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Jody Shimkus, Project Assessment Director
Environmental Assessment Office
PO Box 9426 Stn Prov Govt
Victoria, BC V8W 9V1                                               

December 18, 2006

Dear Ms. Shimkus:

Below are outlined our concerns regarding the proposed South Fraser Perimeter Road (SFPR).  However, our comments are not exhaustive nor are they deemed to be complete. Our submission is structured in topics according to the order of topics in the SFPR Environmental Assessment Application (main volume).

The Western Canada Wilderness Committee strongly suggests against proceeding with the proposed alignment along the north and western perimeter of Burns Bog. Instead, we recommend adoption of the alternate and much more environmentally sustainable Hoover-Naas route, which is the preferred option of other regulatory agencies including the Canadian Wildlife Service and the provincial Ministry of Environment.

The Wilderness Committee has many strong concerns about the proposed highway development. If built, the South Fraser Perimeter Road will be a large and permanent feature on the landscape passing through or over a very wet environment, including Burns Bog, many streams and other wetlands.

Proposed wetlands to be impacted are home to numerous high priority species such as Pacific water shrew, red-backed vole, red-legged frog, Vancouver Island beggarticks and the streambank lupine. We are also concerned about fragmentation of habitat, especially with the number of streams and wetlands being traversed and the high probability of Pacific water shrew inhabiting most of these areas.

In many sections of the Application, it is stated that potential impacts will be assessed more fully during preliminary detailed design. The Application is therefore potentially unreliable in the tentative conclusions it draws. How can a decision on the proposed project be made if we do not know the full impacts? Mitigation and compensation proposals are very conceptual. For example, the fisheries habitat and compensation plan, the surface water quality and sediment control plan, the habitat, vegetation and wildlife mitigation and compensation plans (all part of the Environmental Management Plan) and the protected wildlife species salvage operations are all very basic. These plans primarily consist of an outline of objectives and desired outcomes, which do not constitute adequate compensation details expected in today's comprehensive environmental management plans.

AGRICULTURE

The Western Canada Wilderness Committee concurs with the December 15, 2006 written comments from the Fraser Valley Conservation Coalition regarding the proposed project's impact on agriculture.

AIR QUALITY
The August 27th Jacques Whitford air quality report states that a quantitative screening level assessment of the two routes under consideration would normally include both vehicle emissions modeling and atmospheric dispersion modeling for each option, followed by an assessment. The assessment would normally be conducted assuming a worst case scenario for each, based on the higher extremes of existing air quality combined with the worst case impacts of each option from the model analysis. Inferences would then be made regarding potential impacts to human health and sensitive ecosystems.

However, the report states that, due to time constraints and limits placed on the scope of work by the Corporation of Delta, the report is confined to the identification and analysis of potential impacts on local air quality from each proposed route based on past experience and a limited review of the literature. Therefore the air quality report, which is still in draft form, does not provide quantitative screening and is therefore potentially unreliable in the tentative conclusions it draws. 

The report’s conclusions are in general terms and lack any detailed analysis.  This is inevitable in view of the restricted scope of the report and the absence of detailed information and modeling.  There is only a brief reference to potential impacts to human health or sensitive ecosystems such as Burns Bog along whose western border the Relocated Highway (Option 2) would pass.

The report indicates an increase in particulate air pollution from the new road.  The majority of trucks will be fueled by diesel.

• Diesel vehicles produce more than two-thirds of particulate air pollution from on-road sources.(http://www.cbecal.org/alerts/toxic/tDiesel070601.shtml).
• Diesel exhaust contains a hazardous mixture of hundreds of different chemical compounds, including over 40 chemicals known to be human carcinogens, probable human carcinogens, reproductive toxicants or endocrine disrupters. (http://www.4cleanair.org/comments/Cancerriskreport.PDF).
• Diesel fuel produces exhaust components that tend to form into spherical, respirable particles about 0.1–0.5 µm in diameter. These particles consist of an inert carbonaceous core with a large surface area that is ideal for adsorbing heavy metals and organic compounds such as polycyclic aromatic hydrocarbons, which are small compounds of 3 to 5 benzene rings that diffuse easily through cell membranes and bind to receptors within the cytoplasm. (Erica Weir, Diesel exhaust, school buses and children's health. Can. Med. Assoc. J., Sep 2002; 167: 505, www.cmaj.ca).
• In 1989 the International Agency for Research on Cancer identified exhaust emissions from diesel engines as a probable human carcinogen. A number of studies have linked occupational exposure to diesel engine emissions with an elevated risk of lung cancer. In addition, diesel exhaust contains several of the Environmental Protection Agency's "criteria" air pollutants (www.epa.gov/air/urbanair/6poll.html) — including sulfur dioxide and fine particulate matter (< 10 µ in diameter) — that have been associated with the exacerbation of asthma. Once inhaled, diesel-exhaust particles are thought to promote the release of specific cytokines, immunoglobulins and oxidants, which can culminate in airway inflammation, mucous secretion, serum leakage into the airways and contraction of bronchial smooth muscle. (Erica Weir, Diesel exhaust, school buses and children's health. Can. Med. Assoc. J., Sep 2002; 167: 505, www.cmaj.ca)
• Studies have shown that diesel exhaust causes cancer and is responsible for 70% of pollution-related health problems and hundreds of deaths annually in the Los Angeles region. (http://www.latimes.com/news/local/la-me-ports7nov07,1,1720050.story?ctrack=1&cset=true )
• The most comprehensive study of urban toxic air pollution ever undertaken shows that pollutants emitted by motor vehicles account for about 90% of the cancer risk from toxic air pollution, mostly from diesel soot (70%).   (South Coast Air Quality Management District. Multiple Air Toxics Exposure Study-II. March 2000).
• Cancer risks from diesel emissions are about ten times higher than that from all other hazardous air pollutants combined. (http://www.scorecard.org/env-releases/def/hap_diesel.html).
• For the U.S. as a whole, the average cancer risk associated with diesel emissions 580 per million- 80% of the total estimated cancer risk from all hazardous air pollutants (740 per million). (http://www.scorecard.org/env-releases/def/hap_diesel.html).

As well as an increased risk of cancer, other adverse impacts on human health have been proven to arise from exposure to increased emissions from vehicles including:

• Children living within 1000 m of truck-laden motorways were found to have reduced lung function. ("Air pollution from truck traffic and lung function in children living near motorways." Epidemiology 8:298-303, 1997).
• Increased risk of hospitalization due to asthma for children living within 200m of a main road (Lin, Munsie, Hwang, Fitzgerald, and Cayo. (2002). Childhood Asthma Hospitalization and Residential Exposure to State Route Traffic. Environmental Research, Section A, Vol. 88, pp. 73-81.).
• The link between exposure to diesel exhaust and asthma has been borne out epidemiologically in studies indicating that children living along major trucking thoroughfares are at increased risk of asthma and allergic symptomsand of having objective evidence of respiratory dysfunction.( Erica Weir, Diesel exhaust, school buses and children's health. Can. Med. Assoc. J., Sep 2002; 167: 505, www.cmaj.ca).
• Increased risk of heart attacks and respiratory problems in all age groups.  A Dutch study has shown that people living near a main road are nearly twice as likely to die from these causes (Hoek, Brunekreef, Goldbohn, Fischer, van den Brandt. (2002). Association between mortality and indicators of traffic-related air pollution in the Netherlands: a cohort study. Lancet, 360 (9341): 1203-9.).
• Exposure to 25 times more particle pollution for people living close to a highway and considerably higher levels of carbon monoxide pollution.  These pollutants are linked to increases in mortality and morbidity. (Zhu, Hinds, Kim, Sioutas. Concentration and size distribution of ultrafine particles near a major highway. Journal of the Air and Waste Management Association. September 2002. Zhu, Hinds, Kim, Shen, Sioutas. Study of ultrafine particles near a major highway with heavy-duty diesel traffic. Atmospheric Environment. 36(2002), 4323-4335).
• Children living within 250m of highways with 20,000 vehicles per day are six times more likely to develop all types of cancer and eight times more likely to get leukemia.  (Pearson et al. (2000). Distance-weighted traffic density in proximity to a home is a risk factor for leukemia and other childhood cancers. Journal of Air and Waste Management Association 50:175-180.)
• B.C. Research has shown that even low levels of particulate matter can lead to increased deaths, emergency room visits, hospital stays, and days lost from work or school. Children and older adults are most likely to be affected by this type of air pollution. As well, premature death can occur in those with heart or lung diseases. (http://www.bchealthguide.org/healthfiles/hfile65e.stm#E46E319)

• Diesel vehicles such as buses and trucks are an important source of fine particles. Reduce diesel emissions by replacing older engines with newer and cleaner engines. For example, the diesel school bus is 223 times more toxic than a new bus fueled by compressed natural gas. (http://www.cbecal.org/alerts/toxic/tDiesel070601.shtml).
• Retrofit existing engines with particulate filters or diesel oxidation catalysts.
• Switch to cleaner fuels such as ultra-low sulphur diesel fuel, biodiesel or natural gas.

More information is required on the effects of atmospheric emissions related to the SFPR plans on health, particularly among the young and elderly.  The Ministry of Transport should also report on local and regional ambient air quality, including air inversion conditions. This should include levels in locations directly adjacent to the SFPR. The levels should also be characterized to include both daily averages and high and low peaks and should reflect hourly, daily and seasonal fluctuations.

FISHERIES VALUES

The proposed South Fraser Perimeter Road (SFPR) corridor includes a range of fisheries values (a number of watercourses and wetlands that provide habitat for salmonids and other fish species) that are potentially impacted by the construction and operation of the proposed project. The fisheries resource is highly valued due to the loss of habitat relative to pre-European settlement. Although steps have been taken to avoid and minimize impacts to fish and fish habitat, there will be many residual impacts to the fisheries resource. 

• The large drainage ditch flowing north to the Fraser River along 96th Street contains cut-throat trout (provincially blue-listed - official Threatened Status in B.C.) (http://wlapwww.gov.bc.ca/wld/documents/fishfacts/cutthroattrout.pdf) and is capable of supporting anadromous salmon.
• Other species recognized provincially (red-listed or blue-listed) or federally (Species at Risk) are present in the Fraser River.
•  The foreshores of the Fraser River adjacent to the proposed SFPR includes and extensive area of red-coded (high value) habitat.
• Cougar Canyon Creek supports several salmonid species.
• In the Pattullo to future Golden Ears Connector section there are 17 watercourses considered to be salmonid-bearing (or potentially so). 30 of the 40 watercourses not containing salmonids are considered to be significant sources of food and nutrients to downstream populations.
• Not all watercourses were surveyed, therefore results are not definitive.
• Detailed design of stormwater discharge outlets, biofiltration and wetlands are not included in the Environmental Assessment Application.
• Although the Fraser River foreshore has been designated a ‘No Touch Zone’, care must be taken not to affect the river foreshore by secondary impacts from altered hydrology, nutrient run-off, pollution etc.

MITIGATION AND COMPENSATION.

“The potential impacts of stormwater will be assessed more fully during preliminary and detailed design….”(SFPR Environmental Assessment Application, P230.)
These details should have been developed and submitted with the Environmental Assessment Application i.e. before authority to proceed is (or isn’t) granted. The Application is therefore potentially unreliable in the tentative conclusions it draws.

“Where the proposed road alignment requires relocation of a drainage ditch that has fish habitat values, it has been assumed that the re-location will incorporate riparian planting and, if appropriate, the placement of large woody debris, boulders and / or other in-stream structures to increase the habitat value in the watercourse.  This work is assumed to be self-compensating and impacts were assessed as zero. The plans used for this analysis will be refined during detailed design of the Project; therefore calculations are estimates.” (SFPR Environmental Assessment Application, P233.).
This should be developed and submitted with the application i.e. before authority to proceed is (or isn’t) granted.  Also, a literature review should be conducted to assess the success of other re-creation projects.

“To avoid or mitigate for potential impacts to fisheries values as a result of the construction and operation of the proposed SFPR Project, …. will develop and implement a Fisheries Habitat and Compensation Plan for addressing potential construction related impacts on fisheries and fish habitat, as part of its Environmental Management Plan.(EMP)” (SFPR Environmental Assessment Application, P256.). 
This should be developed and submitted with the application i.e. before authority to proceed is (or isn’t) granted. An outline of objectives, desired outcomes, and methods in the Environmental Assessment Application (P254-271) and EMP section (P525) does not constitute adequate compensation details or EMP.

