letter to Minister of Environment asking for environmental review of FSD/Texada Island coal proposal

(A letter has already been sent to the federal minister requesting a federal EA, by a lawyer acting on behalf of VTACC)

Please consider having your group sign on to this.  It is part of building a legal strategy.

Thanks,
Donald Gordon for Coal Dust Free Salish Sea

Dear Minister Polak:

We write on behalf of Coal Dust Free Salish Sea (CDFSS) to request that you exercise your powers under section 6 of the Environmental Assessment Act to designate the proposed shipment of coal from Fraser Surrey Docks (FSD) to Texada Island, for storage and transshipment to ocean going vessels as a “reviewable project” for which an environmental assessment is required.

CDFSS is a group of residents of the Georgia Strait/Salish Sea basin. Our concern is that this major coal transshipment project – which will see up to 8 million tonnes of coal per year shipped by ocean barge through the Salish Sea - is proceeding without any assessment of the risks it poses to the environment, and the First Nations and other communities who depend on that environment. We therefore ask that you give this request careful attention and, we hope, conclude that an environmental assessment of this coal shipment project is in the interests of all residents of the Salish Sea basin and, indeed, all British Columbians.

As you are no doubt aware, the Port Metro Vancouver is currently considering an application by FSD to expand coal storage and shipping facilities to enable the delivery, storage and handling of up to 8 million tonnes of coal originating in the US states of Montana and Wyoming ¹. The coal received by FSD will not be loaded onto ocean-going vessels at FSD; rather, it will be loaded onto open barges and shipped up the Salish Sea to a Lafarge facility on the northwest coast of Texada Island, for storage and re-loading to ocean going bulk carriers.

On September 12, 2013 the Port requested that FSD prepare an environmental impact assessment, to be conducted under the Port’s own project review process, which is ongoing as of the date of this letter. The Port’s assessment is restricted to increased coal train traffic from the US border and to the activities occurring within Port limits and jurisdiction, with a particular focus on coal dust emissions and related health impacts.² It is not considering any potential impacts associated with the shipment of the coal by barge from the mouth of the Fraser River to Texada, the unloading, storage and handling of the coal at the Lafarge facility, and the re-shipment of that coal via bulk carriers traveling through the Salish Sea to the open Pacific. Similarly, while the Ministry of Energy and Mines is reviewing a Mines Act permit amendment for the Lafarge site, its review is restricted to on-site activities falling within the purview of the Mines Act. There is no government agency that is looking at the environmental impacts and risks associated with this project as a whole.³

The planned shipment, storage and re-loading of coal originating at the FSD is a major industrial activity by any standard. The FSD application contemplates an initial 4 million tonnes of coal handling in years 2 - 5, to increase to 8 million tonnes in year 6. All of this coal will be shipped by open barge from FSD, down the Fraser River to the Salish Sea, and up the busiest internal waterway in BC to Lafarge’s facility on Texada. Due to combustion risks, the barges will not be covered. As of September 12, 2013 the PMV has asked FSD to incorporate dust suppression measures that will reduce dust releases in the Fraser River; however, there is no requirement that these measures be effective in the much windier Georgia Strait/Salish Sea. This creates the risk of uncontrolled coal dust dispersion into the Salish Sea. Once at the Lafarge facility, the coal will be unloaded and stored in 800,000 tonne open piles, where wind and rain will cause further uncontrolled dispersion of coal dust into both the aquatic and ambient environment. This is over a 5x increase in stockpile size from the current 150,000 tonne stockpile. The coal will then be re-loaded onto bulk carriers, which will again traverse the Salish Sea to the open Pacific.

A project of this scale poses obvious risks to the environment. Contaminants commonly associated with coal include selenium, mercury and arsenic, all of which are toxic to biological life forms, and all of which bio-accumulate through the food chain. A major spill of coal could produce a significant acidifying effect in the receiving marine environment, particularly if the spill occurred in shallow waters. While the Port has taken some steps to assess the air quality impacts of coal dust at the Port, the air quality impacts in the Salish Sea and on Texada Island – including risks of coal dust dispersal to large oyster beds within 200 meters of the Lafarge facility - are receiving no such review.

Allowing this project to go ahead without an environmental assessment is unacceptable. Local governments, First Nations, recreational boaters, shell fish harvesters, fishing groups and residents of the Salish Sea basin all expect this government to ensure that major industrial projects posing significant risks to public safety and health are properly and fully assessed before they proceed. That clearly is not happening here, due to an unintended loop hole in the law. You have the authority under s. 6 of the Environmental Assessment Act to close that loophole, and require an environmental assessment of this project that includes all activities from the point of shipment from FSD to the point of exit from internal BC waters, and we urge you to do so.⁴ Not doing so will amount to a gamble with the health of the aquatic environment of the Salish Sea. It will also gamble with the health of Lasqueti and Texada Island residents. Clearly an Environmental Assessment of this project is in the interests of all residents of the Georgia Strait/Salish Sea basin.