On February 1st, through freedom of information requests by Roger Emsley, it was revealed that in March of 2020 Environment Canada Scientists attempted to express major concerns about the Roberts Bank Terminal 2 project into a key stage of the environmental assessment. Their final submission outlining the department’s position including that “Project-induced changes to Roberts Bank constitute an unmitigable species-level risk to western sandpipers, and shorebirds” was not submitted because of the direction of the then Minister of the Environment and Climate Change, Johnathan Wilkinson. This seems to be a clear abrogation of his responsibilities and mandate as Canada’s Environment Minister.
When Johnathan Wilkinson was asked why he withheld the concerns of his own scientists, Wilkinson responded “Upon review, it was determined that the expert input already tabled with the review panel stood for itself, and that closing remarks would not alter or add value to the Department’s analyses, conclusions, and recommendations already on the record.” Imagine, the head of Environment Canada silencing its own scientists’ concerns for the environment at a key stage of an environmental review of a contentious project such as the RBT2! And to think that I thought that muzzling of Canada’s scientists ended with the former Conservative government.
Now after that eighteen-month delay in finding out the concerns of Environment Canada scientists, there are only 6 days left for Canadians, that is, YOU, to submit your thoughts and feelings to the Impact Assessment Agency of Canada on the RBT2 project. This will be your last chance to express your thoughts, concerns, and opposition to the project after which a final decision will be made.
Roger Emsley has noted a much easier way to make a submission to the Impact Assessment Agency. Instead of having to create an identity with the GC Key as is detailed on the front pages, a much easier way to submit comments is to “Simply copy the letter and paste it into your email, add your name and address, date it, copy the address email@example.com into the To box, and hit send.“
We have now only seven days to make our voices heard and register opposition to a project that most likely will highly degrade or destroy the Pacific Flyway. If we, that is each one of us taking personal responsibility to submit a comment, we will have no grounds for complaint about the end result.
So if you really care and are willing to act, possible next steps are:
1) Take some minutes to write your concerns and email them with your Name, Address, and Date to the Impact Assessment Agency
2) An alternative option for getting your submissions on file immediately is to use the GC Key to submit directly to the IAA. (Instructions to register a GC Key account are at the end of this email).
2) Make sure everyone else in your household registers their comments separately (the more separate submissions there are, the great the impact they will have)
3) Blind copy either this email or your own communication to everyone you think cares about the environment, today! (if you do, I would love to be included in your blind copy)
4) Also consider contacting your MP, cc’ing to:
Minister Steven Guilbeault, Minister of Environment & Climate Change Canada: Steven.Guilbeault@parl.gc.ca
Prime Minister Justin Trudeau: Justin.Trudeau@parl.gc.ca
Minister Joyce Murray, Minister of Fisheries and Oceans and Canadian Coast Guard: Joyce.Murray@parl.gc.ca
Premier John Horgan: Premier@gov.bc.ca
You might be wondering why one individual would bother making such an effort to stop approval of the Roberts Bank Terminal 2 project? Several times in my life I have decided that an issue is too important to avoid and have chosen to go flat out. With respect to the environment and the Pacific flyways of both North, Central, and South America, restraint is not an option. I hope you will decide to share this with one or two-family or friends to amplify this effort.
Please take action to make a difference!
Websites providing further information:
1) the outrageous story about Johnathan Wilkinson blocking his Environment Canada submissions to the environmental impact assessment https://www.nationalobserver.com/2022/02/01/news/feds-quashed-damning-scientific-conclusions-about-port-expansion-birds
2) PDF attached of actual document of Environment Canada scientists closing remarks for the Roberts Bank Terminal 2 Project blocked/muzzled by Johnathan Wilkinson
3) Roberts Bank Terminal 2 Impact Assessment Page https://www.iaac-aeic.gc.ca/050/evaluations/proj/80054?culture=en-CA
4) Nature Vancouver Blog submitted by board member Bev Ramey https://naturevancouver.ca/roberts-bank-terminal-two/ (Note the easier way to submit provided by Roger Emsley)
Steps to register a GC Key and Submit Instantaneously
* If you already have a GC Key for banking, consider just using it, alternatively
* Click on Submit a Comment
* On next page, click on Submit a Comment
* Message will say you will be redirected to Login Page
* You will go to ‘Agreement to the Canadian Impact Assessment Registry’s….
* Click I have read and agree…
* Click on Continue
* For individuals, click on Sign-in Using GCKey
* Click on English if that’s your preference
* At this point you can use your GCKey or create a new one for this purpose
* Assuming you want to set up a new one, click on Sign Up
* Click on I Accept
* Plugin the name you wish. As I have a key already and wanted a separate one for this submission, I selected First, Middle & Last Name with no spaces between Names (spaces screwed it up)
* Create a Password
* Put in three Security Question/Answers
* Easy peasy
* You are then redirected to the Impact Assessment Page where you can either type of cut and paste a previous composed submission.
Impact Assessment Agency Canada
160 Elgin Street, 22 Floor
Ottawa, Ontario K1A 0H3
Subject: Roberts Bank Terminal 2 – Invitation for Public Comment.
I am opposed to the proposed Roberts Bank Terminal 2 (RBT2) project. The additional information provided by the Vancouver Fraser Port Authority (VFPA does not resolve the substantive issues raised by Environment and Climate Change Canada (ECCC) scientists. The environmental assessment conditions as drafted do not protect the Roberts Bank ecosystem nor the wildlife. ECCC and other independent scientists have provided compelling evidence that the project will affect both biofilm quality and quantity on Roberts Bank, threaten the entire Western Sandpiper species and negatively impact other wildlife.
Furthermore I have major concerns with the potential draft conditions:
- Why are warnings from the government’s own scientists being ignored?
- Why do the draft conditions assume biofilm quality and availability will not be damaged when ECCC science shows they will?
- Why assume mitigation will be possible if damage is detected when it will be too late to prevent the damage?
- Why, if mitigation measures fail, are there no provisions in the draft conditions, to either stop the project, or to prevent environmental damage to Roberts Bank wetlands and the wildlife that relies on them?
- Why (in section 10.2) do the draft conditions propose biofilm can be created when scientists have said it is not possible on the scale required?
- Why ignore Review Panel concerns about Project effects on polyunsaturated fatty acid production in biofilm, which is a critical nutritional component for Western Sandpipers?
- Why risk environmental degradation when the Panel had “considerable uncertainty around the possibility that loss of productive biofilm habitat could be mitigated by the large-scale re-creation of biofilm habitat capable of supporting shorebirds”?
The Fraser Estuary cannot withstand any more industrial or port development, but this is exactly what the Port of Vancouver plans to do with the addition of RBT2. Roberts Bank is recognized as one of the top Important Bird Areas in Canada. It is recognized as providing critical wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada. Southern Resident Killer Whales, whose prime habitat is the Fraser Estuary, will be further endangered by vessel noise and further degradation of their major food source – Chinook Salmon. Why put all of this at risk?
The federal government must finally recognize RBT2 is likely to cause significant adverse environmental effects that cannot be mitigated and which are not justified in the circumstances.
The time has come – deny approval for Roberts Bank Terminal 2.