February 8, 2019 Submitted via email and U.S. Mail Roberts Bank Terminal 2 Project Secretariat Canadian Environmental Assessment Agency 160 Elgin Street, 22nd Floor Ottawa, ON K1A 0H3 CANADA
[email protected] Re: Swinomish Indian Tribal Community, Suquamish Tribe, and Tulalip Tribes (“U.S. Tribes”): Further Comments on Sufficiency of Information Greetings: Earthjustice jointly represents the Swinomish Indian Tribal Community, Suquamish Tribe, and Tulalip Tribes (“U.S. Tribes”) in the Canadian Environmental Assessment Agency’s environmental assessment of the proposed Roberts Bank Terminal 2 Project. We submit these comments in response to the Panel’s December 4, 2018 request for comments on the sufficiency of the information prepared by the proponent, the Vancouver Fraser Port Authority (“VFPA”) regarding Information Request packages 7 through 13. As explained more fully below and in comments previously submitted by the individual U.S. Tribes, the information needed to fully and fairly review the Project remains incomplete; Information Request packages 7 through 13 continue to neglect the U.S. Tribes presence and their concerns as they relate to this Project.1 1 See, e.g., IR7-31 (U.S. Tribes view not represented on Marine Biophysical Components – Mitigation Measures/Offsetting); Appendix IR10-01-C3, Semiahmoo First Nation: Issues, Views, and Concerns Related to the Porposed Project and Marine Shipping Associated with the Project, Table 10: Marine Fish – Valued Component, at pg. 17 (local assessment area does not extend across the U.S. border); IR13-25 (did not consult with U.S. Tribes on Current Use of Lands and Resources for Traditional Purposes – Quality of Current Use Experience, Cumulative Effects Assessment).