Metro Vancouver calls for a Federal Environmental Assessment of the Massey Tunnel Replacement Project
The following is the text of the letter approved by the Metro Vancouver Board today
Planning, Policy and Environment
Tel. 604.432.6350 Fax 604.432‐6296
The Honourable Catherine McKenna
Minister of Environment and Climate Change
200 Sacré‐Coeur Boulevard
Gatineau, QC K1A 0H3
Re: Request for a Federal Environmental Assessment of the George Massey Tunnel Replacement Project
On behalf of the Board of Directors of the Greater Vancouver Regional District (‘Metro Vancouver’), I am writing to advise that at its April 1, 2016 regular meeting, the Board adopted the following resolution:
That the GVRD Board send a letter to the federal Minister of Environment and Climate Change requesting that the Minister, pursuant to section 14(2) of the Canadian Environmental Assessment Act, 2012, order a federal environmental assessment of the George Massey Tunnel Replacement Project.
Metro Vancouver is the regional government for the southwest region of British Columbia and is comprised of 21 municipalities, 1 electoral area, and 1 Treaty First Nation. We provide regional planning, regional utilities (including liquid waste, solid waste, and drinking water), and political leadership to a total population base of approximately 2.4 million in the greater Vancouver area.
Given our broad responsibilities in delivering regional services and in protecting the ongoing livability of this region, our Board is requesting a federal environmental assessment of the George Massey Tunnel Replacement Project. We are requesting that a federal environmental assessment be referred to a review panel on which Metro Vancouver and other key stakeholder groups would have an
opportunity to participate.
Federal Environmental Assessment Review Request
Metro Vancouver’s specific concerns with respect to the George Massey Tunnel Replacement Project are related to our legislative responsibilities in the areas of regional growth management and planning, air quality and climate change, environment, regional parks, and regional utilities.
The Province of British Columbia Ministry of Transportation and Infrastructure’s proposal to replace the existing George Massey tunnel with a 10‐lane tolled bridge has the potential to cause significant adverse environmental effects. Potential impacts include:
1. Changes to Regional Transportation Patterns which Affect Regional Growth Management.
Although two lanes of the 10‐lane tolled bridge are to be dedicated transit/HOV lanes, the project as a whole represents a major ($3.5 billion) expansion of car‐oriented infrastructure.
If implemented, it will create growth pressures that may impede the realization of Metro 2040: Shaping our Future, the regional growth strategy, which promotes compact, transit oriented development patterns, the efficient use of land, and an efficient transportation network.
The potential impacts of this project on surrounding agricultural land, which the regional growth strategy strives to protect, and the potential to shift traffic congestion to adjacent communities, are of particular concern.
Transportation decisions and future land use are inextricably linked and have direct and far reaching effects on the environment. These decisions will influence, if not determine, whether human settlement patterns are compact or sprawling. A project of this magnitude requires an understanding of its impacts on future growth in the region to determine its potential to cause significant adverse environmental effects.
2. Greenhouse Gas Emissions and Climate Change
Metro Vancouver and its member municipalities are committed to reducing greenhouse gas emissions and taking action on climate change. Metro 2040: Shaping our Future, the regional growth strategy, encourages land use and transportation infrastructure that reduce energy consumption and greenhouse gas emissions, and improve air quality. It contains strategies to help Metro Vancouver and member municipalities prepare for, and mitigate risks from, climate change. In addition, municipal official community plans include provincially mandated greenhouse gas emission reduction targets.
The Ministry of Transportation and Infrastructure’s Project Definition Report for the George Massey Tunnel Replacement Project anticipates lower idling‐related greenhouse gas emissions, but contains no information related to the potential greenhouse gas emissions that will result from the project as a whole, which may be significant. The Project Definition Report omits any mention of climate change.
Through the Province of British Columbia’s environmental assessment review process thus far, the Ministry of Transportation and Infrastructure has committed to an evaluation of potential project‐related changes in greenhouse gas emissions, but only in response to the demands of stakeholders. With respect to climate change specifically, the Ministry of Transportation and Infrastructure has indicated it will examine how climate change may impact its project, but will not consider the potential contribution of the project to climate change.
The potential for this project to increase greenhouse gas emissions and contribute to climate change is of concern given the commitments of local, provincial, and federal governments to address climate change impacts. Minimal information is provided on the potential long‐term significant adverse environmental effects related to greenhouse gas emissions and therefore, this project requires a more thorough evaluation on these impacts.
