Skeena Watershed Conservation Coalition P.O. Box 70 Hazelton, B.C. V0J 1Y0 www.skeenawatershed.com 250.842.2494 March 10, 2014 Canadian Environmental Assessment Agency 410-701 Georgia Street West Vancouver, BC V7Y 1C6 Via email: [email protected] Honourable Catherine McKenna Minster of Environment and Climate Change Via email: [email protected] Honorable Hunter Tootoo Minister of Fisheries, Oceans and the Canadian Coast Guard Ottawa, Ontario <Original signed by> Via email: [email protected]. Honourable James Carr, Minister of Natural Resources Via email: [email protected] Pacific Northwest LNG Project – Public Comments re CEAA draft Environmental Assessment Report From: Skeena Watershed Conservation Coalition CEAA Reference: 80032 1.0 Introduction 1.1 Skeena Watershed Conservation Coalition Skeena Watershed Conservation Coalition (SWCC) is a diverse group of people living and working in the Skeena River watershed. Our board of directors and membership reflect the broad interests of the people in this region. We are united in understanding that short term industrial development plans, even 50 year plans, will not benefit our region in the long run if they undermine the social and environmental fabric that holds the watershed and its communities together. SWCC’s mission is to cultivate a sustainable future from a sustainable environment rooted in culture and a wild salmon ecosystem. Objectives and strategies arising from this 1 mission include educating the public and decision-makers in order to increase awareness and understanding of the natural ecological and human assets that currently exist, as well as helping to create a vibrant and resilient future for the Skeena watershed. SWCC has previously reviewed the Pacific NorthWest LNG (PNW LNG) Project Application/Environmental Impact Statement (Application/EIS) which describes the project and the potential environmental, social, economic, cultural, and health-related effects of all phases of the project under contract with a CEAA Contribution Agreement. Those comments were delivered to CEAA on May 1, 2014. The following written comments are in regard to the review of the CEAA draft Environmental Assessment report dated February 2016. As there were major conceptual changes to the proposed PNW LNG project, and subsequently, supplemental information to review, SWCC contracted dr. Marvin Rosenau to conduct a review of the project pier, berth, and jetty, and as such, his review is appended to this submission. 1.2 Pacific NorthWest LNG Project Pacific NorthWest LNG Ltd. proposes to construct and operate a liquefied natural gas (LNG) facility and marine terminal near Prince Rupert, within the district of Port Edward. The Pacific NorthWest LNG facility would be located on Lelu Island. The proposed project would convert natural gas to LNG for export to Pacific Rim markets in Asia. The Pacific NorthWest LNG Project is subject to review under both the Canadian Environmental Assessment Act, 2012 (CEAA 2012) and B.C.'s Environmental Assessment Act and as such, has undergone a joint environmental assessment process. 1.3 SWCC’s Previous EIS Comment Summary― May 1, 2014 SWCC’s assessment of the PNW LNG Project Application/EIS found an inadequacy and insufficiency of baseline data as set out in the EIS Guidelines and Application Information Requirements, particularly in regard to Sections 1, 2, 13, 15, and 19. Adequate and sufficient baseline data are critical to the environmental assessment process due to the required subsequent effects assessment and cumulative effects – both of which revolve around and depend on complete and sufficient baseline data. The lack of adequate baseline data has led to faulty conclusions regarding the effects assessment, the cumulative effects assessment, predicted residual effects, and the conclusions in regard to the Valued Components. Much of the effects assessment is based on professional opinion and does not reflect adequate science and guiding federal policies such as the precautionary principle. The quality of science in the Application/EIS is very low level and does nothing at all to provide confidence in the proposed mitigation measures and habitat offsets. Due to the proposed project’s location at the mouth of the Skeena River, which is an internationally significant salmon producing river, potential adverse effects are inadequately addressed at a basic level. The marine environment adjacent to the 2 proposed project is considered a biological hotspot in relation to the overall Skeena estuary and the BC Northcoast. Over the last forty years, numerous studies led by the federal government and development proponents have concluded that the Skeena River estuary is one of the most biologically productive areas on the BC Pacific coast. These past studies have noted the many potential adverse impacts to marine resources if development were to be located on Lelu Island and/or Flora Bank. However, the PNW LNG Application/EIS are in substantial disagreement with those studies. It is considered pointless to attempt to interpret