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Legislative Office:

Room 145, Parliament Buildings


Victoria, B.C. V8V 1X4

Phone: 250 952-7594


Fax: 250 952-7598
e-mail: icki.Huntington.mla@leg.bc.ca

Legislative Assembly
Province of British Columbia
Vic i Huntington, M.L.A.

(Delta South)

Constituency Office:
4805 Delta Street
Delta, B.C. V4K 2T7

Phone: 604 940-7924


Fax: 604 940-7927
www. ickihuntington.ca

October 3, 2016

Michael Shepard
Project Assessment Manager
Environmental Assessment Office

PO BOX 9426 Stn Prov Govt


Victoria, BC V8W 9V1
Re: Proposed Information Requests on the George Massey Tunnel Application for an En ironmental
Assessment Certificate - Comments from Vicki Huntington. MLA Delta South
General Comments
There are a number of unfounded assumptions and gaps in information that need to be addressed for
the environmental assessment to proceed in a meaningful way. It is my hope that my submission will
help ensure the environmental assessment process can accurately assess the project's environmental
effects.
For example, by the proponent s own admission, a change in the toll (or a regional tolling plan) could
affect the project's use by tens of thousands of vehicles a day, with consequent implications for the
project's environmental effects. The proponent has yet to set an official toll rate, which injects
significant uncertainties into the assessment process. Similarly, the proponent makes a number of
statements about agricultural land that demonstrate a fundamental ignorance of development
pressures in the region. Additionally, proposed mitigation strategies for environmental effects are often
presented without detail.
I hope the proponent will address the issues I've raised to ensure the claims about the project are
founded on solid evidence, and that the mitigation measures proposed will adequately address the
Project's environmental effects.

Vicki Huntington, MLA


Delta South

4.4 Fish and Fish Habitat


(43) 4.4.4.4: The proponent states that changes in fish habitat quantity resulting from permanent fish
habitat loss will be avoided through the implementation of a Fish Habitat Offsetting Plan, which has not
yet been developed. This lack of detail is unacceptable given the significant difference between total
habitat loss and planned habitat enhancement provided by the proponent. Table 4.4-5 in Section 4.4.3
(p. 36) shows an estimated instream and riparian area habitat loss of 7,734 m2 and 3,734 m2,
respectively. Habitat enhancement projects are estimated to add instream, riparian and shallow subtidal
areas of 1,700 m2, 1,275 m2 and 125 m2, respectively (p. 42; 4.4.4.3). Overall habitat loss would
therefore total 8,368 m2, before offsetting measures are taken into account. Given the substantial size
of this habitat loss, and that affected areas include highly productive (red-coded) tidal brackish marsh,
and intertidal and shallow subtidal channel areas of Deas and Green sloughs, the proponent should be
required to present a Fish Habitat Offsetting Plan. As the proponent states, Fish habitat loss has the
potential to affect fisheries productivity, because it may result in a measureable reduction in the
sloughs productive capacity as year-round rearing habitat for CRA fish, including juvenile Pacific
salmon (p. 35; 4.4.3). This risk of any potential reduction in productive capacity should be better
quantified before judgment is rendered on the Application.