The Fraser River estuary is the single most important area of aquatic bird and raptor habitat in British Columbia. The intertidal marshes found in the estuary provide critical rearing areas for juvenile salmon. Metro Vancouver has a legislative responsibility to consider the regional and cumulative impacts of projects on the region’s ecology.
In addition, the current George Massey tunnel and the proposed new bridge bisect Metro Vancouver’s Deas Island Regional Park, having a direct impact on habitat for which Metro Vancouver is the public steward.
A federal environmental review would, we hope, involve a more comprehensive and complete look at the Fraser River estuary than the current provincial environmental review entails. The public concerns related to the potential significant adverse environmental effects on the Fraser River and the Park, in our opinion, necessitate a federal environmental review.
Metro Vancouver believes that the concerns raised in this letter highlight the potential for significant adverse environmental effects and, in Metro Vancouver’s view, provide a compelling case for a federal environmental review. Metro Vancouver therefore respectfully requests you use your discretion, pursuant to section 14(2) of the Canadian Environmental Assessment Act, 2012, to order a federal environmental assessment of the George Massey Tunnel Replacement Project. Metro Vancouver requests, as well, that you consider referring the federal environmental assessment to a review panel on which key stakeholder groups, including Metro Vancouver itself, would have an opportunity to participate.
Thank you for your consideration of these requests.
Chair, Metro Vancouver Board
cc: The Honourable Mary Polak, BC Minister of Environment
The Honourable Todd Stone, BC Minister of Transportation and Infrastructure
UPDATE to which should be added
From: Eliza Olson [*******]
Sent: Saturday, April 02, 2016 3:23 PM
To: ‘firstname.lastname@example.org‘ <email@example.com>
Cc: ‘firstname.lastname@example.org‘ <email@example.com>
Subject: Attention: Greg Moore, letter to Hon. Min. McKenna
Greg Moore, Chair Metro Vancouver Board,
Congratulations on a very insightful letter sent to the Hon. Catherine McKenna, Minister of the Environment and Climate Change, requesting a Federal Environmental Assessment of the George Massey Tunnel Replacement Project.
Under Section 3 Habitat, there is no mention of the potential impact of the replacement of the tunnel on the Fraser Delta Ramsar Site, No. 243, specifically the South Arm Marsh.
In 2012, the Fraser Delta Ramsar site was proclaimed. This is an international designation bestowed upon wetlands of international importance at the request of the originating country. This includes all levels of government within that country. In the case of the Fraser Delta Ramsar Site, the request began with the Corporation of Delta, then Metro Vancouver, the BC Government and finally the Federal Government.
I am bringing this to you attention because it appears that since the great celebration that took place in 2012 that the moral obligations that go with asking and accepting the Ramsar designation of the Fraser River Delta as a “wetland of international importance” appears to be forgotten.
Failure to honour our international obligations regarding the Fraser Delta Ramsar Site No. 243, regardless how unintended, can bring dishonour to all levels of government.
The following wetland areas included in the Fraser Delta Ramsar Site No. 243, are Alaksen, Burns Bog, Boundary Bay, Serpentine, South Arm Marsh and Sturgeon Bank.
I am sure that this was not the intention of your letter. I am bringing this to your attention as a humble servant.
Eliza Olson, LLD., B.Ed
Burns Bog Conservation Society
Did you know that an area of peatland the size of a soccer field stores the equivalent of CO2 that your car produces going around the world 3 times? Help us save our peatlands. Give today. www.burnsbog.org
My email inbox has been filling up today with a contretemps on LNG on the Fraser playing out in the letters page of the Richmond News. Since I have learned that it is sometimes a bit tricky getting to see on their web page what has been printed in the paper, I thought it might be useful to set out the correspondence here.
The day started with an email from Viviana Zanocco who is the Community and Aboriginal Relations Manager in External Relations department of FortisBC to undisclosed recipients.
As part of our commitment to sharing project-related information with you in a timely manner, attached is a letter in which we respond to misinformation presented in a recent letter to the editor published in the Richmond News; we’re sharing it with you prior to its distribution to the media.
