From:To: Panel RBT2 / Commission RBT2 (CEAA/ACEE)Cc:Subject: Submission to the Roberts Bank reviewDate: October 25, 2016 5:32:59 PMAttachments: PastedGraphic-1.tiff

ATT65806.htmBC Nature Assessment of EIS Roberts Bank Terminal 2 Project FINAL.pdfATT65807.htm

Panel Manager Debra MylesDear Debra

Attached is a submission from our special representative as BC Nature's submission on the Roberts Bank Terminal 2 Project.Please note this report has been completed under my direction and has my full support.It should be submitted to the panel as a BC Nature submission.BC Nature (Federation of BC Naturalists) is a federation of 53 naturalist clubs and societies across BC with over 6,000 members.

Sincerely,Alan Burger

Alan E. Burger, PhDPresident: BC Nature(Federation of BC Naturalists)

Alan Burger

Emsley Roger; Davison Betty

Assessment of the Environmental Impact Statement of the Roberts Bank Terminal 2 Project

Patricia Baird, Ph.D.

Kahiltna Research Group and Simon Fraser University

25 October 2016

i

Report to BC Nature on the Completeness and Accuracy of the Environmental Impact Statement of the

Roberts Bank Terminal 2 Project

Patricia Baird, Ph.D.

Kahiltna Research Group

and

Centre for Wildlife Ecology

Simon Fraser University

Burnaby, B.C.

pab7@sfu.ca

and

BC Nature (Federation of BC Naturalists)

c/o Heritage Centre

1620 Mount Seymour Road

North Vancouver, BC

V7G 2R9

Email : manager@bcnature.ca

Phone: 604-985 3057

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LAYOUT OF THE DOCUMENT

This Report is divided into 1) a Commentary on Vancouver Fraser Port Authority’s (VFPA)

Environmental Impact Statement (EIS) for construction of a second terminal at Roberts Bank (RBT2), and

2) an Appendix with expanded data supporting all statements in the Commentary.

The Commentary summarizes the following:

1) environmental values at Roberts Bank - the importance of this ecosystem, 2) errors and omissions

in the EIS, 3) how conditions at Roberts Bank might change due to construction of RBT2, 4) an analysis of

the models used in the EIS, 5) risks, 6) a summary of Best Practices in any environmental analysis and

how VFPA does not employ them, and 7) issues around choosing an alternate site.

The Appendix has two main parts:

1) the environmental issues in siting this port at Roberts Bank, and 2) the economic and

transportation issues surrounding the geographic placement of a world-class Canadian Pacific gateway

port at Roberts Bank . The Appendix on environmental issues is an in-depth analysis of the food web at

Roberts Bank, with notations of the critical elements of the food web that would be altered if RBT2 was

built, and how this alteration would have a substantially negative effect on the entire food web that

depends on Roberts Bank. The Appendix on economic and transportation issues contains excerpts of

data from other reports and is mainly a summary of many other comments about this, and is therefore

short.

COMMENTARY ON VANCOUVER FRASER PORT AUTHORITY’S EIS-

THE ROBERTS BANK ECOSYSTEM AND FOOD WEB AND THE EFFECT ON IT

BY CONSTRUCTION OF RBT2

EXECUTIVE SUMMARY

The proposal by Vancouver Fraser Port Authority (VFPA) to build a second terminal at Roberts Bank

(RBT2) is ill-advised from an environmental viewpoint.

There is not sufficient, valid information in VFPA’s EIS to assure that the Project would not

cause significant adverse environmental effects on Roberts Bank and the entire marine food

web there.

In contrast, there is a large body of literature showing that construction of Roberts Bank

Terminal 2 (RBT2) will have severe effects on the marine food web there.

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The predicted effectiveness of the proposed mitigation measures and follow-up programs are

absolutely inappropriate. No mitigation is possible if Roberts Bank is altered in any possible

way because there is no other site in the Greater Vancouver area/ Lower Mainland that is at all

comparable to Roberts Bank in its suite of abiotic factors and the resulting diversity and

abundance of flora and fauna.

Roberts Bank is unique among all of the tidal mudflats of the Fraser River delta because of the

combination of abiotic factors present which allow a rich foodweb based on marine biofilm to

exist in the mudflats (phytoplankton, e.g. diatoms, are the most important component of this

particular marine biofilm)

Marine biofilm assemblages at Roberts Bank are different in abundance, accessibility, and

species assemblies from others in the Lower Mainland because of the suite of abiotic factors

only present at Roberts Bank.

New research has discovered that the importance of this particular assemblage of marine

biofilm to the marine food web at Roberts Bank is the long-chained essential fatty acids (LCEFA)

that they produce. This is why Roberts Bank is such a critical a mudflat/tidal wetland, different

from all of the other tidal wetlands in the Lower Mainland.

Therefore, of all of the sites considered, the choice of expanding VFPA into the Roberts Bank

area was ecologically the worst option to choose out of all the sites, based on the vital

importance of the Roberts Bank ecosystem for the globally-important flora and fauna that use

the area throughout the year.

An intensive biological assessment of each of the five possible alternative sites in the Lower

Mainland or of Prince Rupert was not conducted by VFPA so there is no comparable set of

studies to compare in an in-depth analysis.

The Roberts Bank ecosystem is one of the most important tidal flats on the North American

west coast for marine flora and fauna, of which Fraser River sockeye salmon (Oncorhynchus

nerka) and shorebirds are some of the most familiar; and any alteration of the current

ecosystem there would have severe consequences and repercussions throughout the entire

food web - not just at the Fraser River Delta - if RBT2 was built

The Fraser River Delta, the largest estuary on the Pacific coast of North America (21,703

hectares), supports the highest concentration of migratory birds in Canada - up to 1.4 million

during peak migration

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A globally significant portion of the world’s western sandpiper population Calidris mauri (>21%

and up to 64% in some years), as well as the entire population of the Pacific subspecies of

dunlin, Calidris alpina pacifica, which breed in Alaska, have their last major stop at Roberts Bank

during northward spring migration

Because of the abundance and diversity of migrants through Roberts Bank and nowhere else in

the greater Fraser River estuary system, and because of the discovery of an abundance of

marine diatoms there which produce LCEFA, we assume that this assemblage of diatoms and

LCEFA are not replicated anywhere else in the Lower Mainland.

Therefore, Roberts Bank stands out as a unique ecosystem, and the conditions there cannot be

replicated anywhere else in the Lower Mainland even if mitigation was attempted. The water

currents, salinity, temperatures, nutrients, turbidity, and many other abiotic factors present at

Roberts Bank only exist there because of the free outflow of the Fraser River and the

concomitant free circulation of seawater in the particular area.

Consequently, the populations of heterotrophs dependent on the unique marine biofilm there

will be severely impacted if numbers and species of marine diatoms disappear from Roberts

Bank.

VFPA did not discuss the importance of the LCEFA that marine biofilm produce and how this

nutrient is critical for the entire food web at Roberts Bank.

It appears that VFPA did not review the pertinent literature which shows how marine biofilm in

tidal wetlands/mudflats needs specific abiotic factors in order to bloom and produce LCEFA.

Often VFPA did not sample at the correct time or place to get the information that they needed

on marine biofilm, and in so doing, misinterpreted how the ecosystem works at Roberts Bank.

VFPA did not address the negative impacts of RBT2 construction on the entire food web at

Roberts Bank – from zooplankton to migratory birds and Fraser River salmon, based on the

importance of marine biofilm to these groups.

VFPA did not properly address cumulative impacts on Fraser River salmon and other fish, or

impacts along the Pacific Flyway for migrating shorebirds, of reproducing waterbirds, or other

migrant or overwintering waterbirds.

VFPA inappropriately combined data on marine and freshwater biofilm and therefore

misinterpreted impacts of construction of RBT2.

VFPA did not compare other similar ecosystems to see how removing crucial wetlands can lead

to a collapse of an entire flyway.

v

VFPA did not consider wetland conservation and management in the context of a flyway.

VFPA used two inappropriate ecological models that tell us little, if anything, about how the

ecosystem at Roberts Bank works.

VFPA ignored the Precautionary Principle which is commonly used in management decisions

that could negatively affect an ecosystem.

VFPA either ignored or did not consider important the many international treaties that would be

affected and perhaps violated by construction of RBT2.

VFPA did not update Canada’s current and projected trading needs given the expansion and

upgrades at other West Coast ports in BC such as that at Prince Rupert, which will cancel any

need for port expansion at Roberts Bank.

The Commentary of this report summarizes all of the above points, and Appendices I and II support

statements in the Commentary in great detail.