The Western Canada Wilderness Committee concurs with the December 2006 comments from the Fraser Heights Community Association's regarding the proposed project's impact on fisheries values.

“The executive summary of Technical Volume 9, the fish habitat impact volume, states that there will be no net loss from today’s values. The summary also states that the document will describe the existing fisheries values while at the same time using a geographic scope of 50m either side of the proposed alignment throughout the entire corridor. These are only a portion of an extremely limiting set of criteria being used for the assessment of fisheries values.

To accurately assess the true impact on fisheries values, information gathering, rather than being just a single snapshot in time, should be done in a more historical context and focussed in a more regional geographic scope. Consequently a more accurate picture of the impact of the proposed SFPR would appear.

For instance there has historically been incremental degradation of fisheries values in the Fraser Heights portion of the SFPR corridor due to the original railway line being built, the placement of an intermodal container facility in an important wetland and 25 years of residential building in the area, etc. Despite the information gathering efforts of the applicant there are sources untapped, such as anecdotal evidence from local residents and streamkeepers groups that the Fraser Heights wetlands were once teeming with fish.

Although the effort is to achieve a no net loss result I have no doubt that further degradation will occur in the Fraser Heights section if the SFPR is built in the area. No net loss should be determined in a more historical sense. Also if a portion of the mitigation is to be compensation in other areas then the overall impact will be regional as opposed to a 50m corridor on either side of the SFPR and its’ right of way.

There are a number of questions and points I would like to make about various sections of volume 9:

• Page v – In the abbreviations list there is no mention of Sturgeon or Sockeye salmon. Thirteen non salmonids are mentioned. There are fourteen non salmonids present in Centre Creek. Also Sockeye fry are present in Surrey Bend (Centre Creek).
• Page viii – Amphibians are not mentioned in the Surrey Watercourse classification as they are in the Delta classification. Are minimum standards used in this application and will amphibians be given consideration throughout the entire project?
• Page 7 – There are no considerations at this time for shading effects, no components of mitigation such as biofiltration swales and no planning for storm water management. This application should not be considered without this critical information. Water management or lack thereof will potentially have the biggest detrimental impact on the surrounding environment of the SFPR. To state that best management practices will be implemented and apply to only culverts and removal of vegetation in the physical footprint of the proposed alignment is entirely inadequate!
• Page 8 – Habitat rating 3 (no touch zone) has the potential to be lowered to a habitat rating 2 designation. Compensation value for a no touch zone should not have a potential minimum rating equal to a lesser designation.
• Page 10 – The fish habitat mapping information for the complex of red-listed streams including Centre Creek and the South Fraser Perimeter Ditch (east drainage), as shown in Appendix 3, appears to be incomplete. The red-list stream designation should extend an additional 0.25 kilometres further upstream as the result of a rearing and spawning stream restoration project completed by The Land Conservancy of B.C. and the Fraser Heights Stewardship Society. There are Sockeye salmon and 14 species of non-anadromous fish present in this location. The applicant has not listed Sockeye salmon and lists only 13 non-salmonids in the application. Also there is no mention of the Federal Restrictive Covenant placed on 12 hectares of Centre Creek and surrounding area adjacent to the CN property. The tier 2 designation of Centre Creek is inadequate. Due to the previously stated information the rating should be upgraded to tier 1 status. As is being proposed for another area of Fraser Heights the SFPR should cross Centre Creek using a bridge or viaduct style structure.
• Page 60 – There is an error in naming the owner of land at Centre Creek.
• Page 74 – The resting area for fish described in the site specific mitigation for Centre Creek could leave the fish vulnerable to increased predation.
• Page 81 – In the Environmental Management Plan there is no indication of sufficient coverage by the Environmental Monitors who will placed on site or who they are employed by.
• Page 83 – The information in this section pertaining to compensation opportunities throughout the SFPR corridor goes into great detail in numerous specific locations. The fact that the storm water management data will be submitted at a future date could render much of the current detailed information useless.”

(Fraser Heights Community Association).

HYDROGEOLOGY
“The quality and quantity of groundwater in the SFPR study area is vital for a variety of biological and socio-community environmental components, ranging from aquatic life, to human drinking and irrigation water uses.  In addition, a number of locations in the study area have values that are potentially particularly sensitive to changes in groundwater supply or condition, especially Burns Bog.” (SFPR Environmental Assessment Application, P274). Once common, large bogs in the Fraser Lowland are now rare and are particularly sensitive to physical and hydrological disturbance. Covering 4,000 hectares, Burns Bog is the largest domed bog on the Pacific coast of North America and the largest undeveloped tract of land in urbanized Canada.

 The construction and operation of the proposed SFPR potentially impacts;

• The level of the water table.
• Velocity and direction of groundwater flow.
• Season variations.
• Alterations to pH.
• Contaminate levels.
• Nutrient levels.

It is our position that further studies need to be conducted, including a literature research focusing on the building of roads on and near these sensitive ecosystems, and that models need to be created for the differing design and engineering plans for the sections of road that are likely to affect these sensitive areas.

Sections of the proposed SFPR are to be constructed in the vicinity of Burns Bog and therefore potentially affect the groundwater conditions, surface hydraulics, water chemistry and the lagg zone.
 

MITIGATION AND COMPANSATION

This section “provides concepts for mitigation to address the potential groundwater impacts at specific locations / sites along the proposed SFPR”. (SFPR Environmental Assessment Application, P299).
These should be developed and submitted with the application i.e. before authority to proceed is (or isn’t) granted. An outline of objectives, desired outcomes, and methods in the Environmental Assessment Application (P299-303) does not constitute adequate compensation details.

“It is anticipated that potential impacts on groundwater quality in the study area….. can be effectively mitigated through a Surface Water Quality and Sediment Control Plan” (SFPR Environmental Assessment Application, P300). These plans will be developed in parallel with finalizing the design and construction methodology…” (SFPR Environmental Assessment Application, P317).
This should be developed and submitted with the application i.e. before authority to proceed is (or isn’t) granted. An outline of objectives, desired outcomes, and methods in the EMP section (P526) does not constitute adequate compensation details or EMP.

