From: McLean, Robyn (EC) Sent: Tuesday, April 30, 2019 7 ... · From: McLean, Robyn (EC) Sent: Tuesday, April 30, 2019 7:13 PM ... Water Quality ... AQMS Air Quality Management System

From: McLean, Robyn (EC)Sent: Tuesday, April 30, 2019 7:13 PMTo: Parker, Cindy (CEAA/ACEE)Subject: RBT2 ECCC Written Submission - revised

Hi Cindy,

Please find attached ECCC’s updated written submission for RBT2. There were two errors identified in the original version sent to the Review Panel on April 15, 2019 that have been corrected in the revised version as follows:

• Chapter 3, Section 3.5 Marine Emissions - ECCC’s recommendation was incorrectly presented in the original version and has been updated on p. 27. • Chapter 4, Section 4.4 Wetlands and Wetland Functions - ECCC’s conclusion on p. 47 incorrectly stated that the shallow subtidal zone is not a wetland. The updated version now correctly states that the shallow subtidal zone is a wetland based on the CWCS.

Thank you, Robyn McLean

<contact information removed>

ENVIRONMENT AND CLIMATE CHANGE CANADA (ECCC)

WRITTEN SUBMISSION TO THE REVIEW PANEL

FOR THE ROBERTS BANK TERMINAL 2 PROJECT

PUBLIC HEARING

April 15, 2019

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Table of Contents

List of Abbreviations ........................................................................................................................................................................ 4

Executive Summary........................................................................................................................................................................... 5

CHAPTER 1: ECCC’s Mandate, Roles and Responsibilities ............................................................................................ 6

1.1 Introduction ................................................................................................................................................................................ 6

1.2 Fisheries Act ................................................................................................................................................................................ 6

1.3 Canadian Environmental Protection Act ......................................................................................................................... 7

1.4 Migratory Birds Convention Act ......................................................................................................................................... 7

1.5 Species at Risk Act ................................................................................................................................................................... 8

CHAPTER 2: Overview of ECCC’s Participation in the Environmental Assessment ......................................... 8

2.1 Introduction ................................................................................................................................................................................ 8

2.2 Technical Comments Provided to the Review Panel .................................................................................................. 9

Water Quality ............................................................................................................................................................................. 10

Disposal at Sea .......................................................................................................................................................................... 11

Accidents and Malfunctions................................................................................................................................................. 11

Effects of the Environment on the Project ..................................................................................................................... 12

CHAPTER 3: Air Quality ................................................................................................................................................................ 12

3.1 Canadian Ambient Air Quality Standards (CAAQS) ................................................................................................. 12

Introduction ................................................................................................................................................................................ 12

Analysis and Conclusions ...................................................................................................................................................... 15

Recommendations to the Review Panel ......................................................................................................................... 16

3.2 CALMET-CALPUFF Model Domain Size and Regional Emission Sources ........................................................ 17

Introduction ................................................................................................................................................................................ 17



3.3 Model Bias ................................................................................................................................................................................ 19

Introduction ................................................................................................................................................................................ 19



3.4 Background Air Quality ....................................................................................................................................................... 22

Introduction ................................................................................................................................................................................ 22


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3.5 Marine Emissions ................................................................................................................................................................... 25

Introduction ................................................................................................................................................................................ 25



3.6 Locomotive Emission Rates ............................................................................................................................................... 27

Introduction ................................................................................................................................................................................ 27



3.7 Cargo Handling Equipment Emissions .......................................................................................................................... 28

Introduction ................................................................................................................................................................................ 28



CHAPTER 4: Coastal Birds Assessment ................................................................................................................................ 29

4.1 Biofilm and Shorebirds ........................................................................................................................................................ 29

Introduction ................................................................................................................................................................................ 29



4.2 Species at Risk ........................................................................................................................................................................ 39

Introduction ................................................................................................................................................................................ 39



4.3 Artificial Lighting .................................................................................................................................................................... 43

Introduction ................................................................................................................................................................................ 43



4.4 Wetlands and Wetland Functions ................................................................................................................................... 44

Introduction ................................................................................................................................................................................ 44



4.5 Accidents and Malfunctions – Marine Birds ............................................................................................................... 51

Introduction ................................................................................................................................................................................ 51

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CHAPTER 5: Summary of Recommendations to the Review Panel ...................................................................... 54

5.1 Water Quality ...................................................................................................................................................................... 54

5.2 Accidents and Malfunctions ......................................................................................................................................... 54

5.3 Air Quality ............................................................................................................................................................................ 54

5.4 Coastal Birds Assessment .............................................................................................................................................. 56

Appendix ............................................................................................................................................................................................. 59

Appendix 1: Canadian Ambient Air Quality Standards (CAAQS) ............................................................................... 59

Appendix 2: Management levels for air pollutants under the CAAQS .................................................................... 60

Appendix 3: British Columbia Air Zone map ...................................................................................................................... 62

Appendix 4: RBT2 Technical Data Report Biofilm Regeneration Study ................................................................... 63

Appendix 5: Roberts Bank Salinity Model Results Verification: Comparison of 2012 Modelled Salinity to 2016 & 2017 Measured Salinity .............................................................................................................................................. 63

Appendix 6: EIS Appendix 15-A Capacity 2 Analysis ...................................................................................................... 64

Appendix 7: Review of Biofilm Reports (2016-2018) ...................................................................................................... 65

Appendix 8: ECCC Expert Witness Panel Curriculum Vitae .......................................................................................... 79

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List of Abbreviations AQMS Air Quality Management System BC British Columbia CAAQS Canadian Ambient Air Quality Standards CCME Canadian Council of Ministers of the Environment CEAR Canadian Environmental Assessment Registry CEPA Canadian Environmental Protection Act CO Carbon monoxide COSEWIC Committee on Endangered Wildlife in Canada CWAQD Canada-wide Air Quality Database CWCS Canadian Wetland Classification System DFO Fisheries and Oceans Canada DHA Docosahexaenoic acid ECA Emission Control Area ECCC Environment and Climate Change Canada EIS Environmental Impact Statement EPA Eicosapentaenoic acid EwE Ecosystem with Ecosim and Ecopath E2 Regulations Environmental Emergency Regulations GHGs Greenhouse gases IMO International Maritime Organization LAA Local Assessment Area MAMUs Mobile air quality monitoring units MARPOL International Convention for the Prevention of Pollution from Ships MBCA Migratory Birds Convention Act MEIT Marine Emissions Inventory Tool NOx Nitrogen oxide NO2 Nitrogen dioxide PCB Polychlorinated biphenyl PM Particulate matter PM2.5 Fine particulate matter PUFA Polyunsaturated fatty acids RAA Regional Assessment Area RBT2 Roberts Bank Terminal 2 SARA Species at Risk Act SHARP Synchronized Hybrid Ambient Real Time Particulate SOx Sulphur oxide SO2 Sulphur dioxide SRKW Southern Resident Killer Whale TEOM Tapered Element Oscillating Microbalance US EPA United States Environmental Protection Agency WAA Wetland Assessment Area WFA Wetland functions assessment WMA Wildlife Management Area

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Executive Summary Environment and Climate Change Canada’s (ECCC) review of the Vancouver Fraser Port Authority (the Proponent) proposed Roberts Bank Terminal 2 Project (the Project) is based on the Department’s mandate and the federal legislation it administers.

ECCC’s legislative framework for protecting and managing the environment is founded on various statutes, including the Migratory Birds Convention Act, the Species at Risk Act, the Canadian Environmental Protection Act., and the pollution prevention provisions of the Fisheries Act.

ECCC is participating in the environmental assessment process to provide the Review Panel with the following:

• A review of the Proponent’s characterization of potential adverse environmental effects of the Project, and marine shipping associated with the Project;

• A review of the predicted effectiveness of the proposed mitigation measures and considerations for additional mitigation measures;

• A review of the appropriateness of the proposed follow-up programs; and • Recommendations for the Review Panel

During ECCC’s technical review, various issues with respect to the Proponent’s assessment of the potential environmental effects of the Project and proposed mitigation measures were identified to the Review Panel. At present, several outstanding concerns remain regarding the assessment of air quality, biofilm and shorebirds, species at risk, and wetlands.

This submission summarizes ECCC’s outstanding concerns, and includes advice and recommendations based on a review of the information provided by the Proponent in its application pursuant to the Canadian Environmental Assessment Act, 2012. The recommendations presented in this submission (provided in Chapter 5) are for the consideration by the Review Panel and are intended to address outstanding issues related to ECCC’s mandate. ECCC is pleased to discuss these matters during the public hearing including the topics raised in the March 5, 2019 letter from the Review Panel to ECCC.

In its letter of March 5, 2019, the Review Panel requested ECCC to:

“…provide a written submission and make an oral presentation at the public hearing as they relate to the department’s expertise and mandate, including an overview of the latest research and findings on biofilm and shorebirds, and air quality”.

ECCC’s submission provides:

• Seven recommendations concerning the Proponent’s air quality assessment as it relates to the determination of baseline conditions, the application of Canadian ambient air quality standards, and on the overall modelling approach that was applied to the assessment, including the modelling domain size that was selected, and assumptions used to assess marine, locomotive and cargo handling emissions.

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• Nine recommendations concerning the Proponent’s assessment of coastal birds are provided tothe Review Panel as it relates to biofilm and shorebirds, species at risk, effects of artificial lighting,wetlands and the wetland functions assessment, and on accidents and malfunctions related tomarine birds.

CHAPTER 1: ECCC’s Mandate, Roles and Responsibilities 1.1 Introduction

The mandate of Environment and Climate Change Canada (ECCC) is determined by the statutes and regulations assigned to the Minister of Environment and Climate Change. In delivering this mandate, the Department is responsible for the development and implementation of policies, guidelines, codes of practice, inter-jurisdictional and international agreements, and related programs.

The following chapter describes specific relevant legislation administered by ECCC and relevant to the Project. For purposes of accuracy, interpretation and application of the legislation, regulation or policy, the Review Panel is invited to refer to official versions of legislation found on the Department of Justice website (http://laws.justice.gc.ca/). The Panel is also encouraged to refer back to ECCC’s June 23, 2016 letter to the Panel (CEAR 450) for further information on ECCC’s mandate.

ECCC’s obligation as a Federal Authority in possession of specialist or expert information or knowledge as is defined under section 20 of the Canadian Environmental Assessment Act, 2012. The scope of specialist or expert information or knowledge provided by ECCC in this submission is based on the departmental mandate described herein.

These comments are not to be interpreted as any type of acknowledgement, permission, approval, authorization, or release of liability related to any requirements to comply with federal statutes and regulations. Responsibility for achieving regulatory compliance lies solely with the Vancouver Fraser Port Authority.

1.2 Fisheries Act

https://laws-lois.justice.gc.ca/eng/acts/F-14/

The overall administration of the Fisheries Act is the responsibility of the federal Minister of Fisheries and Oceans; however, the responsibility for the administration (including the enforcement) of the pollution prevention provisions of the Fisheries Act, subsection 36(3), has been assigned to the federal Minister of Environment and Climate Change.

Meeting the requirements of the Fisheries Act is mandatory, irrespective of any provincial or territorial regulatory or permitting system. Only a federal regulation under the Fisheries Act or another Act of Parliament can authorize a discharge of a deleterious substance in water frequented by fish.

Subsection 36(3) of the Fisheries Act states that, unless otherwise authorized by regulations meeting specific criteria, “no person shall deposit or permit the deposit of a deleterious substance of any type in water

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frequented by fish or in any place under any conditions where the deleterious substances or any deleterious substance that results from the deposit of the deleterious substance may enter any such water”.

In the absence of a regulation authorizing its release, any release of a deleterious substance from the construction, operation, reclamation or decommissioning stages of the Project, to any waters frequented by fish, may constitute a violation of the Fisheries Act.

1.3 Canadian Environmental Protection Act https://laws-lois.justice.gc.ca/eng/acts/c-15.31/

ECCC is responsible for the administration and enforcement of the Canadian Environmental Protection Act, 1999 (CEPA). CEPA is aimed at preventing pollution and protecting the environment and human health. A key aspect of CEPA is the prevention and management of risks posed by toxic or other harmful substances. Substances that are declared "toxic" under CEPA are added to the List of Toxic Substances in Schedule 1 of the Act and regulated accordingly.

Authority to require emergency plans for toxic or other hazardous substances set out in Schedule 1 to the Environmental Emergency Regulations (E2 Regulations) is provided in Part 8 of CEPA. The E2 Regulations are aimed at enhancing the protection of the environment and human life and health by promoting the preparedness for response to and recovery from environmental emergencies. The E2 Regulations require those who own, have charge, management or control of toxic and hazardous substances set out in Schedule 1 to the E2 Regulations at or above the specified thresholds to provide required information on the substance(s), their quantities and to prepare and implement environmental emergency plans. ECCC provides expertise related to emergency plans for projects to ensure they remain consistent with the requirements of CEPA. Further, ECCC's reviews of accidents and malfunctions are also based on the Department's mandated interests as they relate to the pollution prevention provisions of the Fisheries Act, and the Migratory Birds Convention Act.

Under CEPA, the federal government established stringent health based ambient air quality standards for fine particulate matter and ground-level ozone. On November 3, 2017 the Canadian Council of Ministers of the Environment established Canadian Ambient Air Quality Standards (CAAQS) for NO2. Although the CAAQS are not legally-binding, federal, provincial, and territorial governments have agreed to work collaboratively to implement actions to improve air quality and to report on the achievement of the CAAQS on a regular basis. The CAAQS are underpinned by air quality management levels which call for progressively more rigorous actions by jurisdictions as air quality approaches or exceeds the CAAQS. Further information on the CAAQS is provided in Chapter 3 and Appendix 1.

1.4 Migratory Birds Convention Act https://laws-lois.justice.gc.ca/eng/acts/m-7.01/

ECCC administers and enforces the Migratory Birds Convention Act, 1994 (MBCA). The purpose of the MBCA is to implement the Migratory Birds Convention between Canada and the United States by protecting and conserving migratory birds, as populations and individual birds. The Migratory Birds Regulations, established

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under the MBCA, provide for the conservation of migratory birds and for the protection of their nests and eggs. Within this context, it is the responsibility of the Government of Canada to protect and conserve the roughly 500 species of migratory birds regularly occurring in Canada.

Subsection 5.1 of the MBCA prohibits the deposit of a substance that is harmful to migratory birds in waters or an area frequented by migratory birds or in a place from which the substance may enter such waters or such an area. The Act also prohibits the possession of a migratory bird, nest or egg without lawful excuse. This inadvertent harming, killing, disturbance or destruction of migratory birds, nests and eggs (what is known as incidental take) is prohibited under the MBCA. Incidental take, in addition to harming individual birds, nests or eggs, can have long-term consequences for migratory bird populations in Canada, especially through the cumulative effects of many different incidents.

1.5 Species at Risk Act https://laws-lois.justice.gc.ca/eng/acts/s-15.3/ ECCC is responsible for the overall administration and enforcement of the Species at Risk Act, 2002 (SARA). The federal Minister of Environment and Climate Change and the Parks Canada Agency is responsible for individuals of species at risk found in national parks, national historic sites or other protected heritage areas, as well as for all other non-aquatic species at risk. The federal Minister of Fisheries and Oceans is responsible for aquatic species at risk.

The purpose of SARA is to prevent wildlife species from being extirpated or becoming extinct, to provide for the recovery of wildlife species that are extirpated, endangered or threatened as a result of human activity, and to manage species of special concern to prevent them from becoming endangered or threatened. Schedule 1 of SARA provides a list of wildlife species at risk in Canada that are considered extirpated, endangered, threatened, or of special concern. Endangered and threatened migratory bird species at risk (species, subspecies, and distinct populations) have federal legislative protection under SARA.

SARA provides measures for the protection of listed threatened, endangered or extirpated species and their residences. Subsection 32(1) of SARA states that no person shall kill, harm, harass capture or take an individual of a wildlife species listed as an extirpated, endangered or threatened, and Section 33 states that no person shall damage or destroy the residence of one or more individuals of a wildlife species listed as endangered or threatened or as an extirpated species if a recovery strategy recommends the reintroduction of the species into the wild in Canada.

CHAPTER 2: Overview of ECCC’s Participation in the Environmental Assessment 2.1 Introduction ECCC has provided technical sufficiency comments to the Review Panel on the Proponent’s Environmental Impact Statement (EIS) and Marine Shipping Addendum, including supplemental information throughout the environmental assessment process as follows:

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• Provided an oral presentation and letter to the Review Panel at the Orientation session held in June 2016 on the Department’s mandate, roles and responsibilities (CEAR 450).

• Provided two initial letters to the Review Panel on sufficiency of information in the Proponent’s EIS and Marine Shipping Addendum including a review of proposed disposal at sea activities (September 2016, CEAR 564) and migratory birds information (October 2016, CEAR 574).

• ECCC submitted technical sufficiency comments on the EIS and Marine Shipping Addendum to the Review Panel during public comment period #1 in all areas of the Department’s mandate including: water quality, air quality, wildlife and migratory birds, environmental emergencies, weather and climate, and effects of climate change on the Project (October 2016, CEAR 581).

• ECCC responded to 11 specific information requests from the Review Panel over the course of the sufficiency review on topics including marine water and sediment quality, dredging, biofilm and shorebirds, coastal, marine and migratory birds, species at risk, wetlands and on effects of the environment on the Project (see CEAR 999).

• ECCC participated in the Review Panel’s public comment period #2 and provided technical sufficiency comments on the Proponents responses to Review Panel Information Requests, specifically responses in package 6 (air quality) and package 8 (marine vegetation, biofilm) (November 2018, CEAR 1346).

• ECCC also participated in the Review Panel's public comment period #3 and provided technical sufficiency comments on the Proponents responses to Review Panel Information Requests, specifically responses in package 7 and 13 (habitat offsetting), package 9 (coastal birds), and package 11 (water and sediment quality, accidents and malfunctions) (February 2019, CEAR 1454).

• ECCC will also provide oral presentations to the Review Panel at the Public Hearing on the subjects of air quality, coastal and migratory birds, and wetlands and wetland functions.

2.2 Technical Comments Provided to the Review Panel ECCC has contributed technical expertise and provided specialist information to the Review Panel on a variety of topics throughout the environmental assessment as noted in section 2.1. This written submission focuses on outstanding issues with regard to the air quality (Chapter 3), coastal and migratory birds, species at risk, and wetland assessments (Chapter 4). A summary of ECCC’s recommendations to the Review Panel is provided in Chapter 5.

ECCC’s written submission provides technical comments and recommendations for the Review Panel’s consideration on:

- The potential adverse environmental effects of the Project - Predicted effectiveness of the proposed mitigation measures - The appropriateness of proposed follow-up programs (where applicable) - Analysis of the Proponent’s conclusions with respect to potential effects

ECCC’s analysis in Chapter 3 on air quality includes consideration of recent responses by the Proponent to Review Panel Information Requests in package 141 that were not available at the time of public comment

1 See CEAR 1465

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period #3. These include responses on ferry emission estimates and air quality modelling bias and uncertainty.

ECCC has also included technical comments on several reports posted on the Registry which ECCC had not previously submitted to the Review Panel. ECCC’s analysis of the Proponent’s Biofilm Regeneration Study Technical Data Report is provided in Appendix 4, and ECCC’s analysis of the Proponent’s Salinity Model Verification Report is provided in Appendix 5. Appendix 6 provides additional technical comments on the Proponent’s Capacity 2 Analysis from Appendix 15-A of the EIS. ECCC’s technical comments on the Proponent’s 2018 Biofilm report2 is provided in Appendix 7 (ECCC’s technical comments on the Proponent’s 2016 and 2017 biofilm studies are provided in CEAR 1454).

Technical comments and recommendations that ECCC has provided to the Review Panel on other topics including water quality, disposal at sea, environmental emergencies and effects of the environment on the Project, are summarized below.

Water Quality ECCC reviewed the Proponent’s water and sediment quality information for the Project contained in the EIS as well as in responses to Review Panel Information Requests in package 11. ECCC’s most recent comments on water and sediment quality were provided to the Review Panel in CEAR 1454.

ECCC’s comments were focused on the Proponent’s assessment of PCB concentrations in discharged sediments from the terminal’s supernatant discharge pipe, and whether they will be consistently below DFO’s recommended threshold of 12-200 pg/g (DFO 2010)3. Supernatant will be generated during construction when unsettleable fine sediments are discharged during the placement of terminal fill (approximately 3%). The concentrations of PCBs and other parameters in the supernatant discharge are expected to vary depending on what type of fill material is being placed for terminal construction.

As a result, ECCC recommends that all fill material be characterized (dredgeate and quarry sand) to demonstrate that acceptable supernatant discharge quality can be maintained throughout the Project’s construction period. Further, it remains unclear to ECCC whether the supernatant discharge may increase PCB exposure in Southern Resident Killer Whale (SRKW) critical habitat, particularly when dredgeate from the upper layer of the tug basin is being placed as fill. It was indicated in the Proponent’s response to IR11-23 on quality of marine sediment that PCB concentrations in the upper sediment layers of the tug basin exceed the DFO upper threshold of 200 pg/g. ECCC recommends that the supernatant either not be discharged when dredgeate from the upper layers of the tug basin is being placed as fill, or further details to demonstrate that these sediments will not exceed the DFO upper threshold (200 pg/g) or increase ambient PCB concentrations in SRKW critical habitat would be necessary.

2 Biofilm Dynamics during 2018 Northward Migration (2019)(CEAR1385) 3 DFO 2010: Impact of at sea disposal on resident killer whale (Orcinus Orca) critical habitat: Science in support of risk management. Canadian Science Advisory Secretariat, Science Advisory Report 2010/046. Fisheries and Oceans Canada, Pacific Region.

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Disposal at Sea Through the course of the sufficiency review process, ECCC has examined the Proponent’s modifications to the Project and recognizes that RBT2 as currently proposed (Project Construction Update, CEAR 1210) is unlikely to require a disposal at sea permit under CEPA. However, as Project planning advances it remains the Proponent’s responsibility to ensure any further modifications that may be proposed are considered in terms of potential disposal at sea requirements under CEPA and to notify ECCC accordingly. ECCC’s response to a Review Panel Information Request on disposal at sea describes that certain Project elements (e.g., construction of the terminal using dredged material) must be undertaken in a manner that does not cause marine pollution (ECCC IR-04, CEAR 1091). If the proposed Project should proceed to the regulatory phase, ECCC will take final Project details and all pertinent impact mitigation and monitoring commitments into account before reaching a final determination on the need for a disposal at sea permit.

Accidents and Malfunctions ECCC provided comments on the Proponent’s assessment of accidents and malfunctions in the EIS, Marine Shipping Addendum and in responses to Review Panel information requests (package 11). As described in section 1.3, ECCC provides expertise related to emergency plans for projects to ensure they remain consistent with the requirements of the E2 Regulations under CEPA, the pollution prevention provisions of the Fisheries Act, and the MBCA. ECCC also encourages Proponents to prepare emergency response and spill contingency plans that reflect a consideration of potential accidents and malfunctions and account for site-specific conditions and sensitivities.

ECCC’s most recent comments on the Proponent’s assessment of accidents and malfunctions were provided to the Review Panel in CEAR 1454. In reviewing the Proponent’s response regarding the assessment of a worst-case accident scenario involving a container ship and a crude oil tanker (see Proponent response to IR11-08), it was unclear to ECCC whether the Proponent’s estimate of a potential worst-case spill was based solely on one type of oil (i.e. petroleum cargo) or on a mix of multiple oil types that may include petroleum cargo and vessel fuel oils and lubricants. ECCC recommends that clarification on the oil types that were modelled would be required to inform the appropriate response and recovery strategies as different types of oil will have different environmental effects.

In consideration of the Proponent’s response to IR11-08, ECCC recommends that spill probability modelling be required to support the Proponent’s assessment of an accident scenario involving a collision between a container ship and tanker carrying crude oil, particularly as the Proponent estimates the potential worst-case oil spill volume to be higher than original estimates. The Proponent’s initial assessment of a worst-case accident scenario in the EIS only related to a container ship grounding incident which was predicted to result in a maximum spill volume of 7,500 m3 of vessel fuel only.

ECCC is of the view that the potential environmental effects associated with a collision scenario between a container ship and a tanker carrying crude, regardless of the probability of occurrence, have not been fully assessed. ECCC recommends that the types of oil included in the potential maximum spilled volume be clarified. ECCC further recommends that if the estimate was only specific to a spill of a single type of oil, then all other plausible fuel oil types such as marine diesel and heavy fuel oil should also be modelled.

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Effects of the Environment on the Project In ECCC’s sufficiency review of the EIS in October 2016, ECCC provided two comments on climate change related information based on a review of Section 31 of the EIS (Effects of the Environment on the Project) (CEAR 581). The first comment related to the use of fixed design values obtained from historical climate observations (i.e. 1 in 10-year rainstorm). ECCC noted that the scientific literature indicates that changes in the intensity and probability of short duration heavy precipitation events are expected to occur with ongoing climate change. The second comment related to the Proponent’s statement that significant changes are not expected with respect to storm intensity, related wave conditions, and associated storm surges in B.C. coastal waters. ECCC’s comment highlighted that there is uncertainty in future projections of storm conditions (storm intensity and related wave conditions) at the regional and local scale and that this uncertainty is not equivalent to stating with confidence that changes in storm conditions are not expected.

In November 2017, ECCC expanded on these two comments in response to ECCC-IR-06 received from the Review Panel (CEAR 1091). Specifically, it was noted that it is ECCC’s view that the estimation of the one-in-10-year precipitation event based on the historical data will likely underestimate future precipitation events (i.e., frequency and intensity) especially towards the latter part of the century. Secondly, ECCC noted that assuming that future storm conditions will be within the envelope of the past ignores the additional uncertainty associated with climate change.

CHAPTER 3: Air Quality 3.1 Canadian Ambient Air Quality Standards (CAAQS) Introduction Policy Context for CAAQS

Federal, provincial and territorial governments are working collaboratively to improve air quality through the implementation of the Air Quality Management System (AQMS). The Canadian Ambient Air Quality Standards (CAAQS) are a key element of the AQMS and are intended to be the drivers for air quality improvements across the country in order to further protect human health and the environment. Once approved by the Canadian Council of Ministers of the Environment (CCME), the federal government establishes the CAAQS as ambient air quality objectives under sections 54 and 55 of the Canadian Environmental Protection Act, 1999 (CEPA).

Section 54:

(1) For the purpose of carrying out the Minister’s mandate related to preserving the quality of the environment, the Minister shall issue

(a) environmental quality objectives specifying goals or purposes for pollution prevention or environmental control, including goals or purposes stated in quantitative or qualitative terms…

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Section 55:

For the purpose of carrying out the mandate of the Minister of Health related to preserving and improving public health under this Act, the Minister of Health shall issue objectives, guidelines and codes of practice with respect to the elements of the environment that may affect the life and health of the people of Canada

Although the CAAQS are not legally-binding, federal, provincial, and territorial governments have agreed to work collaboratively to implement actions to improve air quality and to report on the achievement of the CAAQS on a regular basis. The CAAQS are underpinned by air quality management levels which call for progressively more rigorous actions by jurisdictions as air quality approaches or exceeds the CAAQS.

The CAAQS are provided in Appendix 1.

CAAQS and Air Zone Management

In addition to being national objectives under CEPA, the CAAQS are used in the Air Zone Management Framework of the AQMS and are supported by air quality management levels associated with a range of concentrations for each pollutant (Appendix 2). Under the Air Zone Management Framework, management actions become progressively more rigorous as air quality within an air zone deteriorates from the green level (representing clean air quality) to the red management level (representing exceedances of the CAAQS.) The framework guides provinces and territories in the level of actions to implement as air quality levels within air zones approach or exceed the CAAQS, thereby ensuring that the CAAQS are not treated as “pollute-up-to” levels. The CAAQS are based on the principles of keeping clean areas clean and continuous improvement.

A map of current air zones for British Columbia (BC) is provided in Appendix 3. The Project is in the Lower Fraser Valley air zone.

Use of the CAAQS in Environmental Assessment

As noted in the Guidance Document on Air Zone Management4, jurisdictional flexibility is a key principle of the AQMS that enables jurisdictions to implement the CAAQS in a manner that is consistent with their specific management practices and circumstances. While not intended to be used as enforceable standards to be achieved at the project perimeter, during an environmental assessment process the CAAQS may be used in conjunction with the results from air quality modelling to predict the impact of a project on downwind locations, including communities and sensitive receptors. This information may be considered by jurisdictions in determining the nature and severity of the project’s impact on air quality levels and the resulting mitigation measures that may be required to maintain good air quality levels or to prevent an exceedance of the CAAQS.

4 https://www.ccme.ca/files/Resources/air/aqms/pn_1481_gdazm_e.pdf

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Applying the CAAQS

Provinces and territories are responsible for designating which monitoring stations within their borders are used to report on CAAQS achievement. While the designated monitors are usually located in population centres, air zones are designed to cover all geographic areas (including over water) within a jurisdiction and the resulting management levels and actions may be applied across an air zone. In addition, air pollutants can travel long distances and affect communities and receptors far from the initial source.

It should be noted that the CAAQS were developed in consideration of both human health and the environment. As such, the lack of a nearby human population within the estimated impact area of a project is not a reason to discount the use of the CAAQS during an environmental assessment. This is especially relevant if the estimated impact area contains air pollution-sensitive ecosystems. Sensitive ecosystems encompass national and provincial parks, protected areas, areas of cultural or heritage value and areas that are or may be susceptible to adverse effects from direct exposure to pollutants, acid deposition or eutrophication.

Determining the Baseline Air Quality for an Area

To establish a baseline air quality level for the area under review, all existing monitoring data may be used. These include:

• CAAQS-reporting stations (stations designated by the province or territory for reporting on achievement of the CAAQS).

• Stations that report to the Canada-wide Air Quality Database (CWAQD) maintained by ECCC.

• Provincial and territorial stations not in the CWAQD.

• Stations owned by air zone organizations5.

• Stations owned by third parties (e.g. industry).

Modelling results or information from previous environmental assessments, provincial or territorial air quality or air zone reporting, and information from research studies may also be used to establish a baseline level of air quality for the area under review. Expectations for Air Quality Modelling in Federal Environmental Assessments

Modelling data may be used to compare predicted concentrations to ambient standards, including national standards such as the CAAQS, to estimate the contribution of the project to local air quality. In order to assess the impact of a proposed project on ambient air quality levels, ECCC recommends that modelled predictions be compared to the most stringent federal, provincial or territorial air quality standards applicable to the given area. In many cases, the CAAQS will be the most stringent levels for key

5 These are not-for profit organizations with a multi-stakeholder membership and are established by some provinces and territories to address air quality within the air zone. Some organizations operate their own monitoring stations.

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air pollutants, especially for longer-term projects with emissions after 2025. It is recommended that modelling results be compared to the most stringent CAAQS limits currently available (i.e. 2020 for PM2.5

and 2025 for NO2 and SO2). However, for project activities or stages that will be limited to a specific time frame, such as project construction prior to 2025, it is acceptable to compare modelled data to the CAAQS that will be in effect for that time period.

Modelling may also be used to estimate the potential for project emissions to influence air quality in neighbouring air zones or adjacent jurisdictions. Under the AQMS, the federal government is responsible for coordinating actions to address inter-provincial and international air pollution through a system of regional airsheds.

