Climate Change

Delta Port Third Berth Expansion: Letter to Government

September 1, 2006

Dave Carter, Senior Program Officer
Canadian Environmental Assessment Agency
757 West Hastings St
Vancouver BC, V6C 1A1

Dear Mr. Carter

Re: Delta Port Third Berth Expansion Project – Comprehensive Study Report

Please accept our comments on the Delta Port Third Berth Expansion Project – Comprehensive Study Report.  The Georgia Strait Alliance (GSA) is a charitable, non-profit society formed in 1990 to protect and restore the marine environment and promote the sustainability of Georgia Strait, its adjoining waters and communities. 

Our goals are to:
1. Protect biodiversity and wildlife habitat;
2. Restore the region's water and air quality;
3. Promote the social, cultural, economic and environmental sustainability of the region's communities;
4. Foster understanding and stewardship of the marine environment; and
5. Raise awareness of the links between the health of ecosystems and human communities.

GSA is active on a range of educational and advocacy efforts aimed at safeguarding the marine environment and the health of the human and non-human inhabitants that make this remarkable inland sea their home. Our programs include intertidal stewardship and monitoring; encouragement of reduced use of toxic household products; promotion of green boating and best practices in marine industries; Marine Protected Areas; improved sewage treatment, and reduction of pollution and habitat impacts from salmon farms. We promote science, collaboration and common sense as tools in the pursuit of sustainability. We also recognize that “sustainability” must encompass not only a healthy environment, but also social factors such as human health and a healthy economy.

GSA is made up of over 50 member groups and 1000s of individuals around the region. Our organizational members include environmental, recreational, labour, and community groups, sport and commercial fishing organizations, small businesses, marine industry organizations and many others that together comprise well over 100,000 people

We have many concerns regarding the Delta Port Third Berth Expansion Project, however, we would like to focus our comments here on the impacts this expansion will have the endangered Southern Resident Killer Whale.

  • The Southern Resident Killer Whale (SRKW), a transboundary species, has been designated as endangered by both the US and Canadian governments, primarily because of concerns regarding its small size, its small numbers of reproductively active adults, its low reproductive rate, and its decline of 17% between 1995 and 2001.  This species joins the 62 other marine species in our region which are listed as “at risk” by Canadian, US, BC or Washington State agencies.  This growing list is an indication that we are putting increased pressure on Georgia Strait, and its adjoining waters of the Strait of Juan de Fuca and Puget Sound, and it is having a measurable negative impact on marine wildlife.  The best available science (which can be found in the SRKW’s Recovery Strategy, Draft – March 2005) indicates that this species is under growing pressure from human activity.  The greatest pressures are a reduction in the availability of prey due to collapsing salmon stocks; high levels of persistent organic pollutants that may be compromising their reproductive and immune systems; a high volume of boat traffic from commercial and recreational sources; and other human-caused stress arising from the geographic location of their range.  Considering these facts, we are concerned and surprised that the report concludes a negligible impact on marine life from potential collisions and increases in noise that will come with the port expansion (p.180).  Conclusions such as these are too often based on a lack of information rather than evidence that there is little or no effect.  We are concerned that this is a risky conclusion that will harm the 63 species “at risk” in our region and potentially cause this list to grow.
  • Southern Residents live in the waters off northern Washington and Southern British Columbia.  In Canada, where they are found in the waters of Southern Georgia Strait, they are surrounded by two large urban centers - Victoria to the west, and Greater Vancouver to the east.  The whales are already experiencing the impacts of more traffic on our waters, and a further increase in traffic due to the port expansion will only put more pressure on them, in particular from increases in noise.  A recent study (Hildebrand et al., 2006) showed that noise levels in the offshore waters of California in 2003-2004 were 10 to 12 decibels higher than in 1964-1966, an average noise increase rate of three decibels per decade.  The reason for the increase is from growth in the global shipping trade, the number of ships traveling the world's oceans, and the higher speeds and propulsion power for individual ships.  According to Lloyd's Register figures quoted in the study, the world's commercial fleet more than doubled in the past 38 years, from 41,865 vessels in 1965 to 89,899 vessels in 2003. The authors believe that their study area is representative of activity in the Pacific North East, therefore it is likely that the waters of Georgia Strait, with its growing ports, are far noisier than they were just a few decades ago. For marine species, such as the SRKW, this could have a significant negative impact on their ability to communicate, which will only get worse with the current expansion project. This is hardly a negligible impact for an endangered species and we feel that this has not been adequately addressed in this report.
  • As the killer whale makes it home on both sides of the border, an international assessment of impacts on this species must be considered, as the effects here in Canada cannot be analyzed in isolation of what the species is experiencing while in US waters. It should be noted that on both sides of the border, recovery strategies are being developed for this endangered species.

Therefore, we ask the following:

  • That a more comprehensive review be completed to properly assess the impacts increased noise would have on marine life and propose mitigation plans, such as making changes to shipping lanes.

    • This review should use a precautionary approach for assessment of the conclusion that potential increases in collisions and increases in noise from the port expansion will have a negligible impact on marine wildlife, including the Southern Resident Killer Whale.
  • That information from both US and Canadian SRKW recovery strategy processes be considered in order to effectively estimate the short and long-term impacts on this species of the port expansion.
  • That you consider the creation of an independent and more comprehensive review of how the port, including its maintenance and the ships that it will bring to our shores, will affect the marine life of Roberts Bank and Georgia Strait.

Thank you for considering our comments.


Christianne Wilhelmson
Program Coordinator, Georgia Strait Alliance

McDonald, Mark A., John A. Hildebrand, and Sean M. Wiggins. Increases in deep ocean ambient noise in the Northeast Pacific west of San Nicolas Island, California. J. Acoust. Soc. Am. 120, 711 (2006) 

Cc John Cummins, MP Delta-Richmond East
     Honourable Stephen Harper, Prime Minister


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