Comments on GCT Deltaport Expansion Berth Four Project

The proposed GCT Deltaport Expansion Berth Four Project as planned would have significant adverse impacts on aquatic habitats based on the following factors alone.

The 8 December 2006 conclusion of "no significant adverse environmental impacts" related to the Deltaport Third Berth Project was predicated on the assumption of appropriate mitigation measures to be implemented (https://www.ceaa-acee.gc.ca/052/details-eng.cfm?pid=3734). Despite multiple creative ideas for aquatic habitat compensation habitat, the benefits of those proposed compensation efforts will remain un-quantifiable over the long term. It is not known if they will be effective at all. Additionally, the potential aquatic habitat compensation sites proposed are in puzzlingly distant areas which not only fail to benefit the life history stages and species that would be directly affected by the proposed GCT Deltaport Expansion Berth Four Project, the creation of such compensation habitats also would displace habitat benefits to species currently using those exisitng habitats.  It is extremely unlikely that sufficient benefits would be available to fully compensate any further development activities on Roberts Bank.  

On 1 April 2003 Fisheries and Oceans Canada indicated they were not prepared to authorize fish habitat destruction for a then-proposed expansion on the east side of the Deltaport causeway (https://www.projects.eao.gov.bc.ca/api/public/document/588695eba4acd4014b81f2e6/download/Letter%20dated%20Apr.%201_03%20from%20Jeff%20Johansen%20%28DFO%29%20to%20Pat%20McLaughlin%20and%20Darrell%20Desjardin%20%28Proponent%29%20regarding%20the%20Proposed%20Container%20Terminal%20Expansion%20at%20Roberts%20Bank.pdf ).  Given that the GCT Deltaport Expansion Berth Four Project coincides with the project expansion proposed in 2003, and limited opportunity to create additional beneficial compensatory aquatic habitat, it should be reasonable to assume that the impacts of the proposed GCT Deltaport Expansion Berth Four Project would give arise to a conclusion of significant adverse effects.  

Further, regional cumulative effects on the aquatic environment in the Roberts Bank remain unassessed and of widespread concern.  

Also, justification of the project on economic grounds has also been questioned.

Should political decision making (by Governor in Council) be required whether the project should proceed, it behooves the Agency to ensure that Governor in Council also be presented with:

a)  a completed regional cumulative effects assessment of projects affecting aquatic habitats of Roberts Bank and species which depend upon them;

b) a fully developed assessment of alternatives to the project.  Alternatives to the project should include expansion of the Port of Prince Rupert, and a no-project alternative.  The no-project alternative should consider the merits of ever-expanding global shipping in light of sustainability and carbon emission imperatives.