December 15, 2006
Jody Shimkus email: email@example.com
Project Assessment Director
Environmental Assessment Office
Province of British Columbia
PO Box 9426, Stn Prov Govt.
Victoria, BC V8W 9V1
Dear Jody Shimkus:
Re: Draft Terms of Reference: Proposed South Fraser Perimeter Road
On behalf of the Fraser Valley Conservation Coalition ("FVCCC"), a citizens
environmental group in the south Fraser Valley with 350 members from
Richmond to Chilliwack, the following comments are made with respect to the
proposed South Fraser Perimeter Road.
Rationale for the Gateway Program, including the South Fraser Perimeter
Road, is predicated on economic benefit that will be derived from dramatic
expansion of roadways to move goods and people.
The FVCC assert that, to the contrary, in its current proposed form, the
agricultural, community, economic and environmental costs of the Gateway
Program and the South Fraser Perimeter Road will dramatically exceed any
benefits to this region.
Boundary Bay is internationally recognized as an ecologically distinct
region. Plans to accommodate dramatic increases of trucking in Boundary Bay,
represented in the Delta Port Third Berth and the Gateway Program (and
specifically the twinning of the Highway #1 and Port Mann Bridge and South
Fraser Perimeter Road), threaten ecological sustainability and quality of
human life in this region.
The Environmental Assessment estimates that agricultural impact is
restricted to 90 hectares (222 acres) of Delta farmland that will be
directly affected by the SFPR and right-of-way and an additional 15 hectares
(37 acres) of agricultural land will be loss to production as a result of
severance or isolation and another 20 ha would be reduced to lower value
The Fraser Valley Conservation Coalition propose that, although not
recognized by the EA, the SFPR will also negatively impact agriculture in
Surrey (Port Kells), Barnston Island and throughout the Fraser Valley.
The Fraser Valley Conservation Coalition concurs with the conclusions of the
Corporation of Delta (November 23, 2006, South Fraser Perimeter Road
Environmental Assessment, Summary of Staff and Advisory Committee Comments):
"Staff believes that the severance and isolation impacts are understated in
the EA application since the analysis assumes that fields and parcels that
are severed or isolated will be consolidated with neighbouring parcels
regardless of ownership, and hence are not accounted for as losses to
agricultural land or production."
The reality that British Columbia already has the most parcelized farmland
in Canada (Planning for Agriculture, Agricultural Land Commission, 1998)
challenges this assumption. In fact, the thirty year history of BC's
Agricultural Land Reserve (ALR) shows that subdivision or severance of
farmland often precedes exclusion from the ALR and ultimate development of
Only five percent of British Columbia's land base is suitable to
agriculture. More than half of that, and the most productive soils - are in
Fraser River estuary where rich alluvial soil has formed the backbone of
social and economic life. Currently this farmland is producing only 50% of
the food needed to support British Columbia's current population. Planners
and agrologists of the Agricultural Land Reserve Protection and Enhancement
Committee (ALR-PEC) calculate that British Columbia will require on million
additional acres of farmland to support population growth projections for
the next 20 years, but there is no more farmland to be had.
In October 2006, the Wall Street Journal announced that the USA, the world's
largest food supplier, had become a net importer of foods. While partially
due to changing global food production trends, this development was in part
due to the US having paved its own farmland at a rate of 2 acres/minute
since 1970 (total loss of 38 million acres), while its population grew by 88
million during the same period.
British Columbia's food security faces several other foes: ground level
ozone, global warming, intense pressure to convert the land to residential
and industrial development and competition for biofuels crops in the age of
peak oil. The FVCC's is particularly concerned that the Environmental
Assessment does not sufficiently anticipate agricultural losses resulting
from increased vehicle emissions from SFPR (see Air Quality/Health).
