the project description to disposal at sea via submarine pipeline at an ‘approved’ disposal location. Based on previous discussions with the Proponent, it is understood that a site is being sought in close proximity to the project location for disposal of fine sediments in suspension. Disposal at sea activities, including site assessment/selection, should be specifically recognized as a project component taking into account the following considerations: • There is no existing site within the vicinity of the project location that could be considered for

proposed disposal activities, and potential locations for a disposal site have not been identified by the Proponent

3

• If disposal at sea is demonstrated by the Proponent to be the appropriate management option, potential disposal sites must be identified and characterized to facilitate an understanding of the potential impacts on the receiving environment.

• Environment Canada strives to minimize the number of active disposal at sea sites so that potential impacts associated with disposal at sea activity are spatially limited and monitoring efforts are focused and effective. In those cases where use of an existing site is not operationally feasible or other issues may preclude its selection as the most appropriate disposal at sea site, new candidate disposal sites must be identified and characterized. Disposal sites should be selected to minimize the impact on the marine environment, including interference with other uses of the sea.

• The project is located within Southern Resident Killer Whale Critical Habitat. Species at Risk Act tests must be satisfied for any proposed disposal activity in Critical Habitat.

Berth Pocket The Project Description indicates that the berth pocket will be dredged to approximately 20 m below existing seabed, then densified and backfilled to a level of 11.6 m below existing seabed, or a depth of 18.4 m at lower low water level. Dredgeate will be transported via cutter section dredge/pipeline and placed in containment dykes. The Table 3 Summary of Project Components and Activities does not reference “backfilling” of dredged materials as previously described in section 2.3.1 of the Project Description. Clarification on backfilling or movement of material throughout this phase of construction activities is required. Marine Terminal – Three berth wharf structure The Project Description identifies the need to dredge, densify, and backfill sediments in the caisson trench, located adjacent to the berth pocket. The purpose of this activity is to remove in situ low permeability and loose, sandy silts. Dredgeate will be transported via cutter section dredge/pipeline and placed in containment dykes. The following uncertainties important to understanding potential project impacts are noted: • Figure 8 illustrates the general layout of caisson wharf structure but it does not identify the

dredge cut associated with the construction of the caisson trench. • The Table 3 Summary of Project Components and Activities does not reference ‘backfilling’

as previously described in section 2.4.1.2 of the Project Description. Clarification on backfilling or movement of material throughout this phase of construction activities is required.

• The Project Description indicates that a temporary 1.5m thick layer of crushed rock (192,000 m3) will be placed at the bottom of the trench to act as a cap to filter outflow of fines produced during the vibro-densification process. Further information is needed regarding the extent of expected outflow of fines produced during this activity, and whether additional mitigation measures will need to be considered to control suspended sediments.

4

Marine Terminal – Land Development The Project Description estimates the total volume of dredging of the berth pocket and caisson trench to be 4.2 million cubic metres. Dredging would be performed using cutter suction dredge, and then transported hydraulically through a pipeline and placed within the containment dykes. Unusable, fine sediments remaining in suspension (approximately 600,000 m3) would require disposal at sea via submarine pipeline at an approved disposal at sea location. An additional 10.5 million cubic metres of sand sourced from maintenance dredging on the Fraser River is also required for fill, and would involve use of a temporary transfer pit. • No details have been provided regarding the anticipated concentration of fine sediments that

will be remaining in suspension and potentially disposed of at sea. • In previous discussions with the Proponent, feedback was requested regarding a potential

salt marsh project adjacent to the terminal footprint, which would assist in settling fines prior to potential disposal at sea. Environment Canada requests clarification on whether this particular activity is still considered a viable option.

• Table 3 in the Project Description references ‘dredging of underwater temporary transfer pit for terminal fill and preload’. Further clarification on volume and expected grain size characteristics of the material proposed for the transfer pit is required. Additional information on overall dimensions and height of transfer pit at various capacity scenarios is also needed.

• The Project Description states that the transfer of sand from the temporary transfer pit to fill sites will occur via a separate dredge and temporary pipeline. Surplus suspended sediments would potentially require disposal at sea via submarine pipeline. Additional information regarding the nature, extent and timing of the ‘separate’ dredge, subsequent placement of fill, and potential disposal at sea activities is needed

• The Project Description indicates that containment dykes are not lined but will have a filter layer of gravel to minimize seepage of fines from the retained fills. Additional information regarding grain size characteristics of fill material and estimates for seepage of fines from the containment dykes is needed.

Tug basin expansion The Project Description highlights the need for dredging approximately 140,000 m3 via clamshell to approximately 6 m below existing seabed level. Dredged volume will be re-used as general fill within the terminal or the causeway with the surplus suspended sediments released via submarine pipeline to an approved disposal at sea location. Additional information is needed on the anticipated concentration of fine sediments that will remain in suspension.



EA Contact Name: June Yoo Rifkin Telephone: 604-666-7829

Address: 201 – 401 Burrard

Vancouver, BC V6C 3S5 Fax: 604-666-5928

Email: [email protected]



See Attachment I setting out information relevant to appropriately characterizing potential effects on wildlife values including migratory birds and wetlands, and the potential environmental effects of proposed disposal at sea activities.