In the letter, a local resident said the George Massey tunnel replacement project is being driven by the needs of LNG proponents and could impact fish and fish habitat. This is something we’ve heard repeated in the community as the discussion about the bridge replacement unfolds and requires clarification.
The fact is that LNG carriers that could one day ply the waters of the Fraser River would be able to do so even if the tunnel remains in operation. WesPac Midstream LLP is proposing to build an LNG marine terminal next to our Tilbury LNG facility, which we’ve safely operated on the shores of the Fraser River since 1971. The jetty would be built to accommodate vessels in the same size range or smaller than the existing vessels currently operating on the Fraser River. WesPac has confirmed publicly that the concept under review wouldn’t be impacted regardless of whether or not the tunnel remains in operation.
We also believe that LNG will play an important role for the marine transportation industry in reducing emissions and potential environmental impacts associated with the use of heavy oil and diesel.
FortisBC’s Richmond News_ Letter to the Editor is a pdf file you can read from that link
I am indebted to Susan Jones of Fraser Voices for the following rebuttal
In the letter to the Richmond News it is stated:
Whether the George Massey Tunnel is removed, replaced or expanded – or how the proposed bridge project is constructed – will have no impact on the WesPac proposal.
[This is] simply not true
Port Metro Vancouver (PMV) discussed LNG ships and the George Massey Tunnel Replacement Project with the Gateway group.
The following are some notes I have on this topic. Those FOI emails acquired by Voters Taking Action Against Climate Change and newspaper articles indicate that the LNG operations were included in the discussions between PMV and the federal and provincial governments.
BC Government representatives began a series of meeting with Port Metro Vancouver in early 2012 as the port made it clear that:
“The tunnel is also a marine bottleneck. It was not designed for the size of ships used in modern day trade, which must access the Fraser River in Richmond and Surrey. As a result, the tunnel is becoming a significant obstacle to international trade on the Fraser.”
(Robin Silvester, CE0, Port Metro Vancouver: Vancouver Sun, April 29, 2012)
Discussions were underway about clearances for the new potential crossing and Port Metro Vancouver made it clear to the government that plans should include air drafts to accommodate large ships:
“Liquid bulk tankers with larger air draft requirements (e.g. LNG) should be considered,”
(Port Development Strategies Manager, Jennifer Natland, Nov. 29, 2012 to Project Planners)
On September 20, 2013, the B.C. Government announced plans to build a bridge instead of replacing the tunnel. Port Metro Vancouver was included in the following meetings for planning and design. Emails show that port staff urged the province to design a taller bridge, even though that would mean higher costs, a more challenging design and a steeper grade for Highway 99 traffic on both approaches.
On July 16, 2014, Port Metro Vancouver CEO, Robin Silvester queried:
“What is the air draft of the largest length LNG vessel that we could imagine in the river?”
Port marine operations director Chris Wellstood responded:
“…we feel that the 61-metre MAX air draft would allow for the larger part of the world’s LNG fleet” – tankers up to 320 metres long- to pass under new bridge and head up the Fraser.””
In another exchange of emails:
“On a June 5th a follow up meeting between PMV and Gateway was held to discuss PMV’s height requirement and as a result of that meeting Gateway was going to provide a revised drawing with a 130 m one-way channel for clearances…
…The main issue with additional height for the bridge is that the shore landings need to be higher and longer which increases the overall cost of the project…
…Please let me know if you see a problem with the original height requirements requested by PMV in 2012…”
(Chris Wellstood, Director Marine Operations & Security, Habour Master to Cliff Stewart, to Cliff Stewart, Vice President, Infrastructure Delivery, Port Metro Vancouver, July 15, 2014)
A June 2014 briefing note by port officials following a meeting with provincial counterparts cautions:
“…there are multiple challenges with high costs to achieve PMV’s requested height” of 65 metres”.
These negotiations did not include the public or the local governments. The public have not been provided with credible information for other options such as upgrading the existing tunnel, twinning the tunnel, a smaller bridge or retaining the status quo with better transit and restrictions on truck hours.
In spite of repeated requests for the business case for this Project, the provincial government has failed to produce this information. This should have been presented to the public and local governments for comment in the early planning stages.
Also considerations of safety with LNG vessels on the river has not been addressed.
