Comments on the Roberts Bank Terminal 2 Project

Boundary Bay Conservation Committee (BBCC) February 3, 2019

Cindy Parker Panel Manager, Roberts Bank Terminal 2 Project [email protected]

About the Boundary Bay Conservation Committee (BBCC)

The Boundary Bay Conservation Committee (BBCC) was established in 1988 to enhance public awareness of the Fraser River delta and estuary. We have worked with other conservation groups to obtain protection and recognition for this world class ecosystem.

Comments on RBT2 EIS Purpose of the Project and Responses from VFPA The information provided by the Vancouver Fraser Port Authority (VFPA) in the Environmental Impact Statement (EIS) does not provide evidence to support the stated Purpose or Rationale of the Roberts Bank Terminal 2 Project (RBT2);

Purpose:

“Port Metro Vancouver (PMV) proposes to build RBT2 to meet increasing forecasted demand for containerised trade on the west coast of Canada and to continue to maximise the potential economic and competitive benefits of the port.” (Section 2.1 of the EIS)

Rationale:

“Forecasts developed by Ocean Shipping Consultants (OSC), independent experts in global economics and logistics, show that in the near term, existing container capacity on Canada’s west coast and specifically, in B.C.’s Lower Mainland, will become constrained.” (2.1.1 of the EIS)

The EIS fails to provide evidence of future constrained container capacity to meet container traffic demand on Canada’s west coast.

1. The EIS does not include independent studies to provide evidence in support of the RBT2 Project. (Page 2)

2. Data is incomplete and incorrect for container traffic capacity on Canada’s west coast. (Pages 2-9)

3. The Environmental Impact Statement (EIS) fails to provide an accurate account of historic forecasts which were not realized. (Pages 10-13)

4. West Coast Container Traffic Forecasts are skewed. (Pages 13-16)

5. The EIS fails to disclose a growing imbalance between full import and full export containers. (Page 16-17)

6. The EIS fails to disclose that container traffic capacity demand is largely for growth in US-bound container traffic through B.C. (Page 18-19)

7. The EIS fails to disclose that tax dollars will be needed to provide infrastructure to service the planned Roberts Bank Terminal 2 (RBT2) Project which will double current capacity. (Page 20)

8. The EIS fails to identify the economic, environmental and social costs. (Page 20)

1. The EIS does not include independent studies to provide evidence in support of the RBT2 Project.

 The Vancouver Fraser Port Authority (VFPA) relies on several port- commissioned studies, Vancouver Container Traffic Forecast Studies by Ocean Shipping Consultants.

 The port studies are focused on Vancouver Container Traffic but the stated purpose of RBT2 is to provide container capacity for Canada’s west coast. It is extraordinary that the EIS bases its case for RBT2 on Canada’s west coast container capacity and forecasts but the source is studies on Container Traffic Forecasts for Vancouver. It has resulted in a lack of vital information on the role of the Prince Rupert Port Authority in meeting the purpose of the Project.

 The most recent study by InterVistas, August, 2018, was commissioned to provide an independent review of the Ocean Shipping Consultant Study of 2016. Of course the study concluded that the OSC Report was reasonable as InterVISTAS and OSC are both owned by Royal HaskoningDHV.

 Some information provided in the EIS cannot be confirmed as it is not properly referenced.

The VFPA has provided several studies by Ocean Shipping Consultants: 2012; 2013; 2014; and 2016.

Some of the data in the OSC, 2016 Report is incorrect and/or out-of-date rendering the information inaccurate. Unfortunately, four other new reports submitted by the Vancouver Port Authority (VFPA) are also flawed as they based their information on the data from the OSC, 2016 Study:

1. Roberts Bank Terminal 2 Project Overview and Rationale, October, 2018 2. Potential Impact of a Failure to Develop RBT2 at VFPA – November 2017, Ocean Shipping Consultants 3. Roberts Bank Terminal 2 container vessel call forecast study – November 1, 2018, Mercator 4. Review of OSC’s Container Traffic Forecast Study – Port of Vancouver, 2016, InterVISTAS

2. Data is incomplete and incorrect for container traffic capacity on Canada’s west coast Due to the absence of substantiating data, there is no evidence that there is a shortage of container traffic capacity on Canada’s west coast. In Figure 2-4 of the EIS, the VFPA fails to properly reference the statistics for capacity so it is impossible to locate supportive data for the Port’s claim of shortage of container capacity. Figure 2-4 is a graph to show Canada’s west coast container traffic capacity and demand from 2011 to 2030. The graph, until a recent submission by the VFPA in November, 2018, appeared to be the only source in the Roberts Bank Terminal 2 Environmental Impact Statement (RBT2 EIS) of Canada’s west coast container traffic capacity numbers. The source of the graph in Figure 2-4 (copied below) is referenced as Ocean Shipping Consultants, 2016 which is 226 pages. The graph is not in the report so presumably it is calibrated from some information in the report. Why did the VFPA not reference the source specifically and provide a table with data?

Figure 2-4 Note: a TEU is equal to one twenty-foot container.

Figure 2-4 shows combined container traffic capacity at the Vancouver Fraser Port Authority (VFPA) and the Prince Rupert Port Authority. The graph shows that without the Roberts Bank Terminal 2 (RBT2) Project, west coast container traffic capacity will be about 6.8 million TEUs by 2022 with no further capacity to 2030. This does not correlate with published information which shows west coast capacity at over 8 million TEUs by 2030, without RBT2. The container traffic capacity could be higher if the port at Prince Rupert, Fairview Container Terminal, keeps expanding to meet demand. A research paper by engineers reveals a potential capacity of 4 million TEUs at the Prince Rupert Port Authority:

1 Pacific Northwest Logistics Patterns: The Port of Prince Rupert as a Successful National Gateway Strategy; A report prepared for Transportation Northwest (TransNow) University of Washington, Anne V. Goodchild, PhD Kelly Pitera, MS Susan Albrecht; 2009 3

The following Table 1 provides evidence of much higher west coast container traffic capacity than presented in the RBT2 EIS.