Analysis and Conclusions Proponent Conclusions

In response to Review Panel IR6-23, the Proponent has predicted PM2.5, SO2, and NO2 concentrations for the existing and future conditions with the Project and has compared to the CAAQS (Table IR6-23-A1). The predictions for PM2.5 are generally below the CAAQS for both existing and future conditions, although the predicted PM2.5 in the existing condition is above the CAAQS in close proximity to the Project (EIS, Figure 4-21). The predictions for SO2 are above the CAAQS for the existing conditions and below the CAAQS for future conditions.

The response to Review Panel IR14-04 (Figure IR14-04-A2) shows that the 1-hour NO2 is predicted to exceed the CAAQS over the majority of the study domain for both the expected and future conditions, and the annual NO2 is predicted to exceed around the Project footprint. Further, the 1-hour concentration of NO2 exceeds the CAAQS 129 days of the year near Westshore and Deltaport Terminals.

ECCC Conclusions

Canadian Ambient Air Quality Standards for PM2.5 and Ozone

For the Lower Fraser Valley air zone (where the Project is located), PM2.5 and ozone data has been reported for the periods from 2011-136 to 2014-167. There appears to be an increasing trend for both PM2.5 and ozone levels in this air zone based on CAAQS reporting since 2011-13, however this may be attributed to a change in monitoring technology in 2013. Metro Vancouver switched the PM2.5 monitor from a Tapered Element Oscillating Microbalance (TEOM) monitor to a Synchronized Hybrid Ambient Real Time Particulate (SHARP) monitor. Studies have found that the TEOM instruments under-report particulate concentrations when compared to other instruments. PM2.5 and ozone air zone data from the reporting periods 2011-13 to 2014-16 are shown in Table 1.

6 https://www2.gov.bc.ca/assets/gov/environment/air-land-water/air/reports-pub/lfv_air_zone_report_2011-2013.pdf 7 https://www2.gov.bc.ca/assets/gov/environment/air-land-water/air/reports-pub/air-zone-reports/2014-2016/lfv_air_zone_report_2014-2016_final.pdf?forcedownload=true

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Table 1: PM2.5 and ozone air zone data from the reporting periods 2011-13 to 2014-16

Pollutant 2011-2013 2012-2014 2013-2015 2014-2016

PM2.5 24-hour (ug/m3)

14 17 20 19

PM2.5 annual (ug/m3)

5.6 6.5* 6.9 6.3

Ozone 8-hour (ppb)

54 58 64* 60

*Based on only two years of data, **data from Lower Fraser Valley air zone reports (2011-13, 2012-14, 2013-15, 2014-16)

The 2014-2016 air zone report for the Lower Fraser Valley states that after considering the impact of transboundary flows and exceptional events (such as forest fires), the air zone remained in the yellow management level for PM2.5 and the orange management level for ozone (therefore orange management level overall). Based on the Air Zone Management Framework under the AQMS, this would imply that actions to prevent exceedances of the CAAQS in this air zone should be considered.

In Table IR6-23-A1, the Proponent predicted PM2.5 concentrations for the future case are below the CAAQS, however the air zone is still approaching an orange management level.

Canadian Ambient Air Quality Standards for SO2 and NO2

Since provinces are not obligated to report on SO2 and NO2 until 2020, there has yet to be a management level assigned to the air zone.

The Proponent’s predictions of SO2 for the existing conditions are above the CAAQS, however the future case for SO2 is predicted to be below the CAAQS. The reduction in SO2 shown in Table IR6-23-A1 may be attributed to the implementation of new regulations under the International Convention for the Prevention of Pollution from Ships (MARPOL) that set limits for SO2 and NO2 emissions from ships. (Annex VI Prevention of Air Pollution from Ships).

Concentrations of 1-hour NO2 is predicted to exceed the CAAQS over the majority study domain for future conditions (Figure IR14-04-A2). Annual NO2 is predicted to be above the CAAQS in proximity to the Project (Figure IR14-04-A4). These NO2 predictions indicate that NO2 management actions will be required for the air zone.

Recommendations to the Review Panel In consideration of the above analysis, ECCC recommends that:

• The Proponent design and implement a local air quality monitoring program in multiple locations.

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• The Proponent participate in local and regional air quality management initiatives, where applicable.

• The Proponent takes an iterative approach to air quality management and makes any necessary adaptations to Project equipment or procedures to prevent Project emissions from contributing to deteriorating air quality in the local and regional area.

3.2 CALMET-CALPUFF Model Domain Size and Regional Emission Sources Introduction In conducting an air quality assessment, there are modelling inputs and modelling parameters that are defined. Two of those parameters are domain size and regional emission sources. The model domain size is typically chosen to include 10% of the relevant air quality objectives or standards. The inclusion of regional sources in the model domain allow for the potential interactions of those sources with those of the Project. It is common practice to model regional sources in a sufficiently large modelling domain to determine how the proposed Project could interact and contribute to regional air quality.

Air quality predictions of NO2 for the Project are above both the 1-hour and annual CAAQS. The current modelling methodology the Proponent has used (limited modelling domain and adding one background value to represent regional sources) a simplified method that does not account for all effects to air quality.


In response to Review Panel IR6-11, the Proponent described that a model domain size sensitivity test was included in the Air Quality Scoping Study process in 2013. This sensitivity study compared the results of modelling one point source, a ship at berth, on a 26 km by 24 km domain versus a 30 km by 30 km domain. The point source was located in the center of the domain at the Project site. This sensitivity analysis showed that there was almost complete overlap between the predicted concentrations for both domain sizes, and therefore, predicted concentrations at discrete receptor locations were almost identical.

The Proponent provided the same sensitivity analysis (using one point source in the center of the domain) for the 50 km by 50 km domain size requested in Review Panel IR6-11. The WRF-NMM model was re-run for the larger 50 km by 50 km domain and was used as pseudo observation for input into CALMET. The CALMET model was re-run over the 50 km by 50 km domain with a grid resolution of 1 km. The original 26 km by 24 km meteorological domain used in the EIS was also re-run at a 1 km grid resolution for direct comparison. The Proponent concluded that the 50 km by 50 km sensitivity study concentrations at discrete receptor points were virtually identical in both model simulations or have negligible differences. The Proponent further concluded that this combined with the results of previous sensitivity studies indicated that there would be no appreciable differences in maximum predicted concentrations if a larger modelling domain was used in the assessment; and therefore determined that re-modelling with a 50 km by 50 km modelling domain was not necessary.

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Further, in response to Review Panel IR6-12 the Proponent stated that emissions sources in the surrounding region have been accounted for in the 26 km by 24 km domain, and that results of sensitivity tests discussed in response to IR6-11 indicated that an increased domain size would not have an effect on predicted concentrations.

To support the statement that regional sources in the 50 km by 50 km domain are captured by the 26 km by 24 km domain, the Proponent stated that contributions from other emission sources beyond the boundaries of the local study area are included in background air quality levels measured at station T39 in Tsawwassen. An analysis of air quality monitoring at station T39 from June 2-3, 2004 was used as the basis for the Proponent’s conclusion that station T39 captures all regional sources outside of the 26 km by 24 km domain. Further to that analysis, the Proponent considered air quality concentrations and wind directions from 2010 to 2015. The Proponent concluded that:

• Ships in the Strait of Georgia and from marine terminals at Roberts Bank are included in the observations at station T39.

• SO2 emissions from oil refineries in Washington State and cement plants located on Tilbury Island in Delta and in Richmond contribute to the SO2 concentrations measured at station T39.

• If SO2 from distant sources are monitored at station T39 then other contaminants from other distant sources are monitored at station T39 as well.

The Proponent further concluded that expanding the modelling domain to include modelling of large emission sources would have the effect of double-counting those emissions when combining predicted concentrations with the 98th percentile background air quality from station T39.

ECCC Conclusions

ECCC is of the view that conducting a sensitivity analysis using one point source in the center of the modelled domain does not capture all of the possible interactions the Project may have with existing and future regional emission sources. The goal of modelling a larger domain is to ensure that the meteorological processes that might influence the dispersion of pollutants from regional and Project sources are adequately captured. Furthermore, in order to determine potential effects of the Project on the receiving environment, interactions with other emission sources in the region should be considered. Limiting the model domain size and representing all regional sources with one background value does not provide enough information to determine the full effect of the Project on regional air quality.

In the case where regional sources are modelled, a background value can still be added. However, determining the appropriate background value to add depends on the comparison of the regional source modelling predictions to ambient monitoring data. To determine how representative the modelling of regional sources is, predictions at the monitoring station location can be compared to the measured concentrations. In the event that monitoring data still indicates that some of the regional emission sources are not captured in the regional modelling then a lower percentile (i.e. lower than the 98th percentile as used by the Proponent) can be added to the regional source model results. A lower percentile background value added to the regional source modelling results captures any source that was

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not included in the regional source modelling. This approach ensures that regional sources are accounted for, not just in magnitude of concentration but spatially relative to the Project.

ECCC also notes that although CALPUFF is not a photochemical model it employs simplified estimations for important chemical transformation processes, including the oxidation of sulfur dioxide, transformation of nitrogen oxides to nitric acid, nitrate aerosol formation, scavenging of gases into cloud water, and particle deposition. Where the modelling domain is not large enough and regional emission sources are not included, then the potential for those sources to contribute to chemical reactions and secondary pollutant formation is not adequately considered, and the potential interactions of the Project with regional sources is not fully understood. ECCC is of the view that the addition of one background value from one monitoring station applied over the entire domain does not allow for the possibility of chemical reactions and secondary pollutant formation influenced by regional sources to interact with those similar processes associated with the Project.

In addition, adding one background value to represent all regional sources only adds the magnitude of the concentration, and the dispersion and spatial extent of where the contaminants originate and travel may not be captured. The spatial distribution of regional sources relative to the Project and relative to prevailing synoptic patterns (i.e. meteorology) influences how the Project will interact with the regional sources and potentially affect regional air quality.

Given that predictions of NO2 are above the CAAQS, a more rigorous modelling assessment is recommended. The current methodology the Proponent has used (adding one background value to represent regional sources) is a simplified method that does not adequately determine effects. ECCC is of the view that increasing the model domain size coupled with including all regional sources in the model, and determining a lower background percentile value, would allow for all Project interactions with regional sources to be captured.

Recommendations to the Review Panel ECCC continues to recommend that the air quality assessment for the Project include the additional analysis that has been described above. A larger modelling domain coupled with inclusion of regional emission sources would allow for a complete assessment of the Project’s effects on air quality.

3.3 Model Bias Introduction When conducting air quality modelling assessments there are various methods that can be used to develop modelling inputs. Some of these modelling inputs and assumptions can lead to uncertainty or bias in the model results. Determining these uncertainties or biases can be done statistically, however these statistics if used incorrectly can introduce invalid conclusions.

Accurate modelling assessments are central to determining project impacts to air quality. A full understanding of assumptions and any model bias imposed by those assumptions is critical for evaluating predictions and assessing Project impacts on air quality.

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In Information Request package 14 (IR14-03), the Review Panel requested that the Proponent determine the possible bias and level of uncertainty in modelled ambient air pollutant concentrations introduced by modelling one year of meteorology, 2010. In response, the Proponent calculated model bias and fractional bias to support conclusions that 2010 was a representative model year.

In response to Review Panel IR14-03, the Proponent stated that “the analysis demonstrated that the prediction of worst-case concentrations of air pollutants when other sources from the airshed are included (as defined background concentrations) reduces uncertainty in the model with an overall tendency to over predict air pollutant concentrations.” The Proponent further concludes that, the “2010 data is considered adequately conservative for predicted air pollutant concentrations for existing conditions, expected conditions, and future conditions with the Project because similarly conservative assumptions were used for modelling expected and future emissions from the marine terminal operations in 2025”. In summary, the Proponent states that “dispersion model output results have not been compromised.”

ECCC Conclusions

ECCC does not support the Proponent’s assumptions and methods used to calculate model bias and fractional bias, and is of the view that the methodology of the bias analysis does not support the Proponent’s conclusions.

Sample Size

For the model bias calculation, the Proponent selected 10 hours of the year 2010 and 10 days of the year 2010 as the sample to determine model bias. These 10 hours and 10 days represent the maximum predicted concentrations for the 1-hour NO2 and 24 hour NO2. The Proponent has compared these 10 hours and 10 days to observations at station T39. However, it is not evident from the Proponent’s response whether or not the highest 10 observed concentrations match the timing of the highest 10 model-predicted concentrations. To calculate bias, the observed-modelled concentration pairs should be coincident in time. If the observed concentrations occurred at different times from the modelled times, then the meteorological conditions would be different, and the differences between observed and modelled values would be partially dependent on errors in model advection of contaminants. The use of 10 samples results in a sample size of 0.1% - 2.7% (10/8760, 10/365), which has low statistical power. This low sample size and resulting low statistical power is not sufficient to draw conclusions. Using the highest 1% of all hourly observations and highest 10% of all daily observations would allow the comparison to have increased statistical power.

Monitoring data from 2010 for Station T39

In response to Review Panel IR14-03, the Proponent stated that monitoring at station T39 started in June 2010, meaning that only half of the year 2010 has monitoring results that can be used in the statistical

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comparison. Without a full year of monitoring data to compare to, the maximum 10 hours selected for comparison is limited to 6 months of monitoring data. This means there is half of the year where the model could have under predicted or over predicted and it cannot be verified using station T39.

In the response, the Proponent did not use other locations other than T39 for the model bias analysis. Model bias may vary from location to location, yet the analysis was only performed for one location. A difference in model bias from one location to another will indicate potential differences in bias for wind speeds and temperatures, hence dispersion. For example, a model that has a colder bias for a coastal location versus an inland location will generate an excessively strong and turbulent daytime sea breeze.

Comparison to other years (2011-2015)

In the analysis of determining if 2010 meteorology is a representative year, the Proponent compared 2010 predictions to 2010-2015 monitoring data. This comparison does not take into account the possible change in air pollution trends in 2010-2015 that are independent of meteorology, i.e., the emissions of NO2 are dependent on the emission sources in those years and may fluctuate differently than in 2010. Furthermore, the comparison does not consider the complex relationship that NO2 formation and destruction has on meteorology (e.g., the relationship with ground-level ozone and volatile organic compounds). These variations are apparent in the concentrations provided in Table IR14-03-1. The hourly values of the maximum observed NO2 concentrations were higher in each of the years 2011 through 2015 than in 2010. The model bias and fractional bias analysis did not consider these possible variations.

For the comparison using 2011 to 2015 observations, the observed-modelled pairs will involve different meteorology including differences in wind speed, direction, temperature, and vertical stability. Observed values of concentrations need to be compared with modelled values derived from modelling runs using the same meteorology to avoid confounding effects. The biases that are calculated between the modelled year 2010 and the five years of monitoring data (2011-2015) are subject to several confounding factors (as described above) and are therefore not valid. To compare model results to the years 2011-2015 of monitoring data, the Proponent should conduct modelling for those particular years.

Conservatisms

The Proponent has used model conservatism to indicate that any variability in meteorology would be compensated by the conservative approach taken in model assumptions. Further, in response to Review Panel IR14-03, the Proponent frequently cited that the model was conservative.

While ECCC acknowledges that there may be a number of operational assumptions made by the Proponent in the modelling approach that are conservative, ECCC disagrees with the assertion that conservatisms would compensate for any biases introduced by modelling one year, 2010. The meteorological model and its variability over different years introduces variables on the aspects of dispersion and atmospheric chemistry. The conservatisms listed above are not scientifically connected to the meteorology. Furthermore, in the context of environmental assessment, the goal of air modelling is to produce accurate predictions of existing and future ambient concentrations. Considering that the Proponent’s predictions of NO2 are above the CAAQS, the need for accurate and unbiased modelling

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becomes more evident. It is not possible to qualitatively “credit” perceived conservatisms in the model to reduce predicted concentrations below guideline values.

Summary

With the combination of selected 10 samples (25 for fraction bias) and with only a 6 month monitoring period, ECCC is of the view that this does not provide enough data to do model bias or fractional bias statistics. A more fulsome statistical analysis is recommended before conclusions on bias and level of uncertainty can be made. It is ECCC’s view that one of the most efficient ways to determine model bias from modelling 2010 is to model other years and do a statistical analysis.

Recommendations to the Review Panel ECCC recommends that the air quality assessment for the Project apply a more rigorous statistical approach using timed-matched values of observed and modelled concentrations of NO2. Modelling of more than one year would allow for a complete assessment of the Project’s effects on air quality.

3.4 Background Air Quality Introduction In an air quality assessment not only is the predicted incremental concentrations from project sources important, it is the overall cumulative air quality that is used to determine effects. Cumulative air quality is the baseline plus the predicted increment resulting from project contributions. The term baseline is used to define concentrations from both natural and anthropogenic sources. Typically, baseline is determined from air quality modelling data or a combination of modelling and air quality modelling data. The Proponent has referred to the baseline concentrations as background concentrations. Determination of background (or baseline) concentrations is the basis for assessing a project’s potential effects on air quality, and as such, background values should be selected that are representative of the existing air quality over the entire modelling domain.


For determination of background concentrations, the Proponent used data from station T39 for the period 2010 to 2012. The Proponent provided an analysis of the air quality data from the Vancouver International Airport station (station T31) and Richmond South (station T17). By comparing stations T31 and T17 to T39 (the station used in the assessment), the Proponent found that concentrations of CO, NO2, SO2, and PM2.5 at stations T31 and T17 are higher than station T39. However, the Proponent notes that station T31 is influenced by the airport, and station T17 in Richmond is influenced by local conditions such as vehicle traffic emissions that are not representative of the local area. Based on this analysis, the Proponent concluded that background air quality in the local study area is best represented by station T39.

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The Proponent described an air quality monitoring study that was conducted on Tsawwassen First Nation (TFN) lands as part of a joint initiative between the Proponent, Metro Vancouver, Westshore Terminals and TFN. The Proponent indicated that data for the study was collected by three mobile air quality monitoring units (MAMUs) that were deployed at two locations on TFN lands over three two-month periods (fall 2014, spring 2015, and summer 2015). The MAMUs were placed at two different locations on TFN lands, one near the wastewater treatment plant and the other at Tsatsu Shores. In order to analyze the data from the TFN study and compare to station T39, the Proponent averaged the wind rose for the MAMU over its two locations. The meteorological observations at the two TFN locations (wind speed and direction) were compared to the ECCC Tsawwassen weather station at the BC Ferry Terminal but were not compared to station T39. The Proponent concluded that station T39 provided a reasonably accurate representation of the air quality levels on TFN lands and the Project area. The Proponent further concluded that the 98th percentile background concentrations were not biased by the use of 2010-2012 data in the assessment.

The Proponent also provided a comparison of data at station T39 between the 2010- 2012 and 2010-2016 monitoring periods and concluded that overall air quality concentrations at station T39 did not change appreciably over recent years with the exception of SO2. In regard to the analysis of PM2.5 concentrations, the Proponent concluded that while PM2.5 concentrations increased in recent years, the increase did not change the conclusions of the air quality assessment for the Project.

ECCC Conclusions

ECCC does not support the Proponent’s conclusion that station T31 and T17 are not representative of the local area as they are influenced by urban sources, and therefore not included in the analysis of background air quality. ECCC is of the view that data from station T17 is representative, and should be included in the Proponent’s analysis. A vast area of the modelling domain is urban and therefore background concentrations for the air quality assessment should be determined from more than one monitoring location, and preferably locations that represent an urban environment.

In comparing to measurements on TFN lands, the analysis conducted by the Proponent assumed that the two locations of monitoring have the same meteorology. Averaging data between the two locations may not be appropriate especially as the two monitoring locations on TFN lands are potentially subject to different meteorological conditions and are for different time periods. The Tsatsu Shores site is less than 300 m from the base of a bluff approximately 50 m high, whereas the wastewater treatment plant site is surrounded by flatter terrain. Furthermore, the meteorological observations at the two TFN locations (wind speed and direction) were compared to the ECCC Tsawwassen weather station at the BC Ferry Terminal but were not compared to station T39. The comparison of meteorological observations between ECCC’s weather station at the BC Ferry Terminal and the MAMU only included wind speed and direction; the analysis did not include temperature or a comparison to station T39. In ECCC’s view, the analysis and comparison of TFN monitoring data to station T39 is incomplete and ECCC cannot verify the Proponent’s conclusion that station T39 data is representative of air quality on TFN lands.

The Proponent did an analysis of the 2010-2012 and 2010-2016 monitoring periods at T39 and concluded that only SO2 changed between those two periods. This could be attributed to the reduction of SO2

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emissions as a result of the implementation of the North American Emission Control Area (ECA). Since the ECA was already implemented during the assessment it would be more appropriate to use background SO2 data that reflects the existing post-ECA environment in this assessment.

In the Proponent’s analysis of the station T39 data for the 2010-2012 and 2010-2016 periods, PM2.5 concentrations appeared to increase. As noted in section 3.1 above, Metro Vancouver switched the PM2.5 monitor from a TEOM monitor to a SHARP monitor in 2013. Studies have found that the TEOM instruments under-report particulate concentrations when compared to other instruments, especially when the air contains a considerable amount of semi-volatile particulates. A portion of the semi-volatile particulate can be lost due to the heating of the sample in the TEOM making the under-reporting most prevalent during colder temperatures. The Canadian Environmental Sustainability Indicators: Data Sources and Methods for the Air Quality Indicators (ECCC 20148) describe the under-reporting nature of TEOM instruments. The Proponent did not consider this under-reporting in their analysis and therefore, the use of 2010-2012 PM2.5 concentrations from station T39 may under-represent the PM2.5 in the region. The Proponent noted that, according to the updated data, the 98th percentile values for PM2.5 over the last few years have decreased. It is unclear to ECCC if this assessment is accurate.

Summary

For appropriate determination of background air quality, ECCC is of the view that the following information should be included in the analysis of background:

• Given that the mean and 98th percentile concentrations of NO2 measured at station T17 (Richmond South) are higher than those at station T39, and the Richmond South station is representative, both stations should be incorporated into the analysis of background pollution.

• As a means of presenting a more accurate characterization of ambient conditions on TFN lands, a wind rose using combined data from both the Metro Vancouver and Westshore MAMUs for both the Tsatsu Shores and wastewater treatment plant locations should be included in the analysis.

• Given that SO2 and PM2.5 concentrations change in more recent years, these changes should be reflected in the determination of background.

Recommendations to the Review Panel ECCC is of the view that the above analysis is required in order to determine the appropriate background for the Project. The background value should be determined using more than one air quality station, a more complete analysis of differences between monitoring stations, and more recent data particularly given recent changes in emission controls and monitoring technology.

8 http://www.ec.gc.ca/indicateurs-indicators/default.asp?lang=en&n=BA9D8D27-1.

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3.5 Marine Emissions Introduction ECCC’s role is to provide expert technical and scientific support to Transport Canada relating to air pollutant and greenhouse gas emissions from marine shipping under the Government’s Clean Transportation Initiative. ECCC also administers the regulation of the quality of fuel used by the marine sector, in support of Transport Canada’s implementation of the North American ECA. In addition, ECCC produces the National Marine Emissions Inventory Tool (MEIT), which is a database of marine emissions from all commercial vessels operating in Canadian waters, based on 2015 activity data, and is updated on an on-going basis.

Marine vessels are a potentially important source of criteria air contaminants from fuel combustion in their main engines, auxiliary engines, and boilers particularly NOx, SOx, particulate matter (PM), and volatile organic compounds. Fuel combustion in engines and boilers of marine vessels also results in emissions of greenhouse gases (GHGs).


In response to Review Panel IR6-18, the Proponent provided the percentage of ships, broken down by ship type, that were assumed to have NOx Tier III engines in the marine emissions estimates for both the EIS and Marine Shipping Addendum assessments and compare them to what was assumed for Project-associated container ships. The Proponent assumed that all of the merchant vessels and container ships will be Tier III complaint by 2030. Specifically, the Proponent states “by 2030, only the occasional ship calling at Roberts Bank is likely to be more than 20 years old and not subject to newer, more stringent emission standards”.

ECCC Conclusions

The Proponent in their analysis assumed that 91% of container ships would be Tier III compliant by 2030. ECCC did not accept the Proponent’s assumptions for the rate of introduction of Tier III compliant vessels. ECCC continues to believe that the Proponent’s assumption is overly optimistic and should be revised to account for new information on the rate of introduction of Tier III compliant vessels into the fleet.

ECCC’s previous methodology for predicting the introduction of Tier III vessels assumed that the distribution of vessel ages would remain constant for each vessel type in future years. In earlier analysis, ECCC had assumed that new vessels starting in 2016 would be Tier III compliant. Using this as a base assumption, ECCC had predicted that 54% of all merchant vessels and 78% of container ships would be Tier III compliant by 2030. ECCC has recently learned that the actual rate of introduction of Tier III vessels is much slower that previously assumed and this will affect the proportion of vessels meeting the Tier III standard, and thus ship-source NOx emissions for 2030.

MARPOL Annex VI, Regulation 13 requires that vessels constructed after January 1st, 2016 and operating in an Emission Control Area be NOx Tier III compliant. ECCC recently learned that the definition for newly

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constructed vessels for the purpose of the International Maritime Organization (IMO) Tier III NOx standard is based on the date the keel was laid for the new ship, rather than the date the ship is brought into service. ECCC is aware of many new vessels that were brought into service well after January 1st, 2016 but with keels laid prior to this time, which do not need to meet the Tier III requirements. It is ECCC’s understanding that there have been very few, if any, visits to the Port of Vancouver to date by ships confirmed to meeting the Tier III standard.

ECCC has further investigated the number of keels laid globally in the 2009-2018 period in order to re-evaluate our previous forecasts for the rate of introduction of Tier III NOx compliant vessels. Table 2 shows that there was an unusually high number of keels laid in 2015, and very few between 2016-2018.

Table 2: ECCC Analysis of Number of Keels Laid Globally by Year9

This suggests that there will be fewer vessels than previously forecasted meeting the definition of “newly constructed” after 2016 for the purpose of the Tier III NOx standard. As a result, ECCC now estimates that <1% of vessel calls at the Port of Vancouver in 2020 will be Tier III compliant. We are working on revised emissions projections for 2030, but our preliminary forecast is that <40% of vessel calls will be Tier III compliant in 2030. In contrast, the Proponent’s methodology for forecasting Tier III resulted in an estimate of 25% of containerships meeting Tier III in 2018 (according to Figure IR6-18-2). In reality, during 2018 there were close to zero ships that met Tier III that called to the Port of Vancouver.

This new information may have a significant impact on the NOx emissions estimates. ECCC concludes that the NOx emission rates from marine shipping for the future conditions is underestimated and therefore the NO2 predictions for marine shipping are underestimated.

9 https://maritime.ihs.com Table 2 reflects ECCC analysis of data generated by IHS Markit

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Further, the Proponent modelled bulk carriers and container ships while at berth and maneuvering, but did not consider these vessel types underway in the Strait of Georgia, advising that these would be captured by the background ambient data. The number of commercial vessels operating within the Strait of Georgia is expected to increase, and ambient data will not reflect emission increases from future but foreseeable marine traffic. Therefore, in ECCC’s view the Proponent has further underestimated the emissions from marine shipping by not including the vessels underway in the maximum worst case 1-hour emissions estimates and air quality modelling. The Proponent’s NO2 predictions, which assumes 91% of vessels meeting Tier III and does not account for increased emissions from ships underway, are greater than the CAAQS over the majority of the study area. ECCC is of the view that this exceedance of the CAAQS is greatly underestimated.

Recommendations to the Review Panel ECCC recommends that more realistic assumptions of the rate of introduction of Tier III vessels and marine emissions from ships underway in the Strait of Georgia be included in the assessment. ECCC is of the view that this information is necessary to assess the contribution of emissions resulting from marine shipping associated with the Project.

3.6 Locomotive Emission Rates Introduction Given that NO2 predictions are above the CAAQS for the majority of the study area for the Project’s air quality assessment, correctly accounting for all NO2 and other emissions is important for determination of effects and identifying appropriate mitigation measures.


With respect to locomotive emissions, the Proponent concludes that the assumption that 100% of the switcher locomotives would meet Tier I emissions standards by 2025 is considered to be realistic as it is based on regulations and trends in fleet turnover as documented by the Railway Association of Canada.

ECCC Conclusions

In ECCC’s previous comments to the Panel on the Proponent’s assessment of locomotive emissions (CEAR 1346), it was noted that there were no Tier I or higher yard switchers in Canada in 2015 according to the Railway Association of Canada. Further, according to the United States (US) EPA, the emission factor for uncontrolled switch locomotives (17.40g/bhp for NOx and 0.44 g/bhp-h for PM) is significantly higher than the Tier I emission factor that the Proponent used for emission calculations and modelling. In ECCC’s view, the Proponent has not used appropriate assumptions in their modelling of locomotive emissions, particularly as it is unlikely that 100% of the switch locomotives will meet Tier I in 2025.

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Recommendations to the Review Panel ECCC continues to recommend reassessing the locomotive emissions with a more conservative assumption of Tier levels to reflect the current and expected near term (2025) fleet of yard switcher locomotives in Canada. As indicated in section 3.1 above, the predicted NO2 concentrations are above the CAAQS over the majority of the study area. As ECCC notes, the Proponent has not used appropriate assumptions for calculating locomotive emissions and therefore NOx emissions are underestimated, which leads to the potential for NO2 predictions to be underestimated as well.

3.7 Cargo Handling Equipment Emissions Introduction New compression ignition engines used in off road diesel engines are regulated via the Off-Road Compression Ignition Engine Emission Regulations under CEPA, which set progressively more stringent standards for air pollutant emissions. These emission standards are broken down into tiers, with more stringent standards applying as time goes by. By the end of 2021, only engines meeting final Tier IV emission standards will be admissible for importation.

The Proponent has assumed that all diesel engine cargo handling equipment will have Tier IV engines. While it is true that Tier IV engines will be widely available at that time, engines which were manufactured prior to the full implementation of final Tier IV standards at the end of 2021 would be available during the life of the Project and would meet less stringent standards.

Since NO2 predictions are above the CAAQS for the majority of the study area for the Project’s air quality assessment, correctly accounting for all NO2 and other emissions is important for the determination of effects to air quality from the Project.


The Proponent’s air quality assessment assumed existing cranes at Deltaport were diesel-powered and any new cranes bought would be electric. The Proponent noted some cranes at RBT2 (ship-to-shore gantry cranes, container yard automatic stacking cranes, and intermodal yard rail-mounted gantry cranes) would be electrified from the onset of operations. The Proponent assumed that other equipment is diesel- powered and meet Tier IV standards for the lifetime of the operations phase.

The Proponent noted that once cranes reached the end of their useful life at Deltaport they were assumed to be replaced with electric cranes. This assumption was based on feedback provided by the operator. The Proponent indicated that Deltaport now has a new operator and plans related to the timing of replacement of cranes at Deltaport were not available. The Proponent indicated the assessment was still realistic because of other conservative assumptions, such as assuming a 24-hour emission scenario with no down time for the cargo handling equipment.

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ECCC Conclusions

It should be noted that Tier IV standards will not be fully phased in until 2021 (i.e. equipment with a model year of 2022 or later must meet final Tier IV emission standards in order to be admissible for importation). Older equipment that meet less stringent standards will be available on the market. The Proponent has not described the implications for the air quality predictions if Tier IV cargo handling equipment are unable to be purchased once it has reached the end of their life.