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TABLE OF CONTENTS

LAYOUT OF THE DOCUMENT ............................................................................................................... ii

COMMENTARY ON VANCOUVER FRASER PORT AUTHORITY’S EIS- THE ROBERTS BANK ECOSYSTEM

AND FOOD WEB AND THE EFFECT ON IT BY CONSTRUCTION OF RBT2 ................................................. ii

EXECUTIVE SUMMARY ......................................................................................................................... ii

TABLE OF CONTENTS .......................................................................................................................... vi

1. INTRODUCTION ................................................................................................................................ 1

2. ENVIRONMENTAL VALUES AT ROBERTS BANK - THE IMPORTANCE OF THE ROBERTS BANK

ECOSYSTEM ............................................................................................................................................. 4

2.1 Summary of Environmental Values…………………………………………………………………………………………………4

2.2 Uniqueness of Roberts Bank ................................................................................................................ 5

2.3 Shorebirds in Tidal Flats ....................................................................................................................... 7

2.3.1 Shorebirds at Roberts Bank ...................................................................................................... 7

2.3.2 Wetlands - links in a chain - Habitat ......................................................................................... 9

2.3.3 Conservation Planning .............................................................................................................. 9

2.3.3 Bottlenecks ............................................................................................................................. 10

2.3.4 Other Flyways in North America ............................................................................................. 11

2.3.5 Other Similar Chains of Wetlands and Tidal Flats ................................................................... 11

2.4 Biofilm and the Marine Food Web ..................................................................................................... 13

2.4.1 Biofilm - recap ......................................................................................................................... 13

2.4.2 Zooplankton ........................................................................................................................... 13

2.4.3 Other Invertebrates and Fish ................................................................................................. 14

2.4.4 Selective uptake of LCEFA ....................................................................................................... 15

3. ERRORS AND OMISSIONS IN PORT METRO VANCOUVER’S ASSESSMENT OF RBT2 AS SUMMARIZED

IN THE EIS AND HOW CONDITIONS THERE MIGHT CHANGE DUE TO CONSTRUCTION ........................ 16

3.1. Sampling Issues ................................................................................................................................. 16

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3.1.1 Biofilm Recap……………………………………………………………………………………………………………………..16

3.1.2 Timing ..................................................................................................................................... 17

3.1.3 Other Sampling Issues ............................................................................................................ 17

3.2 Assumption Issues .............................................................................................................................. 17

3.2.1 VFPA confuses freshwater with marine biofilm and thus they mis-state the effect of a

decrease in marine biofilm on shorebird populations and on salmon ............................................. 17

3.2.2 Effects of different abiotic factors on phytoplankton ............................................................ 18

3.2.3 Effect of changes in abiotic factors on omega-three fatty acids ............................................ 18

3.3 Flow of Nutrients at Freshet- Misunderstanding by VFPA ................................................................ 19

3.4 Salinity and Biofilm – Misinterpretation by VFPA .............................................................................. 20

3.4.1 Changes in salinity .................................................................................................................. 20

3.4.2 Inadequate Knowledge on How the Entire Ecosystem at Roberts Bank will be affected - The

Precautionary Principle ..................................................................................................................... 21

3.5 Energy vs. Productivity – the Quality of Nutrients is More Important than the Quantity ................ 22

3.5.1 Chlorophyll α is the Wrong Parameter to Measure ............................................................... 22

3.5.2 Quality of the Food Web Depends on the Amount of Omega-3 Fatty Acids Present in Marine

Biofilm ............................................................................................................................................... 22

3.5.3 Use of Chlorphyll α as Proxy for Importance of Biofilm in EwE (Ecopath with Ecoism) Model

Displays Lack of Understanding of the Ecosystem ............................................................................ 23

3.6 Probable Effects of the Construction of Roberts Bank Terminal 2 on Marine Life currently living in

Roberts Bank and Issues with VFPA’s Interpretation of the EIS .............................................................. 24

3.6.1 Dependence of Marine Life on the Current Roberts Bank Food Web and the Estimated Losses24

3.6.2 Effects on the Food Web State by VFPA’s EIS ......................................................................... 24

3.6.3 VFPA Misinterprets Effect of Construction of RBT2 on the Food Web .................................. 24

3.6.4 Cascading Effects on the Food Web at Roberts Bank, including Salmon ............................... 25

3.6.5 Inappropriate Shorebird Opportunity Model ......................................................................... 26

3.6.6 VFPA ignores the Significance of Omega-three Fatty Acids in the Food Web at Roberts Bank27

viii

3.7 Data Gaps ........................................................................................................................................... 28

4. AN ANALYSIS OF THE MODELS USED IN THE EIS- THE UBC “ECOPATH WITH ECOSIM”(EwE) MODEL

.............................................................................................................................................................. 29

4.1 Ecosystem Modelling ......................................................................................................................... 29

4.1.1 Ecopath Model ........................................................................................................................ 29

4.1.2 Ecoism Model ......................................................................................................................... 30

4.1.3 Summary of EwE ..................................................................................................................... 30

4.2 Shorebird Foraging Model ................................................................................................................. 31

5. RISKS .............................................................................................................................................. 31

5.1 Unknowns – Fatty Acids and Heterotrophs ....................................................................................... 31

5.2 Unknowns – Shorebirds and the Food Web ...................................................................................... 32

5.3 Unknowns-The Pacific Flyway ............................................................................................................ 32

5.4 Summary of Risk................................................................................................................................. 33

6. A SUMMARY OF BEST PRACTICES IN ANY ENVIRONMENTAL ANALYSIS AND HOW VFPA DOES NOT

EMPLOY THEM ...................................................................................................................................... 33

6.1 A Logical Approach To Risks And Consequences ............................................................................. 33

7. CHOOSING AN ALTERNATE SITE .................................................................................................... 35

8. CONCLUSIONS - FINAL STATEMENT............................................................................................... 38

APPENDIX 1 ........................................................................................................................................ 40

SUMMARY MARINE FOOD WEB ROBERTS BANK .............................................................................. 40

REVIEW AND SYNOPSIS OF TIDAL FLAT ECOSYSTEMS EMPHASIZING THE ROBERTS BANK ECOSYSTEM,

WITH COMMENTARY ON THE VFPA’S EIS FOR ROBERTS BANK AND THE CONSTRUCTION OF RBT2 ..... 40

A1. Food web productivity ....................................................................................................................... 40

A1.1 How Diatoms become available for the marine food web in the spring. ............................... 41

A1.2 Importance of Diatoms and their Fatty Acids in the Roberts Bank Ecosystem ....................... 42

A1.3 Trophic Transfer ...................................................................................................................... 44

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A2. Diatoms-Ecological Niches- with reference to possible changes in abiotic factors at Roberts Bank 45

A2.1 Temperature ............................................................................................................................ 45

A2.2 Salinity. .................................................................................................................................... 46

A2.3 Acidity ..................................................................................................................................... 47

A2.4 Other abiotic factors ................................................................................................................ 47

A2.5 Summary .................................................................................................................................. 48

A3. The Phytoplankton Community and Fatty Acids ............................................................................... 48

A3.1 Amounts of LCEFA in phytoplankton species. ......................................................................... 49

A3.2 Marine vs. Freshwater Species of Phytoplankton. ................................................................. 50

A3.3 Seasonal Changes in Fatty Acid Content. ............................................................................... 51

A4. How diatoms transfer LCEFA up the food web ................................................................................. 51

A4.1 Zooplankton ............................................................................................................................ 51

A4.2 Other Invertebrates and Fish .................................................................................................. 52

A5. Selective uptake and biomagnifications of LCEFA and Transfer between Trophic Levels ............... 53

A6. Shorebirds in Tidal Flats with Emphasis on the Roberts Bank Ecosystem ......................................... 54

A7. The Pacific & Atlantic Flyways –Relationship between Shorebird Migration and Hotspot Stopover

Sites .......................................................................................................................................................... 55

A7.1 Western Sandpipers and Dunlins. ........................................................................................... 56

A7.2 Semipalmated and Least Sandpipers- Atlantic Flyway equivalents to western sandpipers ... 58

A8. Physiological changes for migration ................................................................................................. 59

A8.1 Fatty Acids as Migratory Flight Enhancers-Shorebirds ............................................................ 60

A9. Linkages of Wetlands. ........................................................................................................................ 61

A10. Fatty Acids in Reproduction and Migration-Seabirds ...................................................................... 63

A11. Terrestrial Environments Dependent on Wetlands ......................................................................... 65

A12. Conservation Planning and Habitat ................................................................................................ 65

A12.1 Other Similar Chains of Wetlands and Tidal Flats ................................................................ 66

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A13. Phytoplankton and Oil Spills ............................................................................................................ 69

A14. International Treaties and Conventions .......................................................................................... 71

A14.1 The Pacific Salmon Treaty ..................................................................................................... 71

A14.2 Other Fisheries Treaties ........................................................................................................ 72

A14.3 The Trilateral Committee for Wildlife and Ecosystem Conservation and Management Treaty