SmartGrowth America points out that loss of farmland poses economic problems
beyond lost farmgate receipts or lost food security. "The loss of farmland
and open space often causes unexpected economic challenges for rural
communities. In these communities, farmland, forests, ranch land and open
space tend to be the economic drivers that attract businesses, residents and
As an organization that spent considerable effort in the past year to keep
Barnston Island within the protection of the ALR, FVCC is extremely
concerned that placement of a commercial truck highway at its doorstep will
subject the "jewel on the Fraser River" to increased pressure to
The FVCC is concerned that the Environmental Assessment does not accurately
address agricultural losses from increased vehicle emissions. More than half
of BC's $2.4 billion farm gate receipts
(http://www.agf.gov.bc.ca/stats/faststats/brochure2005.pdf) are produced in
the Fraser Valley, where air pollution currently costs up to 25% of crop
yields. Elevated pollution levels commonly associated with highways
carrying 25,000 to 40,000 trucks per day are certain to contribute to
elevated levels of ground level ozone and rob this region of additional
FVCC is concerned that net agricultural losses from SFPR will also impact
important wildfowl populations. Located on the Pacific Flyway, Boundary Bay
is visited by an estimated 1.4 million migrating wildfowl each year. There
is no greater threat to survival for wildfowl than loss of farmland for
feeding and nesting, and agricultural losses from SFPR will significantly
impact these populations, some of which are already in decline.
The Fraser Valley Conservation Coalition asserts that SFPR will produce
significant agricultural losses at a time when no net agricultural loss is
The Fraser Valley Conservation Coalition's concerns about the impacts of
this project on elevated air pollution levels begin at plans to expand
DeltaPort to increase importation of goods to be moved by SFPR. The National
Research Defence Council Harboring Pollution
(http://www.nrdc.org/air/pollution/ports/execsum.asp) documents that "These
impacts range from increased risk of illness, such as respiratory disease or
cancer, to increases in regional smog, degratdationof water quality, and the
blight of local communities and public lands."
FVCC believes that the EAO does not address concerns raised by an
international body of science (see: Key Studies on air pollution and health
effects near high-traffic areas compiled by the Environmental Law and Policy
Centre and Sierra Club US
These concerns are serious for all of the impacted communities, but are of
greatest consequence for residents of the neighbourhoods of East Ladner,
Sunbury, Kwantlen Heights and Bridgeview which will be completely encircled
by highways if South Fraser Perimeter Road is constructed as currently
The EAO does not take into account the long distance impacts of elevated air
pollution from SFPR. Wind patterns in the Fraser Valley (in particular
sea-to-shore breezes) are such that pollution produced in the urban centres
of the GVRD are carried into the rural communities of the Fraser Valley
Regional District (Ozone Air Quality 2005
experience corresponding elevated incidents of eye and respiratory ailments
and crop damage.
Given that the Fraser Health Authority Air Quality Report predicts,
"...reasonable range of estimates is that between 15 and 150 deaths per year
in the Lower Mainland may be attributable to air pollution... About as many
deaths in the Lower Mainland may be attributable to air pollution as occur
from HIV, accidental falls or traffic accidents," FVCC maintains that there
can be no improvements to quality of life from increased economic activity
that justifies this level of risk to human life from increased air pollution
that SFPR will represent.
The FVCC supports without reservation its fellow "Gateway 25" member, the
Burns Bog Conservation Society, in the latter's stated (letter dated
December 12, 2006) concerns with respect to the potential impacts of SFPR on
Burns Bog and its sensitive resident wildlife populations.
Because of their unique migratory path, there has been a longstanding
question about whether the small population of sandhill cranes that return
to Burns Bog and Pitt Polder are each spring are a subspecies in urgent need
of protection. Given the dramatically small number (less than 20 birds) and
their known hypersensitivity to nesting disturbance and pollution, the
impact of these birds' Burns Bog home is of particular concern to FVCC.
The FVCC is additionally concerned that the SFPR represents a violation of
the conservation covenant placed on Burns Bog on March 24, 2004 by the
Government of Canada, Province of BC, Greater Vancouver Regional District
and Corporation of Delta.
FVCC supports without reiterating concerns expressed by fellow Gateway 25
groups: Against Port Expansion (APE), Boundary Bay Conservation Committee
(BBCC) and Friends of Semiahmoo Bay, but add:
Boundary Bay is internationally recognized for its distinct, rich ecology
made up of seashore, intertidal mud flats, estuaries, salt marshes, farmland
and urban areas: all of which provide for this region's rich biodiversity.
The SFPR will have an impact on far more vulnerable populations than the
taxpayers of this region. FVCC is concerned that the EAO does not recognize
the serious impacts of SFPR on our endangered Orca populations, the last
Canadian nesting population of Barn Owls, three known Great Blue Heron
colonies and more than 333 species of birds (16 species of gulls, 22 of
raptors), amphibians that inhabit the wetlands throughout the route (but
particularly in Fraser Heights and Royal Heights).
SFPR, as currently proposed, will significantly diminish quality of life for
residents in the communities of Tsawwassen, East Ladner, Sunbury,
Annieville, Kwantlen Heights, Bridgeview, Birdland, Royal Heights, Fraser
Heights, Port Kells and Barnston Island.
Many of FVCC's fellow "Gateway 25" members will provide detailed responses
specific to their neighbourhoods., but the FVCC is concerned that the EAO
has demonstrated adequate understanding of the extent of losses due to
community disruption (expropriation, severance of neighbourhoods), loss of
heritage, loss of safety from increased truck traffic, decreased livability
due to elevated levels of pollution, loss of the aesthetic value from losses
of farmland and wildlife habitat/populations, losses of tourism, flooding
In short, hundreds of homes will be expropriated, other long time residents
will move to escape the elevated noise and air pollution levels causing
severe disruption to the social fabric of many long established
For some residents of Bridgeview, expropriation payments and construction
migitation provides no relief. A low income neighbourhood, Bridgeview has
homes valued at $75,000, but residents bought out on expropriation will be
unable to find replacement housing for that amount of money.
Additionally, it must be pointed out that many of the residents most
directly impacted by SFPR are seniors who have limited economic and social
FVCC point to community impacts of transportation megaprojects, like SFPR,
as described by the US Department of Transportation's Great Expectations
"...transportation megaprojects disrupt the lives of individual citizens
everyday - temporarily and permanently - and encompass travel routes, noise,
debris, congestion, safety, property issues, business operations, public
transit, the environment and more..."
FVCC are concerned that the EAO does not accurately recognize the levels or
permanence of disruption this project will impose on affected communities.
The Application TOR describe the cost of SFPR at $800-$900 million. The
Fraser Valley Conservation Coalition are not satisfied that this cost
(published December 2004) provides for significant increases in energy
prices, increased labour costs (particularly in light of a severe labour
shortage) and increased costs of construction materials (British Columbia's
Construction Sector, Budget & Fiscal Plan 2006/2007-2008/09, BC Ministry of
The FVCC are concerned that at $800 - $900 million for 40 kilometers of road
($20-22.5 million/kilometer), SFPR is a project from which Lower Mainland
taxpayers will never economically recover.
As well, the EAO does not allow for increased health costs associated with
the increased vehicle-related elevations in air pollution. A 1995 B.C.
Environment study estimated that health care costs of air pollution in the
Lower Fraser Valley alone was estimated to be $830 million in 1990 and is
projected to rise to $1.5 billion by 2005.
In the section "Community", FVCC describes changes to the social fabric of
all neighbourhoods along the SFPR. FVCC maintains that no one with the
economic means to do otherwise will want to live next to a high speed truck
highway, and is concerned that quality of life for remaining residents will
be significantly diminished, resulting in reduction of socio-economic makeup
of these communities and bringing increased social problems. The EAO does
not anticipate the significantly increased social costs that these changes
are likely to produce for the taxpayers of Delta and Surrey.
FVCC's supports without reiterating the concerns of fellow "Gateway 25"
member, the Fraser River Coalition about the impacts of this project on the
largest salmon-producing river in the world. FVCC adds that the EAO does not
adequately recognize that the increased vehicle traffic will impact climate
change and that, in turn, will affect water levels, temperature, flow
moderation of the waters of the Fraser River. The Department of Fisheries
and Oceans has documented that Pacific salmon are sensitive to temperature
increases. The Fraser River already often reaches temperatures of 22 degrees
while the salmon are returning to spawn. An increase of only one or two
degrees and most of the returning salmon will likely die before spawning.