WATER QUALITY
“A variety of contaminants can be introduced into watercourses as a result of highway construction, operation and maintenance activities….Such contaminants can impact water quality and the ability of aquatic ecosystems to provide habitat to fish and wildlife.” (SFPR Environmental Assessment Application, P305).

Criteria from historical data was not satisfactory so additional field work was conducted.  However, it is stated that this was conducted in the Spring of 2004  (SFPR Environmental Assessment Application, P305).  This is not adequate.  Sampling should be taken over a period of at least 1 year to take seasonal variations into consideration.

“Construction represents the greatest potential for impacts including:

• Hydrocarbon leakage from construction equipment.
• Fuel, oil and chemical spills from temporary storage areas.
• Potentially contaminated surface water runoff  from demolition debris.
• Sediment laden runoff from excavation and construction activities.
• Debris and spill on roads, which could find their way to watercourses in the study area.”

“During highway operation contaminants can be directly introduced into watercourses and / or introduced indirectly due to surface run-off from impervious areas. Direct input of hydrocarbons, polycyclic aromatic hydrocarbons, and metals which may be present in road runoff can occur as a result of;

• Leaked automobile fluids (e.g. gasoline, oil, grease).
• Wear from vehicle and engine parts (e.g. brake pads).
• Exhaust emissions.”

An increase in impervious surfaces during highway operation may include alterations in hydrology including surface runoff and reduced infiltration. This may result in increased suspended solids, nutrients, metals, and organic compounds in surface runoff, potentially indirectly causing degradation of water quality in adjacent watercourses.” (SFPR Environmental Assessment Application, P316)

MITIGATION AND COMPENSATION
“To avoid or mitigate potential impacts to water quality… the MOT will construct and implement a Surface Water Quality and Sediment Control Plan as part of the Environmental Management Plan. These plans will be developed in parallel with finalizing the design and construction methodology…” (SFPR Environmental Assessment Application, P317).
This should be developed and submitted with the application i.e. before authority to proceed is (or isn’t) granted. An outline of objectives, desired outcomes, and methods in the Environmental Assessment Application (P317-319) and EMP section (P526) does not constitute adequate compensation details or EMP.

VEGETATION AND WILDLIFE

INTRODUCTION
Despite the corridor for the proposed South Fraser Perimeter Road (SFPR) being largely developed for agriculture, commercial and residential land use, there are many less developed areas with high vegetation and wildlife values.

• Burns Bog, an ecologically complex and important raised peat bog.
• eight Delta ravines, forested slopes and tributaries of the Fraser.
• Forests and wetlands of Fraser Heights.
• Surrey Bend.

All these areas are sensitive ecosystems, particularly Burns Bog and Surrey Bend. Once common, large bogs in the Fraser Lowland are now rare and are particularly sensitive to physical and hydrological disturbance. Covering 4,000 hectares, Burns Bog is the largest domed bog on the Pacific coast of North America and the largest undeveloped tract of land in urbanized Canada. Surrey Bend is one of only two relatively untouched bogs in the Fraser Valley, is less disturbed by human impact than Burns Bog, contains, by far, a more diverse inventory of wetland types, is the third largest bog in the Fraser Valley lowlands, is almost the last undiked land in the lower Fraser Valley.

While efforts have been made during the pre-design process to avoid impacts to vegetation and wildlife, the proposed alignment is still expected to cause high impacts on vegetation and wildlife.

It is our position that further studies need to be conducted, including a literature research focusing on the building of roads on and near these sensitive ecosystems.

SITE SERIES PRESENT.
The study area is ecologically diverse; there are a total of 57 site series, of which 8 occur in Burns Bog.

In the study area there are;

• 6 (provincially) red-listed (official Extirpated, Endangered or Threatened Status in B.C.) and 7 (provincially) blue-listed (official Threatened Status in B.C.) site series.
• Red listed plant communities cover a total of 342 ha of which 6.8 ha will be directly impacted by the SFPR footprint (but likely to total more due to disturbance during construction and secondary impacts from the removal of other habitats, altered hydrology, ).
• Blue-listed plant communities cover a total of 163 ha. Of which 19ha will be directly impacted by the SFPR footprint (but likely to total more due to disturbance during construction and secondary impacts from the removal of other habitats, altered hydrology).
• Most of the red-listed plant communities are bog forests in Burns Bog, and upland and riparian forests of the Delta Ravines, Bridgeview and Fraser Heights.  The blue-listed communities are largely upland and riparian forests at Bridgeview, Fraser Heights and the Delta Ravines.

IMPACTS TO VEGETATION

Habitat loss, fragmentation, introduction of exotic species due to disturbance.

• Total direct loss of 97 ha of areas of vegetation and wildlife value, 6.8 ha of red-listed and 19 ha of blue-listed vegetation will potentially be affected. (in footprint, and therefore more destroyed / damaged during construction and secondary impacts from the removal of vegetation elsewhere, altered hydrology etc.).
• 35 ha loss of cultivated fields (including Agricultural Land Reserve lands) which is important habitat for a wide diversity of wildlife.
• 15 ha loss of upland forest, which is important for red-listed and blue-listed plant communities, large and small mammals, western screech owl and the Vancouver Island beggarticks.
• 8 ha loss of riparian forests which are important for red-legged frogs, amphibians, birds and Pacific water shrew.
• 18 ha loss of wetland habitat which are important for red-legged frogs, Pacific water shrew, amphibians, great blue heron, and aquatic insects.
• Habitat fragmentation. “Large tracts of ..... ecosystems are more ecologically valuable than smaller ones, especially small areas that are surrounded by unfavorable habitat. Large blocks of habitat are more viable, are usually more diverse structurally, and support a greater variety of fauna. The quality of an ecosystem can also be adversely affected if construction introduces sharp new boundaries between useable and non-useable habitat.  This may introduce an edge effect, where the physical conditions change ..... This alters the species composition and structure of the vegetation along and near the edge, often with implications to wildlife.” (SFPR Environmental Assessment Application, P344).  Red-listed and blue-listed habitat in North Delta will be cut-off from each other and from the Fraser River.  Red-listed Sunbury Ravine has the potential to be enhanced with education and economic opportunities, and blue-listed Norum Creek Environmental Reserve will be almost wiped out.  Isolating habitats in small pockets reduces their genetic fitness and can result in their death.
• Red-listed and blue-listed vegetation impacts are located mainly at Burns Bog, the Delta Ravines, Port Mann, Fraser Heights and Port Kells area.Certain types of disturbances to these habitats, such as by clearing adjacent areas, may alter light, wind, and drainage regimes, significantly degrading their quality.  For example, the North Delta bluffs will be stripped of hundreds of trees that provide shade for the red-listed habitat on the banks of the Fraser River, keeping water temperatures steady for migrating and breeding salmonids, protecting air quality, are nesting sites for over 150 species of birds including bald eagles (nine), several hawk, owl, and woodpecker species, and others, some of which are listed as special concern, and which are hunting grounds for the barn owl (which may also nest here).

