The South Fraser Perimeter Road has the potential to completely alter the functioning of Burns Bog and possibly destroy it as well as destroying heritage homes, streams and archeological sites in North Delta. The full document can be read at www.gatewayprogram.bc.ca. It is 3000 pages long. The public has had only 60 days to digest all this information. We encourage you to read our submission and to contact your MP or MLA to express your opinions.
We hope to post other submissions in the near future so please keep posted.
December 12, 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 mail
Dear Ms. Shimkus:
Thank you for the opportunity to comment on the proposed South Fraser Perimeter Road Project. However, I must protest the amount of time to review 3,000 pages of documentation within a 60-day time frame. Our comments are not exhaustive nor are they deemed to be complete.
It is our position that further studies need to be conducted. This includes a literature research focusing on how other countries or organizations approach building roads on or near boglands. In addition models need to be created for the differing design and engineering plans for the sections of road that will be built on bogland.
Members of the Society have attended several Open Houses and presentations regarding the South Fraser Perimeter Road. Most notably, the recent presentation by Gateway to the Scientific Advisory Panel to the GVRD Burns Bog Management Planning Committee has left the Society with several concerns.
It is the Burns Bog Conservation Society’s position that it is adamantly opposed to any South Fraser Perimeter Road routing option that results in any incursion into or collateral impact on the Burns Bog Conservation area.
The Burns Bog Conservation Society does not have the requisite engineering or commercial resources to fully assess the relative merits of any South Fraser Perimeter Road routing proposal. However, the Burns Bog Conservation Society’s position on the South Fraser Perimeter Road project is 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.
The Burns Bog Conservation Society notes that at a recent workshop on the Burns Bog “lagg” or transition zone held at UBC and attended by numerous world class scientists as well as by Gateway staff, the scientists were unanimous in their concern about the lack of detailed scientific knowledge about the Burns Bog lagg zone and its critical contribution to maintaining the Bog ecosystem.
Similar concerns were echoed at a recent presentation by Gateway to the Burns Bog Scientific Advisory Panel, November 21, 2006. The scientists present recommended that before any action is taken by Gateway to proceed with the South Fraser Perimeter Road that a detailed scientific literature review research project be undertaken to see how other countries or management bodies deal with roads and bogs. It was further recommended that an extensive modeling program be implemented to determine the impacts on the Bog.
One book that the Gateway personnel may wish to review is the Muskeg Engineering Handbook, editor, Ivan C. MacFarlane, NRC Associate Committee on Geotechnical Research, 1969, University of Toronto Press.
Olav Naas also referred to a report by Agra Consulting that was commissioned prior to the building of the Alex Fraser Bridge during the November 21, 2006 meeting with the Scientific Advisory Panel. This report deserves reviewing.
The Society notes that the proposed South Fraser Perimeter Road routing almost certainly transects the Burns Bog lagg zone and may negatively impact the lagg zone and the Bog itself via:
- Potential below grade disruption on the water hydrology and thus the lifeblood of the Bog;
- Potential traffic generated fugitive dust and water spray penetrating the Bog proper; and
- Potential wildlife disruption and possible loss of rare and endangered species.
It was also noted at the recent SAP meeting that the proposed road would go through “Sherwood Forest” on the Nottingham farm. This section is perceived as the last bit of original lagg in that area and necessary for future investigations of the function of the lagg and it could possibly provide vital information on managing the lagg of the Bog for its future conservation. This lagg section is scheduled for destruction BEFORE sufficient scientific research can be carried out to determine the proper management of the Burns Bog lagg. We respectfully request that no action be taken on this section until sufficient research has been completed on this section.
As a consequence the Burns Bog Conservation Society’s position is that the SFPR Environmental Assessment must address these issues in a comprehensive fashion and that the Burns Bog Scientific Advisory Panel of the GVRD Burns Bog Planning Team must rigorously review the results in detail by the EAO as well.
The Burns Bog Conservation Society’s position is that the Gateway Project has a substantial “burden of proof” to clearly show that the proposed SFPR routing will meet the “do no harm” criteria.
The Burns Bog Conservation Society’s position is that in addition the Gateway Project has a further burden of proof that the proposed routing will be consistent with the stringent conditions for Burns Bog conservation as codified in the Conservation Covenant agreed to by all levels of government at the time of the acquisition of 5000+ acres by four levels of government at the expenditure of $73 M of the taxpayers monies.
