Fisheries and Oceans Peches et Oceans • Canada Canada Regional Director General Directrice generale regionale Pacific Region Region du Pacifique Suite 200 - 401 Burrard Street Piece 200 - 401 rue Burrard Vancouver, British Columbia Vancouver (C.-B.) V6C 3S4 V6C 3S4

FEB 0 ~ 2019

Ms. Jocelyne Beaudet, Panel Chair Dr. David Levy, Panel Member Dr. Douw Steyn, Panel Member c/o Cindy Parker, Panel Manager Ca"nadian Environmental Assessment Agency 160 Elgin Street, 22'ld Floor Ottawa, ON, KIA OH3

Dear Ms. Beaudet:

Subject: Fisheries and Oceans Canada's Response to the Roberts Bank Terminal2 Project Review Panel's December 4, 2018letter

Thank you for you December 4, 2018 letter addressed to Catherine Blewett, the former Deputy Minister of Fisheries and Oceans Canada.

As requested in your letter, DFO has reviewed the Vancouver Fraser Port Authority's responses to the Information Request Packages 9 through 13 and the remainder of responses to Packages 7 and 8. Please find attached Fisheries and Oceans Canada's comments on the sufficiency and technical merit of the responses.

If you, or anyone conducting work on your behalf, have questions regarding DFO's response, , or by email at

Rebecca Reid Regional Director General, Pacific Region

Attachment: Fisheries and Oceans Canada's Response to the Roberts Bank Terminal 2 Project Review Panel's December 4, 2018 letter Canada Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project This document is provided in response to the December 4, 2018 letter addressed to Catherine Blewett, former Deputy Minister of Fisheries and Oceans Canada (DFO) from the Panel Chair Jocelyn Beaudet, pertaining to the Roberts Bank Terminal 2 Project. The Review Panel requested DFO to provide the Review Panel with comments on the responses from the Vancouver Fraser Port Authority (VFPA; the Proponent) to the Review Panel’s information request packages 9 through 13 and the remainder of responses to Packages 7 and 8, by February 8, 2019. Specifically, the Review Panel has requested that DFO comment on whether the responses sufficiently address the Information Requests that were issued by the Panel and the technical merit of the information provided in response to the Information Requests.

DFO has previously provided comments on the sufficiency of the Proponent’s responses to the Review Panel’s Information Request Packages 2-5 in CEAR#1102 and CEAR#1289. This response contains DFO comments on the information provided by the Proponent in response to Information Request Packages 7, 11, and 12.

DFO Evaluation of VFPA Response to IR7-25 Marine Fish Mitigation – On Site Offsetting Concepts: Sandy Gravel Beach Review Panel Information Request: Given the range (4.5 to 10 hectares) of sandy gravel beach in the proposed offset concept, provide a rationale for why 4.5 hectares was used in the calculation to predict biomass of functional groups in the sandy gravel beach offset concept. Proponent Response: The Proponent’s response provides rationale for why 4.5 ha was used in the calculation to predict biomass of functional groups in the sandy gravel beach offset concept. The response outlines an approach of preferentially selecting offset habitat concepts with high productive potential (measured via biomass), as well as considering the likelihood of success of offset concepts based on physical characteristics of available on-site locations. The Proponent indicates that sandy gravel habitats have relatively low estimates of productive potential in comparison to intertidal marsh and mudflat habitats and its productivity is largely attributed to Fucus. Because of this low relative productive potential, ‘Existing sandy gravel habitats were selected as habitat types over which offsetting habitats (with higher productivity) could be located and built.’

DFO Evaluation: The sandy gravel beach offsetting concept targets spawning habitat for forage fish, one of the Marine Fish VC sub-components predicted by the Proponent to have residual effects following mitigation. The Proponent acknowledges the importance of this habitat type to forage fish and proposes to create 4.5 ha of sandy gravel beach on-site. However, in its response to IR7-25, the Proponent also identifies existing sandy gravel beach habitat as a habitat type over which other offsetting habitats could be located due to its low productive potential (biomass in tonnes) relative to other habitat concepts (as predicted using the ecosystem model). Productivity gains associated with the sandy gravel beach offset concept are predicted by the Proponent to be largely attributed to Brown algae (Fucus) and green algae (Ulva).

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 1

While the Proponent’s modelling estimates sandy gravel beach habitat to have relatively low productive potential in comparison to other habitat concepts, the metric used to assign value to sandy gravel beach (productivity in tonnes) does not fully capture the benefit of this habitat type to forage fish as spawning habitat. Table IR7-26-A1 demonstrates relatively low gain in productivity for forage fish relative to productivity gains resulting from vegetative biomass in the offsetting concepts which are largely attributed by gains in macroalgae for sandy gravel beach, tidal marsh species for the tidal marsh offsetting concept, and biofilm for the mudflat offsetting concept. Thus, the relative values of these habitat types using productivity is also largely attributed to vegetative biomass.

Sandy gravel beach was not identified in the estimated proportions of underlying habitat in EIS Table 17- C1 Proposed areas for Onsite Habitat Offsetting Concepts or the existing habitat types in Table IR7-26-1. It is unclear whether the Proponent intends to build offsetting habitat over existing sandy gravel beach. If construction of offsetting habitat is proposed on existing sandy beach habitat (loss of sandy beach habitat) and construction of sandy beach habitat is proposed as an offsetting measure (gain of sandy beach habitat) it appears the net benefit may be limited and result in unnecessary impacts to existing fisheries resources.

DFO Evaluation of VFPA Response to IR7-26 Marine Fish Mitigation – OnSite Offsetting Concepts Review Panel Information Request: Describe how the net gain in autotrophic productivity from the onsite offsetting concepts was estimated. Describe the assumptions for calculating the net biomass increase of heterotrophic functional groups associated with the offsetting concepts. Describe how the areal extent of the conceptual habitat projects was integrated into the calculations and results shown in Table 17-C2 of Appendix 17-C of the EIS; Change in Biomass for Functional Groups With the Project and With Proposed Onsite Offsetting. Proponent Response: The Proponent uses the Roberts Bank ecosystem model to evaluate changes in functional groups from a ‘without Project’ to a ‘with Project’ state. Those changes can result from direct negative effects of the project footprint, and from positive or negative effects of the indirect changes caused by the Project on conditions in the Roberts Bank study area. To estimate the benefits generated by offsetting measures, the Proponent uses model outputs to select the best examples of the natural habitats (defined as those one-hectare cells that have the highest 0.02% of functional group biomass) that the offsetting measures are attempting to emulate. The net gain of the offsetting measure is based on the biomass predicted for the offsetting measure (based on the best natural analogue habitats), less the losses (biomass per hectare) resulting from the placement of the offset over existing habitat values. The area of the offset is used to scale the results to total changes in biomass predicted to occur with the implementation of each offsetting measure. The Proponent provides an expanded table that sets out the important functional groups (as well as some aggregated groups) and the gains or losses to each of them that is associated with each offsetting measure.

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 2

DFO Evaluation: The Proponent has expanded its description of the computations used to evaluate offset benefits as requested by the Panel. Many of the assumptions and steps are not well described and the Panel may benefit from seeing these laid out more explicitly. The use of a few equations such as the framework used by Minns (2007) may be helpful. In addition, a table that focusses solely on the offsetting benefits may be of more use to reviewers. That table could include, for example, a few key rows of Table IR7-26-A1: 1. Area of offset proposed 2. Productivity (biomass/ha) predicted to result from the offset type 3. Productivity of pre-existing habitat where the offset will be placed 4. The gain (#1 x #2) and the loss (#2 x #3), and the overall net change. A key assumption that has not been addressed in the response to IR7-26 is the use of the upper 0.02% of modelled biomass estimates of existing habitats as the prediction of the gain expected to result from offsetting. Previously DFO noted that justification for this choice was not well explained, and concern was expressed that constructed habitats may not achieve such biomass levels. It was suggested that either an empirical analysis of existing compensation works be used to guide the estimation of offsets, or some consideration for the offsets that do not meet the modelled predictions.