IMPACTS TO PLANT SPECIES AT RISK

• 1 red-listed plant species (streambank lupine) and 2 blue-listed plant species area (Vancouver Island beggarticks and Yellow marsh-marigold) were found in study area. 
• Streambank lupine SARA Schedule 1 – Endangered.
• Vancouver Island beggarticks SARA Schedule 1 – Special Concern.
• 5 other blue-listed plants potentially occur but weren’t found, 4 of which are likely to be present (Henderson’s checker-mallow, pointed broom sedge, pointed rush and rice cutgrass). 
• 3 other regionally significant plants (not federally or provincially designated), previously only found in Burns Bog were all located along the alignment (velvet-leaved blueberry cloudberry, and bog rosemary).
• Cloudberry, crowberry and velvet-leaved blueberry (all present at Burns Bog) are considered to be remnants of the last ice age.  They were left behind as the glaciers receded and are at the most southern limit of their distribution. (Vancouver Natural History Society, 1996. Nature in Vancouver. Cavendish Books Inc, North Vancouver).

IMPACTS TO BURNS BOG

• Loss of 12.78 ha of habitat with high vegetation and wildlife values. (However, there will be a total loss of 26.73 ha. This includes additional 3.97 ha of areas with attributes required to preserve Burns Bog viability (Zone 1) and areas with attributes supporting but not required for Burns Bog viability (Zone 2), and 9.98 ha of areas with few of no attributes supporting Burns Bog viability, and areas with insufficient data (Zone 3) (totaling an extra 13.95 ha).  This data is extremely misleading, suggesting there will be a 12.78 ha loss of habitat important to the functioning, viability and health of Burns Bog, when in reality there will be a loss of 26.73 ha.
• In addition, 13.95 ha of project related footprint impacts to areas that are disturbed, or rural, or land in agricultural (berry) production that have hydrological values.
• Lodgepole pine – Sphagnum ecosystem (red-listed) has become less common and less intact in the north-west corner of Burns Bog due to long-term biological changes (e.g. increased drainage associated with cranberry cultivation), it is therefore imperative to preserve the remaining habitat.
• The “removal of vegetation at the bog margins eliminates the buffer between the central bog and surrounding agricultural areas, and has implications for the entire ecosystem. Potential impacts also extend beyond the footprint due to alterations to hydrology (i.e. quantity, quality, and movement patterns), which potentially lead to drier, more nutrient-rich terrestrial (i.e. non bog) conditions that favour forest or shrub ecosystems.” (SFPR Environmental Assessment Application, P351). There is a lack of detailed scientific knowledge about Burns Bog lagg zone, and there are no details included in the Assessment Application regarding how the impacts of the proposed project on the water hydrology will be mitigated. 

IMPACTS TO WILDLIFE SPECIES AT RISK

• Sensory disturbance (noise, olfactory, visual).
• Habitat loss and fragmentation (see above).
• Amphibians are sensitive to water pollution, draining of wetlands (temporary and permanent), clearing of vegetation beside breeding ponds, and removal of vegetation leading to increased predation and limiting opportunities for thermal cover, all of which are potential impacts of the proposed project.
• Mortality (road collisions). (There is lots of excellent research from the US and UK about the impacts of roads on wildlife.)
• Removal of shelterbelts.
• Changes in wildlife movement due to removal of wildlife corridors.
• 35 ha loss of cultivated fields which is important habitat for a wide diversity of wildlife.
• 15 ha loss of upland forest, which is important for large and small mammals, western screech owl and the Vancouver Island beggarticks.
• 8 ha loss of riparian forests which are important for red-legged frogs, amphibians, birds and Pacific water shrew.
• 18 ha loss of wetland habitat which are important for red-legged frogs, Pacific water shrew, amphibians, great blue heron, and aquatic insects.

INSECTS

• Total of 102 species observed.
• 6 aquatic or semi-aquatic insect or butterfly species considered at risk (Extirpated, Endangered, Threatened or of Special Concern) by the provincial Conservation Data Centre potentially occur.  3 blue-listed dragonfly were documented; beaverpond baskettail, blue dasher and yellowlegged meadowhawk.
• Aquatic insects – high impact in the Pattullo Bridge to Golden Ears Bridge Connector sector.
• Wetland habitat loss, fragmentation, changes to hydrology, changes in movement patterns and collisions impacting the beaverpond baskettail and blue dasher (both blue-listed) and high insect diversity in the Pattullo Bridge to Golden Ears Bridge Connector sector.

HERPETOFAUNA

• Total of 7 amphibian and 2 reptile species observed.
• 7 amphibian and reptile species at risk potentially occur in study area. 2 do for sure – Red-legged frog (Species At Risk Act (SARA) Schedule 1 –Special Concern, Committee on the Status of Endangered Wildlife in Canada (COSEWIC) special concern and provincially blue-listed) and western toad (COSEWIC Special Concern, SARA Schedule 1 –Special Concern), 5 species unlikely to occur.
• Western red-backed salamander, and ensatina not recorded but known to occur.
• Potential habitat loss, fragmentation, changes in movement patterns and potential mortality of red-legged frog and high amphibian diversity,
• High impacts to amphibians and reptiles in the Pattullo Bridge to Golden Ears Bridge Connector sector.