The Project Description has not identified all the potential adverse environmental adverse effects that could be reasonably anticipated from the proposed project, including the following: • Migratory Birds and Wetlands in terms of impacts to upland wetlands and estuarine habitats and functions

(including functions that support migratory birds and species at risk). For example, a significant proportion of the Wrangel Island Snow Goose population inhabits the marshes of the Fraser River estuary, including Roberts Bank. Substantial bird populations, including shorebirds (Dunlin, Black-bellied Plover), waterfowl (American Widgeon, Mallard), Trumpeter Swan, and Great Blue Heron rely on agricultural fields, which serve as critical habitat during the winter months. The number and variety of global, continental, and nationally-significant bird populations of the region is not adequately described. The Bird Studies Canada’s IBA database is a useful reference to be consulted for such an accounting.

• Vegetation resources including species at risk in terms of alteration of drainage patterns associated with land

development, introduction of invasive species.

• Wildlife resources including species at risk in terms of disturbances, displacement and fragmentation of wildlife habitat; current account of species diversity and abundance.

• Water Quality in terms of effects on migratory birds/habitat.

• Air Quality in terms of transboundary effects. While the transboundary effects on air quality are listed in Section 6.1.9 Transboundary Effects, these effects are limited to “Air quality at Point Roberts, primarily during operations.’ Under the 1991 Canada-United States Air Quality Agreement , Canada and the U.S. committed to notify each other concerning proposals which are within 100 km of the Canada-U.S. border and if carried out could cause significant transboundary air pollution. Notification must be provided for any new air pollution source or any major modifications to existing facilities located 100 km of the border. As the proposed project is located within close proximity to the Canada/US border, appropriate technical analyses within relevant

http://www.ec.gc.ca/Air/default.asp?lang=En&n=83930AC3-1

local/regional study areas should be undertaken to determine the potential for transboundary impacts. A 30 X 30 km Local Study Area, and a Regional Study Area that encompasses the entire Lower Fraser Valley airshed, bounded by the North Shore mountains, extending east to Hope, south of the US border, and include western shipping channels is recommended to facilitate an adequate assessment of transboundary effects.

• Cumulative Effects on migratory birds, wetlands, air quality, species at risk are not reflected in the Project Description.




A Canadian Environmental Protection Act, 1999, section 127(1) permit for Disposal at Sea is likely required in relation to construction and operation of the marine terminal and associated facilities (i.e. proposed loading, transportation, and disposal of dredged or excavated materials). The potential environmental effects considered in relation to proposed disposal at sea activities are itemized in relation to response to questions 1 and 2.




Specify as appropriate: • Migratory birds under authority of the Migratory Birds Convention Act, and their associated

habitats (e.g. wetlands). • Non-aquatic species at risk under authority of the Species at Risk Act, including recovery

strategies and management plans and their related processes. • Application and implementation of the Federal Policy on Wetland Conservation to ecological

wetland communities supporting migratory birds and species at risk. • Water quality: Section 36(3) of the federal Fisheries Act, administered by Environment Canada,

prohibits the discharge of deleterious substances to waters frequented by fish, or to a place where those substances might enter such waters.

• Air quality, including transboundary effects. • Behaviour, fate and effects of spills • Climate and meteorological conditions

5. (a) Did your department or agency determine under the former Act that an EA of the Project was likely not

required? Yes No





From: Rifkin,June Yoo [PYR]To: McLean,Robyn [CEAA]Subject: T2 FAAR - EC Signed VersionDate: October 17, 2013 6:53:48 PMAttachments: 2013 10 17 T2_FAAR_EC_SIGNED.pdfImportance: High

Hi Robyn, Please find the signed FAAR from EC for the proposed T2 project. Note that there have been no changes to the draft document provided to you yesterday. Thank you again for your patience! June
mailto:/O=EC/OU=VANCOUVER/CN=RECIPIENTS/CN=YOO-RIFKINJmailto:[email protected]

Federal Authority Advice Record Request - Roberts Bank Terminal 2 ProjectRoberts Bank Terminal 2 FAAR (EC)September 24, 2013 Agency File No.: 005455Barry JeffreyEnvironmental Assessment and Marine ProgramsEnvironment CanadaSUBJECT: Determination of Environmental Assessment Requirement for theProposed Roberts Bank Terminal 2 Project (the Project) Port Metro VancouverRoberts Bank Terminal 2 Project – Port Metro VancouverAgency File No.: 005455

EC response - T2 FAAR2013 10 16 Roberts Bank T2 FAAR Attachment2013 10 16 Roberts Bank Terminal 2 FAAR_EC_UNSIGNEDSeptember 24, 2013 Agency File No.: 005455Barry JeffreyEnvironmental Assessment and Marine ProgramsEnvironment CanadaSUBJECT: Determination of Environmental Assessment Requirement for theProposed Roberts Bank Terminal 2 Project (the Project) Port Metro VancouverRoberts Bank Terminal 2 Project – Port Metro VancouverAgency File No.: 005455

T2 FAAR - EC Signed Version2013 10 17 T2_FAAR_EC_SIGNED

McLean,Robyn [CEAA] Jeffrey,Barry [PYR] Rifkin,June Yoo [PYR] · 2014-07-21 · From: McLean,Robyn...

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