Comments by Gerald Graham, Ph. D.

regarding the Deltaport Third Berth

Expansion Project Comprehensive Study prepared by Fisheries and Oceans Canada

Introduction

Fisheries and Oceans Canada‟s 2005 comprehensive study of the Deltaport Third Berth
Expansion Project concluded that “(T)he potential cumulative effects of additional
vessels visiting Deltaport is likely to be negligible” ( P. 179 ). It is the contention of this
submission that the conclusion reached by the DFO study is based on incomplete
information as well as an incorrect interpretation of data that is available.

What the study looked at and determined

The DFO study looked at the impact of increased ship movements to and from the
expanded Deltaport terminal, as well as from the entirely new, second terminal which is
expected to be operational by 2021. These movements are anticipated to increase as
follows:

 From 3.1 ship movements per day in 2003 to 3.4 when the third berth addition to
the existing terminal is in operation.
 Up to 5.3 ship movements per day when the second terminal is in operation in
2021 ( P. 179 ).

The study correctly noted the recent trend towards larger container vessels being used ( P.
179 ).

The study conceded that “(T)he project will introduce some additional residual effects of
noise and collision risk from additional ship visits” ( p. 179 ) Nevertheless, the study
concluded that given the

“…low quantity of vessels and the slow speed… from existing and projected
future vessels visiting Deltaport, compared to other vessels in the Strait of
Georgia, the collision and noise risk to marine mammals is considered to be
negligible.” ( P. 180 )

Deficiencies in the study

The author takes issue with this conclusion, basically on four grounds:

1. The increase from 3.1 ship movements per day to 3.4 and then 5.3 is significant,
not insignificant. Similarly, the increase in the risk of collision and the noise risk
to marine mammals will not be insignificant.
2. The study fails to consider the increased threat of oil spills presented by an
increase in ship movements. The increased threat level this represents to the
endangered southern resident killer whales is significant.
 3. The study only considers the impact of increased ship movements in the Strait of
Georgia, whereas it should be looking at the impact of these ship movements in
Boundary Pass, Haro Strait and the Strait of Juan de Fuca, all of which form part
of the core habitat for the southern resident killer whales of the area.
4. The project has, it seems, not been TERMPOLed.

Let us examine each of these points in turn.

The increase in ship movements is significant

An increase from 3.1 to 3.4 ship movements per day may not seem like much, but it is
actually an increase of 109.5 ship movements per year through one of the world‟s busiest
shipping lanes. What is more, we are talking here about what are generally very large
vessels – vessels that are getting larger and larger each year.

Furthermore, an increase from 3.1 ship movements per day today to 5.3 ship movements
per day fifteen years from now would represent an increase of 803 ship movements per
year, which by any yardstick is a very large increase in transits. In short, the increase in
ship traffic is likely to be considerable rather than marginal, with potentially significant
increases in collision risk, noise risk and ship strike risk to marine mammals as well.

The threat of oil spills is significant

For some inexplicable reason, the comprehensive study only looks at the increased threat
posed by noise and ship strikes. While these are no doubt important threats, so is that
posed by oil. The oil spill threat comes not just from tankers but from the fuel on board
cargo vessels.

It is generally recognised that oil spills represent one of the principal threats to the
survival of southern resident killer whales, which are on both Canadian and American
endangered species lists.

The environmental threat of increased shipping extends well beyond Georgia

Strait

Again, for some unknown reason, the comprehensive study only looks at the threat posed
by increased shipping in the Strait of Georgia, i.e. the body of water in the immediate
vicinity of the project site. While undoubtedly significant, the entire commercial shipping
route to and from the Pacific Ocean, in and out of Deltaport should be taken into account.
This route includes, from west to east, and in addition to Georgia Strait, the Strait of Juan
de Fuca, Haro Strait and Boundary Pass. Taken together, these four waterways constitute
the core habitat of the endangered southern resident killer whales. In fact, for much of the
year large cargo ships navigate in very close proximity to the whales, particularly in Haro
Strait on the American side of the border, close to San Juan Island. Significantly, part of
this region, particularly around Boundary Pass, is being considered by Canadian
authorities for designation as a National Marine Conservation Area.
Within each of these maritime areas, a significant increase in the level of commercial
shipping activity can be expected to increase the amount of noise the killer whales are
subjected to. The risk of collisions, ship strikes and oil spills will also necessarily
increase.

What ever happened to TERMPOL?

Transport Canada is supposed to apply the TERMPOL review process whenever a new
berth is being built along the coast. TERMPOL is expected to be implemented in respect
of the anticipated Gateway project which Enbridge is considering for Kitimat. Thus, why
not for Deltaport expansion at Roberts Bank? While TERMPOL principally applies to
terminals handling bulk oil, natural gas and chemicals, it can be applied to other cargoes
as well. Given the presence along the proposed shipping route of southern resident killer
whales, a Species at Risk Act-listed endangered species, and the significant threat to them
posed by oil spills, one is hard pressed to see how the Minister of Transport could refrain
from applying the TERMPOL process in this instance.

Conclusion

Contrary to the bold assertion in the comprehensive study to the effect that the effects of
increased shipping related to the Deltaport expansion are likely to be minimal, this
critique humbly submits that the cumulative effects of this long-term project are
potentially catastrophic in respect of the southern resident killer whales which frequent
the area used by ships entering and leaving Deltaport.

DFO‟s comprehensive study completely ignores the fact that Deltaport shipping traffic
will traverse, on a daily and continuous basis, year in and year out, the core habitat for
these same whales, and that Environment Canada is considering the establishment of a
National Marine Conservation Area in an area that encompasses the major shipping
channel of Boundary Pass.

Already subjected to a number of stressors, including noise, ship strikes and the threat of
oil spills, as well as the lack of prey and environmental contamination, the significant
increases in ship traffic associated with the Deltaport expansion could sound the death
knell for this icon of the Pacific Northwest. One need only look to Prince William Sound,
where the 1989 Exxon Valdez oil spill virtually wiped out one local pod of orcas, for an
example as to what might happen.

For all these reasons, at the very least, the authors of the comprehensive study need to go
back to the drawing board, demonstrate that they are aware of these significant threats,
and indicate what steps are planned to mitigate the negative effects associated with them.
Only by doing this can their study be worthy of the designation „comprehensive‟.