Rebuttal of the South Fraser Perimeter Road Project Assessment Report, 2008

In order to address the Environmental Assessment Office (EAO) report on the South Fraser Perimeter Road (SFPR) as released July 25, 2008, I must begin by asking the question — what is the purpose of the road?

The purpose, as I understand it, is to provide a transportation route connecting Delta Port with the South Fraser dock and ultimately the Port Kells switch yard for the movement of containers by truck. The solution, as proposed by the dusted off 20 year old perimeter plan, tweaked a bit to give a token nod to environmental concerns, is in fact the most expensive and environmentally damaging option that the Campbell government could have chosen. That viable alternatives were not given due consideration, is the most shocking aspect of the report.

My critique is that the SFPR, if it moves forward as proposed, is not part of a comprehensive regional plan for moving goods. It is an old plan that will not address today’s concerns. What follows is only one aspect of many that rightly questions the methodology and the scope of the EAO report and its approval of a destructive route through Delta and North Surrey.

The scope or parameters of the SFPR project immediately takes for granted that there will be a road. From the beginning, the outset was pre-determined. The purpose as given in the terms of reference by the Ministry of Transportation is to

"…determine the most viable alignment for the corridor between Highway 91 and Highway 15 for a high standard (80 km/h) four lane facility with accesses restricted to appropriately spaced and located signalized intersections which in the long term are proposed to be converted to interchanges." (MOT Infrastructure Website — see References)

The project was subject to review under both the British Columbia Environmental Assessment Act (BCEAA) and the Canadian Environmental Assessment Act (CEAA) as a single harmonized review. As a result of a “harmonized review” the CEAA requires consideration of the rationale or need for the project and alternatives as part of the environmental assessment. Consequently, the provincial Ministry of Transportation included, and summarily dismissed, alternatives to the project such as increased use of rail and transit in its application.

For example, one striking alternative was virtually ignored — Short-Sea Shipping.

The 138 page EAO assessment gave the short-sea shipping alternative six lines of consideration. While citing the Greater Vancouver Short-Sea Container Shipping Study, a study by Novacorp with the newly named Port Metro Vancouver, Transport Canada, and FREMP (2005), the EAO assessment rejected short-sea shipping because

"it would not provide for goods leaving the Lower Mainland (i.e., requiring access to Highway 1) nor would it address the 50% of goods that move by truck, or traffic bound for the ferry terminal." (SFPR Report 2008, p.23)

However, that is not what the Novacorp study concluded. It is as if the Campbell government did not read the report at all or worse, deliberately ignored the findings of the Novacorp 2005 study. There are two important aspects to short-sea shipping that I will outline below: the economic viability and the environmental impact.

The study looked at viable “market penetration” and compared goods movement transit times, dwell times at the container terminals, and delivery costs compared to transporting goods by road. Short-sea shipping is deemed by this report to be a very viable alternative to goods movement by truck along the region.

"The Consulting Team has researched and analyzed the opportunities for such an integrated facility. The commercial advantages of this concept (and for a location with adjacent or nearby container businesses) are primarily related to the savings in drayage (trucking) costs around and amongst the congested road network of the region." (Novacorp 2005, p.14)

To make short-sea container shipping work up river, barge movements could not be less than 100 containers, return trip. However, Port Metro Vancouver says it could move much more. Chris Badger, Manager of Port Metro Vancouver Port operations, transportation, logistics and marketing stated that it’s highly feasible to take 200 trucks off the road in one barge pulled by a tug (Vancouver Sun, March 06, 2008). Gordon Houston, President and Chief Executive Officer, Port Metro Vancouver stated that it is feasible for a tug to pull 500 containers up the Fraser River (Delta Chamber of Commerce Luncheon, April 23, 2008).

The costs of tug and barge were calculated at four hours travel time between Roberts Bank and Fraser Surrey Docks (FSD); in other words, the calculation would be the equivalent of removing 25 containers along River Road per hour with every barge. Cost differences between Roberts Bank and FSD were very competitive.

"The comparison leads to the following preliminary conclusions:
• at barge-load volumes of 100 containers per round trip, short-sea service is at a distinct pricing disadvantage compared with truck transport;
• at barge-load volumes of 200 containers per round-trip (i.e., 100 containers each way), short-sea services on all routes become more price competitive, and on selected routes become directly competitive, with truck transport; and
• as barge-load volumes increase to 200 containers and higher per round-trip, short-sea services are expected to offer price advantages versus truck transport on some routes and become directly price competitive on other selected routes." (Emphasis mine, Novacorp 2005, p. 56)

Three of the five short-sea shipping routes seen as “competitive….at comparable rates with the trucking industry” included FSD: FSD to / from Roberts Bank; FSD to/ from Vancouver Inner Harbour, and; Coast 2000 to / from FSD (Novacorp 2005, p. 56).

