Sunbury Neighbourhood Association

Letter to Sukh Dhaliwal

January, 30th, 2009


Sukh Dhaliwal
Opposition Critic for the Asia-Pacific Gateway 

Dear Sukh, 

As you well know, the Canadian taxpayer purchased Burns Bog at considerable effort and expense to save it in perpetuity for all future generations. A group of our best wetland scientists were brought together to form the Burns Bog Scientific Advisory Panel to keep and eye on the bog, to monitor it and to make recommendations for it’s long term health, protection and restoration. 

A protective covenant was signed by all levels of Government…

A covenant that states… 

Section 2.5… “This agreement shall be perpetual to reflect the public interest in the protection, preservation, conservation, maintenance and enhancement of the natural state of the bog and the amenities for ecological and environmental reasons.”

And Section 4.1 states… “…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 or the amenities.

The Key words in those sections are…. the amenities.

Section 1.0 Definitions and Interpretation, 1.1 (a) “Amenity” includes every natural, scientific, environmental, wildlife or plant life value relating to the bog;”

The South Fraser Perimeter project will, by the admission of its own Environmental Assessment, directly impact these amenities and the bog itself with habitat removal, contamination and the killing of species at risk.

The Burns Bog Scientific Advisory Panel states…

"It is clear that wherever the SFPR is put, it will have major consequences to wildlife.  A route within or immediately adjacent to the mixed conifer forest on the Bog’s western edge will have the greatest impacts on ecological integrity, through ecosystem conversion and negative edge effects."

They say the ability to apply the guidelines for Bog protection and restoration recommended by the SAP council will be compromised. 

They state that the SFPR will impact the protected lands “without a doubt”.

And they say that the lands surrounding the protected lands should be purchased and added to the conservancy lands for the long term health of the bog.

It is abundantly clear that the intention of the covenant includes and protects the lands that the SFPR would destroy.

The Scientific Advisory Panel has confirmed this intention and is calling for the protection of these amenities and wants them to be formally protected and included in the Partnership lands.

The SAP has also recently told the Metro Vancouver working group that the berm system that Gateway is planning is inappropriate and will be ineffective. 5 berms covering only 25% of the bog edge are planned and only one of those 5 is in the right spot, so the initial concept of a berm and double ditch mitigation system is not being followed and will definitely fail.

Now we find out that the preload material that Gateway is using has a high salt content, some of which is coming from the contaminated area if front of the old Dow Chemical Plant. The preload is supposed to be clean material that will not affect the water quality, bog hydrology or plant species within the Bog.

The Owner’s table of Commitments and Assurances is not being followed. It lists many vague promises and states that the contractor will be responsible for developing mitigation plans and ensuring these actions are carried out. A private contractor has not been selected, and yet the Provincial Government has started construction. The whole point of a P3 partnership is that the contractor assumes the risks, however no contractor will take on the responsibility of preloading where experts are warning that building a highway over unstable ground will be extremely costly with expectedly poor results.

If the taxpayer is paying for and preparing the roadbed then where are the risks to the contractor, and who is making sure the one hundred and forty three commitments and assurances are being properly identified and followed?

There can be no arguing with the evidence at hand; they are impacting Burns Bog which is contrary to the covenant that protects it.

As the Opposition Critic for the Asia-Pacific Gateway, we ask that you call for a suspension of construction of this highly damaging project and pressure the Provincial and Federal Governments into using the alternatives that will accomplish the real economic realities, while protecting Burns Bog. 

The Asia Pacific Gateway and Corridor Initiative, (APGCI 2007), is a very thorough document and it’s clear in its recommendations that further Port infrastructure in the Lower Mainland is a waste of time and money, and that we need to steer away from truck dependant transport for our goods, except for local delivery.

The recent downturn in world economics has proven their point even further.

Prince Rupert has increased in container traffic while every other port on the west coast of North America is way down. The economic need for the SFPR is not there, and the funding should not be wasted on such an unnecessary and damaging highway. I’ve attached the ‘APCGI Report and Recommendations’ and a page of quotes for reference.

Tell the Federal and Provincial Governments to take the advice of their advisors who are telling them to protect the environment and communities by building the Gateway to Asia through our Northern Ports where it makes economic and environmental sense.

Thanks for your attention in this very important matter, 

In anticipation,

Don Hunt

Sunbury Neighbourhood Association


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