Sunbury Neighbourhood Association

Response TO EAO Discussions - May 2007 

The Gateway Project is being touted by the BC Government as the economic gateway to the burgeoning Asian markets.

The planned expansion of DeltaPort and its rail and road infrastructure are a big part of this campaign, the most damaging of which would be the South Fraser Perimeter Road.

When the Environmental Application Documents were released, the public was given 60 days to read, research and reply to over 3500 pages of documentation.

That required a person to read over 50 pages a day, just to get through documents that were difficult to access and had no labels to designate which topic was in which volume.

While wading through the papers it became apparent that there were many errors, inconsistencies and omissions.

Figures and Tables had incorrect labels and misinformation. Maps were inaccurate or had no legend to direct the reader. References were erroneous or missing altogether.

When these errors were pointed out to Gateway they responded with quotes such as:

“This was an error in the original submission…and has been revised in an erratum presentation to the EAO…” and…

“Any errors found in the Application will be corrected and reported via the EAO website.”

Of all the errors that were pointed out, only a few have been posted. 

The point that they miss is that the working groups that helped shape the application, as well as the general public, were reviewing false information for comment and therefore were denied the opportunity to properly assess the impacts.

Not only does one technical document contradict another, but there are numerous contradictions within the same volume!

“Historical water quality data were not available for the water courses within the SFPR footprint”,

(Technical Volume 11, p. i, para 2)

“limited historical water quality information was available for the SFPR project area.”

(Technical Volume 11, p. 6, para 1)

“Historical water quality data in tributaries located in the study area were reviewed….”

(Technical Volume 11, p. 6, para 3)

“Historical water quality data were not available for the Fraser River tributaries along the SFPR alignment.”

(Technical Volume 11, p. 19, para 1)


“…the physical extent of the Burns Bog water mound is the primary influence on the overall viability of Burns Bog.”…”the proposed roadway is aligned directly over portions of the mound…”

(Technical Volume 10, pg. 47, paragraphs 3 & 4)

“The estimated loss of habitat with vegetation and wildlife values from Burns Bog is 12.78 ha…This includes…areas with attributes required to preserve Burns Bog viability.” (Main Binder, p. 350, Potential Impacts to Burns Bog)

An estimated 12.78 ha of land supporting the viability of Burns Bog…would be impacted due to the SFPR. About 7 ha of this is zone 1 land with attributes required to preserve the viability of Burns Bog...” (Main Binder, p. 366, para 3)

“The proponent does not consider that the SFPR project will diminish the viability of Burns Bog.” (Ministry Responses to Public Comments, Pg. 72                                                                                                                

Contradictory statements throughout the Documents are interspersed with outright false information such as the description of the new residential development at 176th and 104th   in Surrey, where 100 or so new homes have been built on the hillside by people who were not told of the impending highway that would be built across the street.

A highway with a viaduct that will take the place of the mountain and river views that these new residents thought they would enjoy.

Pg. 452, Para 2, 173rd to 176th Street area. “The north facing hillside in this area has single family homes on the upper areas, and numerous trees.”

The trees have been removed and homes built so close to the proposed route that some of them will be in the shadow of an SFPR viaduct.

Pg. 463, Table 8.3-8.  173rd St to 176th Street interchange…’Moderate’ impact rating…”Trees provide effective screening & existing views from Fraser Heights residences are limited. This is far from the truth. Visual impact to the residents of Fraser heights would be substantial with a major interchange and raised viaduct in place of the view of the mountains.

The developers, the Real Estate agents, and the City of Surrey did not properly disclose the information about the SFPR. The Ministry of Transportation and Highways hid the signage on a side road, (104a …a one block long street), and the environmental application concealed the actual impacts. Now these new residents that are facing a huge reduction in property values will have to consider legal action.

The public as well as the working Groups were not provided with accurate information with which to base their assessments and conclusions.

As well, the conclusions reached by Gateway themselves were predicated on this misinformation and incorrect data.

The entire Gateway project proposal needs to be sent back to the drawing board. The SFPR is planned in the wrong place, it is based on 20 year old thinking, and the alternatives were not properly considered.


Vegetation and Wildlife

Many different species of plants, birds, mammals, reptiles, amphibians, and insects would be negatively impacted, including the many rare and endangered species

Areas that are red- and blue-listed species habitats and sensitive environments that are described as ‘the only remaining habitat of its kind in the province’ would be reduced in size, fragmented, and in some cases eliminated.

These are areas that are known for species of special concern and have been designated and listed so that they can be protected.

Geotechnical Instability

The North Delta slopes are well known for their instability. The ground around Burns Bog and the lowlands all along the south side of the Fraser River is soft with peat and silty sand. Peat levels are over 200 feet deep in some areas and the vibrations from truck traffic create a constant need for repair and replacement of the existing infrastructure. Building a highway with raised viaduct structures in these soil conditions will be more than an engineering challenge; it will be an expensive and risky proposition.

Burns Bog

The Burns Bog ecosystem is unique in the Northern hemisphere, and has been cited as being the finest example of a raised bog in the northwest of North America.