4.8 Terrestrial Wildlife Assessment


(9) 4.8.2.1: The proponent says it follow[ed] methods adapted from the [B.C. governments] Inventory
Methods for Raptors (RIC 2001), except for the fact that their vehicles drove 20 km/h faster than
recommended to complete the raptor survey. The proponent says this was to ensure safety while
driving on the highway; however, one can envision scenarios (for instance, through the use of assistance
vehicles) where a 40 km/h survey would have been possible. The Resources Inventory Committee (RIC)
is clear that Vehicle speed should not exceed 40 km/hr. They state that Roads and secondary trails
are used as transect routes along which a vehicle is driven at low speed in one direction while at least
two observers scan the countryside for perched and soaring raptors. Low speed appears to be an
important factor in conducting an accurate raptor survey. The RIC also notes that vehicle surveys have a
number of disadvantages vs. surveys on foot. The proponent should explain how it can be at all
confident in the validity of its raptor survey given the adjustment in speed in clear opposition to B.C.
government standards.
(16) 4.8.2.3: The proponent estimates current barn owl mortalities in the LAA are 20 individuals per
year, but notes that mortality data is not regularly collected along Highway 99. All wildlife strikes along
the South Fraser Perimeter Road (SFPR) are currently recorded daily and tracked by the Ministry of
Transportation and Infrastructure; the proponent should likewise be required to track mortalities by
species in advance of construction and through project operation, to establish better baseline
population data and ensure mitigation measures are as effective as possible.
(42) 4.8.4.3: The proponent suggests increased traffic volume as a result of the Project will lead to a
very small increased collision risk for barn owl within the Project alignment, and directs readers to
Section 5.1 Traffic. However, traffic assumptions based on an untolled bridge scenario which is the
proponents baseline worst case scenario show an increase of annual average daily traffic volumes
(AADT) at the new bridge by more than 30,000 from current volumes by 2030 . This would represent
roughly 40 per cent higher daily traffic volumes at this location. The proponent should provide further
evidence and analysis that an increase in traffic volume of that magnitude would pose only a small
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increased collision risk for barn owls along the corridor. Further, the proponent does not show how
traffic volumes are expected to increase under this scenario along the length of the LAA. It should be
required to do so, as it would provide a more detailed portrait of the risk profile in different road
segments. The majority of the surrounding habitat that will have moderate foraging value for barn owls
is located along the Highway 99 stretch in Delta.
(42) 4.8.4.3: The proponent states that addressing collision risk for barn owls during the development of
the SFPR with hedgerows and fences has been effective in reducing mortality risk. The proponent does
not cite any research or data related to this experience and it should be required to do so. The
proponent also states that hedgerows and fences will be erected in high-risk areas within the Project
alignment, but does define these areas. The proponent should specify what areas will be classified
high-risk in relation to the maps provided in Appendix B (Figures 5b-5p).
(42) 4.8.4.3: It is noted that to be fully effective as a mitigation measure, hedgerows must reach 2 to 3
metres in height, which may take ten years to attain. The proponent notes that planting hedgerows in
advance of Project operation will expedite this process, but given the average age of barn owls in the
region is 2 to 3 years, this time lag may still represent 2 to 3 generations of barn owls before the
mitigation is deemed effective. The proponent should offer solutions that do not delay implementation
of this mitigation measure.

4.9 Air Quality


(5) 4.9.1.2: Segment 1 should be extended to include the Oak Street Bridge, to better capture the full
scope of added congestion generated by traffic induced by the Project. Currently, the boundary of the
segment stops at Bridgeport Road, which is roughly a kilometer from the Oak Street Bridge.
(5) 4.9.1.2: Emissions data are based on conservative traffic modelling assumptions under the untolled
bridge scenario (TL-RTM Untolled) from Section 5.1.2.4. Given the disparity in traffic volume estimates
between both a tolled and untolled option, the proponent should include emissions analysis of tolled
options for comparison and include emissions estimates from induced demand from the new bridge.

5.1 Traffic
(2) 5.1.1.1: The proponent claims the Project will reduce congestion on adjacent municipal streets,
which can provide future benefits to local area social and economic values. The proponent does not
appear to have backed up this claim with evidence. This section does not appear to contain any traffic
analysis on adjacent municipal corridors. This is particularly concerning given the potential for significant
traffic diversion once the Project is in place, as evidenced by the proponents estimates for traffic
increases at the Alex Fraser Bridge of 33,000 AADT by 2045 from 2014-2015 levels (p. 19; 5.1.2.4.2). The
proponent should model scenarios that estimate the effect the Project will have on important municipal
traffic corridors.
(4) 5.1.1.3: Assumptions related to traffic forecasts for the new bridge have been based off the Port
Mann Bridge tolling framework. The proponent should specify in more detail the exact assumptions
that have been carried forward into this analysis. For example, the Port Mann Bridge began with a
reduced small vehicle toll rate of $1.50 for the first year before increasing the rate to $3.00 in 2014 and
later $3.15 in 2015.