........................................................................................................................................................... 72

A14.4 The Migratory Bird Treaty /Convention Acts ........................................................................ 74

A15. Conservation Medicine .................................................................................................................... 74

A16. Impacts on Migrants by Climate Change ........................................................................................ 75

APPENDIX 2 – ANALYSIS - CHOICE OF GEOGRAPHIC PLACEMENT OF A PACIFIC GATEWAY PORT AND

THE ACCOMPANYING ECONOMIC AND TRANSPORTATION ISSUES ..................................................... 76

V. LITERATURE CITED ......................................................................................................................... 84

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1. INTRODUCTION

The Fraser River Delta is the largest estuary on the Pacific coast of North America, and Roberts

Bank is the most important wetland in the estuary. A few significant factors that make Roberts Bank

stand out as the most important wetland in southern BC:

Roberts Bank is a unique ecosystem among other similar nearby wetlands in the Vancouver Lower

Mainland and adjacent areas. It is the “Goldilocks” wetland.

o Timing of nutrients from the Fraser River at freshet is just right for flora and fauna, for

example, phytoplankton, zooplankton, fish, and migrating shorebirds dependent on this

wetland.

o The combination of abiotic factors, e.g. salinity, temperature, light, turbidity, at Roberts Bank

at the time of spring shorebird migration and waterbird pre-breeding is just right for growth

and development of diatoms and heterotrophs that eat them.

o The large population of diatoms in the biofilm present only at Roberts Bank and not at other

mudflats in the Fraser River - Boundary Bay area enables the rich diversity there.

o Timing of the bloom of diatoms at Roberts Bank, one of the main foods for shorebirds, is just

right for their northward spring migration.

o Timing of the diatom bloom is just right for the growth and development of zooplankton,

which are prey for other heterotrophs including migrating salmon and salmon smolt exiting

the Fraser River at this time.

o Timing of omega-three (Ω-3) fatty acids, other nutrients, abiotic factors, and prey is just right

in the spring for waterbirds such as great blue herons that forage at Roberts Bank .

Spring abiotic conditions are unique at Roberts Bank because of the salinity, turbidity, water flow,

temperature, light, and other abiotic factors that are a juxtaposition of the Fraser River and

oceanic conditions at that time.

Spring abiotic conditions are a perfect combination of all of the factors needed by the assemblage

of fatty acid-producing diatoms at Roberts Bank to grow and divide.

Roberts Bank supports the greatest number of migrating birds because of its unique marine

biofilm-based food web (biofilm is mainly marine diatoms).

The importance of the marine diatoms is that they produce Ω-3 fatty acids that other species

cannot produce and which are vital for physiological processes, reproduction, and development in

all heterotrophs (marine life that cannot make their own food).

2

These Ω-3 fatty acids from marine diatoms are thought to enhance long-distance flight and are

critical to have in the diet of migratory birds as well in the diets of zooplankton and fish.

The fatty acids are not used mainly as fuel, but are rather concentrated up the food web,

demonstrating not only their unique importance, but also the fact that they cannot be replaced by

just some other bulk carbon source of nutrient. Nutrient quality is most important in this food

web.

Studies have shown that many heterotrophs, from zooplankton to vertebrates, that eat Ω-3 fatty

acid-poor food have physiological and reproductive issues.

Studies have shown that fatty acids produced by marine diatoms is in greater abundance and is

different from that produced by freshwater diatoms.

Roberts Bank is the final major stopover link in the Western Flyway chain for migrating shorebirds

before they arrive in Alaska to breed, and it is believed that fatty acids help birds’ muscles in long

distance migration.

Therefore, it is essential to maintain Roberts Bank in its current condition in order for shorebird

migration not to be severely affected by any alteration to the Goldilocks Ecosystem of Roberts

Bank.

Salmon smolt exit the Fraser River in the spring to spend their time at sea, and here they eat

zooplankton which have fed on diatoms. Without fatty acids, salmon are predicted to not develop

as well as those that have consumed prey filled with fatty acids.

Roberts Bank is also important at other times of the year besides the spring. It supports

thousands of migrating or overwintering waterfowl, gulls, terns, and shorebirds at various times of

the year, mainly migratory shorebirds and waterfowl.

Over 28 species of birds have been found at Roberts Bank in daily counts of >50, and often with

counts in the hundreds or thousands throughout the year. Many of these birds are on the

Province’s list of vulnerable species, on the Blue List, or listed as High Priority in the Conservation

Framework.

Loss or degradation of the critical mudflat/diatom productivity at Roberts Bank is almost certain to

occur with the expanded Roberts Bank terminal, and this fact is acknowledged in the

Environmental Impact Study (EIS) released by the Vancouver Fraser Port Authority (VFPA).

This degradation of the Roberts Bank ecosystem will have negative cascading effects on the entire

marine food web at Roberts Bank, including birds and salmon, and these effects might be

irreversible.

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The unique productivity of diatoms, the effect of Ω-3 fatty acids on the food web, the substitution of

bulk carbon for quality of carbon (e.g. fatty acids vs. chlorophyll a) were all neglected by the VFPA’s

EIS.

This neglect by VFPA is sufficient to deny this project to be able to proceed.

The VFPA failed to seriously consider alternative sites such as Prince Rupert for another expanded

port facility.

Some Inadequacies of the VFPA EIS are

o A lack of understanding of how the Roberts Bank ecosystem works.

o A lack of describing the importance of fatty acids.

o A lack of the understanding of marine and freshwater diatoms and their ecology and

distribution.

o A lack of understanding of the distribution of shorebirds at Roberts Bank and in the Fraser

River delta.

o A lack of understanding of the entire food web at Roberts Bank.

o The erroneous use of models like the EwE and shorebird model to explain the ecology of

Roberts Bank.

o The ignoring of International Treaties that would be affected by construction of RBT2

o The neglect of the VFPA to incorporate the Precautionary Principle, which is the gold

standard necessary to address for any kind of alteration to an ecosystem.

Finally, if there was another site in the Lower Mainland that was such a rich food source for migratory

birds as is Roberts Bank, the birds would already have found it and would stage there in large numbers.

There is no such alternate site. Even for a layperson, without having to delve into the science behind

why Roberts Bank is so important, it is obvious that Roberts Bank is the only show in town.

In the following Commentary, I show how the Roberts Bank ecosystem fits into the chain of tidal

flats along the migratory pathway of shorebirds, and why it is so important. I also summarize how the

richness of this particular ecosystem is critical for flora and fauna not only in the local ecosystem, but

also in those populations which might utilize it only briefly during their life cycle. Furthermore I suggest

possible negative effects on this ecosystem if RBT2 is built. In the Commentary, I also highlight the

omissions, data gaps, and erroneous assumptions made in the EIS, as well as the inadequate level of

scientific understanding by VFPA of many of the complex processes that operate in the Roberts Bank

4

ecosystem. I will not address the scientific/ecological merits and detractants of the other proposed sites

for a container facility, nor will I address Volumes 1, 2, or 4 of the EIS. Of Volume 3, I will only address

parts of sections 10.0 - 15.0, and 17.0.

In the first Appendix of this document, which is in more detail than is the Commentary, I describe

the ecosystem and food web at tidal flats in general, from the lowest to the highest trophic level, with

emphasis on phytoplankton, and discuss the effect of the most important parts of this web on the entire

ecosystem. I then link this general discussion of tidal flats to the particular ecosystem at Roberts Bank. In

the second Appendix, I briefly outline a case for positioning of a world-class Canadian shipping container

facility at the Port of Prince Rupert, and why this is superior a location to the Port of Vancouver.

2. ENVIRONMENTAL VALUES AT ROBERTS BANK - THE IMPORTANCE OF THE ROBERTS BANK

ECOSYSTEM

2.1 Summary of Environmental Values

Roberts Bank is uniquely different from the other tidal flats in the greater Fraser Estuary -

Boundary Bay ecosystem.

This difference stems from its location, and the abiotic factors and marine food web that are a

result of this location.

Roberts Bank is a critical staging site along the Pacific Flyway for many species of shorebirds,

including a large proportion of the western sandpiper and the entire population of the Pacific

dunlin.

Stopover sites for migratory birds are links in a chain - all are necessary, and if one is destroyed,

there is potential for migration to cease for species dependent on this link.

Roberts Bank is uniquely important in that it is the final major staging area for shorebirds

migrating to their Alaskan breeding grounds, and it is at Roberts Bank where they complete their

final fueling up to make the long journey.

Roberts Bank is also critical for growth and development of Fraser River salmon smolt and forage

fish because of the abundance of their marine prey there.

Marine biofilm, concentrations of phytoplankton in tidal flats, at Roberts Bank are the heart of this

marine food web, and their presence in large numbers and in the species assemblages that exist at

Roberts Bank, is what supports the rich food web at Roberts Bank.