Its air and water cleaning qualities are important to the livability of the Lower Mainland as well as the biodiversity of the largest Salmon River in the World.

Gateway’s own documents clearly show that the SFPR would severely impact this rare and sensitive jewel.

Building a major roadway along the northern and western sides of the Bog would threaten the very existence of the Bog and be contrary to a legal and binding covenant that was signed by all levels of Government to protect the Bog in perpetuity.

Fish Habitat

The North Delta Bluffs contain 8 urban ravines, (4 of which are Environmental Reserves). These ravines are home to Salmon- and Trout-bearing streams.

The SFPR would cover these bluffs with a two tier cement highway.

A considerable amount of rainwater will evaporate from the warm pavement, and the water that does make it down into the creeks will be polluted with road run-off, (Hydrocarbons, lubricants, antifreeze, windshield washer fluid, and salt).

The Fraser River is directly affected by the health of its tributaries, and is already listed as endangered.

Gateway’s Mitigation plans cannot protect against these changes in water quantity and quality, especially in the event of an accident causing a spill.

The changes in water quantity and quality would negatively affect the vegetation, insects and fish populations that inhabit these red- and blue-listed streams.


Water movement is especially important to the well being of our urban streams, the Fraser River and Burns Bog.

Pushing a new highway along the Fraser River, through ecological reserves, and along the north and western sides of Burns Bog would severely impact the water flow for these systems. The rain shadow of the highway would reduce the amount of water over its entire length through evaporation.  A major highway along north and west edges of Burns Bog would also interfere with the natural flow between the Bog and the Fraser River upon which they both depend.

Water Quality

There is growing awareness that our water quality is a key factor in the survival of our species and the many others that we share our planet with.

Our urban streams are very important not only to the fish and wildlife that live there, but also to the Fraser River and its genetic fitness.

Running a new highway along the banks of the Fraser River, through the environmentally sensitive North Delta ravines, our agricultural farmland, or anywhere near Burns Bog would subject them to roadway chemicals and exhaust pollution daily, as well as large spills from accidents.

The water balance in Burns Bog is especially important for the rare and endangered plants that inhabit it, and for the life of the bog itself.

We are trying to maintain and enhance the quality of our waters, and building the highway where proposed would be counter to these ideals.


The Agricultural Land Reserve (ALR) was set aside in 1973 by the Government of the day because they realized the importance of preserving this exceptionally fertile farmland for the future production of food for the Nation. While our population continues to grow, little by little it is chipped away for development, and there is always a public outcry.

Now the Transportation Ministry is trying to disguise the fact that their Gateway proposals will eliminate or render useless 1,000 acres of A.L.R. land and poison much more with roadway run-off and diesel particulate.  

Alternate proposals by the Municipality of Delta and concerned citizen groups would reduce this waste more than tenfold.


The impacts to our communities will be severe….

The pollution from a new highway past 20 schools and 46 parks and playgrounds will elevate cancer deaths and respiratory diseases in our children.

Noise and lighting pollution from a 24/7 freeway to the residential areas that are currently backing onto greenspace will reduce property values.

The eviction over 150 families’ project wide, some of whom pioneered these areas.

The closure and removal of several businesses, and the elimination of over 125 acres of Industrial Land.

Neighbourhoods cut off from each other and the Fraser River which gave the basis for their existence.

Gateway only considers structures when they speak of Heritage, The context of these homes within the community, with our founding families is our true Heritage.

Local Air Quality

Gateway’s documents spell it out quite clearly.  Close proximity to a major roadway will result in an increase of cancer deaths and respiratory diseases…Period.

Long-term exposure to diesel particulate causes decreased lung function, increased mortality, respiratory disease, and lung cancer."

Regional Air Quality

The method of modeling used by Gateway is an attempt to minimize the perceived impacts.

With our awareness of Global warming and the need to maintain green-space, it would be environmentally unconscionable to remove the vegetation along the banks of the Fraser River, threaten the viability of Burns Bog.


Residential areas along the SFPR would receive what Health Canada calls ‘a serious noise problem’ that the proponent admits will affect normal speech inside our homes and be disturbing to sleep patterns.

The proposed mitigation measures are open grade asphalt (quiet pavement), that helps, but only if its dry, and 3meter high walls that are not as tall as the exhaust stacks of the trucks.

Archaeology & Contaminated Sites 

The proponent has not properly determined the extent of these sites in size, or depth, or cost. Estimations have been put off for further study, but the expected mitigation costs are in the hundreds of millions. 

The biggest misinformation in the entire documents is;

“…the over all impact of the SFPR on existing communities is deemed to be relatively benign.” (Technical Volume 15, pg. iii, paragraph 6).                     

The true cost of the SFPR and the Gateway project will be much greater than the three Billion dollars they say, and will have the single largest impact on Delta and the Lower Mainland in our history.

Transit initiatives, upgrades to existing infrastructure and community based alternatives would have a far superior affect at a much, much lower cost to the taxpayer in dollars and livability impacts.

For more information and links to supporting documents please see the attached:


SFPR Links: