area i crab fisherman association · 2016-10-28 · groups will adequately assess the impact on...

Area I Crab Fisherman Association

October 26, 2016

Debra Myles Review Panel Manager- Roberts Bank Terminal2 Project Canadian Environmental Assessment Agency 160 Elgin Street, 22"d Floor Ottawa, On KIAOH3

Sent by email to [email protected] and [email protected]

Subject: Area I Crab Fisherman Association's comments to the Review Panel on the Sufficiency and Technical Merit of the Environmental Impact Statement and Marine Shipping Addendum for the Roberts Bank Terminal 2 Project (Reference Number 80054).

Dear Ms. Myles:

The Area I Crab Fisherman Association is participating in the environmental assessment of the Vancouver Fraser Port Authority's (the Proponent) proposed Roberts Bank Terminal 2 project and represents the views and concerns of not only the commercial crab harvesters who operate in the Roberts Bank area to earn their living, but also the commercial crab harvesters all along the BC coast who are concerned with the degradation of crab habitat and stock levels and the loss of commercial crab fishing grounds. A project of this magnitude will send an adverse ripple effect throughout the entire BC coast commercial crab fishery.

Please find attached our more specific comments on the sufficiency and technical merit using the template provided by the RBT2 Panel.

If you have any questions or concerns regarding this letter, please contact the undersigned.

Area I Crab Fisherman Association Justin Taylor, Director Email:

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Proposed Information Requests on the Sufficiency and Technical Merit of the Environmental Assessment

Participant: Justin Taylor October 26, 2016

Organization (if applicable): Area I Crab Fisherman Association

General Comments:

In Area I, commercial crab harvesting activity occurs every day from June 15 to November 30 each year.

Department of Fisheries and Oceans Canada (DFO) sub-area 29-6 and 29-7 (the location of the proposed RBT2) are two of the most productive

areas of harvest in Area I. (Supported by Hemmera June 2014 report titled RBT2- Dungeness Crab Productivity)

Area I fishers trust that Vancouver Fraser Port Authority (the Proponent), Hemmera, DFO, First Nations and other environmental and science

groups will adequately assess the impact on crab biology, habitat and environment. The proposed RBT2 structure will disrupt the natural tidal

flow on and off of Roberts Bank. It is crucial that the long term impact on crab habitat (i.e. vegetation, refuge and nursery areas, food sources,

etc ... ) and crab migration routes of this tidal disruption is extensively analyzed.

The existing activities of the Roberts Bank Terminals have resulted in a commercial crab fishing area closure that was implemented in 2009.

That closure has had a very detrimental effect on commercial crab fishing activity and harvest levels within sub-area 29-6 and 29-7. In 2010

there were 51 commercial boats fishing in Area I. After 2 rounds of area reselection, only 21 boats remain. Loss of fishing area has been a

major contributing factor to this trend.

The RBT2 proposed expansion of the area closed to commercial crab harvesting will result in a further displacement of commercial crab

harvesting and will force fisherman into other crowded areas within Area I and eventually into other adjacent commercial crab license areas

that are already oversubscribed. Therefore, there is a coast-wide effect on other crab fishing areas of fishing area lost in Area I.

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The Proponent implies in the "Roberts Bank Terminal 2 Marine Shipping Supplemental Report" to the "Roberts Bank Terminal 2 Environmental Impact Statement" that there is no way to measure the potential consequential effects on harvest and associated revenues of commercial fishing and seafood enterprises of an expanded navigational closure, and therefore the impact is considered to be negligible. Area I fishers strongly disagree.

Historical Electronic Monitoring (EM) data is available from DFO that provides detailed information on the actual commercial crab trap hauls

and vessel movements in an around the Delta port area both prior to and subsequent to the existing Deltaport commercial crab fishing

navigational closure. This specific data on fishing activity can be analyzed in conjunction with Logbook and Fish Slip data on harvest results in

terms of landings and revenues in and around Area 29-6 and 29-7. That "measureable" data "from existing conditions" needs to be analyzed by

the Proponent and will undoubtedly provide proof of the detrimental impact the existing Delta port commercial fishing closure has had on

commercial crab fishing and harvesting. That analysis needs to be used to extrapolate and predict the significant negative impact on

commercial crab harvest levels resulting from the proposed expansion of the navigational closure related to RBT2.

