Letter of Comment(A62643) Hearing Information Comments
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Letter of Comment(A62643) Name: Ms. Hannon, Susan Title: Group: Your Application to Participate (ATP): A56868 filed on 2014-02-02 Letter of Comment Filing Date: 2014-09-04 Hearing Information Project Name: Trans Mountain Pipeline Expansion Project Company: Trans Mountain Pipeline ULC File Number: OF-Fac-Oil-T260-2013-03 02 Hearing Order: OH-001-2014 Comments Views on project: I believe that the Board should reject the proposal because of the potential harm to marine ecosystems. I am concerned about the potential effects of oil spills and on the possible sublethal and cumulative effects of slower oil leakage on shorebirds and waterbirds. In addition, increased tanker traffic through the Salish Sea and connected straights will cause more disturbance to birds. These areas are major wintering sites for thousands of ducks, loons, grebes, swans and other waterbirds from inland areas of Canada and are breeding areas for many resident bird species (cormorants, herons, gulls, including some SARA listed species (e.g. marbled murrelet). Expertise: BSc (1974) Marine Biology, University of Guelph MSc (1978) Ecology, University of Alberta PhD (1984), Avian ecology, University of British Columbia Professor (1984-2009), Ecology, University of Alberta, currently Emeritus Professor Over 35 years of experience doing research on populations of birds, 25 years of teaching ecology and conservation biology at a major university. I'm an active birdwatcher and wildlife conservationist. I am currently a resident of Salt Spring Island, who moved here in order to enjoy the wildlife, ocean and beaches. Importance of the Salish Sea to marine birds The Salish Sea contains more than 20 globally significant “Important Bird Areas” (IBA's) that support more than 1% of the world’s population of 25 species at some point in their life cycle. These sites are designated by Birdlife International as globally significant habitat for conservation of bird populations. Seventy-two bird 444 Seventh Avenue SW Telephone/Téléphone : (403) 292-4800 Calgary, Alberta T2P 0X8 Facsimile/Télécopieur : (403) 292-5503 http://www..neb-one.gc.ca 444, Septième Avenue S.-O. 1-800-899-1265 Calgary (Alberta) T2P 0X8 1 and 29 mammal species depend on the Salish Sea’s intertidal (mudflats, salt marshes, eel grass beds) and marine habitats (Gaydos and Pearson 2011) for significant periods of their life cycles. The tanker route for the Kinder Morgan trans Mountain Pipeline passes within a few kilometres of six of these IBA’s (Fig 1). This commentary focusses on the birdlife in these six areas. Information was obtained from the Canadian IBA website. As tankers leave the Westridge Marine terminal in Burnaby BC, they pass through Burrard Inlet, site of the Burrard Inlet Important Bird Area (Fig. 1). This area protects globally important populations of Western Grebe, Barrow's Goldeneye and Surf Scoter and nationally important habitat for the Great Blue Heron. The grebes and ducks were historically found spending the winter here in the thousands, though now their populations have dwindled. The Great Blue Heron (faninni subspecies; listed under the federal Species at Risk Act as Special Concern) feeds along the shores of English Bay and Burrard Inlet. Ospreys, Cormorants and Bald eagles nest and feed in the area. As the tankers turn south and move through the Strait of Georgia they pass the alongside the Fraser River Estuary, where the Boundary Bay, Roberts Bank, Sturgeon Bank and Fraser River Estuary IBA is located (Fig 1). This IBA is a major stopover for migrating shorebirds, waterfowl and raptors of the Pacific Flyway. Millions of birds migrating from as far away as South America land on the mudflats and marshes of the Fraser River estuary in spring to feed on their route north to their breeding grounds. The reverse happens in the fall. Some species spend the entire winter in the estuary. This IBA supports globally or continentally significant populations of American Wigeon, Northern Pintail, Mallard, Brant, Snow Goose, Trumpeter Swan, Western Sandpiper, Black-bellied Plover, Dunlin, Great Blue Heron, Western Grebe, Red-necked Grebe, Glaucous-winged Gull, Thayer's Gull, and Mew Gull. Over 50 species of shorebirds have been found here and as many as 500,000 Western Sandpiper and 100,000 Dunlin have been counted here in one day. Nationally significant numbers of Barn Owl and Peregrine Falcon also occur here. The surrounding agricultural lands and forest patches provide important breeding and roosting habitat for herons and bald eagles. Tankers will then move further south within 20 km of Porlier Pass IBA. Porlier Pass is the channel between the southern end of Valdes Island and the northern end of Galiano Island. Similar to Active Pass (see below) strong tides pass through a narrow opening between the islands. The strong currents cause upwellings, where nutrients are brought up from the bottom, creating