Table 1: Canada’s West Coast Container Capacity without Roberts Bank Terminal 2

Sources of Information are referenced in Appendix A

Terminal TEU Capacity TEU Capacity TEU Capacity 2020 2022 2030

Deltaport 3,000,000 3,000,000 3,000,000 Vanterm 1,080,000 1,080,000 1,080,000 Centerm 1,500,000 1,800,000 1,800,000 Fraser Surrey Docks 200,000 200,000 200,000 Vancouver Fraser Port Authority Total Capacity 5,780,000 6,080,000 6,080,000

Prince Rupert Port Authority Total Capacity 1,600,000 1,800,000 2,400,000

West Coast Total Capacity 7,380,000 7,880,000 8,480,000

One reason for the discrepancy in capacity numbers in the RBT2 EIS, compared to other sources, is the ongoing misrepresentation of capacity at Deltaport. In the Environmental Assessment for the Deltaport Third Berth, the Vancouver Fraser Port Authority claimed capacity at 900,000 TEUs prior to the Project.

“The proposed Deltaport Third Berth project at Roberts Bank will expand an existing terminal by adding a third berth, additional container storage yard and new equipment. The capacity of Deltaport will increase from 900,000 TEUs per annum to 1.3 million TEU by 2008.”2

The 900,000 TEU figure did not correlate with the information from the Deltaport operator, Terminal Systems Inc. (TSI). Their numbers consistently claimed capacity at 1.4 million TEUs on their website (copied in Appendix A), in their brochure and in a Transport Canada Study:

“Centerm, Vanterm and Deltaport exceed the average productivity of container terminals in the US. Terminal Systems Inc. is adding a third berth at Deltaport to increase capacity from 1.4 to 2.1 million TEUs per year by 2009 and has ordered equipment to increase Vanterm’s capacity to over 1.0 million TEUs by 2009.”3 Note: TSI claimed the Third Berth would increase the capacity by 700,000 TEUs and the Vancouver Port Authority claimed it would increase capacity by 400,000 TEUs.

2 Deltaport Third Berth Project, Environmental Assessment Application, January, 2005, Chapter 3, page 120 3 Transport Canada Study, Pacific Coast Container Terminal Competitiveness Study – TP, 14837E, Ch. 4; 4.2 Productivity 4

Terminal Systems Inc. brochure, ‘Global Business. Local Interests. September, 2007. The page below is copied from the TSI brochure which shows 1.4 million TEUs of capacity in 2006. The brochure also shows that Deltaport had already handled more than a million TEUs in 2006.

Further evidence of the west coast container traffic capacity rising to 8 million TEUs without RBT2 is the B.C. website for Canada’s Pacific Gateway. http://www.pacificgateway.gov.bc.ca/container.htm

“CONTAINER MOVEMENT increasing container terminal capacity at B.C. ports Port Metro Vancouver . 3.7 million TEUs capacity increasing to 6 million TEUs by 2020.

. 4 terminals: Deltaport, Centerm, Vanterm and Fraser Surrey Docks and support services including dynamic transloading facilities and off-dock industries.

. CN and Canadian Pacific provide efficient direct rail service to major North American distribution centres.

. CN and Canadian Pacific railways have signed service level agreements with the Port Metro Vancouver and individual terminals on performance and efficiency.

…Fairview Terminal can handle the world’s largest container ships. . 850,000 TEUs container capacity . Room to expand to 2 million TEUs by 2020”

This information was not provided in the Roberts Bank Terminal 2 Project EIS and confirms that the container traffic capacity presented in the graph, Figure 2-4, is incorrect. The graph shows west coast container traffic capacity to 2030 at about 6.8 million TEUs without RBT2 and reaching about 9.2 million TEUs with RBT2 whereas the 9.2 million TEUs can be achieved without RBT2 as shown in the table and information above. 5

West coast container capacity is expanding and has the potential to expand to 10 million TEUs without RBT2 if Prince Rupert expands to 4 million TEUs and Vancouver to 6 million TEUs. Potential at Prince Rupert can be confirmed in the more recent submission by the VFPA in October, 2018

Additional submission from VFPA: Roberts Bank Terminal 2 Project Overview and Rationale, Oct. 18, 20184

In response to questions from the Review Panel, the Vancouver Fraser Port Authority, submitted, ‘Roberts Bank Terminal 2 Project Overview and Rationale, October 2018. Page 20, Figure 2, shown below, confirms Vancouver port expansions as shown in Figure 2-4 above. Total capacity for Vancouver is not provided and this appears to be the same information as in Figure 2-4.

However, updated information on the Prince Rupert Port Authority, page 22, confirms more container traffic capacity than previously documented in the Environmental Impact Statement (EIS). The information on page 22 (shown below) is updated information on Fairview Container Terminal at Prince Rupert. This confirms planned expansions to 2.7 million TEUs and beyond demonstrating a growing capacity at Prince Rupert to meet demand.

4 Roberts Bank Terminal 2 Project, Overview and Rationale, October, 2018 Document # 1341 6

The ‘Project Overview and Rationale’ document claims:

“All planned and possible expansion at Fairview container terminal in Prince Rupert is needed to handle Canada’s growing trade, but it is not enough to accommodate the shortfall in needed capacity on the west coast of Canada.” (Page 22)

There is no evidence of shortfall in capacity for decades and certainly not to 2030 which is the stated purpose of this environmental assessment.

The graph on page 24 of the ‘Project Overview and Rationale’ (shown below) depicts container traffic capacity without Roberts Bank Terminal 2.

It is interesting to note that the graph omits the line of design capacity and includes only the line of 85% of capacity. This is not acceptable as the Prince Rupert Port Authority does not claim to operate at 85% of capacity. The operators factored in capability constraints in their original design.

The capacity numbers remain flawed as the data for the Vancouver terminals remain incorrect. Factoring in design capacity (as opposed to 85% capacity) shows Canada’s west coast container capacity at 7.65 million TEUs by 2025 without Roberts Bank Terminal 2. This is higher than the 6.8 million TEUs as shown in the graph of Figure 2-4, discussed above.