"Based on the parameters of the analysis, and through interpolation, 400 containers per round-trip on a number of short-sea routes is expected to provide significant competitive pricing advantages when compared with truck dray rates on the same route." (Emphasis in original, Novacorp 2005, p.57)

Fraser Surrey Docks already handles 200,000 to 300,000 containers a year and, according to Badger, the container traffic on the Fraser is only at 10 to 15 per cent capacity. Badger believes the infrastructure is already in place, as he stated,

"the highway — in this case the Fraser River — and the railroad tracks run side by side all the way to Hope. What we need is the interface between the two and that is still missing at the moment. The interface would be a series of terminals to transfer containers between ships and rail." (Vancouver Sun, March 8, 2008)

This view certainly challenges the Liberal government’s claim that short-sea shipping “would not provide [for] goods leaving the Lower Mainland” (SFPR Report 2008, p. 23). In fact, the Novacorp study gave some indication that Gateway’s prospective road projects may be ineffective:

"Travel time estimates in 2021 for container transfer by truck reflect that, despite the completion of already committed transportation infrastructure improvements in Greater Vancouver, travel times on the roadway network over the links defined are expected to increase, in some cases dramatically." (Emphasis mine, Novacorp 2005, p.70)

Regarding environmental impacts, the Novacorp report included a comparative analysis of emissions between the intra-regional short-sea shipping of marine containers with the intra-regional trucking of marine containers. As noted in the report,

"…the extent that lower emissions can be achieved by one transportation mode over another will facilitate policy and support decisions in the public interest and contribute to objectives under the Kyoto Protocol." (Novacorp 2005, p.76)

"It is apparent that transfer between nodes in the outer harbour (i.e., along the Fraser River to/from Roberts Bank at the mouth) by tow boat is consistently the most fuel efficient and, accordingly, these routings will have a lower CO2 and VOC emissions for each container transported." (Emphasis mine, ibid, p.80)

When questioned regarding short-sea shipping, Transportation Minster, Kevin Falcon stated that

"…short-sea shipping also involves more terminal handling, so there are emission challenges around the extra terminal handling that's involved and the movement of the containers in and around the ports. That's a challenge that has to be dealt with. Of course, the member would know that there are marine emission issues, too, that have to be looked at.” (Hansard, April 14, 2008)

However, according to Novacorp, the difference between the portion of CO2 and VOC emitted by trucks routing along the SFPR between Roberts Bank and FSD carrying the same number of containers to that of a tug pulling a barge of 200 containers is 277%. Let’s be clear: that’s 277% less emissions by barge than by truck for the equivalent number of containers (Novacorp 2005, p.81).

Strategic planning for transportation has by necessity changed, particularly since climate change is now our reality. The SFPR concept evolved from the 1980’s and gained momentum with the Delcan study in the 1990’s. The Novacorp report, written three years ago before the price of fuel rose dramatically, clearly indicated a different approach to transporting goods. It is far more cost effective and environmentally sound to include short-sea shipping in a comprehensive regional plan for goods movement. It questions the need for a very costly and environmentally damaging highway which will not, by 2021, meet the needs of trucking containers. The road will be obsolete before completion.

So I ask the question again. What is the purpose of the road? If it is to move containers, then alternatives such as increasing rail capacity and short-sea shipping can very easily accommodate the anticipated containers coming through Deltaport — even with the proposed expansions. Truck routes exist and can be expanded to include designated truck lanes. These alternatives are economically viable and have profoundly less impact on the environment, both land and air.

I cannot reconcile myself to the concept that the Environment Assessment Office can produce a report that would not consider these alternatives. I cannot accept that an office, charged with the responsibility to protect our environment, would approve such a potentially damaging highway to be built without a comprehensive regional plan that incorporates sound business practices and environmental science. The assessment office ran rough shod over community concerns, environmental impacts and economic alternatives. The EAO report, by omitting a thorough review of alternatives, is a sloppy attempt by the Campbell government and Minister Falcon to force a project through regardless of best practice and as such, the process was profoundly flawed.

References

Greater Vancouver Short-Sea Container Shipping Study. Novacorp with Port Metro Vancouver, Transport Canada, and FREMP, 2005. http://gvgc.org/pdf/GVGC_SSS_PreFeasibility_Report_Final.pdf

Hansard. Legislature of British Columbia, April 14, 2008.

Ministry of Transportation (MOT) Infrastructure Website. http://www.th.gov.bc.ca/publications/reports_and_studies/southfraser/sou...

South Fraser Perimeter Road Project Assessment Report. Environmental Assessment Office, June 27, 2008. http://a100.gov.bc.ca/appsdata/epic/html/deploy/epic_document_196_26295....

Water 'highway' could take trucks off Metro's roads. Vancouver Sun, March 8, 2008. www.canada.com/vancouversun/news/story.html?id=a7322b02-167f-4c9d-a6d3-6...