(16) 5.1.2.4.1: The proponent presents two model scenarios between 2030 and 2045 one tolled [GMT
(TL-RTM Tolled)], the other not [GMT (TL-RTM Untolled)] with traffic volume differences higher than
40,000 annual average daily traffic movements. This represents more than half of current daily volumes.
The proponent states that the majority of this difference applies to drivers who avoid crossing the river
at all or divert to the Alex Fraser Bridge, primarily during off-peak periods and weekends. The
proponent should specify why it believes the majority of the difference will come from these changes,
given TransLinks RTM does not permit exact estimates of travel pattern changes in terms of not
crossing the river, diversion to an alternate crossing, or changing modes.
The proponent should also provide further rationale or justification for the conclusion that traffic
diversion to the Alex Fraser Bridge would occur primarily in off-peak periods and weekends.
(16) 5.1.2.4.1: The New Bridge Growth Forecast uses an annual auto growth forecast of 0.65 per cent,
which the proponent claims is consistent with recent-year trends for Richmond and Delta traffic via the
Tunnel and AFB, and at about half of RGS population and employment growth forecasts for south-ofFraser municipalities. Annual truck growth is pegged at 1.5 per cent and based on similar recent-year
trend data. The proponent should explain the discrepancy between these growth rates and historical
data for the Massey Tunnel presented in the George Massey Tunnel Replacement Project Traffic Data
Overview (p. 1; Figure 1; Appendix B), which show no growth in AADT at the Massey Tunnel since the
late 1980s, and a slightly negative annual growth rate of -0.36 per cent between 2003 and 2014 (p. 20,
Table 1, Appendix B). Combined traffic growth from both the Massey Tunnel may show 0.64 per cent
annual increases between 2003 and 2013, but as the proponent notes The AFB has absorbed almost all
of this growth, because of the lack of available capacity at the Tunnel (p.1; Appendix B). Growth at the
AFB during this time period has increased by 1.51 per cent per year (p. 2; Appendix B). Likewise,
modelling in the Traffic Data Overview estimates that traffic through the Tunnel will grow to
approximately 100,000 vehicles per day by 2045 (p. 13; Appendix B). The discrepancy between the lack
of historical growth at the existing Tunnel and this estimate is not explained.
(19) 5.1.2.4.2: The proponent estimates daily traffic volumes will increase at the Alex Fraser Bridge
under the With Project and Tolled scenario by 33,000 AADT from 2014-2015 levels, which represents a
31 per cent increase. These volumes are 20,000 AADT higher than the comparison scenario without the
Project. Given the proponent has stated TransLinks RTM does not permit exact estimates of travel
pattern changes in terms of diversion to alternative crossings like the AFB (see p. 16; 5.1.2.4.1), the
proponent should further explain how it was determined that this increase is primarily because of offpeak diversion from the tolled facility to the untolled facility (p. 18).
(19) 5.1.2.4.2: The Project is expected to increase traffic volumes at the Alex Fraser Bridge by 20,000
AADT by 2045, in comparison to a scenario without the Project. This represents a total increase of
33,000 AADT from 2014-2015 levels. As noted in the Traffic Data Overview (p. p. 2, Figure 3; Appendix
B), AFB already experiences significant congestion during rush hour periods. This is an unsustainable
situation and the proponent should prepare analysis of an upgraded AFB and/or a regional tolling policy
in the future, as additional modelled scenarios for consideration.
(24) 5.1.3.2.1: The proponent claims the Project will support provincial and regional strategies to
encourage mode shift to transit and carpooling by providing dedicated transit/HOV lanes along the
Highway 99 corridor. However, providing dedicated lanes does not guarantee significant increases in
ridership, and is not the same as increases in service. The proponents traffic model analysis predicts
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transit mode share over the future bridge will increase between 5-10 per cent by 2045, as compared to
a scenario without the Project. The Traffic Data Overview cites 2014 transit mode share at 0.7 per cent
of daily traffic volumes (p. 20, Table 2, Appendix B), but does not cite transit mode share scenarios
without the Project. An increase of 5-10 per cent by 2045 from 2014 mode share of 0.7 per cent is of
marginal impact and it is misleading to suggest the Project supports provincial and regional strategies to
encourage mode shift to transit. While daily HOV mode share is higher, at 16.6 per cent in 2014 (p. 20
Table 2, Appendix B), a 5-10 per cent increase by 2045 from this level would only increase overall mode
share by between 0.6-1.6 per cent. Similar arguments hold for levels of cycling mode share increase
expected from the Project given how low current mode share levels are.
(14) Appendix B, Section 5: The analysis of laning requirements in this section does not indicate whether
the 8-lane and 10-lane bridge scenarios under consideration were modelled using a tolling scenario
similar to previous assumptions in other sections (e.g., Port Mann tolling structure). This is a critical
omission, as it underpins the rationale for choosing a 10-lane bridge. The proponent argues the new
bridge requires 10 lanes, as opposed to eight, to avoid peak-period congestion on opening day (see p.
29, Appendix B). There are significant differences in traffic estimates between tolled and untolled bridge
scenarios. Tolling is projected to reduce traffic volumes at the new bridge by roughly 40,000 AADT by
2045 (p. 15, Figure 5.1-2; 5.1.2.4.1). This is more than half the current volume at the Tunnel. Given these
dramatic effects on traffic volume, and given the critical importance these traffic numbers will have on
Valued Components in the application, such as terrestrial wildlife, atmospheric noise, air quality, land
use and human health, the lack of specifics is of critical concern and should be clarified before
proceeding further.
Further, the proponent does not sufficiently justify the argument that an 8-lane bridge would result in
peak-period congestion on opening day. As previously mentioned, traffic volumes at the Tunnel have
remained relatively flat since the late-1980s and have showed a slight annual decrease in volume since
2003 of -0.36 per cent (p. 20, Table 1, Appendix B).
(29) Appendix B: The proponent argues The absence of an additional lane for slow moving and weaving
traffic would lead to heavier congestion; compromising travel times for the faster moving through
traffic. This statement should be justified with reference to relevant research and specifically quantify
the compromised travel times.
(18) Appendix C: The only mention of induced demand the Project will have on traffic volumes appears
in the Steers Davies Gleave consultant report. Induced demand should be considered when evaluating
traffic forecasts under different modelling scenarios. Other scenarios used by the proponent in the
application should likewise comment further on the induced demand assumptions contained in each
scenario.