Factoring in 6 million TEUs for Vancouver terminals and the 2.7 million TEUs for Prince Rupert gives a total container traffic capacity of 8.7 million TEUs by 2025 without RBT2. This is more in line with documented information referenced above.

The graph on page 25 of the ‘Overview and Rationale ‘document, (shown below), has the same flawed data for Vancouver Terminals. The graph depicts container traffic capacity with Roberts Bank Terminal 2 (RBT2). Again the graph omits the line of design capacity. Factoring in design capacity shows Canada’s west coast container capacity at 10 million TEUs with RBT2. This is lower than the 10.2 million TEUs shown in Figure 2-4.

Factoring in the 6 million TEUs for Vancouver terminals, plus 2.4 million TEUs for planned RBT2, plus 2.7 million TEUs for Prince Rupert gives a total of 11 million TEUs by 2035.

(Note: Where is the data? Where are the tables? Where are the references with links and page numbers?)

The information on pages 24 and 25 of the ‘Overview and Rationale’ document omits the line of design capacity and includes a line that shows 85% of capacity. Port capacity, according to an expert in port economics, Professor Wayne K. Talley, is calculated by considering all factors and determining the lowest throughput:

“A modular method for estimating the capability of a given port is presented, where capability is defined as the maximum annual throughput (in tons of cargo) that a port can handle under normal working conditions…. The lowest throughput estimate is the constraining capability of the port (or choke point) and thus is selected as the maximum annual throughput that the port can handle under normal working conditions.” ‘Port Performance: An Economics Perspective’, Wayne K. Talley https://web.itu.edu.tr/~keceli/advancedportmanagement/port%20economics.pdf

In other words, the limitations are factored into the initial determination of design capacity so the 85% capacity claim lacks validity. The bottom line is Canada’s west coast could have container traffic capacity of 11 million TEUs by 2035 with RBT2 or 8.6 million TEUs without RBT2. There is potential, with future expansions at Prince Rupert, for 10 million TEUs for Canada’s west coast container traffic without RBT2. This is more than double the current business of 4.4 million TEUs in 2018. The following graph shows actual TEUs and forecast demand from the Ocean Shipping Consultants, 2016 Report (page 26). The graph also shows capacity according to the VFPA with RBT2 compared to documented capacity, without RBT2.

Graph 1: B.C. West Coast Container Capacity, Forecasts and Actual TEUs

million TEUS B.C. West Coast Container Capacity, Forecasts and Actual TEUs 10.00 DTRRIP - Deltaport Terminal Road Terminal 2 (RBT2) 9.20 9.00 and Rail Improvement Project Expansions at Centerm and Prince Rupert 8.48 8.00 7.38 7.88 7.50 7.00 6.80 6.60 6.25 6.20 6.40 6.00 DTRRIP 5.90 5.70 5.00 4.68 4.68 4.15 4.40 3.73 4.00 4.15 3.82 3.36 3.53 3.55 3.27 3.00 2.85 2.91 2.67 2.00 2.41

1.00

0.00 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025 2030 OSC 2016 Low Case Forecast OSC 2016 Base Case Forecast OSC 2016 High Case Forecast Capacity according to VFPA with T2 Documented Capacity without Terminal 2 Canada's West Coast Actuals

There will be sufficient container capacity without RBT2 and should the container traffic grow faster than forecasts, there is opportunity for 2 million more TEUs at Prince Rupert. Since 2008, even the lowest case forecasts by the Vancouver Fraser Port Authority have not been realized.

3. The Environmental Impact Statement (EIS) fails to provide an accurate account of historic forecasts which were not realized. Historic Throughput and Forecasts

Figure 2-2 in the Environmental Impact Statement is flawed as the vertical axis is skewed.

The updated version, in response package one, Appendix IRI-03-B, is not very different from the original. Data from 2015 has been added and the presentation has been modified to correct the vertical axis.

Original EIS Figure 2-2

Revised Figure 2-2

The forecasts in Figure 2-2 are referenced as Ocean Shipping Consultants (OSC) 2001. Table (IRI-03-01) has been provided without specific references. The Table is just referenced as OSC – no date. The OSC 2001 Report has not been submitted so the forecasts have not been substantiated. Why has the VFPA not submitted this Report? This is serious as the VFPA repeatedly states that container traffic has exceeded high forecasts:

“Figure 2-2 demonstrates the robustness and accuracy of the forecasts. Actual west coast container traffic remains closely aligned with, and has in many years exceeded, the high forecast…” (RBT2-EIS, 2.2.4 Historic Canadian West Coast Container Traffic Forecasts, page 2-7) This is the only information that the Vancouver Fraser Port Authority (VFPA) has provided to assert that historic forecasts were accurate. It is not properly referenced and it goes back 18 years. It is misleading to claim accurate forecasts as there have been numerous reports of forecasts since 2001. The lowest case forecasts for the VFPA have not been realized since 2008 and the VFPA has failed to disclose this information.

Data in the ‘Deltaport Third Berth Project, Environmental Assessment Application,’ 2005, confirms that VFPA forecasts are not being realized as shown in the Graph and Table below.

Graph 2: Container Traffic Forecast and Throughput for Deltaport Third Berth Project

Vancouver Container Traffic Forecasts, Deltaport Third Berth (2005) million TEUs and Actual Throughput 7.0 6.5 6.0 5.5 5.0 4.5 4.0 3.5 3.0 2.5 2.0 1.5 1.0 0.5 0.0 2000 2002 2004 2006 2008 2010 2012 2014 2016 2018 2020

High Case Forecasts Actual TEUs Low Case Forecasts Base Case Forecasts

Forecast data in the Graph above and Table below are from Table 3.3 in ‘Projected North American and West Coast Container Traffic Growth’, ‘Deltaport Third Berth Project, Environmental Assessment Application,’ 2005 Page 116. Actual Throughput 2000 to 2007 is referenced in Appendix B. Data for Vancouver throughput, 2008 to 2018, is from VFPA Statistics which are posted on their website. ‘ 11

Data for Vancouver throughput, 2000-2012, on page 28/187 of the Ocean Shipping Consultants 2013 Report is incorrect from 1985 to 2007 as it does not include throughput from Fraser River Port. Actuals are provided in Appendix B.

