Sunbury Neighbourhood Association

March 2006 - Critique of the Engineering response to our presentation - see our comments in red below...





Mayor and Council




Environmental Services Division




September 6, 2005




 Response to Sunbury Neighbourhood Association Presentation


The following report has been reviewed and endorsed by the Chief Administrative Officer.


That this report be received for information.



To provide information relative to a presentation made to Council at the May 30, 2005 Regular Council meeting by the Sunbury Neighbourhood Association (SNA) regarding North Delta transportation issues.


 At the May 30, 2005 Regular meeting of Council, the SNA provided a presentation to Council regarding North Delta transportation issues and the proposed South Fraser Perimeter Road (SFPR).  This presentation included information on archaeology, heritage, socio-economic issues, engineering issues, noise, air quality, and habitat.  The SNA's background information to their May 30, 2005 presentation is included as Attachments A and B.  At this meeting, Council requested staff to provide additional information relative to the issues addressed by the SNA and this information is provided in the following. 


 The items below provide additional information from staff with respect to the issues addressed in Attachments A and B prepared by the SNA.

 Socio-Community Issues

 Staff's initial comments regarding the consultants' draft report on socio-community impacts of the SFPR were sent to the Gateway Program and the Provincial Environmental Assessment Office (EAO) in July. One of the staff comments is that the study has not adequately investigated the impacts on the Sunbury and Annieville neighbourhoods, particularly the potential for neighbourhood disturbance by traffic filtering through residential streets to access the SFPR if access roads are provided here.

 The Gateway Program staff are now meeting directly with SNA to address their detailed concerns, particularly regarding the possibility of removing planned access roads to the SFPR  in the Sunbury area.  Decisions regarding the route through this area have not yet been made, for example, whether the road would be placed on top of the railway or whether it would be tiered in part or a tunnel! These decisions will have to be made before the proposal is submitted to the EAO as a project for review, which is currently anticipated to occur in December 2005.  Until these decisions have been made, the following preliminary comments are provided with respect to the SNA's concerns about socio-community impacts:

Despite the fact that residents have expressed fervent opposition to access through the neighbourhoods and the fact that council sent a letter to Gateway opposing access to the SFPR at Centre, Delwood and Knudson Streets,….Gateway will only go so far as to say “unlikely” and “not contemplated” Can we get written confirmation that they are indeed gone? 

  • Staff agree with the SNA's conclusions that houses overlooking the SFPR and/or hearing noise from the SFPR are likely to suffer loss of property value when construction starts.  The recently released consultants' draft noise report suggests that mitigation measures will be necessary along the whole stretch of the proposed route from the Alex Fraser Bridge to Elevator Road.  More detailed studies need to be done before the effectiveness of the mitigation measures can be assessed. 

 Residents have already suffered loss of property value just on the speculation of the highway.  A noise mitigation wall that blocks more view than noise will send values plummeting.  Also, we want to be clear that negative impact noise will not only occur during construction but will also come from the 80 km highway after completion, despite ‘quiet pavement’ and newer technology in motors.

  • Along River Road, through Sunbury and Annieville, property values could possibly increase due to less truck traffic on the road, provided that there are no noise and visual impacts from the SFPR.  Less traffic could, in effect, return two village streets to the residents and a program of street beautification could be considered for these stretches of road.

 The possibility of no noise or visual impacts from the SFPR is impossible!  Have you not seen the plans? A four lane highway starting just west of the Alex Fraser Bridge and rising to clear the tracks at Center Street. “Twin superstructures”, 7.16m off the ground, (approx. 25’). The whole thing is canted to provide nearly 4.5m, (or 14+ feet), of cement for the houses on the south side of River Road to look at. They will not only hear it, but will see it, instead of the view of the river and mountains, a view that they paid for!  Houses further along River Road that might not look directly at the highway will still hear it and wear the particulate pollution blown up off the river.

  • Staff are not in a position to comment on the concern by SNA regarding destruction of the only waterfront view property in N. Delta.  Due to the slope of the land and depending on whether the road is one level or tiered, it may be possible for many homes to retain their views over the road to the Fraser River.

 The removal of up to 75 homes to be replaced with a highway will dramatically change the value of the homes left behind.  Having the neighbour’s house, beautiful trees and a ravine replaced by a tiered four lane highway will devalue a property even if a view is maintained.

  • Staff are also not in a position to determine whether the SFPR would lead to owners being replaced by renters and a “downturn” in North Delta demographics. The studies are proposing measures for mitigation of noise and visual impacts, and these measures need to be assessed in detail before any conclusions can be drawn.

 The destruction will be from the excess noise pollution and loss of property values.  The area will turn to rental properties and slowly degrade until only industrial development will be sustainable, as happened in Burnaby when residents were sandwiched between Canada Way and Highway #1. The same thing happened in Mallardville between Lougheed hwy and the freeway.  It took a few years, but there is industrial now, where there were once homes and families.

  • With respect to the SNA's proposal to tunnel along and under Nordel Way instead of placing a road along the riverside, this would be a very expensive undertaking.  Gateway estimates it would cost half of their total budget for the SFPR. Huge road improvements would also be necessary to 116 Street or Scott Road to take the traffic emerging from the tunnel back to the riverside and Surrey-Fraser Docks.  This would adversely impact the residential areas in the vicinity of these streets.

 Gateway’s estimates are $161 million for the highway option (not including a shed-style roof), and $400 million for the tunnel.  A difference of $239 million that doesn’t include loss of property values, loss of property taxes over the next 50 years, increased health care costs from the increased pollution, environmental costs,  nor the fact that a tunnel being straighter and more level will save time and money.  We have repeatedly asked Gateway to provide a breakdown of costs for comparison as their numbers seem to be taken out of the air.

 What huge road improvements are needed for 116 or Scott Road?  Our proposal has River Road coming down out of Annieville, laying on top of the east bound lanes of the tunnel and staying connected to Regal and old River Road (only one driveway in that section is at the current River Road grade, so almost all driveways will improve in slope). Grace road will overpass to Elevator road.  No HUGE improvements to 116 or Scott road and no adverse impacts for the residents in this area.

Air Quality

 The information provided by the SNA with respect to comments made by the Fraser Health Authority (FHA) and the GVRD were made during the initial phase of the pre-application for the environmental assessment of the SFPR.  Since this time the scope of the proposed project increased to include the western section of the road from Nordel Way to Deltaport Way.  The comments received from FHA and GVRD were incorporated into the new work plan for the local air quality study.   The draft Local Air Quality study has just recently been released to the BC Environmental Assessment Office (EAO) Working Group for the environmental assessment of the SFPR.

 The draft study uses outdated information,…is lacking quality data, is contradictive, and inadequate as noted in your review. Environmental sub-committee meeting report 13 (June, 16, 2005).

One concern raised by the SNA was that of the existing local air quality of the area.  In response to this concern Council resolved:

 “THAT a letter be prepared for the Mayor's signature to the Greater Vancouver Regional District requesting that their Mobile Air Monitoring Unit (MAMU) be positioned on River Road to provide baseline air quality information for this corridor.”

 Five percent of deaths in Canada are linked to air pollution.  Asthma and pulmonary disease increases dramatically near highway sources of PS2 particulate. Measuring River Road air quality will not accurately reflect highway conditions.  A UBC study concluded people living next to a major highway inhale up to 12 times more pollutants, experience more health problems and die sooner!  The worst pollution effects are within 300 meters of busy highways and you have an elementary school and playground within this distance, not to mention all the residents.  The study also found that major truck routes are particularly high polluters and elevated levels of diesel exhaust particulate (a probable human carcinogen) are found up to 750 meters away.  Now we are talking about three elementary schools and many more residents.  How much value do you put on the ability to breathe clean air versus pollution?

Attachment C is the June 9, 2005 letter from Mayor Jackson to Chair Marvin Hunt of the GVRD requesting air quality monitoring along the River Road corridor through North Delta.  Attachment D is the July 19, 2005 response from the GVRD to this request advising that prior to committing to conducting air quality testing they would like to review the draft Air Quality Study for the SFPR.     Since this study has just recently been released to the EAO working group, we expect that GVRD will be reviewing this study in the near future and providing further discussion with Delta regarding our request.


 The SNA report listed the results of the baseline noise monitoring program done for the draft Noise Impact Assessment for the SFPR.  The baseline monitoring indicated that the community noise levels along the River Road corridor were elevated due to the road and rail traffic as well as industrial noise. 

 The draft SFPR Noise Impact Assessment identifies noise increases over the baseline levels by the year 2021 for all of the six North Delta sites monitored for baseline noise if the SFPR is built along the currently proposed alignment.  The Ministry of Transportation (MoT) noise policy for mitigation is triggered by projected increases over the baseline noise ten years after project completion.   The draft report suggests that with the use of open graded asphalt (OGA), also known as “quiet pavement”, and conventional noise mitigation walls in some places, that the noise impacts from the SFPR could be fully mitigated in accordance with MOT policy.   Since the design is preliminary, more work is required to clearly identify the areas of noise mitigation once more detailed road designs are available.

 Noise pollution levels near a busy highway cannot be fully mitigated by ‘quiet pavement’ and noise mitigation walls.  People living near the highway will suffer the effects of noise pollution which will only compound health risks including cardio vascular disease.  Noise pollution takes away from the quality of life and reduces the livability of a region.

Staff have provided comments on the draft Noise Impact Assessment that includes the statement that OGA should be used in conjunction with conventional noise mitigation measures to meet the objectives of the MOT noise policy, not used alone to ensure consistent mitigation since it does not mitigate engine and braking noise.


 The SNA notes the information to be included in the environmental assessment application for the SFPR.  The majority of the public health issues to be investigated are associated with air quality impacts from the construction and operation of the road.  Health Canada and the Fraser Health Authority are represented on the EAO working group for the environmental assessment of the SFPR.

 Archaeology and Heritage

 The consultants' draft archaeological report is not yet available.  It will include an analysis of the most appropriate techniques for protecting the archaeological sites along the bank of the Fraser River.  Currently, the findings of this report are being discussed with First Nations, in order to ascertain their wishes in regard to the future of these sites.  Traditionally, the First Nations have not wished to draw attention to these sites by turning them into designated heritage sites.

 The consultants' socio-community study provides some incomplete information regarding the heritage buildings in Delta which are close to the route.  Further information has been provided to the consultants.  As far as staff are aware, three properties on the heritage inventory would be affected – the Glenrose Cannery, and the Johnson and Jensen Houses.  Staff will be recommending that Delta's official response to the EAO should include requests for preservation of these buildings, including removal to another site if necessary.

 Far more than three heritage properties are threatened;

The Johnson house 10278 River Rd.

The residence and store 10274-76 River Rd.

The Nesbitt residence10455 River Rd.

The Night watchman’s shack in the Cannery ravine

(the Cannery residence beside the watchman’s shack is already gone)

The Iverson net shed

The Jenson house and quite possibly the other Johnson house at 10525River Rd.

Then there’s the question of the Starhiem residence at 11059 River Rd…..does it get expropriated? Or does it live there under a freeway bridge?

These heritage sites represent the beginnings of the oldest neighbourhood in Delta, and one of the founding neighbourhoods in B.C.  The sense of history is lost when a site becomes inaccessible and the buildings are removed. Heritage value decreases sharply when a building is moved from its original location.


The SNA presentation highlighted the environmental sensitivity of the North Delta bluffs and ravines and importance of biodiversity.   Concern is expressed regarding the impacts on this habitat from the construction and operation of the SFPR.

The proposed SFPR alignment will include the crossing of several ravines and the clearing of riparian vegetation.  As part of the environmental assessment of the project there is a Wildlife report and a Fisheries and Aquatic Resources report that will quantify the impacts of this proposed route.  This will include an inventory of animal and plant species that may be affected that includes endangered and threatened species.

 “Crossing several ravines” should read “crossing seven environmentally sensitive ravines, of which four are listed as environmental reserves.  People along these ravines have been told not to throw grass clippings over their fence yet someone thinks it is ok to build a highway through them!

The SNA referred to this area as having red and blue coded species and habitat under an international colour coding system.   The government of BC has identified species that are designated as red or blue listed which provides a list of species for consideration for more formal designation as Endangered or Threatened, either provincially under the British Columbia Wildlife Act, or nationally by the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).   Under the federal Species at Risk Act (SARA) species are listed that require conservation and recovery plans.  Currently, species listed under SARA are legally protected on Federal lands.   There is no formal provincial or federal designation that specifically protects the North Delta bluffs.

 You miss the point.  These lands are recognized as important habitat.  If there is no formal designation, there should be!  The ravines are listed as environmental reserves and their connectivity to the Fraser River and their importance in maintaining the genetic health of the Fraser River is well known.  They also help provide an important corridor of riparian habitat leading from Burns Bog to the upper Fraser River for species movement and migration. The value of this habitat cannot be measured for mitigation by mankind…that’s not possible.

 In accordance with Delta’s Official Community Plan, the GVRD’s Sustainable Region Initiative, the BC government’s Ministry of the environment, Environmental Stewardship plan, the Canadian government’s Environmental, and Heritage initiatives…….and The Georgia Basin International airshed treaty, It would be irresponsible to run the SFPR along the bluffs of North Delta, or anywhere near Burn’s Bog.

Gateway, as part of the environmental assessment reports being prepared for the SFPR, have been surveying the proposed alignment for provincially and federally listed species.  The identification of listed species, or their habitat, will not necessarily preclude the development of the SFPR provided the appropriate mitigative measures are taken.

 How do you mitigate species habitat?  How can man-made environs compare to nature?  No mitigation can make up for the myriad of diversity in these ravines and along the bluffs.

The colour coding that the Fraser River Estuary Management Program (FREMP) has assigned the foreshore along North Delta is correctly noted as being red and yellow through this area.    The SFPR will not be subject to a FREMP Environmental Review Committee (ERC) review since it is subject to the provincial and federal environmental assessment processes.  The FREMP review typically provides information back to the proponent and regulatory agencies regarding the projected impacts and proposed mitigation for the project.  FREMP does not issue project approvals.  The environmental agencies represented on the FREMP ERC; Environment Canada (EC), Department of Fisheries and Oceans (DFO), and Provincial Ministry of Environment, are all represented on the EAO working group for the environmental assessment of the SFPR. DFO and EC approvals will be required in order for the project to proceed.  The FREMP designations along the sections of the SFPR that are in close proximity to the Fraser River will be considered by the federal and provincial agencies during their review of the project.

Monetary compensation for habitat loss is noted in the SNA report.  Monetary compensation is not accepted by DFO for compensation for the harmful alteration, disruption or destruction of fish habitat.  Typically, DFO requires “like-for-like” compensation, so that if riparian vegetation is removed it is replaced in such a way that it can provide a similar function in the area.   The Fisheries and Aquatic Resources report, that has not yet been released, will detail the proposed habitat compensation.   In the workplan that describes the information that will be provided in the Fisheries and Aquatic Resources report, it is stated that it is expected that the objective of  “no-net-loss” of productive aquatic and riparian habitat will be achieved for the SFPR.

 Perhaps “monetary” was a poor choice of words.  What we meant is the value placed on the habitat that would be destroyed.  There is a real cost for the loss of riparian habitat and environmentally sensitive areas and that cost cannot be measured in mere dollars, but those consequences are going to cost money!  Lots of it!  The amount of compensation to replace the valuable habitat that would be displaced by the SFPR would be astronomical.  How do you put a value on a tree that for years, the bald Eagles have fledged their young from, and is a prime candidate for nesting?  Clay banks that house kingfisher nests?  Hunting grounds and nesting sites for species of hawks and owls? ‘Environmental reserves’ that have been proven to be crucial in maintaining the biodiversity of the Fraser River?  Mike Wilcox (BC Environmental Stewardship) stated there should be “no net loss”, and perhaps a “net gain” when there is development in this area.  How would this be possible?  It’s not!  Nothing man-made will make up for the loss of such an important section of habitat.

Engineering Issues

The Engineering issues identified by the SNA will be addressed in an upcoming Council workshop with the SNA scheduled for October 3, 2005.


This report presents additional information, as requested by Council, with respect to the issues raised recently by the Sunbury Neighbourhood Association concerning the proposed South Fraser Perimeter Road.

 Conclusion:  The habitat issue alone should be enough to force the SFPR into a tunnel in this area or movement to another location, such as #10 Highway.  No mitigation measures are going to be enough to compensate for what North Delta has to lose; irreplaceable habitat, history and heritage, health and safety, property values and tax revenue.  Delta is committed to improving livability, air quality, heritage protection, and environmental enhancement and protection.  All of which aren’t possible with the current plans for the SFPR. 

-No net loss indeed!-

I am keenly awaiting a response

Don Hunt                                                                                              

Sunbury Neighbourhood Association