DFO Evaluation of VFPA Response to IR7-30 Marine Biophysical Components- Offsetting as Mitigation Measure Review Panel Information Request: Provide a description of how the benefits from offsetting measures balance adverse effects to marine vegetation, marine fish, and marine invertebrates from the proposed Project. This description should include identification of whether offsets are replacing similar habitat to that being harmfully altered or destroyed (such as eelgrass transplant to offset destruction of eelgrass), or whether offsets are targeting other factors limiting productivity at Roberts Bank. Proponent Response: The Proponent’s response re-organizes information presented in the Environmental Impact Statement (EIS) and in the Proponent’s responses to IR7-26 and IR11-14 and provides further narrative. No new substantive information is provided.

The primary response to the Panel’s request to describe how the benefits from offsetting measures balance adverse effects to marine VC’s from the Project is that ‘it is anticipated that predicted shortfalls in some functional groups/focal species will be balanced through the surplus productivity and indirect productivity benefits in others’. DFO Evaluation: Comments on the more detailed information pertaining to the use of overall ecosystem productivity as an offsetting equivalency metric are provided in DFO’s evaluation of the Proponent’s responses to IR7-26 and IR11-14.

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 3

In response to IR7-30, the Proponent states: ‘it is anticipated that predicted shortfalls in some functional groups/focal species will be balanced through the surplus productivity and indirect productivity benefits in others’. Using Marine Invertebrates as an example, DFO illustrates how this approach does not fully consider how the benefits of offsetting measures balance the adverse effects.

Through multiple lines of evidence, the Proponent concludes non-significant residual adverse effects for the Marine Invertebrate Valued Component. The Proponent acknowledges that some Marine Invertebrate VC sub-components are predicted to experience losses as a result of the Project. Table IR7- 26-A1 predicts an overall increase in biomass of 68.52t for the Marine Invertebrate Valued component, mainly attributed to predicted increases in biomass of macro- and meiofauna, with predicted decreases in other sub-components (Dungeness crab, bivalves, and Orange sea pens). Proposed offsetting measures do not appear to substantially benefit Dungeness crab, bivalves and Orange sea pens, as the Proponent forecasts a combined increase in only 1.2t following offsetting compared to a combined loss of 657t. Given the predicted gains and losses at the sub-component level, further discussion of spatial and species trade- offs would be necessary in the development of the final offsetting plan. In its response to IR7-30, the Proponent commits to developing the final offsetting plan with engagement of Indigenous groups, regulatory agencies, and stakeholders.

To supplement other equivalency metrics, DFO is interested in a habitat balance table that presents direct footprint effects to fish habitat (ha), indirect habitat losses (ha), indirect habitat gains (ha), and offsetting proposed (ha). This ledger would be useful to DFO’s understanding of the proposed changes to habitat availability at Roberts Bank resulting from the Project, and in determining whether proposed offsetting measures adequately counterbalance impacts to fish habitat resulting from the Project. This ledger could also be used to identify physical habitat suitability metrics that could inform follow-up monitoring programs to verify the accuracy of Proponent predictions of effects to fish, invertebrates, and fish habitat. In order to consider indirect benefits to habitat or productivity associated with the Project prior to offsetting, these effects would need to be verified through follow-up monitoring and contingency plans put in place should these benefits not be realized.

DFO Evaluation of VFPA Response to IR11-14 Offsetting Equivalency Analysis Review Panel Information Request (numbers added for reference): 1. Provide a defined set of metrics to capture the net benefits from offsetting to mitigate direct and indirect environmental effects from the proposed Project, including habitat losses and the rationale for their selection. The metrics should represent all groups identified in Table 17-3 of the EIS. 2. Provide an equivalency analysis to quantitatively estimate offsetting benefits in relation to Project environmental effects for the selected metrics, in order to characterize residual environmental effects on the marine biophysical components and functional groups. 3. Segregate the analysis to identify the extent to which the proposed offsets are intended to mitigate direct environmental effects (habitat losses associated with the Project footprint) and indirect environmental effects of the Project (modification of productivity caused by changes in circulation and other coastal processes). 4. Explain how the metrics could be used by the Proponent in its follow-up program to verify the accuracy of its predictions and determine whether benefits have been realized through offsetting. 5. Resolve any discrepancies between the offsets identified as part of this response, those presented Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 4

in Table 17-5 of the EIS, and in Table IR12-A of CEAR Doc#314. Use this information as a reference in subsequent responses regarding how offsets are intended to mitigate specific Project-related environmental effects. 6. When responding to this IR, integrate any new information generated in Proponent Responses that would be relevant, such as from IR Packages 5 (4, 7, 14 and 28), 7 (24-31), 8 (5, 6 and 8) and 9 (5) (CEAR Doc#934). Proponent Response: The Proponent identified the biomass of various functional groups as an appropriate equivalency metric for the determination of losses and gains associated with the Project and offsetting measures. Using the Roberts Bank ecosystem model the change in metric values associated with indirect and direct effects of the Project are predicted, and the changes in biomass associated with the offsetting measures are estimated. A detailed table of these computations for a suite of functional groups is provided. The Proponent briefly describes how their Follow-up Program will monitor the efficacy of offset measures. DFO Evaluation: 1. “Clarification”: In the discussion of the use of productivity on Page 3 of IR11-14, there is an important omission in the citation from Bradford et al. (2016). Bradford et al. notes that “An example of an appropriate metric evaluating habitat function is secondary production (i.e., the incorporation of organic matter into body tissue of invertebrate mass per unit time and area...)” [Underlining denotes missing term in the IR]. Invertebrate production is highlighted as a potential surrogate for fisheries productivity in equivalency analyses. Other metrics may be appropriate as surrogates for other parts of the ecosystem (e.g., birds). In the equivalency analyses described by Bradford the intent is to use secondary production as a proxy for food production for all fish thus alleviating the need to make predictions for individual species. Other types of metrics, such as physical habitat suitability measures, could also be used depending on the nature of the habitat and impact. Use of a generalized equivalency metric could be considered equivalent to the Panel’s request that metrics “should represent all groups identified in Table 17-3”.

Extending this approach, it may have been possible to identify 4 equivalency metrics corresponding to the VC sub-components in Table 17-3 (Vegetation, Invertebrates, Fish, Birds), which is a manageable suite of indicators to evaluate the mitigation and offsetting measures. However, the Roberts Bank ecosystem model allows the Proponent to make predictions of change in biomass for individual taxa or assemblages and the IR contains computations for each group, rather than using the simplified approach of higher order surrogates. Unfortunately, to reduce the complexity caused by this suite of functional group metrics, the IR continues to refer to “overall productivity” (which is total biomass of all groups) in some parts of the response, while focusing on individual taxa in other sections. This lack of clarity makes the overall assessment of the mitigation plan more difficult.

2 & 3: The analysis of losses and gains relies on predictions from the ecosystem model. The Proponent has supplied detailed listings of predictions of changes in biomass caused by direct and indirect components of the Project, as well as net gains associated with the suite of offset measures for individual functional groups in Table IR11-14-1. The content of this table is discussed further in Question 1 above.

4: On Page 8 of IR11-14 the Proponent reiterates some elements of the Follow-up Program monitoring. The program is focused on assessing the offsetting measures using standard methods and metrics.

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 5

However, the plan falls short of verifying the accuracy of model predictions as was requested by the Panel. Those predictions are the basis of the scale and scope of the mitigation program. For example, the model predicts substantial increases in secondary (invertebrate) production from the meiofauna and macrofauna groups as a result of indirect effects to the area surrounding the Project; those gains dwarf the losses due to footprint impacts. Similar results occur for biofilm and tidal marsh species groups. These are the main drivers of the prediction of an “overall gain in productivity with the Project” (Table IR11-14- 1). If there is a desire to evaluate changes in ecosystem productivity predicted by the model, the monitoring program will have to be expanded in scope.

5 &6: It is noteworthy that the response to this request states that “the proposed Offsetting Framework was developed to ensure there is no net loss of productivity for key marine biophysical VCs at Roberts Bank, including marine vegetation, invertebrates, fish, mammals, and coastal birds, or for wetlands, meeting the environmental assessment phase requirements of the Project”. As noted earlier, it may have been useful to organize the equivalency metrics and calculations to be explicitly consistent with these VCs.