The Proponent is requested to analyze the available DFO Electronic Monitoring (EM) Data in conjunction with the DFO Logbook Data and Fish Slip Data to determine the specific level of impact the existing Roberts Bank Navigational Closure has had on commercial crab fishing activities, harvests and revenues. When analyzed together, that data will prove that loss of fishing grounds and restricted harvest activity correlates with less harvests and revenues of the commercial crab vessels fishing in the area. This information needs to be considered as part of all sources of "measurable" data and "all lines of evidence".

The Proponent is requested to analyze the available DFO Electronic Monitoring (EM) Data in conjunction with the DFO Logbook Data and Fish Slip Data to quantifiably estimate and forecast the specific level of impact the proposed expansion of the Roberts Bank Navigational Closure (including the RBT2 structure footprint) will have on commercial crab fish ing activities, harvests and revenues. This information needs to be considered as part of all sources of "measurable" data and "all lines of evidence".

Without this analysis, the Proponent cannot conclude that the impact of an expanded closure would be negligible and insignificant on the profitabi lity of commercial crab fishing activities in the area.

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Based on the actual everyday fishing experiences of commercial crab harvesters in the area, the RBT2 footprint and the proposed expansion

of area closed to commercial crab harvesting will result in significant adverse residual and incremental cumulative effects to commercial

crab harvesting revenues. The Area I Crab Fisherman Association has contracted Pacific Coast Fishery Services Inc. to analyze the

aforementioned Electronic Monitoring and Logbook data provided from the DFO. This analysis strongly supports that the existing Delta port

closure's loss of commercial crab fishing area in sub-area 29-6 since 2009 has resulted in significant adverse residual and incremental

cumulative effects to commercial crab harvesting revenues. Please see attached analysis.

This proposed analysis will help to address some of the more specific information requests noted below:


Information Source (section or page# of E/5, Marine Proposed Information Request Rationale

Shipping Addendum, Responses to Information Requirements, etc.)

1) EJS Page 21-18 1) What percentage of the decline in commercial crab harvest levels in Historical Electronic Monitoring sub-area 29-6 subsequent to 2009 is attributable to the Deltaport, (EM) Data is available from DFO Roberts Bank commercial crab navigational closure implemented in that provides detailed information 2009?

on the actual commercial crab trap

2) EJS Pages 21-36 and 21- 2) Have all sources of data (including EM data) been analyzed together to hauls and vessel movements in and 38 determine and conclude that as a result ofRBT2 construction and around the Deltaport area both prior

operation "Change in availability of harvest eligible Dungeness crab to and subsequent to the existing would be negligible. Negligible effects on access to crab harvesting Deltaport commercial crab fishing areas, harvesting equipment, and crab vessel navigation"? How is the created "moderate adverse effect" deemed to be "negligible" navigational closure. This specific in quantifiable terms from the perspective of Area I commercial crab data on fishing activity can be fishermen? analyzed in conjunction with DFO

Logbook and Fish Slip data on harvest results, in terms of landings and revenues in and around Area 29-6 and 29-7, both prior to and

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Information Source (section or page# of £15, Marine Proposed Information Request Rationale


3) EIS Pages 21-40 and 21- 3) What are the "detectable" and "measurable" "potential effects of the subsequent to the first Deltaport 41 Project on access matters in the construction and operation phase" in commercial crab fishing closure.

terms of crab "landings and revenues" resulting from "potential interactions of crab harvesting vessels and equipment and construction-

Analysis of this data will prove that associated vessels and Project-associated container ships and accompanying tugs" inside "of the existing and proposed closure loss of commercial fishing grounds areas"? and restricted commercial harvest

activity in sub-area 29-6 correlates

4) Does the lack of"measurable adverse effect on ongoing male crab with significantly less harvests and

4) EIS Pages 21-41 and 21- revenues of the commercial crab 42 productivity at the management stock level in the Roberts Bank area"

vessels fishing in the area. That necessarily correlate with the lack of"measureable change in availability of crab that would affect the level of the commercial harvest "measureable" data "from existing in the LAA'' given the potential loss of commercial fishing grounds? conditions" will undoubtedly Based on commercial fishers' experiences, a loss of commercial crab support the detrimental impact the harvest area always equates to loss of available eligible male crabs for commercial harvest, regardless of ongoing male crab productivity. existing Deltaport commercial

fishing closure has had on

5) EIS Page 21-43 5) Have "alii ines of evidence" been considered to determine that "a commercial crab harvest levels and negligible effect is expected for the marine fish harvesting sub- could easily be used to extrapolate component" resulting from "area displacement, access matters, and and predict the significant negative resource availability"?

(non-negligible) impact on any

6) ElS Page 21-48 6) Data held by DFO needs to be analyzed to determine more conclusively further and expanded closures.

the percentage of commercially harvestable crab that "would migrate from the area of the proposed expansion to the baited commercial traps The Proponent has not yet that would have been placed outside of the proposed navigational analyzed the available DFO closure expansion". This can be achieved by analyzing available data in

Electronic Monitoring (EM) Data in relation to the existing navigational closure and its impact on commercial harvest results. conjunction with the DFO Logbook

Data and Fish Slip Data to determine the specific level of

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Information Source (section or page# of E/5, Marine

Shipping Addendum, Responses to Proposed Information Request Rationale

Information Requirements, etc.)

7) EIS Page 21-48 7) What data and statistics have been gathered and analyzed to determine impact the existing and proposed the level of effect on reduced commercial harvest results and revenues expanded Roberts Bank as a result of the permitted and "continued crab harvesting for FSC or Navigational Closure has had and Aboriginal domestic purposes in the current navigational closure and in a proposed navigational closure expansion"? will have on commercial crab This supports the fact that the loss of commercial crab harvest area fishing activities, harvests and always equates to loss of available eligible male crabs for commercial revenues. Analyzing this harvest, regardless of ongoing male crab productivity. measurable data is very relevant and

should be considered as part of "all lines of evidence."

8) EJS Pages 21-48 and 21-8) In 2006, DFO required all commercial crab fishing vessels in Area I to

be Electronically Monitored (EM). This EM data on historical Without this analysis, the Proponent 49 and 21-54 and 21-55 commercial crab fishing activity in the LAA is quantifiable and needs to cannot conclude that the impact of

be analyzed and considered before concluding with confidence that an expanded closure would be there will be a "not significant" residual effect on commercial crab

harvests and revenues associated with displaced commercial crab negligible and insignificant on the harvesting activity. profitability of commercial crab

fishing activities in the area.

Based on the actual everyday fishing experiences of commercial crab harvesters in the area, the RBT2 footprint and the proposed expansion of area closed to commercial crab harvesting will result in significant adverse residual and incremental cumulative effects to commercial crab harvesting revenues.

Review Pane./ Rank


Information Source (section or page# of EIS, Marine Proposed Information Request Rationale


The Area I Crab Fisherman Association has contracted Pacific Coast Fishery Services Inc. to analyze the aforementioned Electronic Monitoring and Logbook data provided from the DFO. This analysis strongly supports that the existing Deltaport closure's loss of commercial crab fishing area in sub-area 29-6 since 2009 has resulted in significant adverse residual and incremental cumulative effects to commercial crab harvesting revenues. Please see attached analysis.

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ShowsthecorrelaAonbetweentheaveragecatchpervesselinArea29-6andtheamountoffishingvesselsacAvelyfishinginArea29-6.AKer2009,therewasadrasAcdeclineinaveragecatchpervessel.In2015,13vesselswerecatchingthesametotalaveragecatchas28vesselsin2010.Thisdemonstrateslessabundanceinthearea,whichhaseffecAvelydrivenmorevesselsaway..

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area i crab fisherman association · 2016-10-28 · groups will adequately assess the impact on...

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