5

In particular, diatoms, a type of phytoplankton in the marine biofilm, produce omega-three long-

chained essential fatty acids (LCEFA) necessary and critical for growth and reproduction of

heterotrophs in this web, as well as for shorebird migration, because heterotrophs cannot

produce these fatty acids themselves. They are essential for a number of physiological processes

in all animals.

It is thought that the omega-three fatty acids produced by diatoms at Roberts Bank prepare the

flight muscles in shorebirds for endurance flight for the 1900 km jump to the Copper River delta in

Alaska.

Omega-three fatty acids also are critical for growth and reproduction of the zooplankton and fish,

including salmon, at the Fraser River delta.

Nowhere in this entire greater Fraser River delta – Boundary Bay estuary are marine diatoms as

concentrated and available as they are in Roberts Bank.

Omega-three fatty acid profiles of phytoplankton are species specific.

The abundance and distribution of the species assemblage of marine diatoms at Roberts Bank

depend on its current suite of abiotic factors, which cannot be reproduced elsewhere.

Nutrients and prey from Roberts Bank are exported far and wide by currents and thus the Roberts

Bank marine ecosystem affects the marine biology of Georgia Strait and beyond, even influencing

habitat in United States’ waters.

All of this complex food web and processes associated with it will be irretrievably altered if

Roberts Bank Terminal 2 is built.

2.2 Uniqueness of Roberts Bank

Roberts Bank is a unique ecosystem in B.C. and in the Fraser River Estuary/Boundary Bay tidal flats

because of its geomorphology and how it is situated at the mouth of the Fraser River. Its geographic

position, the slope of the mudflat, the nutrient outflow from the Fraser River, the suite of abiotic factors

such as salinity, nutrients, and light there, as well as the flora and fauna in the Roberts Bank food web,

all make it unique. The rich marine food web at Roberts Bank is due to this geomorphology, location,

and abiotic factors. The Fraser River delta has 21,703 hectares, and is the largest estuary on the Pacific

coast of North America (Flynn et al. 2006). In fact, the southern Strait of Georgia can be considered an

estuary because of the large amount of freshwater output from the Fraser River.

This rich food web at Roberts Bank is a direct result of a greater density of marine biofilm (marine

diatoms) there than in any other mudflat in the area. The diatom-produced nutrients such as omega-3

6

LCEFA affect the rest of the marine food web, attracting large numbers of heterotrophs (heterotrophs

are fauna which don’t make their own food), including migrating shorebirds, Fraser River salmon, and a

myriad of other zooplankton, fish species and waterbirds (Elner et al. 2005, Kuwae et al. 2013, Jardine et

al. 2015). The long chain fatty acids are either polyunsaturated (PUFA) or highly unsaturated (HUFA)

and these are critical nutrients for all heterotrophs, including birds and fish . The particular HUFA that

are most important for heterotrophs are the Ω-3 eicosapentaenoic or docosahexaenoic fatty acids, more

commonly known as EPA and DHA.

Omega-3 (Ω-3) long-chained essential fatty acid LCEFA profiles of phytoplankton are species specific,

meaning that the fatty acids necessary to sustain the rich food web at Roberts Bank are only present

because of the species of marine phytoplankton biofilm that are at Roberts Bank (Piepho et al. 2012).

This marine biofilm is critical not only for migration, but also for growth and development of all

heterotrophs. The food web productivity of marine diatoms and how they become available for the

marine food web at Roberts Bank are described in Appendix 1 Sections A1. - 1.1.

Marine biofilm, phytoplankton which can live only in seawater, differs qualitatively from freshwater

biofilm. It occurs in a different area of Roberts Bank - over muddy inshore areas accessible to shorebirds

- and it produces different amounts of essential nutrients than do freshwater diatoms. Marine diatoms

exist in a narrow range of abiotic conditions, summarized in Appendix 1 Section A2. Diatoms - Ecological

Niches - with reference to possible changes in abiotic factors at Roberts Bank and Section A3. The

Phytoplankton Community and Fatty Acids. The EIS states that marine and freshwater diatoms are the

same. This statement is in error.

The critical nutrients produced by the biofilm, mainly marine diatoms, are long-chained essential

fatty acids not easily produced by heterotrophs (or impossible to produce). These fatty acids have a

critical molecule, omega-three fatty acid (Ω-3), which allows this rich food web to exist. Appendix 1

Section A1.2 Importance of Diatoms and their Fatty Acids in the Roberts Bank Ecosystem summarizes

why diatoms are important and why omega-three fatty acids are important.

Because of the greatest abundance of marine diatoms is at Roberts Bank and nowhere else in such

large numbers in the greater Fraser River estuary system, and because of the vital importance of omega-

three fatty acids for the entire food web there, Roberts Bank stands out as a unique ecosystem that is

not able to be replicated anywhere else. The populations of these heterotrophs will be altered if

numbers and species of marine diatoms disappear from Roberts Bank. I present information further on

outlining how a change in the population species and numbers of marine diatoms at Roberts Bank could

seriously and negatively impact this special ecosystem irreversibly, and I give examples of other

7

ecosystems where this has occurred. Therefore, for the EIS to state that there will be no effect on the

biofilm or on the marine community that relies on them if RBT2 is built is not only inaccurate, but also

misleading.

2.3 Shorebirds in Tidal Flats

Shorebirds use tidal flats as staging-feeding areas on their migration to breeding or overwintering

grounds. These tidal flats are critical for their populations because they provide the nutrients for birds to

migrate. Shorebirds also overwinter on tidal flats in varying numbers from Canada to South America.

Threats to these mudflats in any one part of a annual cycle in any of the steps along the migratory path

can affect the entire population of a migratory species (Myers 1983, Myers et al. 1987, Runge et al.

2014, Aharaon-Rotman et al. 2016). Appendix 1 A6. Shorebirds in Tidal Flats with Emphasis on the

Roberts Bank Ecosystem describes this use in more detail.

2.3.1 Shorebirds at Roberts Bank

Some wetlands seem to be “hotspots” or “magnets,” with thousands of birds foraging along the

mudflats, whereas other ones nearby do not. A good example of a contrast between a hotspot staging

area and an adjacent area where few birds stage is the Roberts Bank mudflat and the adjacent Boundary

Bay mudflats. Shorebird numbers (e.g. western sandpipers and dunlins) at Roberts Bank are an order of

magnitude larger than in Boundary Bay, and from telemetry studies we know that western sandpipers

who overwinter as far south as Panama more frequently stop at Roberts Bank, rather than Boundary

Bay or other sites in BC, on their way north to their breeding grounds in Alaska (Baird 2009). The only

area of Boundary Bay where sandpipers are dense is at the very small Mud Bay where high levels of

marine diatoms have been found.

Most likely for centuries, shorebirds have come to Roberts Bank instead of to other wetlands in

southern BC because of the availability of the critical and key nutrient of omega three long-chained fatty

acids for migration. There is simply no other place as rich in these key components of migration for

these shorebirds to go. If there were, there would be well-documented records of their staging at these

other places for their northward migration, and there are no such records.

The Fraser River Delta, the largest estuary on the Pacific coast of North America (21,703 hectares),

supports the highest concentration of migratory birds in Canada - up to 1.4 million during peak

migration (Flynn et al. 2006). At Roberts Bank shorebirds like western sandpipers and dunlin feed on

soft-bottom inter tidal mudflats (Elner et al. 2005, Jardine 204), and this is where the marine biofilm

thrives (phytoplankton such as diatoms). Many shorebird beaks are structured to feed on biofilm in the

8

mud, not the sand (Elner et al. 2005, Kuwae et al. 2008), and biofilm has been found in stomachs of

shorebirds at Roberts Bank.

A globally significant portion of the world’s western sandpiper population Calidris mauri (>21% and

up to 64% in some years), as well as the entire population of the Pacific subspecies of dunlin, Calidris

alpine pacifica, stops over at Roberts Bank during northward spring migration (Butler and Vermeer

1994, Warnock and Gill 1996, Butler et al. 2002, Kuwae et al. 2012, Drever et al. 2014, Chardine et al.

2015). Because of the importance of this link in the chain of mudflats for migration, the Fraser River

Estuary—Boundary Bay tidal flats are designated a “globally significant Important Bird Area”

(www.ibacanada.ca).