This LNG production and export are putting the public at great risk as they contravene international LNG Terminal Siting Standards as outlined by the Society of International Gas Tanker and Terminal Operators (SIGTTO). The Standards claim LNG ports must be located where they do not conflict with other waterway uses as all other vessels must be considered as ignition sources. The narrow, highly populated lower Fraser River, and narrow shipping lanes through the Gulf Island do not meet the international safety standards of wide exclusion zones.
If that is not enough you might also like to read Elizabeth May’s trenchant comments on BC’s approach to LNG tanker safety
Press Release from The Wilderness Committee and Fraser Voices
Open letter urges government to review project and consider alternatives
RICHMOND, BC – Community and national organizations are calling on the federal government to launch an environmental review of the proposed Massey Tunnel Replacement Project and to withhold federal infrastructure funding from the project.
Resident group Fraser Voices, the Wilderness Committee, Council of Canadians and five other organizations representing over 160,000 members and supporters have sent an open letter urging the federal government to use the money it has promised for infrastructure to fund transit projects in Metro Vancouver instead of the new 10-lane highway bridge.
“This federal money gives Canadians an opportunity to correct the mistakes of the past and build a greener future,” said De Whalen, one of the founding members of Fraser Voices. “But the Massey Bridge is imposing the same old car culture from the 1950s.”
The federal government has said it will fund environmental and social infrastructure with its $10 billion per year stimulus money. Extra vehicles resulting from the Massey Bridge and will add about seven million tonnes of carbon dioxide to the atmosphere over 50 years.
“It is irresponsible to be building new highways during a climate crisis, especially when they do nothing to ease congestion,” said Peter McCartney, Climate Campaigner for the Wilderness Committee. “Even the mayor of Houston, Texas – with its 26-lane freeway – agrees it’s time to stop building highways and build transit instead.”
Community groups are hoping the federal budget next week will include funding for the Broadway Skytrain project and Surrey LRT instead. Along Highway 99, rapid bus service could ease congestion for a fraction of the $3.5 billion price tag of the proposed Massey Bridge.
The following is a press release recently recieved from Modo
Millennials decidedly more likely to embrace benefits of carsharing than older residents
Vancouver, B.C. (March 10, 2016) – Growing exposure to carsharing in recent years is changing the perceptions of Metro Vancouver drivers, who may be considering selling their personal vehicles in favour of carsharing, according to a new Insights West poll conducted in partnership with Modo, Vancouver’s first and only carsharing co-operative.
In the online survey of a representative sample, 13 per cent of Metro Vancouverites say they have relied on carsharing to get around the region over the past year—a proportion that reaches 22 per cent among Millennials (residents aged 18-to-34). With Millennials feeling the financial squeeze in an increasingly expensive region, and with 70 per cent agreeing that carsharing is “an attractive option for people in my age group”, carsharing among this demographic is expected to rise sharply.
Even Metro Vancouverites who have not yet tried carsharing believe it offers significant benefits, with two thirds (65%) perceiving it as “less hassle than owning a car” and a majority citing the importance of savings from fuel costs (62%) and vehicle maintenance (57%). Half of Metro Vancouverites also say carsharing reduces traffic and congestion (49%) and provides easy access to parking (also 49%); which is a positive trend in a region striving to be seen as green, sustainable and most importantly, livable.
“Our members love that we offer them the flexibility to enjoy a less car-dependent lifestyle. They can drive one of our 450 different Modos – from sports cars to SUVs – when they need to without being tied down financially to owning and maintaining a private vehicle,” says Selena McLachlan, Director of Marketing & Business Development at Modo.
McLachlan says that it’s no surprise that the cost savings of carsharing are a highly ranked benefit among the general public. The survey found that seven-in-ten Metro Vancouverites (72%) say they would rather spend their money on other things than car maintenance.
“With the average cost of car ownership hovering around $9,000 per year, it’s easy to see why so many people are making the switch to carsharing and why we’ve experienced steady growth in our membership for the last nearly twenty years. For many of our 15,000 members, the decision to carshare is simply one of pragmatism,” comments McLachlan.
According to the survey, the majority of Metro Vancouver car owners (57%) acknowledged that the benefits of carsharing would make them contemplate selling their car, including 85% of Millennials and 55% of Generation Xers. Savings from vehicle maintenance (37%) and fuel costs (34%) are the most attractive features of carsharing among car owners who would consider shedding their vehicle.
