Area I Crab Fisherman Association <personal information removed> <email address removed> October 26, 216 Debra Myles Review Panel Manager- Roberts Bank Terminal2 Project Canadian Environmental Assessment Agency 16 Elgin Street, 22"d Floor Ottawa, On KIAOH3 Sent by email to RobertsBank@ceaa-acee.gc.ca and Panel.RBT2@ceaa.gc.ca Subject: Area I Crab Fisherman Association's comments to the Review Panel on the Sufficiency and Technical Merit of the Environmental Impact Statement and Marine Shipping Addendum for the Roberts Bank Terminal 2 Project (Reference Number 854). Dear Ms. Myles: The Area I Crab Fisherman Association is participating in the environmental assessment of the Vancouver Fraser Port Authority's (the Proponent) proposed Roberts Bank Terminal 2 project and represents the views and concerns of not only the commercial crab harvesters who operate in the Roberts Bank area to earn their living, but also the commercial crab harvesters all along the BC coast who are concerned with the degradation of crab habitat and stock levels and the loss of commercial crab fishing grounds. A project of this magnitude will send an adverse ripple effect throughout the entire BC coast commercial crab fishery. Please find attached our more specific comments on the sufficiency and technical merit using the template provided by the RBT2 Panel. If you have any questions or concerns regarding this letter, please contact the undersigned. <Original signed by> Area I Crab Fisherman Association Justin Taylor, Director Email:<email address removed> <personal information removed> <personal information removed>
er an/., Review Panel mi":al 2 Pr();ec ~nt. ~E!T2@<.;~ a q Participant: Justin Taylor October 26, 216 Organization (if applicable): Area I Crab Fisherman Association General Comments: In Area I, commercial crab harvesting activity occurs every day from June 15 to November 3 each year. Department of Fisheries and Oceans Canada (DFO) sub-area 29-6 and 29-7 (the location of the proposed RBT2) are two of the most productive areas of harvest in Area I. (Supported by Hemmera June 214 report titled RBT2- Dungeness Crab Productivity) Area I fishers trust that Vancouver Fraser Port Authority (the Proponent), Hemmera, DFO, First Nations and other environmental and science groups will adequately assess the impact on crab biology, habitat and environment. The proposed RBT2 structure will disrupt the natural tidal flow on and off of Roberts Bank. It is crucial that the long term impact on crab habitat (i.e. vegetation, refuge and nursery areas, food sources, etc...) and crab migration routes of this tidal disruption is extensively analyzed. The existing activities of the Roberts Bank Terminals have resulted in a commercial crab fishing area closure that was implemented in 29. That closure has had a very detrimental effect on commercial crab fishing activity and harvest levels within sub-area 29-6 and 29-7. In 21 there were 51 commercial boats fishing in Area I. After 2 rounds of area reselection, only 21 boats remain. Loss of fishing area has been a major contributing factor to this trend. The RBT2 proposed expansion of the area closed to commercial crab harvesting will result in a further displacement of commercial crab harvesting and will force fisherman into other crowded areas within Area I and eventually into other adjacent commercial crab license areas that are already oversubscribed. Therefore, there is a coast-wide effect on other crab fishing areas of fishing area lost in Area I.
Review Panel mt<. t f''minll/ 2 f>rop:.c+ J r;.. /l( S"W. JC The Proponent implies in the "Roberts Bank Terminal 2 Marine Shipping Supplemental Report" to the "Roberts Bank Terminal 2 Environmental Impact Statement" that there is no way to measure the potential consequential effects on harvest and associated revenues of commercial fishing and seafood enterprises of an expanded navigational closure, and therefore the impact is considered to be negligible. Area I fishers strongly disagree. Historical Electronic Monitoring (EM) data is available from DFO that provides detailed information on the actual commercial crab trap hauls and vessel movements in an around the Delta port area both prior to and subsequent to the existing Deltaport commercial crab fishing navigational closure. This specific data on fishing activity can be analyzed in conjunction with Logbook and Fish Slip data on harvest results in terms of landings and revenues in and around Area 29-6 and 29-7. That "measureable" data "from existing conditions" needs to be analyzed by the Proponent and will undoubtedly provide proof of the detrimental impact the existing Delta port commercial fishing closure has had on commercial crab fishing and harvesting. That analysis needs to be used to extrapolate and predict the significant negative impact on commercial crab harvest levels resulting from the proposed expansion of the navigational closure related to RBT2. The Proponent is requested to analyze the available DFO Electronic Monitoring (EM) Data in conjunction with the DFO Logbook Data and Fish Slip Data to determine the specific level of impact the existing Roberts Bank Navigational Closure has had on commercial crab fishing activities, harvests and revenues. When analyzed together, that data will prove that loss of fishing grounds and restricted harvest activity correlat es with less harvests and revenues of the commercial crab vessels fishing in the area. This information needs to be considered as part of all sources of "measurable" data and "all lines of evidence". The Proponent is requested to analyze the available DFO Electronic Monitoring (EM) Data in conjunction with the DFO Logbook Data and Fish Slip Data to quantifiably estimate and forecast the specific level of impact the proposed expansion of the Roberts Bank Navigational Closure (including the RBT2 structure footprint) will have on commercial crab fish ing activities, harvests and revenues. This information needs to be considered as part of all sources of "measurable" data and "all lines of evidence". Without this analysis, the Proponent cannot conclude that the impact of an expanded closure would be negligible and insignificant on the profitability of commercial crab fishing activities in the area.