Many other studies document hundreds of thousands of western sandpipers and other small

shorebirds at Roberts Bank during spring migration. Historical records back to the 1970s and 1980s note

that over 100,000 or more per day of shorebirds were found in the foreshore at Roberts Bank, 99% of

which were small Calidris sandpipers –e.g. western sandpipers or dunlin (Butler et al. 1987, Butler and

Campbell 1987, Butler and Cannings 1989, Campbell et al. 1990). During that same period, sandpipers at

adjacent wetlands were documented at 20,000 per day at Iona Island and Mud Bay, and 3,000 per day

at the Reifel Refuge. The majority of the birds at Roberts Bank were western sandpipers as well as

dunlins, least sandpipers, black-bellied plovers, and semipalmated plovers. Mud Bay is known to have

an abundance of diatoms - the only area in Boundary Bay that does - and it is very small compared to

Roberts Bank, which hosts at least 1.4 million shorebirds at peak migration (Flynn et al. 2006), with

estimates at “several thousand birds per minute” passing through (R. Butler Environment Canada,

retired, pers. comm.). Peak migration in spring through Roberts Bank is in April. Western sandpipers

peak on the fall migration from July - August (Cassidy et al. 1998) and in October - January, very large

numbers of waterfowl, shorebirds, and gulls overwinter there.

Roberts bank is the preferred sub-area of this complex tidal flats because western sandpipers are

marine biofilm grazers when at this final stop before their spring migration flight to Alaska, and partake

of the availability of their marine biofilm prey, which is more available at Roberts Bank than elsewhere

and which has a greater density there than in other parts of the Fraser River - Boundary Bay complex

(Kuwae et al. 2012). Jardine et al. (2015) found biofilm in at least 22% to 53% of fecal matter of western

sandpipers foraging there.

9

2.3.2 Wetlands - links in a chain - Habitat

High-quality migratory stopovers are important along every flyway for many species, and tidal flats

(mudflats) such as Roberts Bank are most important for shorebird species to enable long-distance

migration (Myers et al. 1987, O’Reilly and Wingfield 1995, Warnock and Bishop 1998, Clark and Butler

1999). Stopover sites for shorebirds along any Flyway are like links in a chain, each separated by

hundreds or even thousands of kilometers, but all are necessary for migration because shorebirds need

to intake food at these stops in order to reach the next tidal flat. Roberts Bank is especially important for

shorebirds because it is the final major migratory stopover site on the Pacific Flyway of North America

before Alaska.

Loss of intertidal habitat on flyways, especially staging sites where birds refuel for the next migratory

leg, can have serious repercussions for their populations (e.g. Myers et al.1987, Goss-Custard et al. 1995,

Buehler and Piersma 2008, Warnock 2010, Rakhimberdiev et al. 2011). The food web in a mudflat

which is the final foraging area before a long-distance, usually nonstop, flight to the breeding ground is

extremely critical for shorebirds because here they need high quality food with omega-3 fatty acids in

order to make this final 1900 km (~1180 mi) leg of the flight to the next foraging stop, the Copper River

delta area in Alaska. I explain the reasons for this need for marine biofilm and why Roberts Bank is so

important further in this document.

2.3.3 Conservation Planning

Conservation planning that includes mobile species is becoming more and more important in any

decision making (Myers 1983, Myers et al. 1987, Runge et al. 2014, Aharon-Rotman et al. 2016). Any

kind of movement of populations from one geographic area to another, even though they are

predictable and straightforward, can make them vulnerable to habitat loss of any kind. Habitat loss is

equivalent to loss of a valuable food source. This is often forgotten. The value and management of the

Roberts Bank area and its unique food web are not separable from the value and management of the

entire network of wetlands along the Pacific Flyway. Likewise, mobile species like migratory birds

connect countries and ecosystems and are good environmental indicators at both a local and a global

scale (Battley et al. 2008). There have been direct and indirect effects on the food web (e.g. biofilm) and

therefore on migrating shorebirds in other flyways such as the Austral-Asian flyway. These disturbances

and declines of the food web there are suspected to be the principal cause for population declines there

(MacKinnon et al. 2012, Murray and Fuller 2015, Clemens et al. 2016, Piersma et al. 2016).

10

Flyways are the sum of all of the links of stopover sites which cannot be managed or assessed

separately from each other. Each link is strategically important for migration. In many flyways today, we

see decreases in population numbers of migratory birds because parts of the flyway have been

disrupted, disappeared, or altered because of development. For example, the Austral-Asian Flyway has

been severely impacted by development (Amano et al. 2010, MacKinnon et al. 2012, Piersma et al.

2016). In this flyway, 89% of the monitored breeding shorebird populations in northeastern Russia have

declined (MacKinnon et al. 2012). Tidal mudflats around the Yellow Sea have decreased by 28% since

the 1980s and over 65% since the late 1960s (Murray et al. 2014). Fastest declining seabirds in this

flyway are the long-distance Arctic breeders (Battley et al. 2008).

Because of this chain or links of “stepping stone” stopovers in a flyway, various groups have

published strategies of how to manage flyways as a whole, and not individually. Runge et al. (2014)

summarize the Asia-Pacific Waterbird Strategy that summarizes management strategies for migratory

species across the entire network in the Austral-Asian Flyway (Frisch 2006). For the European-African

Flyway, the International Wader Group established two white papers, one The Cadiz Commentary

(2003), and the other, The Kollumerpomp Statement (International Wader Study Group 2001). These are

found in Appendix 1 - A12.1 Other Similar Chains of Wetlands and Tidal Flats.

Any habitat loss or change in habitat quality has to be looked at across the entire habitat available to

a species. Especially if an entire population passes through an affected habitat during part of its life

cycle, if that patch is severely altered or lost, “...extinction of the migratory species will result” (Runge et

al. 2014). It is necessary to manage multiple and interacting threats to a population by all countries

where this population reproduces, overwinters, and/or migrates. For example, in the East Asian-

Australasian Flyway (EAAF), there is the EAAF Partnership - an alliance of 30 governments and NGOs

working together to preserve globally vulnerable species (Runge et al. 2014). The UN’s Ramsar sites and

the WHSRN sites are often part of this conservation effort, but sometimes valuable habitats adjacent to

these sites, for example, Roberts Bank get omitted by accident. “Mobile species simply require new

approaches in conservation planning to account for dependencies among sites and among populations,

especially when all aspects of things like migration are not well understood…” (Runge et al. 2014).

2.3.3 Bottlenecks

An evaluation of bottlenecks in shorebird migration would indeed reveal that Roberts Bank is one

such bottleneck. All bottlenecks in a species’ migratory path are at risk because of changing human use

of these areas (Berger et al. 2008). Information on connectivity between sites has been incorporated in

11

conservation planning in other areas (Moilanen et al. 2008, Beger et al. 2010, Linke et al. 2011). The

rapid decline of mobile species globally suggests that “time is running out to achieve large-scale

conservation action necessary to avert their loss” (Kirby et al. 2008, Runge et al. 2014). Planning

conservation corridors for these species is challenging, but it can and must be done. Runge et al. (2014)

suggest “whole-landscape management” – an action taken in Europe to manage the pink-footed goose

(Anser brachyrryhynchus -- see Klassen et al. 2008).

2.3.4 Other Flyways in North America

Appendix I Section A7. The Pacific & Atlantic Flyways – Relationship between Shorebird Migration

and Hotspot Stopover Sites - describes two major flyways in North America: the Pacific and Atlantic

Flyways. This section details the relationship between migration and hotspot stopover sites, and Section

A7.1 Western Sandpipers and Dunlins summarizes migration of two important species of shorebirds, the

western sandpiper and the Pacific dunlin, along the Pacific Flyway. It describes the distance of the legs of

their flights, and what they eat- especially how they shift their diets to marine biofilm at their final stop

before Alaska. This section also notes the specialized structures in the tongues and palate of many

shorebird species that allow them to eat biofilm. It also summarizes a number of studies on their diet,

highlighting the importance of diatoms/biofilm and the omega-3 fatty acids they produce as very

important in the prey of these shorebirds.

Appendix I Section 7.2 , Semipalmated and Least Sandpipers - Atlantic Flyway equivalents to

western sandpipers, describes two similar shorebird species on the Atlantic Flyway - the semipalmated

and least sandpipers. They, too, consume long-chained essential fatty acids on both their northward and

southward final migration legs. Thus it is apparent that the consumption of marine biofilm by migrating

shorebirds is the norm before a long nonstop flight, and that only certain “hotspot” wetlands contain

the necessary density of omega-3 long-chained fatty acids which are ultimately produced by the marine

phytoplankton there.

2.3.5 Other Similar Chains of Wetlands and Tidal Flats

In the East Asian-Australian Flyway, a path of development recently occurred, with substantially

disastrous results from which many populations of shorebirds will never recover (MacKinnon et al. 2012,

Murray et al. 2014, Jones 2016, Szabo et al. 2016). Recently there has been major repurposing of

mudflats and tidal areas along this flyway with development and expansion of shipping facilities or

resource extraction. Rogers et al. (2016) document the collapse of this flyway from these causes, and

describe the repercussions. They state that shorebird populations “are in trouble worldwide” but

12

document the “steepest and most widespread declines” in the East Asian-Australian Flyway. They note

that this flyway, like that in the eastern Pacific, along the coasts of South, Central, and North America,

covers many different nations, all with different environmental regulations and conservation. There is

human pressure on habitats to continue to develop coastal sites for resource extraction or movement of

goods. These coastal habitats, like those on the Pacific Flyway, are critical staging areas for shorebirds in

their long trans-equatorial migration from wintering to breeding grounds and return. These habitats are

bottlenecks which if degraded, destroyed, or altered can have disastrous effects on the survival of

shorebird populations.

For further discussion of this issue, refer to Appendix I Section A9. Linkages of Wetlands and Section

A12. Conservation Planning and Habitat.

2.3.6 Other Bird Species at Roberts Bank

Over 28 species of birds have been found at Roberts Bank in daily counts of > 50, with most total

counts of these in the hundreds or thousands, and some in the ten-thousands. The species at Roberts

Bank that are listed on the BC Ministry of Environment’s Provincial list of vulnerable species or have a

high priority goal in the Conservation Framework (CF) or are on the Blue List are the following:

o Great blue herons Ardea herodias are listed in the BC Vulnerable list as S3, meaning that

they are Vulnerable in the nation or state/province due to a restricted range, relatively few

populations (often 80 or fewer), recent and widespread declines, or other factors making it

vulnerable to extirpation. The coastal subspecies of the great blue heron is on the Provincial

Blue List.

o Double-crested cormorants Phalacrocorax auritus are on the Provincial list as S3S4

(Vulnerable or Apparently Secure), are on the BC Blue List, and on the Committee On the

Status of Endangered Species In Canada List (COSEWIC) list as not at risk. They are #2 in

priority Conservation Goal of the Conservation Framework

(http://www.env.gov.bc.ca/conservationframework) although they are Globally Secure.

o Surf scoters Melanitta perspicillata are on the BC Blue List (Special Concern - formerly

Vulnerable), on the Provincial List as S3B,S4N (Vulnerable breeding, Apparently Secure Non-

breeding) and Globally Secure.

o Caspian terns Hydroprogne caspia are on the BC Blue List, and are S3B, Globally low,

COSEWIC not at risk, and on the Conservation Framework, it is #2 priority.

13

2.4 Biofilm and the Marine Food Web

2.4.1 Biofilm - recap

The biofilm at Roberts Bank exist in the abundance and species assemblages at Roberts Bank only

because of the unique combination of geophysical structure and abiotic factors that come together to

make Roberts Bank ideal for marine biofilm blooming. They have a narrow range of abiotic factors they

need in order to bloom. These conditions are present at Roberts Bank in the Fraser River delta area -

and not elsewhere. Although the very small area of Mud Bay has some outflow that assists diatom

blooming in less significant amounts, the ocean circulation there is very different, thus shaping a

different makeup of the food web.

Biofilm are the drivers of the rich marine food web at Roberts Bank. They are the keystone element

that allows the food web to exist. They produce Ω-3 fatty acids in large numbers in the spring and this

essential nutrient is what attracts marine life to Roberts Bank . Diatoms are consumed by heterotrophs

and the Ω-3 fatty acids are passed up the food web.

2.4.2 Zooplankton

When heterotrophs, (from copepods and other zooplankton at the bottom of the heterotroph food

web, to vertebrates like migrating shorebirds or fish, including salmon), all graze on biofilm, LCEFA are

transferred to them, and a new reservoir of lipids in the food web is then available for other

heterotrophs above them in the food web. These lipids continue up the food web throughout the spring

and summer as zooplankton and their predators in turn are eaten by animals at higher trophic levels,

like fish or herons. This is what Lee (1974) called the “green wave” as eventually the fatty acids (both

polyunsaturated, PUFA, and highly unsaturated, HUFA), move in time and space, into fish, shorebirds,

seabirds, and into the terrestrial environment where they are carried by birds and by decaying

organisms that wash up on the shore (Gladyshev et al. 2013). As a result of changing abiotic conditions

in the spring, this large bloom of fat- rich diatoms at the surface is only present a few weeks in the

spring where diatoms are available for the grazing zooplankton, e.g. copepods and for the surface

feeding vertebrates like migrating shorebirds.

Therefore, it is fair to say that the quality of the essential nutrients at the bottom of the food chain

is dependent on the composition of that community’s primary producers. Small zooplankton, such as

crustaceans that graze on diatoms and other phytoplankton need omega-three (Ω-3) fatty acids for

reproduction and egg development (Anderson and Pond 2000, Mϋller-Navarra et al 2009, Brett et al.

2009, Chen et al. 2012), and when phytoplankton communities shift to cyanobacteria-dominated

14

assemblages, for example, trophic transfer efficiency of PUFA and egg production, e.g. by Daphnia

magna, a small crustacean, can decrease and the system can have “little to no Ω-3 HUFAs” (Mϋller-

Navarra et al 2009). Even if elemental nutrients like carbon or other sources of energy are high and

food quantity is high, but Ω-3 levels are low, secondary production can be low (Mϋller -Navarra et al.

2000, 2004, Persson et al. 2007, Gladyshev et al. 2011). Therefore, the form that nutrients are in may be

as important or more important than their relative abundances (Anderson and Pond 2000, Frost et al.

2005).

2.4.3 Other Invertebrates and Fish

In 2006, more than 80 species of fish and shellfish, including two billion juvenile salmon, spent part

of their life cycles in the Fraser River delta (Flynn et al. 2006). Flynn et al. (2006) further state that the

Fraser River is the largest salmon-producing river in the world. In food web models it has been shown

that there are higher reproductive rates and faster and highly efficient growth in both zooplankton and

fish which consume high quality phytoplankton – i.e. phytoplankton with the largest proportion of PUFA

and HUFA like the essential fatty acids DHA and EPA (Watanabe et al. 1983, Ahlgren et al. 1990,

Danielsdottir 2007, Brett et al. 2009). Presence of EPA has been identified as a strong predictor of

growth in cladocerans (zooplankton) (Müller-Navarra et al. 2000, Brett et al. 2006), and increased

dietary uptake of the LCEFA arachadonic acid, ARA, correlates with better growth in juvenile bivalves

(Milke et al. 2006), with gonad development in sea urchins (Castell et al. 1972, 2004, Hughes et al. 2011,

Raymond et al. 2014) and with higher reproduction in marine copepods (Pond et al. 1996). DHA has

been found critical for larval development in fish (Bell et al. 1995, Sargent et al. 1999, Copeman et al.

2002) and in egg production and viability in copepods (Jónasdóttir 1994, Broglio et al. 2003).

Commercially important fish species require dietary long-chained polyunsaturated fatty acids (PUFA) ,

which are produced by PUFA-rich algae – phytoplankton (Tocher 2003, Arts and Kohler 2009).

Thus, fatty acid composition and availability from primary producers play a decisive role in food web

structure by limiting secondary production, and the limitation of Ω -3 HUFA can directly influence the

ecosystem with decreased growth rates and secondary production over many taxa. This limitation has

the potential for “cascading effects “up the food web and on ecosystem-level processes (Twining et al.

2015). If there is not enough EPA and DHA in the diet of marine animals, they can become

malnourished, have abnormalities in development, stunted growth, and can die (Yongmanitchai and

Ward 1989, Renaud et al. 1991, Reitan et al. 1994).

15

2.4.4 Selective uptake of LCEFA

Gladyshev et al (2010, 2013) investigated the transfer efficiency of essential nutrients between

trophic levels- phytoplankton producers to zooplankton consumers, to fish and birds. They compared

these ratios for both bulk carbon and for carbons in Ω-3 PUFA, and found that PUFA were transferred

with about twice as high an efficiency as was bulk carbon. They note that many previous studies only

considered transfer of carbon, but not the particular quality of the carbon, and state that selective

uptake and storage of LCEFA is found throughout the food web. Zooplankton do not oxidize Ω-3 PUFAs,

but rather store them (Gladyshev et al. 2013), and in physiological research in humans, it was found that

50–70% of doses of short-chain PUFA were used for energy within a 24 hour period, but in contrast, 85%

of the long-chain DHA was selectively incorporated into cell membranes, and not oxidized (Broadhurst

et al. 2002, Plourde and Cannane 2007). This means that essential long-chain PUFA are selectively taken

up and transferred up the food web and are bio-accumulated. This bio-accumulation of PUFA in the

marine environment is also characteristic of an aquatic terrestrial transfer up the food web (Gladyshev

et al. 2013). For example in fish prey of gray herons, the concentration of EPA and DHA in muscles of

herons was about twice as high as those of the fish (Gladyshev et al. 2010). Thus, biofilm at Roberts

Bank is essential not only for the marine food web - e.g. zooplankton and fish, but also for shorebirds,

seabirds, and land birds and mammals that consume marine prey. The LCEFA, e.g. PUFAs, accumulate in

higher trophic levels with a higher transfer efficiency than other substances like bulk carbon, most likely

because they are important for growth, maintenance, and reproduction.