BIRDS

• Total of 122 bird species observed out of 215 species regularly seen.
• 12 bird species at risk present (10 blue-listed, 2 red-listed).
• Red-listed – peregrine falcon and western grebe.
• Blue-listed – barn owl, barn swallow, caspian tern, double crested cormorant, great blue heron, green heron, gryfalcon, sandhill crane, short-eared owl, and western screech owl (kennicotti ssp).
• The great blue heron, barn owl, peregrine falcon and western screech owl are listed under Schedule 1 of SARA (Special Concern, Threatened, Special Concern respectively).  
• Study area is also within the core of B.C. barn owl breeding habitat.
• 13 other bird species potentially present (9 blue-listed, 4 red-listed).
• Another 13 bird species at risk have been recorded in the western Fraser Delta, although not necessarily in the study area.
• High impacts to water associated birds south of highway in the Deltaport Way to 80th Street sector.
• Moderate to high impacts to raptors in the Deltaport Way to 80th Street sector, moderate impacts in the Alex Fraser Bridge to Pattullo Bridge and in the Pattullo Bridge to Golden Ears Bridge Connector sectors.
• High impacts to other birds in forested areas between Crescent Slough and the 72nd Street right-of-way and moderate impacts elsewhere in the Deltaport Way to 80th Street sector.
• Potential impacts to barn owls from loss of roosting habitat and vehicle collisions (Delta Portway to Crescent Slough).
• Potential for disturbance of a peregrine falcon nest at Port Mann Bridge.
• Losses of western screech-owl habitat at McAdam Creek.
• Potential disturbance to sandhill cranes using fields adjacent to Burns Bog and Crescent Slough due to visual and noise disturbance, and at Burns Bog where they are assumed to nest.

MAMMALS

• 22 mammals out of the possible 40 that could occur were observed (13 small, 9 large).
• Medium and large mammals (potentially 13) primarily inhabit Burns Bog and Fraser Heights, as these contain the largest areas of undisturbed habitat in the area. 
• 7 species at risk potentially occur, 3 are confirmed, 3 are likely to be present.
• The capture of a Pacific water shrew (also known as the marsh shrew) (COSEWIC endangered, SARA Schedule 1 (Endangered), and red-listed) in the Fraser Heights wetland, a site rated as low potential, is highly significant.  This are is connected to sloughs and wetlands in the Surrey Bend GVRD Park through a series of culverts.  Most of these habitats have been disturbed and were rated as low potential, however, they could provide habitat corridors that link patches of Pacific water shrew habitat. This species is also present in Burns Bog (a skull has been found) and there is related habitat.  The Pacific water shrew, which is extremely rare, is confined to the Lower Fraser Valley, and continues to decline and fragment due to development. (wlapwww.gov.bc.ca/wld/documents/shrew.pdf)
• Potential reduction in Pacific water shrew habitat from areas near Burns Bog, creeks in the Delta Ravines, and in Fraser Heights.
• Trowbridge’s shrew (blue-listed) was observed only once, but is likely to be more widespread. 

Southern red-backed vole (red-listed) are mainly restricted to Burns Bog and may be widespread in pine and salal habitats on the outer edges of bog (4 individuals were (3 individuals confirmed, 1 tentative identification).  There is a possibility that this Clethrionomys gapperi occidentalis ssp may be genetically distinct from other red-backed voles ( more research is required ).

• Impacts on the habitats and populations of southern red-backed vole around north Burns Bog, in forest with Lodgepole pine and salal near 80th Street.
• Burns Bog is a key habitat for all mammal species present as it provides cover and foraging opportunities. The cultivated fields adjacent also provide foraging habitat, and there is regular movement of species via the wildlife corridors through the Delta Ravines and Fraser Heights wetlands as well as the Serpentine Fen, between these habitats and other habitats further east and south. 
• Ditches in and along the outer edges of Burns Bog are heavily colonized and provide shelter belt corridors even in periods of little or no water. 
• Many species occur in Fraser Heights and some move between here and the nearby Surrey Bend Regional Park all the way to Burns Bog.
• 12 to 17 Black bears are known to inhabit Burns Bog and radio collared bears have been tracked as far as Whatcom county Washington and back through the Serpentine Fen and the farmlands east past Sumas. This large mammal has big home range requirements. Reducing the amount of suitable habitat available will increase the potential for negative bear-human conflicts.
• Moderate to high impacts to mammals in the Deltaport Way to 80th Street and in the Pattullo Bridge to Golden Ears Bridge Connector sectors, and moderate impacts in the 80th Street to the Alex Fraser Bridge sector.

MITIGATION AND COMPENSATION
The mitigation and compensation sections for vegetation and wildlife are, at best, extremely poor.

• Section 7.7.6.2 Design and Construction Mitigation, (page 363) states that “An Environmental Management Plan (EMP) will be developed for the project” part of which will “outline how site-specific avoidance and mitigation measures will be addressed during construction.”  The EMP “will be submitted to regulatory agencies for review and comment after final design is completed and prior to construction.” This should be developed and submitted with the application i.e. before authority to proceed is (or isn’t) granted. An outline plan in the EMP section (P526) does not constitute an adequate EMP. The same goes for the Emergency Response Plan – we need to know what the worst case scenario is and it’s likelihood. This should be taken into consideration (especially as the proposed development is adjacent to the ecologically sensitive and important Burns Bog and other rare and sensitive habitats) –if the risk is too high the project should not be granted authority to proceed.

• Also in section 7.7.6.2 Design and Construction Mitigation, (page 364) it is stated that although sections of the SFPR will be constructed across wildlife corridors, “Sections of the project may include structures or designs that provide for these movements while others may require mitigation. In some cases, additional site-specific work is required as part of future design stages to determine the appropriateness and feasibility of options for maintaining wildlife passages.”

Again this should be developed and submitted with the application i.e. before authority to proceed is (or isn’t) granted. 

• “Further measures for additional reductions of impacts [to Burns Bog] will be considered during detailed design.” (Also in section 7.7.6.2 Design and Construction Mitigation, P364)

Again this should be developed and submitted with the application i.e. before authority to proceed is (or isn’t) granted.

•  “Salvage operations for red-legged frog, Pacific water shrew and other species listed under SARA Schedule 1 will be conducted in areas where their habitat may be affected by construction.” (SFPR Environmental Assessment Application, P365). Then what?  Take them where? To a protected area? Create new area? What is the success rate for translocations of these species?  Where keep them while construction is happening? How long for? We need to see literature research and credible detailed salvage plans for this before authority to proceed is (or isn’t) granted.