DFO Evaluation of VFPA Response to IR11-20 Effects Assessment for Juvenile Chinook and chum salmon

Review Panel Information Request: Conduct an effects assessment of the proposed Project within the Marine Fish Local Assessment Area (EIS Figure 13-1) on juvenile Chinook and chum salmon in the vicinity of the Project that is independent of the RB model results. Include an evaluation of the effects of the Project on juvenile Chinook and juvenile chum survival during their seasonal occupation of Roberts Bank in the vicinity of the Project. Provide a table summarizing the respective sources of evidence relied upon to draw effects conclusions and their relative weighting.

Include a cumulative environmental effects assessment on juvenile Chinook and chum salmon in combination with other past, existing and future project effects and activities within the Marine Fish Local Assessment Area. Include the following existing structures:  Tsawwassen Causeway and terminal,  Westshore Terminal,  Deltaport Causeway,  Deltaport including Deltaport Third Berth,  sea dykes between Brunswick Point and the Tsawwassen Causeway. The cumulative environmental effects assessment should evaluate the effects of the above structures on the utilization and seasonal distribution of juvenile Chinook and chum salmon in relation to juvenile salmon access to historical and existing intertidal marshes and other shallow sub-tidal habitats.

When responding to this IR, integrate any new information generated in Proponent Responses that would be relevant, such as from IRs in Packages 5 (4, 7, 14 and 28), 7 (24-31), 8 (5, 6 and 8) and 9 (5). Proponent Response: The Proponent’s response to this request involved re-organising information on the assessment of potential Project-related effects on juvenile Chinook and chum salmon already included in various submissions; no new information is presented in this response.

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 6

1) Adequacy of Roberts Bank ecosystem model to forecast Project impacts to juvenile Chinook and chum salmon. The Proponent states that DFO’s understanding that outputs of the Roberts Bank ecosystem model are not intended to be used to forecast the responses of particular functional groups, but to forecast the effect of the Project on the overall productivity of the entire ecosystem, is inaccurate. The Proponent states that “the objective of the Roberts Bank ecosystem model was not to provide an assessment of Project impacts for each functional group at a fine temporal scale. Instead, the ecosystem model was used to forecast longer term changes in the productive potential of each functional group that may result from terminal and causeway footprints by incorporating ecosystem considerations…” (IR11-20, page 3). As a consequence, the Proponent states that “the Roberts Bank ecosystem model provides a useful indication of the relative change over the longer term on each functional group (including juvenile Chinook and chum salmon) with and without the Project…” (IR11-20, page 4). The results of the ecosystem model are strengthened by the extensive sensitivity analyses completed in the EIS which demonstrate that ecosystem model outputs for juvenile Chinook and chum salmon are robust to uncertainty in input parameters.

The Proponent also states that the scale of the Roberts Bank ecosystem model is relevant and appropriate for detecting and quantifying changes in the productivity of juvenile Chinook and chum salmon that may result from the Project’s proposed footprint. Spatial boundaries of the ecosystem model were selected to encompass the anticipated maximum extent of Project related changes in coastal geomorphic processes, which in turn influence the productivity of the Roberts Bank ecosystem components, including juvenile Chinook and chum salmon.

2) Conduct an effects assessment of the proposed Project on juvenile Chinook and chum salmon that is independent of the ecosystem model. Multiple lines of evidence were considered and integrated in the assessment of Project-related effects on marine fish sub-components, including juvenile Chinook and chum salmon. The ecosystem model forecasted a minor increase with the Project in the productive potential of juvenile Chinook and chum salmon, which was likely over-estimated based on sensitivity analyses. Lines of evidence that were integrated into the juvenile salmon assessment included ecosystem model outputs, empirical data collected during the Project’s field surveys, literature findings, evidence from previous environmental assessments, and additional assessment conclusions of the Project. The ecosystem model forecasted a minor increase in juvenile salmon productivity with the Project, whereas other lines of evidence suggest a minor loss in juvenile salmon productivity via construction, acoustic and lighting disturbance, and migration mechanisms. As a result, consideration of other lines of evidence changed the direction of the ecosystem model output and a minor loss in juvenile salmon productivity was assessed pre-mitigation instead of a minor gain predicted by the ecosystem model.

3) Provide a cumulative environmental effects assessment on juvenile Chinook and chum salmon in combination with other past, existing and future Project effects and activities. A cumulative effects assessment on juvenile Chinook and chum salmon is not warranted because, taking mitigation into account, potential Project-related changes in juvenile salmon productivity are assessed as negligible, with no residual effects that could combine with the effects of other projects or activities. Best available scientific information suggests that large scale environmental mechanisms, rather than local

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 7 factors such as shoreline development, are predominantly responsible for recent declines in the productivity of Chinook and chum populations of the southern B.C. coast (including the Fraser River).

In Section 5 on ‘Evidence from conclusions of other intermediate/valued component assessments: Changes in water quality’, the Proponent states that based on the conclusions of the surficial geology and marine sediment assessment, contaminants present at Roberts Bank are closely associated with fine sediments that have largely accumulated in locations outside those that will be disturbed by Project activities (such as the upper intertidal zone north of the causeway near Brunswick Point). No appreciable sediment contamination was observed in Project areas. As a result, potential effects on juvenile Chinook and chum salmon from re-suspension of sediment contaminants were characterized as negligible. DFO Evaluation: 1) Adequacy of Roberts Bank ecosystem model to forecast Project impacts to juvenile Chinook and chum salmon. The Proponent’s statement that “the ecosystem model was used to forecast longer term changes in the productive potential of each functional group that may result from terminal and causeway footprints by incorporating ecosystem considerations…” (IR11-20, page 3, and as cited above) is not quite what the Proponent had written in the Preamble to IR3-01 to IR3-24, as referenced to CEAR Document #984. In that document, the Proponent stated that “It is important to note that the objective of the RB model is not to provide an assessment of Project impacts for each functional group at a fine temporal scale (i.e., a specific migratory window), but to estimate changes in productive potential, with and without the Project, at the ecosystem level” (Sufficiency Information Request Package 3 Preamble to IR3-01 to IR3-24, page 10 and re-iterated on P1 of IR3-24 in the same document). The question here is whether the Roberts Bank ecosystem model provides a useful indication of the relative change of each functional group over the longer term.

This is a discussion of whether the model can be used to forecast impacts on the productivity of single functional groups, which is the way that EwE models are commonly used. The key point in the Proponent’s response is that they are not attempting to do this at fine temporal scales. DFO maintains its conclusion that the model is useful for evaluating integrated ecosystem productivity aspects, but is less appropriate for evaluating highly migratory functional groups. However, in the Proponent’s subsequent analyses of the impacts of the Project on the productivity of juvenile Chinook and chum using non-model sources, they conclude all other mechanisms (injury and direct mortality; changes in the acoustic environment, water quality, sedimentation, light, and habitat availability) indicate minor losses, which contrast with the minor positive impacts forecast for juvenile Chinook and chum salmon by the ecosystem model. Their conclusion is therefore for a minor negative impact of the Project on the productivity of juvenile Chinook and chum salmon. This indicates the ecosystem model results for these groups did not play a major role in the final assessment by the Proponent. The Proponent’s conclusion of minor negative impacts of the Project on the productivity of juvenile Chinook and chum salmon is reasonable based on the data presented, independent of the outcome projected by the ecosystem model.

2) Conduct an effects assessment of the proposed Project on juvenile Chinook and chum salmon that is independent of the ecosystem model. It is always best practice to attempt to validate the results of large and complex ecosystem models with data and analyses independent of the model outputs. The analyses by the Proponent of other (non-model) sources of information are appropriate, and the conclusion of minor negative impacts seems justified.