Western sandpipers, for example, selectively consume diatoms from the biofilm and selectively

uptake long chain essential fatty acids (LCEFA) like all other animals in the food web. In one key study,

biofilm made up approximately 7.0 ± 1.9% of the microphytobenthos (based on carbon), but diet models

of western sandpipers consistently indicate that consumed biofilm (with long-chained fatty acids,

carbon-rich compounds), was at least 65%, indicating selective feeding of biofilm (Kuwae et al. 2008).

2.4.5 The Difference between LCEFA and Bulk Carbon

Gladyshev et al. (2013) state that most studies on food webs consider only carbon transfer, which is

used as a proxy for energy or nutrients, but these studies do not investigate the quality of the carbon-

whether it is of the LCEFA type or just bulk carbon. The amount of chlorophyll α in a system, often used

as a proxy for the amount of energy or nutrients, is only a proxy for the amount of photosynthesis by

phytoplankton. It is a quantitative measurement and is not an equivalent of the quality of food

available, nor of the lipid content or essential nutrients in an ecosystem (Karasov and Martinez del Rio

16

2007). Studies on ecosystems often use energy or a quantitative amount of elemental nutrients as

currency of energy up the food web yet Polis et al. (2004) state that food quality, e.g. the abundance of

LCEFA, is more important, especially with respect to Ω-3 fatty acids. For further discussion of these

issues, refer to Appendix I Section A5. Selective uptake and biomagnifications of LCEFA and Transfer

between Trophic Levels.

Appendix I Sections A8. - 8.1 summarize why LCEFA - especially HUFA omega-three fatty acids-are so

important for shorebird migration. They detail physiological changes for migration in shorebird flight

muscles. Section A10. Fatty Acids in Reproduction and Migration - Seabirds, and Section A11. Terrestrial

Environments Dependent on Wetlands demonstrate why diatoms are important for bird species other

than shorebirds. Marine birds, waterbirds of many species, and even land birds that consume marine

prey have better reproduction and development if diatoms and long-chained essential fatty acids are

part of their diet.

3. ERRORS AND OMISSIONS IN PORT METRO VANCOUVER’S ASSESSMENT OF RBT2 AS SUMMARIZED

IN THE EIS AND HOW CONDITIONS THERE MIGHT CHANGE DUE TO CONSTRUCTION

This section describes the VFPA EIS’s sampling details and methods for Roberts Bank Terminal 2

(RBT2), which I show to contain a number of errors, omissions, and misinterpretations. I have addressed

a number of these below. These comments only address: “Baseline Field Studies for Port Metro

Vancouver’s EIS for RBT2” (http://www.robertsbankterminal2.com/wp-content/uploads/rbt2-baseline-

field-studies-terms-of-reference-february-2013.pdf) and Volume 3: Biophysical Effects Assessments

(http://www.robertsbankterminal2.com/wp-content/uploads/rbt2)

3.1. Sampling Issues

3.1.1 Recap of Abiotic Factors important for Biofilm

Marine biofilm blooms, meaning that it reproduces to make vast quantities of cells, under a perfect

storm of abiotic factors that come together in the spring at Roberts Bank. Nutrients stream out of the

Fraser River at freshet, sunlight is increasing in the spring, salinity at the Roberts Bank area changes

temporarily at that time to a concentration that promotes blooming, the temperature changes because

of the amount of fresh water mixing with seawater in the spring. It is at this time that marine biofilm

abounds, cells filled with omega-three fatty acids, and the presence of omega-three-filled diatoms in

such large numbers is what attracts shorebirds to Roberts Bank at spring migration in such large

numbers.

17

3.1.2 Timing

VFPA did not sample the salinity at Roberts Bank throughout April and May, which is when the

diatoms bloom and the shorebirds migrate through. They only sampled for a few days in late April, and

as has been found from pilot studies (K. Hobson Western University London Ontario, pers. comm.), in

order to sample the entire biofilm bloom, a time – series of weeks of samples are needed. Blooming

takes place over such a short time that it is easily missed, as it was in a 2016 sampling at Roberts Bank

(K. Hobson pers. comm.). The exact dates vary each year. Likewise, VFPA’s baseline field studies of

numbers and species of phytoplankton were sampled during mid-summer (2012), and by then, diatoms

that had been at the surface in the spring during shorebird migration quit blooming, and the PUFA and

HUFA that they produced during the freshet in April and May had moved through the food web into

higher trophic levels. The zooplankton, fish, shorebirds and seabirds, and the terrestrial environment in

mid-summer have PUFA and HUFA from the diatoms’ spring production. A measurement of sampling of

the biofilm mid-summer explains nothing about how important the biofilm in the spring is. They also

failed to measure the Ω-3 LCEFA in heterotrophs at Roberts Bank.

3.1.3 Other Sampling Issues

VFPA seems not to have understood how an ecosystem like Roberts Bank functions because of the

timing of sampling as well as where they collected the samples. The “wide distribution” of affected

species in the LAA and RAA stated in the EIS does not include when these potential prey items were

sampled, nor what species they were, nor if they were present in areas accessible to shorebirds. Were

shorebirds also present in these other areas (the “wide distribution”) and were they feeding? Were they

present in large numbers? Were the shorebirds found in these other areas during their short two-to-

three-week period on the northward migration? Usually on the southbound leg, shorebirds spread out

into many different habitats and are present in smaller groups because the next hops south from the

Fraser River delta are short, and there is no physiological need for the birds to forage on Ω-3 LCEFA,

which at that time would be in prey items that had accumulated these nutrients up the food web.

3.2 Assumption Issues

3.2.1 VFPA confuses freshwater with marine biofilm and thus they mis-state the effect of a decrease in

marine biofilm on shorebird populations and on salmon

VFPA concludes that the amount of biofilm (the number of diatoms in the area) will remain the

same after RBT2 is built as before, and that only the composition of taxa will change with more

freshwater diatoms in abundance. This assumption is probably true due to the change in river water

18

flow when structures for RBT2 are in place. However, the assumption that shorebirds will feed on these

is in error because the freshwater diatoms have a substrate of sand and the shorebirds can’t feed on the

sand because their beaks are structured to feed on biofilm in the mud. In addition, freshwater diatoms

do not carry as much Ω-3 LCEFA as do marine diatoms (Nixon 1988, Brett and Mϋller-Navarra 1997,

Brett et al. 2009, Twinning 2015), and as such, are not as critical to shorebird migration or to

transferring the Ω-3 LCEFA to the terrestrial environment. No matter how many diatoms are

hypothesized to be in the Roberts Bank system post- RBT2, if the taxa assemblage is radically changed,

Roberts Bank will not have the same ecosystem as before.

3.2.2 Effects of different abiotic factors on phytoplankton

Many researchers report that different assemblages of microphytoplankton arise under different

abiotic conditions (Petkov and Garcia 2007, Hill et al. 2011, Galloway et al. 2012, Galloway and Winder

2015) . As mentioned previously, sometimes cyanobacteria arise, which usually is not good for the

ecosystem because of the toxins they produce. Likewise, with no understanding how the phytoplankton

population dynamics will be altered nor how the phytoplankton will react to changes and a new

combination of temperature, salinity, and turbidity, VFPA cannot state that there will be no change in

the ecosystem.

3.2.3 Effect of changes in abiotic factors on omega-three fatty acids

Changing abiotic conditions, including the muddy substrate if VFPA’s Terminal 2 at Roberts Bank

were built, would alter phytoplankton communities there, and the suite of diatoms and other

phytoplankton making up the biofilm there would change, resulting in a decrease in the amount of Ω-3

fatty acids (e.g. EPA and DHA) in algae that remained (see Mallin and Paerl 1994, Pinckney et al. 1998,

Urrutxurtu et al. 2003 Nixon 1988, Brett and Muller-Navarra 1997, Galloway and Winder 2015).

Previous studies have shown that temperature, light, nutrients, and growth phase all affect total algal

lipids and fatty acid profiles (Renaud et al. 1991, Thompson et al. 1992, Reitan et al. 1994, Leu et al.

2006, Hu et al. 2008 , Rossol et al. 2012, Piepho et al. 2012, Cashman et al. 2013, Scwenk et al. 2013, Bi

et al. 2014). The EIS discounts the effect of sediment on phytoplankton by including them with the

infaunal invertebrates “capable of migrating upward through the deposited sediment...” Diatoms are

maintained on the surface during the early spring because they have manufactured fatty acids shich

give them buoyancy. There is no guarantee that diatoms will not be affected by the increased sediment.

