Vancouver Fraser Port Aut11or1ty M,~\ PORTof 100 The Pointe, 999 Canada Place Vancouver, B.C. Canada V6C 3T4 '-f1 vancouver portvancouver.com May 8, 2019 Jocelyne Beaudet Panel Chair, Roberts Bank Terminal 2 Project C/O Cindy Parker, Panel Manager, Roberts Bank Terminal 2 Project Canadian Environmental Assessment Agency 22nd Floor, Place Bell, 160 Elgin Street Ottawa, ON KlA 0H3 Dear Mme. Beaudet, RE: Response to Biofilm and Shorebirds Component (Chapters 4.1, 5.4, and related appendices) of Environment and Climate Change Canada Submission (CEAR Document #1637) The Vancouver Fraser Port Authority (VFPA) is submitting to the Review Panel a response to the biofilm and shorebird component of Environment and Climate Change Canada's (ECCC's) April 15, 2019 written submission (CEAR Document #1637). The VFPA's intent in providing this response is to support further dialogue at the public hearing. Note that this response is specific to the biofilm and shorebirds component of ECCC's submission (Chapters 4.1, 5.4, and related appendices). We are also providing a copy of this letter and the enclosed response to ECCC. The VFPA acknowledges all comments provided by ECCC in their April 15, 2019 written submission on other topics, including air quality, species at risk, lighting, wetlands, and accidents and malfunctions. The VFPA has reviewed these comments in full and looks forward to further discussion at the public hearing on all topics raised in ECCC's written submission. Per the Public Hearing Procedures for the Roberts Bank Terminal 2 Project, CVs for each contributor to this submission are also provided. <Original signed by> Cliff Stewart, P.Eng., ICD.D Vice President, Infrastructure cc Cindy Parker, Panel Manager, Roberts Bank Terminal 2 Project Douw Steyn, Panel Member David Levy, Panel Member Alli Morrison, BC Environmental Assessment Office Robyn McLean, Environment and Climate Change Canada Encl. (1) 1. VFPA Response to Biofilm and Shorebirds Component (Chapters 4.1, 5.4, and related appendices) of Environment and Climate Change Canada Submission (CEAR Document #1637) 2. CVs for Wendell Challenger, Mary-Lou Lauria, James Rourke, and Ronald Ydenberg Canada Response to Biofilm and Shorebirds Component (Chapters 4.1, 5.4, and related appendices) of Environment and Climate Change Canada Submission (CEAR Document #1637) 1.0 Introduction In their April 15, 2019 submission (CEAR Document #1637 1), Environment and Climate Change Canada (ECCC) conclude (p.35) that “the data and analyses in the Proponent’s technical reports do not support the Proponent’s conclusions that the Project would not affect the quantity or quality of food available to migratory Western Sandpipers and other shorebirds.” The VFPA respectfully disagrees and provides this written response for clarification. In this document numerous mischaracterisations, errors, selective and mis-citation of relevant literature, as well as inconsistencies in ECCC’s response are detailed. The following assertions about the EIS and additional work outlined in Panel information requests made by ECCC are addressed: Project changes to physical processes influencing salinity; The potential for the existence of a salinity trigger influencing fatty acid production in biofilm; The assertion that biofilm at Roberts Bank will shift from a marine to a freshwater type diatom community; Fatty acid availability; The assertion that the biofilm community will ‘shift’ to lower tidal elevations; The association between western sandpiper usage and Fraser River discharge; and The ability to restore or enhance mudflats to better support biofilm. In Appendix A, a detailed listing of specific erroneous statements are provided, along with responses to each. 2.0 Project Changes to Physical Processes Influencing Salinity ECCC asserts (p.30) that “Predicted Project effects include a lowering in salinity and an increase of the entrainment time of freshwater from the Fraser River during the spring breeding migration of Western Sandpipers (EIS, Appendix 9.5-A). The entrainment of freshwater would restrict tidal flushing and create a more protracted decrease in salinity conditions over Roberts Bank, and may dampen daily oscillations. Such conditions would fall outside the variability of the current system (i.e. tides, light and temperature) and are not 1 CEAR Document #1637 From Environment and Climate Change Canada to the Review Panel re: Written Submission for the Roberts Bank Terminal 2 Public Hearing (Note: Updated May 1, 2019). Roberts Bank Terminal 2 VFPA Response to ECCC’s April 15, 2019 Posting (CEAR Document #1637) | Page 1 representative of current salinity regimes on any of Canoe Passage, Brunswick Point or Roberts Bank situations.” This seriously mischaracterises the EIS. The Project is