FVCC are concerned that the EAO does not adequately anticipate the impact
elevated vehicle-caused pollutants or increased stormwater runoff from 40
additional kilometers of impervious surface on Fraser River salmon.
Every loss to salmon is felt far up the food chain, including the endangered
raptors, bears and Pacific Orcas that rely on these fish for food.
FVCC is also concerned that the EAO does not anticipate that diminished
viability of Burns Bog will impede its ability to cool and filter the waters
of the Fraser River.
FVCC's supports without reiterating concerns fellow "Gateway 25" member
groups, and in particular, the Sunbury/Annieville Neighbourhood Association
about the loss of heritage homes and other habitats for SFPR.
FVCC is equally concerned that measures proposed to mitigate damage and
disrespect to First Nations middens and burial grounds are wholly
inadequate. Construction that prevents concrete or blacktop from being
placed directly atop these heritage sites, but nevertheless to build over
them falls far short of afford them and their survivors the reverence and
respect they are owed.
Without reiterating concerns of our fellow "Gateway 25" members, FVCC
supports Fraser Heights Community Association and Sunbury/Annieville
Neighbourhood Association in their respective concerns about geotechnical
stability of the parts of the Fraser and in particular the shoreline areas
of Delta and Surrey that have been identified as earthquake vulnerable
zones. In the last three years we have seen numerous dangerous slide
incidents on the North Shore. FVCC is additionally concerned that the
Ministry of Transportation is unable to protect residents along SFPR from
similar slide incidents during heavy rainfall. While our fellow "Gateway 25"
members will articulate concerns about the impacts of these incidents on
resident human populations, FVCC is not satisfied that EAO has addressed the
risk to resident wildlife populations along the inland and shoreline truck
route and in the Fraser River.
One of the world's great rivers, the "Mighty Fraser" is one of the most
spectacular natural features of the Fraser Valley. The FVCC suggest that to
uglify this spectacular shoreline with a high speed truck highway is to
forfeit far greater future economic benefits from tourism.
Tourism will additionally be impacted by elevated particulate from the
25,000 to 40,000 vehicles per day (VPD) expected on SFPR. Environment
Canada's Georgia Basin Ecosystem Initiative study "...predicts that just one
day of visibly bad air could result in future tourist revenue losses of
$7.45 million in the Greater Vancouver area and $1.32 million in the Fraser
FVCC is concerned that the EAO does not sufficiently anticipate the social
and economic losses that this project will have on tourism in the region.
Finally, FVCC has great concerns about the lack of due public process around
the Gateway Program as a whole and specifically the South Fraser Perimeter
Road. When the Project was announced on January 31, 2005, the Minister of
Transportation announced that there would be no public debate about whether
or not the project would be implemented. In the case of the South Fraser
Perimeter Road, impacted communities have been limited to discussion about
specific features of the route, often in an absence of hard information
about proposed routes, expected vehicle volumes, etc.
The EAO process is a case in point: 3400 pages of documents were posted on a
public web site and local citizens groups, without access to funding to hire
engineers, biologists, hydrologists and health experts to assist us in
responding, were nevertheless limited to 60 days for response.
FVCC maintains that the taxpayers of this region who will be forced to pay
the $3.5 to $7 billion for the Gateway Program, and who's region will be
dramatically altered by this program, have been denied the opportunity to
have an informed and adequate say in the proposed plan.
One of the most ecologically distinct and valuable regions of the world,
Boundary Bay should be protected from the harsh ecological, health, social
and economic costs of the kind of massive highway expansion represented by
the Gateway Plan and specifically the South Fraser Perimeter Road.
Further, FVCC maintains that to proceed with the SFPR in light of current
scientific knowledge about the impacts to human and environmental health
that increased vehicle emissions will produce is to knowingly endanger human
and wildlife populations throughout the region.
Fraser Valley Conservation Coalition