4.10 Atmospheric Noise


(26) 4.10.5.2: Many of the locations in Table 4.10-5 show significant increases in dBA post-Project and
are located in Deas Island Regional Park, with some locations showing increases ranging from 7 to 11
dBA. Though the increases do not exceed the Ministrys noise policy threshold for moderate impacts,
more should be said on the effect this increase in noise may have on wildlife that lives in the park.

(26) 4.10.5.2: The proponent should document in more detail exactly what mitigation measures are
planned for each location. Residents and other property owners and tenants deserve a specific outline
of how their neighbourhoods will change, both with the Project and with planned mitigation measures.

5.2 Marine Use


(9) 5.2.2.1: The proponent notes multiple shortcomings in its desktop review of marine traffic, which did
not accurately account for all commercial or pleasure vessels or guided sport fishing. These shortcoming
could have been addressed through on-site monitoring.
(30) 5.2.3.2: The proponent notes that recreational vessels with a reduced draft will be less affected by
infringement on access during construction. The proponent does not seem to account for the possibility
that recreational users may avoid recreating altogether due to the presence of construction activities
(due to safety, visual quality, or noise concerns, for example), regardless of the availability of access for
reduced draft vessels.
(31) 5.2.3.2: The proponent notes that the public raised changes to marine use by deep water vessels as
a potential issue, and further notes that revised projections (not due to the Project itself) predict a 10
per cent increase in such traffic. Additionally, the proponent notes that the proposed draft is similar to
the Alex Fraser and was determined in conjunction with the Port. Given the high level of concern about
increased deep water vessel traffic resulting from this project, a detailed plain-language analysis of
water and air draft that speaks directly to the publics concerns about marine traffic increases is
warranted.

5.3 Land Use


5.3: Rapid transit is mentioned once in the 99-page land use assessment. It is listed as one of the
Projects goals and attributes, i.e.: The bridge will accommodate future rapid transit. There is no
discussion of a timeline for that aspect of the Project, as well as how it might affect land use and sprawl
or densification.
Elsewhere in the document, the proponent writes The new bridge also is designed to accommodate
future rapid transit as population density and transportation demand south of the Fraser increases in
the future. There should be a discussion and modelling of how the Project, with and without rapid
transit, will affect population density and transportation demand. If rapid transit is a goal and attribute
of the Project, then it should be documented in detail as a likely effect of the Project. The phrase rapid
transit currently appears on ten pages out of 4,418; LRT or ALRT does not appear, other than in the
Acronyms and Abbreviations section.
(11; 28) 5.3.2.3: The proponent makes reference to privately held land in its section on land ownership
without providing a breakdown of what organizations or individuals are holding that land. The title
information is available to the proponent, and current owners include organizations such as holding
companies and land developers. The proponent should discuss the types of organizations holding this
privately owned land to make more accurate conclusions about future land use. For example, a housing
developer holding ALR land (e.g., 026-302-365) likely has different plans than an agricultural firm holding
the same land. The proponent makes a number of conclusions on the basis of The majority of land
within the Delta portion of the LAA [being] classified as agriculture. These conclusions should be reexamined, as the baseline information used is misleading. This work should be conducted throughout
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the LAA, and modeled on the detailed information on ownership provided in Figure 5.3-9 and Table 5.37.
(19) 5.3.2.4: The proponent mentions Vancouver Fraser Port Authoritys land use plan without
discussing its stated desire for 2,500 acres of industrial land. This goal will have a large impact on land
use in the region and should be considered in the land use assessment.
(63) 5.3.3: The proponent distinguishes between the Project and new transportation infrastructure and
concludes that the Project will not change the distribution of population, but encourage denser, land
intensive, high quality forms of development within existing land uses. The proponent also believes the
Urban Containment Boundary and ALR will stop sprawl.
The premise that ALR land is sacrosanct and development pressures on that land will not increase as a
result of the Project is false. The proponent acknowledges elsewhere in the document that there are
development and speculative pressures on ALR land along the corridor. Additionally, multiple ALR
parcels that are involved in the Projects agricultural mitigation process are currently held by holdings
companies, including property developers. The proponent goes so far as to propose mitigating measures
(e.g., planting trees) to diminish the likelihood of the development of ALR land along the corridor after
the Project is complete. The proponent cannot reasonably conclude that the ALR, in tandem with the
Project, will lead to densification and development of existing land uses. This section is poorly argued
and should be re-written with a better grasp of current speculation on ALR land.
(66) 5.3.3.4: The proponent cites the Golden Ears Bridge as increasing land values in the region of the
bridge due to improved access. Yet the proponent also says There is no potential for the improved
[Massey] river crossing to lead to the conversion of non-development land into development land,
and Given the strength of existing land use policies such as the Agricultural Land Reserve [etc.,] any
significant changes in this regard are considered unlikely. These statements should be challenged,
particularly in light of the number of developers holding ALR land, and the net loss of 377 hectares of
ALR land in the South Coast since 2009. In addition to conducting a baseline study that looks at
purchasing trends since the announcement of the Massey Replacement Project, the proponent should
discuss what pressures the Project will place on agricultural land and land prices, and what that will
mean for food producers.

5.4 Agricultural Use


(7) 5.4.1.3.5: The proponent should be more specific about future pressures due to population and
economic development, and incorporate that knowledge into its assessment. There are known parcels
of ALR land in the RAA still under option likely for the purposes of development (e.g., those held by the
Emerson Group in Delta; 774 acres owned or optioned by the Emri Group on Barnston Island; and ALR
land owned by the Port of Vancouver in Richmond). The Port has also stated in its land use plan that it
requires 2,500 additional acres of industrial land to accommodate future trade.
(12) 5.4.2.3.1: The proponents data on the net change to South Coast ALR lands in recent years is both
incorrect and misleading. The ALRs annual reports for the South Coast region report the following
changes:

Table 1 Net Change in ALR Land, South Coast

ALC
Report
2015/16
2014/15
2013/14
2012/13
2011/12
2010/11
2009/10

Ha
Inclusion
0
0
+7
+43
+39
+14
+11

Ha
Exclusion
-22
0
-56
-5
-3
-5
-400

Net
Change
-22
0
-49
+38
+36
+9
-389

The proponents numbers, allegedly drawn from the ALCs 2011-12 to 2014-15 reports, are simply
inaccurate, and do not reflect conditional and final approvals for inclusion and exclusion. The proponent
says there has been a net increase of 63 ha over that time period; the actual increase reported by the
ALC is 25 ha. However, even that number would be misleading. If you add the latest 2015/16 report, the
net increase drops to 3 ha. If you add in the 2009-10 and 2010-11 reports, which are readily available,
the ALC reports a net decrease in South Coast ALR land of -377 ha. Its imperative that accurate baseline
and trend information be used to inform the proponents analysis of agricultural impacts, and to allow
for an accurate environmental assessment of the Projects effects.
(34) 5.4.3.2.3: The proponent should provide evidence that visual landscape buffers alongside a 10lane bridge will intensify agricultural production on adjacent ALR lands and keep it from being held for
speculation.
(41) 5.4.4.3.1: The agricultural mitigation strategy relies heavily on the consolidation of adjacent
properties. The proponent says it is developing farm-specific mitigation plans in consultation with the
ALC and affected land owners. If the landowners do not agree to a consolidation proposal with former
crown lands, or if they do not develop those consolidated lands in a timely fashion, or at all, then the
mitigation of the Projects agricultural effects will fail. Agricultural plans for those former Highway 99
right-of-way lands should be established now. If agreements have been reached and mitigation plans
(i.e., strategies to develop their new lands) have been established with the landowners, those details
should be released.
(43) 5.4.4.4: The proponents agricultural mitigation primarily relies on adding Highway 99 right-of-way
lands to the ALR. However, that plan is met with significant hedging: If all 21.4 ha of the available land
within the Highway 99 ROW are eventually developed for agricultural use, a net gain of
approximately 1.4 ha of agricultural land will be achieved (emphasis added). The proponent should
provide a detailed plan and timeline outlining how and when all of the ALR offsets will succeed. If more
than six per cent of the new agricultural land is not put into production, the Project will result in a net
loss of agricultural land.
(43) 5.4.4.4: The proponent clearly breaks down the soil classification of the lands being excluded in the
main document. It should do the same for the lands that are intended to be added to the ALR, instead of
noting that It is anticipated that the land that will be made available for agricultural use would be of
similar or better capability(emphasis added). More details on this land are available to the proponent
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(see, for example, the proponents application to the ALC), and they should be included in the
environmental assessment process.

5.5 Visual Quality


(8) 5.5.3.1: The visual quality assessment was conducted during clear, sunny days to provide optimal
viewing conditions. Visual quality at night or on an overcast evening would be affected by lighting on
the bridge and traffic (e.g., headlights) on the bridge where currently there is none. These baseline
conditions should also be measured through fieldwork to establish the Projects effects on visual quality
under these circumstances. Simulated future visual conditions under evening, nighttime, and overcast
conditions should be provided. There are no references to bridge lighting, traffic (i.e., the presence of
visible traffic that would previously have been in a tunnel), or external factors such as night, darkness, or
overcast or cloudy conditions resulting in any effect on visual quality conditions. All of these factors may
change how the Project affects the visual quality conditions at any given viewpoint.
(Appendix B) 5.5: The simulated photos do not accurately reflect the human field of vision or the visual
quality changes that an individual would experience at a given viewpoint. If the photos are meant to
simulate the future viewscapes from the locations provided, then they should encompass the full visible
span of the proposed bridge from those viewpoints. The following simulated photos do not accurately
capture the future visual conditions of the viewpoints. Panoramic shots should be provided to accurately
represent changes to the visual quality of the landscape: Figure 2; Figure 4; Figure 10; Figure 14; Figure
16; Figure 20; Figure 22; Figure 24; Figure 30; and possibly Figure 32.

7.0 Human Health Effects Assessment


(1) 7.0: The first highlight for health effects is improvements in local and regional air quality, primarily
due to reductions in congestion-related idling, are anticipated to have a positive effect on human
health. See critiques elsewhere in this submission regarding traffic projections, which would affect the
proponents conclusions about the Projects human health effects.
(1) 7.0: The Project is anticipated to improve health equity by providing disadvantaged groups with
better access to reliable transportation options. There is no projection for rapid transit to be a part of
this project in the first ten years of its life. Additionally, estimates of improved transit times rely heavily
on traffic projections which are based on a tolling scenario that may not come to pass. The proponents
traffic model analysis predicts transit mode share over the future bridge will increase between 5-10 per
cent by 2045, as compared to a scenario without the Project. The Traffic Data Overview cites current
transit mode share at 0.7 per cent of daily traffic volumes (5.1, Appendix B, Table 2, p. 20). An increase
of 5-10 per cent by 2045 from existing mode share of 0.7 per cent is of marginal impact and it is
misleading to suggest the Project will support improved health outcomes for disadvantaged groups.
(10) The proponent states that agricultural production will not be adversely affected by the project.
See previous comments in sections 5.3 and 5.4 that undermine the proponents assumption. The
proponents statement does not hold, and the information on agricultural land and health effects should
be reconsidered in light of: increasing pressures on ALR land as a result of improved corridors; private
land developers holding ALR land in the LAA; the net loss of 377 hectares of ALR in the South Coast since
2009; and the lack of adequate measures to ensure the success of the proponents ALR offset plans.