“Carsharing is definitely growing across Metro Vancouver and as people are becoming more familiar with its benefits, their attitudes towards personal vehicle ownership are changing,” says Mario Canseco, Vice President, Public Affairs, at Insights West. “Most Metro Vancouverites younger than 55 are pondering whether it is a good time to vacate the garage and start carsharing.”
As part of the study, a separate survey was conducted with a sample of Modo members, which shows that they are already experiencing the benefits that other Metro Vancouver car owners (who are not yet carsharing) are attracted to, with more than four-in-five saying that saving on vehicle maintenance is important to them (84%) and that carsharing is “less hassle than owning a car” (82%).
Add this to their ability to conveniently book a different kind of Modo for every type of trip – from a sporty Fiat Abarth to a practical Honda CRV – in advance or on the fly, the case for signing up as a member becomes even more compelling. It’s clear that carsharing is changing the transportation landscape in the region and that many residents are seeing this as a positive. Across Metro Vancouver, just under half of residents (47%) consider carsharing as an important part of their city’s transportation choices.
This item was inspired by one of Ken Ohrn’s posts on Price Tags. Not that I am complaining, you understand. One must acknowledge that an effort is being made to improve cycling safety here, but at this particular location not much more was needed to produce something that would actually be safe. Designated lanes are better than sharrows – or nothing at all – but a painted line does not really do much to actually separate out two different modes. A kerb would be better: a boulevard or barrier even more so.
The road is very wide with a large park like central median with mature trees. While the posted speed is the standard 50 km/hr the combination of the median and the broad paved area encourages much faster speeds. I observe that when I or my partner drive at the posted speed, everyone else is moving much faster. Since these improvements were made that has got a bit better at busy periods.
This is the intersection of King Edward and Valley. It was formerly one moving traffic lane with parking permitted at the kerb. Paint has been used to designate a bike lane between the parked cars at the curb and the general purpose (GP) traffic lane. You will also note that only a very short length of the curb lane becomes a right turn lane at the intersection.
If the double white line had been moved towards the curb by a metre then the parked cars would have acted as a buffer between the moving vehicle traffic and the bicycles, and the risk of dooring by a driver reduced. Of course, the risk of dooring by a disembarking passenger would have been greater and the bus stops required a different treatment.
The bus stop is on the far side of the intersection (of course) and the bollards have been put in now to stop the parking space being used as a queue jumper. Traffic backs up down the hill from the traffic light at Arbutus Street. You will also observe that there are no cars parked when the picture was taken (mid afternoon, weekday). That is because there is ample off street parking provided within the Arbutus Village development on the right. There is really no need for parking along this side of this part of the avenue. Prior to this work there were essentially two travel lanes – and a bit of a freeway mentality for the car drivers. The green paint patches are for the driveways at the Village entrances/exits.
Now some will say that additional road width would be needed to allow for a proper protected bike lane. It seems to me that a narrower GP travel lane is already in place but has not done very much to reduce speeds. I suppose old habits die hard. Moreover there is plenty of space available but we do get awfully close to a knee jerk reaction when trees and lawn are threatened. Up at the Arbutus Intersection the paved right turn lane has been extended – simply because the large number of hefty off road pick ups and all wheel drive SUVs had created a longer informal turn lane out of the uncurbed median.
This is the Google map view
That is the name that a small group, unified its opposition to megabridge Massey Tunnel replacement project chose for itself last night. The forces of No once again facing up to the deceptions of the Christy Clark government.
There are two contributions from that group this morning. The first is the GMTRP brief draft prepared by Nicholas Wong – a substantial document that may get some updating and, if it does, will get replaced by later versions over time. For now here is the first paragraph of the Executive Summary, which should convince you it is worth your time to read the whole thing: the brief deals only with the traffic, seismic, and pricing concerns and thus leaves a whole raft of issues unexamined
The GMTRP has been plagued by contradictory or absent information. In such an environment, it is impossible to form an educated opinion of the project. To explore the systematic nature of the political deception surrounding the bridge proposal, three broad areas were explored: traffic, seismic safety standards, and budgetary concerns. The conclusion being that removing the GMT is unnecessary and a poor economic choice to alleviate traffic congestion or to address any of the stated project goals. The only advantage to removing the GMT is to allow larger ships up the Fraser River indicating that the tolled crossing is designed as a subsidy for the export industry.