Recommendations to the Review Panel ECCC recommends that:

• Where practicable, the Proponent should select equipment with low emissions that meet the latest applicable Canadian emissions standards and guidelines.

• The Proponent should not remove emission control technologies from off-road equipment.

• The Proponent should implement an emission control technology maintenance program, which may include combined use of individual equipment fuel usage indicators, equipment emission testing, and electronic diagnosis techniques to trigger maintenance.

• The Proponent should also provide employee training on minimizing off-road equipment idling and the importance of avoiding tampering with emissions control systems.

• The Proponent commit to meeting the most stringent emission standards and turn equipment over to electric as soon as feasible.

CHAPTER 4: Coastal Birds Assessment 4.1 Biofilm and Shorebirds Introduction Species that migrate in large numbers rely on key stopover sites to congregate and replenish fuel supplies, and the loss or degradation of such habitats can have a disproportionate effect on a population’s viability, and in theory, lead to rapid extinction (Weber et al. 1999). For example, migratory shorebirds using the East Asian–Australasian Flyway have experienced severe population declines since the 1990s, and habitat loss at important stopover sites in the Yellow Sea are implicated as a key contributing factor (Studds et al. 2017). Roberts Bank is internationally recognized as a migratory stopover area for shorebirds and as an overwintering site for hundreds of thousands of waterfowl and shorebirds. This area is the most important site for shorebirds in the Fraser River estuary and delta. The Fraser River estuary is a Site of Hemispheric Importance in the Western Hemispheric Shorebird Reserve Network and designated as an “Important Bird Area” by BirdLife International. The Alaksen National Wildlife Area and George C. Reifel Migratory Bird Sanctuary and provincial Wildlife Management Areas were established over portions of the Fraser River estuary to protect and conserve birds. Western Sandpipers (Calidris mauri, WESA) are the most abundant shorebird on Roberts Bank, followed by Pacific Dunlin (Calidris alpina pacifica, DUNL). The entire global population of Western Sandpipers, approximately 3.5 million

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birds, migrates northward along the Pacific Flyway to their Arctic breeding grounds; an estimated 42%–64% of these birds rely on Roberts Bank to refuel (Drever et al. 2014). Given that the next major stopover (the Stikine River Estuary) along the Pacific Flyway migratory flyway is more than 850 km away, the Fraser River estuary provides a critical link in the chain of stopover sites during shorebird migration.

Food availability at stopover sites and deposition of fat reserves are essential for shorebirds making long-distance migrations (Newton 2006). Biofilm is now known to be a major food resource for shorebirds worldwide (Kuwae et al. 2012; Mathot et al. 2018), a discovery that was first made on Roberts Bank (Elner et al. 2005). Biofilm comprises a thin layer (~0.01–2 mm) of microbes, organic detritus, benthic invertebrates (meiofauna) and sediment bound together by extracellular polymeric substances secreted by diatoms and bacteria that forms over the intertidal area. A Western Sandpiper may consume 190g of biofilm per day (7 times its body weight), and estimates are that biofilm, on average, accounts for 45-59% of the total diet or 50% of their daily energy budget (Kuwae et al. 2008). Fatty acids, especially Polyunsaturated Fatty Acids (PUFA), produced by diatoms in biofilm appear critical to migrating shorebirds (see Mathot et al. 2018 for review). Uptake occurs by shorebirds grazing biofilm directly, or indirectly through consumption of invertebrates that have grazed diatoms. Diatoms have two distinct growth phases (Schwenk et al. 2013): a normal exponential growth rate with carbohydrate production that depends on available nutrients, light, temperature, and salinity (Smith and Underwood 2000); and a stationary growth phase where diatoms rapidly synthesise lipids (fatty acids). This second growth phase is triggered when diatoms experience sudden changes in nutrient levels (e.g., nitrogen or silica), salinity (Pal et al. 2013), or other environmental stressors (Sharma et al. 2012). The rapid physical and chemical oscillations associated with springtime on Roberts Bank are mechanisms linking the abundance of diatoms in intertidal biofilm with high fatty acid production. Given the importance of fatty acids as fuel for migrating birds (McWilliams et al. 2004), the capacity of Roberts Bank to furnish these essential nutrients is directly tied to its importance as a stopover site.

Fatty acid production by microalgae is a fundamental driver of ecological processes (Colombo et al. 2017), and inducing lipid production in diatoms is a topic of industrial interest (Hildebrand et al. 2012, Levitan et al. 2014, Schnurr and Allen 2015, Adarme-Vega et al. 2016). Fatty acids provide a high energy, low weight fuel for migrating sandpipers (Jenni and Jenni-Eiermann 1998, Guglielmo et al. 1998, Egeler and Williams 2000, Guglielmo 2010). Elevated levels of PUFA (particularly Eicosapentaenoic acid (EPA) and Docosahexaenoic acid (DHA)) in biofilm on Roberts Bank in spring coincide with the arrival of Western Sandpipers on northward migration (Schnurr et al. in review; Drever et al. 2014), and such fatty acids can increase peak performance of birds (Price 2010). Although invertebrates have been shown to make the Δ12 and Δ15 desaturase enzymes necessary for short chain PUFA synthesis (Kabeya et al. 2018; Monroig and Kabeya 2018), birds are not known to have this ability (Viegas et al. 2017) and need to acquire these essential PUFAs ‘pre-formed’ in their diets. Consumption of PUFA has various beneficial effects. PUFA are considered to act as performance-enhancing nutrients to prime flight muscles of birds for long-distance flights by eliciting physiological responses to mobilize the transport of fuel across cellular membranes (Maillet and Weber 2006; 2007; Weber 2009). Semipalmated Sandpipers (Calidris pusilla), a species closely related to Western Sandpiper, fed diets high in EPA and DHA showed increased activity of key muscle enzymes to upregulate energy metabolism for prolonged flight (Maillet and Weber 2007). Further, EPA (which is abundant in diatoms) is a precursor for anti-inflammatory eicosanoids and may facilitate muscle

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recovery after strenuous migration (Price 2010). Since shorebirds cannot produce short-chain PUFA independently, and only make EPA and DHA from shorter-chain PUFA with limited efficiency, they need to ingest PUFA pre-formed in their diet. Therefore, the availability of PUFA in biofilm links habitat quality to migratory performance. Further, the roles of DHA and EPA in development and reproduction in vertebrates indicate that negative carryover effects would result if the quantity and/or quality of biofilm at a migratory stopover site were compromised (for example, Budge et al. 2014; Hixson et al. 2015).

Importance of the Topic to the Environmental Assessment

Biofilm covers all intertidal flats of the Fraser River estueary, but the high-PUFA biofilm grazed by shorebirds is restricted to muddy upper intertidal areas with an estuarine influence (Kuwae et al. 2008). WESA grazing is most intensive on the mudflats off Brunswick Point and the high intertidal zones of Roberts Bank, indicating birds are focussing in on fatty acid-rich patches of biofilm.

The EIS shows that the Project would result in a direct, permanent loss of 2.5 ha of biofilm, representing 0.8% of the total biofilm area, and could indirectly affect productivity and availability of the remaining biofilm grazed by shorebirds on Roberts Bank (up to 291.3 ha10) by permanently altering the salinity regime. Hydrological modelling by the Proponent predicts that the Project would increase the freshwater influence by trapping freshwater from the Fraser River and reducing mixing with seawater, thus changing the salinity regime and reducing salinity over Roberts Bank on average by -3.5 to -5.6 PSU during shorebird spring migration. ECCC predicts that the change in the salinity regime would affect biofilm productivity and distribution on Roberts Bank, with implications to Western Sandpipers and shorebirds generally (see Appendix 7).


In addition to the EIS, the Proponent completed three annual field studies assessing intertidal biofilm on Roberts Bank. The Proponent concluded predicted changes in salinity are not expected to result in significant adverse effects11 on biofilm or the availability or quality of food available to migrating Western Sandpipers. Based on the EIS and subsequent 2016-2018 biofilm studies, key Proponent conclusions regarding Project-induced changes to the salinity regime on biofilm and Western Sandpipers are as follows:

1. Biofilm at Roberts Bank is not limiting for Western Sandpipers;

2. The Project would not adversely affect the quantity and quality of food available to Western Sandpipers and other shorebirds;

10 Sum of area of biofilm-dominated sediments within the Local Assessment Area (Upper Intertidal, Mid-Intertidal, Lower Intertidal, Canoe Passage zones) 11 As advised by the Proponent in its January 11, 2019 covering letter to Mme. Beaudet, Review Panel Chair, and on pages vii and 85 of the 2018 Biofilm report (CEAR 1385)

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3. Biofilm productivity with the Project in place is predicted to increase within the Brunswick Stratum, demonstrate no response to changing salinity within the Intertidal Stratum, and not be affected within the Canoe Passage Stratum due to predicted negligible changes in salinity for this area;

4. Biofilm at Roberts Bank are adapted to dynamic estuarine conditions, including a highly variable salinity regime, with comparably high biofilm fatty acid and carbohydrate levels annually documented in both freshwater (Canoe Passage) and marine/brackish habitats (Intertidal Stratum) during the three years of the 2016-2018 study program; and

5. The Project is not predicted to result in significant adverse effects on biofilm or affect the availability or quality of food available to northward migrating Western Sandpipers. Results from this additional work (2016-2018 biofilm studies) have reduced uncertainty concerning adverse effects from the proposed Project and strengthen the EIS conclusions.

ECCC Conclusions

ECCC finds that the Project would disrupt or remove the salinity trigger responsible for initiating fatty acid production in biofilm on Roberts Bank (see Appendix 7). Associated risks are that the EIS predicts12 a shift from the current biofilm community dominated by marine-type diatoms to a predominantly freshwater-type biofilm community. Freshwater-type diatoms are smaller and less productive (WorleyParsons 2015), and have lower abundances of fatty acids (Galloway and Winder 2015). Further, the EIS predicts that the biofilm would shift to lower elevations in the intertidal (EIS, Appendix 10-C, Figures 3-47 and 3-49; and Appendix 15-B, Figures 8 and 36). The coarser sediment of these lower elevation areas would render the associated biofilm inaccessible to grazing by Western Sandpipers as their grazing structures are restricted to fine sediment (Elner et al. 2005, Jimenez et al. 2015).

The Proponent’s conclusions regarding predicted Project effects on biofilm are not supported in their analysis, and their conclusions are made with insufficient consideration of ecological mechanisms underlying the production of fatty acids. ECCC disagrees with the interpretation of results, and finds the Proponent’s conclusions do not incorporate current understanding of the ecological drivers of biofilm-based fatty acid production and shorebird migration. Accordingly, ECCC is of the view that the Proponent’s statement that biofilm at Roberts Bank would continue to be capable of supporting migrating Western Sandpipers with the Project in place is not supported by the best available evidence. More than 70% of the foraging use by Western Sandpipers on the Fraser River estuary occurs on Roberts Bank (Hemmera 2014), where the sediments are finer and less sandy than at Boundary Bay and Sturgeon Banks (Luternuaer and Murray 1973, Kellerhals and Murray 1969). There is no known way to recreate the habitat found at Roberts Bank, as acknowledged by the Proponent and stated in previous submissions by ECCC. Therefore, reductions in food supply at Roberts Bank would not be offset by increases at other sites on the Fraser River estuary. Further, the capacity to support migrating birds is a function of supply versus demand. The difference between supply (of biofilm) and demand (by shorebirds) was considered in the

12 EIS, Volume 3, Section 11 Marine Vegetation Effects Assessment, 11.6.3.5 Biofilm

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EIS (Biofilm and Infauna Capacity Calculations), and ECCC has previously described13 concerns with those analyses. The 2016-2018 reports on biofilm have not addressed these key shortcomings, and ECCC’s concerns remain.

The Proponent’s position is that the results from their latest field work ‘reduces uncertainty concerning effects from the proposed project and strengthens conclusions regarding the likelihood of no significant adverse effects to biofilm or Western Sandpipers as reported in the EIS’. ECCC is of the view that the latest fieldwork may reduce the uncertainty around how Roberts Bank provides nutrients for migrating birds, but it strengthens the science around the likelihood and the potential severity of adverse effects to biofilm and Western Sandpipers (see Appendix 7).

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 representative of current salinity regimes on any of Canoe Passage, Brunswick Point or Roberts Bank situations. By effecting these changes in the salinity regime, the Project would alter or remove altogether the salinity trigger responsible for initiating high fatty acid production in biofilm over Roberts Bank. The consequential risk is a markedly reduced quality of biofilm associated with the current muddy, upper intertidal areas.

The EIS predicts14 that biofilm that consists primarily of marine-type diatoms would be replaced by biofilm made up of mostly freshwater-type diatom species. Freshwater-type diatoms tend to have lower abundances of critical fatty acids (Galloway and Winder 2015), and therefore are likely of less nutritional value to Western Sandpipers and to shorebirds more generally. Further, the EIS predicts that the biofilm community would shift spatially to lower elevations in the intertidal zones. The generally coarser sediment of lower elevation areas would render the associated biofilm inaccessible to grazing by Western Sandpipers. The tongues of Western Sandpipers are adapted to grazing on fine sediments, and lose their functionality on coarse sediments (Elner et al. 2005, Jimenez et al. 2015).

Other evidence of potential Project effects may be found in the response of shorebird abundance to freshwater inputs to the site, as counts of Western Sandpipers are negatively correlated to discharge rates of the Fraser River (see Appendix 7, Figure 7.3). After correcting for strong daily variation in counts of Western Sandpipers at the site (Drever et al. 2014), lower numbers of Western Sandpipers are observed at Roberts Bank during days and years with larger discharges. Where these sandpipers divert to during these conditions of high discharge rates from the Fraser River and how this displacement affects their migration are unknown, but the presumption is that the consequences would be adverse. Further studies of movements of shorebirds are needed to resolve this uncertainty. Overall, given that the Project is

13 ECCC’s Sufficiency Review of the EIS (CEAR 581) 14 EIS, Volume 3, Section 11 Marine Vegetation Effects Assessment, 11.6.3.5 Biofilm

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predicted to accentuate the effects of the Fraser River freshet on the mudflat habitat, lower numbers of sandpipers would be expected.

Overall, ECCC continues to provide the following expert information:

i. Not all intertidal biofilm can be considered to be of equal value to shorebirds.

ii. The Project would likely compromise the ecological mechanisms responsible for biofilm producing fatty acids required by migrating shorebirds.

iii. The projected change in the salinity regime associated with the Project presents a high risk of reducing the quality and quantity of marine-type biofilm with high fatty acid content that is available to Western Sandpipers, and shorebirds generally, during northward migration to their breeding grounds.

iv. Those impacts would have serious consequences for many shorebirds, and Western Sandpiper in particular.

Predicted Effectiveness of Proposed Mitigation Measures

The Proponent maintains that the Project would not have adverse effects given the high natural variability of the existing system and a surplus of biofilm. ECCC disagrees with the Proponent’s assessments of the nature and scope of the potential changes to biofilm productivity on the muddy intertidal of Roberts Bank because mechanisms for production of diatoms of dietary value to shorebirds would be disrupted (see Appendix 7).

In addition to the direct loss of 2.5 ha of intertidal mudflats associated with the widened causeway associated with the Project, the indirect effects of the RBT2 terminal structure pose a risk to the ecological function of the biofilm community over the entire intertidal of the Local Assessment Area (LAA) due to the changes in salinity and predicted location of biofilm. Effective mitigation of both the direct and indirect effects to biofilm would necessitate engineering the replacement of, at least, an equal area of biofilm bearing mudflats (558 hectares is generally categorized as mud), comprised of fine silt over a deep anoxic layer, and also replication of the particular set of conditions necessary for biofilm grazed on by shorebirds. There are no known measures to mitigate changes in biofilm assemblage composition that may result from changes in salinity15.

Large-scale re-creation of mudflats with biofilm of a type that supports shorebirds is without precedent, and ECCC is of the view that currently there is no way to create high quality biofilm habitat. In addition, the proposed location of the mudflat offset is not an area where Western Sandpipers are presently observed in high numbers, and therefore, Western Sandpipers use of the proposed offset site would therefore likely be low. Furthermore, mudflats near the expanded causeway structure may be avoided by shorebirds due to predator avoidance behaviour (the danger of falcon attacks).

15 EIS, Volume 3, Section 11 Marine Vegetation Effects Assessment, 11.7 Mitigation Measures

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Appropriateness of Proposed Follow-up Programs

The Proponent has committed to a ‘Follow-up Program to verify the effects prediction by monitoring western sandpiper [sic] prey availability, specifically biofilm and benthic invertebrates to address ECCC’s concerns in the prediction of negligible residual effects to shorebirds, most notably western sandpipers’.

While the proposed follow-up program would provide monitoring and data, ECCC does not support the Proponents proposed Follow-up Monitoring Program because the predicted Project effects on biofilm are not mitigatable. ECCC finds that Project effects on biofilm would likely be immediate and irreversible.

Recommendations to the Review Panel Further to ECCC’s previous advice16, ECCC is of the view that the Project would likely result in adverse effects to biofilm with major, unmitigable consequences for shorebirds, Western Sandpipers in particular. The Project would likely reduce the quality and quantity of fatty acids provided by biofilm on the intertidal mudflats of Roberts Bank to migratory shorebirds. ECCC maintains that predicted Project-induced changes to Roberts Bank constitute an unmitigable species-level risk to Western Sandpipers, and shorebirds more generally, due to the predicted disruption to the salinity regime that supports fatty acid production from biofilm. Given the high shorebird usage at Roberts Bank, even low probability events carry a high risk because nutrient shortfalls during breeding migration could have species-level consequences. Also, the proposed offsetting measures on Roberts Bank are not adequate to address the potential impacts. Due to what ECCC believes to be high and unmitigable risks to an entire species of migratory shorebird, ECCC advises that only a Project redesign17 would avoid geomorphological processes on Roberts Bank impacting biofilm and shorebirds.

Summary of criteria used to characterize effects on biofilm and shorebirds

Criteria Characterization Rationale for Characterization

Magnitude High Changes to the ecological processes that result in the production of fatty acids within biofilm would result in a reduction of quality and quantity of fatty acids during a critical period in the life cycle of Western Sandpipers.

Extent Local/National Local for biofilm: Effects are predicted to occur throughout the LAA.

National for shorebirds: Given the LAA is the most important stopover site for Western Sandpipers and other shorebirds in Pacific Canada, a reduction in the

16 ECCC’s Sufficiency Review of the EIS (CEAR 581), and ECCC response to Review Panel IR-09 and IR-10 (CEAR 1146) 17 ECCC response to Review Panel IR-10 (CEAR 1146)

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food supply can be expected to affect a large proportion of the species (up to 64%) in Canada and globally.

Duration Permanent Changes to the hydrological regime would become fixed once construction is complete.

Reversibility Irreversible Changes to the hydrological regime would become fixed once construction is complete. The absence of options to create high quality biofilm habitat means habitat loss will be permanent.

Frequency Continuous Changes to the hydrological regime would become fixed and year-round once construction is complete.

Confidence Moderate This view is supported by ECCC field studies, a review of studies conducted by the Proponent, and experimental evidence contained in the scientific literature on the production of fatty acids by microalgae.

References

Adarme-Vega, T. C., Lim, D. K., Timmins, M., Vernen, F., Li, Y., & Schenk, P. M. (2012). Microalgal biofactories: a promising approach towards sustainable omega-3 fatty acid production. Microbial cell factories 11: 96.

Budge, S.M., Devred, E., Forget, H-E, Stuart, V., Trzcinski, M.K., Sathyendranath, S. & Platt, T. (2014) Estimating concentrations of essential omega-3 fatty acids in the ocean: supply and demand. ICES Journal of Marine Science 71: 1885–1893.

Colombo, S.M., Wacker, A., Parrish, C.C., Kainz, M.J., & Arts, M.T. (2017). A fundamental dichotomy in long-chain polyunsaturated fatty acid abundance between and within marine and terrestrial ecosystems. Environmental Reviews 25: 163-174.

Drever, M.C., Lemon, M.J., Butler, R.W., & Millikin, R.L. (2014). Monitoring populations of Western Sandpipers and Pacific Dunlins during northward migration on the Fraser River Delta, British Columbia, 1991–2013. Journal of Field Ornithology 85:10-22.

Egeler, O., & Williams, T. D. (2000). Seasonal, age, and sex-related variation in fatty-acid composition of depot fat in relation to migration in western sandpipers. The Auk 117: 110—119.

Elner, R.W., Beninger, P.G., Jackson, D.L., & Potter, T.M. (2005). Evidence of a new feeding mode in western sandpiper (Calidris mauri) and dunlin (Calidris alpina) based on bill and tongue morphology and ultrastructure. Marine Biology 146: 1223–1234.

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Galloway A.W.E., & Winder, M. (2015). Partitioning the relative importance of phylogeny and environmental conditions on phytoplankton fatty acids. PLoS ONE 10(6): e0130053.

Guglielmo, C. G. (2010). Move that fatty acid: fuel selection and transport in migratory birds and bats. Integrative and Comparative Biology 50: 336–345.

Guglielmo, C. G., Haunerland, N. H., & Williams, T. D. (1998). Fatty acid binding protein, a major protein in the flight muscle of migrating western sandpipers. Comparative Biochemistry and Physiology Part B: Biochemistry and Molecular Biology 119: 549-555.

Hemmera, 2014. Roberts Bank Terminal 2 Technical Data Report: Abundance and Distribution of Overwintering Shorebirds in the Fraser River Estuary. Port Metro Vancouver, Vancouver, BC.

Hildebrand, M., Davis, A. K., Smith, S. R., Traller, J. C., & Abbriano, R. (2012). The place of diatoms in the biofuels industry. Biofuels 3: 221-240.

Hixson, S.M., Sharma B., Kainz M.J., Wacker A., & Arts M.T. (2015) Production, distribution, and abundance of long-chain omega-3 polyunsaturated fatty acids: a fundamental dichotomy between freshwater and terrestrial ecosystems. Environmental Reviews 23: 414-424.

Jenni, L., & Jenni-Eiermann, S. (1998). Fuel supply and metabolic constraints in migrating birds. Journal of Avian Biology 29: 521-528.

Jiménez, A., Elner, R.W., Favaro, C., Rickards, K., & Ydenberg, R.C. (2015). Intertidal biofilm distribution underpins differential tide-following behavior of two sandpiper species (Calidris mauri and Calidris alpina) during northward migration. Estuarine, Coastal and Shelf Science 155: 8-16.

Kabeya, N., Fonseca, M.M., Ferrier, D.E.K., Navarro, J.C., Bay, L.K., Francis, D.S., Tocher, D.R., Castro, L.F., Monroig, O. (2018). Generes for de novo biosynthesis of omega-3 polyunsaturated fatty acids are widespread in animals. Science Advances 4:1-8.

Kellerhals, P., & Murray, J. W. (1969). Tidal flats at Boundary Bay, Fraser River delta, British Columbia. Bulletin of Canadian Petroleum Geology 17: 67-91.Kuwae, T., Beninger, P.G., Decottignies, P., Mathot, K.J., Lund, D.R. & Elner, R.W. (2008). Biofilm grazing in a higher vertebrate: the western sandpiper. Ecology 89: 599 - 606.

Kuwae, T., Beninger, P. G., Decottignies, P., Mathot, K. J., Lund, D. R., & Elner, R. W. (2008). Biofilm grazing in a higher vertebrate: the western sandpiper, Calidris mauri. Ecology 89: 599-606.

Kuwae, T., E. Miyoshi, S. Hosokawa, K. Ichimi, J. Hosoya, T. Amano, T. Moriya, R. C. Ydenberg, & R.W. Elner (2012). Variable and complex food web structures revealed by exploring missing trophic links between birds and biofilm. Ecology Letters 10.1111/j.1461-0248.2012.01744.x.

Levitan, O., Dinamarca, J., Hochman, G., & Falkowski, P. G. (2014). Diatoms: a fossil fuel of the future. Trends in biotechnology 32: 117-124.

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Luternauer, J. L., & Murray, J. W. (1973). Sedimentation on the western delta-front of the Fraser River, British Columbia. Canadian Journal of Earth Sciences 10: 1642-1663.Maillet, D., & Weber, J. M. (2006). Performance-enhancing role of dietary fatty acids in a long-distance migrant shorebird: the semipalmated sandpiper. Journal of Experimental Biology 209:2686-2695.

Maillet, D., & Weber, J. M. (2007). Relationship between n-3 PUFA content and energy metabolism in the flight muscles of a migrating shorebird: evidence for natural doping. Journal of Experimental Biology 210:413-420.

McWilliams, S. R., Guglielmo, C., Pierce, B., & Klaassen, M. (2004). Flying, fasting, and feeding in birds during migration: a nutritional and physiological ecology perspective. Journal of Avian Biology 35: 377-393.

Mathot, K. J., Piersma, T., & Elner, R. W. (2018). Shorebirds as Integrators and Indicators of Mudflat Ecology. In Mudflat Ecology (pp. 309-338). Springer, Cham.

Monroig, O. & Kabeya, N. (2018). Desaturases and elongases involved in polyunsaturated fatty acid biosynthesis in aquatic invertebrates: a comprehensive review. Fisheries Science 84: 911-928.

Newton, I. (2006). Can conditions experienced during migration limit the population levels of birds? Journal of Ornithology 147: 146-166.

Pal, D., Khozin-Goldberg, I., Didi-Cohen, S., Solovchenko, A., Batushansky, A., Kaye, Y., & Boussiba, S. (2013). Growth, lipid production and metabolic adjustments in the euryhaline eustigmatophyte Nannochloropsis oceanica CCALA 804 in response to osmotic downshift. Applied microbiology and biotechnology 97: 8291-8306.

Price, E.R. (2010). Dietary lipid composition and avian migratory flight performance: Development of a theoretical framework for avian fat storage. Comparative Biochemistry and Physiology, Part A. 157:297-309.

Schnurr, P. J., & Allen, D. G. (2015). Factors affecting algae biofilm growth and lipid production: a review. Renewable and Sustainable Energy Reviews 52: 418-429.

Schnurr, P.J., Drever, M.C., Kling H.J., Elner, R.W. & M.T. Arts (in review). Seasonal changes in fatty acid composition of estuarine intertidal biofilm: Implications for Western Sandpiper Migration. Estuarine, Coastal and Shelf Science.

Schwenk, D., Seppälä, J., Spilling, K., Virkki, A., Tamminen, T., Oksman-Caldentey, K. M., & Rischer, H. (2013). Lipid content in 19 brackish and marine microalgae: influence of growth phase, salinity and temperature. Aquatic ecology 47: 415-424.

Sharma, K. K., Schuhmann, H., & Schenk, P. M. (2012). High lipid induction in microalgae for biodiesel production. Energies 5: 1532-1553.

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Smith, D. J., & Underwood, G. J. (2000). The production of extracellular carbohydrates by estuarine benthic diatoms: the effects of growth phase and light and dark treatment. Journal of Phycology 36: 321-333.

Studds, C.E., Kendall, B.E., Murray, N.J., Wilson, H.B., Rogers, D.I., Clemens, R.S., Gosbell, K., Hassell, C.J., Jessop, R., Melville, D.S. & Milton, D.A. (2017). Rapid population decline in migratory shorebirds relying on Yellow Sea tidal mudflats as stopover sites. Nature communications 8: 14895.

Viegas I., Araújo P.M., Rocha A.D., Villegas A, Jones J.G, Ramos J.A, Masero J.A., Alves J.A. (2017). Metabolic plasticity for subcutaneous fat accumulation in a long- distance migratory bird traced by 2H2O. Journal of Experimental Biology 220:1072-1078.

Weber, J.M. (2009). The physiology of long-distance migration: extending the limits of endurance metabolism. The Journal of Experimental Biology 212:593-597.

Weber T.P., Houston, A.I., & Ens, B.J. (1999). Consequences of habitat loss at migratory stopover sites: a theoretical investigation. Journal of Avian Biology 30: 416–26.

WorleyParsons (2015). Roberts Bank Terminal 2 – Technical Data Report: Biofilm Physical Factors. http://www.robertsbankterminal2.com/wp-content/uploads/RBT2-Biofilm-Physical-Factors-TDR1.pdf

4.2 Species at Risk Introduction The ranges of nineteen species listed on Schedule I of SARA, and four species assessed by the Committee on Endangered Wildlife in Canada (COSEWIC), overlap with the Project and marine shipping area18. The majority of these species are migratory birds. ECCC has responsibilities related to the conservation and projection of these species through SARA and the MBCA.

The Fraser River estuary, including Roberts Bank, supports globally significant numbers of Western Grebes, a species listed as ‘Special Concern’ on Schedule I, during the spring, fall, and winter periods. Nationally significant numbers of the Special Concern fannini subspecies of Great Blue Heron occur in the Fraser River estuary, with large numbers observed in the intertidal and shallow subtidal areas of Roberts Bank as well as upland areas. The largest and most significant colony in Canada is located in Tsawwassen, adjacent to the Project area, with a minimum of 462 nests were counted in 2017 (Canadian Wildlife Service of ECCC, unpublished data).

Barn Owl, a species listed as ‘Threatened’ on Schedule I, also occur in nationally significant numbers in terrestrial habitats of the Fraser River estuary, and is subject to recovery planning under SARA. Other federally-listed species that are regularly or periodically observed in the Fraser River estuary, and specifically in and around the Project area, include Barn Swallow (Threatened), Marbled Murrelet (Threatened), Peregrin Falcon (Special Concern), and Short-eared Owl (Special Concern). The remaining species have been observed in the estuary, but occur either infrequently, in very low numbers, or both. Killdeer and Short-billed Dowitcher also occur regularly in the Project area, are identified as high priority

18 ECCC response to Review Panel IR-09 (CEAR 1146)

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candidates for assessment by COSEWIC. Similarly, Long-billed Dowitcher was identified as a mid-priority candidate and has been observed in globally significant numbers19 within the Fraser River estuary.

Vehicular collisions are recognized as a conservation concern at both local and national scales, but are more challenging to address than with other vertebrates (Bennett 1991, Mead 1997, Forman and Alexander 1998, Lode 2000, Harden 2002, Seiler and Helldin 2006, Watts et al. 2007, Leu et al 2008, Kociolek and Clevenger 2011). Based on the historical lack of information regarding the magnitude of bird mortality in Canada due to human-related activities, ECCC undertook a systematic evaluation to determine mortality estimates based on a range of sources (Calvert et al. 2013).

Most birds reported as roadkill in North America are for passerines and owls (for more, see Table 1 in Bishop and Brogan 2013). Adjusted for scavenging, the mortality estimate on Canadian one and two lane roads, outside of urban centers, is 1,167 birds/100 km during the 122 days of the breeding season in Canada (Bishop and Brogan 2013). Clustering of avian roadkill events occur (Slater 2002, Clevenger et al. 2003), and many factors can influence the occurrence of roadkill ‘hotspots’, especially the type of habitat found beside the road (Orlowski 2005, Crispim de Oliveira Ramos et al. 2011, Kociolek and Clevenger 2011, Rosa and Bager 2012). Many studies report seasonal differences in collision rates (for example, Erritzoe et al. 2003, Kociolek and Clevenger 2001), including Barn Owls (for example, Boves and Belthoff 2012, Hindmarch et al. 2014). Barn Owl mortality rates have been shown to increase during winter months.

Effective mitigation is often species-or taxa-specific (Bishop and Brogan 2013). The volume of traffic, speed of vehicles, individual configuration of roads, and road density are the most frequently mentioned factors affecting bird mortality on roads (Clevenger et al. 2003, Erritzoe et al. 2003, Holm and Laursen 2011, Kociolek and Clevenger 2011). Use of obstacles, such as hedgerows, have been recommended to reduce bird collision rates, including for Barn Owls (Ramsden 2003); however, other factors need to be considered to account for unintended effects to non-target species (Bishop and Brogan 2013).


Bird Mortality As stated in the EIS, the Project at full operations is predicted to increase daily port-related truck movements by 100%, train movements by 38%, and other vehicles by 83% (collectively, ‘vehicle’). These projected increases are anticipated to result in increased avian mortality rates relative to baseline conditions. It is well established that Barn Owls are particularly susceptible to vehicles collisions. Barn Owl annual mortality associated with vehicle collisions on 4-lane roads, during the breeding and fledging season in their remaining range in BC, was estimated be 851 owls (Bishop and Brogan 2013). In the provincial ‘Recovery Plan for the Barn Owl in British Columbia’, road mortality from transportation and service corridors was identified as one of the main threats faced by Barn Owls in the province (BC Ministry of Environment 2014).

19 https://www.ibacanada.ca/site.jsp?siteID=BC017

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Of the remaining Schedule I and COSEWIC-assessed species that are observed in the Project area, Short-eared Owl, Barn Swallow, and Killdeer have been documented through carcass surveys of roads in BC (Preston and Powers 2006, Ashley and Robinson 1996).

Habitat Loss Refer to section 4.4 on Wetlands and Wetland Functions for ECCC’s perspective regarding habitat loss in relation to Western Grebes and Great Blue Heron.


Bird Mortality In the EIS, the Proponent provided predictions on the increases in vehicle collision rates for each coastal bird subcomponent. The Proponent determined that increased mortality would have, with the exception of Barn Owl, on overall ‘negligible effect’ on coastal bird productivity in the LAA. For Barn Owl, there would be a ‘minor decrease’ in productivity due to collisions. To address this impact to owls, the Proponent advised in the EIS that it would work with the appropriate authorities to develop and implement mitigation. In subsequent responses to Review Panel information requests, the Proponent provided information on specific mitigation to address residual effects to owls. These include physical barriers, reducing speed limits, installing nest boxes, education and awareness, and decreasing roadside habitat suitability. The Proponent indicates it would work with the authorities as implementation of some of the proposed mitigation are outside of its control and jurisdiction.

The Proponent has not proposed to implement non-vegetative barriers as part of the Project because of concerns on cost and that the associated benefits to a small area of the range of the species would be ‘small’ to ‘negligible’.

ECCC Conclusions

Bird Mortality ECCC has four remaining areas of concern in relation to Barn Owls and are summarized as follows:

• Physical barriers: the implementation of non-vegetative barriers would benefit Barn Owls and other avian species at risk, including Barn Swallows, observed in the Project area. Vegetated roadsides can increase the likelihood of bird collisions with vehicles (Bishop and Brogan 2013), including Barn Swallows (Orlowshi 2008, COSEWIC 2017). Therefore, it is important that barrier design be effective for the target species (Barn Owl) and not increase the mortality threat for non-target species such as Barn Swallow and migratory birds generally.

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• Decreasing habitat suitability: loss of owl foraging habitat is the most important threat to the species. Despite the risk of vehicle collision, owls select roadside grass verges more than other habitat types within home ranges. Preserving these habitats will support survival and recovery of the species. Therefore, the Proponent’s proposed mitigation to reduce roadside owl habitat suitability would not align with the needs of the species.

• Installation of nest boxes: the number of nest boxes, the extent to which this measure would mitigate Project-associated road mortality, and post-installation monitoring to assess effectiveness have not been described.

• Spatial scope of mitigation measures: the effects of Project-related vehicle collisions would extend beyond the area (LAA) where mitigation is currently proposed. Therefore, the Project’s contribution to the cumulative effects to Barn Owls within the Regional Assessment Area (RAA) would not be addressed.

Recommendations to the Review Panel In ECCC’s view, even with implementation of all agreed-upon mitigation, it is highly unlikely that a 0% collision mortality rates could be reasonably achieved in the Project area. ECCC recommends the Proponent:

• Design and install a physical barrier in the LAA to reduce road-associated avian mortality risk for Barn Owls. This include designing the physical barrier such that:

− It does not serve as an attractant and therefore increase vehicle collision risks to other avian species, including species listed on Schedule I and those protected under the MBCA.

− Conserves suitable Barn Owl roadside grass verge habitat where they are co-located.

• Install a physical barrier in the RAA, and that conserves suitable Barn Owl roadside grass verge habitat where they are co-located.

• Develop a plan, in consultation with the Government of British Columbia, Indigenous groups, and ECCC, that describes:

− The type(s) of physical barriers to be installed, locations, and maintenance regime.

− The number of nest boxes that would be installed and their locations in the LAA and RAA.

− Post-installation nest box effectiveness monitoring, to assess usage and productivity, for the duration of the Project.

− Annual reporting to assess mitigation effectiveness and any need for adaptive management measures.

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References

BC Ministry of Environment (214) Recovery Plan for the Barn Owl (Tyto alba) in British Columbia. Prepared for the BC Ministry of Environment, Victoria, BC. 30pp.

Bishop, C. A., and J. M. Brogan. 2013. Estimates of avian mortality attributed to vehicle collisions in Canada. Avian Conservation and Ecology 8(2): 2. http://dx.doi.org/10.5751/ACE-00604-080202

Calvert, A. M., C. A. Bishop, R. D. Elliot, E. A. Krebs, T. M. Kydd, C. S. Machtans, and G. J. Robertson. 2013. A synthesis of human-related avian mortality in Canada. Avian Conservation and Ecology 8(2): 11. http://dx.doi.org/10.5751/ACE-00581-080211

4.3 Artificial Lighting Introduction In the BC marine environment, migratory birds, including several SARA-listed species fall under ECCC’s legislative mandate. Migratory birds in the marine environment, (i.e., marine birds), refer to those that spend any component of their life cycle associated with marine environments including estuaries, foreshore marshes, mudflats, sandflats, inshore and offshore marine waters, islands, islets and pelagic waters.

In the context of the potential for incidental take (i.e., incidental harm to birds, nests and eggs), which is prohibited under the MBCA, ECCC is concerned with the detrimental effects of bird collisions or strandings at lit and floodlit structures, as well as those associated with transiting vessels. Artificial lighting can cause birds to collide with structures, resulting in injury or death. Many bird species are also known to circle artificial sources of lighting, which can lead to disorientation and depletion of energy reserves resulting in death or exhaustion. Exhausted birds will drop to the ground/vessel where they are at risk of predation.


The Project is anticipated to increase sky glow dependant on the location of the point of reception as identified in Section 9.4 of the EIS. Light trespass at the existing Deltaport Terminal is identified as the highest point of increase and will be re-classified from E2 (low ambient brightness) to E3 (medium ambient brightness). Marine and coastal birds are known to be sensitive to artificial light, which can lead to behaviour modification, injury, or death.


The EIS described potential effects to marine and coastal birds due to artificial light. The Proponent anticipates that the effects would be minor, and also assumed that birds would move to more suitable habitat if disturbed. The Proponent’s conclusion of minor residual effects was based on a lack of reporting

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for the area, and the existing conditions at the terminal, i.e., baseline artificial lighting in the area is described as ‘high’.

ECCC Conclusions

ECCC finds the Proponent’s assessment lacks data on the effects of artificial lighting on coastal and marine birds in the region and that this lack of data may not necessarily mean little effect on coastal or marine birds. Similarly, statements that birds are habituated to artificial lighting and that cumulative environmental effects would not occur should be supported by scientific data and literature. ECCC is of the view that the continued presence of marine birds in the region, where they are currently exposed to vessel traffic and industrial activity, does not ensure they would fully habituate to increased levels in vessel traffic and artificial lighting as a result of the Project. Further, coastal and marine bird responses would likely vary with the levels of disturbance and artificial lighting in the area.

Recommendations to the Review Panel In ECCC’s view, the displacement of birds from the area should be avoided or lessened given the high ecological values of the Project area. ECCC previously provided comments and advice (CEAR 581 and CEAR 1454) regarding a follow-up monitoring program to address data gaps and inform adaptive management measures. ECCC recommends that a light mitigation and monitoring plan be developed that is specific to concerns regarding coastal and marine birds, that is also based on the most recent scientific literature and best management practices available.

4.4 Wetlands and Wetland Functions Introduction The Proponent carried out an effects assessment on wetlands in response to Review Panel information requests in package 11 and 13. In Review Panel IR11-21, the Proponent was requested to characterize the potential losses of hydrological and biogeochemical wetland functions related to direct and indirect effects from the Project, irrespective of productivity gains due to the Project and offsetting concepts. ECCC reviewed the Proponent’s response to IR11-21 and provided detailed comments, analysis and recommendations in CEAR 1454.

The Fraser River estuary is the largest on Canada’s Pacific coast. Since the Fraser River estuary supports internationally and globally significant bird and fish populations, the estuary has been designated as a RAMSAR Site20, Site of Hemispheric Importance under the Western Hemispheric Shorebird Reserve Network (Western Hemisphere Shorebird Reserve Network, 2009a), and an Important Bird Area (McKelvey 1986; McKelvey and Summers 1990; Butler and Campbell 1987; Butler and Cannings 1989; Butler et al. 1989; Butler and Vermeer 1994; Summers et al. 1994, 1996). The estuary also contains the Alaksen National Wildlife Area and George C. Reifel Migratory Bird Sanctuary, and five provincial wildlife

20 http://www.ramsar.org/wetland/canada

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management areas - Sturgeon Bank WMA, Roberts Bank WMA, South Arm Marshes WMA, Boundary Bay WMA, and Serpentine WMA.

The importance of the Fraser River estuary to internationally and globally significant bird and fish populations, as well as the various designations of the area are described in sections 4.1 and 4.2 above. The Fraser River estuary also supports provincially and federally listed fish and wildlife species; avian species include, amongst others, Great Blue Heron (spp fannini), Barn Owl, Barn Swallow, and Western Grebe.

Historical wetland loss in the Lower Fraser have been well documented (Metro Vancouver 2010, Moore et al 2004, Moore et al 1990, Kistritz et al 1996, Boyle et al 1997). In particular, the brackish marsh at Sturgeon Bank has experienced a significant amount of recession (loss) in recent decades (Marijnissen, 2017, Boyd, unpubl. report). Documented historical wetland losses in the Lower Fraser are characterized by ECCC as having reached ‘critical levels’.


For the marine vegetation assessment, the Proponent identified five subcomponents: eelgrass, intertidal marsh, macroalgae, biomat, and biofilm. Intertidal marsh was identified as the one wetland type present in the LAA. Four mechanisms were evaluated in assessing potential Project effects on marine vegetation productivity: direct loss and mortality, changes in water quality, changes to sedimentation and coastal processes, and biotic interaction. The Proponent employed an ecosystem model (Ecosystem with Ecosim and Ecopath (EwE)) to characterize Project-related effects on ecosystem productivity. The Proponent also incorporated site specific (empirical) data and professional judgement in drawing conclusions on Project effects to marine vegetation. In response to Review Panel information requests in package 11 and 13, the Proponent submitted a wetland functions assessment (WFA), and provided additional information, including technical designs, regarding approaches to offsetting for intertidal wetlands. Further to the EIS, the Proponent identified, described and assessed intertidal mud flat, intertidal sand flat, and eelgrass as wetlands in the LAA. Hydrological, biochemical, and ecological wetland functions were assessed for both baseline and future wetland case conditions (with and without proposed offsetting). The Proponent determined, in assessing future state conditions, that the Project would result in some losses in certain functions associated with intertidal marsh, mud flat, and eelgrass wetlands, and that there would be no loss in functions associated with sand flat wetlands.

Environmental Effects

The Proponent determined the following:

Habitat loss

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As described in Table 11-12 of the EIS, the Project would result in a direct, permanent loss of 55.6 ha of intertidal and 113.0 ha of subtidal habitat, and 17.4 ha of shallow subtidal habitat would be lost due to dredging or densification.

Changes in water quality

The Proponent predicts the Project would result in an average change in the salinity regime on Roberts Banks of -3.5 PSU. Maximum change in the 50th percentile value is -8 PSU to +4 PSU during the freshet and -7 to +4 PSU during the non-freshet period. The Proponent determined that the predicted decrease in salinity would be within the range of natural variation, and that the duration of marine vegetation exposure to lower salinities would be longer.

As described in Table 11-13 of the EIS, 170 ha and 962.7 ha of marine vegetation would be affected by increased turbidity during Project construction. More specifically, of the marine vegetation subcomponents, macroalgae (Ulva) (103 ha/952 t) and eelgrass (approximately 67 ha/10.7 t) would be affected.

Changes to sedimentation and coastal processes

Due to Project-induced changes in coastal geomorphology processes, sediment deposition over Roberts Bank is predicted to change which in turn could affect marine vegetation. These include a predicted increase in deposition over a 41 ha area, decreased wave energy over a 70 ha area, and changes in tidal current velocity over most of the Roberts Bank tidal flats.

Biotic interactions

The EwE model provided quantitative predictions of changes in productivity in marine vegetation sub-components.

The Proponent predicted that:

• Changes in eelgrass, macroalgae (other than rockweed), biomat and biofilm productivity would be negligible;

• There would be a minor decrease in rockweed productivity; and

• There would be a minor increase in intertidal marsh productivity.

Overall, the Proponent predicted that there would be an overall increase in net productivity in the future with the Project for all marine subcomponents combined.

Mitigation

In the EIS and in subsequent responses to Review Panel information requests in packages 11 and 13, including the WFA, the Proponent described measures to avoid and reduce adverse effects to wetland functions including, for example, locating the terminal footprint away from the sensitive intertidal habitat areas to subtidal habitat areas, and supporting measures to control English cordgrass (Spartina anglica).

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To address residual effects, the Proponent has proposed onsite offsetting measures relevant to functions associated with intertidal marsh, mudflat, and eelgrass. In developing these measures, the Proponent describes the guiding principles, such as equivalency, additionality, location, timing, and duration, and how these would be applied to the offsetting measures. For example, impacts to intertidal marsh functions would be addressed through creation of 15 ha intertidal marsh habitat onsite; 4.5 ha of enhanced mud flat would be created onsite that is suitable for biofilm; and for eelgrass, 3 ha of onsite native eelgrass would be planted. Given its prediction of no residual effects, the Proponent has not proposed offsetting measures for intertidal sand flats, but indicates that creation of 4.5 ha of sandy gravel beach would function for fish and waterfowl.

The Proponent predicts that proposed offsetting would improve specific wetland functions in the LAA. The Proponent concluded that proposed mitigation, including offsetting, would achieve the goal of no net loss of wetland functions and ensure that no further loss of wetland habitat occurs (in support of the Federal Policy on Wetland Conservation). The Proponent advises that the Final Offsetting Plan would address and account for uncertainty in offsetting success and associated time lag for the offset to become effective, and that monitoring would be conducted as part of the Follow-up Program and in support of an approach based on the adaptive management approach.

ECCC Conclusions

ECCC agrees with the Proponent that intertidal mud flats and sand flats are wetlands, but finds that the shallow subtidal zone is a wetland based on the Canada Wetland Classification System (CWCS). For Roberts Bank, ECCC has advised that the average depth to which eelgrass, a wetland indicator plant, grows should be the criterion used to determine the lower boundary of the tidal flats wetlands (CEAR 1454).

ECCC emphasizes that the productivity estimates described in the EIS reflect potential values only. There is uncertainty regarding the extent that full wetland productivity would be realized in the Wetland Assessment Area (WAA) in the future with the Project condition. There is also uncertainty whether the same range and degree of functions that are reflected in the (current) baseline condition would be realized.

Environmental Effects

ECCC previously described in detail its concerns with the Proponent’s wetlands assessment (CEAR 1454). While the Proponent concluded that that the Project would not result in residual adverse effects to wetlands and associated functions in the WAA, and, therefore, that there would be no cumulative environmental effects, ECCC is concerned with the undervaluation of intertidal mud flats, and intertidal and subtidal sand flats. The Proponent predicts residual effects, variously ‘negligible’ or ‘minor’, to all wetland types in the WAA other than for intertidal marsh. Recent studies on mud flat wetlands indicate these habitats provide valuable contributions to Roberts Bank wetland ecosystem productivity levels.

Based on available scientific literature, ECCC does not consider the information provided in the Proponent’s WFA adequate to assess indirect effects to wetland habitats in the WAA. ECCC notes that the

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Proponent’s finding of low biological activity in the intertidal/shallow subtidal sand flats, including in relation to microphytobenthos, has no supporting data in the EIS or in supplemental information the Proponent has provided. The functions provided in those aforementioned areas by microphytobenthos, single-celled and filamentous green algae, and areas vegetated with macrophytes, including Ulva and Fucus, have not been described. Without that information, ECCC notes there is potential for residual effects to the flora associated with those wetland types (or classes).

Mitigation

The Proponent predicts that the Project footprint would affect geomorphological-related processes, including scour, water quality, deposition, currents, wave regime, turbidity, and sedimentation. These effects would be particularly pronounced in areas of shallow subtidal sand flats. The Proponent does not propose offsetting for intertidal or shallow subtidal sand flats, which support many taxa of coastal birds, including herons (e.g. Great Blue Herons), diving birds (e.g. Western Grebes, scaup and scoter species) and shorebirds (e.g. Dunlin). ECCC agrees that it is not technically feasible to recreate shallow subtidal sand flat habitat, and that offsetting measures other than ‘like-for-like’ would need to be considered to address residual effects. However, in contrast to the Proponent’s view that offsetting for intertidal mud flat habitat would necessarily support biofilm of the type important to Western Sandpipers and other shorebirds, ECCC finds that since there is insufficient supporting scientific and technical information available, there would be significantly high uncertainty associated with the effectiveness of that offsetting measure.

ECCC data indicates marshes receded between 1989 and 2011 (Boyd, W.S., McKibben, R., and Moore, K. 2014) which does not agree with the Proponent’s view that marshes on Sturgeons Bank and Roberts Bank have expanded in recent decades.

Recommendations to the Review Panel ECCC offered recommendations in review of the Proponent’s response to the Review Panel’s IR11-21 and IR13-17 (see CEAR 1454). ECCC recommends the Proponent:

• Update the WFA to incorporate ECCC’s aforementioned recommendations.

• Complete a wetlands cumulative effects assessment.

• Incorporate the following into an updated Offsetting Plan:

- The results of the updated WFA.

- The results of a cumulative effects assessment.

- A minimum 4:1 offsetting ratio to address time lags and technical limitations with offsetting wetland habitats generally, and intertidal mud flat and intertidal and shallow subtidal sand flats in particular.

- That effectiveness monitoring of offsetting sites be carried out for the duration of the Project.

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References

Bollens, S.M., J.R. Cordell, S. Avent, and R. Hooff. 2002. Zooplankton invasions: a brief review, plus two case studies from the northeast Pacific Ocean. Hydrobiologia 480: 87-110.

Boyd, W.S., McKibben, R., and Moore, K. 2014. Bulrush marshes on the Fraser River Delta have undergone significant changes between 1989 & 2011 (DRAFT). Environment and Climate Change Canada.

Boyle, C.A., L. Lavkulich, H. Schreier, E. Kiss. 1997. Changes in land cover and subsequent effects on Lower Fraser Basin ecosystems from 1827 to 1990. Environmental Management. 21:185-196.

Butler, R.W. 1989. Breeding ecology ad population trends of the great blue heron (Ardea Herodias fannini) in the Strait of Georgia, pp. 112-130 In Vermerr, K, and R.W. Butler (eds). 1989. The ecology and status of marine and shoreline birds in the Strait of Georgia., British Columbia. Spec. Publ. Can. Wildl. Serv., Ottawa.

Butler, R.W., and R.W. Campbell. 1987. The birds of the Fraser River delta: populations, ecology and international significance. Can. Wildl. Serv., Ottawa, Ontario, Occasional Paper No. 65: 73 p.

Butler, R.W. and R.J. Cannings. 1989. Distribution of birds in the intertidal portion of the Fraser River delta, British Columbia. Technical Report No. 93, Canadian Wildlife Service, Pacific and Yukon Region, British Columbia. 60 pp.

Butler, R.W., N.K. Dawe, and D.E.C. Trethewey. 1989. The birds of estuaries and beaches in the Strait of Georgia. In The ecology and status of marine and shoreline birds in the Strait of Georgia, British Columbia. Edited by K. Vermeer and R.W. Butler. Special Publication Canadian Wildlife Service, Ottawa, ON, pp 142-147.

Butler, R.W., K. Vermeer, and G.E. John Smith. 1994. Estimated energy consumption by estuarine birds a different trophic levels, pp. 70-74, In Butler, R.W., and K, Vermeer (eds.). The abundance and distribution of estuarine birds in the Strait of Georgia, British Columbia. Can. Wildl. Serv., Ottawa, Ontario, Occasional Paper No. 83.

Deegan, L.A. 2002. Lessons learned: the effects of nutrient enrichment on the support of nekton by seagrass and salt marsh ecosystems. Estuaries 25(4): 727-742.

Elliott, M. and V.N. deJonge. 2002. The management of nutrients and potential eutrophication in estuaries and other restricted waterbodies. Hydrobiologia (475/476): 513-524.

Kistritz, R.U., K.J. Scott, C.D. Levings. 1996. Changes in fish habitat in the Lower Fraser River analyzed by two wetland classification systems. Pages 19-40 in C.D. Levings and D.J.H.

Mahaffy, M.S., D.R. Nysewander, K. Vermeer, T.R. Wahl, and P.E. Whitehead. 1994. Status, trends, and potential threats to birds in the Strait of Georgia, Puget Sound, and Juan de Fuca Strait. In Review of the marine environment and biota of Strait of Georgia, Puget Sound, and Juan de Fuca Strait. Edited by R.C.H. Wilson, R.J. Beamish, F. Aitkens, and J. Bell. Canadian Technical Report of Fisheries and Aquatic Sciences 1948: 256-281.

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Marijnissen R. 2017. Marsh Recession and Erosion Study of the Fraser Delta, B.C., Canada from Historic Satellite Imagery. Communications on Hydraulic and Geotechnical Engineering. Technische Universiteit Delft.

McKelvey, R. 1986. Aerial surveys of migratory birds on the Fraser River delta, 1985-86. Technical Report No. 10, Canadian Wildlife Service, Pacific and Yukon Region, British Columbia. 24 pp.

McKelvey, R. and K.R. Summers. 1990. Aerial surveys of the migratory birds on the Fraser River delta, 1989-90. Technical Report No. 109, Canadian Wildlife Service, Pacific and Yukon Region, British Columbia. 73 pp.

Metro Vancouver. 2010. Lower Fraser Wetland Loss: Wetland Loss to Human Encroachment in the Fraser Lowlands from 1999 – 2009, and Comparison to Loss from 1989 – 1999. Metro Vancouver.

Moore, Kathleen, Peggy Ward and Katrina Roger. 2004. "Urban and Agricultural Encroachment onto Fraser Lowland Wetlands - 1989 to 1999." In T.W. Droscher and D.A. Fraser (eds). Proceedings of the 2003 Georgia Basin/Puget Sound Research Conference.

Moore, K.E. 1990. Urbanization in the Lower Fraser Valley, 1980-1987. Technical Report Series No. 120. Canadian Wildlife Service, Environment Canada. 12 pp.

Nichols, F.H., J.E. Cloern, S.N. Luoma, and D.H. Peterson. 1986. The modification of an estuary. Science 231(1): 567-573.

Rogers, C.E. and J.P.McCarty. 2000. Climate change and ecosystems of the Mid-Atlantic region. Climate Research 14(3): 235-244.

Summers, K., P. Hayes, and R. McKelvey. 1994. Aerial surveys of waterfowl and gulls on the Fraser River delta, 1992-93. Technical Report No. 203, Canadian Wildlife Service, Pacific and Yukon Region, British Columbia. 64 pp.

Summers, K.R., K. Fry, and R. McKelvey. 1996. Aerial surveys of waterfowl and gulls on the

Fraser River Delta, 1995-96. Technical Report No. 260, Canadian Wildlife Service, Pacific and Yukon Region, British Columbia. 70 pp.

Wasson, K., C.J. Zabin, L. Bedinger, M.C. Diaz, and J.S. Pearse. 2001. Biological invasions of estuaries without international shipping: the importance of intraregional transport. Biological Conservation 102: 143-153.

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4.5 Accidents and Malfunctions – Marine Birds Introduction The BC coast has high values for marine birds. For instance, during the breeding season (generally summer), approximately 5.6 million seabirds are estimated to nest at 503 sites along the BC coast. In addition, vast numbers (likely in the tens of millions) of non-breeding individuals and seasonal migrants from as far away as the Southern Hemisphere reside in BC marine habitats throughout the year. An estimated 184 marine bird species have been recorded in the southern Strait of Georgia and in the Strait of Juan de Fuca; including 45 breeding species, and upwards of 110 species in winter and 118 species on migration. Of those species that breed in the Project’s marine shipping area, a large proportion are concentrated in breeding colonies, often located on islands. At certain times of the year, large aggregations of birds can form around breeding colonies or other valuable foraging or staging habitats, and localized populations can be vulnerable to chance events (such as an oil spill). For example, in late summer and early fall, many species of waterfowl use the area for molting and staging, and many also overwinter in the area. Many of these species are of international, national and regional significance, and include several species designated on Schedule 1 of SARA.


The marine shipping estimates for the Project (as outlined in the EIS and Marine Shipping Addendum) are expected to be 260 vessel calls to RBT2 per year at full capacity (520 vessel movements to and from the Project terminal). Shipping can impact marine birds due to direct or indirect exposure to a spill resulting from an acute accident or from chronic oiling. Marine birds can also be impacted through collisions, noise, light, and wake related to marine transport.


In Section 8.3 of the Marine Shipping Addendum, Marine Birds Effects Assessment, the Proponent assessed potential effects to sea ducks, pelagic birds, waterfowl, gulls and terns, and shorebirds subcomponents. Transiting vessels, including wake, collisions, noise, and visual disturbance were identified as having potential effects on marine birds. The Proponent concluded that potential effects to marine birds due to vessel wake, noise, and visual disturbance were negligible based on existing conditions and the ability of birds to habituate. The Proponent concluded that there would be residual effects to marine birds due to collisions (i.e., bird mortality), but that these effects would be infrequent. This determination was based on a lack of reported mortalities from transiting vessels, and was carried forward in the assessment to support a conclusion that cumulative effects would also be unlikely. The Proponent did not propose mitigation measures to address potential residual effects to marine birds due to interactions with vessels. In Section 10 of the Marine Shipping Addendum, Assessment of Potential Effects of Accidents or Malfunctions, the Proponent provided a qualitative assessment of potential effects to marine birds due to a heavy fuel oil spill in several previously modelled locations throughout the marine shipping area.

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Moderate to high magnitude residual effects on productivity were identified as persisting even after the proposed mitigation was implemented. The Proponent concluded that residual effects would not be significant based on the low likelihood of a spill in Boundary Passage. The Proponent proposed mitigation measures to reduce the likelihood and severity of a spill; however, did not propose mitigation specific to the effects of a spill on marine birds. In response to Review Panel IR11-11 on accidents and malfunctions related to marine birds, the Proponent provided additional information based on Trans Mountain Expansion Project’s models to identify seasons and locations where the ecological consequences of a spill may be higher. The Marine Shipping Addendum identified spring as the season for a plausible worst-case scenario spill and results of the assessment indicated potential effects would be greatest at Site E Arachne Reef (Segment B) across all seasons. Overall, the Proponent concluded that marine bird habitat would be affected by a spill in the marine shipping area across all scenarios and seasons.

ECCC Conclusions

ECCC’s sufficiency review of the EIS and Marine Shipping Addendum (CEAR 581) identified collisions and accidents and malfunctions as concerns for the Project within the marine shipping area. ECCC continues to recommend that the Proponent develop and adopt mitigation measures to avoid or reduce the potential for collisions with transiting vessels.

ECCC also requested the following additional information from the Proponent regarding the assessment of accidents and malfunctions as it relates to marine birds:

• Complete a quantitative assessment to assess potential impacts to marine birds in the event of a heavy oil spill in the LAA;

• Conduct stochastic modelling to assess the behaviour and fate of a hypothetical oil spill under a range of environmental conditions; and

• Develop an emergency marine response strategy for marine birds and other wildlife species in the event of a heavy fuel spill.

In ECCC’s view, the Proponent’s responses to Review Panel IR11-11 did not address the Review Panel’s information request (see CEAR 1454). ECCC recommended, further to those described above, that the Proponent provide the following:

• Information on the potential effects from a heavy fuel oil spill in areas and times of year that represent plausible worst-case environmental attributes, conditions, and response times accounting for species presence, abundance, and seasonal use of the area by marine birds.

• A discussion on how best available information on marine bird presence, abundance, and distribution was integrated into the assessment to address spatial or temporal vulnerabilities of marine birds, including the Proponent’s conclusion that shoreline vulnerability in Segment B is representative of other portions of the marine shipping area.

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• A re-assessment that includes greater specificity on relative degree of vulnerability among various marine bird species, subcomponents, and their corresponding seasonal presence and abundance.

• Provide further discussion on the effects of surface oiling at Site H during seasons when pelagic species are likely to be present and vulnerability may be highest.

• Provide a rationale for the use of the summer season used in the summary of stochastic modelling results.

Recommendations to the Review Panel ECCC recommends that:

• A Wildlife Emergency Response Plan be developed that includes the following information (i.e., oil spill response strategy):

- Information (such as population, life cycle and habitat requirements) on the migratory birds and/or species at risk in the Project area, including areas that could be potentially impacted by an oil spill;

- Information concerning the most appropriate strategy for assessing the extent of risk or impact to migratory birds, species at risk, and their habitats;

- Information on locations and inventories of response equipment, facilities, and personnel that would be accessed to support wildlife response activities;

- Information concerning the most appropriate (regionally-and temporally-specific) response strategies for preventing more migratory birds, species at risk, and their habitats from becoming affected;

- Information concerning the appropriate response strategies for the treatment of affected migratory birds, species at risk, and their habitats; and

- The type and extent of monitoring that would be conducted in relation to various events (e.g., spill event at a marine terminal or along the shipping lane), including information that would be collected prior to, during, and following an event such as an oil spill.

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CHAPTER 5: Summary of Recommendations to the Review Panel 5.1 Water Quality ECCC recommends that all fill material be characterized (dredgeate and quarry sand) to demonstrate that acceptable supernatant discharge quality can be maintained throughout the Project’s construction period.

ECCC also recommends that the supernatant either not be discharged when dredgeate from the upper layers of the tug basin is being placed as fill, or further details to demonstrate that these sediments will not exceed the DFO upper threshold (200 pg/g) or increase ambient PCB concentrations in SRKW critical habitat would be necessary.

5.2 Accidents and Malfunctions ECCC recommends that spill probability modelling be required to support the Proponent’s assessment of an accident scenario involving a collision between a container ship and tanker carrying crude oil, particularly as the Proponent estimates the potential worst-case spill volume to be higher than original estimates. ECCC also recommends that the types of oil included in the potential maximum spilled volume be clarified. ECCC further recommends that if the estimate was only specific to a spill of a single type of oil, then all other plausible fuel oil types such as marine diesel and heavy fuel oil should also be modelled.

5.3 Air Quality CAAQS

In consideration of the analysis provided in section 3.1, ECCC recommends that:

• The Proponent design and implement a local air quality monitoring program in multiple locations.

• The Proponent participate in local and regional air quality management initiatives, where applicable.

• The Proponent takes an iterative approach to air quality management and makes any necessary adaptations to Project equipment or procedures to prevent Project emissions from contributing to deteriorating air quality in the local and regional area.

CALMET-CALPUFF Model Doman Size and Regional Emission Sources

ECCC continues to recommend that the air quality assessment for the Project include the additional analysis that has been described in section 3.2. A larger modelling domain coupled with inclusion of regional emission sources would allow for a complete assessment of the Project’s effects on air quality.

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Model Bias

ECCC recommends that the air quality assessment for the Project apply a more rigorous statistical approach using timed-matched values of observed and modelled concentrations of NO2. Modelling of more than one year would allow for a complete assessment of the Project’s effects on air quality.

Background Air Quality

ECCC is of the view that the analysis provided in section 3.4 is required in order to determine the appropriate background for the Project. The background value should be determined using more than one air quality station, a more complete analysis of differences between monitoring stations, and more recent data particularly given recent changes in emission controls and monitoring technology.

Marine Emissions

ECCC recommends that more realistic assumptions of the rate of introduction of Tier III vessels and marine emissions from ships underway in the Strait of Georgia be included in the assessment. ECCC is of the view that this information is necessary to assess the contribution of emissions resulting from marine shipping associated with the Project.

Locomotive Emission Rates

ECCC continues to recommend reassessing the locomotive emissions with a more conservative assumption of Tier levels to reflect the current and expected near term (2025) fleet of yard switcher locomotives in Canada.

Cargo Handling Equipment Emissions

ECCC recommends that:

• Where practicable, the Proponent should select equipment with low emissions that meet the latest applicable Canadian emissions standards and guidelines.

• The Proponent should not remove emission control technologies from off-road equipment.

• The Proponent should implement an emission control technology maintenance program, which may include combined use of individual equipment fuel usage indicators, equipment emission testing, and electronic diagnosis techniques to trigger maintenance.

• The Proponent should also provide employee training on minimizing off-road equipment idling and the importance of avoiding tampering with emissions control systems.

• The Proponent commit to meeting the most stringent emission standards and turn equipment over to electric as soon as feasible.

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5.4 Coastal Birds Assessment Biofilm and Shorebirds

ECCC is of the view that the Project would likely result in adverse effects to biofilm with major, unmitigable consequences for shorebirds, Western Sandpipers in particular. The Project would likely reduce the quality and quantity of fatty acids provided by biofilm on the intertidal mudflats of Roberts Bank to migratory shorebirds. ECCC maintains that predicted Project-induced changes to Roberts Bank constitute an unmitigable species-level risk to Western Sandpipers, and shorebirds more generally, due to the predicted disruption to the salinity regime that supports fatty acid production from biofilm.

Given the high shorebird usage at Roberts Bank, even low probability events carry a high risk because nutrient shortfalls during breeding migration could have species-level consequences. Also, the proposed offsetting measures on Roberts Bank are not adequate to address the potential impacts. Due to what ECCC believes to be high and unmitigable risks to an entire species of migratory shorebird, ECCC advises that only a Project redesign would avoid geomorphological processes on Roberts Bank impacting biofilm and shorebirds.

Species at Risk

In ECCC’s view, even with implementation of all agreed-upon mitigation, it is highly unlikely that a 0% collision mortality rates could be reasonably achieved in the Project area. ECCC recommends the Proponent:

• Design and install a physical barrier in the LAA to reduce road-associated avian mortality risk for Barn Owls. This include designing the physical barrier such that:

− It does not serve as an attractant and therefore increase vehicle collision risks to other avian species, including species listed on Schedule I and those protected under the MBCA.

− Conserves suitable Barn Owl roadside grass verge habitat where they are co-located.

• Install a physical barrier in the RAA, and that conserves suitable Barn Owl roadside grass verge habitat where they are co-located.

• Develop a plan, in consultation with the Government of British Columbia, Indigenous groups, and ECCC, that describes:

− The type(s) of physical barriers to be installed, locations, and maintenance regime.

− The number of nest boxes that would be installed and their locations in the LAA and RAA.

− Post-installation nest box effectiveness monitoring, to assess usage and productivity, for the duration of the Project.

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− Annual reporting to assess mitigation effectiveness and any need for adaptive management measures.

Artificial Lighting

In ECCC’s view, the displacement of birds from the area should be avoided or lessened given the high ecological values of the Project area. ECCC previously provided comments and advice (CEAR 581 and CEAR 1454) regarding a follow-up monitoring program to address data gaps and inform adaptive management measures. ECCC recommends that a light mitigation and monitoring plan be developed that is specific to concerns regarding coastal and marine birds, that is also based on the most recent scientific literature and best management practices available.

Wetlands and Wetland Functions

ECCC offered recommendations in review of the Proponent’s response to the Review Panel’s IR11-21 and IR13-17 (see CEAR 1454). ECCC recommends the Proponent:

• Update the WFA to incorporate ECCC’s aforementioned recommendations.

• Complete a wetlands cumulative effects assessment.

• Incorporate the following into an updated Offsetting Plan :

- The results of the updated WFA.

- The results of a cumulative effects assessment.

- A minimum 4:1 offsetting ratio to address time lags and technical limitations with offsetting wetland habitats generally, and intertidal mud flat and intertidal and shallow subtidal sand flats in particular.

- That effectiveness monitoring of offsetting sites be carried out for the duration of the Project.

Accidents and Malfunctions – Marine Birds

ECCC recommends that:

• A Wildlife Emergency Response Plan be developed that includes the following information (i.e., oil spill response strategy):

- Information (such as population, life cycle and habitat requirements) on the migratory birds and/or species at risk in the Project area, including areas that could be potentially impacted by an oil spill;

- Information concerning the most appropriate strategy for assessing the extent of risk or impact to migratory birds, species at risk, and their habitats;

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- Information on locations and inventories of response equipment, facilities, and personnel that would be accessed to support wildlife response activities;

- Information concerning the most appropriate (regionally-and temporally-specific) response strategies for preventing more migratory birds, species at risk, and their habitats from becoming affected;

- Information concerning the appropriate response strategies for the treatment of affected migratory birds, species at risk, and their habitats; and

- The type and extent of monitoring that would be conducted in relation to various events (e.g., spill event at a marine terminal or along the shipping lane), including information that would be collected prior to, during, and following an event such as an oil spill.

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Appendix Appendix 1: Canadian Ambient Air Quality Standards (CAAQS)

Pollutant Averaging time

Standard (numerical value) Statistical form of the standard 20151 2020 2025

Ozone*2 8-hour 63 ppb 62 ppb The 3-year average of the annual 4th highest of the daily- maximum 8-hour average concentrations.

Fine particulate matter (PM2.5)2

24-hour (calendar day) 28 µg/m3 27 µg/m3

The 3-year average of the annual 98th percentile of the daily 24-hour average concentrations.

Annual (calendar year) 10.0 µg/m3 8.8 µg/m3

The 3-year average of the annual average of the daily 24-hour average concentrations.

Sulphur Dioxide (SO2)3

1-hour 70 ppb 65 ppb

The 3-year average of the annual 99th percentile of the daily-maximum 1-hour average concentrations.

Annual (1-year) 5.0 ppb 4.0 ppb

The arithmetic average over a single calendar year of all 1-hour average concentrations.

Nitrogen Dioxide (NO2)4

1-hour 60 ppb 42 ppb

The 3-year average of the annual 98th percentile of the daily-maximum 1-hour average concentrations.

Annual (1-year) 17.0 ppb 12.0 ppb

The arithmetic average over a single calendar year of all 1-hour average concentrations.

(1) This is the effective year. (2) Published in Canada Gazette Part 1, May 25, 2013. (3) Published in Canada Gazette Part 1, October 28, 2017. (4) Published in Canada Gazette Part 1, December 9, 2017. *Not usually modelled but provided for information ppb: parts per billion, µg/m3: micrograms per metre cubed

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Appendix 2: Management levels for air pollutants under the CAAQS Management levels for ozone (O3)

Management level 2015 2020

Red > 63 ppb > 62 ppb

Orange 57 to 63 ppb 57 to 62 ppb

Yellow 51 to 56 ppb

Green < 50 ppb

**The concentrations have the same statistical form as the corresponding CAAQS and the metric values for comparison to the concentrations must be rounded to the same number of digits as the shown concentrations.

Management levels for fine particulate matter (PM2.5)

Management level

PM2.5 24-hour PM2.5 annual

2015 2020 2015 2020

Red > 28 µg/m3 > 27 µg/m3 > 10.0 µg/m3 > 8.8 µg/m3

Orange 20 to 28 µg/m3 20 to 27 µg/m3 6.5 to 10.0 µg/m3 6.5 to 8.8 µg/m3

Yellow 11 to 19 µg/m3 4.1 to 6.4 µg/m3

Green < 10 µg/m3 < 4.0 µg/m3


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Management levels for sulphur dioxide (SO2)

Management level

SO2 1-hour SO2 annual

2020 2025 2020 2025

Red > 70 ppb > 65 ppb > 5.0 (CAAQS) > 4.0 ppb

Orange 51 to 70 ppb 51 to 65 ppb 3.1 to 5.0 ppb 3.1 to 4.0 ppb

Yellow 31 to 50 ppb 2.1 to 3.0 ppb

Green ≤ 30 ppb ≤ 2.0


Management levels for nitrogen dioxide (NO2)

Management level

NO2 1-hour NO2 annual

2020 2025 2020 2025

Red > 60 ppb > 42 ppb > 17.0 ppb > 12.0 ppb

Orange 32 to 60 ppb 32 to 42 ppb 7.1 to 17.0 ppb 7.1 to 12.0 ppb

Yellow 21 to 31 ppb 2.1 to 7.0 ppb

Green ≤ 20 ppb ≤ 2.0 ppb


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Appendix 3: British Columbia Air Zone map

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Appendix 4: RBT2 Technical Data Report Biofilm Regeneration Study ECCC Comments on Technical Merit of the Information Provided

The Proponent commissioned a biofilm regeneration field study conducted on the intertidal mudflats of Roberts Bank from July 17 - August 31, 2013. As noted on page i in the Disclaimer to the Report, ’this out-of-scope information is included in the Technical Report/Technical Data Report for each study, but may not be considered for the assessment of potential effects of the Project unless relevant for understanding the context of those effects or to assess potential cumulative effects’. The study findings indicate that the biofilm community was re-established to undisturbed levels within nine days after direct physical removal on small-scale plots.

The findings from this study augment the current understanding of the nature of biofilm, but ECCC advises that the focus of the study may have limited relevance to assessing the effects of the Project given that:

1. The Project does not involve temporary direct physical removal of intertidal biofilm, but rather permanent direct physical removal plus a complex of indirect and long-term effects that could result in irrecoverable changes in biofilm quantity, quality and distribution; and

2. Biofilm communities and properties vary seasonally and the study findings for July/August may not be applicable to other months, e.g., recovery times may differ in other times of the year.

Accordingly, ECCC is concerned that the current Executive Summary statement that, ‘Biofilm at Roberts Bank is naturally resilient and will return to an undisturbed state within nine days of a physical disturbance’ is liable to be misrepresented and engender the false conclusion that biofilm is generally resilient to any disturbance. The specific context of the term ‘resilient’ is needed to clarify the study’s findings such that they do not lead to erroneous conclusions about potential effects relevant to the Project.

ECCC notes the report identifies the link between biofilm biomass and community composition of the biofilm, in particular the diatom genera Nitzschia and Navicula, predominantly marine-influenced diatoms. This link underscores ECCC’s concerns21 that changes to the salinity regime of the area may have permanent effects on the productivity of the site.

Appendix 5: Roberts Bank Salinity Model Results Verification: Comparison of 2012 Modelled Salinity to 2016 & 2017 Measured Salinity ECCC Comments on Technical Merit of the Information Provided

The Proponent has submitted an additional report on salinity for their assessment of marine water quality (EIS, Section 9.7). The Proponent modelled the relationship of salinity at various stations to elucidate

21 ECCC’s Sufficiency Review of the EIS (CEAR 581), ECCC’s response to Review Panel IR-08 and IR-10 (CEAR 1109 and 1146), and, ECCC’s Sufficiency Review of Proponent IR responses (CEAR 1346)

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spatial and temporal patterns, including the relative influence of freshwater that is dependent on Fraser River discharge volume and proximity to Canoe Passage.

The report purports that the model accurately represents the salinity patterns exhibited in field data with respect to Fraser River flow, capturing the dominant processes and incorporating the natural variability in the system.

Given that only the freshet period (May – July) and non-freshet period (October – December) were modelled, ECCC does not concur that the salinity results are adequate to support the assessment of Project-related effects on valued components. ECCC notes that salinity patterns vary monthly. Merging data from 3-month periods and lumping 2016 and 2017 data could result in ecologically important differences being masked. Further, the salinity predictions fall outside of the critical pre-freshet ~ 3-week window of shorebird breeding migration in April/May and cannot be used to determine risk to intertidal biofilm.

ECCC suggest that the following additional information would assist the Panel’s understanding of salinity in the Project area:

Inclusion of a prediction on how the Project is projected to change the ‘salinity regime’ over the upper intertidal biofilm fields in terms of minimum, mean and maximum salinity over time in a tidal cycle, especially during the April/May period, as this would provide more biologically relevant results. Currently, the model predictions are expressed only as 50th percentile salinity change values that are not translatable to the real world of diatoms in biofilm. The biofilm research that the Proponent has conducted has focused on correlations with the 5th and 95th percentiles; therefore, ECCC recommends that these values also be presented. In addition, given that fluctuations in salinity can trigger a lipid accumulation response in microalgae, a characterization of how variance is expected to change would inform an assessment of how the Project may impact fatty acid production by biofilm.

Appendix 6: EIS Appendix 15-A Capacity 2 Analysis ECCC Comments on Technical Merit of the Information Provided

In responses to information requests, the Proponent states that a surplus of biofilm is supported on Roberts Bank (i.e., that this resource is not limiting to Western Sandpiper, shorebirds more generally, or other predators that forage on the flats). ECCC previously provided comment on this assertion22. To assess the validity of this statement, ECCC is completing a sensitivity analysis of the Capacity 2 Analysis.23

ECCC suggests that the following additional information would assist the Panel and ECCC’s understanding of the technical merit of the Capacity 2 Analysis:

22 ECCC’s Sufficiency Review of the EIS (CEAR 581) 23 EIS, Volume 3, Appendix 15-A, Section 3.4.6.2

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1. What is the value of the total biofilm stock used? The EIS references ‘ASL Environmental Sciences 2013’ and ‘Appendix A Figure 46’, but not the value used in the analysis. Without this information, the accuracy of the value used cannot be confirmed.

2. What are the function and parameters used in the daily recovery curve and what is the daily recovery period? The EIS shows only a figure of the curve (Appendix A, Figure 47), but the exact nature of the recovery curve and the daily period of recovery used in the simulation will affect the estimate of the ability of the standing stock to regenerate after daily depletion.

3. How does recovery after foraging affect capacity, as calculated in the simulation? The Proponent uses three parameters in the analysis: 1) standing stock, 2) demand, and 3) recovery. It is not clear how they have used demand and recovery in calculating capacity. The details here are critical because different ways of calculating consumption and recovery have different biological meaning and will give differing estimates of the ability of the site to accommodate shorebird populations. For example, calculating capacity prior to or after daily consumption and recovery calculations will give differing estimates of capacity. It appears that the standing stock is reset to the same value during each day, which may be biologically unrealistic. ECCC has attempted to replicate three possible methods of estimating capacity, and our results to date indicate the recovery period plays no role in the estimate of capacity.

4. Is there an allowance for depletion across the migratory period? Allowing for seasonal depletion will strongly increase the chance of a day with limited biofilm in a migratory season.

5. What varies between Monte Carlo ‘draws’? Is it solely the number of Western Sandpipers and Dunlins? ECCC requests that the simulation be conducted with variation in the parameters that are known to be stochastic or imprecise.

Appendix 7: Review of Biofilm Reports (2016-2018) Marine Vegetation (Biofilm)

In relation to marine vegetation and biofilm, ECCC finds 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.

Summary of Proponent Submission

The Proponent has provided a technical report that presents new data and analyses on biofilm sampled in 2018, entitled:

• Biofilm Dynamics during 2018 Northward Migration (2019) (CEAR 1385)

ECCC Analysis of Proponent Submission

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The 2018 Biofilm report includes a consideration of additional samples that were not presented in the EIS or in the 2016 and 2017 biofilm reports24. This new report provides information on the spatial and temporal variability in biofilm biomass, fatty acid abundance, diatoms and other factors. The results described in the 2018 report confirm the variability described in the two previous biofilm reports (2016, 2017). The Proponent examined correlations among measures of biofilm and environmental variables, and determined that predicted changes in salinity from the Project are not expected to result in significant adverse effects25 on biofilm or the availability or quality of food available to northward migrating Western Sandpipers.

ECCC Perspective on the 2018 Biofilm Report

The additional year of data in the 2018 Biofilm report does not change ECCC’s previously stated detailed responses (see CEAR 1346). The data collected to date, including in 2018, and analyses do not, in ECCC’s view, support the Proponent’s position that:

1. Biofilm at Roberts Bank is not limiting for Western Sandpipers; and

2. The Project would not adversely affect the quantity and quality of food available to Western Sandpipers and other shorebirds.

In general, the Proponent’s conclusions about predicted Project effects on biofilm are based on correlations that do not incorporate a current understanding of the ecological drivers of fatty acid production and shorebird migration. Below ECCC provides a technical review of the 2018 Biofilm report showing that the Proponent’s technical reports do not support the Proponent’s conclusions.

Technical Review

The 2018 Biofilm report builds on the Proponent’s previous studies conducted in 2016 and 2017, and provides a multiyear assessment that reveals complex interactions between the abundances of fatty acids and carbohydrates with environmental conditions at the Roberts Bank site. ECCC’s review finds that this set of reports links fluctuations in salinity with patterns in fatty acid and carbohydrate production by biofilm. These patterns are consistent with our understanding of how shorebirds access the limited pulses of fatty acids from biofilm, and as well the published literature on fatty acids and biofilm dynamics (see below).

ECCC questions the Proponent’s approach of using salinity patterns in Canoe Passage as a proxy for assessing effects to biofilm located in other areas on Roberts Bank. ECCC finds, therefore, that the results associated with the approach do not provide scientific evidence for the conclusion that the Project would

24 Shorebird and Biofilm Dynamics Study during Northward Migration; and Investigation of Selective Feeding of Biofilm Communities by Shorebirds during Northward Migration (2016) (CEAR 1110); and, Biofilm Dynamics during 2017 Northward Migration (2017) (CEAR 1215) 25 As advised by the Proponent in its January 11, 2019 covering letter to Mme. Beaudet, Review Panel Chair, and on pages vii and 85 of the 2018 Biofilm report (CEAR 1385)

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‘not result in significant adverse effects on biofilm or affect the availability or quality of food available to northward migrating Western Sandpipers’.

Fatty acids provide a high energy, low weight source of fuel for sandpipers engaging in long-distance migratory flights (Jenni and Jenni-Eiermann 1998, Guglielmo et al. 1998, Egeler and Williams 2000, Guglielmo 2010). Studies conducted under the EIS and previously published work have demonstrated that sandpipers are not randomly distributed on Roberts Bank during northward migration, but feed in areas with high biofilm abundance (Jiménez et al. 2015, Appendix 15-B: Shorebird Feeding Opportunity in Migration). A Western Sandpiper may consume 190g of biofilm per day (7 times its body weight). Estimates from foraging rate, energy content and metabolism data indicate that biofilm, on average, accounts for ≥45% of the diet and up to 50% of their daily energy budget (Kuwae et al. 2008). Therefore, sandpipers likely target high quality biofilm as a source of fatty acids. The 2018 Biofilm report draws many of its conclusions based on the availability of carbohydrates, and appears to ignore the importance of fatty acids as an optimal fuel source for migrating birds.

The 2016-2018 set of reports demonstrate that biofilm is rich in fatty acids, however the factors triggering production of fatty acids are complex, and scientific understanding is rapidly developing. Fatty acid production by microalgae has received considerable attention due to growing interest in the use of diatoms for the production of biodiesel and as lipid-rich (omega-3 and omega-6 fatty acids) food sources for aquaculture (Hildebrand et al. 2012, Levitan et al. 2014, Schnurr and Allen 2015, Adarme-Vega et al. 2016). Experimental studies demonstrate that growth rates of microalgae, including diatoms, exist in two distinct phases (Schwenk et al. 2013): a normal ‘exponential’ growth rate with carbohydrate production that depends on available nutrients, light, temperature, and salinity (Smith and Underwood 2000); and a ‘stationary’ growth phase, wherein diatoms rapidly synthesise lipids (fatty acids). This second growth phase is triggered when diatoms experience sudden changes in nutrient levels (e.g., nitrogen or silica), salinity (Pal et al. 2013), or other environmental stressors (Sharma et al. 2012). The rapid changes in spring time temperatures, light conditions, tidal cycles and salinity that occur on Roberts Bank in tandem with the Fraser River freshet, are mechanisms linking the abundance of intertidal biofilm with the fatty acid production.

Proponent’s summary findings and ECCC’s review

The Proponent offers a summary of its findings on predicted Project-induced changes to the salinity regime on biofilm and Western Sandpipers (see cover letter to 2018 Biofilm report, and p. 4 and 5) as follows:

‘In summary, the 2016, 2017, and 2018 results align with the following conclusions described in the EIS:

• Roberts Bank is a dynamic environment to which the existing biofilm community is adapted;

• Ongoing salinity monitoring continues to show that under existing conditions there is large natural variation in salinity across Roberts Bank due to variable Fraser River flow and tidal mixing;

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• Biofilm is consistently documented in high abundance under varying salinity conditions across Roberts Bank, with biofilm fatty acid levels varying little between years and,

• Biofilm at Roberts Bank will continue to be abundant and capable of supporting migrating Western Sandpipers with the project in place’.

In the following, ECCC offers expert knowledge related to each of the Proponent’s four position statements noted above.

(1) Roberts Bank is a dynamic environment to which the existing biofilm community is adapted

Biofilm is a complex community of a large number of species (e.g., Appendix G in the 2018 Biofilm report) that occurs in a range of habitats and not a single organism. Biofilm communities comprise a mix of micro-flora and fauna that occur in a wide range of estuarine salinity conditions and habitats. Many, for example, are considered biofouling agents (Flemming 2002). However, the biofilm that produces fatty acids important to Western Sandpipers exists only in narrow intertidal habitats at critical periods (Kuwae et al. 2008) and under specific salinity tolerances (Schwenk et al. 2013). Reliable predictions of potential Project effects requires an understanding of the species-specific conditions under which the diatoms produce fatty acids during the period shorebirds are present at the site.

The conditions necessary for triggering diatoms to produce lipid/fatty acids can be identified in the 2018 Biofilm report data. The highest fatty acid abundances occur in the April samples (Figure 3-8), when the Western Sandpipers are migrating through the area, and coincide with rapid, high amplitude oscillations in salinity values (Figure 4-2). Thus, a ‘shock’ imposed by changes in salinity ’triggers’ diatoms to switch from their growth and carbohydrate production phase to the high fatty acid production phase (Schwenk et al. 2013, Pal et al. 2013). The high fatty acid pulses occur in association with high abundance of marine diatoms (see Figure 2-3). Consistent with this mechanism, fatty acid production drops and carbohydrate production increases later in April and May correlated with both lower salinity and less variable salinity conditions (Figure 3-11).

Project-induced changes include lower predicted salinity, and potentially lower variability. By affecting these processes, either singly or in combination, the Project would likely alter or remove altogether the trigger responsible for initiating fatty acid production in biofilm over Roberts Bank. The EIS predicts26 a shift in the diatom community to a predominantly freshwater-type biofilm community. The consequential risk is that biofilm that consists primarily of marine-type diatoms would be replaced by biofilm made up of mostly freshwater-type diatom species. Freshwater-type diatoms tend to have lower abundances of critical fatty acids (Galloway and Winder 2015). Further, the EIS predicts that the biofilm community would shift spatially to lower elevations in the intertidal. The generally coarser sediment of lower elevation areas would render the associated biofilm inaccessible to grazing by Western Sandpipers. The tongues of Western Sandpipers are adapted to grazing on fine sediments, and lose their functionality on coarse sediments (Elner et al. 2005; Jimenez et al. 2015).

26 EIS, Volume 3, Section 11 Marine Vegetation Effects Assessment, 11.6.3.5 Biofilm

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In summary, a Project-induced change in the salinity regime would likely:

i. Markedly reduce the quality of biofilm associated with the current muddy, upper intertidal areas because of the changes in the conditions necessary to trigger high fatty acid production; and

ii. Move biofilm into lower intertidal areas where the birds could not generally access them.

(2) Ongoing salinity monitoring continues to show that under existing conditions there is large natural variation in salinity across Roberts Bank due to variable Fraser River flow and tidal mixing

ECCC concurs that there is large natural variation in salinity across Roberts Bank which, as noted in (1) above, contributes to the observed spatial and temporal differences in the diatom communities that comprise biofilm. There are however, also specific predicted changes in salinity creating uncertainty around the impacts of the Project that the Proponent has not considered. Predicted Project effects include a lowering in salinity and an increase of the residence time of freshwater from the Fraser River (EIS, Appendix 9.5-A). An entrainment of freshwater would restrict tidal flushing and create a more protracted decrease in salinity conditions over Roberts Bank, and dampen daily oscillations. Such conditions would fall outside the variability of the current system and would not be representative of current salinity regimes either on Canoe Passage, Brunswick Point or Roberts Bank.

Temporal variation in salinity

Two distinct periods are evident within the April 13 – May 17, 2018 data presented: April 13 to April 30, and May 1 to May 17, 2018 (e.g. see Figure 4-2 and Figure 3 -17). The first time period occurs before full initiation of the Fraser River freshet, and as large numbers of Western Sandpipers stopover in the area during northward migration. The second period coincides with the Fraser River freshet, and when few migrating Western Sandpipers are observed at Roberts Bank. In one year of study (2017), the sampling did not commence until the bulk of migrating birds had passed (Figure 4.1).

The Proponent’s analyses does not account for this biologically relevant partitioning. In the first time period, the salinity regimes of the three sites are similar, ranging from 5 to 30 PSU. In the second period, however, the pattern changes: salinity in the Canoe Pass Strata drops to near freshwater values (<5 PSU), whereas the salinity at Brunswick Point drops slightly (<10 PSU), and the salinity in the Intertidal Stratum remains the same (varying between 10 and 20 PSU). In this set of reports, the Proponent repeatedly states that fatty acid abundance is high across a wide range of salinity, and Canoe Pass is used as the freshwater endpoint of this spectrum. However, the characterization of Canoe Pass as a ‘freshwater’ site applies only to the second period, during which shorebird migration in nearly over, and may have limited utility in characterizing the salinity spectrum experience by migrating birds.

Spatial variation in responses to salinity

Spatially, biofilm at the three sites examined differ in their responses to salinity conditions. The Proponent found a positive association between salinity and fatty acid and carbohydrate productivity in the Canoe Passage Stratum (i.e., increases in salinity = increases biofilm productivity), while a negative association was identified at Brunswick Point (i.e., increases in salinity = decreases biofilm productivity), and a neutral

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association was found in the Intertidal Stratum. However, these correlations are based on average salinity, without consideration of the variance in salinity, which can trigger fatty acid production in diatoms (Pal et al. 2013). The need to consider average salinity as well as its variance can be observed in the covariate modelling (Table 3-21). The Proponent finds that fatty acid measures are positively correlated with 95th percentile of salinity (marine conditions), and conversely, negatively correlated with the 5th percentile of salinity (relatively freshwater conditions). If the fatty acid content of the mudflats depends on both the average saline conditions and the amplitude of the daily fluctuations, then it could explain these counter-intuitive results. Therefore, these correlations need to be interpreted within the context of a hypothesis related to the triggers of fatty acid production in biofilm.

In summary, and as advised in (1) above, ECCC advises that the projected change in the salinity regime would likely impact the quality and quantity of high fatty acid available for Western Sandpipers, and shorebirds generally, during northward migration to their breeding grounds (April/May).

(3) Biofilm is consistently documented in high abundance under varying salinity conditions across Roberts Bank, with biofilm fatty acid levels varying little between years

ECCC agrees that biofilm is abundant under varying salinity conditions, but disagrees with the Proponent’s 2018 biofilm assessment that fatty acids are generally available to shorebirds. In the 2018 Biofilm report, Figures depicting annual averages in fatty acid abundance or energy content (Figure 3-13, Figure 4-3) are plotted to compress annual variation, which prevents the reader from gauging the evidence directly. ECCC’s replotting of the approximate data from Figure 4-3 with an appropriate scale indicates that fatty acid abundance may vary significantly among the 3 years of the studies (see Figure 7.1 below). Fatty acid abundance appears lowest in 2017, coinciding with year of lowest counts of Western Sandpipers (Figure 7.1), indicating Western Sandpipers are responding to interannual abundance of fatty acids. In addition, fatty acid abundance at Roberts Bank varies widely between spring and winter, with lower abundance in the wintertime, and higher values in spring coinciding with the northward migration of sandpipers (see Figure 7.2 below). This seasonal variation underscores the need to understand the processes that trigger fatty acid production within biofilm.

The Proponent’s report also documents high variation in carbohydrate abundance. This annual variation in carbohydrate abundance may be linked to fatty acid abundance, given that diatoms produce carbohydrate in the exponential growth phrase, and fatty acids in the stationary growth phrase (Smith and Underwood 2000). Hence, the temporal patterns of carbohydrate production at all sites in 2018 (Figure 3-8) are negatively correlated to fatty acid production, indicating that production of fatty acids is high at the start of the first period (April 13- 20) when birds are migrating through the site. During the second period, carbohydrate production increases at all stations, coinciding with the development of the full freshet, a generally reduced and dampened salinity regime, and a levelling off in total fatty acid production to baseline conditions (~500 mg/m2).

Biofilm values separate out into the two salinity periods in 2018, and general spatial and temporal patterns are evident when each period is considered separately (for example, see Figure 3.8). During the first period (April), abundances of total fatty acids and their sub-components (total monounsaturated fats, total saturated fatty acids and total polyunsaturated fatty acids) appear high but variable in Canoe

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Passage (I, H), lower at sites adjacent to Brunswick Point (X, J), and intermediate in the Intertidal Stratum (Y, A, C). Elevated values observed at the start of the first period (April 13- 20) correspond to high fatty acid production conditions, with total fatty acid values being two to three times higher than the observed baseline of ~500 mg/ m2, particularly in the Canoe Passage Stratum.

Given the high fatty acid values at the start of the sampling period, the fatty acid production likely started earlier in April before sampling began. Due to the timing of the fieldwork, there are no data to analyze. In the second period (May 01-17), however, total fatty acid levels in Canoe Pass dropped to low - intermediate levels while the other two strata remained relatively the same. The general drop in total fatty acid values at all sites in the second period indicates the cessation of the high fatty acid phase and commencement of the growth and carbohydrate production phase, and corresponds to the lower salinities imposed by the freshet, particularly in Canoe Pass. This highlights the sensitivity of fatty acid production to even short-term temporal changes in salinity. Also, to note, patterns of biofilm production exhibit high inter-annual and inter-station variability underlining the importance of maintaining functionality of the whole system so that production increases/decreases in different areas can counterbalance each other. For example, the most productive station for fatty acids in 2018 (H) had lower median values for fatty acids than the Intertidal Stratum in 2016 and 2017.

In summary, the report documents intra- and inter-annual variation in fatty acid abundance, and when interpreted with literature on lipids and fatty acids and bird migration (Jenni and Jenni-Eiermann 1998, Guglielmo et al. 1998, Egeler and Williams 2000, Guglielmo 2010), supports the theory that Western Sandpipers exploit the high lipid pulses from biofilm on Roberts Bank and Canoe Passage, rather than feeding on carbohydrates, during the northward migration (Mathot et al. 2018). Additional evidence of the operating mechanisms for diatom productivity stem from the May 2018 field data. During the May 01-17 period, the salinity regimes were generally dampened/lowered at all three sites (Figure 4-2), and Achnanthidium (freshwater-type diatoms) became dominant in the biofilm community (Figure 3-23). In parallel, carbohydrate production increased sharply, and there was no evidence of high fatty acid production (Figure 3-8).

(4) Biofilm at Roberts Bank will continue to be abundant and capable of supporting migrating Western Sandpipers with the Project in place

ECCC finds insufficient evidence to support this statement. The Proponent has drawn conclusions beyond what is reasonable based on the measures of fatty acid abundance contained in this set of reports. The capacity to support migrating sandpipers cannot be assessed based on abundance estimates of fatty acid and carbohydrates alone, and must be placed in the context of demand/requirements from migrating sandpipers. The difference between supply (of biofilm) and demand (by shorebirds) was considered in the EIS (Biofilm and Infauna Capacity Calculations), and ECCC has previously described27 several concerns with those analyses. The 2016-2018 set of reports on biofilm have not addressed these key shortcomings.

In addition to these concerns, analyses of counts of Western Sandpiper conducted from 1991 to 2018 indicate abundances of Western Sandpipers are linked to discharge rates of the Fraser River (see Figure

27 ECCC’s Sufficiency Review of the EIS (CEAR 581)

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7.3 below). After correcting for strong daily variation in counts of Western Sandpipers at the site (Drever et al. 2014), lower numbers of Western Sandpipers are observed at Roberts Bank during days and years with larger discharges. Therefore, if the Project accentuates the effects of the Fraser River freshet on the mudflat habitat, then lower numbers of sandpipers can be expected.

ECCC’s review has determined that biofilm types and conditions supporting shorebirds are restricted temporally and spatially, and are not uniformly abundant. The 2018 Biofilm report assumes that Western Sandpipers are indiscriminate biofilm grazers, and interprets the high variability and productivity of diatom communities as evidence of abundant food irrespective of biofilm type and location. However, grazing by Western Sandpipers is a specialized foraging mode that enables rapid uptake of biofilm on intertidal estuarine mudflats. The predicted shift of biofilm towards coarser sediments would result in it becoming less available to migrating sandpipers. Further, the focus on carbohydrates in the 2018 and 2016-2017 biofilm studies ignores the understanding that migrating Western Sandpipers rely on fatty acids, rather than carbohydrates, for long-distance flights during northward migration (Jenni and Jenni-Eiermann 1998, Guglielmo et al. 1998, Egeler and Williams 2000, Guglielmo 2010). Therefore, the characterization of biofilm as abundant, without providing an understanding of the mechanisms behind the supply and demand of fatty acids and other essential nutrients, is insufficient to predict the Project’s indirect effects on food supply for migrating sandpipers.

ECCC Conclusion

Biofilm grazing for a shorebird at a stopover site during long-distance migration is a specialized feeding mode adapted to rapidly consuming fatty acids in diatoms from fine-grain muddy substrate. ECCC’s assessment of the Proponent’s field data, with a focus on the qualities of biofilm that are most relevant to feeding shorebirds, and to the impacts to the birds from predicted changes in geomorphological processes, reveals the high risks associated with the proposed Project.

The 2018 Biofilm report builds on the Proponent’s previous studies, and serves to better resolve potential Project effects on intertidal biofilm grazed by shorebirds. There appears, however, to be a fundamental dichotomy between the Proponent and ECCC in the interpretation of the available information. Specifically, and from the 2018 Biofilm report, the Proponent maintains that the results from their latest field work ‘reduces uncertainty concerning effects from the proposed project and strengthens conclusions regarding the likelihood of no significant adverse effects to biofilm or Western Sandpipers as reported in the EIS’. In contrast, ECCC finds that, while the latest fieldwork reduces the uncertainty, it strengthens the interpretation that the Project carries a high risk of reducing the availability and quality of the main food source (biofilm), thereby threatening the successful migration of hundreds of thousands of Western Sandpipers. As in previous submissions28, ECCC concludes that the Project would present adverse effects on biofilm and Western Sandpipers, as such effects would be likely high in magnitude, encompass biofilm within the entire LAA (local) and Western Sandpipers over the entire Pacific Canada (national), and would be continuous, permanent, and irreversible. The additional year of data in the 2018 Biofilm report does

28 ECCC’s Sufficiency Review of the EIS (CEAR 581), and, ECCC response to Review Panel IR-09 and IR-10 (CEAR 1146)

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not change ECCC’s previously stated detailed responses (see CEAR 1346). The data collected to date, including in 2018, and analyses do not, in ECCC’s view, support the Proponent’s position that:

1. Biofilm at Roberts Bank is not limiting for Western Sandpipers; and

2. The Project would not adversely affect the quantity and quality of food available to Western Sandpipers and other shorebirds.

Overall, ECCC continues to advise that:

1. Not all intertidal biofilm is equal for shorebirds.

2. The Project is likely to compromise the ecological mechanisms responsible for producing biofilm required by shorebirds.

3. The projected change in the salinity regime presents a high risk of reducing the quality and quantity of high fatty acid content, marine-type biofilm that is important to Western Sandpipers, and shorebirds generally, during northward migration to their breeding grounds.

ECCC recognizes the differences in the interpretation of the technical data and the associated risks to shorebirds. As this is a rapidly evolving scientific area, the Panel may wish to obtain an additional perspective from an independent, arms-length review of the datasets by leading authorities on mudflat ecology, biofilm, diatoms, fatty acids and shorebird physiology.

Other Technical Considerations:

Chlorophyll-a

Contrary to conclusions in the 2018 Biofilm report (page 84, Conclusion 8), Chlorophyll-a is a poor proxy for fatty acid or carbohydrate abundance. It is weakly correlated with fatty acid or carbohydrate abundance (Figure 3-10). In 2018, Chlorophyll-a values remained at similar levels at all stations throughout the entire sampling period (April 13 – May 17), despite the large changes in both fatty acid and carbohydrate values (see Figure 3-8). The abundance of Chlorophyll-a also has a different relationship with 5th percentile temperature than fatty acids (Table 3-21), indicating its abundance may be driven in part by different ecological processes.

Invertebrates

The Proponent determined from their 2018 field studies that invertebrates represent an alternative and abundant source of fatty acids to Western Sandpipers during northward migration (Question 4, page vi. and 5.0-12 page 80). ECCC disagrees with the Proponent’s conclusion, given that invertebrate abundance was low at the Canoe Pass and Intertidal (Roberts Bank) Strata where the muddy physical conditions favoured biofilm. Invertebrate abundance was only found to be high in the sandy conditions of the Brunswick Point Stratum, which are unsuitable for biofilm grazing by Western Sandpipers. To note, invertebrates are generally less important in the diets of northward migrating Western Sandpipers than biofilm (Kuwae et al. 2008; Jimenez et al. 2015). In addition, invertebrates have similar fatty acid profiles to

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biofilm (2018 Biofilm report, Appendix D), including high amounts of the fatty acid 16:1n-7 (Pond et al. 1998), indicating that invertebrates are actively feeding on biofilm. As such, they would not be an alternative source of fatty acids if Project induced effects compromised the biofilm. Essentially, diatoms in biofilm producing the fatty acids required for shorebird migration are the same diatoms as those being consumed directly or indirectly by invertebrates. Given the high contribution of biofilm to the primary productivity of estuarine ecosystems (Underwood and Kromkamp 1999), compromising the mechanism by which biofilm produces fatty acids may have ecosystem-wide consequences.

Biologically relevant time windows

To resolve more biologically meaningful patterns in section 3.1.3.1, Spring Spatial and Temporal Distributions, and other sections, the Proponent should re-run analyses using combined sampling dates (April 13 – May 17) for two separate temporal windows, representing the April and May dates, at the Canoe Passage, Brunswick Point and Intertidal Strata independently.

References

Adarme-Vega, T. C., Lim, D. K., Timmins, M., Vernen, F., Li, Y., & Schenk, P. M. (2012). Microalgal biofactories: a promising approach towards sustainable omega-3 fatty acid production. Microbial cell factories 11: 96.

Egeler, O., & Williams, T. D. (2000). Seasonal, age, and sex-related variation in fatty-acid composition of depot fat in relation to migration in western sandpipers. The Auk 117: 110—119.

Flemming, H. C. (2002). Biofouling in water systems–cases, causes and countermeasures. Applied microbiology and biotechnology 59: 629-640.


Galloway A.W.E., & Winder, M. (2015). Partitioning the relative importance of phylogeny and environmental conditions on phytoplankton fatty acids. PLoS ONE 10(6): e0130053.

Guglielmo, C. G. (2010). Move that fatty acid: fuel selection and transport in migratory birds and bats. Integrative and Comparative Biology 50: 336–345.

Guglielmo, C. G., Haunerland, N. H., & Williams, T. D. (1998). Fatty acid binding protein, a major protein in the flight muscle of migrating western sandpipers. Comparative Biochemistry and Physiology Part B: Biochemistry and Molecular Biology 119: 549-555.

Hildebrand, M., Davis, A. K., Smith, S. R., Traller, J. C., & Abbriano, R. (2012). The place of diatoms in the biofuels industry. Biofuels 3: 221-240.


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Jiménez, A., Elner, R. W., Favaro, C., Rickards, K., & Ydenberg, R. C. (2015). Intertidal biofilm distribution underpins differential tide-following behavior of two sandpiper species (Calidris mauri and Calidris alpina) during northward migration. Estuarine, Coastal and Shelf Science 155: 8-16.

Kuwae, T., Beninger, P. G., Decottignies, P., Mathot, K. J., Lund, D. R., & Elner, R. W. (2008). Biofilm grazing in a higher vertebrate: the western sandpiper, Calidris mauri. Ecology 89: 599-606.

Levitan, O., Dinamarca, J., Hochman, G., & Falkowski, P. G. (2014). Diatoms: a fossil fuel of the future. Trends in biotechnology 32: 117-124.

Mathot, K. J., Piersma, T., & Elner, R. W. (2018). Shorebirds as Integrators and Indicators of Mudflat Ecology. In Mudflat Ecology (pp. 309-338). Springer, Cham.

Pal, D., Khozin-Goldberg, I., Didi-Cohen, S., Solovchenko, A., Batushansky, A., Kaye, Y., & Boussiba, S. (2013). Growth, lipid production and metabolic adjustments in the euryhaline eustigmatophyte Nannochloropsis oceanica CCALA 804 in response to osmotic downshift. Applied microbiology and biotechnology 97: 8291-8306.

Pond, D. W., Bell, M. V., Harris, R. P., & Sargent, J. R. (1998). Microplanktonic polyunsaturated fatty acid markers: a mesocosm trial. Estuarine, Coastal and Shelf Science 46: 61-67.

Schnurr, P. J., & Allen, D. G. (2015). Factors affecting algae biofilm growth and lipid production: a review. Renewable and Sustainable Energy Reviews 52: 418-429.

Schnurr, P.J., Drever, M.C., Kling, H., Elner, R.W., & Arts, M. (2019). Seasonal changes in fatty acid composition of estuarine intertidal biofilm: implications for western sandpiper migration. Estuarine, Coastal and Shelf Science. Submitted.

Schwenk, D., Seppälä, J., Spilling, K., Virkki, A., Tamminen, T., Oksman-Caldentey, K. M., & Rischer, H. (2013). Lipid content in 19 brackish and marine microalgae: influence of growth phase, salinity and temperature. Aquatic ecology 47: 415-424.

Sharma, K. K., Schuhmann, H., & Schenk, P. M. (2012). High lipid induction in microalgae for biodiesel production. Energies 5: 1532-1553.

Smith, D. J., & Underwood, G. J. (2000). The production of extracellular carbohydrates by estuarine benthic diatoms: the effects of growth phase and light and dark treatment. Journal of Phycology 36: 321-333.

Underwood, G., & Kromkamp, J. (1999). Primary production by phytoplankton and microphytobenthos in estuaries. Advances in ecological research, 29, 93-153.

WorleyParsons (2015). Roberts Bank Terminal 2 – Technical Data Report Biofilm Physical Factors. http://www.robertsbankterminal2.com/wp-content/uploads/RBT2-Biofilm-Physical-Factors-TDR1.pdf

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Figure 7.1: Fatty Acid Abundance and Western Sandpipers on Roberts Bank, British Columbia, Canada.

Figure 7.1 represents mean total fatty acid abundances at Roberts Bank from Figure 4-3 in the 2018 Biofilm report. Points were pulled from the Proponent’s 2018 Biofilm report, Figure 4-3, using DataThief software and are approximate. Solid lines show predicted annual trends in fatty acid abundance from a generalized linear model that included an interaction with day of year and year. Mean fatty acid abundance (Day of Year 123) differed significantly in 2016 from other years and was lowest in 2017. The seasonal trend was significant, and significantly different in 2018 from the other years. Seasonal patterns in shorebird counts at Roberts Bank in the 3 years are shown using the seasonal trends from ongoing monitoring by the Canadian Wildlife Service and estimated from the model described in Drever et al. 2014 (Journal of Field Ornithology).

Table 7.1: Parameter estimates from generalized linear model used to describe seasonal and interannual trends in mean total fatty acid abundances at Roberts Bank using data extracted from Figure 4-3 of the Proponent’s 2018 Biofilm report. Day of year is centered and rescaled and the intercept is 2016 on day of year 123.

Model Term LCI Estimate UCI P-value (Intercept) 6.65 6.76 6.86 <0.0001 Day of Year 0.03 0.32 0.60 0.0454 2017 -0.83 -0.48 -0.20 0.0109 2018 -0.51 -0.32 -0.15 0.0048 DOYx2017 -0.39 0.15 0.71 0.5960 DOYx2018 -0.90 -0.51 -0.12 0.0255

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Figure 7.2: Seasonal differences in Fatty Acid Abundance on Roberts Bank, British Columbia, Canada.

Organic content, total lipid, chlorophyll-a and amounts of major groups of fatty acids at Roberts Bank, British Columbia, Canada, during spring 2016 and winter 2017 (Schnurr et al. 2019). SFA = saturated fatty acids. MUFA = monounsaturated fatty acids. PUFA = polyunsaturated fatty acids. Box plots represent the distribution of observed values, where midline is the median, with the upper and lower limits of the box

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being 75th and 25th percentiles. Whiskers extend up to 1.5× the interquartile range, and outliers are depicted as points. Blue circles indicate predicted means from linear mixed effects models, and bounds are 95% predictions intervals from fixed effects. Dashed lines indicate no significant differences between seasons.

Figure 7.3: Abundance of Western Sandpipers at Roberts Bank in relation to the daily discharge rate of the Fraser River.

Marginal effect of Fraser River discharge on Western Sandpiper abundances at Roberts Bank, BC. Counts of Western Sandpipers are from ongoing monitoring by the Canadian Wildlife Service, Environment and Climate Change Canada. Discharge rates (m3/sec) are from the hydrometric station at Hope, BC. Points show residuals of baseline model (trend model in Drever et al. (2014)), plotted against Fraser River daily discharge. The lines with associated 95% confidence intervals are drawn from a model that includes the baseline model plus an interaction between migratory period (Early: April 15-29 (red), Late: April 30 to 15 May (blue)), and daily Fraser River discharge. Therefore, after correcting the seasonal changes in abundance of sandpipers, fewer birds are counted at Roberts Bank when discharge rates are high (exceeding 3000 m3/sec). A small number of count days were missing discharge values (4%) and were interpolated (triangles).

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Appendix 8: ECCC Expert Witness Panel Curriculum Vitae Air Quality Richard Holt Snehal Lakhani Robert Nissen Katelyn Wells Coastal Birds Assessment Sean Boyd Jayme Brooks Mark Drever Robert Elner Blair Hammond David Hope Elsie Krebs Kathleen Moore Andrew Robinson

ECCC

Richard Holt, P.Eng.

Head of Clean Transportation, EPB/ETD

Environment and Climate Change Canada

401 Burrard St.

Vancouver, British Columbia, V6C 3S5

SUMMARY

Richard Holt is the Head of Clean Transportation, in the Cross Sectoral Energy Division, Energy and

Transportation Directorate, Environmental Protection Branch of ECCC.

Mr. Holt leads a team with responsibility for providing technical and policy advice on emissions from the

marine, aviation, and rail sectors. Among the team’s recent projects in the marine sector are the

development and operation of the Marine Emissions Inventory Tool; a study to assess the current and

future environmental impacts of shipping emissions in Canada’s Arctic; and an evaluation of the potential

release of fugitive Volatile Organic Compounds from petroleum tankers.

Since 2013, Mr. Holt has been an Advisor on the Canadian Delegation for meetings of the International

Maritime Organization’s Marine Environment Protection Committee in order to provide technical analysis

and advice on emission reduction approaches for international shipping.

EXPERIENCE

12/2016-3/2018; 7/2018-Present Head, Clean Transportation, CSED, ECCC

Gatineau, QC / Vancouver, BC

Provided analysis and advice to ensure Pan-Canadian Framework initiatives (carbon pricing and Clean Fuel Standard) appropriately consider technical, and policy issues relevant to the aviation, rail, and marine sectors.

Oversaw the development of an innovative Marine Emissions Inventory Tool to evaluate the impacts of future policy measures to address ship emissions.

In collaboration with other departments, oversaw development of aviation workplan to evaluate emissions from use of biojet fuel.

Provided strategic advice and briefings to senior departmental officials on technical and policy issues.

3/2018 - 7/2018 A/Manager, Integrated Transportation Policy, CSED, ECCC Gatineau, QC / Vancouver, BC

Provide continuity and strategic leadership in charting development of $1.2M workplan. Lead Environment and Climate Change Canada’s engagement in interdepartmental work on

emerging files including development of a national zero-emissions vehicle strategy; mitigating

off-road greenhouse gas emissions; and addressing emissions from international aviation and

marine transport.


Head of Clean Transportation, EPB/CSED


4/2013 - 12/2016 Head, Marine Analysis, TD, ECCC

Gatineau, QC / Vancouver, BC

Strategic work planning and financial management of $500k annual operating budget

Led research to inform regulatory decision-making to reduce the impacts of marine vessels on the environment.

Provide strategic advice and briefings to senior departmental officials on technical and policy issues relating to greenhouse gas and air pollutant emissions from marine vessels.

Represent Canada as a delegate at the International Maritime Organization and Arctic Council, and present research to international audiences.

Co-chair government-industry stakeholder working group on marine vessel emissions. 1/2009 - 4/2013 Senior Program Engineer, TD, ECCC

Gatineau,QC/ Vancouver,BC

Provided analysis and technical expertise as a member of Canadian delegation in international negotiations to establish greenhouse gas emission regulations for aviation and commercial shipping.

Provided technical leadership, analysis, and policy advice in the development of new regulations for locomotive air pollutant emissions and heavy-duty vehicle greenhouse gas emissions.

Participated in multi-agency collaborative workgroups to address air quality management issues in several transport sectors including rail; vehicle inspection and maintenance; marine and ports; and transit authority emissions planning.

3/2004 – 1/2009 Senior Program Engineer, Air Emissions Management Unit, ECCC Vancouver, BC

Developed and completed multi-stakeholder diesel emissions reductions projects, including a province-wide school bus retrofit project and a locomotive emissions reduction demonstration.

Developed and delivered workshops on diesel emissions reduction for private and public agency fleet and environmental managers.

Conceived and led a new railway industry-government partnership to facilitate information exchange and promote effective emission reduction opportunities for railways.

Evaluated and provided expert technical advice on emissions for environmental assessments for transportation infrastructure projects.

1/2001 - 3/2004 Application Engineer, Norpac Controls Ltd.

Burnaby, BC Designed and applied complex process control strategies for industrial clients.

Developed excellent negotiation and customer service skills while successfully managing several of the company’s largest accounts.


Head of Clean Transportation, EPB/CSED


7/1997 - 1/2001 Assistant Project Engineer, Metro Vancouver Burnaby, BC

Analysed emissions data and provided environmental reports on the Burnaby waste -to-energy plant to provincial regulatory authority and Metro Vancouver Board.

Implemented several environmental improvements to the Burnaby waste-to-energy plant including a fly ash treatment system; optimizing reagent addition for acid gas control; and design and execution of a waste composition and analysis study.

10/1996 – 7/1997 Process Engineer, Cominco Engineering Services Richmond, BC

Operator in a hydrometallurgical research facility.

Education

B.Sc.(Eng.) Environmental Engineering) with Honours - 1996 University of Guelph (Guelph, Ontario)

Professional Association

Professional Engineer, Engineers and Geoscientists BC (since 2001)

Snehal Lakhani, P.Eng Senior Program Engineer, EPOD, ESB

Environment Canada 1166 West Pender

Vancouver, British Columbia V6E 3H8

Curriculum Vitae

SUMMARY Mr. Snehal Lakhani is the Senior Program Engineer, Environmental Operation Division, Environmental Stewardship Branch with Environment Canada. As Senior Engineer, Mr. Lakhani has had experience in resource extraction projects and environmental impacts as they relate to ECCC mandate areas. Since 2012, Mr. Lakhani has been reviewing various environmental assessment projects with a specific focus on air emissions and impacts

EXPERIENCE October 2012 – Present, Senior Program Engineer (Air Issues Liaison)

Provide air expertise and liaison for projects undergoing an environmental assessment in BC and Alberta.

Liaise with other Tier 2 and Tier 3 experts on specific air related concerns or expertise dependent on project needs.

Regional lead on the Air Network to develop consistent approaches to air reviews across the country. Led the development of generic air advice and work on the environmental outcomes.

April 2009- October 2012. Senior Program Engineer (Municipal)

As the regional lead (BC and Yukon) for the municipal wastewater effluent file:

Lead two national working groups to assist in the development of proposed Wastewater Systems Effluent Regulations (WSER) under the Fisheries Act.

Developed the compliance strategy for the proposed WSER.

Developed a national approach on work plans for the municipal wastewater sector which included rationalizing costs for program activities.

Snehal Lakhani, P.Eng Senior Program Engineer, EPOD, ESB

Environment Canada 1166 West Pender

Vancouver, British Columbia V6E 3H8

Curriculum Vitae

EDUCATION 1986-1988 Bachelor of Engineering Degree, Chemical

Lakehead University,

Thunder Bay, Ontario

1984-1986 Diploma of Engineering Technology, Chemical

Lakehead University,

Thunder Bay, Ontario

PROFESSIONAL CERTIFICATIONS Registered Professional Engineer in Ontario (PEO) 1990

Registered Professional Engineer in BC (APEGBC) 1995

ROBERT NISSEN RESUME


201 – 401 Burrard Street

EDUCATION/TRAINING: Lakes International CALPUFF 2016 Environment Canada Project Planning and Control: Techniques and Tools 2008 Environment Canada Writing in Plain Language 2008 Environment Canada SMOKE (Emissions Software) Training 2006 Environment Canada CMAQ (Air Quality Model) Training 2006 Environment Canada WATFLOOD hydrological model workshop 2000 University of Toronto Ph.D. Physics (cloud physics group) 1996 University of Toronto M.Sc. Physics (cloud physics group) 1990 University of British Columbia B.Sc. Physical Geography 1984 WORK EXPERIENCE: Environment Canada Physical Scientist - Air Quality 2006-present Environment Canada Physical Scientist (assignment: air quality group) 2005-2005 Environment Canada Weather Radar Applications Scientist 2000-2006 Environment Canada Contractor 1998-2000 Environment Canada Post-Doctoral Researcher (Visiting Fellow) 1996-1998 University of Toronto Scientific Programmer 1985-1988 Environment Canada Meteorologist-In-Training 1984-1985

SCIENTIFIC EXPERIENCE/SKILLS: Atmospheric/Earth Sciences

Participated in field experiments (e.g. Joint Warm Rain Experiment, Penang, Malaysia; Canadian Atlantic Storms Project, St. John’s, NL; Toronto Winter Storms Program) and gained strong observational skills enabling suitable adjustments in data collection strategies in tandem with rapidly changing weather conditions

Performed hydrometeorological analyses for the Capilano River and Bear Creek watersheds Gained expertise in cloud feature recognition and relation to cloud microphysical and meteorological

processes Developed procedures through usage of Excel and Mappoint software to generate lightning strike

location maps which are forwarded via intermediaries to the media Assessed instrument behaviour aboard CRUISER air quality lab and communicated developing

problems to collaborators Ran GEM LAM meteorological model and assessed FST-formatted outputs using CMC tools such as

xrec, voir, and editfst Maintained regional archive of GEM LAM outputs through monitoring of acquisition scripts and the

use of the xrarc tool when needed to extract from CMC’s main archive, and developed fact sheet Trained in CMAQ and SMOKE air quality software applications Used netCDF file utilities to concatenate netCDF files, extract and compute specific fields, and for

visualization (e.g. IDV), and implemented CMC’s FST-to-netCDF converter Processed air quality scenario data to assess statistical metrics for PM2.5 and ozone exceedances Assessed numerical model output to evaluate mixing heights through consideration of various

boundary layer processes pertinence to air quality issues and influence of different surface types (e.g. water, forest, agricultural, urban).

Assessed mixing height and ventilation index values derived from radiosonde data.


Weather Radar Provided recommendations to forecasters for use of suitable radar products and concurrent satellite

imagery for various diagnostic assessments, e.g. convection in mountainous terrain, rainshadows, virga, forest fire smoke characteristics, wind phenomena)

Developed creative solutions for analysis software development, e.g. influence of various clutter-removal filters; radar sensitivity variations with range, time, and for comparison with neighboring radars for cross-calibration purposes

Developed software to perform Velocity Azimuth Display (VAD) and Extended VAD (EVAD) analyses for assessment of wind field variations with height and precipitation fall speed variation with height

Initiated development of software to geo-reference weather radar data, facilitating rapid identification of relevant radar data for requested locational studies (e.g. accident investigations; watershed rainfall estimates); radar cross-calibration analyses for quality control purposes; integration and comparison of weather radar-derived precipitation input estimates with surface-based precipitation estimates and stream runoff data in complex terrain; and future dual-Doppler wind retrieval analyses

Participated in environmental assessments for Mt. Silver Star and Prince George radars Communications

Presented scientific information at various conferences (see list below) and through multi-media “Kstream” presentations in the series “Robert’s Radar Reminders”

Delivered internal presentations ‘URP Techniques on Severe Storm Detection’ at the 2005 PSPC spring seminar series, and ‘Radar and Convection’ at the 2005 PSPC special summer convection seminars

Collaborated with UBC graduate students to present weather radar data and interpretation Collaborated with consulting firms such as RWDI, Jacques Whitford, and Levelton on various air

quality aspects Served as the EC representative on the PYR committee and the PYR representative on the national

EC committee for National Public Service Week in 2006 Proofread and critiqued colleagues’ written scientific and technical reports

MEMBERSHIPS:

Canadian Meteorological and Oceanographic Society (CMOS), Scientific Program Committee, CMOS Congress 2005 AURAMS, m3user, NW-AIRQUEST email distribution lists EC Emissions Processing Interest Group, and MANTIS subscriber Royal Astronomical Society of Canada

PUBLICATIONS: Refereed Papers Teakles, A., R. So, B. Ainslie, R. Nissen, C. Schiller, R. Vingarzan, I. McKendry, A. M. Macdonald, D. A. Jaffe, A. K. Bertram, K. B. Strawbridge, W. R. Leaitch, S. Hanna, D. Toom, J. Baik, and L. Huang, 2017, ‘Impacts of the July 2012 Siberian fire plume on air quality in the Pacific Northwest ‘, Atmos. Chem. Phys., 17, 2593–2611, 2017. Available online at: https://www.atmos-chem-phys.net/17/2593/2017/ Makar, P., R. Nissen, A. Teakles, J. Zhang, Q. Zheng, M. D. Moran, H. Yau, and C. diCenzo, 2014,‘Turbulent transport, emissions and the role of compensating errors in chemical transport models’, Geosci. Model Dev., 7, 1001–1024, 2014. Online at: https://www.geosci-model-dev.net/7/1001/2014/gmd-7-1001-2014.pdf

List, R., C. Fung, R. Nissen, 2009: ‘Effects of Pressure on Collision, Coalescence, and Breakup of Raindrops, Part I: Experiments at 50 kPa’, J. Atmos. Sci., 66, 2190-2203. Online at http://ams.allenpress.com/archive/1520-0469/66/8/pdf/i1520-0469-66-8-2190.pdf List, R., R. Nissen, C. Fung, 2009: ‘Effects of Pressure on Collision, Coalescence, and Breakup of Raindrops, Part II: Parameterization and Spectra Evolution at 50 and 100 kPa’, J. Atmos. Sci., 66, 2204-2215. Online at http://ams.allenpress.com/archive/1520-0469/66/8/pdf/i1520-0469-66-8-2204.pdf Nissen, R., R. List, D. Hudak, G. McFarquhar, R.P. Lawson, N.P. Tung, S.K. Soo, and T.S. Kang, 2005: 'Constant raindrop fall speed profiles derived from Doppler radar data analysis for steady non-convective precipitation', J. Atmos. Sci., 62, 220-230. Nissen, R., D. Hudak, S. Laroche, R. de Elia, I. Zawadzki, Y. Asuma, 2001: 'Three-dimensional wind field retrieval applied to snow events using Doppler radar', J. Atmos. Oceanic Technol., 18, 348-362. Gultepe, I., G. Isaac, D. Hudak, R. Nissen, J.W. Strapp, 2000: ‘Dynamical and microphysical characteristics of Arctic clouds during BASE’, J. Climate, 13, 1225-1254. Hudak, D., and R. Nissen, 1996: 'Doppler Radar Applications in Major Winter Snowstorms', Atmos. Res., 41, 109-130. McFarquhar, G.M., R. List, D. Hudak, R. Nissen, J.S. Dobbie, N.P. Tung,T.S. Kang, 1996: 'Flux Measurements of Pulsating Rain with a Disdrometer and Doppler Radar during Phase II of the Joint Tropical Rain Experiment in Malaysia', J. Appl. Meteor., 35, 859-874. List, R., D. Hudak, R. Nissen, N.P. Tung, S.K. Soo, T.S. Kang, 1988: 'Raindrop Size Distributions in Warm Rain at Penang', Tropical Precipitation Measurements, J.S. Theon and N. Fugono, Eds., A. Deepak Publishing, Hampton, VA, 271-278. Papers in Refereed, Printed Conference Proceedings D. Hudak, N. Donaldson, R. Nissen, S. Boodoo, and R.P. Ford, 2004: ‘An Assessment of the Errors Associated with Doppler Radar-based QPE under Various Weather Scenarios’, 8th International Conference on Precipitation, Vancouver, BC, 8-11 August 2004. Nissen, R., 2004: ‘The Digital Rainfall Intensity Project (DRIP): Real-Time Comparison of Radar-Derived and Raingauge-Measured Amounts’, Pacific Northwest Weather Workshop extended abstracts, Seattle, 27-28 February, 2004. Nissen, R., D. Hudak, L. Neil, N. Donaldson, S. Boodoo, R.P. Ford, and P. Campbell, 2003: ‘Relative Importance of Factors Degrading Quantitative Precipitation Estimates for Heavy Rainfall Events in Coastal and Continental Locations’, AMS 31st Radar Meteorology Conference, Seattle, WA, 6-12 August 2003, 216-219. Zhou, Y., and R. Nissen, 2003: ‘3D Wind Field Retrieval Over Complex Terrain Using the Laroche-Zawadzki Single-Doppler Velocity Retrieval Technique’, AMS 31st Radar Meteorology Conference, Seattle, WA, 6-12 August 2003, 327-330. Nissen, R., D. Dudley, and L. Funk, 2003: ‘Negative Scanning From A High Elevation Radar: Operational Examples’, AMS 31st Radar Meteorology Conference, Seattle, WA, 6-12 August 2003, 860-862. Ford, R.P., D. Hudak, N. Donaldson, R. Nissen, S. Boodoo, L. Neil, P.Campbell, B. Murphy and P. Pilon, 2002: 'An Evaluation of the Importance of Various Error Sources to Doppler Radar-based Rainfall Estimates in Southern Ontario and Southwestern British Columbia, Canada', World Weather Research Programme's International Conference on Quantitative Precipitation Forecasting, Reading, UK.

Nissen, R., and D. Hutchinson, 2001: ‘The January 4-5, 2001 Rainstorm:Sensitivity of Radar-Derived Precipitation Amounts to Bright Band Corrections’, Extended Abstracts, Pacific Northwest Weather Workshop, Seattle, Washington, 2-3 March. Nissen, R., and R. List, 1998: 'Equilibrium Raindrop Size Distributions and Observed Spectra Evolution', Preprints of the Conference on Cloud Physics and 14th Conference on Planned & Inadvertent Weather Modification, Everett, Washington, USA, 17-21 August, 403-406. Nissen, R., D. Hudak, S. Laroche, I. Zawadzki, R. Elias, 1997: 'Three-Dimensional Wind Field Retrieval of Doppler Radar Data in Arctic Storm Events', Proceedings, Conference on Polar Processes and Global Climate, Orcas Island, Washington, USA, 3-6 November, Vol. 2, 176-178. Hudak, H., R. Nissen, P. Rodriguez, 1997: 'Doppler Radar Techniques/Observations during BASE', Proceedings, 2nd Scientific Workshop for the MacKenzie GEWEX Study (MAGS), Saskatoon, Canada, 23-26 March,61-65. Gultepe, I., G.A. Isaac, D. Hudak, A. Korolev, R. Nissen, J.W. Strapp,1997: 'Microphysical and Dynamical Characteristics of Arctic Clouds during BASE', 27th Arctic Workshop, Ottawa, Canada, 27 February-2 March, p. 103. Nissen, R., and R. List, 1996: ‘Doppler radar-derived profiles of raindrop terminal velocities in stratiform rain’, Proceedings, 12th Intern. Conf. on Clouds and Precipitation, Zurich, Switzerland, 19-23 August, Vol. 1, 35-38. Nissen, R., and R. List, 1992: 'The Effects of Pressure on Equilibrium Raindrop Size Distributions', Proceedings, 11th International Conference on Clouds and Precipitation, Montreal, Canada, 17-21 August 1992, 107-110. List, R., R. Nissen, G.M. McFarquhar, D. Hudak, N.P. Tung, T.S. Kang, S.K. Soo, 1991: 'Properties of Tropical Rain', Preprints of the 25th International Conference on Radar Meteorology, Paris, France, 24-28 June 1991, 774-777. List, R., G.M. McFarquhar, D. Hudak, R. Nissen, N.P. Tung, T.S. Kang,1991: 'Time Integrated Rain Spectra in Tropical Rain and their Explanation', Annales Geophysicae (Atmospheres, Hydrospheres, and Space Sciences) of the European Geophysical Society XVI General Assembly, Wiesbaden, Germany, 22-26 April 1991, C575-C576. List, R., D. Hudak, R. Nissen, T.S. Kang, N.P. Tung, S.K. Soo, 1989: 'New Concepts on Steady Tropical Rain, with Applications', 5th WMO Scientific Conference on Weather Modification and Applied Cloud Physics, Beijing, 5-8 May, 1989, 431-434. List, R., D. Hudak, R. Nissen, N.P. Tung, S.K. Soo, T.S. Kang, 1988: 'Results from Warm Rain Studies in Penang, Malaysia', Proceedings,10th International Cloud Physics Conference, Bad Homburg, FRG, 15-20 August, 1988, Vol. 2, 446-448. Papers Presented At Conference in Report Form Nissen, R., C. di Cenzo, N. McLennan, H. Landry, D. Talbot, X. Qiu, 2008: ‘GEM LAM Modelling for Coastal British Columbia Air Quality Issues’, Conference Paper for Canadian Meteorological and Oceanographic Society 42nd Annual Congress, Kelowna, Canada. Qiu, X., P. Dallaire, M. Gauthier, J. Lundgren, M. Lepage, W. Boulton, C. di Cenzo, R. Nissen, 2008 : ‘CMAQ Modelling in Coastal Pacific Northwest with GEM-LAM Data’, Conference Paper for Canadian Meteorological and Oceanographic Society 42nd Annual Congress, Kelowna, Canada.

Zhou,Y., R. Stull, and R. Nissen, 2005: ‘Observational Error Statistics for Radar Data Assimilation’, Conference Paper for Canadian Meteorological and Oceanographic Society 39th Annual Congress, Vancouver, Canada. Zhou, Y., R. Stull, and R. Nissen, 2005: ‘Single-Doppler Radar Wind-Field Retrieval Experiment on a Qualified Velocity-Azimuth Processing Technique’, Ninth Symposium on Integrated Observing and Assimilation Systems for the Atmosphere, Oceans, and Land Surface (IOAS-AOLS), San Diego, January 2005. Nissen, R., and L. Neil, 2004: 'The BC Wildfires of 2003: Tracers for Detection of Atmospheric Features by Weather Radar and Satellites’, Conference Paper for Canadian Meteorological and Oceanographic Society 38th Annual Congress, Edmonton, Canada. Nissen, R., L. Neil, D. Hutchinson, and S. Hamilton, 2000: ‘The Bear Creek Hydrometeorological Project’, Conference Paper for Canadian Meteorological and Oceanographic Society 34th Annual Congress, Victoria, Canada. Nissen, R., and R. List, 1996: 'Raindrop Terminal Velocity Profiles in Stratiform Rain', Conference Paper for Canadian Meteorological and Oceanographic Society 30th Annual Congress, Toronto, Canada. Hudak, D., R. Nissen, and R. List, 1994: 'Doppler Radar Signatures of Precipitation in Major Winter Snowstorms', Conference Paper for Canadian Meteorological and Oceanographic Society 28th Annual Congress, Ottawa, Canada. List, R., and R. Nissen, 1988: 'Rain Spectra and Equilibrium Peaks Measured in Toronto in 1987', Conference Paper for Canadian Meteorological and Oceanographic Society 22nd Annual Congress, Hamilton, Canada. Technical Report (Data Catalogue) List, R., D. Hudak, R. Nissen, N.P. Tung, S.K. Soo, T.S. Kang, 1988: 'Joint Warm Rain Experiment of the Malaysian Meteorological Service and the University of Toronto, Canada, October 20 to November 1, 1986’. A report jointly prepared by the Meteorological Service of Malaysia and the University of Toronto, Canada, (Data catalogue), Printed by the Government of Malaysia, March 1989, pp. 107. Theses:

Ph.D. Thesis: 'Effects of Air Pressure on Raindrop Size Distributions: Modelling and Field Data Verification', 1996, University of Toronto

M.Sc. Report: 'Pressure Effect on Raindrop Size Distributions', 1990, University of Toronto Honours B. Sc. Graduating Essay: 'Scalar Averaging and Vector Averaging of Wind Data', 1984,

University of British Columbia CONFERENCE PARTICIPATION:

American Meteorological Society 12th Fire and Forest Meteorology Symposium, held at Boise, ID May 2018

Canadian Meteorological and Oceanographic Society 51st Annual Congress, held at Toronto, ON June 2017

Canadian Meteorological and Oceanographic Society 50th Annual Congress, held at Fredericton, NB June 2016

Canadian Meteorological and Oceanographic Society 48th Annual Congress, held at Rimouski, PQ, June 2014

Canadian Meteorological and Oceanographic Society 47th Annual Congress, held at Saskatoon, SK, June 2013

Canadian Meteorological and Oceanographic Society 46th Annual Congress, held at Montreal, PQ, June 2012

CMAS Conference in Chapel Hill, NC Oct. 2011

Canadian Meteorological and Oceanographic Society 45th Annual Congress, held at Victoria, BC, June 2011

CMAS Conference in Chapel Hill, NC Oct. 2010 Environmental Prediction in Canadian Cities workshop in Vancouver, BC, Dec. 2008 Canadian Meteorological and Oceanographic Society 42nd Annual Congress, held at Kelowna, BC,

May 2008 Air Quality Forecaster’s Forum in Montreal, PQ Nov. 2006 CMAS Conference in Chapel Hill, NC Oct. 2006 Canadian Meteorological and Oceanographic Society 39th Annual Congress, held at Vancouver, BC,

May-June 2005 BC Clean Air Forum, held at Richmond, BC, April 2005 8th International Conference on Precipitation, held at Vancouver, BC, August 2004 Canadian Meteorological and Oceanographic Society 38th Annual Congress, held at Edmonton, AB,

May-June 2004 Pacific Northwest Weather Workshop, held at Seattle, Washington February 2000, March 2001,

March 2002, March 2003, February 2004, March 2006, March 2008 Western Canada Weather Workshop, 2000 (Victoria), 2001 (UBC), 2002 (UBC), 2003 (UBC), 2004

(UBC) AMS 31st Radar Meteorology Conference, held at Seattle, WA August 2003 Canadian Meteorological and Oceanographic Society 34th Annual Congress, held at Victoria, BC

June 2000 29th International Conference on Radar Meteorology, held at Montreal, Canada July 1999 Conference on Polar Processes and Global Climate, held at Orcas Island, Washington, USA

November 1997 North American Radio Science Meeting, held at Montreal, Canada July 1997 MacKenzie Basin GEWEX Study (MAGS) 2nd Annual Workshop, held at Saskatoon, Canada March

1997 Canadian Meteorological and Oceanographic Society 30th Annual Congress, held at Toronto,

Ontario June 1996 Canadian Meteorological and Oceanographic Society 28nd Annual Congress, held at Ottawa,

Ontario June 1994 11th International Cloud Physics Conference, held at McGill University, Montreal, Quebec August

1992 10th International Cloud Physics Conference, held at Bad Hamburg, Germany August 1988 Canadian Meteorological and Oceanographic Society 22nd Annual Congress, held at Hamilton,

Ontario June 1988

Katelyn Wells, B.Sc. Senior Air Quality Analyst, EPB/EPOD

Environment Canada 401 Burrard St.

Vancouver, British Columbia, V6C 3S5

Curriculum Vitae

SUMMARY

Ms. Wells is a Senior Air Quality Analyst, EPB/EPOD, with Environment and Climate Change Canada (ECCC). As a Senior Air Quality Analyst for EPOD, Ms. Wells provides air quality reviews of Environmental Assessments and Environmental Impact Statements nationally. Ms. Wells is an Air Quality Scientist with a background in meteorology and air quality including data collection, analysis, and modelling. She is knowledgeable in the environmental assessment and permitting procedures within various Canadian Provinces. She has experience setting up and running air quality and meteorological models for a both research and oil and gas and mining industries. She is adept at summarizing and writing results of assessments in technical data reports.

EXPERIENCE Dec 2017 – present Acting Senior Air Quality Analyst, EPOD, ECCC, Vancouver BC

EA and EIS review: Conducts air quality reviews of EA’s and EIS’s for the Prairie Northern and

Pacific Yukon Regions. Provides scientific/technical air quality advice to EPOD programs Collaborates with experts within EPOD and other Directorates on air quality

content Environmental Hearings:

Participates in environmental hearings in Northern Canada (including Hope Bay TMAC Resources in May 2018 and the Baffinland Iron Mines in April 2019, both were Nunavut Impact Report Board public hearings, testified as air quality witness on behalf of ECCC)

Testifies as air quality witness on behalf of ECCC for Join-Review panel hearings (most recent: Teck Frontier Oil Sands Mine October 2018)

May 2016 – Dec 2017 Air Quality Research Scientist, Meteorological Service of Canada (MSC),

ECCC, Vancouver BC Air Quality Science Research:

Involves the transportation, dispersion and the chemical transformation of trace gas and particle species in the atmosphere.

Reading literature, contacting experts in the field, web searching and many other means of attaining the latest information, techniques and methodologies.

Statistical analysis of large data sets such as regression analysis, PMF, PCA, cluster analysis and other statistical techniques.

Aid in troubleshooting specific issues with NOx measurements in the Lower Fraser Valley, collaborating with Metro Vancouver.

Air Quality Field Research: Conduct field measurement activities to support research. Includes travel to field locations, planning field campaigns, logistical preparations

for field campaigns, instrument maintenance and calibrations, documentation of calibrations and maintenance, installation of instrumentation, writing instrument protocols, collecting data, data archiving, data validation (QA/QC), writing or amending validation software, budgeting.


Environment Canada

Curriculum Vitae

Responsible for 2nd and 3rd level validation for the Marine Boundary Layer site as well as weekly checks on site performance

Responsible for checking instrument operations, calibrations, and data analysis at the Near Road study site mobile trailer

Science Communication: Assist with and provide analysis for papers, reports, and presentations that

communicate air quality research to a variety of audiences Attend meetings relating to research:

Attend meetings with Stakeholders on a regular basis including but not exclusive to , 1) the NAPS Roadside Committee meetings, 2) the MBL Oversight Committee meetings and other meetings as required

Collaborate with other agencies, departments and branches to encourage the sharing of information and resources to accomplish common goals. This includes collaborations with universities (UBC, UofT, York, VIU, SFU, UC Davis, WSU, UWA), branches (S&T), other departments (Health Canada, DFO, AAFC), and other agencies (BC Environment, BC Ministry of Agriculture, Metro Vancouver, FVRD, EPA, NPS, USDA).

July 2012 – May 2016 Air Quality Scientist, Stantec Consulting, Burnaby BC

Ambient Monitoring and Data Analysis: Worked with the air quality team to create baseline air quality and meteorology

for the region surrounding proposed projects. Included leading and participating in field programs to collect dustfall samples,

meteorological data, and air quality data. Projects also include snow course surveys, QA/QC and analysis of the collected

data, and creation of visual aids such as web pages, graphs, and spreadsheets. Co-author of numerous baseline reports relating to air quality, meteorology, and

snow surveys. Air Quality and Meteorological data analysis:

Downloaded, analyzed, and QA/QC air quality and metrological data using various programming tools (MATLAB, R, VBA).

Author of Airshed study reports using graphs, tables, and discussion suitable for regulators and the public

Environmental Assessments and Permitting: Compiled facility design information and create emissions inventories using

various emission factors relevant for the specific project Authored modelling plans according to the BC Modelling Guidelines that were

then approved by regulators Conducted meteorological modelling over large domains and complex terrain

using MM5, WRF, CALWRF, CALMET, and AERMET and air dispersion modelling using CALPUFF, AERMOD, and SCREEN3.

Processed and analyzed the output data from the models using various post processing tools via scripting languages, VBA, and excel.

Air Quality Discipline Lead role: ensuring all air quality components of an Environmental Assessment were completed correctly, on time, and on budget. Participated in regular meetings with project managers, clients, regulators, and stakeholders

Author and lead author of the numerous Technical Data Reports and Environmental Assessment chapters relating to air quality.

Types of projects modelled and involved on: Liquefied Natural Gas facilities, gas plants, pipelines, copper/gold mines, coal mines, compressor stations, terminals.


Environment Canada

Curriculum Vitae

Jan 2009 – July 2012 Atmospheric Science Research Assistant, University of British Columbia

(UBC), UBC Weather Forecast Research Team (WFRT), Vancouver BC Statistical evaluation of medium range ensemble weather forecasts and of short-range high-resolution ensemble weather forecasts

Created an ensemble verification system (using C, MATLAB, Perl, Python, php, html) that contained a tailored set of nine verification metrics that is currently being run annually but the WFRT

Verification metrics utilized observations, requiring data base quarries Results displayed on a real-time web page to aid forecasters

Compilation, configuring and operation of the WRF-NMM weather forecast model for the WFRT

Troubleshoot issues related to configuration and operation of model including those relating to complex terrain

Asses specific physics schemes appropriate for the region Work with the team to determine domain size and optimal resolution Used bash scripting to animate and to ultimately run models operationally for the

WFRT on HPCC Participate in weekly weather briefings and science seminars

Prepared and disseminate individual weather forecasts Presented weather forecasts to public using green screen technology Presented progress of research projects

EDUCATION Bachelor of Science, Major in Atmospheric Science with Distinction University of British Columbia, Vancouver BC, 2012 AWARDS, TRAINING, & CERTIFICATIONS Management of Fugitive Dust, Occupational Level 1 First aid, collision avoidance driving, 4x4 off-road driving, Mental Health in the Workplace, Wilderness first aid, H2S Training, Transportation Endorsement, WMIS, Bear Aware, Green Defensive Driving, Visual Basic Application training, Campbell Scientific Data Logger training Chih-Chuang and Yien-Ying Wang Hsieh Memorial Scholarship, Canadian Meteorological and Oceanographic Society (CMOS) Undergraduate Scholarship, CMOS/The Weather Network Scholarship, Natural Sciences and Engineering Research Council of Canada (NSERC) – Undergraduate Student Research Award (two awards held), University of British Columbia President's Entrance Scholarship, Selkirk College Board of Governors Entrance Award

Curriculum Vitae W. Sean Boyd

Research Scientist Wildlife Research Division, Science & Technology Branch, Environment Canada Pacific Wildlife Research Centre (PWRC) RR1 – 5421 Robertson Rd., Delta, B.C. V4K 3N2

Education B.Sc. (Engineering), Dalhousie University, Halifax, N.S., 1971 B.A. (Biology), Dalhousie University, Halifax, N.S., 1975 M.Sc. (Zoology), University of British Columbia, Vancouver, B.C., 1978Ph.D. (Biology), Simon Fraser University, Burnaby, B.C. 1995

Research and Teaching Experience 1980 - 1997: Biologist, Canadian Wildlife Service, Environment Canada (EC), Delta, B.C. 1997 - 2006: Research Scientist, Canadian Wildlife Service, EC, Delta, B.C. 1998 - present: Adjunct Professor, Simon Fraser University, Burnaby, B.C. 2006 - present: Research Scientist, Wildlife Research Division, Science & Technology Branch,

ECCC, Delta, B.C.

Recent Publications

Leach, A. G., J. S. Sedinger, T. V. Riecke, A. W. Van Dellen, D. H. Ward, and W. S. Boyd. 2019. Brood Size Affects Future Reproduction in a Long-Lived Bird with Precocial Young. American Naturalist: Vol. 193, No. 3.

O’Hara, P.D., J. Wood, S. Avery-Gomm, V. Bowes, L. Wilson, K. H. Morgan, W. S. Boyd, J. M. Hipfner, J-P Desforges, D. F. Bertram, C. Hannah and P. S. Ross. 2018. Seasonal variability in vulnerability for Cassin’s Auklets (Ptychoramphus aleuticus) exposed to plastic pollution in the Canadian Pacific region. Science of the Total Environment 649: 50–60; https://doi.org/10.1016/j.scitotenv.2018.08.238.

Leach, A.G., D.H. Ward, J.S. Sedinger, M.S. Lindberg, W.S. Boyd, J.W. Hupp, and R.J. Ritchie. 2017. Declining Survival of Black Brant from Subarctic and Arctic Breeding Areas. Journal of Wildlife Management 81(7):1210–1218; 2017; DOI: 10.1002/jwmg.21284.

Bertram, D.F., D. L. Mackas, D.W. Welch, W. S. Boyd, J. L. Ryder, M. Galbraith, A. Hedd, K. Morgan, and P.D. O’Hara. 2017. Variation in zooplankton prey distribution determines marine foraging distributions of breeding Cassin’s Auklet. Deep Sea Research Part I: Oceanographic Research Papers. http://dx.doi.org/10.1016/j.dsr.2017.09.004


Sean Boyd 2

Willie, M.C., D. Esler, W.S. Boyd, P. Molloy, and R.C. Ydenberg. 2017. Spatial variation in polycyclic aromatic hydrocarbon exposure in Barrow's goldeneye (Bucephala islandica) in coastal British Columbia. Marine Pollution Bulletin, 118: 167-179.

Bertram, D.F., MacDonald, C.A., O’Hara, P.D., Cragg, J.L., Janssen, M.H., McAdie, M. & Boyd, W.S. 2015. Marbled Murrelet Brachyramphus marmoratus movements and marine habitat use near proposed tanker routes to Kitimat, BC, Canada. Marine Ornithology 44: 3–9.

Rodway, M.S, H.M. Regehr, W.S. Boyd, and S.A. Iverson. 2015. Age and sex ratios of sea

ducks wintering in the Strait of Georgia, British Columbia, Canada: Implications for monitoring. Marine Ornithology 43: 141–150.

Boyd, W. S., T. D. Bowman, J-P L. Savard, and R. D. Dickson. 2015. Conservation of North

American Sea Ducks. Chapter 14 in Ecology and Conservation of North American Sea Ducks. Edited by Jean-Pierre L. Savard, Dirk V. Derksen, Dan Esler, John M. Eadie. Studies in Avian Biology 46:529-560. CRC Press 610 pp.

Dawe, N. K, W. S. Boyd, T. Martin, S. Anderson, and M. Wright. 2014. Significant marsh primary

production is being lost from the Campbell River estuary: another case of too many resident Canada Geese (Branta canadensis). British Columbia Birds 25:2-12.

Nicolai, C. A., J. S. Sedinger, D. H. Ward, and W. S. Boyd. 2014. Spatial variation in life-history

trade-offs results in an ideal free distribution in Black Brant Geese. Ecology 95(5):1323-31. DOI:10.1890/13-0860.1.

Pearce, J. M., J. M. Eadie, J-P L. Savard, T. K. Christensen, J. Berdeen, E. J. Taylor, S. Boyd,

A. Einarsson, and S. L. Talbot. 2014. Comparative population structure of cavity-nesting sea ducks. The Auk 131(2):195-207. DOI:10.1642/AUK-13-071.1.

Boyd, W.S., D.H. Ward, D.K. Kraege, and A.A. Gerrick. 2013. Migration patterns of Western

High Arctic (Grey-belly) Brant Branta bernicla. Wildfowl Special Issue 3: 3-25. O’Hara, P.D., W.S. Boyd, W.R. Crawford. 2012. Integrating the Coriolis effect in trajectory

models used for estimating seabird mortality attributable to illicit ship-source oily discharges occurring offshore of British Columbia. Proceedings of the thirty-fifth Arctic and Marine Oilspill Program (AMOP) Technical Seminar on Environmental Contamination and Response: 675-688.

Lok, E.K., D. Esler, J.Y. Takekawa, S.W. De La Cruz, W.S. Boyd, D.R. Nyeswander, J.R.

Evenson, and D.H. Ward. 2012. Spatio-temporal associations between Pacific herring spawn and surf scoter spring migration: evaluating a “silver wave” hypothesis. Marine Ecology Progress Series. 457:139-150.. DOI:10.3354/meps09692.

Nicolai, C.A., J.S. Sedinger, D.H. Ward, and W.S. Boyd. 2012. Mate loss affects survival but not

breeding in black brant geese. Behavioral Ecology 23(3):643-648. DOI:10.1093/beheco/ars009.

Jayme Brooks

5421 Robertson Road, Delta BC

Jayme Brooks is a wildlife biologist, working primarily in the urban development, oil and gas, mining, and wind energy sectors. Project experience includes preparation of municipal environmental assessments and development permits; large-scale industry development projects under provincial and federal environmental assessment regulations; and pre- and post-construction monitoring programs. Most recently, Jayme has been involved in the review of federal and provincial environmental assessment applications and supporting documentation as an Environmental Assessment Officer for the Canadian Wildlife Service branch of Environment and Climate Change Canada.

PROFESSIONAL EXPERIENCE

Canadian Wildlife Service, Environment and Climate Change Canada Environmental Assessment Officer

December 2018 – Present

• Providing technical, scientific, and regulatory advice to proponents undergoing an environmental assessment process under the Canadian Environmental Assessment Act, 2012 or the BC Environmental Assessment Act.

• Review responsibilities include: o Liaising with internal and external subject matter experts and other levels of government to

provide comprehensive analyses of the proponent’s supporting application materials; o Providing ongoing technical/scientific support and advice throughout all stages of the

environmental assessment process; and o Representing the department during consultation with proponents, other regulators, and the

public.

Keystone Environmental Ltd., Pinchin Ltd., and Stantec Consulting Ltd. Environmental Consultant / Wildlife Biologist

March 2012 – December 2018

• Prepared environmental assessment applications for the oil and gas industry under the Canadian Environmental Assessment Act, 2012 and BC Environmental Assessment Act, including cumulative effects assessment, technical data reports, wildlife and species at risk management plans, and responses to information requests during the application review process.

• Prepared and submitted permit applications through FrontCounter BC, including General Wildlife Permits under the BC Wildlife Act, Notifications and Approvals under Section 11 of the BC Water Sustainability Act, and Requests for Project Review under the federal Fisheries Act.

• Developed standard operating procedures for bird nest surveys, Oregon forestsnail salvages, and amphibian salvages.

• Mentored junior staff in field techniques, including bird identification and nest survey protocols, amphibian and gastropod identification, and wildlife salvage best management practices.

• Liaised with regulatory agencies and clients to determine project-specific requirements, such as permitting, species at risk occurrence, sensitive habitats, or other constraints to development.

• Provided business development services, including correspondence with existing and potential clients, review of requests for proposals through online sources such as BC Bid, and development and submission of proposals and budgets.

• Designed and implemented baseline surveys, including wildlife species inventories for amphibians, terrestrial and marine birds, and mammals; wildlife habitat assessments for terrestrial ecosystem mapping; and remote camera and acoustic recorder installations.

• Led multi-disciplinary field crews of work peers, Indigenous representatives, and subcontractors throughout northern and coastal BC for a variety of baseline inventory and monitoring projects.


MARK C. DREVER

Research Scientist Wildlife Research Division

Environment Canada 5421 Robertson Road, RR #1

Delta, BC, V4K 3N2

Adjunct Professor

Department of Forest and Conservation Sciences

University of British Columbia 2424 Main Mall

Vancouver, BC, V6T 1Z4

EDUCATION 2000-2005 Ph.D. (Zoology). University of Guelph, Guelph, Ontario

Dissertation: Nest success, climate variability, and population dynamics of prairie ducks in an agricultural landscape

1994-1997 M.P.M. (Pest Management). Simon Fraser University, Burnaby, BC Thesis: The ecology and eradication of Norway Rats preying on Ancient Murrelets on Langara Island, Queen Charlotte Islands, British Columbia

1987-1992 B.Sc. (Honors). University of Toronto, Toronto, Ontario Major: Zoology and Environmental Science

EXPERIENCE 2019 Research Scientist. Wildlife Research Division, Environment Canada,

Delta, British Columbia. Responsible for science needs related to modelling habitat and populations of shorebirds, seabirds, and waterbirds.

2010 - 2018 Migratory Bird Biologist. Canadian Wildlife Service, Environment Canada, Delta, British Columbia. Responsible for population assessment for shorebirds, seabirds, and waterbirds.

2009 - 2010 Biometrician. Canadian Wildlife Service, Environment Canada. Performed quantitative analyses in support of review of Environment Canada’s bird monitoring programs.

2005 - 2009 Postdoctoral Research Fellow. Department of Forest Sciences, University of British Columbia, Vancouver, British Columbia. Conducted research on mountain pine beetles on forest birds, and on climate change and prairie duck populations, supervised graduate students.

1997- 2000 Seabird Research Associate. Populations Section, Canadian Wildlife Service, Environment Canada, Delta, British Columbia. Conducted data collection and analysis, report writing, field camp construction for monitoring seabird populations in British Columbia.

1992 - 1993 Biological Intern. US Fish and Wildlife Service. Hawaii and California. Conducted research and conservation management on endangered birds.

<contact information removed><contact information removed>

PUBLICATIONS_________________________________________ 60+ Peer-reviewed publications, 15 Technical Reports (listed below relevant to shorebird conservation) Hope, D.D., C. Pekarik, M.C. Drever, P.A. Smith, C. Gratto-Trevor, J. Paquet, Y. Aubry, G.

Donaldson, C. Friis, K. Gurney, J. Rausch, A. Mckellar, and B. Andres. 2019. Shorebirds of Conservation Concern in Canada – 2019. Wader Study. Submitted.

Kehoe, L.J., J. Lund, L. Chalifour, Y. Asadian, E. Balke, S. Boyd, J.M. Casey, B. Connors, N. Cryer, M.C. Drever, S. Hinch, C. Levings, M. MacDuffee, H. McGregor, J. Richardson, D.C. Scott, D. Stewart, R.G. Vennesland, C.E. Wilkinson, P. Zevit, J.K. Baum, and T.G. Martin. 2019. Prioritizing conservation actions in heavily urbanized biodiverse socio-ecological systems. Proceedings of the National Academy of Sciences of the United States of America. Submitted.

Schnurr, P.J., M.C. Drever, H.J. Kling, R.W. Elner, and M.T. Arts. 2019. Accumulation of fatty acids in intertidal biofilm communities coincides with shorebird spring migration through the Fraser River estuary, British Columbia, Canada. Estuarine, Coastal and Shelf Science. Submitted.

Hope, D.D., A. Drake, D. Shervill, M.J.F. Lemon, and M.C. Drever, 2019. Correlates of annual stopover counts in two species of Arctic-breeding shorebirds: roles of local, breeding, and climactic drivers. Avian Conservation and Ecology. Submitted.

Drever, M.C., J.F. Provencher., P.D. O'Hara, L. Wilson, V. Bowes, and C.M. Bergman. 2018. Are ocean conditions and plastic debris resulting in a 'double whammy' for marine birds? Marine Pollution Bulletin 133: 684-692.