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3.3 Flow of Nutrients at Freshet- Misunderstanding by VFPA

The construction of VFPARBT2 will also impede transport of nutrients from the Fraser River

seaward. Figure 2 below shows the typical distribution of nutrients at a generic river discharge

(http://coastalchange.ucsd.edu/st3_basics/waves.html).

Figure 2.

Blockage by the new container-loading structures would not be trivial. Aerial photographs of the

Fraser River output today show a vast far-reaching plume of sediment and nutrients flowing out to sea

(see Figure 3 below) If RBT2 is built, it will block much of this outflow. This outflow carries nutrients of all

kinds into the marine ecosystem and the flora and fauna there are dependent on these nutrients.

Blockage of this flow would have unknown negative effects. Note also the proximity of the United

States’ marine boundary, less than one km from the proposed RBT2. Note how outflow from the Fraser

River travels far into Georgia Strait, thus affecting all of the marine life there.

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Figure 3.

3.4 Salinity and Biofilm – Misinterpretation by VFPA

3.4.1 Changes in salinity

The EIS does state that there will be changes in salinity. The analysis of the changes by VFPA is not

clear. It is known that salinity changes will be permanent because of the nature of the structure which

will be placed more or less perpendicularly to the outflow of the Fraser River. As the EIS states, even

though the biofilm/phytoplankton/diatoms might “…experience high variability in water quality and

chemistry…” (Section 11.6.3.5), this statement is taken out of context and does not refer to what would

be a permanent change in salinity and turbidity of the Roberts Bank area. The freshet conditions that

marine diatoms use to support their tolerance of fresh water are very short-lived in the current Roberts

Bank ecosystem, and the biofilm has adapted to this pulse and indeed has geared its blooming time to

this pulse (Brett et al. 2009, Galloway and Winder 2015). The EIS then states that the “…increased

freshwater influence is predicted to reduce the productivity of specific biofilm areas during freshet

conditions” and that “…more than 50% of the biofilm at Roberts Bank will experience lower mean water

column salinity compared to existing conditions…”. That is an extremely big proportion of phytoplankton

that will not be available to shorebirds, zooplankton, fish, and the rest of the heterotrophic food web. It

is precisely during these freshet conditions when Ω-3 fatty acids produced by diatoms become available

to the entire food web.

The EIS actually states that a decreased salinity will harm the biofilm. They predict that this

“…osmotic stress…” will lead “…to decreased productivity or cell death.” If this is the result, then it is

clearly obvious that the essential Ω-3 fatty acids found at Roberts Bank will not be available to the

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heterotrophs dependent on marine phytoplankton. They predict that salinities will have a mean of 5.8

PSU (Practical Salinity Unit))and that there will be a “…decrease in productivity for the marine-

influenced biofilm assemblage during freshet…” and that the mean water column salinity “…is expected

to remain above 10 PSU.” Where they have obtained this precise information is not clear; neither is it

certain that these statements are correct. They continue that the “…optimal salinity range for biofilm

productivity is not well understood…” and that is true. They then cite a salinity tolerance range of

biofilm assemblages that do not ever occur at Roberts Bank, so it is unclear what the point of their

argument is.

Their final statement in Section 11.6.3.5 page 11 - 77 is that the “…predicted decrease in salinity

suggests a potential for reduced productivity in areas of biofilm, primarily in the predominantly marine-

influenced biofilm assemblage near the Roberts Bank causeway.” This is the precise area that is critical

habitat of the diatoms which transfer of essential Ω-3 fatty acids up the food web to zooplankton, Fraser

River salmon, and migratory shorebirds. In fact, the Causeway will cover a large area where biofilm

occur at present.

3.4.2 Inadequate Knowledge on How the Entire Ecosystem at Roberts Bank will be affected - The

Precautionary Principle

There is much that is unknown about the Roberts Bank ecosystem and the changes that will occur if

the natural ebb and flow of nutrients and seawater with their suite of different abiotic conditions.

Because so much is unknown, and because so much can be altered in the ecosystem by the construction

of VFPA’s RBT2, the Precautionary Principle definitely needs to come into play. VFPA states that “…due

to the relatively recent understanding of biofilm to science…” , “…previous examples of observed effects

of similar (to RBT2) industrial development to biofilm are not available. Hence there is not precedence

to support the predictions made here…” (page 11 - 81). Actually, studies from the Austral-Asian flyway,

mentioned earlier, have shown that a disruption of the intertidal food web has indeed irreversibly

negative effects on bird migration.

Finally, the fact that VFPA combines freshwater and marine biofilm in their summary of biomass

changes reveals a poor understanding of how this ecosystem works currently (Appendix 10-C). Most

definitely the freshwater-influenced biofilm do not have the potential to offset losses of marine biofilm.

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3.5 Energy vs. Productivity – the Quality of Nutrients is More Important than the Quantity

3.5.1 Chlorophyll α is the Wrong Parameter to Measure

VFPA cites primary productivity as the main parameter to measure, which reveals little

understanding of how the food web at Roberts Bank operates. As mentioned previously, they assume

that energy and productivity should be assessed using chlorophyll α. All plankton models used in the EIS

are converted to Energy and Productivity using chlorophyll α, some measured by hyperspectral sensors

“to test the accuracy of the biomass estimate.” Spectrophotometry and pigment analysis were used to

estimate this, and from the EIS: “As pigment presence and density are often taxa specific (Millie et al.

1993), the use of narrow band imaging can identify taxa present, estimate biomass, and map the spatial

extent of the entire biofilm community with minimal disturbance.” VFPA spent an inordinate amount of

time analyzing the various pigments in the biofilm (under “Laboratory Techniques; Analysis”), but the

presence of these various amounts of chlorophyll and other pigments explain little about the quality of

the biofilm present.

VFPA used hyperspectral mapping to estimate the extent of “biofilm-dominated substrates.” They

did not collect specimens and did not identify proportions of the different species assemblages. Likewise

they did not analyze the samples for presence and type of fatty acids. The hyperspectral mapping also

did not occur at the time when the shorebirds stopped at Roberts Bank on their northward migration.

Therefore, their statements of “causal relationship” or their deduction of “whether or not loss of biofilm

is critical” has no basis in Science.

3.5.2 Quality of the Food Web Depends on the Amount of Omega-3 Fatty Acids Present in Marine Biofilm

Throughout the EIS, the recurring mistake made about amount of nutrients for shorebirds, fish,

zooplankton, or any fauna in the food web, terrestrial or marine, is that all plankton models are

converted to Energy and Productivity using chlorophyll α. However, it is the Ω-3 fatty acids in diatoms,

not chlorophyll α that are the keystone nutrient for shorebirds foraging at Roberts Bank. This, not

energy per se is the critical ingredient necessary for the long migratory leg from BC to Alaska that

shorebirds take. Chlorophyll α is ubiquitous in marine ecosystems, from the poles to the tropics, and Ω-3

LCEFAs only occur in a few select places because of the exact abiotic factors that occur there necessary

for diatoms to bloom – as at Roberts Bank or at Arctic ice edges. VFPA did not address Ω-3 fatty acids at

all and did not measure the amounts of fatty acids within the various species. Thus the EIS has little

information regarding how important are the particular biofilm species for the food web (see Kattner

2007, Budge et al. 2014, Galloway and Winder 2015, Twinning 2015,). As stated earlier, the quality of

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the biofilm is determined by the Ω-3 fatty acids (LCEFA) composition of algae (phytoplankton) which in

turn is an important determinant of their food quality (Taipale et al. 2013). And it is the particular

species assemblages present at various times of the year that determine the Ω-3 fatty acid contribution

as a nutrient source, and these amounts of Ω-3 LCEFA vary spatially and temporally throughout the year

(Underwood 2005, Beninger et al. 2011, Kuwae et al. 2012, Jimenez 2013, Jardine et al. 2015).

3.5.3 Use of Chlorphyll α as Proxy for Importance of Biofilm in EwE (Ecopath with Ecoism) Model Displays

Lack of Understanding of the Ecosystem

The EwE model addresses primary productivity only (chlorophyll α) and energy transfer up the food

web, and does not distinguish components of this energy such as LCEFA. As summarized previously, not

all energy is the same, and all carbon is not equal. (Matthias and Becker 1990, Kattner et al. 2007,

Budge et al.2014, Galloway and Winder 2015, Twinning et al. 2015) The quality of the food, not the

quantity has to be assessed. It is only the LCEFA that are important, not just bulk carbon. This is evident

because heterotrophs selectively uptake PUFA and HUFA from all nutrients available to them. Section

10.3 characterizes ecosystem productivity and quantifies project-related changes in biomass- not

changes in species composition or characterization/ identification of omega-3 fatty acids. They looked at

primary productivity only.

In the EIS Section 12.5.1.4 Key Habitat Features, is mentioned that the total organic carbon, TOC,

constitutes “