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[IronNoggin]

Re: The VAFFC Proposal to Ship Jet Fuel into the Fraser River for YVR.

Terry asked the question "Could it be the Victoria bunch are playing games?... as related to the proposal by VAFFC to ship jet fuel into the Fraser River to supply the airlines at Vancouver International Airport (YVR).

The Victoria BC EAO process is a slanted playing field and the process is run in a less than professional, competent and trustworthy manner. When you combine a business or jobs at any cost mentality in the BC government and run a less than defensible environmental assessment (EA) process, parties like VAFFC will use any process to play games to get their irresponsible project approved by what appears to be a BC EAO paper pushing rubber stamping approval agency. Here are some of the problems that we must accept and deal with:

Of about 125 projects BC EAO has reviewed in the past two decades, only about 1 or 2 was ever rejected.
In this project, the BC EAO has gone through at least 3 directors in 8 months - terrible continuity
The BC EAO accepted this project on a volunteer basis as submitted to them by VAFFC on a volunteer basis. Does that mean its findings can be complied with on a volunteer basis?
Why does the BC EAO and the CEAA environmental review process allow large controversial projects like allowing Panamax tankers of fuel into the Fraser River, the building of a terminal and 80 million litre storage tanks on the banks of the worlds biggest salmon stream and Canada's largest waterfowl over-wintering habitat (in a flood and earthquake unsafe zone with no dedicated fire fighting capability) without any proper higher level environmental assessment (EA) and proper and full public hearings (as was required in 1988)?.
Further to the above, in that a similar project from VAFFC was rejected in 1989, why has the federal government not put rules into place to protect the Fraser River estuary from such an irresponsible proposal?
In that this is a Federal port, is in the key habitat of Federally protected fish, Federal protected migratory birds,Federally protected habitat, directly involved servicing a Federal airport, affects Federal navigation laws. Federal shipping laws, Federal pilotage authority, why is this environmental review not done by the Federal government?
The BC Auditor General has criticized the BC EAO for not enforcing condition of its approvals - ie compliance is voluntary!!
The public had all of 2 minutes to comment on the project in a public hearing last winter - a absolute joke! The public then then had to appeal for an extension to submit written comments.
BC EAO emphasized that they intended to keep to a strict time line ie expedited approvals!
BC EAO then let VAFFC put in a 120 day suspension that then lasted about 240 days.
VAFFC then did not change anything in their application or project to reduce any of the environmental risks to the Fraser Estuary i.e. the greatest public complaints about the project..
EAO allows only one option to be examined at a time. The better safer option that will keep fueltransport out of the estuary will not be reviewed
despite the one option rule, VAFFC was allowed by EAO to submit about 3 different options for the pipeline across Richmond and VAFFC insists it will retain the right to use any of these options. Who is running the show?
the January 4th BC EAO advertisement that the process is again open for input was actually published on the last page of a Clip and Save coupon leaflet!! An odd place to find a legal advertisement. I could not determine if I should clip out the A&W ad for 2 hamburgers for the price of one or go for yet another jet fuel fiasco assessment process.
The BC EAO now allows public comment until Feb 1 but the Metro Port study on Tanker Risk in the Fraser is not available for review. Also many other studies by VAFFC including a compensation plan for natives for lost fisheries during jet fuel spills is not available. Why would this application be so incomplete and why would BC EAO allow such to proceed other than to confuse the public.
although VAFFC says they will respond to public inquiries they gave refused to respond to letters written to them by VAPOR
the public VAFFC open house on Jan 28 is not sanctioned by EAO as part of public input but they will be there to answer questions about the BC EAO. Why is this open house at the tail end of the public comment period?
Why has the Federal government delegated their CEAA EA authorities to Port Metro Vancouver - the developer who will profit form any approvals given this project?
Why has the PMV signed a harmonized agreement to jointly review this project when the BC EAO is in a junior government agency and the mandates affected by this project are in the senior (Federal) government?.
Further why did the Federal agency who has the CEAA EA responsibilities improperly delegated to them, and to make matters worse, have the BC EAO head up this EA review? Is this not an undermining of the legitimate authority of Federal ministers?
Why do we have a process in place where VAFFC can go around and shop for the best possible review process so as to get their project approved in what most feel is a green washing process?
Another farce in this game is the fact that today the YVR CEO Larry Berg announced a 5$ increase in the passenger fees at YVR to raise $1.8 billion dollars to make YVR bigger and the best airport in the world and the "Gateway to the Pacific". Nowhere in this $1.8 billion do I see anything to build a secure and environmentally friendly fuel supply to the airport. Berg and his client airlines want to create a world class airport that in some ways will function like an airport would before the fuel pipeline was built to it in the 1960s i.e. a move back to the medieval period of environmental protection.
VAFFC just released s a highly subjective and suspect study by Golder and Sandwell looking at other options such as barging of oil into the North Arm or putting a new tank farm into North Vancouver. This faulty and biased study was directed to not look at the most common sense and the best environmentally friendly option that would protect the Fraser River and all estuarine waterways from tanker and barge based fuel transport. The study blindly refused to study a much safer ARCO and Chevron refinery pipeline option as promoted by VAPOR.
A local Environment Canada officer wroste to the junior BC EAO process in August 2011 noting "
“ The project would present a new and unacceptable risk to the locally, nationally and internationally-important fish and wildlife populations of the Fraser River Estuary, including migratory birds and species at risk…” and “Environment Canada is of the opinion that there is a limited ability with currently available technologies to effectively control a potential Jet-A fuel spill in the Fraser river Estuary”.