(15) 7.2.5.10: The incidence of suicide associated with the Project, regardless of any safety fencing, is
likely to be much greater than that associated with the existing tunnel. The proponent should quantify
the risk and compare it with the installation of new bridges elsewhere (i.e., bridges that did not replace
an existing bridge).
(16) 7.2.5.11: The proponent says there will be a net gain of agricultural land that can be actively
farmed (emphasis added). This language is carefully worded, as it hinges on landowners bringing the
new ALR land into production. If the new ALR land is not brought into production, then the mitigation
will have failed.

8.0 Accidents and Malfunctions


(1) 8.1: The proponent defines an accident as an unexpected occurrence, unplanned event, or
unintended action that can result in an adverse effect. There does not appear to be any reference to an
act of terrorism and its potential effects on the Project and the environment.
(8) 8.3.1: The proponent states that The geographic extent of a spill would depend on the quantity of
the material spilled and location where it was spilled, after which it concludes that it is anticipated
that a spill would be localized in geographic extent. Given that the proponent acknowledges that the
severity of a spill would vary depending on location, they should outline a worst-case scenario to
determine whether their proposed mitigation measures will effectively mitigate the risk.
(16) 8.3.4: The proponent should outline the risks and consequences for the Project and the
environment assuming the explosion of a vessel carrying jet fuel, LNG, or other materials beneath or
near the Project.

9.0 Effects of the Environment on the Project


(1) 9.0: An explanation is required as to why post-mitigation consequences from which Recovery is
anticipated within 20 years of occurrence is deemed a low consequence.
(2) 9.1: The proponent uses data from 1994 to describe the climatic characteristics of the region and to
discuss the likelihood of climate extremes. The proponent should use more recent data to discuss the
likelihood of extreme weather events in the context of climate change.
(3) 9.1: The proponent provides no information on how it determined wind speeds over the course of a
typical year. They state that data was obtained from the climate station at the Vancouver International
Airport; however, there is no information on the timespan examined to determine whether or not the
information used is appropriate.
(3) 9.1: The proponent notes maximum temperature, daily rainfall, and daily snowfall. However, the
proponent notes that wind speeds rarely exceed[ed] 52 km/h (high wind). vancouver.weatherstats.ca
reports maximum wind speeds between 52 km/h and 82 km/h for every year since 1991, all above the
high wind metric cited by the proponent, as well as maximum wind gusts of up to 113 km/h. The
proponent is discussing extreme weather events and should include the maximum reported wind in
order to comment on and make determinations about extreme weather events, particularly as it notes
later that the Project will be designed to withstand maximum wind conditions.

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(3) 9.1: The proponent should explain why it chose wind data from the Vancouver International Airport
instead of other monitoring stations (e.g., South Richmond; Alex Fraser).
(4) 9.1: The proponent says The Project will be designed to withstand maximum wind conditions. The
proponent should make a clear statement on the measures that ensure the Project will not be
vulnerable to a high wind event in the same way as the Pattullo Bridge, as noted in the Pattullo
Bridge rehabilitation and condition monitoring Report.
(12) 9.6: The proponent should discuss whether or not extreme wind events are likely to increase as a
result of climate change, and if so, the consequences for the Project.

12.0 Management Plans


(6-7) 12.1.2: The proponent states that A monitoring program will be developed to evaluate the
effectiveness of the mitigation implemented as part of its Agricultural Management Plan. However, the
Agricultural Management Plan only refers to mitigating construction or temporary effects; it does
not reference the inclusion of Highway 99 right-of-way land into the ALR to offset the loss of over 20
hectares of ALR land, which is the Projects largest obvious agricultural effect. The proponent should be
required to develop and detail a monitoring plan to evaluate the success of its ALR offsets. E.g., if the
new ALR land is not put into productive use in a timely fashion, the management of the Projects
agricultural effects will be a failure. These changes need to be monitored and reported on to minimize
agricultural effects and ensure accountability. The Operation Environmental Management Plan does not
reference agriculture.

13.0 Monitoring and Follow-up Programs


13.0: The monitoring and follow-up programs make no reference to ensuring the ALR offsets are an
effect mitigation measure.

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