You still have five days left to comment
The last post to this blog was about the proposed replacement of the Massey Tunnel by a massive bridge. A small group of people have been getting together to try and co-ordinate activity opposing the province’s proposal. This is what we have so far:
Urgent Deadline for Public Comments on George Massey Tunnel Replacement Project
Please Act Now DEADLINE FEBRUARY 15, 2016
The B.C. Environmental Assessment Office (EAO) is requesting public comments on the valued components in the environmental assessment for the Massey Tunnel Replacement Project.
Click on the RealMasseyTunnelHearings link below. There is a form for you to submit your comments. You can write your comments there or prepare ahead and copy and paste into the space provided. The site provides some information for you consider and there is more below.
Visit Real Massey Tunnel Hearings to get a quick overview of some of the concerns people have identified with this project. You can send your comments to the EAO directly through the website, and they will be automatically forwarded to our municipal, provincial and federal elected representatives. This is our best chance for building awareness of public concerns about this proposal.
- The impacts of this Project are far-reaching and should include a Review Panel federal environmental assessment.
- More information is needed and there should be a future opportunity for input on Scoping and Valued Components before the Application is allowed to proceed,
- The Project is too large and too expensive
- Traffic Congestion will increase at the Oak Street and Knight Street Bridges
- The Project information fails to recognize the national and international significance of the Fraser River Estuary for salmon, sturgeon, eulachons, endangered whales and migratory birds of the Pacific Flyway.
- A 45% percent increase in truck traffic in this region is unacceptable and credible alternatives are available.
- The Project will have a negative impact on regional air quality.
The following are more specific points for your information.
Definition of Valued Component
“For the purpose of environmental assessment in BC, Valued Components (VCs) are components of the natural and human environment that are considered by the proponent, public, Aboriginal groups, scientists and other technical specialists, and government agencies involved in the assessment process to have scientific, ecological, economic, social, cultural, archaeological, historical, or other importance.”
Page 4: EAO: Guideline for the Selection of Valued Components and Assessment of Potential Effects
Valued Components Commentary
- The Open Houses and public information document, ‘Project Description and Key Areas of Study’ have failed to provide sufficient information for the public to make informed comments on the Scope and Valued Components of the George Massey Tunnel Replacement Project (GMTR).
- The B.C. Environmental Assessment process states scoping should be prepared by the B.C. Environmental Assessment Office prior to request for public input on the scope and valued components:
“Issues scoping should begin early in project planning, before initial regulatory submissions, such as the Project Description and draft AIR, are made, as the information gained during issues scoping will inform not only the selection of VCs but also the determination of the scope of the assessment…”
(Note: AIR – Application Information Requirements)
Page 8: EAO: Guideline for the Selection of Valued Components and Assessment of Potential Effects http://www.eao.gov.bc.ca/pdf/EAO_Valued_Components_Guideline_2013_09_09.pdf
- There needs to be a future opportunity for public comment on a credible document which clearly outlines the Scope and Valued Components as identified by the Proponent; the BC Ministry of Transportation; the B.C. Environmental Assessment Office; the Canadian Environmental Assessment Agency; Transport Canada; the Canadian Ministry of Environment and Climate Change; and Health Canada; and Public Safety Canada.
- While the document claims engagement has taken place with Provincial and Federal regulatory agencies, no information is provided as to Scope and Valued Components. It states that will come later. The public and municipalities cannot be expected to comment on Scope and Valued Components without any substantive information from the government agencies. As Scoping and identification of Valued Components are essential to the environmental assessment, the public must be afforded an opportunity to provide comment once these have been credibly identified with supporting documentation.
- The information is incomplete as it does not include the requirement of environmental assessment pursuant to the Canadian Environmental Assessment Act. Due to the importance of the Fraser River Estuary and the cumulative impacts of this Project and several other past, current, and planned projects, a Review Panel Environmental Assessment should be required., Some reasons for the requirement of a federal assessment:
Ø Decommissioning of the Massey Tunnel
Ø Length of the new bridge
Ø Requirements under the Fisheries Act, Canadian Environmental Assessment Act, Navigation Protection Act, Species at Risk Act, Migratory Bird, Environment Protection Act etc.