• “About 57% of the original Burns Bog area has been substantially disturbed. Therefore, it is vitally important to maintain the functionality of the critical ecosystem that currently exists. Disturbance to bog ecosystems cannot be reliably restored, and recent research on restoration is in its infancy. Hence, certain restoration or enhancement can only be viewed as an experimental approach.” (SFPR Environmental Assessment Application, P367). This speaks for itself.

• It is stated that “regeneration of vegetation will be encouraged after construction, but for safety considerations vegetation may be maintained at low height in some areas. Vegetation maintenance may also remove and/or modify existing ecosystems.” (SFPR Environmental Assessment Application, P369)

This therefore is not acceptable mitigation /compensation as it will not restore previous vegetation type, structure, or quality.  It also means that the quoted figures for vegetation destruction are incorrect as they are only in relation to the project footprint.  Destruction, damage and degradation of vegetation, habitats and ecosystems during construction and secondary effects of vegetation removal need to be taken into consideration.

• “Compensation will ... take into account work that is currently underway by the GVRD to develop a biodiversity strategy for the region.  While this work is ongoing it will assist in identifying compensatory opportunities that support maintaining and enhancing regional biodiversity, which is a component of ecosystem functionality.” (SFPR Environmental Assessment Application, P369).

Not good enough. Need to know compensation measures now. Now is the time to be planning and mapping out reserves, corridors and important habitat types.

• “The specific details of the vegetation / wildlife compensation program for the Project will be determined, in consultation with environmental regulatory agencies, as the review of the Project is being undertaken” (SFPR Environmental Assessment Application, P369.)

These details should have been developed and submitted with the Environmental Assessment Application i.e. before authority to proceed is (or isn’t) granted.

• “Compensating for impacts to habitats in Burns Bog by protecting ecosystems of similar characteristics is difficult because: most of the bogs in the Fraser Lowland are either disturbed or they have already been protected.” (SFPR Environmental Assessment Application, P370.) This speaks for itself.

In conclusion, the SFPR Environmental Assessment Application mentions that ‘best management practices’ for highway projects will be conducted.  If this is what is detailed in the report (lack of detailed plans for mitigation and compensation ), ‘best management practices’ just aren’t good enough and need to be reviewed ASAP.

It should also be noted that through the United Nations Convention on Biological Diversity (1992), and under the National Accord for the Protection of Species at Risk (1996), the provincial government has pledged to conserve the diverse array of wildlife (plants and animals) in British Columbia. The Provincial Wildlife Act protects virtually all vertebrate species from direct harm, and although the species present in the study area are unlikely to be directly harmed (they are likely to be harmed by habitat loss, habitat fragmentation, habitat alteration / degradation) legal designation as Endangered or Threatened under the act increases the potential for harming a species and also enables the protection of habitat in a Critical Wildlife Management Area.  At present only 4 species (not present in the study area) are listed, but several species which are present are excellent candidates for protection, in particular the Pacific water shrew.

The Wildlife Act also prohibits the possession or damage to the nest of an eagle, peregrine falcon, gyrfalcon or heron (among other species), whether or not it has an egg in it (section 34) (www.qp.gov.bc.ca/statreg/stat/w/96488_01.htm)

NOISE
Option 1(upgrade of existing road systems): 

• Overall the noise level will increase by about 1-2 dBA above present exposure over a 25 year timespan.
• A section of Highway 17 would be depressed in the Ladner Trunk Road vicinity which would decrease noise levels by 10 dBA.  (However the report states that the presence of existing noise fences and berms should considerably reduce these benefits of sound attenuation).

Option 2 (new alignment for SFPR):

• Significant increases in noise exposures throughout the alignment since a completely new area of impact would be created.  At present most residential buildings are far enough away from the route of the proposed alignment for the impact to be tolerable.  However, with the creation of a new highway and the inevitable rezoning and residential infills that will ensue, this situation will certainly change.  Anticipated noise levels are well above what the CMHC noise criteria for residential construction consider to be acceptable.  There would also be impact to commercial structures with outdoor parking lots and recreation spaces, which in turn would increase noise levels.
• The report states that Option 2 would result in a corresponding decrease in traffic along existing Highway 17.  However, this is based on an assumption that traffic would divert to the new road.  Studies of the assimilation of new roads show that after several years, instead of diverting traffic from the old road, they stimulate significant additional vehicular access as commercial activities increase and new residential development takes place.

LIGHTING
Building a new road, as opposed to upgrading the existing highway, would have a major impact on lighting in this rural area.  Using the rating system presented in McElhanney’s Multiple Accounts Evaluation, the rate for the relocated Highway 17 option would be “Poor”.  By contrast the rate for the improved Highway 17 option would be “Good”.

The lighting along a relocated SFPR would have a significant impact on wildlife.  International studies (UK Environment Agency 2004, Health Council of the Netherlands 2000) evidence the following negative impact on wildlife:

• Disruption of behaviour caused by the ‘false dawn’ of street lights.
• Disruption of biological rhythms leading to lack of rest or sleep which has a detrimental effect on their condition and alertness.
• Attraction of some species to streetlights (e.g. insects and migrating toads) which can result in deaths.  This has been evidenced by the recent decline in urban moth population.
• Repulsion of other species to lighting which can disrupt movements and reinforce the habitat fragmentation created by roads.
• Disorientation which can interfere with migration of birds, amphibians and fish.
• The 80th Street interchange would be within 50m of a forested area on the northern edge of Burns Bog.  Lighting from the interchange would potentially affect the biological rhythms of any diurnal birds that roost in the area and/or the behaviour of nocturnal forest mammals.
• The Highway 99 interchange would be located within 100-200m of a partially forested area on the southwestern edge of Burns Bog.  Thus the lighting could disturb roosting birds and/or nocturnal mammals in this portion of the bog.  It might also disrupt nocturnal foraging by owls in the adjacent fields and/or the movements of wildfowl, which travel from Boundary Bay to forage in the fields or in the ponds within the bog.  In addition, the interchange would cross Crescent Slough which likely support amphibians.  Artificial light can reduce the foraging success of nocturnal frogs (Buchanan 1993).
• The 28th Avenue overpass and off ramp would lie within agricultural fields.  Lighting from this area is likely to disrupt nocturnal foraging by owls and/or the movement of wildfowl flying from Boundary Bay to forage in the fields.
• If lighted, the 72nd Street and 36th Avenue overpasses could have effects similar to the effects of the 28th Avenue overpass.
• The alternative option for an improved Highway 17/62B/River Road would have minimal incremental impact of lighting on wildlife in the forest since the lighting already exists and/or new lighting proposals would be in areas that are currently industrial and therefore likely already lighted.

We thank you for the opportunity to comment on the proposed South Fraser Perimeter Road (SFPR) Project. However, we protest the amount of time to review and comment on over 3,000 pages of the Environmental Assessment Application and related documentation within a 60-day time frame, especially in regard to local citizens and citizen groups who do not have access to engineers, biologist, hydrologists, health experts etc. Therefore, given that much of the data is far too detailed and complicated for laymen to interpret, we see the need for an independent review by experts in these fields.

Respectfully Submitted by

Kaytlin Cooper, BSc (Hons.), MSc     
Senior Author              

Celia Pendery, LLB                 
Contributing Writer      

Jim Cuthbert, RPBio, MSc      
National Field Office Director
Western Canada Wilderness Committee

Cc:       Hon. Stephen Harper
Hon. Rona Ambrose
            Hon. Gordon Campbell
John Cummins, MP
Sukh Dhaliwal, PM
            Hon. Barry Penner
            Mayor L. Jackson & Delta Council

Gateway to Gridlock Re. Proposed South Fraser Perimeter Road, December 2006

Western Canada Wilderness Committee Submission to BC Environmental Assessment Office

The proposed Gateway Program, if allowed to proceed, will have extremely negative impacts on the quality of life and wildlife habitat in the Lower Mainland. The much-emphasized proposed twinning of the Port Mann Bridge is only part of the Gateway program. Also proposed is the construction of two new highways, the North and South Fraser Perimeter Roads, new Pitt River bridge and the expansion of Highway 1. These new highways are to facilitate the movement of goods from the proposed Deltaport expansion, a related project. Contrary to pro-Gateway PR, the Gateway Program is not about accommodating mobility of the general public. It is about facilitating port expansion and the movement of goods. It is driven by business interests, not by municipalities and the public. The results will be:

Traffic Gridlock
The Gateway Project will in the end make traffic congestion much worse. When asked by Vancouver City Council if abridge and highway expansion project of this kind had worked anywhere else in North America to relieve traffic congestion, Gateway Executive Director Mike Proudfoot answered "No."

Building expanded roads and bridges to make more room for cars always attracts more cars, filling up the new space and causing the same gridlock on a larger scale Most bridges fill up again within 5 years of being built. If this happens, we will have spent billions to create an even bigger traffic problem than we have now.

Huge Costs to Taxpayers
The Gateway Project is slated to cost at least $3 Billion. This huge sum of money is considered to be a low estimate: construction costs in the Lower Mainland are expected to go up 55% in the next 5 years, which would bring the total closer to $4.5 billion. (Think of the 2010 Olympic cost overruns). Such expenditures will either result in a larger provincial debt or it will require the provincial government to sell off the bridges and roads to a private operator who will then charge the citizens to use them. Either way it’s the local citizens who will be paying for Gateway for decades to come.

Beyond the cost in taxpayer’s dollars, there is the cost in time. The project is expected to start in 2008 and be complete between 2012 and 2014. The twinned Port Mann Bridge, for example, isn’t scheduled to be completed until 2014, leaving commuters with several more years of traffic frustration before the twinned bridge is even built. Meanwhile, other options to alleviate traffic congestion could be completed much sooner, such as queue jumper lanes for buses leading to the existing bridges, but are stalled by the Gateway plans.

Destruction of Internationally-Significant Wildlife Habitat
The highway expansions and the related Deltaport expansion would have negative effects on many wildlife habitat areas, undeveloped green spaces, and Agricultural Land Reserve (ALR) lands across the Lower Mainland, such as the habitat for migratory birds on the important Pacific flyway.

Port expansion would have a direct effect on the Fraser River estuary, the mouth of the world’s largest salmon river and an area of incredible biodiversity. Dredging and land-filling of the rich tidal mud flats at Roberts Bank will negatively impact marine life, including sea birds, salmon and resident orca whales.

The South Fraser Perimeter Road (SFPR), planned to cut through the northwestern part of Burns Bog, would bury endangered species habitat within the Burns Bog protected area. Road building could cause long-term drainage problems for the Bog.

Loss of Farmland
Gateway highway expansion plans, especially by the South Fraser Perimeter Road and Deltaport expansion, will pave over farmland and ALR lands. Indirect effects from highway expansion would include increased development pressure on farmland across the Lower Mainland, threatening local food security, production and quality.

Air Pollution and Chronic Health Problems
Port and road expansion will dramatically increase marine, car and truck emissions in the Lower Mainland airshed, leading to higher levels of childhood asthma, and decreased lung function and cancer. Due to prevailing winds, the eastern Fraser Valley would be especially hard hit.

Loss of Quality of Life
Vancouver is routinely listed among the top cities to live in the world. In 1996, the GVRD drafted the Liveable Region Strategic Plan (LRSP), an innovative and world-renowned land-use plan that attempts to balance growth with sustainability. The transit-first principles of the LRSP are going to be run over by the highways of the Gateway Project. Gateway will increase pressure on municipal councils to become more car-focussed, increasing urban sprawl and ignoring sustainable transit alternatives.

Solutions
Building giant bridges and highways won’t solve gridlock in the Lower Mainland. There are a whole host of workable solutions for moving people and goods throughout the region more effectively, which will cost less, be ready sooner, and will protect wildlife habitat, farmland, air quality and our neighbourhoods.
For moving people, many public transit based solutions exist that include:

• expanded bus network, including more express buses
• dedicated bus queue jumper lanes leading up to the existing Port Mann Bridge,
• park-and-ride lots connecting to existing light rail,
• expanding the light-rail system further into south-of-Fraser municipalities, and
• re-activating the interurban railways and expanding commuter rail services.

The movement of goods is at the heart of the Gateway Project. Most of the goods that arrive at Greater Vancouver ports are destined to move on to other jurisdictions, such as the US. Goods-movement options should focus on getting goods moving as efficiently as possible, not on clogging our roads and polluting our airshed.

Alternatives to expanding the highway system include: