Marine Birds, Mammals Kitimat Estuary · 2012-02-29 · 2 2.5 KVN has reviewed Enbridge documents relevant to the Estuary area, and species of birds of importance to the region and

Kitimat Valley Naturalists Review of Enbridge Project

Documents:

Marine Birds, Mammals &

Kitimat Estuary

December 2011

KVN Response to Enbridge Northern Gateway Impact and Bird Assessments

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TableofContents1 Forward ...................................................................................................................................................... 1

2 Kitimat Valley Naturalists .......................................................................................................................... 1

3 Definition of Estuary .................................................................................................................................. 2

4 Summary .................................................................................................................................................... 2

5 Eelgrass on the Kitimat River Estuary Delta .............................................................................................. 4

6 Marine Birds .............................................................................................................................................. 5

7 Key Indicator (KI) Species: Marbled Murrelet, Surf Scoter and Bald Eagle ............................................... 5

8 Kitimat River Estuary: Waterfowl & Waders ............................................................................................. 5

9 Incomplete Birding Data ............................................................................................................................ 6

10 Current Trends ........................................................................................................................................... 6

11 Oil Spill Assessment: Black Oystercatcher ................................................................................................. 6

12 Review of Enbridge Presented Bird Data ................................................................................................... 7

13 Mammal Data .......................................................................................................................................... 11

14 Conclusion ............................................................................................................................................... 12

15 References ............................................................................................................................................... 13

16 Acknowledgements ................................................................................................................................. 13

TablesTable 1. KVN Response to Enbridge Northern Gateway Birding Data and Impact Assessment. ....................... 7 Table 2: KVN Response to Enbridge Northern Gateway Estuarine Assessment ............................................. 10 Table 3: KVN Response to Enbridge Marine Mammal Data ............................................................................ 11


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AcronymsinthisReport

BC – British Columbia

CBC—Christmas Bird Count

CCAA—Confined Channel Assessment Area

COSEWIC—Committee on the Status of Endangered Wildlife in Canada

Dilbut—Diluted Bitumen

DFO—Department of Fisheries and Oceans

KVN—Kitimat Valley Naturalists

KI—Key Indicators

NEB—National Energy Board

PAH—Polycyclic Aromatic Hydrocarbons

PEAA—Project Environmental


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1 Forward

1.1 Kitimat Valley Naturalists’ (KVN) review of the vast amount of information prepared for the Northern Gateway Project has identified substantial and significant data gaps related to birds, mammals and eelgrass in the Kitimat River Estuary area. These gaps could have been readily filled had Enbridge appropriately resourced regional birding experts or accessed public databases. Further, KVN’s review has also identified substantial risk to the Kitimat Estuary area.

2 KitimatValleyNaturalists

2.1 The Kitimat Valley Naturalists (KVN) is a nature-oriented organization focused on local natural history, with a specialty in birding. The organization started in 1996, and conducts citizen science surveys on birds, including Christmas bird counts, British Columbia Breeding Birds Surveys, BC Coastal Waterbird Surveys and Beached Bird Surveys. KVN works closely with Bird Studies Canada and are acknowledged caretakers for the Kitimat River Estuary. The organization is a division of BC Nature and Nature Canada and has birding records for the Estuary going back more than 40 years. Kitimat Valley Naturalists make at least 100 visits to the Estuary throughout the year.

2.2 Besides birds, KVN provides amphibian, cetacean and insect surveys for various colleges and BC's Provincial Museum. KVN are also Streamkeepers with DFO, working on various projects, and have an environmental author and former Parks Canada naturalist within their executive. KVN has been working for nine years with the Seagrass Conservation Working Group. They have been locating and mapping eelgrass beds throughout Douglas Channel.

2.3 The KVN are publicly funded through the Canadian Environmental Assessment Agency to participate in the Northern Gateway review process as an intervenor. KVN has chosen to participate in this process due to their interest and expertise in the Kitimat Estuary as it provides critical and spatially limited habitat for fish and wildlife. KVN has a very high interest and local expertise in birds, of which many species utilize the Estuary for critical life history phases.

2.4 The Kitimat Estuary has been in a state of ecological decline for over 50 years due to habitat alienation and degradation from industry. KVN has been actively involved in various projects on the Estuary, including eelgrass transplants and assessments. KVN’s local knowledge and various external studies of the Kitimat Estuary confirm that eelgrass abundance in the Estuary area has dramatically declined to the point that only remnant patches now occur in the Estuary area. The sensitive nature of the estuarine habitat makes it particularly vulnerable to impacts from spills or leaks associated with the project.


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2.5 KVN has reviewed Enbridge documents relevant to the Estuary area, and species of birds of importance to the region and to KVN. Following is a selection of issues, data gaps and key areas of concern identified by KVN.

2.6 The Kitimat River Estuary is very significant. The Estuary is considered by Ducks Unlimited to be one of “B.C.’s most important estuaries…” and is listed as a Class 1 Estuary (most important).1 The Estuary is essential for thousands of birds, and indirectly millions of fish. Many residents earn their livelihood from the Kitimat River Estuary.

3 DefinitionofEstuary

3.1 As we will extensively refer to the Kitimat Estuary (Estuary), the following definition is provided: An estuary is “…a partially enclosed body of water where seawater is measurably diluted by mixing with river runoff. Traditionally, the term has applied to lower deltaic portions of a river but has now been extended to include inlets, bays, sounds, and arms that receive measureable volumes of fresh water.”2 Therefore, the Estuary could be considered to extend well into the Kitimat Arm, including sections of much reduced salinity.

4 Summary

4.1 The Kitimat River is not just another insignificant creek entering the ocean. It is a large and substantial river with an enormous area of Estuary sloughs and grasses. This is critical habitat. It is in effect a huge blue carbon deposit, important to planet health. The Kitimat is an extraordinary Estuary recognized in previous scientific studies. The Kitimat is one of northern B.C.’s five largest estuaries in total square kilometers. The Estuary has provided quality habitat for fish, birds, wildlife, and benthic invertebrates.

4.2 Waterfowl use of the Estuary is high (Hay 1976, Horwood 1992). The unusually large Kitimat River Estuary is located at the mouth of the broad low-elevation Kitsumkalum-Kitimat trough (Clague 1984) which serves as a migratory corridor. The central Estuary and Minette Bay are extensively used by hatchery and wild juvenile salmonids (Slaney et al. 1982, Orr 1985).3

4.3 Construction of the three deep sea terminals and their associated causeways is believed to have affected adjacent areas by reducing freshwater circulation to the western portion of the Estuary (Hunter and Jones 1982). Historically, two log storage and handling facilities were sited within the highly productive foreshore habitat of Minette Bay.4 The eastern-most facility still operates.

1 British Columbia’s Vital Estuaries: http://www.ecoreserves.bc.ca/misc/BC_FS_VitalEstuaries.pdf 2 Richard E. Thomson, Oceanography of the British Columbia Coast. p.17. 3 Dawn Remington, Coastal Wetlands Habitat Assessment and Classification for Northwestern British Columbia, p.46. 4 Ibid, p.47.


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4.4 Several water quality issues have arisen as the result of industrial effluents, including allegations of taste and odor tainting of the Eulachon, and concerns over the accumulation of PAH's and dioxins in marine and estuarine sediments and shellfish (DFO 1993).5

4.5 The habitat at Kitimat Estuary has been substantially altered by over 50 years of cumulative impact and industrial development. Decline over 50 years of the keystone, key indicator species, eelgrass, clearly shows the devastation. The identified sites and abundance of eelgrass at the Kitimat Estuary have shown a consistent devastating decline over the past 50 years.

4.6 Whole valley logging, smelter toxins, pulp mill effects, pipeline and powerline developments have all exacted costs to the Estuary. Further impacts to the Estuary are not sustainable. The potential for a diluted bitumen leak or spill affecting the Estuary is very high (if not certain) and the impacts are likely to be catastrophic on a number of ecological and social levels. The Kitimat system is in great peril. It is imperiled by a triple oil threat. Potential disasters are from an upstream pipeline rupture, spillage at the nearby tank farm, and collisions or groundings from supertankers. Further development and mishaps, especially of the magnitude and severity of an oil spill make the cumulative effects on the Kitimat system overwhelming.

4.7 It is obvious to KVN that Enbridge has not undertaken sufficient assessment of the Estuary and associated ecology. It is largely ignored. The Kitimat River Estuary is one of the North Coast’s greatest assets. Enbridge is demonstrating a lack of understanding and valuation. Contrary to Enbridge statements, potential impacts to the Estuary associated with a spill or leak cannot be mitigated.

4.8 The economic value of the Estuary to the town of Kitimat was not taken into consideration by Enbridge Northern Gateway when an oil spill analysis was done. The Kitimat Estuary is the nursery for various salmon species that migrate to spawn up the Kitimat River. Recreational fishing of the Kitimat River is a major economic factor; drift boat outfits, fishing guide outfits, and campers at Radley Park all bring economic benefit to the town.

4.9 The Kitimat River and Estuary are currently under review by BC Rivers Institute to be designated an endangered river.

5 Ibid, p.47.


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5 EelgrassontheKitimatRiverEstuaryDelta

5.1 As a DFO “sensitive habitat”, eelgrass is ecologically significant because it is a keystone species that provides a number of important functions within intertidal and subtidal marine ecosystems, including primary production, nutrient processing, wave and current energy buffering, organic matter (detritus) input, food and habitat for fish and invertebrates, and food for birds.6

5.2 Three reports completed and published from 1976 through to 1981 make extensive reference to eelgrass beds in Minette Bay and Minette Channel. These report specifically refer to:

• areas dominated by eelgrass;

• extensive beds occurring in Minette Bay Channel; and

• beds of eelgrass occur in outer delta areas and along the western shore of Minette Bay.

5.3 Beginning in 2002 and continuing through 2011, numerous underwater investigations failed to find these eelgrass beds.

5.4 In October 2002, along the western edge of the outer delta, small patches of eelgrass were found and mapped at Hospital Beach. By 2011, these eelgrass patches had diminished significantly.

5.5 KVN estimate the remaining eelgrass on the Kitimat River Delta to be less than 10% of what existed in mid 1970’s.

5.6 The KVN concur with a 1980’s published report that the Kitimat River Estuarine Delta has been alienated due to outfalls and physical encroachment from the Rio Tinto Alcan and Eurocan facilities. The same report specifically notes a deterioration of water quality in Minette Bay.

5.7 The KVN believe this to still be true as attempts to transplant eelgrass in Minette Bay in 2003, 2004, and 2005 all failed. Water quality was highly suspected as the reason for failure.

5.8 Prior to 1950, the Kitimat River Estuary delta was a pristine ecosystem with healthy eelgrass beds, major salmon and eulachon runs, and contaminant-free shorelines and mudflats. Following the building of one, then two industrial complexes, combined with the municipal outfall, the Estuary inexorably deteriorated to its present state.

5.9 During the KVN review of the Northern Gateway proposed pipeline, there was almost no recognition of the Estuary, its past or present condition nor its extreme vulnerability to an oil spill.

6 Gretchen Harlow & Katherine Dunster: Eelgrass Mapping Review: Eelgrass mapping Initiatives in Coastal British Columbia, p. 12.


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6 MarineBirds

6.1 Many inaccurate or incomplete representations exist in Enbridge’s reporting of the marine birds in the vicinity of the Kitimat Estuary. Some of these inaccuracies include a misrepresentation of the Key Indicator Species used in reporting.

7 KeyIndicator(KI)Species:MarbledMurrelet,SurfScoterandBaldEagle

7.1 The key indicator (KI) species selected do not adequately reflect the critical role that the Kitimat and surrounding estuarine areas play in sustaining bird populations. Two of the three Key Indicator species, Surf Scoter and Marbled Murrelet, do not represent the northern end of the Estuary where there is the greatest abundance of birds. KVN’s sightings show these two birds to be almost absent from the northern end of the Estuary.

7.2 Marbled Murrelet life history is not critically linked to estuarine habitat. From a total of 200 documented sightings since 1975, only 22 were seen in the northern end of the Estuary. Sightings since 2006 have been almost non-existent. There have been fewer than 20 sightings in the vicinity of Kitamaat Village.

7.3 None of the large flocks of Surf Scoters have been seen near the Kitimat River Delta in the last two decades.

7.4 Bald Eagles are present in the Estuary year round and nest in the area, however, they also nest throughout the channel length and throughout the Kitimat Valley, Lakelse Lake area and beyond. Bald Eagle life history is not critically linked to estuarine habitat.

8 KitimatRiverEstuary:Waterfowl&Waders

8.1 The most abundant birds utilizing the Estuary are waterfowl and waders. These two main groups of birds utilize the Estuary for specific time periods associated with migration and wintering.

8.2 Migratory: Significant numbers of shorebirds and waterfowl utilize the Kitimat River Estuary during both migration periods. The spring migration, somewhat confined to mid-April through to mid-May appears to have the highest numbers of species and individuals. The autumn migration is much more protracted. Migrating shorebirds first appear in late August. Migrants continue to use the Estuary until at least October.

8.3 Wintering: The Kitimat River Estuary is an important wintering area for numerous species. Waterfowl compose the highest numbers. Wintering birds, such as Trumpeter Swans, arrive in October and stay until at least March.


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8.4 Both a wading species and a waterfowl species should have been considered as KI species for the project.

9 IncompleteBirdingData

9.1 Enbridge did not consult local expertise for current trends or historical observations in their birding data. The Kitimat Valley Naturalists have been involved with BC Coastal Bird surveys since 2006 (in two estuary sites).

9.2 KVN notes that the Enbridge bird surveys on the Estuary were not conducted during all critical times. For example, surveyors missed breeding Killdeer, a regular Estuary breeding bird. May was missed as an observation time, which has repeatedly been one of the best time periods for Estuary birds. More species of migratory birds visit the Estuary during May than any other migratory month.

10 CurrentTrends

10.1 There is a lack within the data of mentioning current bird trends within the Estuary. For example, there is no documentation of current trends in reference to the following species:

a) Migrating Snow Geese: Snow Geese used to be a rare migrant. It is now an expected spring and fall migrant.

b) Great Blue Herons now use the Estuary as a wintering area. There are now two recent summer sightings suggesting the species might become resident at the Estuary.

c) Surf Scoters, reported in large numbers in 1975, have not been witnessed in the last decade. This suggests Surf Scoters may be in decline in the Douglas Channel system. This contradicts Enbridge’s conclusions about the population being stable. They cite a 21-year-old reference in making this conclusion.

d) Trumpeter Swan numbers have increased in the last 10 years. High-count numbers have exceeded 40 on more than one occasion.

e) Ospreys are now Estuary nesters. At least three nests are located within the Estuary area, and

they also have a presence in Miskatla Inlet.

11 OilSpillAssessment:BlackOystercatcher

11.1 The use of the Black Oystercatcher as an assessment shorebird is not representative of the estuarine birds. The Black Oystercatcher has never been recorded in the delta of the Kitimat River Estuary and only recently at Coste Rocks. Shore birds and dabbling ducks must be considered if conducting an Oil Spill Assessment.


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12 ReviewofEnbridgePresentedBirdData

12.1 Table 1 provides specific KVN response to Enbridge statements concerning birds in the project area.

Table 1. KVN Response to Enbridge Northern Gateway Birding Data and Impact Assessment.

Page Ref.

Enbridge Analysis Kitimat Valley Naturalist Response

Birding Inaccuracies

Vol. 6B p.12-12

During preliminary marine surveys, individuals or pairs of murrelets were observed in the PEAA in the protected inlets and bays along Douglas and Devastation Channels, including Bish cove and Emsley Cover (Horwood 2006).

Murrelets have been observed along the east side of Kitimat Arm late in the day with fish in their bill. This suggests breeding activity along the Kitimat Arm other than just at Bish Creek. (p.12-12) There should have been multiple radar surveys in the PEAA area where there are high numbers of murrelets. Locations of significant concentrations of Marbled Murrelets are Amos Passage, Coste Rocks, and Foch Lagoon. The Enbridge report does not cover these or other significant places where murrelets forage or gather.

Vol. 6B p. 12-3

[The Bald Eagle] is the only raptor found throughout the general region around the Kitimat Terminal at all times of the year and consequently acts as a good representative for raptor species.

This is not true. Sharp-shinned Hawks and Merlin are present year round. Merlin is a breeding bird.

Vol. 6B B9-18, Fig. 4-17

The Enbridge maps show a complete absence of Bald Eagle nests in the Estuary area.

Bald Eagle nests are known on backshore of the Estuary (2), one at Eagle Bay, one at km 5 along the Bish Creek Road, and yet another near Kitkiata Inlet. None of these nests were recorded in B9-18, figure number 4-17.

Vol. 6B p.12-3

The blue-listed Surf Scoter uses Kitimat Arm and Douglas Channel during non-breeding periods.

Surf Scoters are present in the Douglas channel area during the breeding season. Evidence of Surf Scoters during breeding season as historically recorded: a) July 7, 1975 800 Coste Rocks b) July 4, 1991 15 Douglas Channel c) July 9, 2003 300 Coste Rocks

Vol. 6B p. 3-9

No reference is provided regarding Great Blue Heron wintering

The Estuary is a wintering area for Great Blue Herons. a) December, 2010: 21 Great Blue Herons

Vol. 6B p. 12-9

Report collisions. Workers and contractors at the Kitimat Terminal will be instructed to report any collisions of birds with structures.

Uncertain of how reporting collisions will in anyway help mitigate for KI species.

Vol. 6B p. 12-2

To assess the environmental effects on different types of marine birds, key indicators (KIs):

Occurrence and use of available habitats in the project area (PEAA)

Sensitivity to project effects Importance to local communities

and resource users National or international

None of these three KI species represent dabbling ducks, waders or shorebirds which occur in abundance within the PEAA. Significant numbers of geese and ducks use the Estuary during the spring and fall migration. Three examples are: a) April, 2003: 300 Snow Geese b) October, 2008: 4,000 Canada Geese c) December, 2010: 487 Mallards


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importance (including status under the Species at Risk Act)

Value as an indicator of environmental effects for related recourse and broader systems

Ecological importance

Vol. 6B p. 2-4

Terrestrial surveys were conducted during October 2005; July 2008; and February, April, June and September 2009. … Where time allowed, surveyors attempted to record marine birds at each point during morning, midday and evening.

The viewing times also missed two critical months – May and October.

a) Greater White-fronted Geese are recorded more often in October than any other month during the fall migration.

b) Migratory or wintering Mallards and Bufflehead begin to appear in October

c) 45% of all Snow Goose sightings at the Estuary took place in May.

KVN questions why only attempts were made to gather accurate information. This suggests that bird data gathering was sporadic.

Vol. 6B p. 5-5

Belted kingfisher were observed across all seasons at low density suggesting that the species breeds and winters in the area, only migrating locally.

Kingfishers forage within the PEAA and they nest on the edge of the PEAA. Kingfishers do breed in the PEAA.

Errors in Birding Data

Vol. 6B p. 3-9

Great Blue Heron is the only wading bird that has been recorded within or near the PEAA and CCAA.

This in an inaccurate statement. Sandhill Crane have been increasing in numbers in the Estuary.

Vol. 6B p. 3-10

…and Snow Geese…are likely to occur within the PEAA and CCAA during migration periods.

Snow Geese do occur within the PEAA and CCAA during migration periods.

Vol. 6B p. 3-15

Some Harlequin Ducks may breed in the creeks flowing into Douglas Channel. Numbers of birds using remote parts of the PEAA and CCAA are poorly known.

