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April 6, 2017 : From SRA to Tim Blair

April 6, 2017

Tim Blair – Senior Planner, Project and Environment Review Process
Cc: Liisa Hein – Manager of Infrastructure Delivery
Vancouver Fraser Port Authority
100 The Pointe, 999 Canada Place
Vancouver BC, V6C 3T4

Strathcona Residents Association:
Comments on proposed Centerm Expansion Project

Mr. Blair,
The Strathcona Residents Association (SRA) met recently to give neighbours a chance
to ask questions and express their concerns about the Centerm Expansion Project
(CEP) proposed by the Vancouver Fraser Port Authority (VFPA). Liisa Hein and Lilian
Chau kindly attended our meeting to answer questions. As some of our concerns were
technical and beyond the scope of their expertise, they encouraged us to express our
views in writing.

Our comments are provided in the interest of the health, safety and overall well-being of
our community’s residents. Five key issues are our priority concern:

1. Air Quality Impacts, Monitoring and Management
2. Safety Concerns Related to Increased Road and Rail Container Traffic
3. Fire and Emergency Responses
4. Water Quality at Crab Park
5. Viewscape at Crab Park

1. Air Quality Impacts, Monitoring and Management

The project study related to air quality concludes that there will be a sizeable net
increase in emissions related to the CEP. We are concerned that this substantial
increase in project-related emissions will be added to already sub-standard air quality
conditions in our community, and has the potential to adversely impact the health and
quality of life for residents in the Strathcona community.

Such a serious potential impact requires robust assessment. Unfortunately, due to the
avoidable omission of air quality data from a number of important air quality monitoring
stations and sites, the current study conducted by the VFPA does not provide adequate
Information regarding current air quality in the vicinity of the Port or the Strathcona area.
We therefore request for additional studies to be conducted that properly incorporate the
following:

• Baseline and future data collection from relatively new meteorological stations
at Portside (just East of Canada Place and West of Crab Park) and at
Templeton High School, as well as from passive monitoring sites in East
Vancouver (Downtown East Side and Strathcona). We deem the
meteorological stations in Burnaby North and Robson Square chosen for the
current air assessment study not suitable for capturing the impact of the Port
on our community;
• Reference to the findings of the Burrard Inlet Area Local Air Quality Study –
Monitoring Program Results (Air Quality Policy and Management Division,
Metro Vancouver, December 2012), in particular those pertaining to existing
characteristics of the Central Burrard Inlet Area (CBIA). This study was
undertaken by Metro Vancouver specifically due to anticipated increases in
emissions related to port expansion within “this relatively densely-populated
area”; it is therefore essential that it be included in the air quality analysis
associated with this project;
• Supplementary air dispersal modelling that incorporates emissions from
expected new road and rail container traffic;
• A cumulative effects assessment that takes into consideration both current and
reasonably foreseeable future emission sources (including Vanterm and
Alliance Grain Terminal) within the local air shed that can be expected to
impact East Vancouver communities adjacent to the project and primary
project transportation corridors;
• In addition, we request that the supplementary study inform a human health
risk assessment related to increased air emissions (both from project
construction and operations, and transportation “supply chain” sources (rail CP
and CN lines as well as container truck traffic along Clark and Hastings).

Ultimately, the SRA is seeking a project permit condition that requires the Proponent to
develop and implement an Air Emissions Management Plan (AEMP), in consultation
with affected communities, Metro Vancouver and Environment Canada. We envision
that the AEMP would be similar to that required by federal authorities in relation to the
expansion of the Westridge Marine Terminal in Burnaby, that would include the
following requirements:

• Community consultation in development and implementation phases;
• The establishment of additional air quality monitoring capacity within affected
communities, including the establishment of a permanent meteorological
station at McLean Park in Strathcona to ensure proper coverage of impacts
communities;
• One-year baseline of air quality monitoring data prior to operations;
• Accessible monitoring results;
• Regular bi-annual follow-up review; and
• Adaptive management measures as warranted.