f~obcrt., Rc.!View Panel E:'anA Terrninal 2 l'r ojer.t all( R812(<:,,:cc<l,qr, -,a Based on the actual everyday fishing experiences of commercial crab harvesters in the area, the RBT2 footprint and the proposed expansion of area closed to commercial crab harvesting will result in significant adverse residual and incremental cumulative effects to commercial crab harvesting revenues. The Area I Crab Fisherman Association has contracted Pacific Coast Fishery Services Inc. to analyze the aforementioned Electronic Monitoring and Logbook data provided from the DFO. This analysis strongly supports that the existing Delta port closure's loss of commercial crab fishing area in sub-area 29-6 since 29 has resulted in significant adverse residual and incremental cumulative effects to commercial crab harvesting revenues. Please see attached analysis. This proposed analysis will help to address some of the more specific information requests noted below: Information Source (section or page# of E/5, Marine Shipping Addendum, Responses to Proposed Information Request Rationale Information Requirements, etc.) 1) EJS Page 21-18 1) What percentage of the decline in commercial crab harvest levels in Historical Electronic Monitoring sub-area 29-6 subsequent to 29 is attributable to the Deltaport, (EM) Data is available from DFO Roberts Bank commercial crab navigational closure implemented in that provides detailed information 29? on the actual commercial crab trap 2) EJS Pages 21-36 and 21-2) Have all sources of data (including EM data) been analyzed together to hauls and vessel movements in and 38 determine and conclude that as a result ofrbt2 construction and around the Deltaport area both prior operation "Change in availability of harvest eligible Dungeness crab to and subsequent to the existing would be negligible. Negligible effects on access to crab harvesting Deltaport commercial crab fishing areas, harvesting equipment, and crab vessel navigation"? navigational closure. This specific How is the created "moderate adverse effect" deemed to be "negligible" in quantifiable terms from the perspective of Area I commercial crab fishermen? data on fishing activity can be analyzed in conjunction with DFO Logbook and Fish Slip data on harvest results, in terms of landings and revenues in and around Area 29-6 and 29-7, both prior to and
erts t5an ReviP-W Panel an l ' Information Source (section or page# of 15, Marine Shipping Addendum, Responses to Proposed Information Request Rationale Information Requirements, etc.) 3) EIS Pages 21-4 and 21-3) What are the "detectable" and "measurable" "potential effects of the subsequent to the first Deltaport 41 Project on access matters in the construction and operation phase" in terms of crab "landings and revenues" resulting from "potential commercial crab fishing closure. interactions of crab harvesting vessels and equipment and constructionassociated vessels and Project-associated container ships and accompanying tugs" inside "of the existing and proposed closure areas"? Analysis of this data will prove that loss of commercial fishing grounds and restricted commercial harvest activity in sub-area 29-6 correlates with significantly less harvests and 4) Does the lack of"measurable adverse effect on ongoing male crab 4) EIS Pages 21-41 and 21- revenues of the commercial crab 42 productivity at the management stock level in the Roberts Bank area" necessarily correlate with the lack of"measureable change in vessels fishing in the area. That availability of crab that would affect the level of the commercial harvest "measureable" data "from existing in the LAA'' given the potential loss of commercial fishing grounds? conditions" will undoubtedly Based on commercial fishers' experiences, a loss of commercial crab support the detrimental impact the harvest area always equates to loss of available eligible male crabs for commercial harvest, regardless of ongoing male crab productivity. existing Deltaport commercial fishing closure has had on 5) EIS Page 21-43 5) Have "alii ines of evidence" been considered to determine that "a commercial crab harvest levels and negligible effect is expected for the marine fish harvesting sub- could easily be used to extrapolate component" resulting from "area displacement, access matters, and and predict the significant negative resource availability"? (non-negligible) impact on any 6) Data held by DFO needs to be analyzed to determine more conclusively further and expanded closures. 6) ElS Page 21-48 the percentage of commercially harvestable crab that "would migrate from the area of the proposed expansion to the baited commercial traps The Proponent has not yet that would have been placed outside of the proposed navigational closure expansion". This can be achieved by analyzing available data in relation to the existing navigational closure and its impact on commercial harvest results. analyzed the available DFO Electronic Monitoring (EM) Data in conjunction with the DFO Logbook Data and Fish Slip Data to determine the specific level of