Harlequin Ducks do breed in the Douglas Channel system. KVN is concerned this special bird has not been fully researched.

Vol. 6B p. 3-17

A complete list of potentially occurring shorebirds is included in Appendix A.

Four species on this list have never been recorded in the delta area:

Ruddy Turnstone Solitary Sandpiper Black Oystercatcher Wandering Tattler

Termpol Binder 1 of 3

There is no bird data representing bird populations on Kildala Arm within the submitted materials to the NEB from Enbridge.

Kildala Arm is less than 10kms from the proposed terminal. Kildala waters are connected by tides/currents as shown in the technical data provided in the Termpol Binders.


Absent data in the tables regarding bird sightings in the CCAA (including the delta/Estuary of the Kitimat River)

Public records can be used for a better representation of sightings within the Kitimat Delta.


No inclusion of the Red-throated Loon in inner waters of the CCAA (including delta).

Red-throated Loon is present. See BC Coastal Waterbird Surveys, 2010 and Breeding Bird Atlas Data.


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No reference or records exist to the Greater Yellowlegs or Lesser Yellowlegs (large wading shorebird) in Kitimat delta or anywhere in the CCAA.

Evidence is provided in public records such as the BC Coastal Bird Surveys.


No reference or evidence of the Common Murre in the CCAA including the Kitamaat Village and Estuary.

Evidence is provided in public records in BC Coastal Waterbird Surveys 2009 and 2010.

Termpol Binder 2 of 3 Table B1 Pg. B-22

The table indicates the Glaucous Winged Gull nests at Coste Rocks.

Extensive historical survey information provides no evidence of nesting Glaucous-winged Gulls at Coste Rocks.

Termpol Binder 2 of 3 Pg. B-20

No public records or sightings of the Dowitcher within the CCAA.

This species is recorded in the delta/Estuary area in public records (BC Coastal Waterbird Surveys).


No specific mention of the Common Merganser in the CCAA.

Common Mergansers are year-round residents and breed in the Kitimat delta area. Breeding evidence as well as the year-round presence of this species in the delta/Estuary area. Evidence can be found in public records: Christmas Bird Count Data, See BC Coastal Waterbird Surveys, Birds of BC, and BC Breeding Bird Atlas Data.


Ring-necked Ducks are profiled but there is no specific mention of presence or records for the CCAA.

This species is recorded in the delta/Estuary area in public records (Christmas Bird Counts).


Brant is profiled but no presence indicated. This species has been recorded in the delta/Estuary area in public records (Christmas Bird Counts).

Termpol Binder 2 of 3 (Pg. B-8)

Snow Goose and White Fronted Goose are profiled, but no presence in the delta/Estuary is indicated.

There is an abundance of public records which show presence of the Snow Goose and White Fronted Goose in the Estuary and delta.


Western Grebe is profiled and stated it is found in the Douglas Channel but not indicated in the CCAA column.

Public records show there are frequent sightings of Western Grebe within the Estuary waters, as noted in BC Coastal Waterbird Surveys.


Red-necked Grebe profiled and stated it is found in the Douglas Channel but not indicated in the CCAA column.

Public records show there are frequent sightings of Red-necked Grebe within the Estuary waters, as noted in 10 of 12 Coastal Bird Surveys.

Volume 6B Pg. 12-3

No seabird colonies are recorded within Kitimat Arm or the greater area of Douglas Channel. For this reason, colonial species are not selected as KIs.

Coste Rocks – Pigeon Guillemots nesting evidence

Ashton Point – Suspected breeding of Pigeon Guillemots

12.2 KVN has extensive local knowledge of the natural history of the Kitimat River Estuary and adjacent habitats. KVNs limited review of the project data has identified errors and data gaps. Table 2 provides specific KVN response to Enbridge statements concerning the Kitimat and area estuaries.


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Table 2: KVN Response to Enbridge Northern Gateway Estuarine Assessment Page Ref.