Table 2: Data from Study for Deltaport Third Berth Environmental Assessment

‘ Projected North American and West Coast Container Traffic Growth’, ‘Deltaport Third Berth Project, Environmental Assessment Application,’ 2005 Page 116.

In comparison to Figure 2-2, in the RBT2-EIS, the information from 2005 presents a more realistic picture of inflated forecasts which are not being realized.

Figure 2-3: The VFPA has submitted an updated graph using data from OSC, 2016.

The graph below is the same information as in Figure 2-3, with updated actuals and smaller intervals for clarity.

Graph 3: Container Traffic Actuals from VFPA Statistics and Forecasts from OSC 2016

Canada West Coast Container Traffic Forecast , OSC 2016, and Actuals to 2018 10.0 9.5 9.0 8.5 8.0 7.5 7.0 6.5 6.0 5.5 5.0 4.5 4.0 3.5 3.0 2.5 2.0 1.5 1.0 2011 2013 2015 2017 2019 2021 2023 2025 2027 2029 2031 2033 2035 Actual TEUs Low Case Base Case High Case

The forecasts for Canada’s west coast container traffic demand in OSC, 2016 have been reduced from the forecasts in the OSC, 2013 Report. The OSC 2016 Report forecasts a demand of 6.4 million TEUs to 8.6 million TEUs by 2035. As outlined on pages 3 to 8 of this document, capacity will be 8 to 10 million TEUs by that time without Roberts Bank Terminal 2.

4. West Coast Container Traffic Forecasts are skewed.

The OSC 2016 Report shows higher increases in container demand for the Vancouver Fraser Port Authority (VFPA) than are being realized. In contrast, the forecasts for the Prince Rupert Port Authority are unrealistically low. The information is clearly incorrect.

Table 1.40 on page 26 of the OSC 2016 Report has container traffic forecasts for Prince Rupert and Vancouver combined. Table 7.1 on page 219 has forecasts for the Vancouver Fraser Port Authority. These tables are shown in Appendix C. Subtracting forecasts for Vancouver from the West Coast Totals provides forecasts for Prince Rupert.

The Base Case forecasts from these Tables are shown in the Graph and Table below. Actual throughput has been added to the Graph. A trend line has been added to show how the forecasts for Prince Rupert are already wrong. The trend line for the Vancouver ports shows that the forecasts for Vancouver remain unrealistically high.

The Base Case shows 3.99 million TEUs for Vancouver ports by 2020. With West Coast projections of 4.9 million TEUs, that would mean .91 million TEUs for Prince Rupert by 2020. However that amount of throughput was achieved by Prince Rupert in 2017. The Base Case in OSC 2016 indicates Prince Rupert will not achieve 1 million TEUs until 2026. However, Prince Rupert already handled more than 1 million TEUs in 2018.

Graph 4 and Table 3 below show the skewed forecasts. The OSC 2016 Report erroneously shows significant growth in container traffic for Vancouver and minimal growth at Prince Rupert.

Graph 4: Actual TEUs from Port Websites and Forecast TEUs from OSC 2016

million TEUs Ocean Shipping Consultants , 2016: Container Traffic Forecasts for Vancouver Fraser Port Authority and Prince Rupert Port Authority 2008 to 8.0 2035 1 TEU = 1 20-foot container 7.5 7.0 6.5 6.0 5.5 5.0 4.5 4.0 3.5 3.0 2.5 2.0 1.5 1.0 0.5 0.0 2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030 2032 2034 Prince Rupert Base Case Forecasts VFPA Base Case Forecasts VFPA Actuals Prince Rupert Actuals Linear (VFPA Actuals) Linear (Prince Rupert Actuals)

Table 1.40, OSC 2016 shows west coast container traffic, Base Case, from 4.00 million TEUs in 2016 to 7.30 million TEUs in 2030, an increase of 3.3 million TEUs. Of the 3.3 million TEUs, OSC 2016 reports an increase of 2.88 million TEUs for Vancouver and 0.42 million TEUs for Prince Rupert. This would be a Compound Annual Growth (CAGR) of 3.44% for Vancouver and a CAGR of 2.25% for Prince Rupert. This misinformation is serious as the forecasts fail to provide evidence to support the Purpose of RBT2.

Table 3: Data of Actuals TEUs and Base Forecasts from OSC 2016 Table 1.40 on page 26 and Table 7.1 on page 219 These tables are shown in Appendix C.

VFPA Actual Prince VFPA Base Prince Rupert Year TEUs Rupert Case Base Case Actual TEUs Forecast Forecast 2008 2.49 .18 2009 2.15 .26 2010 2.51 .34 2011 2.50 .41 2012 2.71 .56 2013 2.82 .54 2014 2.91 .62 2015 3.05 .77 2016 2.93 0.80 3.18 0.80 2017 3.25 0.90 3.37 0.83 2018 3.40 1.10 3.58 0.82 2019 3.78 0.92 2020 3.99 0.91 2021 4.18 0.92 2022 4.38 0.92 2023 4.52 0.88 2024 4.66 0.94 2025 4.81 0.99 2026 4.94 1.06 2027 5.08 1.12 2028 5.21 1.19 2029 5.35 1.15 2030 5.48 1.12 2031 5.60 1.10 2032 5.72 1.08 2033 5.84 1.16 2035 6.08 1.22

Actuals for Prince Rupert are already above OSC, 2016 High-Case Forecasts as shown on Graph 4 above. Actuals for VFPA are already below Low-Case Forecasts as shown in Table 4 below:

Table 4: VFPA Actuals Compared to Forecasts, OSC 2016 VFPA Actuals Low Case Base Case High Case 2016 2.93 3.16 3.18 3.20 2017 3.25 3.31 3.37 3.44 2018 3.40 3.48 3.58 3.69

These OSC, 2016 forecasts for the RBT2 Project are used in the InterVISTAS Study, Review of OSC’s Container Traffic Forecast Study – Port of Vancouver, 2016, which would explain why their ‘most likely’ forecasts are not being realized. In addition, the numbers in the InterVISTAS Tables on pages 20 and 21 are incorrect making it difficult to compare actuals with forecasts. They are supposed to correlate with OSC 2016 forecasts but there has been an error in copying the numbers from the OSC 2016 Report. The result is the forecasts for ‘most likely’ throughput are inaccurate, at least for recent years.