a highly productive area for plankton and fish, and further up the food chain, for fish-eating birds. Large concentrations of Mew Gulls and thousands of Brandt’s, Double-crested and Pelagic cormorants feed here, especially in winter. In addition waterfowl, loons, grebes, gulls and alcids feed in the area and there is a breeding colony of Glaucous-winged Gulls and American Black Oystercatchers on the east coast of Valdes Island. Active Pass IBA (Fig 1) is also an area of strong tidal action and upwellings located between Galiano and Mayne Islands. It is a highly productive feeding area for fish-eating birds during the spring, fall, and winter. It supports “nationally, continentally or globally significant populations of Pacific Loon and Brandt's Cormorant (in winter), and Bonaparte's Gull (on migration). The 2,000 Pacific Loons that regularly occur at the pass during winter comprise the largest concentration in the Strait of Georgia. In addition, about 4,000 wintering Brandt's Cormorants have been recorded here. Bonaparte's Gulls pass through in large numbers, with about 10,000 recorded during fall migration, and daily maximum counts of between 7,000 and 15,000 birds recorded during spring migration. Several pairs of Bald Eagles nest along the shores of the pass, and upwards of 100 eagles occasionally forage in the waters during the winter.” (IBA website). 444 Seventh Avenue SW Telephone/Téléphone : (403) 292-4800 Calgary, Alberta T2P 0X8 Facsimile/Télécopieur : (403) 292-5503 http://www..neb-one.gc.ca 444, Septième Avenue S.-O. 1-800-899-1265 Calgary (Alberta) T2P 0X8 2 The fifth IBA that the tankers will pass close to is Sidney Channel (Fig 1). This channel lies between James Island and Sidney Island. The area is underlain by sand where sandlance breed, attracting large numbers of fish-eating birds during spring and summer, including the nationally threatened Marbled Murrelets, auklets, cormorants, gulls, Great-blue herons and shorebirds. The area provides important wintering area for sea ducks and supports significant populations of migrating grebes, loons, brants and shorebirds during spring migration and large numbers of Brandt’s Cormorants during fall migration. Black Oystercatchers (about 2% of the estimated national population) nest on islets in the area. As the tankers turn south west they pass Chain Islets and Great Chain Island, just off Oak Bay in the Juan de Fuca Strait. These island IBA’s support globally significant breeding colony of Glaucous-winged Gulls (over 1% of the North American population) and a migratory population of Brandt's Cormorants (over 2% of the estimated world population). Pigeon Guillemots and American Black Oystercatchers also nest on the islets. Ecological and economic implications of an oil spill along the tanker route in the Salish Sea Given the millions of seabirds found in the Salish Sea throughout the year, representing 1-2% of the global populations for several species, an oil spill would be catastrophic. Oil-coated seabirds have high mortality rates even when rescue efforts are attempted. Canada and British Columbia have a responsibility to protect the habitats of these bird species, some of which are listed by the Species at Risk Act and by the BC Wildlife Act. Migratory birds are protected by the federal Migratory Bird Protection Act. In addition to the ecological implications, bird watching brings in a considerable amount of money to the BC economy. Raincoast Conservation Foundation estimated that bird watching in the Salish Sea generates over $342 million and a total economic output of close to $900 million, supporting over 5,000 regional jobs. Part of my enjoyment in this region is to walk along the ocean birdwatching, wildlife viewing (e.g. whale- watching) and kyaking. I engage in birdwatching weekly, whale watching annually and kyaking in the summer bimonthly. All of these recreational activities would be negatively affected in the event of an oil spill. I am also concerned about the livelihoods of members of my community who engage in fishing and outdoor adventure guiding. References Devenish, C., D.F. Diaz Fernandez, R.P. Clay, I. Davidson and I.Yepez Zabala. (eds.) 2009. Important Bird Areas Americas – Priority sites for biodiversity conservation. BirdLife Conservation Series No. 16. BirdLife International, Quito, Ecuador. Gaydos, J.K. and S.F. Pearson. 2011. Birds and mammals that depend on the Salish Sea: a compilation. Northwestern Naturalist 92:79-94. Attachments 444 Seventh Avenue SW Telephone/Téléphone : (403) 292-4800 Calgary, Alberta T2P 0X8 Facsimile/Télécopieur : (403) 292-5503 http://www..neb-one.gc.ca 444, Septième Avenue S.-O. 1-800-899-1265 Calgary (Alberta) T2P 0X8 3 Document Name Document Type Size transmountain tanker route and IBA's final Map 127.07 KB 444 Seventh Avenue SW Telephone/Téléphone : (403) 292-4800 Calgary, Alberta T2P 0X8 Facsimile/Télécopieur : (403) 292-5503 http://www..neb-one.gc.ca 444, Septième Avenue S.-O. 1-800-899-1265 Calgary (Alberta) T2P 0X8 4.