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 8

There appears to be one contradictory set of statements regarding changes in the acoustic environment (Sufficiency information request IR11-20, page 11): “Potential injury effects on juvenile Chinook and chum salmon from changes in the acoustic environment were assessed as minor based on underwater noise modelling results that predicted exceedances of injury thresholds in the immediate vicinity of impact piling activities with the potential to cause injury and mortality of fish. Acoustic disturbance in the immediate vicinity of pile driving activities is expected to be negligible.” These sentences are either contradictory, or poorly worded. Perhaps the Proponent is concluding that acoustic disturbances will be negligible with mitigation? It is unclear how a conclusion of minor injury effects on juvenile Chinook and chum salmon in the immediate vicinity of pile driving activities was obtained if underwater noise modelling predicted exceedances of injury thresholds for fish. The Proponent’s analyses of potential minor impacts to juvenile Chinook and chum salmon productivity as a result of the Project due to changes in habitat availability are reasonable. The Proponent’s conclusions of a minor loss of juvenile Chinook and chum salmon productivity due to changes in the acoustic environment from the Project are unclear as written in this IR response. To cite from EIS 13.6.3.1 page 13-99: “If impact piling is used, sound levels near the source will reach levels that can cause physical harm to salmon, and behavioural change can also be expected within meters of impacts piling activities”.

In the section on changes in water quality, the Proponent states (IR11-20, Page 10-11) that 1) “no appreciable sediment contamination was observed in Project areas”; and 2) “potential effects on juvenile Chinook and chum salmon from re-suspension of sediment contaminants were characterized as negligible” because “contaminants present at Roberts Bank are closely associated with fine sediments that have largely accumulated in locations outside those that will be disturbed by Project activities”. The pathways of effects regarding the exposure of juvenile Chinook and chum salmon to potentially-elevated contaminant concentrations in this area as a result of the Project are complex and should not be assumed to be negligible. This response is based on at least two specific concerns:

1. Analyses by the Proponent indicate that the existing depositional area will expand across the northern tidal-flats post-Project based on 1) the bed shear stress plots generated before and after the Project (blue/green contours in bed shear stress figures: EIS, Section 9.5 Appendix-D, p. 14-15 and reproduced below) and 2) locally-derived sediment resuspension criteria (0.2 N m-2; Amos et al. 1997). This event will promote the accumulation of fine sediment, organic-rich material, and trace-elements within the vicinity of the Project area and the out-migration routes of shore-tied and shallow-dwelling juvenile Chinook and chum. Trace-elements are commonly associated with fine silts and clay as well as organic material (Sutherland et al. 2018);

2. The processes that can re-suspend sediments, and the contaminants contained therein, are not limited to physical or hydrodynamic forces (e.g. tidal or wave action). For example, sediment mobilization can also occur due to biological activities, such as, eelgrass movement, fish-finning, and shorebird wading/probing. Bioaccumulation of contaminants via the food web may serve as an additional pathway for contaminant exposure (e.g. fish feeding on harpacticoid copepods that migrate between eelgrass and organic-rich biofilm-laden sediments (Levings, 1985; Webb, 1991; Luoma and Rainbow, 2005)). Alternately, bioaccumulation may amplify contaminants up the food chain at lower concentrations or decrease Chinook and chum prey survivability and availability at higher contaminant concentrations (van Damme et al. 1984).

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 9

Figures below are from EIS, Section 9.5 Appendix-D, p. 14-15, and pertain to DFO’s response regarding changes in water quality (above).

3) Provide a cumulative environmental effects assessment on juvenile Chinook and chum salmon in combination with other past, existing and future Project effects and activities. In regards to the cumulative effects assessment, the Proponent says this is not warranted because the greatest pressures are at large spatial scales. This speaks to the issue of these juvenile salmon being highly migratory, and the problems of looking at a small spatial area within their larger migration route, such as the Roberts Bank ecosystem model (see comments above). The Proponent is probably correct that the strongest drivers are at large spatial scales. This conclusion is, in effect, a qualitative cumulative effects assessment. However, while this may be true in general, it does not mean that it is true for those salmon populations that occupy the Roberts Bank ecosystem during some phase of their migration. It does not consider the role that Roberts Bank might play in mitigating (buffering) or exacerbating these large-scale impacts on juvenile salmon that use or pass through this area. In addition, current research by DFO is Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 10 finding there are stock-specific rearing areas for Chinook salmon in the Strait of Georgia. While this information is not specific for the Roberts Bank area, it does suggest that use of the Roberts Bank region by Chinook salmon is also likely to be stock-specific. Therefore, any impacts to Chinook salmon in this region may affect those Chinooks stocks which use this area during their juvenile migrations. The problem is that full cumulative effects assessments are difficult and rely on long data series; a full cumulative effects assessment of the role of the Roberts Bank ecosystem on juvenile Chinook and chum salmon would require a directed research program over a long period of time.

REFERENCES Amos, C.L. Feeney, T., Sutherland, T.F. and Luternauer, J.L., 1997. The stability of fine-grained sediments from the Fraser River delta. Estuarine, Coastal and Shelf Science 45, 507-524.

Levings, C.D. 1985. Juvenile salmonid use of habitats altered by a coal port in the Fraser River Estuary, British Columbia. Marine Pollution Bulletin. 16(6): 248-254.

Luoma, S.N. and P.S. Rainbow. 2005. Why is metal bioaccumulation so variable. Biodiversity as a unifying concept. Environ. Sci. Technol. 39(7): 1921-1931.

Sutherland, T.F., L.M. Garcia-Hoyos, P. Poon, M.V. Krassovski, and M.G.G. Foreman, A.J. Martin, and C.L. Amos. 2018. Seabed attributes and meiofaunal abundance associated with a hydrodynamic gradient in Baynes Sound, British Columbia, Canada. Journal of Coastal Research, 34(5): 1021 – 1034.

Van Damme, D., C. Heip, and K.A. Willems. 1984. Influence of pollution on the harpacticoid copepods of two North Sea estuaries. Hydrobiologia, 112: 143 – 160.

Webb, D.G. 1991. Effect of predation by juvenile Pacific salmon on marine harpacticoid copepods. II. Predator density manipulation experiments. Marine Ecology Progress Series, 72: 37 – 47.

DFO Evaluation of VFPA Response to IR12-13 - Organic Enrichment

Review Panel Information Request (numbers added for reference): 1. Provide a detailed description of the existing conditions relative to nutrient and organic matter enrichment and to the occurrence of anoxic events within the Marine Water Quality Study Area, including the area north of the existing causeway and the inter-causeway area of Roberts Bank. 2. Provide an explanation for how the potential change in the distribution of organic-rich sediments due to the proposed Project may affect water quality at localized or larger scales within the Marine Water Quality Study Area. 3. Provide a discussion on the potential environmental effects that could change water quality and lead to anoxic conditions for the environmental components assessed in the EIS and, clarify whether the potential for organic enrichment was considered in the design and evaluation of the proposed offsetting habitat concepts for the Project. 4. Provide a description of the specific measures that would be included as part of the follow-up program to verify organic enrichment conditions and applicable mitigation measures in the event that organic enrichment is identified as a result of the Project placement.

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 11

Proponent Response: Preamble Under existing conditions, large-scale eutrophication does not occur within the local study area (LSA) as shown by RBT2 environmental field studies (Hemmera, 2014b; EIS Appendix 9.6-A) and the eight-year Deltaport Third Berth Project (DP3) Adaptive Management Strategy (AMS) monitoring program results (Hemmera et al. 2015). Similarly, the Project is not predicted to measurably change the mass inputs of finer textured sediments, detrital or living organic matter, or various nutrients such as nitrate, phosphates, silicates, or iron that may trigger the occurrence of anoxic events. As such, the VFPA is confident that the Project will not lead to anoxic events as evidenced by the responses below.