The Environmental Impact Statement (EIS0 states the Purpose of RBT2 is to provide 2.4 million TEUs of container capacity per year to ensure sufficient capacity on the west coast of Canada. The EIS did not state the Purpose is to ensure sufficient capacity for just Vancouver; the stated Purpose is to ensure sufficient capacity for Canada’s west coast. Consequently, the EIS requires inclusion of accurate capacity and forecasts for the Prince Rupert Port Authority. To support the Purpose of RBT2, the VFPA has relied solely on the Ocean Shipping Consultants Reports which are identified as Container Forecast Studies for the Port of Vancouver. The OSC Reports address west coast container traffic forecasts and throughput but fail to accurately report on the container traffic business at the Prince Rupert Port Authority.

As the container business is growing rapidly in Prince Rupert with a Compound Annual Growth Rate (CAGR) of 19.8% over the past 10 years, it makes sense that capacity expansions be built at that location. This was advised by three independent transportation experts in the ‘Strategic Advisors Report, Asia Pacific Gateway and Corridor Initiative Report and Recommendations, 2008’. Burghadt, De Fehr and Turner recommended that:

“…policy makers develop container capacity in Prince Rupert before making investments in Vancouver”…and further that: “…a systematic approach be taken to achieve an understanding of port capacity before a conclusion is reached that a particular port must necessarily be larger.”

This advice remains relevant as there is no understanding of Vancouver Fraser Port Authority’s container capacity in the Environmental Impact Statement for the Roberts Bank Terminal 2 Project.

5. The EIS fails to disclose a growing imbalance between full import and full export containers.

Review Panel Request

 Provide information on the annual TEUs of imports and exports of each of the ports under the Vancouver Fraser Port Authority jurisdiction from the year 2000 and projected for 2020 and 2030; and provide the percentage of TEUs coming or going to the United States

In response to the request, the Vancouver Fraser Port Authority (VFPA) noted that they could only disclose aggregate container throughput and provided actuals of imports and exports for Vancouver, 2000 to 2015 and then forecasts to 2020 and 2030 and stated:

“As noted in Section 2.2.2 of the EIS, the Port of Vancouver handles an almost equal volume of import and export containers, which provides for a resilient, commercially attractive port to shippers and shipping lines.”

The import/export TEUS appear to be of almost equal volume if the statistics include both full and empty import/export TEUs. This is shown in Graph 5 below which provides Vancouver’s Total Container Traffic Exports and Imports (full and empty), 2008-2018

Graph 5: Vancouver Fraser Port Authority Total Exports and Imports 2008-2018

Source: Vancouver Fraser Port Authority Statistics on website Port of Vancouver Total Exports and Imports 2008-2018 million TEUS 2,000,000 1,800,000 1,600,000 1,400,000 1,200,000 1,000,000 800,000 600,000 400,000 200,000 0 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Total Imports Total Exports

While the totals consistently show a close balance of import/export containers, the VFPA has failed to disclose that there is a growing imbalance between full import and full export containers as shown in Graph 6 below. The VFPA should have provided this highly relevant information.

The graph below shows that export of full containers has gone down since 2013. In contrast, during the last 5 years, the import of full containers has grown at a Compound Annual Growth Rate of 4.22%. Graph 6: Vancouver Fraser Port Authority: Full Container Exports and Imports

million Port of Vancouver Full Container Exports and Imports 2008-2018 TEUS 2,000,000 1,800,000 1,600,000 1,400,000 1,200,000 1,000,000 800,000 600,000 400,000 200,000 0 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 Total Laden Exports Total Laden Imports

Source: Vancouver Fraser Port Authority Statistics on website 17

6. The EIS fails to disclose that container traffic capacity demand is largely for growth in US- bound container traffic through B.C.

The growing gap between the import and export of full containers coincides with the growth in US- bound full import containers through Vancouver.

Page 69 of the Ocean Shipping Consultants Study of 2016 states less than 30% of import containers are for B.C. It appears only 10% to 15 % of container traffic imports are destined for the Vancouver area so more capacity is not required to meet local demand.

According to Container Traffic Forecasts for Vancouver, OSC 2016, 21% of import containers (full and empty) were US-bound in 2013 compared to 13% in 2011 and 18% in 2012. Then the percentage of US- bound container rose to 23% in 2014 and 24% in 2015. (Tables in Appendix D)

Graph 7 below shows Actuals for Import Containers (full and empty) to 2017 and Forecasts from 2017 to 2030 according to OSC 2016. OSC 2016, Table 1R1-03-2, forecasts that 23% of future import containers will be US-bound.

The Vancouver Fraser Port Authority states different information in a recent submission to the Review Panel. Page 24/36 of ‘Updated Roberts Bank Terminal 2 Project Overview and Rationale, October, 2018’, states:

“Container traffic destined for, or originating from, the United States through Vancouver was 15 per cent in 2017, a figure that has remained relatively consistent in recent years.”

Which information is credible? Where is the evidence?

Graph 7 below shows that Canada-bound import container traffic was flat from 2006 to 2016. In comparison US- bound import container traffic has grown. As Canada-bound import container traffic has been relatively flat, there is no evidence to support the forecasts in the graph below. These are the same unsupported forecasts as shown on pages 13 and 14 of this document.

Graph 7: VFPA: Actual and Projected Import TEUs and Destinations

Appendix E: Table of data and sources for graph below.

At the information session of January 30, 2019, the VFPA stated the port does not make trade policies and that terminal operators serve many different customers. They further stated they cannot discriminate against specific customers inferring that the VFPA has no control over the fact that the container business of Vancouver ports is expanding to funnel US imports through Canada.