Vol. 7B p.7-12

A hydrocarbon release into a watercourse that flows to the marine environment (e.g., a tributary of the Kitimat River) has the potential to affect estuarine and marine vegetation if unmitigated. Baseline vegetation in the Kitimat River Estuary has not been assessed formally. However, most of the vegetation in the Estuary is sedges in a salt marsh (Taylor 2009, pers. comm.).

Since the Pine River spill affected the river for over a year (drinking water) then it is safe to say a spill along the Kitimat River would also affect the town’s drinking water, the hatchery, and estuarine plant, fish, wildlife and benthic invertebrate communities. The town’s water intake facility and the hatchery are very close to the Estuary area. Enbridge admits that the vegetation in the Estuary has not been assessed formally. How can we make a credible response when Enbridge admits they have not done detailed baseline surveys? The Estuary is very close to the terminal and could suffer greatly from an marine oil or upriver oil spill. The Estuary is one of the most critical habitats in the valley and has shown to have declined in the last 50 years due to industrial activity. Enbridge does not appear to recognize this therefore seemingly has no plans to accommodate any oil at the Estuary.

Vol. 7B p.7-12 p.7-13

There may also be eelgrass beds and rockweed in various parts of the Estuary.

In fact, there is some eelgrass in limited parts of the Estuary. Their statement, however, is unacceptable. They have not adequately researched or assessed clearly what is present in the Estuary area. Should there be a spill, there is no baseline data to indicate whether the Estuary has recovered to 2011 levels.

Vol. 7B p.7-13

Recovery times of five years have been documented (Morris and Harper 2006).

So far, all of Enbridge’s references (e.g. Taylor 2009, pers. Com) support their statements. They make no mention of reports and scientific data that show present conclusions unfavorable to the project. Enbridge is showing the best possible scenario which is more than likely not realistic. For example, the recovery of the Estuary is likely to be much longer than 5 years. The information from the spill in Prince William Sound shows a much longer recovery. In short, Enbridge continues to minimize effects.

Vol. 7B Pg. 7-13

In marine environments, adult rockweed plants at heavily oiled sites suggest that this species may be relatively tolerant to oiling and resistant to smothering, but sensitive to high-intensity cleanup operations, such as hot water and power washing (van Tamelen and Stekoll 1996). Although exposure of marine vegetation to hydrocarbons may not lead to dramatic immediate mortality, contamination of intertidal sediments could lead to long-

This is clearly an admission that oil contaminated sediments, of which the Kitimat River Estuary is composed, could release toxins for years. Enbridge gives no evidences to the number of years the Estuary would take to recover from a major spill. The use of the word ‘may’ suggests an element of doubt. Toxins released into the environment “will” affect reproduction and delay recovery. This is an unacceptable risk.


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term (i.e., months to years) release of contaminants, which may affect reproduction and recruitment and delay recovery of affected populations.

Vol. 7A Northern Gateway would implement measures to mitigate effects on vegetation (see Volume 7A, Spill Contingency Plan), including removal of heavily contaminated soil and vegetation for disposal at an approved waste treatment and disposal facility, or in-situ burning where heavy equipment would cause environmental damage.

The removal of heavily contaminated soil and vegetation in an estuarine environment essentially means digging up the affected part of the Estuary. This would likely involve heavy equipment and massive disturbance of this sensitive ecosystem. In-situ burning and digging would also cause massive disturbance of estuarine habitat, and is not an acceptable activity on the Estuary.

Northern Gateway Response to Douglas Channel Watch IR No. 1

Redundant downstream boom installations are typically installed in order to capture product that may escape from upstream containment points.

Redundant booms installed in the Kitimat River or tributaries are unlikely to prevent oil from being carried downstream to the Kitimat Estuary. Booms cannot be readily deployed and maintained across the river channel without being affected by debris flowing down the river.

Risk Assess. of Hypothetical Spill Examples TDR: Section 2 1BEcological Risk Assess. Pg. 2-20

Sinking of the oil on the water surface. As the hydrocarbon present in the surface oil weathers, its density increases. If the density of the hydrocarbon in the surface oil exceeds that of sea water, the surface oil is assumed to form hydrocarbon globs that would sink to the sub-tidal sediment.