1. Provide a detailed description of the existing conditions relative to nutrient and organic matter enrichment and to the occurrence of anoxic events within the Marine Water Quality Study Area, including the area north of the existing causeway and the inter-causeway area of Roberts Bank. General trends in sediment organic carbon (SOC) and nutrient distribution across the Local Study Area (LSA) were discussed, while organic matter enrichment and occurrence of anoxic events were referred to EIS document sections (9.5.6, 9.6.6, and 9.7.6) and appendices (9.5-A, 9.6-A). SOC and fine-sediments are naturally elevated in higher intertidal areas relative to that of lower intertidal areas on both sides of the Roberts Bank (RB) causeway. The causeway redirection of the Fraser river (FR) plume results in a relatively lower organic-silt fraction in the high-intertidal intercauseway region. High-energy waves remobilize fine- organic sediments from lower to higher intertidal depositional areas where wave energy dissipates. The main sources of sediment nutrient consist of agricultural/forestry-related runoff, FR watershed, municipal waste discharge, bird/wildlife excreta, and upwelling offshore waters. Increases in sediment nitrogen (nitrite, nitrate, ammonia) and phosphate may reflect eutrophication. Two hot spots of ammonia were observed at Westham Island (agricultural inputs) and DP3 tug-turning basin. Sediment phosphate (SP) varied spatially with sediment texture, SOC, and redox conditions, with higher values in the RB intercauseway region and Boundary Bay. High sediment sulfide concentrations were found in quiescent organic-rich, fine-sediment areas: 1) high intertidal northwest of causeway; and 2) DP3 tug basin (Hemmera, 2014a; Appendix C). The sulfide distribution was similar to that of ammonia, potassium, and sulfate. Although sediment anoxia is differentiated from water-column anoxia, there is a relationship between the two. Sediment redox is a net balance between heterotrophic microbial decomposition of detrital organic matter, bioturbation, and re-oxygenation by overlying water. Results of both RBT2 environmental field studies (EIS-Appendix 9.6-A) and the DP3 AMS program (Hemmera et al. 2015) indicate that large-scale eutrophication does not occur within the LSA under existing conditions. The potential for large-scale eutrophication or anoxic events in the LSA is very low due to twice-daily tidal flushing, wave action oxygenation, nutrient exchange, and reoxygenation with Strait of Georgia (SoG) and FR waters. Eutrophication occurred behind the DP3 tug basin where the elevated rock berm trapped and ponded water at tidal heights < 1-m chart datum (CD) (Hemmera, 2014a; Appendix C). Increases in heavy epiphyte loads, eelgrass decomposition, sediment sulfide, organic carbon, and total nitrogen were observed along with decreases in dissolved oxygen (Hemmera et al. 2015). The VPFA installed a swale in the tug-basin berm (2014) as a mitigative measure to facilitate drainage during low tides and improve water quality. Follow up monitoring indicated improved water quality following swale installment (VFPA 2016).

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2. Provide an explanation for how the potential change in distribution of organic-rich sediments due to the proposed Project may affect water quality at localized or larger scales within the Marine Water Quality Study Area. Project changes in organic-rich sediment distribution are not predicted to affect DO levels or water quality in general (EIS Section 9.7.8). Project changes to coastal geomorphology due to interactions between physical structure, tidal currents and wind-generated waves, will change sediment erosion/deposition, tidal elevation, and FR freshwater distribution across the tidal flats. Organic-rich, fine-silt sediments occur in the RB northern high intertidal zone due to the onshore dissipation of wave and tidal energy. Changes in tidal currents (accelerations and decelerations) during freshet and non-freshet periods are predicted to occur near the Project terminal in the lower tidal flats. Sediment deposition may be promoted with velocity reductions (0.3m/sec) in the “elbow” corner connecting RBT2 and the Westshore terminal. However, given that this area is frequently inundated with tidal currents (<1m chart datum (CD)), the potential for organic-rich fine sediment deposition is unlikely due to low bed-shear stress threshold for mobilization of fine sediments. NW and SE winds are the most frequent and dominant driving force for wave generation in southern Strait of Georgia (SoG). The Project terminal will partially block waves coming on to the tidal flat, creating a wave shadow east of the Project terminal. During a calmer climate, wave- induced sediment mobilization/suspension will be less frequent, thereby promoting sediment deposition within the “elbow” feature. No change in predicted wave heights will occur shoreward of tidal elevations of approximately 1.5m CD. The largest offshore waves are generated from SE, S, and NW directions. SE waves produce the strongest wave shadow effect due to the Project’s long-axis orientation and position relative to the Westshore terminal. Post-Project, the depositional “elbow” feature will be exposed to a NW wave regime and will likely result in bottom wave scour within this depositional feature, thereby removing organic-rich fine sediments. In the unlikely event that organic-rich sediments accumulate in elbow-shaped feature and sediments become anoxic, the likelihood that the water quality would be adversely affected at a large scale or even a localized scale is extremely unlikely. The elbow-shaped feature and other areas of the LSA are subject to twice-daily tidal flushing, wave action oxygenation, nutrient exchange and re-oxygenation with SoG and FR waters. These coastal processes would exceed the rate of accumulation of eutrophication-related parameters or DO depletion within the water column.

3. Provide a discussion on the potential environmental effects that could change water quality and lead to anoxic conditions for the environmental components assessed in the EIS and, clarify whether the potential for organic enrichment was considered in the design and evaluation of the proposed offsetting habitat concepts for the Project.

Project-related environmental effects on water quality and DO levels that could lead to anoxic conditions are considered unlikely. Marine water quality is linked to several biological components: 1) Marine vegetation; 2) Marine invertebrates; 3) Marine fish; 4) Marine mammals; and 5) Coastal birds. There are no anticipated Project-related effects associated with sediment organic carbon, nutrient enrichment, anoxic events, and marine water eutrophication that will change marine water quality and adversely affect biological components. Sediment organic carbon and nutrient enrichment occurs naturally in depositional environments, eelgrass beds, and intertidal marshes in the LSA. Organic enrichment and enhanced microbial sulfate reduction are not known to result in adverse effects to epibenthic or pelagic fauna at Roberts Bank, since 1) sulfide and ammonia diffusion are lower than air-water re-oxygenation in shallow ecosystems and 2) twice-daily tidal flushing, nutrient exchange, and reoxygenation via SoG and FR waters. The potential for organic enrichment was not directly considered in the design and evaluation of the proposed Project offsetting habitat concepts, as marine-water adverse effects (eutrophication) from the

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 13 organic enrichment is considered unlikely. Depending on the habitat type, organic matter enrichment may be considered a natural and desirable ecosystem process (e.g. intertidal march systems). Habitat concepts proposed to offset potential decreases in productivity (described in EIS Section 17.3 and EIS Appendices 17-A and 17-B) have been designed to be ecologically representative of the FR estuary and natural processes in the intertidal flats. For example, to facilitate dewatering and avoid low-tide pooling of water associated with potential accumulation of organic carbon, nutrients and DO depletion, intertidal marsh habitat concepts have been designed with a slope ratio of between 10:1 and 20:1 (see EIS-Appendix 17- B). Conversely, proposed mudflat habitats concepts have been designed with little to no slope to accumulate organic carbon and support colonization by biofilm, thereby providing foraging habitat for shorebirds and sediment-dwelling meio-and macrofaunal invertebrates.

4. Provide a description of the specific measure that would be included as part of the follow-up program to verify organic enrichment conditions and applicable mitigation measures in the event that organic enrichment is identified as a result of the Project placement. The purpose of the RBT2 Follow-up (FUP) is to verify the accuracy of effect predictions and/or effectiveness of any mitigation measures implemented for predicted adverse effects of the Project (EIS Section 33.5). The Project specific FUP focuses on remaining uncertainties with the Project effect predictions and effectiveness of mitigation (IR13-30 (CEAR Doc#1331)). In the case of organic enrichment, the VFPA is confident in the prediction that the Project will not introduce additional sources of nutrient or organic matter to the LSA and the occurrence of large-scale anoxic events and eutrophication with or without the Project is extremely unlikely. As such, a FUP is not warranted to verify organic enrichment conditions or associated effects to water quality, or to verify the effectiveness of the associated standard and proven mitigation. The Project has, however, committed to routine compliance monitoring of measureable water quality parameters (Appendix IR13-30-A; CEAR Doc #1331), which will likely include indicators of increased nutrients or organic matter. Compliance monitoring also oversees the appropriate implementation of mitigation measures, including those set to avoid, reduce, or eliminate or control the introduction of additional sources of nutrients or organic matter (sediment-control measures). The results of compliance monitoring will provide data that could indicate the occurrence of organic enrichment or associated effects to water quality. Moreover, compliance monitoring results will assist with determining, through systematic evaluation, when additional or revised measures are required to rectify and/or enhance current mitigation measures to achieve the outcomes predicted in the EIS (IR13-29; CEAD Doc #1331). DFO Evaluation: DFO evaluation of VFPA preamble Unexpected changes have been observed to occur with sediment topography and organic/nutrient enrichment in previous port projects on Roberts Bank. Caution should be taken when applying the outcomes of past Roberts Bank environmental monitoring programs that may differ in objectives, indicator variables, local study ranges (spatial scale), and study designs (far-field vs near-field; spatial and temporal frequency) (Table 1). In terms of previous project objectives, the RBT2 environmental field study was designed to gather baseline data across the Roberts Bank tidal flat to provide evidence-based information and calibration support for the hydrodynamic, sediment transport, and ecological models. In contrast, the DP3-AMS monitoring program was focused on the inter-causeway region and was designed to 1) provide practical and advance warning of any potential emerging negative ecosystem trends during project construction and operation, and 2) establish actions that VFPA can implement to mitigate negative effects (AMS, 2006; 2015).