Whether the VFPA statement is true or not, it is the job of the VFPA to ensure the best use of Vancouver container terminals to serve Canadians. The VFPA is applying to build a new container terminal at Roberts Bank and the public, as well as the Review Panel, deserve full disclosure of the data and statistics showing that recent import container traffic growth is for US-bound containers. As Canada-bound container traffic has been fairly constant with little growth, the obvious intent is to create more container capacity for US-bound containers.

The forecast for Canada-bound container imports, as shown in Graph 7, shows a sudden surge of growth from 2018 forward. This is not consistent with the actuals for the past 10 years. Where is the evidence to support this forecast of dramatic growth in Canada-bound containers as shown in Tables in OSC 2016 and OSC 2014, referenced in Appendix E? Where do forecasts for the Prince Rupert Port Authority fit into this picture of supplying west coast container capacity?

7. The EIS fails to disclose that tax dollars will be needed to provide infrastructure to service the planned Roberts Bank Terminal 2 (RBT2) Project which will double current capacity.

There is no benefit to the Canadian economy of dredging and filling 400 acres of the Fraser River estuary to create an island, and to expand the tug basin and causeway for the import of US-bound containers.

The containers will need tax-funded roads, railway upgrades, and transloading infrastructure to transport through Canada. Congested rail lines will negatively impact the import/export of Canadian goods.

8. The EIS fails to identify the economic, environmental and social costs.

The damage to the Fraser estuary will degrade the world-renowned ecosystems that support salmon, endangered Southern Resident Killer Whales, and millions of migrating birds at Canada’s major stopover of the Pacific Flyway.

The fragile balance of estuarine fresh/salt water mix will be altered, threatening the survival of migrating waterfowl and shorebirds travelling thousands of miles between Alaska and Patagonia in southern South America. Numerous species will be negatively impacted with the doubling of container shipping at Roberts Bank, especially western sandpipers who feed on life-sustaining biofilm on the Roberts Bank mudflats. This irreplaceable food source is richest in the area where the port plans to use 100 acres for the expanded causeway and 289 acres for the planned island which will be the size of 219 football fields. The economic, environmental and social costs are a high price for Canadians to pay to funnel US containers through Vancouver. The VFPA’s RBT2 Project is not in the public interest. Information in the RBT2 EIS does not provide evidence to support the claim of constrained container capacity to meet forecasted demand.

Appendix A

References for Table 1: Canada’s West Coast Container Capacity without Roberts Bank Terminal 2

Container Capacity at Vanterm Terminal, Burrard Inlet 1,080,000 TEUs by 2020

“Vanterm increased its capacity to 0.60 million TEUs in 2005”

Container Capacity Expansion Plans at Pacific Coast Ports, Hanam Canada Corporation, January 2007, Page 31/72 https://www.tc.gc.ca/media/documents/policy/tp14710e.pdf

“…Terminal Systems Inc….has ordered equipment to increase Vanterm’s capacity to over 1.0 million TEUs by 2009….” Transport Canada, Pacific Coast Container Terminal Competitiveness Study - TP 14837E, December, 2011, Chapter 4.2 https://tc.gc.ca/eng/policy/report-research-ack-tp14837e-chapter4-1646.htm

A June, 2018, article states Vanterm’s investment will increase capacity to 1,080,000 TEUs. “GCT is also investing $160 million in infrastructure improvements at its 900,000-TEU Vanterm container terminal that will boost its capacity by approximately 20 per cent.”

Big money deal for Delta port operator, June 10, 2018 https://www.vitadaily.ca/faq/big-money-deal-for-delta-port-operator-1.23328931

A Study commissioned by the Corporation of Delta documents a capacity of 1 million TEUs at Vanterm:

“By 2031, it is assumed that Terminal 2 will be operating at full capacity. This is based on the following forecasted annual throughputs at full capacity: … II Vanterm (1 million TEUs)”

Inland Intermodal Cargo Facility Study for the Corporation of Delta Draft 1.6 August 15, 2014, page 20 of document; scrolled page 29/76 https://delta.civicweb.net/document/111945/F02%20Inland%20Port%20Study.pdf

Container Capacity at Centerm Terminal, Burrard Inlet 1,800,000 TEUs by 2020

A 2007 Transport Canada Study:

“In 2006 Centerm completed a major terminal redevelopment doubling its capacity from 0.36 million TEUs to 0.78 million TEUs per year. The company expects to double its volume within two years and reach a million TEUs by 2010.”

Container Capacity Expansion Plans at Pacific Coast Ports, Hanam Canada Corporation, January 2007, Scrolled page 31/72 https://www.tc.gc.ca/media/documents/policy/tp14710e.pdf

A 2014 Announcement: “… Port Metro Vancouver announced that it is considering design options to increase container capacity at the Centerm terminal in the Burrard Inlet, from its current 900,000 TEUs to as much as 1.8 million TEUs”

Port Metro Vancouver, Container Capacity Improvement Program http://www.robertsbankterminal2.com/wp-content/uploads/PMV-Container-Capacity-Improvement-Program-Update- November-2014.pdf

Container Capacity at Fraser Surrey Docks - 34 kilometres up the Fraser River from the Estuary 600,000 TEUs in 2005 Handling 100,000 to 200,000 TEUs

In 2005, Fraser Surrey Docks spent $190 million on expanding container capacity to 600,000 TEUS. Then its main customer transferred to another Vancouver Terminal.

Container docks in Surrey idle after $190m expansion, Vancouver Sun, June 21, 2006 http://www.canada.com/vancouversun/news/story.html?id=243c5a27-053e-49c4-8bde-f94f9ffef45d

Container Capacity at the Port of Prince Rupert 2,500,000 TEUs by 2025 Potential for 4 million TEUs The Port of Prince Rupert began operations in 2007.

“The original design capacity of the terminal was 500,000 TEU. However effective management and an efficient workforce have seen throughput grow to 776,412 TEUs in 2015… … with phase 2A complete the project expanded the wharf to 800m in length and increased throughput capacity to 1.35 million TEUs per annum.”