why this current study is in strong conflict with past effects conclusions at the species, habitat, and ecosystem levels. SWCC considers the Application/EIS inadequate; the baseline data needs to be developed and then thoroughly evaluated as to potential impacts and effects. The rush to develop LNG facilities on the north coast has resulted in compromised data collection, and hurried analysis and interpretation. SWCC’s concern with sound and quality decision-making in the Skeena estuary converges with Fisheries Act and Canadian Environmental Protection Act legislation and with the long-term sustainability of the Skeena watershed, Skeena estuary, and the BC north coast. SWCC argues that the proposed LNG plant should not be situated in the Skeena estuary. 2.0 SWCC Comments to the CEAA draft Environmental Assessment Report ― February 2016 2.1 General Comments SWCC considers that the environmental assessment process leading up to the draft Environmental Assessment Report (EAR) continues to utilize weak or non-existent baseline data. Though the information base improved throughout the process, there is still a lack of fundamental understanding in regard to: • the Skeena River discharge; • the transport of sediment by Skeena River discharge; • the deposition of said sediment on the estuary sediment banks and delta front; • the effects of Skeena discharge flows on other prevailing currents such as tidal, wind-driven, and upstream saline water entrainment into the Skeena River; • the variability of large snowmelt events creating large Skeena flood flows that re- mobilize stored sediments in the inner portion of the estuary and re-deposit them in various drying and wetted banks. SWCC considers the data noted above as critical to understanding what effects, if any, would result from changes to the environment caused by the proposed project. Given the tight timelines set out in both the BC and Canada environmental assessment processes, the responsibility falls on the project proponent to collect adequate baseline data and 3 therefore be prepared with the EIS Application. However, in this case the proponent was not adequately prepared. In the course of SWCC’s review of the Application and review of the draft EAR, SWCC has unanswered and lingering questions regarding the proponents assessment of effects, including social, economic, cultural, environmental, and health-related effects, which appear to tainted by subjective opinions and conclusions. As such, the PNW LNG EA process appears to fail in identifying the potential impacts of the proposed development, particularly in relation to, or linked to changes to climate that are currently existing in the Skeena area, and in conjunction with other development processes, such as the other seven proposed LNG terminals, the two approved gas pipes (Spectra and PRGT), and other related port developments that cumulatively act to infringe on ecological integrity in the inner and mid-estuary areas. There is no lack of science denoting the high value habitat that supports juvenile salmon in and adjacent to Lelu Island. However, the draft CEAA report does not take note of this fact. Nor does the draft CEAA report take note of the past and current impacts to juvenile salmon habitat. For example, the amount of shoreline that has been hardened by development over the last three decades is relatively large. There is no lack of science proving that shoreline hardening is detrimental to juvenile salmon. But who is talking about it? This is effectively obliteration of excellent critical habitat that sustains Skeena salmon abundance. PNW LNG wishes to continue this tradition of impacting habitat. Yet the draft CEAA EAR does not appear to take note of the finest juvenile salmon habitat on the BC north coast. It is strange that Environment Canada and the Canada department of Fisheries and Oceans (dFO) of the day (in the 1970s) made note of the excellent habitat and recommended against development of the inner and mid-estuary area. SWCC notes that the cherry-picking of select science by the proponent, and to all appearances by CEAA, has tainted the EA process. SWCC questions why the abundance, the condition, and the genetic diversity of the many juvenile salmon caught and analysed by the Lax Kw’alaams/Skeena Fisheries Commission/ SFU joint venture did not provide meaningful discussion in the draft CEAA EAR? It is important to note that the majority of those juvenile fish, particularly the sockeye, came from populations that are currently denoted at risk and are managed under Sockeye Recovery Plans, of which dFO is an important partner. These populations include the Lakelse, Kitwanga, Morice-Nanika, and the Babine wild stocks. The latter stocks comprise by far, the largest sockeye stocks in the Skeena watershed. There does not seem to be much sense involved here; on one hand there are up-river recovery plans being funded and implemented in conjunction with Canada dFO, various First Nations, and the international Pacific Salmon Treaty–Pacific Salmon Commission 4 Northern Fund.