URGENT Deadline – Tuesday December 17, 2013 for input to Coal Facility at Surrey Docks
(This information is thanks to Susan Jones)
URGENT – If you are concerned about Port Metro Vancouver Plans for building a Coal Facility at the Surrey Docks, please make sure you make a submission to the Environmental Assessment Impact by Tuesday, December 17, 2013.
Some points follow to assist your submission
You can fill in a form at the following website OR email Port Metro Vancouver directly as outlined below.
Form at: http://RealPortHearings.org – Open the site and click on “email tool”
OR: Port Metro Vancouver will accept public comments through the following channels:
By Email: FSD-EIA@portmetrovancouver..com
By Mail: Tim Blair, Senior Planner Port Metro Vancouver, 100 The Pointe, 999 Canada Place , Vancouver BC V6C 3T4
By Fax: 1-866-284-4271
Some points to consider:
- Railway crossings are extremely dangerous so more and longer trains cause more accidents. Over the operating lifetime of the terminal, some number of people will be killed by collisions with coal trains. Emergency vehicles, or vehicles taking personnel to hospitals to respond to an emergency, will be delayed at train crossings at a time when seconds count.
- Powder River basin coal is well known for its tendency to spontaneously combust, causing health and safety as well as environmental problems
- Coal trains may derail – derailments can be caused by an accumulation of coal dust, and also by the accumulation of damage done to the rails by the huge coal trains.
- Coal Dust is highly combustible. When it is blown from coal piles at the terminal, it could create a fire hazard or other hazardous conditions on and off site.
- An increased volume of large ships in the Salish Sea will increase the chances of collisions between large ships or between large ships and small boats.
- During wind events, coal dust will be blown from coal piles to locations up to 5 miles away, as has been observed at the Point Roberts terminal, and it will be inhaled.
- Diesel particulate matter (DPM) that is less than 2.5 microns in size, the most dangerous size, is emitted by the coal trains and ships. These particles go deep into the lungs of people who breathe the fumes and cause serious health effects including cancer.
- Coal dust from the trains will be inhaled by people. Coal dust contains toxic metals, and has respiratory health effects.
- The Environmental Impact Assessment has been criticized by the Health Authorities, local governments and many experts calling for them to scrap this project and start over due to failure to adequately address serious issues.
- The coal trains and ships will emit Nitrogen and Sulfur Oxides, which create acid rain and have direct health impacts.
- Ships approaching and leaving the terminal will emit air pollutants, including sulfur oxides, nitrogen oxides, hydrocarbon PM, and carbon monoxide. These pollutants can have serious health effects.
- The toxic metals in coal, such as arsenic, can accumulate in soils near the coal trains, resulting in exposure to people and to the environment.
- Emissions from the coal ships as they cross the Pacific Ocean will contribute to regional and global quantities of greenhouse gases, toxic air pollutants, acid rain pollutants, and particulate matter.
- Some of the coal dust that leaves the coal trains will enter the surface stream system, degrading water quality.
No Economical Justification
- The Surrey Docks will just be a conduit for American coal. There is no real money to be made with this project. The American ports aren’t permitted to ship the coal out of their own ports due to health and safety issues.
- The few jobs involved are not worth the health, safety and environmental risks.
- Using our rail and dock facilities as a conduit for American coal will limit other more economical opportunities at the Surrey Docks.
- Surrey Fraser Docks underwent a $190 million container facility expansion in 2005/2006. What happened to that investment? Port Metro Vancouver has removed the container business from Surrey Docks and sent it to Deltaport in spite of the heavy investment and in spite of the availability or real estate and infrastructure for 1 million TEUs of the container business.
- The Fishing Industry and Whale Watching (Tourism) will be impacted.
Destruction of the Fraser Estuary Habitats
- Health impacts also impact the health of the habitats and ecosystems of internationally-significant salmon, migratory birds and orcas.
- The full set of marine impacts will lead to even further reduced capacity for fishing.
- Coal dust will blow from coal piles and loading operations into the marine environment, with substantial environmental consequences.
- Of particular concern is the majority of the world’s populations of sandpipers which feed on biofilm which is formed as the Fraser River fresh water enters into the Strait of Georgia . Particulate matter from coal will be deadly to this species as well as other migratory wildlife.
- Herring that live near Texada Island could be driven to extinction by terminal operations. They are not technically an endangered species but probably should qualify.
- One of the largest salmon runs in the world will be put at risk.