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If large-scale events are the project’s focus for representing ecosystem change, then the following will be overlooked: 1) predicted or unforeseen change associated with localized and near-field habitats that may be identified as sensitive or critical for sustaining productivity levels of specific fisheries (e.g. juvenile salmon) and shorebirds (e.g. western sandpipers); and 2) early-warning and mitigative activities associated with small-scale and near-field events. A predicted change in an environmental variable may be considered negligible relative to bank-wide variation across the large and diverse Local Study Area (LSA), whose topography, sediment texture, wave exposure, nutrient/silt inputs, and biological habitats (eelgrass, biofilms) vary significantly. Alternately, predicted change may be significant within tidal-flat provinces of like characteristics and classifications (eg. Tidal height).

While predicted change resulting from a pre- and post-Project comparison may seem incremental, localized and/or negligible, this incremental change may provide an additive element or tipping point for an ongoing anthropogenic process associated with the original Coalport Causeway construction (Hemmera, 2004; Sutherland et al. 2013). It is important to bring forward “lessons learned” from other relevant port environmental assessments (e.g. DP3-AMS) where unpredicted impacts took place in near- field areas outside of the far-field monitoring program objectives. For example, two impacts took place within the DP3 U-shaped perimeter-dike tidal flat considered to serve as an eelgrass crab nursery (SIR#12- 12,p5): 1) the spontaneous creation (hours) of two large sand-lobed drainage channels in response to a headwater leakage following perimeter dike completion which resulted in eelgrass loss (AMS, 2015); 2) the development of elevated topography, ponding water, benthic organic enrichment, water eutrophication (hypoxia/anoxia) and eelgrass decay behind a new tug-turning basin (AMS, 2015; Hemmera et al. 2013, 2014a-Appendix C). Although the original hydrodynamic and sediment transport model predictions revealed localized and near-field changes (deposition) along the south U-shaped DP3 perimeter dike, the DP3-AMS program was limited to a far-field sampling design in the inter-causeway region.

Table 1: A description of environmental monitoring programs associated with Roberts Bank terminal expansions. RBT2 Baseline Project DP3 Project DP3 U-shaped Basin (Hemmera et al. (Hemmera et al. 2014b) (Hemmera et al. 2015) 2014a; Appendix C) Timeframe 2015-2016 2007 - 2014 2007 (drainage channels) 2012 (eutrophication) Objectives Collect baseline data and  Provide advance warning for calibrate Roberts Bank negative trends; hydrodynamic, sediment, and  Mitigate negative trends ecological models associated with DP3 Local study area Spans Roberts Bank:  Stations limited to DP3  Dungeness crab nursery. intercauseway and northern intercauseway causeway regions.  2 reference stations at outer NW Roberts Bank Spatial design  Spatial design varies  Limited Far-field sampling  2007: New station DP3-9 located between (spatial) according to variable.  Quarterly: DP3-1, -2, -3, -4, -5, - sand-lobed drainage channels created in U-  Eutrophication variable: 6, -7; shaped perimeter dike (Fig 2). Water chemistry limited to 5  Annual: DP3-8, DP3-9. stations  DP3-9 initiated in 2007. Unanticipated  2007: Rapid formation (hours) of 2 sand- events lobed drainage channels due to head- water leak upon sealing of perimeter dike (Fig 3).

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 2007-2013: Change in tidal flat bathymetry between drainage-channel sand lobes and tug basin berm resulting in ponding water.  2013: Sediment organic enrichment, water eutrophication, hypoxia/anoxia, eelgrass loss. Conclusions/  No ecosystem-wide (far-field)  AMS monitoring of drainage channels to Mitigation eutrophication trends across record eelgrass recovery intercauseway LSA.  AMS: swale in tug basin berm created to  Changes in sediment eliminate ponded water and topography – ponds water eutrophication.  Near-field eutrophication event U-shaped perimeter dike behind tug basin

Review Panel Information Request #1: Provide a detailed description of the existing conditions relative to nutrient and organic matter enrichment and to the occurrence of anoxic events within the Marine Water Quality Study Area, including the area north of the existing causeway and the inter-causeway area of Roberts Bank.

DFO Evaluation of Proponent Response to #1:

The Proponent provides a good description of nutrient dynamics on Roberts Bank (RB). The Proponent states that “SOC and fine-sediments are naturally elevated in higher intertidal areas relative to lower intertidal areas on both sides of the Roberts Bank causeway”. The review of existing conditions is insufficient without the inclusion of anthropogenic impacts (e.g. original 1969 coalport causeway) to determine if RBT2 will accelerate or decelerate previous and ongoing causeway-derived alterations, which may appear to be established or “natural” during a pre- and post-comparison. For example, a significant change in tidal elevation and sediment texture was observed in the northern causeway-dike area relative to that of contiguous south-causeway stations between 1969 (Hemmera, 2004) and a 1997 sampling program (Sutherland et al. 2013; Figure 1). A difference in silt-distribution on either side of the coalport causeway was also observed by Swinbanks (1979) as early as 10 years after causeway construction. Sharp deviations observed in silt-clay-sand ratios along with significant increases in tidal elevation, sediment porosity, and organic accumulation provided a sensitive measure to distinguish between natural and anthropogenic process. In this scenario, natural erosion and sediment consolidation along the northern causeway could no longer keep up with Fraser River (FR) silt deposition (e.g. tidal elevation increased significantly providing an above average sedimentation rate over a 30 year period (1969–1997) following causeway construction). These high-porosity, gel-mud sediments were characterized by hypoxic/anoxic conditions and opportunistic polychaetes typically associated with sediment organic enrichment conditions.

Given the proposed shift from the existing L-shaped causeway-dike corner to a C-shaped RBT2 causeway- dike-terminal, the catchment potential of FR silt-laden plume will increase due to the extended barrier provided by the position and orientation of RBT2. Projections in tidal elevation and sediment texture should be made for the northern causeway-dike corner, since the Project is an extension of the original causeway which will also undergo an expansion.

The highest sediment pore-water sulfide concentrations (enrichment variables) are located in the

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 16 northern high-intertidal gel-mud region as well as the DP3 U-shaped perimeter dike (Figure 3) and are highly correlated with fine, porous sediments (Hemmera, 2014b: Appendix 9.6A). The potential influence of anoxic sediment organic enrichment events on water quality will rely on the 1) accumulation rate of sediment organic matter in quiescent hydrodynamic settings (high-intertidal zones) and 2) ponding of overlying water trapped within tidal flat bathymetric barriers that are not inundated regularly (e.g. DP3 eutrophication event behind tug basin in U-shaped perimeter dike; Hemmera, 2013; Appendix 9.6A- Appendix C).

Figure 1: Spatial trends in tidal elevation (A) and grain size distribution (B) on Roberts Bank. Grain size classifications from left to right include <63um,red; <125um; <150um; <180um; <212um; <250um; <300um; <355um; <425um; >425um (Sutherland et al. 2013).

