Resources
» Links
» Perimeter Road Submissions

Fraser River Coalition Submission on the SFPR
--------------------------------------------------------------------------------

28616 Haverman Road,

Bradner, B.C. V4X 2P3


December 15, 2006

Jody Shimkus, Project Assessment Director

Environmental Assessment Office

PO Box 9426 Stn Prov Govt

Victoria, BC V8W 9V1





By fax 1-250-387-2208 and via e-mail: eaoinfo@gov.bc.ca



Dear Ms. Shimkus:

Who We Are:

The Fraser River Coalition (FRC) 30,000 plus membership (of ENGO’s, environmental groups, societies, and special interest groups) have been dedicated to the health, enhancement and protection of the Lower Fraser River and its remaining wetlands since January 1977.

Since our inception, the Fraser River Coalition has participated in the evolving Fraser River Estuary Study (FRES) which evolved into the Fraser River Action Plan (FRAP-1991-1998), the Fraser River Estuary Management Plan (FREMP) , and the Burrard Inlet Environmental Plan (BIEAP) to protect the environmental integrity of the Fraser River Delta in a sustainable manner. We have worked side by side with the Boundary Bay Conservation Committee (BBCC) and the Burns Bog Conservation Society (BBCS) toward this end.

The Coalition strives to raise awareness to all levels of government on threats to the Fraser estuary and wetlands, which is precisely what the proposed South Fraser Perimeter Road is…a threat to the natural integrity and sustainability of the Estuary and of Burns Bog and to the creatures who depend upon both, for their survival whether in permanent or transient residence!

The SFPR as a Threat to the Integrity of the Estuary and of Burns Bog

The Fraser River Delta, and in particular, the proposed South Fraser Perimeter Road (SFPR), therefore fall under our mandate. The potential threats to the Fraser River Delta from terminal expansions by the Fraser River Port Authority, the North Fraser Port Authority, the Vancouver Port Authority, the Tsawwassen Indian Band and the subsequent pressures for those developments, by extension, of port expansions in Prince Rupert, are also of interest to the Fraser River Coalition.

We Question the Need for the Port Expansion and by Extension, the Need for the SFPR

With the proposed development of a container Superport at Prince Rupert being announced after the Environmental Assessment Application (EAA) document was prepared, we agree with the Boundary Bay Conservation Committee (BBCC), that the “industry projections for BC need to be re-assessed in the light of the Prince Rupert proposal in order to justify or modify the VPA’s projections of need for container facilities, and therefore, of the SFPR, on the environmentally-sensitive Roberts Bank.”

Page 2-Fraser River Coalition Comments re the South Fraser Perimeter Road Project

A Comprehensive and Transparent Public Process Before, not After the Fact

Over the years the Coalition has been following the ramifications of development and proposed development and expansion by the Fraser Port Authority at Roberts Bank, and recently, of the Third Berth Project. This opposition is pertinent especially to an entire second terminal, a major highway through Agricultural Land Reserves (ALR), the perimeter road, and increased rail access comprising the Deltaport Expansion, and its connections to the SFPR being done piecemeal. What is needed to help preserve precious habitat so vital to approximately five million migrating birds annually, plus the resident populations of raptors, waterfowl, shorebirds, and songbirds, is a comprehensive, not bits-and-pieces approach. This must also involve a comprehensive plan for the B.C. Coastal marine areas, and will necessitate a full, transparent public process with ample monies to allow full public input, BEFORE, not after the fact.

Research into the Point of No Return for Burns Bog is Needed Before the Work is Done! To do Otherwise is to Sound the Death Knell for both Burns Bog and the Fraser River Delta Wetlands

Ever since the spectre of a perimeter road along the Fraser was raised many years ago, the Fraser River Coalition has been opposed. We believe not enough research has been done as was pointed out by your own scientific panel in November 2006.

The Fraser River Coalition agrees with our member group, the Burns Bog Conservation Society’s position of adamantly opposing any South Fraser Perimeter Road routing option that results in any incursion into or collateral impact on the Burns Bog Conservation area, especially when we do not know either what the short-term re-location or long-term permanent effects will be..

“Do No Harm” Criteria Should Be Met on Any Routing Proposal

While we do not have the engineering or commercial resources to fully assess the relative merits of any South Fraser Perimeter Road routing proposal, we agree with the Burns Bog Conservation Society’s position on the South Fraser Perimeter Road project that any routing proposal should take into account the world heritage nature of Burns Bog and all proposals should first and foremost meet a “do no harm” criteria insofar as the Bog is concerned. From the viewpoint of the Fraser River Estuary, the Fraser River Coalition also opposes the current routing proposal from an aesthetics point of view as well since it cuts the general public off from the serenity and healing benefits of being able to absorb the tranquility and beauty of the Fraser by being able to drive beside it. To destroy 22 hectares of wetland when wetlands along the lower Fraser have been reduced to 10 to 15 percent, is a sacrilege that must warrant a full environmental assessment.

Wildlife Concerns:

In that assessment, the collateral impacts especially on wildlife, wildlife strikes, eagle nesting, the sandhill cranes undisturbed nesting and feeding areas, and additionally, on the black bear which needs territorial space, and the bleeding (draining) of the bog hydrology long-term impact on the lungs and kidneys of the Lower Mainland, must be addressed. Another concern is that the productivity of the marine environment could be negatively affected if the iron-sulphur flow between marshlands and peatlands (terrestrial) and the marine environment is disrupted as it most


Page 3- Fraser River Coalition



surely would be with the SFPR project.. This is pointed out in the Klinger and Erickson’s Marine and Terrestrial Ecosystems report.

The Need to Explore the Following Arguments:

We need to explore the connection to No. 10. Olav Naas says this variation can be done in three years compared to 15-20 years. We are dealing with a known (Highway 99 and No. 10) compared with an unknown (SFPR). One of the problems with the current proposal, is that Gateway has no idea with what they dealing in relation to the Bog and that to preload properly, it will take 10-15-20 years to complete the road.

The traffic coming from Deltaport will hit in three years. It appears to be technically impossible for the proposed SFPR to ready to meet this need. In 15-20 years the SFPR could be redundant.

By working with what we have, costs will be reduced, the time factor for completion will be reduced, disruptions will be reduced and the impact on the Bog will be reduced.

Conclusion:

In conclusion, the Fraser River Coalition sees such a road infrastructure as a poor use of limited financial resources, especially considering the twin disasters of peak oil and global warming bearing down upon us.

Please look at utilization of existing infrastructure and reassess the need at all for the SFPR.


Judy Williams, Evelyn Feller,

Co-Chair, Co-Chair,

Fraser River Coalition Fraser River Coalition

604-856-9598604-270-4050