Ø Ecological and social upstream and downstream effects – scour and infill processes
Ø Endangered and threatened streams critical to viable fish habitats and migratory birds
Ø Watercourses that support fish and fish habitat
Ø Effects on the salt wedge
Ø Impacts on interactive, interdependent riparian habitats between the shoreline and the Fraser River critical to viable fish habitats and species at risk
Ø Impacts to water quality of the Fraser River and adjacent communities
Ø Permits and approvals that are required for the Project – need to identify and list
Ø Effects on navigation in the Fraser River and the shipping route to the open Pacific
Ø First Nations interests, information, land use, Fraser River use and claims
Ø National, provincial and international designations recognizing international ecological significance of the Fraser River Estuary
Ø Cumulative effects of past, current and planned Projects on the South Arm of the Fraser
Ø Hydro technical impacts
Ø Health of fisheries and potential impacts on commercial fishing
Ø Need for a risk analysis to address uncertain residual effect predictions
- National and international significance of the Fraser River Estuary for fish species, migratory and resident birds and endangered whales needs to be included. The lower Fraser Estuary is a declared RAMSAR site which means it is an internationally- recognized Wetlands. The area is also a designated site in the Western Hemispheric Shorebird Reserve Network as well as the site of the top three Most Important Bird Areas in Canada.
- The information is incomplete as it does not identify federal, provincial, regional and municipal land plans, codes, regulations, standards, and initiatives such as Official Community Plans, Regional Growth and Sustainability Strategies, Climate Action Plans, archaeological information and numerous other initiatives. The document states it is reviewing some of these documents but no specifics are provided.
- The information is incomplete as it does not identify effects on cross boundary agreements and initiatives which may be affected by the Project.
- The Project Rationale should include information on alternative options – continue upgrading and retaining the Massey Tunnel; twinning the tunnel; or building a much smaller bridge.
- The section on traffic congestion claims truck traffic will double by 2045. This reason should not be supported in terms of air pollution and safety. Alternatives to increased truck movements (such as inland transloading at Ashcroft) should be presented to the public.
- The section on traffic congestion should include the problem of moving congestion from the Massey Tunnel to the Oak Street and Knight Street Bridges.
- Project Benefits are just descriptive. They need to be substantiated with credible studies. They ignore many public valued components such as clean air, protection of farmland, and use of tax dollars.
- Impacts of Bridge Height should be included – safety, ice, interference with migratory birds of the Pacific Flyway, Sandhill Cranes, night hunters and the largest number of wintering raptors in Canada.
- Impacts of preloading, highway construction, and decommissioning of the tunnel are descriptive and fail to identify valued components.
- Specific information on the installation of pilings and potential impacts should be included – depth, procedures, safety, noise pollution and impacts on fish and wildlife habitat.
- A safety risk assessment for the Massey Tunnel during construction needs to be included. Continuous drilling and vibrations have the potential to impact the tunnel making it potentially unsafe.
- Project costs of $3.5 billion should be itemized with information of how the Project will be funded. A Cost/Benefit Analysis and a Feasibility Study should have been provided at the earliest stages of this assessment. Use of tax dollars is a valued component that needs to be transparent.
- While the document claims Aboriginal Group Engagement, no information is provided for the opportunity to comment on valued components.
- Changes in Fraser River hydraulics, water quality and sediment are identified. These valued components should include permits required by the federal Department of Fisheries and Oceans and the need for a federal environmental assessment.
- Fish and fish habitat are not correctly identified. This section should include studies done over the years by the Fraser River Estuary Management Program that include habitat classifications. Areas of the bridge project include important riparian habitats. These are coded red which are shoreline areas having highly productive habitat. Credible evidence needs to be provided for blanket statements of “low aquatic habitat values.”
- Species at Risk such as the White Sturgeon and Coho Salmon should be identified and included. This should trigger a federal environmental assessment.
- Underwater noise may affect marine mammals. This section should include recent studies that find noise effects whales more than previously understood.
- There will be negative Impacts on wildlife from noise and light pollution during construction and as a result of the Project. Night hunters will be permanently impacted. This is a valued component.
- Vegetation in the area of the Project is varied. Ditches, old streams and water courses support rare or at-risk species. These valued components should have been identified in this section.
- Habitat for endangered Pacific Water Shrew and Barn Owl will be impacted. This project will add to the ongoing loss of critical habitats in the Fraser River Estuary.
- The following statement on air quality is an opinion:
“The Project is expected to result in an improvement in air quality, especially in the vicinity of the Tunnel, as a result of improved traffic flow, since vehicles driving at highway speeds consume less fuel and generate lower emissions. In addition, the new bridge is elevated above ground level, allowing airflow over the top and beneath the bridge, which contributes to improved dispersion of pollutants.”
Congestion will move to the Richmond bridges causing pollution in other areas. Doubling truck traffic by 2045 is not going to improve air quality as stated in this section.
- Air quality is a valued component that needs more information than is provided here to the public. With all the studies and work over the past few years, the public deserves specific, credible, referenced information.
- Impacted farmland and environmentally sensitive areas should be specifically identified. Anticipated no net loss of farmland and expected benefits are meaningless without substantive information.
- Impacts on human health should include stress with ongoing construction: congestion, air pollution, light pollution, noise pollution.
- An environmental risk assessment is a valued component that should be included.
- The information provided to the public fails to meet the principles of transparency, participation, credibility, and purpose that have been established by the International Association for Impact Assessment.