[IronNoggin]

Further on September 12, 2011, Richmond City Council (home of YVR and many of those working at YVR) moved that the City is “is opposed to the transportation of jet fuel on any arm of the Fraser River”.
Something really smells in this environmental review process and several parties including the Federal Government [DFO, EC(CEAA) and Transport Canada (Ports Canada and PMV) and the BC MOE and EAO process and of course VAFFC and its airline owners] is the direct cause of this problem. Something is very rotten when it comes to this less than ethical and legitimate effort to protect the Fraser River from such an irresponsible project. Individuals such as Steven Harper and Christy Clark should take full responsiblilty for how they have allowed environmental protection to become a pawn in the develop at any cost campaign and they must be held responsible by future generations for what is now taking place.

Considering some of the above examples I must conclude that the playing field is very slanted but it is VAFFC that is playing games to get its way. BC EAO with its dismal past EA record is little more than a pawn in the game. A few months ago an environmental lawyer advised me that the BC EAO process was the worst environmental assessment process in Canada. Further to the above points, theEa process is not run in a responsible, competent or accountable manner and is directed by a Minister who will keep his head buried in the sand while he says this is the best EA process around. Minister Lake has actually refused to meet with VAPOR to discuss this issue in that he says VAPOR will bias his thinking.

Many local Liberal MLAs and Conservative MPs are also in denial about the process and find it easier to sit on the fence while the game playing goes on - they seem tosee no problem with gambling with the future of the Fraser River an our salmon runs and the millions of birds that need the estuary.It is a globally significant estuary and its time the airlines showed some leadership and provided their own VAFFC some direction to treat the river as such. It does not take a rocket scientist to see that VAFFC proposal of tankers full of toxic and flammable jet fuel is not a good mix for the Fraser River and its stressed but still abundant populations of fish and wildlife and its great property and recreational values.

In conclusion, I do not believe the BC EAO is playing games - theVAFFC and their airline owners are being like neighbourhood bullies and are using the weak and near hopeless BC EA process to play games so as to force through a totally unacceptable and environmentally irresponsible project. They are being stubborn for no good reason and despite airline environmental policies they are avoiding doing what is right for the river and its fish and wildlife, property values, public safety and are not working in the best interests of YVR that wants to be a "world class airport" and the "Pacific Gateway". Air Canada, Westjet, KLM, Air China, etc may want YVR to be a world class airport but they are insisting that it have a dark ages fuel delivery system. Even in the 1960s, an all pipeline route was built to serve YVR. In the 1960s a much longer pipeline was built from the Ferndale ARCO refinery to serve the much larger and distant SeaTac and then the Portland airports. All Los Angeles airports are served by jet fuel pipelines. What is wrong with the thinking in VAFFC and their owner airlines and Vancouver International Airport (YVR)?

In 1989 an 'in the Fraser River' jet fuel delivery system by the same VAFFC was rejected by the federal government. Why in 2012 would VAFFC, against great public and local government opposition, go back to something very similar to what was rejected in 1989? Some in government and in industry appear to want to move us back into the dark ages of environmental protection. I petty our children and their children and the life forms in the Fraser River that do not have a voice in this matter. In 1988 DFO and EC (CWS) and BC MOE was there to speak for those without a voice. What has Harper and the Campbell/Clark governments done to prevent these environmental protection agencies from doing their jobs?

Unfortunately the Victoria Liberals and the Harper Conservative government feels this is how to develop the economy and the environment is near irrelevant at this time - its the jobs stupid! If common sense prevailed, here we can have the jobs, the airplanes can have their fuel and the Fraser River can be fully spared. To approve this project as it is now proposed is little less than an environmental crime. During the present era, the environmental protection needs can only be met by strong public involvment and above all protesting many industries' and government's dismal sense of environmental stewardship.

Sincerely yours, Otto E. Langer MSc
Fishery Biologist and Aquatic Ecologist.