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Figure 2: Locations of sampling stations on Roberts Bank (left); Ternary plots (right) showing sediment texture categorized by tidal elevation (A), sediment porosity (B); sediment organic content (C); and sediment chlorophyll concentration (D) (Sutherland et al. 2013).

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Figure 3: Spatial distribution of sediment pore-water sulfide concentrations (mg kg-1) across Roberts Bank. The highest value is equivalent to 500 uM (Hemmera, 2014b: Appendix 9.6A).

Review Panel Information Request #2: Provide an explanation for how the potential change in distribution of organic-rich sediments due to the proposed Project may affect water quality at localized or larger scales within the Marine Water Quality Study Area.

DFO Evaluation of Proponent Response #2:

The Proponent states “However, given that the area is in the lower intertidal zone (approximately less than 1-m CD and is frequently inundated and exposed to tidal currents, the potential for deposition of organic-rich fine sediments, which have a low bed-shear stress threshold for mobilization, is considered to be unlikely”. In order to take a precautionary approach, it is important to assess the uncertainty around this statement and consider other relevant local environmental factors (e.g. sediment cohesion, wave shadow effects, biofilm adhesion, eelgrass influence on sediment stability, differential sediment/organic transport, and unforeseen events) that may promote sediment deposition, accumulation, and organic enrichment. These factors are described in the following paragraphs.

2.1) Considerations of factors promoting the accumulation of organic-rich fine sediments

Fine sediment cohesion: As part of the sediment transport model, the Proponent applied a “critical shear stress (resuspension threshold) for the initiation of grain motion for loose sand (diameter=0.1mm)” and ignored “the potential cohesive effects of biofilm or the presence of clay fraction in the sediment mixture” (EIS-Appendix 9.5A; Table 1). The absence of cohesive (silt/clay sediment) and adhesive (biofilm-laden

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 19 sediments) factors within sediment transport predictions will underestimate sediment accumulation in areas that have greater hydrodynamic energy (Amos, 2015). The spatial distribution of existing cohesive sediments (defined as having >10-20% silt/clay; <63um) within the Project vicinity and across the northern RB tidal flat, suggest that those areas of the tidal flat may be behaving in a cohesive manner (EIS-Appendix 9.6A Figures D1, D3). Cohesive sediments yield strength and may not follow the Proponent’s concept of a “low bed-shear stress threshold for mobilization of fine sediments” that is restricted to non-cohesive sandy sediments (Shield’s curve). Thus, the application of the Proponent’s low critical bed-shear stress value (0.12 Pa; fine sand: diameter=100µm) will over estimate sediment transport for larger sand grains and under predict the accumulation of cohesive and/or biofilm-laden silt (EIS-Appendix 9.5A; Table 1). Locally-derived critical bed-shear stress values for fine sediment have been observed between 0.2 – 0.3 Pa on Sturgeon Bank within the LSA (Amos et al. 1997). In addition, bed-shear stress plots show an increase in depositional contours (green/blue) for post-Project RB conditions (EIS-Appendix 9.5A; Figures 11 and 12 below). Further, the Proponent’s predicted removal of deposited sediments over several tidal inundations in the “elbow” depositional zone (EIS-Appendix 9.5A; Figure 11) may be challenging with 1) converging tidal elevation contours (-1, 0, 1m) reflecting various inundation levels and bed-shear stress values and 2) a drainage channel that will supply the “elbow” with a cohesive silt/clay source from the upper silt-laden intertidal flats (EIS-Appendix 9.5A; Figure 18).

Wave shadow effects: The exterior margin of the wave shadow that runs between the existing terminal and Brunswick Point (EIS-Appendix 9.5A; Figure 82) aligns reasonably well with a 4-um clay contour representing approximately 4-6% clay composition (EIS-Appendix-9.6A; Figure 14). This interaction suggests that wave energy has some influence on clay deposition and accumulation, which allows for the accumulation of cohesive sediments within the vicinity of the Project and is not restricted to the fine-silt, high-intertidal area of RB (EIS-Appendix 9.6A; Figure 14 (4um); D1 (4um); D3 (4-63um)). These observations also suggest that the low intertidal zone is not uniformly non-cohesive (sand) and scoured within the wind-driven wave (< 1.5m CD) and tidally-driven <1m CD thresholds. Importantly, the linkage between wave shadow distribution and clay content also suggests that this 4-um cohesive clay contour may expand westward under conditions of a wider wave-shadow exterior margin predicted to occur as a result of the Project (EIS-Appendix 9.5A; Figures 82 & 83 below).

Biofilm adhesion of sediments: Microbial and diatom biofilms are ubiquitous across tidal flats such that it is difficult to find sediments that are void of bacteria or diatoms at some level of biofilm formation. Biofilms are known to stabilize sediments though mucous production that fills sediment voids (pore- spaces), increases sediment adhesion and forms a biofilm sediment skin and microfabric (Sutherland et al. 1998b). Consequently, the sediment erosion criteria is altered through a reduction in surface drag (friction) by the mucous biofilm and a consequent decrease in resuspension thresholds and erosion rates (Sutherland et al. 1998a). While biofilms tend to proliferate in cohesive sediments, they can also influence erodibility of non-cohesive sand.

Eelgrass influence on sediment stability and organic accumulation: Eelgrass meadows are known to baffle current and wave action, increase organic deposition, and promote reducing redox conditions (Heiss et al. 2000; Gacia et al. 2003; Carr et al. 2010). Further, seasonal decomposition of eelgrass supplies a strong organic pulse to depositional zones that can fuel microbial respiration and lead to nutrient changes and hypoxic conditions (Fenchel and Jorgensen, 1977; Kistritz et al. 1983; Vadas and Beal, 1987). An eelgrass meadow (EIS-Appendix 9.5A; Figure 18) is located within the 1m CD bathymetry tidal exchange zone (EIS-Appendix 9.5A; Figure 12) and the depositional Project “elbow” area. Eelgrass may minimize the

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<1m CD tidal exchange energy that the Proponent suggests will remove the deposited “elbow” sediments and altering the bed-shear stress values due to the disruption of water flow by eelgrass blades. Therefore, the potential exists for the “elbow” deposits to be more sheltered, stable, and retain higher organic-silt concentrations during tidal exchange than predicted.

Differential settlement, accumulation, and transport of sediment and organic material: It is important to differentiate between the transport of sediment and organic material given that they differ widely in size, shape, and most importantly density. Instead of focusing solely on the transport of organic-rich sediments in total, we typically examine organic accumulation and/or enrichment within recently deposited sediments as a phased process. Organic-rich sediments can develop through biofilm development and/or eutrophication from microbial demands associated with a high organic input (e.g. strong seasonal input of degraded algae-eelgrass detrital “ropes” in autumn (Vadas and Beal, 1987). The latter two examples may meet the requirement for organic-rich sediment transport depending on the stage of organic enrichment or biofilm adhesive stage. Within the context of potential Project-related effects, organic enrichment of deposited sediments may experience a strong seasonal input or a lag in development over time.

Unforeseen events: Given the impact of an unanticipated rise in tidal elevation (DP3 tug-turning berm construction) on water ponding, epiphytic growth, eelgrass decay, and eutrophication conditions, one might anticipate a similar situation regarding 1) the raised tidal flat elevation required to support dike- construction needs; and 2) further accumulation of fine sediments and organic matter associated with these conditions around the Project perimeter dike, especially that of the depositional “elbow zone”.

2.2) Influence of organic-rich sediments on water quality:

The Proponent’s response to the influence of organic-rich sediments on water quality states that changes in sediment accumulation and organic enrichment are unlikely. In keeping with the precautionary approach, the Proponent should anticipate eutrophication/anoxia associated with 1) increases in tidal- elevation promoted by Project perimeter dike/berm construction that may decrease water drainage within the sheltered “elbow” zone (e.g. lessons learned from DP3 construction of tug-turning berm increased tidal elevation, water ponding, and subsequent eutrophication); and 2) other significant water drainage areas that may be cutoff, redirected, or experience suppressed water flow by the Project that will promote silt accumulation and organic matter enrichment (e.g. northern causeway-dike corner, wave- shadow zone, “mumblies” zone (ridge and runnel complex)). For example, a visible drainage channel that runs parallel to the causeway and through an eelgrass meadow before intersecting the Project footprint may have its drainage flow altered (decreased), while receiving a continual silt source from the high intertidal zone and organic matter from the eelgrass bed (EIS-Appendix 9.6A; Figure 9A; EIS-Appendix 9.5A; Figure 18).

