Government of Canada


Need to Address Real Environmental Impacts in a Revised and New Canadian Assessment Act and Associated Regulations Received Dec. 23, 2016

Submitted By: Otto Langer January 09, 2017

To: Expert Panel on CEAA Review.
I thank you for the opportunity to attend the CEAA review meeting of Dec 12, 2016 in Vancouver BC. I noted to one of your staffers (Bradley) that i had submitted a brief on this review task in July 2016. I was advised to re-submit that brief it in that the panel has been appointed and the review is nearing its final public input phase. Bradly was particularly interested in the Fraser River jet fuel project that I again mentioned in the workshop as to why CEAA now is simply not working in terms of the public interest as related to public safety and the sustainability of our environment. This project is described in my attached brief and two attachments with that brief.
In summary of that terrible EIS process consider the following:
EIS of Jet Fuel terminal in the Heart of the Fraser River Estuary:
The airlines fuel corporation (VAFFC) at Vancouver International Airport is now building a jet fuel dock in the middle of the Fraser River estuary (City of Richmond) so supertankers of cheaper offshore jet fuel can come into the river and there be offloaded and stored in a large tank farm on the edge of the estuary. The fuel will be transported across Richmond in a new pipeline to the airport. This facility was terribly assessed by the Province of BC in harmony with Port Vancouver (who was absent during most of the review) that can be best described as a very low bar environmental assessment as described by a BC Supreme Court Judge (VAPOR vs BC AG and VAFFC 2016).
Also of disappointment was the fact that the federal agencies like EC and DFO did not participate in any public review of the project. No open public hearings were ever held by Port Vancouver or the BC EAO. The token federal participation in the review was mainly by Port Metro Vancouver (PMV). They will lease land to the project and have approved the project on behalf of the Federal Government. This is the type of assessment and approval is an extreme conflict of interest that we could only expect to take place in some distant 'banana republic'.

In 1988 the Federal Government (FEARO) held a public panel review of a much smaller but similar jet fuel project in the river by the same proponent and rejected it due to the risk such highly toxic and flammable fuels would pose to public safety, the river and its life
In that this is a federal port, involves federal land, is home to a large international federal airport. cannot be separated from climate change issues, is home to th world's largest populations of salmon in a single river system, is protected by the federal Fisheries Act, it home to large migratory bird populations protected by federal law, is governed by the NWPA and Canada Shipping Act and a federal pilotage authority etc why was this high risk projects in one of Canada's most sensitive and productive habitats not been subject to a full and proper CEAA Panel Review? Why would we now have less public consultation and environmental protection than we did 27 years ago (i.e. in 1988-89)?

Your review must upgrade CEAA and ensure that other major Fraser River projects such as the Tilbury LNG, Roberts Bank Terminal 2 and the new Richmond - Delta Bridge gets a proper federal assessment. Time is of the essence because while we dither about legislation and the legislatiive process, many of these highly destructive projects will have been built!
Finally I do t not feel the format of the workshop I attended was well set up to allow the Review Panel to really see the problems associated with economic growth, adequacy of the environmental reviews process and much needed real environmental protection.
Sincerely yours,

Otto E. Langer Fisheries Biologist and Aquatic Ecologist 604 274 7655

On 7/20/2016 2:48 PM, Otto Langer wrote:
CEAA Staff:
Attached are my rush comments on the Terms of Reference for the CEAA TofR expert panel review. Generally they are acceptable subject to my comments. In that this is bound to be a lengthy process from this stage to promulgation of new or revised legislation it is urgently requested that a moratorium be put on any pending project in highly sensitive ecosystems in Canada (eg. Fraser River Estuary) so as the projects can be properly assessed by a new CEAA and associated legislation such as HADD (habitat protection) once it be brought back into the Fisheries Act.
In that this process will develop like a CEAA Panel project review I am concerned that it may become rather drawn out, overly legalistic and bureaucratic. Accordingly I have attached my overall comments on the actual review of CEAA for the panels consideration even though they have yet to be appointed. I do not know my whereabouts when the panel may ask for comments or come to Vancouver later this year.
Otto Langer
Fisheries Biologist

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