Sunbury Neighbourhood Association

Letter to Delta Council - October 16, 2008

Dear Mayor and Council,

I recently read a newspaper article where George Harvie was quoted as saying that the SFPR would not impact the Partnership lands.

Where is he getting his information?

Environment Canada, Transport Canada, The Environmental Stewardship Division of British Columbia, and the Burns Bog Scientific Advisory Panel all say that it will, and that the damage cannot be mitigated.

The SFPR Environmental Application even admits that;

“In relation to the ecological boundaries of Burns Bog, the Ministry of Transportation proposes to construct portions of SFPR on land that is part of the bog and directly connected to the land within the conservation area.” (Burns bog discussion paper, Pg 2, Paragraph 3).

“Removal of peat-producing vegetation or vegetation at the bog margin that acts as a buffer between central bog communities and surrounding terrestrial ecosystems would have implications not only for the immediately affected vegetation but for the entire ecosystem.” (SFPR Environmental Application; Burns Bog Discussion Paper).

“…the SFPR is expected to cause footprint impacts to 28.79 ha of land in zones required for, or supporting, the viability of Burns Bog.” “…5.6 ha of the affected land with ecological values is in zone 1 or in the water mound and required for Burns Bog viability…”

(Cumulative Environmental Effects, 10.3, pg. 19, Burns Bog)

Does he understand the meaning of the word ‘Viability’?

“Bogs are complex ecosystems requiring a particular set of biophysical conditions…Due to interactions between vegetation, peat accumulation, chemical conditions, and water movement and storage, impacts to one ecosystem component will affect others. (Main Binder, p. 350, Potential Impacts to Burns Bog)

“The route also passes through ecosystems that are directly part of the bog complex and previously identified as required for the Bog’s ecological integrity (Hebda et al, 2000).”

(Scientific Advisory Panel Opinions to Environment Canada Concerning Potential Environmental Impacts of the Proposed South Fraser Perimeter Road on Burns Bog, Pg. 5)

Impacts to one part of the Bog ecosystem will have an affect on the whole. We know from the preloading activities for Highway 91 and Tilbury Industrial that the effects are felt well into the protected lands. The periphery of the Bog plays an important role in the life of the Bog, and studies of the Bog have made recommendations to protect a greater amount than the 2042 ha partnership lands to a minimum total of 2450 ha. Of the remaining 408 ha that is required to preserve Burns Bog as a viable ecosystem, the SFPR would destroy almost 288,000 square meters and isolate a large portion of the balance from the protected lands. This includes land that Delta Municipality already owns that could easily be added to the protected areas. These lands were supposed to be added to the ‘Partnership Lands’ within two years of the deal being reached….

Why has Delta not contributed its portion of these lands to the protection of the Bog?

Was that not part of the agreement?

Was there not a by-law passed to recognize these lands as ecologically significant and to protect them?

By Gateway’s own admissions, the SFPR would destroy; 

Ø     3,037 square meters of undisturbed sphagnum moss habitat.

Ø     4,780 square meters of red-listed plant communities.

Ø     61,958 square meters of red-coded Pacific Water Shrew Habitat

And the recent shift in the alignment by Sherwood Forest would also destroy roosting and foraging habitat for large numbers of threatened bird populations including Trumpeter Swans, Great Blue Herons, Bald eagles, Owls, and the Sandhill Crane.

And the MoT has stated in a Technical Memorandum to Environment Canada that;

In considering refinements to the alignment on the west side of Burns Bog, analysis undertaken by MoT indicates that a further shift (i.e., to the west side of Crescent Slough) would not eliminate impacts to areas of concern to EC, associated with the original alignment, while at the same time increasing impacts to other values as follows:

Q      Increase the area and intensity of zone of influence effect on wildlife habitat (i.e., Sandhill Crane, Trumpeter Swan and water associated birds) provided by agricultural fields.

Q      Potential increases in collision mortality to Barn owls associated bisecting remaining foraging habitat (to the east of Crescent Slough);

Q      Impacts to fisheries values (where none currently exist) associated with two crossings of Crescent Slough; and

Q      In order to minimize impacts to agricultural values the alignment will still be required cross, and impact, some ecological values associated with the Corporation of Delta lands north of the Nottingham property.

It is noted that the proposed relocation does have cost (est. $20 million) and other social, economic and community effects which are also a critical part of the Environmental Assessment review.

(Technical memorandum to Lisa Walls, A/Manager, Pollution Prevention and Assessment Section from Malcolm Smith, Environmental Manager, SFPR Project on September 21, 2007, regarding MoT Responses to Environment Canada Comments on South Fraser Perimeter Road, Page 8)

Let me give you the quote once again…

“the Province, Delta, and the GVRD shall not do anything, or allow anything to be done, that does or could reasonably be expected to destroy, impair, diminish, negatively affect, or alter the Bog…”

There is clearly enough evidence to invoke the protective covenant and stop the SFPR from being built near the Bog.

The only people saying that the SFPR wouldn’t impact the ‘Partnership lands’ are the Kevin Falcon, Geoff Freer and George Harvie!

Every Regional plan and OCP since the 1960s has emphasized the protection of our environment and our Green space.

The recent International symposium on Wetlands and Peatlands, (U.N. Peatlands Conference, Bali 2007), said that the importance of protecting our Bogs and wetlands cannot be overstated.

Peat Bogs sequester ten times more carbon than any other ecosystem of the same size, and “conservation and restoration of peatlands can be up to 100 times more cost effective as other carbon sequestration measures" 

I would like to arrange a meeting with your Worship and any councilors that are willing stand up for the protection of Burns Bog to discuss how we can move towards stopping the SFPR from impacting the bog and getting Burns Bog recognized as a Ramsar/UNESCO site to give it some real protection.

Looking forward to a speedy reply,

Most sincerely,

 

Don Hunt

Sunbury Neighbourhood Association

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