2. Safety Concerns Related to Increased Road and Rail Container Traffic

The project Traffic Impact Study has a number critical gaps that make its conclusions
unsupportable at this time. These omissions include an evaluation of the:

• Effects of increased rail traffic along Burrard Inlet Spur line;
• Indirect effects of re-diverted car traffic avoiding train crossings through
Strathcona neighbourhood streets;
• Effects of increased container truck traffic along Hastings Street during the
Centennial Overpass construction phase.

Therefore, we cannot accept at this time the finding that there will be only negligible
effects of increased project-related rail and truck traffic on our community. We request
that the VFPA commission a supplementary study to assess the impacts noted above.

In addition to the VFPA commissioning a supplementary study to assess impacts noted
above that were not covered in initial study, we also request the VFPA provide financial
support for implementation of the following:

• Traffic (road and rail) monitoring and adaptive management measures,
including communications with affected communities such as Strathcona (e.g.,
through regular posting of rail and truck traffic projections online);
• Mitigation measures to address safety concerns related to increase of “rat
running” car traffic though our community, e.g., additional traffic calming
measures, especially along Raymur Avenue, Campbell Avenue and Vernon
Drive.

3. Fire and Emergency Response

Our review of your “South Shore Emergency Access Study” suggests that the VFPA has
only considered emergency response evacuation options for Centerm employees. The
SRA therefore requests for the CFPA to put forth evacuation contingency planning for
neighbouring communities in event of a fire and other emergency responses. The
consequences of a lack of contingency plan were adversely experienced by the
Strathcona community during the four-alarm blaze engulfing three shipping containers
at the terminal on the 700 block of Centennial Road in March 2015. The toxic smoke
released due to fire of tricholoroisocyanuric acid lead to evacuation of the port, Downtown
core and impacted the health and safety of Strathcona residents who were advised
by police roaming the streets with loudspeakers to stay indoors and to breathe through
wet towers when needing to go outdoors.

4. Water Quality at Crab Park

Our primary concern related to water quality at Crab Park is in relation to the
re-suspension of sediments containing contaminants during the two seasons of
dredging. From the project studies, it is clear that the sediments in the vicinity of the
West end of the existing terminal are highly contaminated, and that this contamination
extends deeper than the surface. We therefore request the following:

• During dredging activities, comprehensive notification should be provided (both
through media and by posting at beach area) of beach closure;
• All contaminated dredge material should be removed and disposed off-site,
rather than re-used as fill;
• Follow-up water quality monitoring should be put into place at Crab Park that
includes measuring level of metals, polyaromatic hydrocarbons and other
contaminants of concern, expanding upon limited monitoring of fecalchloroform
currently being undertaken by Vancouver Coastal Health.

It is noted that monitoring is proposed for measuring water quality during dredging
operations and post-construction for water column and sediment quality, i.e., in relation
to effects on fish and fish habitat. We recommend that the monitoring program be
extended to measures that would support health of community use of the beach area for
swimming purposes and would continue throughout the life of the project, especially
given the findings that the project will have a permanent effect on extending the
“residence time” of tidal flushing of water within the embayment, formed between the
Western edge of the Centerm Terminal and the cruise ship terminal, by 2-3 hours.

5. Impacts to Viewscapes at Crab Park

Crab Park is the closest park providing beach access to Strathcona community
members. We are concerned that Centerm’s expansion, as proposed, will have a
permanent impact on the view currently enjoyed by park users. We understand that the
Proponent has considered alternatives to a Westward expansion, but for a variety of
reasons, including cost, has decided against these alternatives.

Therefore, our community members who frequently use Crab Park will be bearing, in
part, the costs of the Proponent’s development decisions.
Although we do not claim to speak for all users of this park, we recommend that the
Proponent contribute financially to enhancing existing park facilities, or alternatively
expand the park footprint through the contribution of VFPA lands, as a way to
compensate for this permanent and irreversible impact of the Westward expansion.

Closure

Thank you for the opportunity to provide comments at this time. We understand that the
mandate of the VFPA is, “to facilitate Canada’s trade objectives, ensuring goods are
moved safely, while protecting the environment and considering local communities”. As
one of the communities most directly impacted by the proposed project, we hope you
will give serious consideration to our comments and recommendations.

Sincerely,

Charis Walko, Dan Jackson, Jeff Murton, Wilson Liang
Strathcona Residents Association – Council