Hope, D.D., M.C. Drever, J. Buchanan, M.A. Bishop, G. Matz, and M.J.F. Lemon. 2018. Trends in timing of spring migration along the Pacific Flyway by Western Sandpipers and Dunlins. The Condor: Ornithological Applications 120: 471-488.

Basso, E., J. Fonseca, M.C. Drever, and J.G. Navedo. 2018. Effects of intertidal habitat availability on the use of anthropogenic habitats as foraging grounds by shorebirds: a case study on semi-intensive shrimp farms. Hydrobiologia 809: 19–29.

Drever, M.C., and M. Hrachowitz. 2017. Migration as flow: using hydrological concepts to estimate residence time of migrating birds from daily counts. Methods in Ecology and Evolution 8: 1146–1157.

Navedo, J. G., G. Fernández, N. Valdivia, M.C. Drever, and J.A. Masero. 2017. Identifying management actions to increase foraging opportunities for shorebirds at semi-intensive shrimp farms. Journal of Applied Ecology 54: 567-576.

Drever, M.C., B.A. Beasley, Y. Zharikov, M.J.F. Lemon, P.G. Levesque, M.D. Boyd, and A. Dorst. 2016. Monitoring migrating shorebird populations at an important stopover site on the west coast of British Columbia: Is disturbance a concern? Waterbirds 39: 125-135.

Dekker, D., and M.C. Drever. 2016. Interactions of Peregrine Falcons (Falco peregrinus) and Dunlin (Calidris alpina) wintering in British Columbia, 1994–2015. Journal of Raptor Research 50: 363-369.

Drever, M.C., D. Chabot, P.D. O’Hara, J. D. Thomas, A. Breault, and R.L. Millikin. 2015. Evaluation of an unmanned rotorcraft to monitor wintering waterbirds and coastal habitats in British Columbia, Canada. Journal of Unmanned Vehicle Systems 3: 256-267.

Dekker, D., and M.C. Drever. 2015. Kleptoparasitism by Bald Eagles as a factor in reducing Peregrine Falcon predation on Dunlins wintering in British Columbia. The Canadian Field Naturalist 129 (2): 159-164.

Navedo, J.G., G. Fernández, J. Fonseca, and M. C. Drever. 2015. A potential role of shrimp-farms for the conservation of Nearctic shorebird populations. Estuaries and Coasts 38: 836-845.

Rickbeil, G. J. M., N. C. Coops, M.C. Drever, and T.A. Nelson. 2014. Assessing coastal species distribution models through the integration of terrestrial, oceanic and atmospheric data. Journal of Biogeography 41: 1614–1625.

Drever, M.C., M.J.F. Lemon, R.W. Butler, and R.L. Millikin. 2014. Monitoring Western Sandpipers and Dunlins during northward migration on the Fraser River Delta, 1991 to 2013. Journal of Field Ornithology 84:1-13.

Drever, M.C. 1992. Status and reproductive success of Snowy Plovers breeding on salt pond levees of the San Francisco Bay National Wildlife Refuge. US Fish and Wildlife Service, Fremont, California.

ROBERT W. ELNER Scientist Emeritus Wildlife Research Division, Environment and Climate Change Canada Pacific Wildlife Research Centre, Delta, BC, V4K 3N2

EDUCATION: Undergraduate: B.Sc. (Honors) – Zoology (1970-74)

University of Newcastle upon Tyne, United Kingdom Postgraduate: Ph.D. – Ecology (1974-77) University of Wales, Bangor, Gwynedd, United Kingdom Postdoctoral: Department of Fisheries and Oceans (1977-1979) St. Andrews, New Brunswick, Canada Visiting Postdoctoral Fellowship in Government Laboratories CAREER (2008- present):

- Scientist Emeritus, Environment and Climate Change Canada - Adjunct Professor, Simon Fraser University - Editor-in-Chief, “Waterbirds” (2008-2012) - Convener, 27th International Ornithological Congress (2018)

CAREER (1979- 2008): (1991- May, 2008) Manager, Migratory Bird Population Conservation Canadian Wildlife Service, Environment Canada Pacific and Yukon Region Group and Level: Research Manager (SE-REM-01: 1991-2007; BI-05: 2007-2008) (1990-91) Shellfish Research Scientist, Fisheries and Oceans,

Pacific Biological Station, Nanaimo, British Columbia Group and Level: Research Scientist (SE-RES-02) (1979-90) Crab and Lobster Research Scientist, Fisheries and Oceans, St. Andrews, New Brunswick, 1979-84 Halifax Fisheries Research Laboratory, Nova Scotia, 1984-90 Group and Level: Research Scientist (SE-RES) Level 1 (1979-82); Level 2 (1982-90) Secondment: Senior Advisor, Resource Evaluation Directorate 1987 Fisheries and Oceans, Ottawa PROFESSIONAL BACKGROUND:

• Associate Faculty, University of Guelph, Ontario, Canada, 1981-83. • Associate Faculty (“Chercheur Associe”), Departement de biologie, Universite

de Moncton, New Brunswick, Canada, 1983-1996. • Research Associate, Dalhousie University, Nova Scotia, Canada, 1988-92.


• Honorary Adjunct Professor, Department of Biology, Dalhousie University, Nova Scotia, Canada, 1991-97.

• Board of Governors, Program Officer, The Crustacean Society, 1990-1995. • Editorial Board, Journal of Shellfish Research, 1992-1994. • Affiliate Associate Professor, School of Fisheries, University of Washington,

Seattle, WA, USA, 1990-98. • Member, Scientific Advisory Committee for the Endangered Species Recovery

Fund of the World Wildlife Fund (1994 –1997). • Adjunct Professor, Department of Biological Sciences, Simon Fraser

University, British Columbia, 1999 - present. RECENT AWARDS:

• Partners in Flight, Lifetime Achievement award (August 2018). • Doris Heustis Speirs award, Society of Canadian Ornithologists, for lifetime

contributions in Canadian ornithology (August 2018).

SELECTED BIBLIOGRAPHY: ROBERT W. ELNER (Professional total: 65 Primary Publications, 5 Book Chapters, 70 + technical papers):

1. Sutherland, T.F., P.C.F. Shepherd and R.W. Elner. 2000. Predation on meiofaunal and macrofaunal invertebrates by western sandpipers (Calidris mauri): evidence for dual foraging modes. Marine Biology 137: 983-993.

2. Elner, R.W. and D.A. Seaman. 2003. Calidrid conservation: unrequited needs. Wader Study Group Bulletin 100: 30-34.

3. Mathot, K.M. and R.W. Elner. 2004. Evidence for sexual partitioning of foraging mode in western sandpipers (Calidris mauri) during migration. Canadian Journal of Zoology 82: 1035 - 1042

4. Elner, R.W., P.G. Beninger, D.L. Jackson and T.M. Potter. 2004. Evidence of a new feeding mode in western sandpiper (Calidris mauri) and dunlin (Calidris alpina) based on bill and tongue morphology and ultrastructure. Marine Biology 146: 1223-1234.

5. Nebel, S., D.L. Jackson and R.W. Elner. 2005. Functional association of bill morphology and foraging behaviour in calidrid sandpipers. Animal Biology 55: 235-243.

6. Acevedo Seaman, D.A., C.G. Gugliemo, R.W. Elner and T.D. Williams. 2006. Site differences in refueling rates as indicated by plasma metabolite analysis in free-living, migratory sandpipers. The Auk 123: 563-574.

7. Mathot, K.M., B. D. Smith and R. W. Elner. 2007. Latitudinal clines in food distribution correlate with differential migration in the western sandpiper. Ecology 88: 781-791.

8. O’Hara, P.D., B.J.M. Haase, R.W. Elner, B.D. Smith and J.K. Kenyon. 2007. Are population dynamics of shorebirds affected by El Nino/Southern Oscillation (ENSO) while on their non-breeding grounds in Ecuador? Estuarine, Coastal and Shelf Science 74: 96-108.

9. Kuwae, T., P.G. Beninger, P. Decottignies, K.J. Mathot, D.R. Lund and R.W. Elner. 2008. Biofilm grazing in a higher vertebrate: the western sandpiper. Ecology 89: 599- 606.

10. Stein, R.W., G. Fernández, H. de la Cueva and R.W. Elner. 2008. Disproportionate bill length dimorphism and niche differentiation in wintering western sandpipers (Calidris mauri). Canadian Journal of Zoology 86: 601-609.

11. Pomeroy, A.C., D.A. Acevedo Seaman, R.W. Butler, R.W. Elner, T.D. Williams, and R.C. Ydenberg. 2008. Feeding-danger tradeoffs underlie stopover site selection by migrants. Avian Conservation and Ecology 3: 7.

12. Zharikov, Y., R.W. Elner, D.B. Lank, and P.C.F. Shepherd. 2008. Interplay between physical and predator landscapes affects transferability of shorebird distribution models. Landscape Ecology 24: 129-144.

13. Mathot, K.J., D. Lund, R.W. Elner. 2010. Sediment in stomach contents of Western Sandpipers (Calidris mauri) and Dunlin (Calidris alpina) provide evidence of biofilm feeding. Waterbirds 33: 300-306.

14. Beninger, P.G., R.W. Elner, M. Morancais and P. Decottignies. 2011. Downward trophic shift during breeding migration in the shorebird Calidris mauri (Western Sandpiper). Marine Ecology Progress Series 428: 529-269.

15. Kuwae, T., E. Miyoshi, S. Hosokawa , K. Ichimi , J. Hosoya, T. Amano, T. Moriya , R. C. Ydenberg and R.W. Elner. 2012. Variable and complex food web structures revealed by exploring missing trophic links between birds and biofilm. Ecology Letters 10.1111/j.1461-0248.2012.01744.x

16. Sutherland, T. F., Elner, R. W. and J. D. O’Neill. 2013. Roberts Bank: Ecological Crucible of the Fraser River Estuary. Progress in Oceanography 115: 171–180.

17. Jiménez, A., R. W. Elner, C. Favaro, K. Rickards and R. C. Ydenberg. 2015. Intertidal biofilm distribution underpins differential tide-following behavior of two sandpiper species (Calidris mauri and Calidris alpina) during northward migration. Estuarine, Coastal and Shelf Science 155: 8-16.

19. Mathot, K.J., T. Piersma, and R.W. Elner. 2018. Shorebirds as integrators and indicators of mudflat ecology. In, Mudflat Ecology. P.G. Beninger (Ed.), Springer Nature. Chapter 12: 309-338.

20. Schnurr, P.J., Drever, M.C., Kling, H., R.W. Elner, R.W. and M. Arts. (2019). Seasonal changes in fatty acid composition of estuarine intertidal biofilm: implications for western sandpiper migration. Estuarine, Coastal and Shelf Science. In Review.

1

Blair Hammond Pacific Wildlife Research Centre 5421 Robertson Road, RR #1.

Delta, British Columbia V4K 3N2

Professional Experience Director, Pacific Region, Canadian Wildlife Service (CWS), Environment and Climate Change Canada (ECCC). October 2018-Present Responsible for the management and delivery of all CWS programs in Pacific Region, including migratory bird conservation, species at risk recovery, protected areas, information management and wildlife inputs to environmental assessments, as well as leadership and support on assigned national files. Manager, Conservation Planning & Stewardship Section (PC 5) February 2008-October 2018 Canadian Wildlife Service (CWS), Environment Canada, Pacific and Yukon Region Accountable for work units whose responsibilities included Species at Risk Recovery, National Wildlife Area management and establishment, funding programs, stewardship initiatives and priority partnerships and migratory bird habitat joint ventures. Habitat Protection Biologist (BI 3) August 2001 – January 2005, April 2006-August 2007, November–December 2007 Canadian Wildlife Service, Environment Canada, Pacific and Yukon Region Responsible for building, implementing and coordinating the Region's Ecological Gifts Program, and additional roles with multi-partner landscape conservation initiatives, species at risk programs, agricultural projects and other priority files. Acting National Coordinator, Ecological Gifts Program / Acting Chief, Stewardship Section (PC 4 / PC 5) January 2005 – April 2006 Canadian Wildlife Service, Environment Canada, National Capital Region Responsible for national leadership of the Ecological Gifts Program. For four months also acting national Chief of Stewardship (funding programs, ecological gifts, wetland partnership initiatives), National Capital Region. Regional Manager - September 1998 –July 2001 British Columbia Conservation Foundation, Southern Interior Region Responsible for the overall management of the regional office of a not-for-profit society dedicated to the conservation of fish, wildlife and habitats through the application of science and information.


2

Research Associate - July 1997 – August 1998 Department of Renewable Resources, University of Alberta Supported three research projects examining the impacts of forest practices and oil and gas developments on biodiversity in boreal and montane forests.

Research Biologist - May 1996-April 1997 Centre for Applied Conservation Biology, Faculty of Forestry, U.B.C. Biologist and project manager in a cooperative, multi-year, multi-taxon project examining the efficacy of different riparian buffer widths in maintaining vertebrate and plant biodiversity on managed forest lands in B.C.'s dry interior.

G.I.S. Analyst - March 1995-April 1996 B.C. Parks Contracts, Strathcona Park Elk Project, Vancouver Island Analysis of elk radio-telemetry and habitat data to assess habitat preference and re-introduction potential for a threatened sub-species.

Various Positions (lecturer, research assistant, teaching assistant) September 1993-December 1995 Department of Forest Sciences and Resource Management, U.B.C. Education M.Sc., Centre for Applied Conservation Biology - September 1993-April 1996 Faculty of Forestry, University of British Columbia Integrating formal planning methods into biodiversity management strategies: Roosevelt elk habitat in Strathcona Provincial Park (Vancouver Island). Additional studies undertaken in biodiversity inventory techniques, protected areas planning, landscape and restoration ecology. Completed with First Class standing. Graduate Qualifying year in Forestry - September 1992-April 1993 University of British Columbia Courses in wildlife biology and management, forest ecology, biophysical classifications and mapping, GIS, forest resource management, protected areas planning & soil ecology. B.A. and Unclassified year - September 1987-April 1992 University of British Columbia Specific foci included cultural ecology, ecological economics, ethnography, anthropology, zooarchaeology, and Canadian and imperial history.

David Hope – Shorebird Biologist Education 2013-2018

PhD, Biological Sciences; Simon Fraser University (Burnaby, BC) Thesis title: The role of adaptive behaviour in migratory counts of shorebirds.

2007-2010 MSc, Biological Sciences; Simon Fraser University (Burnaby, BC) Thesis title: The influence of the predator landscape on migratory decisions in two shorebird species.

2000-2005 BSc, Animal Biology Major; University of British Columbia (2003-2005); Bamfield Marine Science Centre (Fall 2004); University College of the Cariboo (2000-2002)

Publications Hope, D.D, D.B. Lank, P.A. Smith, J. Paquet, and R.C. Ydenberg (Submitted). Semiplamated

sandpipers have shifted together and towards safer sites. Global Change Biology Hope, D.D., C. Pekarik, M. C. Drever, P. A. Smith, C. Gratto-Trevor, J. Paquet, Y. Aubry, G.

Donaldson, C. Friis, K. Gurney, J. Rausch, A. McKellar, and B. Andres (In Prep). Shorebirds of Conservation Concern in Canada – 2019. Wader Study.

Ydenberg, R.C. and D.D. Hope (Submitted). Danger management and the seasonal adjustment of migratory speed by sandpipers. Journal of Avian Biology. Submitted April 4, 2019.

Hope, D.D., A. Drake, D. Shervill, MJF Lemon and M.C. Drever (In Review). Correlates of annual stopover counts in two species of Arctic-breeding shorebirds: roles of local, breeding, and climactic drivers. Avian Conservation & Ecology. Submitted February 18, 2019.

Hope, D. D., M. C. Drever, J. B. Buchanan, M.A. Bishop, G. Matz, and M. J. F. Lemon (2018). Trends in timing of spring migration along the Pacific Flyway by Western Sandpipers and Dunlins. The Condor: August 2018, Vol. 120, No. 3, pp. 471-488. DOI: 10.1650/CONDOR-17-126.1

Hope, D. D., D. B. Lank, and R. C. Ydenberg. Mortality-minimizing sandpipers vary stopover behavior dependent on age and geographic proximity to migrating predators. Behavioral Ecology and Sociobiology:1-12. DOI: 10.1007/s00265-014-1695-x

Kurle, C.M., C.V. Kappel, D.D. Hope, A. Lam. Invasion Status of Terrestrial Mammals on Uninhabited Islands within the San Juan Archipelago, Washington. Northwest Science, 87(2), 178-184.

Hope, D.D.; D.B. Lank, B.D. Smith and R.C. Ydenberg. Migration of two calidrid sandpiper species on the predator landscape: how stopover time and hence migration speed vary with proximity to danger. Journal of Avian Biology 42: 523-530. DOI: 10.1111/j.1600-048X.2011.05347.x

Work/Volunteer Experience

Title Description Date

Shorebird Biologist Environment and Climate Change Canada October 2018 - Present

Executive Officer Center for Ecological and Evolutionary Synthesis, University of Oslo Aug - Dec 2012

Organizing Assistant International Statistical Ecology Conference 2012 - Oslo, Norway July 2012

Assistant Center for Ecological and Evolutionary Synthesis, Universitetet i Oslo June - Aug 2012

Volunteer World Wildlife Fund, Oslo - Trude Myhre April - June 2012

Research Assistant Center for Ecological and Evolutionary Synthesis, Universitetet i Oslo

April - June 2012

Volunteer WildResearch - Avian Monitoring 2011

Graduate Student University of Victoria - Ecology of Raccoons on Islands 2010 - 2011

Research Technician University of Victoria - Ecology of Raccoons on Islands 2010

Research Technician (volunteer)

Simon Fraser University - Capturing breeding and juvenile sandpipers in Alaska 2008 & 2009

Volunteer Whistler Bear Research Team 2006-2007

Research Assistant Amy Newman, Department of Psychology, UBC, Vancouver 2005

Library Assistant UBC Main Library, Vancouver 2003 - 2005

Non-academic Publications Hope, D. and R. Ydenberg. Taking the pulse of a migration. BirdWatch Canada. Spring 2017,

Number 79.

EA Krebs - 1

CURRICULUM VITAE

Elizabeth Ann KREBS Pacific Wildlife Research Centre Environment and Climate Change Canada 5421 Robertson Road Delta, BC Email:

EDUCATION 1999 Ph.D. Australian National University, Canberra, Australia

Thesis title: Breeding biology and parental care of the crimson rosella. Supervisor: Dr. Rob Magrath.

1991 M.Sc. (Biology) McGill University, Montreal, Canada.

Thesis title: Reproduction in the cattle egret: The function of breeding plumes. Supervisor: Dr. Wayne Hunte.

1987 B.Sc. (First Class Hons.) Queen's University, Kingston, Canada. ACADEMIC APPOINTMENTS 02/2003 – 08/2005 Postdoctoral Fellow, Centre for Wildlife Ecology, Simon Fraser University, B.C. 07/2000 – 12/2002 University of Queensland Postdoctoral Fellow, University of Queensland,

Australia 03/1999 – 07/2000 Lecturer A, Australian National University, Australia WORK EXPERIENCE 01/11-current Research Manager, Wildlife Research Division, Wildlife and Landscape Science

Directorate, Environment and Climate Change Canada 02/2008-12/2010 Section Head, Landscape Assessment and Planning, Canadian Wildlife Service,

Environment Canada. 09/2005 – 01/2008 Landbird Biologist, Canadian Wildlife Service, Pacific and Yukon Region. 02/2003 – 08/2005 Postdoctoral Research Fellow, Simon Fraser University, B. C.


EA Krebs - 2

07/2000 – 12/2003 Postdoctoral Research, University of Queensland, Australia.

PUBLICATIONS Valdez-Juárez, Simón O, D. J Green, A. Drake and E. A. Krebs 2019. Assessing the effect of seasonal

agriculture on the condition and winter survival of a migratory songbird in Mexico. Conservation Science and Practice in press.

Valdez-Juárez, Simón O., A. Drake, K. J. Kardynal, K. A. Hobson, E. A. Krebs, and D. J. Green. 2018. Use of

natural and anthropogenic land cover by wintering Yellow Warblers: The influence of sex and breeding origin. Condor 120(2): 427–438

Krebs, E. A. 2018 Salvin Goldman Medal awarded to Kathy Martin. Ibis.

https://doi.org/10.1111/ibi.12655 Fogell, DJ, Martin, R.O, Bunbury, N, Lawson, B, Varsani, A, Sells, J, McKeand, AM, Tatayah, V, Trung, CT,

Ortiz-Catedral, L, Masello, M, Heinsohn, R, Krebs, EA, Langmore, NE, Bucher, E and Groombridge, JJ. 2016. Detection of Beak and feather disease virus in native and introduced wild parrot populations: implications for conservation and the pet bird trade. Diversity and Distributions. in review

Hindmarch, S, Krebs EA, Elliott, J and DJ Green, (2014). Urban Development influences breeding

performance of barn owls in the Fraser Valley. Condor 116. DOI: 10.1650/CONDOR-13-052.1 Calvert, A, Bishop CA, Elliot RD, Krebs EA, Kidd T, Machtans C, RG Robertson. (2013). A synthesis of

human-related avian mortality in Canada. Avian Conservation and Ecology 8:11 (DOI: http://dx.doi.org/10.5751/ACE-00581-080211)

Hindmarch, S, Krebs EA, Elliott J, DJ Green. (2012). Do landscape features predict the presence of barn

owls in a changing agricultural landscape. Landscape and Urban Ecology 107:255-262 Waterhouse, L F, Burger, AR, Lank, DB, Ott, PK, Krebs, EA and N Parker (2009). Using the Low-level

Aerial Survey Method to Identify Nesting Habitat of Marbled Murrelets (Brachyramphus marmoratus). BC Journal of Ecosystems and Management 10:80-96.

Waterhouse, L. F., Donaldson A., Lank, D.B., Ott, P.K., Krebs, E. A. (2008). Using air photos to interpret

quality of Marbled Murrelet nesting habitat in south coastal British Columbia. BC Journal of Ecosystems and Management 9:17-37

Middleton, H.A., Green, D. J. & E. A. Krebs. (2007). Fledgling begging and parental responsiveness in

American dippers (Cinclus mexicanus). Behaviour 144:485-501. McFarlane Tranquilla, L., N.R. Parker, R.W. Bradley, D.B. Lank, E.A. Krebs, L. Lougheed and C.

Lougheed. (2005). Breeding chronology of Marbled Murrelets varies between coastal and inshore sites in southern British Columbia. J. Field Ornithol. 76:357–367.

EA Krebs - 3

Krebs, E. A., Hunte, W. and D.J. Green. (2004). The function of breeding plumes in cattle egrets.

Behaviour.141:479-499. Krebs, E. A. and D. Putland (2004). Chic chicks: the evolution of chick ornamentation in rails.

Behavioural Ecology 15:946-951. Green, D. J., E. A. Krebs and A. Cockburn (2004). Mate choice in the brown thornbill: are settlement

decisions, divorce and extrapair mating complementary strategies? Behavioural Ecology and Sociobiology.

Shirley, A, A. Goldizen, D. Jones, E. Krebs and D. Putland. (2003). Do ecological characteristics restrict

the distribution and abundance of moorhens in South Eastern Queensland. Emu 103: 81-86. Krebs, E. A., Green D. J., Double, M. C. and Griffiths, R. (2002). Laying date and laying sequence

influence the sex ratio of crimson rosella broods. Behavioral Ecology and Sociobiology 51:447-454

Krebs, E. A. (2002). Sibling Competition and Parental Control: Patterns of Begging in Parrots. Chapter

12: The Evolution of begging: Competition, Cooperation and Communication. (J. Wright and M. L. Leonard, eds.) Kluwer: Netherlands.

Krebs, E. A. (2001). Begging and food distribution in crimson rosella (Platycercus elegans) broods: why

don't hungry chicks beg more? Behavioral Ecology and Sociobiology 50: 20-30. Krebs, E. A. (2001). Raising rosellas. Nature Australia (Summer 2000/01 issue) Krebs, E. A. and R. D. Magrath. (2000). Food allocation in crimson rosella broods: parents differ in their

responses to chick hunger. Animal Behaviour 59:739-751. Goldizen, A.W., J. C. Buchan, D. A. Putland, A. R. Goldizen and E. A. Krebs. (2000). Patterns of mate-

sharing in a population of Tasmanian Native Hens Gallinula mortierii. Ibis 142: 40-47 Krebs, E. A., R. B. Cunningham and C. F. Donnelly. (1999). Complex patterns of food allocation in

asynchronously hatching broods of crimson rosellas. Animal Behaviour 57: 753-763. Krebs, E. A. (1999). Last but not least: nestling growth and survival in asynchronously hatching crimson

rosellas. Journal of Animal Ecology 68:266-281. Krebs, E. A. (1998). Breeding biology of crimson rosellas (Platycercus elegans) on Black Mountain,

Australian Capital Territory. Australian Journal of Zoology 46: 119-136 Green, D. J. and E. A. Krebs. (1995). Courtship feeding in Ospreys Pandion haliaetus: a criterion for mate

assessment? Ibis 137:35-43. Krebs, E. A., D. Riven-Ramsey and W. Hunte. (1994). The colonization of Barbados by cattle egrets,

1956-1990. Colonial Waterbirds 17:194-197.

EA Krebs - 4

Winquist, T., D. Weary, A. Inman, J. Mountjoy and E. A. Krebs. (1991). Male Swords and female preferences. Technical Comment. Science 253:1426.

Literature reviews and Technical papers Kennedy, JA and EA Krebs. 2010. A Manual for completing all Bird Conservation plans in Canada. 72 pp.

Technical Manual for BCR planners Rich, T et al. 2010. Saving our shared birds: The Partners in Flight Trinational Vision. Lank D., N. Parker, E. A. Krebs and L. McFarlane Tranquilla (2003) Geographic distribution, habitat

selection and population dynamics with respect to nesting habitat characteristics of Marbled Murrelets. 66pp. Contracted for US endangered species status review.

Kathleen Moore

Canadian Wildlife Service, Environment and Climate Change Canada

5421 Robertson Road, Delta BC, V4K 3N2,

Education

BSc (Co-op) – Physical Geography (1984) University of Victoria

Work Experience

30+ years as a Conservation Planner with the Canadian Wildlife Service (Environment and Climate

Change Canada), coordinating GIS projects for various program areas, integrating spatial datasets into

decision support tools, producing custom interpretive products for senior management, and providing

analysis for technical and planning documents. Member of the Pacific Bird Habitat Joint Venture and

the Canadian Intermountain Joint Venture Technical Committee, and of the BC NGO Conservation Areas

Database Technical Working Group.

Key Projects:

British Columbia NGO Conservation Areas Database Technical Working Group. 2017. “Annual British

Columbia Conservation Areas Summary Report 2016”.

Pacific Birds Habitat Joint Venture. 2016. “Pacific Birds Habitat Joint Venture (BC): Implementation Plan

– Waterfowl and Associated Habitats 2015 – 2020.

Canadian Intermountain Joint Venture. 2016. “Update to the Prospectus and Biological Foundation –

Wetlands, Lake and Rivers, Riparian areas and Grasslands”.

Harrison, Bruce and Kathleen Moore. 2013. BC Wetland Trends Project: Okanagan Valley

Assessment. Canadian Intermountain Joint Venture.

Canadian Intermountain Joint Venture. 2010. “Implementation Plan: Wetlands and Associated Species”.

Metro Vancouver. 2010. “Lower Fraser Wetland Loss: Wetland Loss to Human Encroachment in the

Fraser Lowlands from 1999 – 2009 and Comparison to Loss from 1989 – 1999”. Metro Vancouver.

Kenyon, James K., Ken H. Morgan, Michael D. Bentley, Laura A. McFarlane Tranquilla, Kathleen E.

Moore. 2009. “Atlas of Pelagic Seabirds off the West Coast of Canada and Adjacent Areas”. Canadian

Wildlife Service Technical Report #499.


Kenyon, James K., Krista Amey, Kathleen Moore, Michael Dunn. 2007. “The Canadian Wildlife Service’s

British Columbia Marine Bird Area of Interest Database”. Canadian Wildlife Service Technical Report

#479.

Ryder, John, James K. Kenyon, Dan Buffett, Kathleen Moore, Marianne Ceh, Katrina Stipec. 2007. “An

Integrated Biophysical Assessment of Estuarine Habitats in British Columbia to Assist Regional

Conservation Planning”. Canadian Wildlife Service Technical Report #476.

Pacific Coast Joint Venture. 2005. “Pacific Coast Joint Venture: British Columbia Strategic Plan and

Biological Foundation. British Columbia Steering Committee.

Moore, Kathleen, Peggy Ward and Katrina Roger. 2004. "Urban and Agricultural Encroachment onto

Fraser Lowland Wetlands - 1989 to 1999." In T.W. Droscher and D.A. Fraser (eds). Proceedings of the

2003 Georgia Basin/Puget Sound Research Conference. CD-ROM or Online.

Available: http://www.psat.wa.gov/Publications/03_proceedings/start.htm [February 2004]

Canadian Intermountain Joint Venture. 2003. “The Canadian Intermountain Joint Venture: Biological

Foundation and Prospectus”.

Ward, P, K Moore, R Kistritz. 1992. “Wetlands of the Fraser Lowland, 1989: An Inventory”. Canadian

Wildlife Service Technical Report #146.

Moore, Kathleen. 1990. “Urbanization in the Lower Fraser Valley, 1980 – 1987”. Canadian Wildlife

Service Technical Report #120.

Andrew Gordon Robinson Senior Environmental Assessment Officer

Canadian Wildlife Service Environment and Climate Change Canada

5421 Robertson Road, RR#1 Delta, B.C. V4K 3N2

EDUCATION 1996 Diploma, Environmental Technology Protection, Kwantlen University College, British Columbia 1991 Bachelor Science Degree, Zoology, University of British Columbia WORK EXPERIENCE 2006 to present: Senior Environmental Assessment Officer, Canadian Wildlife Service, Pacific Wildlife Research Centre, Environmental Conservation Service, Environment and Climate Change Canada, 5421, Robertson Road, RR1, Delta, B.C. V4K 3N2 - Coordination and delivery of federal wildlife expertise to major project

environmental assessments in B.C. 2004 to 2005: Senior Program Officer, Canadian Environmental Assessment Agency Canadian Environmental Assessment Agency, Suite 320, 757 West Hastings Street, Vancouver, B.C. V6C 1A1 - Coordination of and to federal departments in the implementation of the

Canadian Environmental Assessment Act S.C 1992, c.37 2000 to 2004: Environmental Assessment Officer, Canadian Wildlife Service, Pacific Wildlife Research Centre, Environmental Conservation Service, Environment Canada, 5421, Robertson Road, RR1, Delta, B.C. V4K 3N2 - Coordination and delivery of federal wildlife expertise to major project

environmental assessments in B.C. 1998 to 2000: Environmental Assessment Officer, Indian and Northern Affairs Canada, Lands & Trust Services, 600 1138 Melville Street, Vancouver, BC V6E 4S3 - Coordination of federal department expert advice in support of Responsible

Authority decision-making under the CEAA Act S.C 1992, c.37


Documents

From: McLean, Robyn (EC) Sent: Tuesday, April 30, 2019 7 ... · From: McLean, Robyn (EC) Sent: Tuesday, April 30, 2019 7:13 PM ... Water Quality ... AQMS Air Quality Management System