The second is the text of a report which was adopted by the Richmond Council General Purposes Committee last Monday and will go to Richmond Council for final vote this coming Monday.
To: Mayor and Council Date: February 10, 2016
From: Harold Steves File: 10-6350-05-08
Re: George Massey Tunnel Replacement Project
Richmond Council is concerned about the abrupt change in direction from upgrading the George Massey Tunnel to building a bridge. Richmond Council was fully consulted on the publicly announced plan to twin the tunnel. Richmond Council was not consulted on the decision to change the plan to building a bridge.
The following attachments show how the project changed abruptly from a tunnel to a bridge:
1) July 15, 2004 Massey Tunnel seismic upgrade. Province to spend $22.2 million on seismic upgrade for the Massey Tunnel.
2) Feb. 16, 2006 Twinned tunnel part of Victoria’s long-term plan, “expandingHighway 99 on both sides of the tunnel from four lanes to six.” “The project is on the back burner in part because it would put pressure on traffic bottlenecks to the north requiring expansion of the Oak Street and Knight Street bridges into Vancouver or a new bridge into Burnaby.
3) Feb. 18, 2006 Massey Tunnel will be twinned and “widened from four lanes to six once the provinces more pressing transportation projects are complete.” “Twinning the tunnel would also require improvements to other crossings over the North Arm of the Fraser, such as Oak Street and Knight Street bridges, or a new crossing to connect with growing central Burnaby.”
4) Dec 11, 2008 BUS LANE WILL SPEED TRANSIT commute along Highway 99 with ” high quality, point to point service … between White Rock and Richmond. A “$4.7 million contract” was awarded “to build the four metre wide shoulder bus lane.
5) Feb. 2, 2012 “BC Government meets with Port Metro Vancouver, Surrey Fraser Docks and Engineers to plan George Massey Tunnel Replacement Bridge”
6) Nov. 19, 2012 “Clearances for potential new river crossing” “We should consider future terminals. For example liquid bulk tankers, with large air draft requirements(e.g. LNG)” ….. “We need to consider future terminals such as VAFFC, Lehigh, and possible terminal at our Richmond properties.”
7) Dec. 4, 2012 “Tunnel: Depth required is 15.5 metres below geodetic datum for 50 year life expectancy and 18.5 metres below for 100 year life expectancy.”
8) March 19, 2015 The 14 billion transit plan the BC Liberals conveniently forgot.
9) Nov. 5, 2015 Stone insists Massey bridge process is proper.
The Province spent $22.2 million on a seismic upgrade on the Massey Tunnel in 2004, announced the tunnel would be twinned in 2006, and announced rapid bus in 2008. Studies were done that justified twinning the tunnel and improving public transit. It was noted that the carrying capacity of the Oak Street Bridge and other bridges was limited and therefore the tunnel should only be six lanes. Rapid Bus would reduce traffic and reduce GHG’s. Richmond Council was opposed to both a No. 8 Road Bridge to Delta and a bridge to Boundary Road in Burnaby because it would do irreparable damage to Richmond East farmland. The Rapid Bus system resolved that problem.
What caused the province to suddenly change from a tunnel with public transit to a bridge without it?
The FOI information from Doug Massey shows a concerted effort was made in 2012 by Fraser Surrey Docks and Port Metro Vancouver and others to have the tunnel removed to accommodate deep draft Panamex supertankers. The BC Government met with them to discuss tunnel removal on Feb 2, 2012, future terminals at VAFFC, Lehigh and a new one in Richmond, including liquid bulk tankers (e.g. LNG); and the need to dredge the river to 15.5 metres on Dec. 4, 2012. Secondly the more conservative members in the Liberal Caucus appear to have gained control in the 2013 election.
On Nov 5, 2015 Todd Stone admitted that they did not yet have a business case for a bridge, Now the reason is clear. It appears that the province changed their plans to permit the industrialization of the Fraser River by Port Metro Vancouver. They did not have a business plan for a bridge because the business case was for twinning the tunnel and providing Rapid Bus.
That the City of Richmond request that the Provincial Government provide copies of all reports and studies – including but not limited to business plans, feasibility studies, technical studies, seismic studies, and/or environmental impact studies – that relate to the original plan to twin the George Massey Tunnel and/or provide Rapid Bus service that were considered during the period from 2006 to 2008; and that if necessary, that the foregoing request be made as an official Freedom of Information request.