The Burns Bog Conservation Society further recommends that the Gateway Project in addition to carrying out a thorough literature review of construction and highway building practice worldwide on peatland soils that it vigorously reviews other design or roadway routing. This includes but not exclusively the Hoover/Naas proposal.
In this context we find the Gateway environmental assessment is severely lacking in information on precisely how the impact of the road on Burns Bog, particularly the impact on the water hydrology will be mitigated. The road-base construction certainly has the potential to dam the water flow from the north end of Burns Bog to the Fraser River but there are no details on this issue and no specific mitigation strategies. We are being asked in effect to take it on faith that the Gateway Project will be able to mitigate any impacts. In our view this “faith based” approach is not an acceptable planning approach for a world-class heritage site such as Burns Bog.
Another issue that should be addressed in much more detail is the interaction between Burns Bog and the Fraser River estuary. A recent paper by Klinger and Erickson (1997) suggests there is a link between these two ecosystems via ion exchange. A member of the Burns Bog Science Advisory Panel commented recently on this issue as follows:
“After reading the Klinger and Erickson paper, it does seem to be a reasonable hypothesis that iron does runoff or seep through soils into rivers. The linkage of iron with organic matter in a dissolved form--iron-organic acid complex--is part of the hypothesis that links the iron in the peatlands (broader that just bogs, and including peaty marshes, swamps, and fens). They note that this iron-organic complex allows more iron to be transported into the rivers, estuaries and near shore waters than if the iron were only in mineral forms not linked to the organic. They present some pretty good evidence from the literature on productivity of plankton showing that high productivities of plankton are found in river mouths and near shores situations where peatlands are abundant. They also summarize information indicating that it is Fe, not N or P, that is limiting productivities in ocean plankton.
In order to relate it specifically to Burns Bog, one would need to quantify how much iron-organic complex is running out of the Bog via ditches or overland flow into the rivers, and much harder, how much is seeping through the mineral soils beneath the Bog and the levees into the river. (See Klinger and Erickson’s Figure 1 to see the pathways of iron into adjacent rivers. (Do you have the paper?) A very tough assignment, requiring some serious sampling with pipes and maybe labeled tracers—experts would have to be consulted about how to do this.”
We note that the scientists are clearly stating on this and other issues that much multi-year research must be done before we fully understand the Burns Bog ecosystem and its interaction with the surrounding lagg zone and the Fraser River estuary. Our position is that the Gateway Project analysis is founded on superficial understanding of these sensitive issues and thus not a viable basis for issuance of the environmental certificate.
In conclusion the Burns Bog Conservation recommends that the Gateway Project follow these principals:
- The precautionary principal of “do no harm”
- Extensive literature research on construction of highways on peatland (bogland) soils
- Further research on highway alternatives
- Construct models to help determine which system will adhere to the precautionary principals in reducing the impact on the bog, its wildlife and the hydrology of the bog
- Carry out in-depth research on the potential impacts on rare and endangered wildlife including but not exclusively to Sandhill cranes
- Continue to consult and work with the GVRD Scientific Advisory Panel and the community at large.
Scientists warned about the impacts of a storm similar to Katrina based on models created in the laboratory several years before it happened. Nothing was done. If these warnings had been heeded, perhaps the impact of the storm could have been softened.
We are in the unique position due to scientific advances to not only prevent ourselves from being placed in a similar position as our southern neighbours in New Orleans but to seek alternate ways to solve our transportation problems that are creative and far-sighted.
The Burns Bog Conservation Society is aware that the Gateway Project is faced with many challenges. However, it is incumbent upon us all to seek a solution that will not burden future generations.
Respectfully submitted by
Eliza Olson
President
Burns Bog Conservation Society
Cc: Hon. Stephen Harper
Prime Minister
Hon. Rona Ambrose
Minister of the Environment
John Cummins, MP
Delta-Richmond East
Sukh Dhaliwal, PM
Newton-North Delta
Hon. Gordon Campbell
Premier of British Columbia
Hon. Barry Penner
Minister of the Environment
Mayor L. Jackson & Delta Council
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