Fairview Container Terminal website: Phase II North Expansion https://www.rupertport.com/future/fairview-terminal-phase-2

In August, 2017, the Port of Prince Rupert announced completion of expansion to 1.35 TEUs.

Port of Prince Rupert Press Release: PORT OF PRINCE RUPERT COMPLETES FAIRVIEW TERMINAL EXPANSION, August 28, 2017 https://www.rupertport.com/news/releases/fairview-2-expansion

In June, 2018, the Port of Prince Rupert announced another expansion:

“The Phase 2B expansion will increase annual throughput capacity at Canada’s second largest container terminal to 1.8 million TEUs (twenty-foot equivalent units) when complete in 2022.”

Phase of Prince Rupert Fairview Terminal Expansion Unveiled, June 19, 2018 https://www.rupertport.com/news/releases/fairview-phase-2B-expansion

DP World has plans to increase capacity to 2.4 million TEUs. CMA CGM gains slots to Prince Rupert, capping busy year for port, Bill Mongelluzzo, Senior Editor | Nov 19, 2015, Journal of Commerce https://www.joc.com/port-news/international-ports/port-prince-rupert/cma-cgm-gains-slots-prince-rupert-capping- busy-year-port_20151119.html

A research paper by engineers reveals a potential capacity of 4 million TEUs at the Prince Rupert Port Authority:

“Currently, Prince Rupert is in the design and permitting stage for a second container terminal to begin development in 2015 which would have capacity to move 2 million TEUs annually and potentially bring the total capacity to 4 million TEUs by 2020.” Pacific Northwest Logistics Patterns: The Port of Prince Rupert as a Successful National Gateway Strategy; A report prepared for Transportation Northwest (TransNow) University of Washington, Anne V. Goodchild, PhD Kelly Pitera, MS Susan Albrecht; 2009 pacific northwest logistics patterns: the port of prince rupert ... - ROSA

Container Capacity at Deltaport at Roberts Bank 3 million TEUs without RBT2

The VFPA statistics for container traffic capacity at Deltaport have been misleading for years resulting in claims of need for more capacity.

In 2008, Terminal Systems Inc, the operators of Deltaport, stated on their website, in documents, and in studies, that container traffic capacity at Deltaport was 1.4 million TEUs which would expand to 2.1 million TEUs with the Deltaport Third Berth.

“Deltaport capacity after the completion of Deltaport Berth 3 in 2009 will be 2,100,000 TEUs” TSI Website: 2005-2006

This information was also documented in Chapter 4.2 of the Transport Canada Pacific Coast Container Terminal Competitiveness Study – TP 14837E, 2011.

“…Terminal Systems Inc. is adding a third berth at Deltaport to increase capacity from 1.4 to 2.1 million TEUs per year by 2009

Chapter 4.2 of the Transport Canada Pacific Coast Container Terminal Competitiveness Study – TP 14837E, 2011 https://www.tc.gc.ca/eng/policy/report-research-ack-tp14837e-chapter4-1646.htm

The statistics used in the Environmental Assessment for the Deltaport Third Berth were lower by 500,000 TEUs for claimed existing capacity and lower for added capacity stating the Third Berth would add 400,000 TEUs of capacity:

“The proposed Project at Roberts Bank would increase Deltaport capacity from 900,000 TEUs a year in 2003 to 1,300,000 TEUs by 2008.” Deltaport Third Berth Project, Environmental Assessment Application, Page iv Scrolled p.5/86 https://www.portvancouver.com/wp-content/uploads/2015/03/EA_App_Preface_et_al.pdf

However, when the Project was completed, the VFPA announced an initial capacity that was higher by 300,000 TEUs and a higher added capacity of 600,000 TEUs.

“The project, which took two years to construct, increases Deltaport’s capacity by up to 50 per cent from 1.2 million twenty-foot equivalent units (TEUs) to 1.8 million TEUs.”

Deltaport’s new third berth officially opens, January 18, 2010 https://www.portvancouver.com/news-and-media/news/deltaports-new-third-berth-officially-opens- bringing-a-50-per-cent-increase-in-terminal-capacity/

Then in 2011, the VFPA announced the Deltaport Terminal Road and Rail Terminal Improvement Project (DTRIPP) that would add 600,000 TEUs to Deltaport by 2017 for a total capacity of 2.4 million TEUs:

“The VFPA proposes to provide funding for the design and implementation of a project that could increase the container capacity at Deltaport Terminal by 600,000 TEUs (twenty-foot equivalent unit containers) to a total capacity of 2.4 million TEUs.”

Deltaport Terminal, Road and Rail Improvement Project, Delta, BC, CEAA Screening, October, 2011 https://www.acee-ceaa.gc.ca/052/details-eng.cfm?pid=64535

Section 5.3.1.1 of the RBT2-EIS, states the Deltaport Terminal Road and Rail Improvement Project (DTRRIP): “…will improve efficiency and further increase capacity at Deltaport Terminal by 600,000 TEUs to 2.4 million TEUs by 2017”

Section 2.1.1 addresses rationale for the RBT2 Project: “The Project will provide an additional 2.4 million twenty-foot equivalent unit (TEU) of container capacity per year.” Deltaport Terminal , Road and Rail Improvement Project, Delta, BC, CEAA Screening, October, 2011 https://www.acee-ceaa.gc.ca/052/details-eng.cfm?pid=64535

However, the study for the Deltaport Road and Rail Improvement Project (DRRIP) confirms that Deltaport, without RBT2, can handle 3 million TEUs by 2020 with the transportation upgrades, intermodal yard reconfiguration and improved efficiencies. The road and rail upgrades have added capacity of 600,000 TEUs and the associated upgrades will further increase capacity.

“Case 1: Deltaport has a sustainable capacity of 2.4 million TEU. Deltaport has maximum capacity of 3.0 million TEU in the interim years of high demand up to about 2020. Cases 2 and 3: Deltaport has a sustainable capacity of 3.0 million TEU.”

Projections of Vessel Calls and Movements at Deltaport and Westshore Terminals, Deltaport Terminal Road and Rail Improvement Project (DTRRIP), November 28, 2011, pages 21&22 http://www.robertsbankterminal2.com/wp-content/uploads/Projections-of-Vessel-Calls-and-Movements-at-Deltaport-and- Westshore-Terminals.pdf

There is further evidence the Environmental Assessment Report for the Deltaport Road and Rail Improvement Project (DRRIP):

“Emissions are calculated based on the Deltaport container terminal reaching a capacity of 3 million TEUs per year by 2020 due to Deltaport improvements”

Environmental Assessment Report, Deltaport Terminal Road and Rail Improvement Project; Hemmera; November, 2012, bottom of page 276 (Scrolled 299/450) https://www.portvancouver.com/wp-content/uploads/2015/03/the-environmental-assessment-report.pdf 24

Appendix B: Actual TEUS for Vancouver, 2000 - 2007

Year TEUs TEUs Total TEUs VPA Fraser River Port

2000 1,163,000 66,842 1,229,842 2001 1,146,577 50,565 1,197,142 2002 1,458,218 100,544 1,558,762 2003 1,539,058 252,510 1,791,568 2004 1,664,906 317,582 1,982,488 2005 1,767,379 372,844 2,140,223 2006 2,207,730 94,651 2,302,381 2007 2,307,289 191,402 2,498,691

Sources of Information:

2007: page 14 reported 191,402 TEUS Fraser River Port Sunny Yang Yang: Economic Impact of Short-Sea Shipping: Using the Fraser River as a Commercial Highway

Fraser River Port Authority,“5 year International Summary”. Sources: Fraser River Port Authority Website http://www.fraserportauthority.com/cargo/first.html, November 2004) and Vancouver Port Authority Website: http://www.portvancouver.com/trade_shipping/terminals/,

Application for the Deltaport Third Berth Project, page 112 Environmental Assessment Application, Project Background Sources: 2000 – 2003, Table 3.2, p. 112, Proponent’s Application; 2003 – 2005, Annual Reports, VPA and Fraser Port Authority http://a100.gov.bc.ca/appsdata/epic/documents/p212/d19622/1108345711609_f26c46a9c4474ae28f98bc4 6cce3d3f0.pdf

Port of Vancouver 2005 Statistical Summary: Vancouver Port Authority (VPA) News Release Jan. 18, 2007. Fraser River Port Cargo Stats: 5 year summaries

Statistics Canada, Transportation Canada, Annual Reports and Addendums https://sfta-tfsa.tc.gc.ca/eng/user/me/English/Report

Canadian Shipper Reports Statistics Canada: Shipping in Canada http://www.statcan.gc.ca/pub/54-205-x/2005000/5209017-eng.htm

Vancouver Sun Article: Cargo Surges at Fraser River Port http://www.canada.com/story_print.html?id=1b65ca41-2369-490e-8e40-59b5379e7091&sponsor=

Port of Vancouver Statistics 1985-2004 Referenced on page 81 of Policy Options: The Trading Dragon, December 2005 to January 2006 http://policyoptions.irpp.org/issues/global-warming-a-perfect-storm/the-trading-dragon-boosting-canadas- transportation-infrastructure-to-accommodate-the-new-china-syndrome/

Fraser River Port Authority, 5-year International Summary, referenced in BCIT published paper, “The Fraser River as a Commercial Highway” http://faculty.bcitbusiness.org/kevinw/documents/Fraser_River_SSS_Final.pdf

InterVISTAS 2008 Port Metro Vancouver Economic Impact Study, page 9 http://www.portmetrovancouver.com/docs/default-source/about-facts-stats/2009-01-12_Intervistas_- Port_Metro_Vancouver_Economic_Impact_Study_FINAL_REPORT.pdf?sfvrsn=0 25

Appendix C: Ocean Shipping Consultants 2016: Container Traffic Forecasts

Container Traffic Forecast Study – Port of Vancouver, 2016 Ocean Shipping Consultants https://www.portvancouver.com/wp-content/uploads/2015/05/2016-Container-Traffic-Forecast-Study- Ocean-Shipping-Consultants.pdf

Page 98 – Combined Forecast Demand for Prince Rupert Port Authority and Vancouver Fraser Port Authority

Page 219 - Forecast Demand for Vancouver Fraser Port Authority

Appendix D: Imports and Exports at the Port of Vancouver

Appendix E: Table of Import US-Bound and Canada-Bound Container Traffic to Vancouver: Actuals and Forecasts

Sources of Information: tables copied below VFPA Statistics; Ocean Shipping Consultants Study 2016, page 220, Port of Vancouver - Base Scenario Import Container Port Demand to 2030 Ocean Shipping Consultants Study 2016, page 95, Base Case Imports for Pacific Gateway Ocean Shipping Consultants Study, 2014 Report, Table 8.1 (2007-2013 data) Table 1R1-03-02 – shown in Appendix D

Projected Projected Import Import US Import Canada YEAR Import US Canada Bound Bound TEUs Bound TEUs Bound TEUs TEUs

2000 38,231 507,934 2001 38,779 515,202

2002 96,454 645,497 2003 90,308 662,258 2004 65,983 758,800 2005 44,216 840,108

2006 79,611 1,057,696

2007 91,091 1,210,216

2008 103,545 1,190,763

2009 89,828 1,033,021

2010 129,694 1,167,252

2011 171,679 1,148,931

2012 261,236 1,190,073

2013 316,678 1,191,314

2014 358,036 1,198,642

2015 379,403 1,201,443

2016 357,452 1,196,687

2017 394,048 1,319,202

2018 417,800 1,406,700

2019 439,400 1,479,200

2020 461,000 1,552,300

2021 480,900 1,618,900

2022 501,500 1,688,600

2023 517,600 1,726,000

2024 534,100 1,798,000

2025 551,000 1,855,300

2026 568,400 1,913,700

2027 586,100 1,973,400

2028 599,800 2,019,300

2029 613,500 2,065,700

2030 627,400 2,112,300

Page 220 OSC 2106: Table 7.2 Port of Vancouver - Base Scenario Import Container Port Demand to 2030

Table Page 95 Base Case Imports for Pacific Gateway, OSC 2016