- The lack of review for culturally significant sites both at Fraser Surrey Docks and on Texada Island will further injure the rights of First Nations. Damage to fish, fishing rights and traditional resources is out of step with resolution of the current conflict resolution process.
- Increased train traffic will cause traffic jams at intersections degrading the quality of life.
- Noise from the coal trains will interfere with sleep. This impairs cognitive development in children, and has other impacts in people of all ages.
- Health and safety impacts listed above are severe and a polluted environment will degrade the quality of life in the immediate vicinity, in the estuary and upriver to the Fraser Valley .
- There will be no significant increase in job opportunities.
Cumulative environmental impacts
- Port Metro Vancouver has failed to properly consider past, present and future port projects and related infrastructure. While Port Metro Vancouver is pleased to utilize infrastructure upgrades costing taxpayers billions of dollars, the port refuses to even consider the cumulative impact of port projects and related infrastructure. That is a priority of Canada ’s Environmental Assessment Act yet Port Metro Vancouver is being permitted to avoid this due process.
- To restrict assessments to local projects such as this coal facility is insufficient and contravenes an ethical approach to environmental assessments.
- Canada has invested billions in the Lower Mainland Gateway Corridor and the public is yet to see a credible cumulative environmental assessment. These Gateway projects are degrading the internationally-significant wildlife and the quality of life for the residents in the lower Fraser delta. The sum of the projects merit a full, credible, cumulative environmental assessment. It is the law and it is being breached. Other laws that are being ignored are;
- Canadians Fisheries Act
- Canadian Migratory Birds Convention Act of 1994
- Canadian Environmental Assessment Act
- Canadian Species at Risk Act
- Canadian Department of the Environment Act
- Convention on Biological Diversity
- Federal Policy on Wetland Conservation
- North American Waterfowl Management Plan
- Georgia Basin Ecosystem Initiative
- Georgia Basin Action Plan
- National Recovery Strategy for Southern Resident Orcas (Killer Whales)
- The cumulative impact of all the projects is massive and the effects on essential estuarine habitats are not well understood. As the Pacific Flyway, Orca Passage, and salmon migratory routes are all impacted, the cumulative impacts must accordingly address global concerns. The Fraser River estuary has been greatly impacted by hundreds of different environmentally harmful developments since the 1860s. This all has to be addressed and this provision is stated in Canada ’s Environmental Assessment Act. (or was – perhaps has been recently removed – which would be criminally unethical)
- Cumulative impacts must examine (along with American authorities) the maximum overall risk and noise / traffic that can be allowed in the Fraser River, the Gulf of Georgia and the Strait of Juan de Fuca so as to at least protect marine life and migratory birds of the Pacific Flyway.
Lack of Accountability by Port Metro Vancouver
- This assessment pays lip service to environmental impacts and public consultation demonstrating a lack of accountability.
- Port Metro Vancouver has a direct and clear conflict by being involved directly in the permitting process having interests in the corporations that will profit from the terminal.
- This is clearly a case of the fox in the henhouse and Port Metro Vancouver should not be permitted to do in-house environmental assessments.
- As a Crown Corporation, Port Metro Vancouver is afforded liberties not given to private corporations. Port Metro is using public assets and infrastructure that is built with tax dollars to service movement of goods. Big salaries are paid to Port Metro Vancouver Senior bureaucrats. Port Metro Vancouver is building a portfolio of real estate holdings and business partnerships. In order to build this real estate empire, Port Metro Vancouver has bought land in the Agricultural Land Reserve and speculators are placing options on ALR lands to support future port-related industrial developments. The ordinary citizen has no say and projects are literally bulldozing their way through farmlands, habitat and people’s quality of life. The coal facility at Surrey Docks is just another one of these unaccountable projects that will benefit a few at public and wildlife expense.
- Not long ago, Surrey Docks was advocating increasing container capacity at that port and claimed with little cost the Fraser Surrey Port could handle 1 million TEUs:
“Fraser Surrey Docks, the multi-purpose terminal located 34 kilometres up the Fraser River has the real estate and a majority of the infrastructure already in place to provide upward of 1,000,000 TEU of container capacity. Located on a natural marine highway, in the epicentre of off dock and industrial areas, Fraser Surrey Docks believes environmentally low cost container capacity can be achieved with as little as 10% of the cost of other options.”
- Port Metro Vancouver has effectively muzzled the voice of Fraser Surrey Docks.
The Coal Facility at Surrey Docks should not proceed as it not economically, environmentally or socially feasible.