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September 26, 2017 : From SRA to George Heyman

September 26, 2017
Honourable George Heyman
Minister of Environment and Climate Change Strategy
Victoria, B.C.

ENV.Minister@gov.bc.ca
SENT BY EMAIL

Dear Minister Heyman,
Re: Request for a Provincial Environmental Assessment of the Centerm Expansion Project
under the Reviewable Projects Regulation or Ministerial Designation.

We are writing on behalf of the Strathcona Residents’ Association (“SRA”). The SRA is a
community society that represents the voice of more than 6,000 residents of the Strathcona
neighbourhood located in the north-eastside of Vancouver adjacent to the Vancouver inner
harbour on Burrard Inlet. The purpose of the SRA is to promote the health, safety and wellbeing of residents living in the Strathcona neighbourhood of Vancouver.

We write to bring to your attention the Centerm Expansion Project (“CEP” or “the Project”)which is being proposed by the Vancouver Fraser Port Authority (“VFPA” or “the Proponent”). We are concerned that although the Project clearly qualifies as a Reviewable Project under the provincial Reviewable Projects Regulation (“the Regulation”), the BC Environmental Assessment Office (“EAO”) has not yet commenced an environmental assessment. We have written to the EAO (see attached letter) to express our concerns and to request that the Project be subject to a provincial EA as required by the Environmental Assessment Act (“the Act”).

This matter is of particular concern because we understand that construction may be
commencing as soon as next month. In the event that the EAO takes the position that this
project is not a reviewable project under the Regulation, we ask that you exercise your power under s. 6 of the Act to designate the Project as a reviewable project.

Strathcona residents live immediately to the south of the Project, with three of the marine
terminal’s main ground transportation routes (road and rail) running directly through our
community. The Project as proposed will see a 73% increase in the annual “sustainable”
2 container capacity at the terminal, from 750,000 twenty-foot equivalent units (TEU), or twentyfoot equivalent unit containers, to 1.3 million TEUs, while expanding the footprint of the existing terminal by 15%, leading to the in-filling of nearly 8 hectares of Burrard Inlet. Some of our key concerns related to the Project which warrant designating it for an environmental assessment include:

• Increased health risk in neighbourhoods already identified by Metro Vancouver as
having compromised air quality, by the doubling of air emissions associated with the
Centerm facility without any active proposed mitigation measures;
• Substantial increase of safety risks posed by rail and truck traffic throughout our
community’s streets, again, without any substantive mitigation measures;
• A range of noise and visual impacts to the neighbourhood during both construction and
operations, again, without any substantive mitigation measures; and
• Large volumes of contaminated marine sediments (too contaminated for disposal at
sea) are proposed to be re-used as construction fill for the eastern side of the terminal,
rather than being properly disposed of at upland facilities.1

We note that the VFPA has undertaken its own internal permitting review of its own Project, but that in our view this partial and incomplete process is no substitute for a transparent and adequately-scoped EA process, conducted at arms-length from the very entity that is proposing the Project.

We are very concerned that the commencement of construction is imminent and the provincial government has yet to initiate an EA. VFPA public documents indicate that marine dredging in the inner harbour could start as early as next month (October 2017). Therefore, we write to ask you to act immediately to exercise your powers under s. 6 of the Environmental Assessment Act and require a provincial EA of the Project if one is not already being commenced by virtue of the Project falling within the threshold set out in the Reviewable Projects Regulation. Furthermore, we request that your Ministry refrain from issuing any permits related to the Project until the EAO has conducted an EA of the Project in accordance with the EA Act and Regulation.

Conclusion

We note that the Premier’s mandate letter for your Ministry identifies one of your priorities is to “[r]evitalize the Environmental Assessment process…to ensure…the public's expectation of a strong, transparent process is met.”2 This project is a prime example of the broken EA process because it meets the criteria of a Reviewable Project but no EA has been commenced nor has

1 See https://www.portvancouver.com/wp-content/uploads/2015/05/2017-05-18-CEP-... , accessed September 18, 2017.
2 John Horgan, Premier to George Heyman, Minister of Environment and Climate Change Strategy, July 18, 2017. Mandate
letter, http://www2.gov.bc.ca/assets/gov/government/ministries-organizations/pre... , accessed September 18, 2017.

any explanation been provided for the delay. It is remarkable to us that a project of this scale and magnitude, that is listed as a Reviewable Project, and that poses so many potential social and environmental impacts to large populations within adjacent urban neighbourhoods, would not have been addressed in a more reassuring and transparent manner.

Melanie Mark is being cc’d on this letter to emphasize to her, as our member of the Legislative Assembly, that we look to your government to stand beside us in promoting and protecting the health and well-being of our community. We would be pleased to meet with you to discuss our concerns, and we look forward to receiving a prompt and favourable reply regarding this important matter. Please direct your response to Trefor Smith and Charis Walko at council@strathona-residents.org .

Sincerely,
Dan Jackson “Signed”
Jeff Murton “Signed”
Trefor Smith “Signed”
Wilson Liang “Signed”
Charis Walko “Signed”

Council of the Strathcona Residents Association

cc.

Melanie Mark, MLA, Vancouver-Mount Pleasant
Shane Simpson, MLA, Vancouver-Hastings
Dr. Andrew Weaver, MLA, Oak Bay-Gordon Head
Sonia Fursteneau, MLA, Cowichan Valley
Tim Stevenson, Councillor, City of Vancouver
Elizabeth Ball, Councillor, City of Vancouver
Adriane Carr, Councillor, City of Vancouver
Melissa De Genova, Councillor, City of Vancouver
Heather Deal, Councillor, City of Vancouver
Kerry Jang, Councillor, City of Vancouver
Raymond Louie, Councillor, City of Vancouver
Andrea Reimer, Councillor, City of Vancouver
George Affleck, Councillor, City of Vancouver
Gregor Robertson, Mayor, City of Vancouver

Enclosure: Strathcona Residents Association to the EAO dated September 26, 2017