Bitumen will sink therefore will not be captured by floating booms.

13 MammalData

13.1 KVN is also knowledgeable of marine mammal use in the project terminal area and beyond. KVNs limited review of the project data readily identified errors and data gaps. Table 3 provides specific KVN response to Enbridge statements concerning marine mammals.

Table 3: KVN Response to Enbridge Marine Mammal Data Page Ref.


Missing Data

Kitimat Arm mammal data are weak. No data is provided for the following: pods of seals are regularly seen at Minette

Bay/Delta areas with the various runs of salmon, smolts, herring, smelt, oolichans etc.

Inner fjord regular mammal haul-outs are not mentioned. …

Coste rocks: major habour seal haul out 10 kms out.

Gobeil rocks: seasonal seal haul out 5 kms out. North Loretta Island: major stellar sea lion haul


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Vol. 6B p. 11-2

Pinnipeds include harbor seals and Steller sea lions. Both species may occur year-round in Kitimat Arm…Haul-outs and rockeries represent important habitat for both harbor seals and Steller sea lions. The closest semi-permanent Steller sea lion haulout to Kitimat Arm winter haulout on Ashdown Island (COSEWIC 2003b)…Stellar sea lions are likely to be present in Kitimat Arm year-round.

out 15km out. Junction of Sue and Lorretta Channels (major

seal haul-out) 20 kms out. Amelia Island Rocks: Major seal haul out 25 kms

from terminal.

14 Conclusion

14.1 KVN’s review of the vast amount of information prepared for the project has identified substantial data gaps related to birds in the Kitimat River Estuary area. These data gaps could have been readily filled had Enbridge appropriately resourced regional birding experts or accessed public databases. Further, KVN’s review has also identified substantial risk to the Kitimat Estuary area. The Estuary provides critical habitat for fish, birds, wildlife and benthic invertebrates and has been substantially altered by over 50 years of industrial development. Further impacts to the Estuary are not sustainable. The potential for a dilbit leak or spill affecting the Estuary is very high (if not certain), and the impacts are likely to be catastrophic on a number of ecological and social levels.

14.2 It is apparent to KVN that Enbridge has not undertaken sufficient baseline assessment of the Estuary and associated ecology, thus demonstrating a lack of understanding and valuation. Contrary to Enbridge’s statements, potential impacts to the Estuary associated with a spill or leak cannot be mitigated.


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15 References

Bell, Leonard M. & Kallmar, Ronald J. “The Kitimat River Estuary Status of Environmental Knowledge to 1976”. Special Estuary Series No. 6, December 1, 1976.

Campbell, Colin R., PhD. “Blue Carbon – British Columbia: The Case for the Conservation and Enhancement of Estuarine Processes and Sediments in B.C.” Sierra Club.

Cottrell, T.J. & Hall, J.T. Land Management Branch: “Minette Bay/Kitimat River Estuary Review for Management Options”. March 13, 1981.

Ducks Unlimited Canada, “British Columbia’s Vital Estuaries”. (BC_FS_VitalEstuaries_090604/j) http://www.ecoreserves.bc.ca/misc/BC_FS_VitalEstuaries.pdf

Hay, Robert. B., “An Environmental Study on the Kitimat Region with Special Reference to the Kitimat River Estuary”. The Canadian Wildlife Service Pacific & Yukon Region. June 30, 1976.

Horwood, Dennis. “Birds of the Kitimat Valley” Kitimat Centennial Museum, 1992

Remington, Dawn. Coastal wetlands habitat assessment and classification for northwest British Columbia. For Pacific Estuary Conservation Program. November 1993.

Thomson, Richard E. Oceanography of the British Columbia Coast. Canadian Special Publication of Fisheries and Aquatic Sciences 56. 1981.

16 Acknowledgements

This report was assembled and formatted by Cambria Gordon Ltd. of Terrace, BC.