not predicted to change any of the fundamental physical processes (tidal currents, waves, sediment transport) that created and maintain the upper intertidal area of Roberts Bank where biofilm is found. The Project is expected to change the distribution of freshwater within the upper intertidal area during tidal cycles, because the direction of tidal currents will divert some of the freshwater emanating from Canoe Passage over areas of the intertidal that presently receive this freshwater less frequently. The Project will not change the overall range of salinity experienced at Roberts Bank, much of which encounters the full range of salinity on every tidal cycle (twice daily), from the minimum defined by freshwater from the Fraser River to the maximum salinity defined by the salinity in the Strait of Georgia (e.g., 0 to 30 practical salinity units (PSU). The Project will not change the tidal oscillations in the Strait of Georgia that govern the exchange of water on and off the tidal flats of Roberts Bank, and therefore there will be no change to residence time of water, no retention of water over the tidal flats, and no damping of tidal height. The net result can best be described as a slight change in the distribution of marine and freshwater over Roberts Bank in Canoe Passage and the upper intertidal biofilm areas during the spring freshet (i.e., mean change of < 1 PSU (±1.9 SD) to 3.5 PSU (EIS Section 11.6.3.5, EIS Table 11-19, and updated in IR8-02 of CEAR Document #934 2)). There will be a decrease in the 50 th -percentile salinity (i.e., the level dividing the frequency distribution of all salinity measurements at any location in half) along the north side of the Roberts Bank causeway, extending 2 km to 3 km laterally, and an increase in 50 th -percentile salinity over the outer tidal flats between the most seaward extent of Canoe Passage and the Project. The figures show the predicted 50 th percent salinity changes with the Project (originally presented in EIS Section 9.7). EIS Figure 9.7-9 (reproduced below) shows that the change is greatest during the freshet months of May through July, and EIS Figure 9.7-10 (reproduced below) shows that the change is smaller during the non-freshet months of October through to December. These seasons are chosen to represent the extremes—other times lie in between. A comparison of EIS Figure 9.7-9 with EIS Figure 9.7-10 shows that the difference is smaller in terms of absolute values in the non-freshet period, and the affected area is also smaller. 2 CEAR Document #934 From the Vancouver Fraser Port Authority to the Review Panel re: Compilation of the Review Panel's Information Requests and the Vancouver Fraser Port Authority's Responses (NOTE: Updated February 15, 2019). Roberts Bank Terminal 2 VFPA Response to ECCC’s April 15, 2019 Posting (CEAR Document #1637) | Page 2 3.0 No Evidence for a Salinity Trigger Influencing Fatty Acid Production in Biofilm ECCC asserts (p.32; see also p.68) that “ECCC finds that the Project would disrupt or remove the salinity trigger for initiating fatty acid production in biofilm on Roberts Bank (see Appendix 7).” Roberts Bank Terminal 2 VFPA Response to ECCC’s April 15, 2019 Posting (CEAR Document #1637) | Page 3 ECCC claims that there is a “salinity trigger” that causes diatoms to produce fatty acids. While we agree that salinity is one of many environmental variables that can influence phytoplankton growth (productivity) and fatty acid production, there is no field or published evidence to suggest there is a salinity ‘trigger’ existing under natural conditions at Roberts Bank or elsewhere. The literature cited by ECCC (p.68; Schwenk et al. 2013, Pal et al. 2013) to substantiate a salinity trigger theory in fact proves the contrary. Pal et al. (2013) created a ‘shock’ to diatoms under laboratory conditions, by transferring algal cultures from artificial seawater (ASW) into a sodium chloride-free medium (freshwater), under varying light conditions. Nitrate became depleted (after about 4-5 days) which marked a transition to the stationary phase period (when growth rate is no longer exponential). Their experiment revealed that “shifting the cells from ASW to freshwater media did not cause cell rupture or a prolonged lag in cell divisions or biomass production; in fact, the biomass productivity increased in SFM (freshwater media)”. Pal et al. (2013) also state “planktonic microalgae frequently encounter widely varying mixtures of fresh and salt water during the tidal cycle in coastal waters and estuaries. The microalgae from such environments possess rapidly responding mechanisms that allow their cell walls to swell without rupturing under hypotonic conditions and prevent water loss at increased salinities. The need to cope with fluctuations