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Review Panel Information Request #3: Provide a discussion on the potential environmental effects that could change water quality and lead to anoxic conditions for the environmental components assessed in the EIS and, clarify whether the potential for organic enrichment was considered in the design and evaluation of the proposed offsetting habitat concepts for the Project.

DFO Evaluation of Proponent Response #3:

The Proponent states that “Project-related environmental effects on water quality and DO levels that could lead to anoxic conditions are considered unlikely”. The Proponent should review points in question #2 that present information that sediment deposition, accumulation, and organic enrichment may be more likely in quiescent areas where cohesive behaviour (silt/clay), adhesion factors (biofilms), and eelgrass stability are considered.

Extracted from DFO’s evaluation of the Proponent’s response to Question #2: The Proponent’s response

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 24 to the influence of organic-rich sediments on water quality states that changes in sediment accumulation and organic enrichment are unlikely. In keeping with the precautionary approach, the Proponent should anticipate eutrophication/anoxia associated with 1) increases in tidal-elevation promoted by Project perimeter dike/berm construction that may influence water drainage within the sheltered “elbow” zone (e.g. DP3 construction of tug-turning berm increased tidal elevation, water ponding, and subsequent eutrophication event); and 2) other significant water drainage areas that may be cutoff, redirected, or experience suppressed water flow by the Project that will promote silt accumulation and organic matter enrichment (e.g. northern causeway-dike corner, wave-shadow zone, “mumblies” zone (ridge and runnel complex)). For example, a visible drainage channel that runs parallel to the causeway and through an eelgrass meadow before intersecting the Project footprint may have its drainage flow altered (decreased), while receiving a continual silt source from the high intertidal zone and organic matter from the eelgrass bed (EIS-Appendix 9.6A; Figure 9A; EIS-Appendix 9.5A; Figure 18).

These potential scenarios should be identified and considered in the design and evaluation of the proposed offsetting habitat concepts for the Project.

Review Panel Information Request #4: Provide a description of the specific measure that would be included as part of the follow-up program to verify organic enrichment conditions and applicable mitigation measures in the event that organic enrichment is identified as a result of the Project placement.

DFO Evaluation of Proponent Response #4:

The Proponent states that “In the case of organic enrichment, the VFPA is confident in the prediction that the Project will not introduce additional sources of nutrient or organic matter to the LSA and the occurrence of large-scale anoxic events and eutrophication with or without the Project is extremely unlikely“. The RBT2 Follow-up program (FUP) should be required to track ongoing causeway-induced changes to the northern RB causeway-dike margins. The Project itself should be considered a curved extension of the original causeway-terminal where proposed Project changes may accelerate or decelerate the existing long-term, ongoing benthic alteration. For example, this area shows significant deviations from normal sedimentation rates, sediment texture, and organic enrichment levels for RB or other tidal flats in British Columbia. While “the Project will not introduce additional sources of nutrients or organic matter to the LSA”, it may be responsible for an increase in secondary production (enrichment) of nutrients and organic matter following seabed or water-flow alterations (see question #1). In addition, the unforeseen near-field and localized eutrophication impact to DP3 (see preamble) creates uncertainty in this “unlikely” prediction.

The Proponent should resist referring to impacts as a large-scale target where habitat alterations may be irreversible at this bank-wide spatial scale. Alternately, the Proponent’s compliance monitoring should focus on regional-scales defined by tidal-flat provinces classified as sensitive, critical, or similar characteristics [e.g. biofilm zone, “mumblies (ridge and runnel complex)”, gel-mud depositional zone, etc.]. The latter approach will increase the ability to detect “change” as it will not be referenced against LSA-wide variation spanning 3 distinct and diverse tidal banks (Sturgeon Bank, Roberts Bank, and Boundary Bay) that are influenced by different environmental pressures and anthropogenic inputs.

The study design of the compliance monitoring program should include various spatial and temporal scales specific to 1) both near- and far-field scales; 2) sensitive and critical habitats (e.g. eelgrass habitats, Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 25

Dungeness crab nursery); 3) sedimentary provinces; 4) predicted zones of deposition; 5) drainage channels, etc.). While the spatial frequency associated with the instrument-based survey of physical water properties across the LSA is high (EIS-Appendix 9.6A; Figures 34-35), the spatial frequency of water chemistry (quality) sampling (dissolved nutrients, particulate matter, etc.) on Roberts Bank (EIS-Appendix 9.6A; Figure 36) is very limited and would not be sufficient for assessing near-field, regional, or large-scale effects.

REFERENCES

Amos, C.L., Feeney, T., Sutherland, T.F. and Luternauer, J.L., 1997. The stability of fine-grained sediments from the Fraser River delta. Estuarine, Coastal and Shelf Science 45, 507-524.

Amos, C.L. 2015. Evaluation of sediment modelling for Roberts Bank Terminal 2 EIS. Prepared by Professor C.L. Amos for Dr. T.F. Sutherland (Fisheries and Oceans Canada), November, 2015. pp. 13.

AMS, 2006. Delta Third Berth Project Adaptive Management Strategy. https://www.portvancouver.com/wp- content/uploads/2015/03/Final_Deltaport_Adaptive_Mgmt_Strategy_April_2006.pdf. Accessed on December 16, 2016.

AMS, 2015. Deltaport Third Berth Adaptive Management Strategy Summary. https://www.portvancouver.com/wp-content/uploads/2015/10/2015-01- 25_ReportSummary_Adaptive-Management-Strategy.pdf. Accessed on December 16, 2018.

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Hemmera, 2004. History of Development at Roberts Bank – An Overview. Prepared by Hemmera for the Vancouver Port Authority, November 2004. pp. 36. http://www.robertsbankterminal2.com/wp- content/uploads/A-History-of-Development-at-Roberts-Bank-An-Overview-2004.pdf.

Hemmera, 2013. Deltaport Third Berth Adaptive Management Strategy 2012 Annual Report. Prepared by Hemmera, NHC, and Precision for Vancouver Fraser Port Authority, August, 2013, pp. 344. https://www.portvancouver.com/wp-content/uploads/2015/03/ams-2012-annual-report.pdf. Accessed on December 16, 2018.

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 26

Hemmera, 2014a. Deltaport Third Berth Adaptive Management Strategy 2013 Annual Report. Appendix C: Eelgrass loss Investigation Behind Tug Basin Report, pp. 248-279. Prepared by Hemmera, NHC, and Precision for Vancouver Fraser Port Authority, April, 2014, pp. 421. https://www.portvancouver.com/wp- content/uploads/2015/03/ams-2013-annual-report.pdf. Accessed on December 16, 2018.

Hemmera, 2014b. Roberts Bank Terminal 2 Technical Data Report: Sediment and water quality characterization studies – Appendix 9.6A. Prepared by Hemmera for Port Metro Vancouver, August, 2014, pp. 212.

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Sutherland, T.F., R.W. Elner, J.D. O’Neill. 2013. Roberts Bank: Ecological crucible of the Fraser River estuary. Progress in Oceanography, 115: 171 – 180.

Swinbanks, D.D. 1979. Environmental factors controlling floral zonation and the distribution of burrowing and tube-dwelling organisms on Fraser River delta tidal flats, British Columbia. PhD. Thesis, University of British Columbia, Vancouver, 274 pp.

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Webb, D.G. 1991. Impact of predation-disturbance by large epifauna on sediment-dwelling harpacticoid copeods: field experiments in a subtidal seagrass bed. Marine Biology, 109: 485-491.

Fisheries and Oceans Canada’s Response to the Review Panel’s December 4, 2018 Letter for the Roberts Bank Terminal 2 Project Page 27