Review Panel Rabats RanA Terrunal 2 PrrJfect "an c. PB T llt~'gf'''!~<. gc r... Information Source (section or page# of E/5, Marine Shipping Addendum, Responses to Proposed Information Request Rationale Information Requirements, etc.) 7) EIS Page 21-48 7) What data and statistics have been gathered and analyzed to determine impact the existing and proposed the level of effect on reduced commercial harvest results and revenues expanded Roberts Bank as a result of the permitted and "continued crab harvesting for FSC or Navigational Closure has had and Aboriginal domestic purposes in the current navigational closure and in a proposed navigational closure expansion"? will have on commercial crab This supports the fact that the loss of commercial crab harvest area fishing activities, harvests and always equates to loss of available eligible male crabs for commercial revenues. Analyzing this harvest, regardless of ongoing male crab productivity. measurable data is very relevant and should be considered as part of "all lines of evidence." 8) EJS Pages 21-48 and 21-49 and 21-54 and 21-55 8) In 26, DFO required all commercial crab fishing vessels in Area I to be Electronically Monitored (EM). This EM data on historical commercial crab fishing activity in the LAA is quantifiable and needs to be analyzed and considered before concluding with confidence that there will be a "not significant" residual effect on commercial crab harvests and revenues associated with displaced commercial crab harvesting activity. Without this analysis, the Proponent cannot conclude that the impact of an expanded closure would be negligible and insignificant on the profitability of commercial crab fishing activities in the area. Based on the actual everyday fishing experiences of commercial crab harvesters in the area, the RBT2 footprint and the proposed expansion of area closed to commercial crab harvesting will result in significant adverse residual and incremental cumulative effects to commercial crab harvesting revenues.
Rank Review Pane./ Information Source (section or page# of EIS, Marine Shipping Addendum, Responses to Information Requirements, etc.) Proposed Information Request Rationale The Area I Crab Fisherman Association has contracted Pacific Coast Fishery Services Inc. to analyze the aforementioned Electronic Monitoring and Logbook data provided from the DFO. This analysis strongly supports that the existing Deltaport closure's loss of commercial crab fishing area in sub-area 29-6 since 29 has resulted in significant adverse residual and incremental cumulative effects to commercial crab harvesting revenues. Please see attached analysis.
Vessel Count / Average Catch 3 3 25 25 2 2 # Vessels 15 15 Kg's Vessel Count Area 29-6 1 5 1 5 Area 29-6 Avg Kg Catch Per Vessel 26 27 28 29 21 211 212 213 214 215 Shows the correlaaon between the average catch per vessel in Area 29-6 and the amount of fishing vessels acavely fishing in Area 29-6. AKer 29, there was a drasac decline in average catch per vessel. In 215, 13 vessels were catching the same total average catch as 28 vessels in 21. This demonstrates less abundance in the area, which has effecavely driven more vessels away..
Area I Produc:on Pre-Post Deltaport Closure 39% Reduc:on Kg's 12 1 8 6 4 2 Average Total Landings Area I Pre-Deltaport Closure (<= 28) Average Total Landings Area I Post-Deltaport Closure (>= 29) Area 29-6 Pre-Post Deltaport Closure 58% Reduc:on Kg's 5 4 3 2 1 Average Total Landings Area 29-6 Pre-Deltaport Closure (<=28) Average Total Landings Area 29-6 Post-Deltaport (>=29)
6 Vessel Count per 3 Area 29-6 Avg Kg Catch Per Vessel Vessels 4 2 25 21 215 22 2 Vessel Count Area I Kg's 1 Vessel Count Area 29-6 25 21 215 22 Area 29-6 Avg Kg Catch Per Vessel Percentage Area 29-6 Landings % of Area I Total 5 4 3 2 1 25 21 215 22 Kg % of Area Total Trap Hauls 29-6 % of Area I Total Percentage 8 6 4 2 25 21 215 22 Trap Hauls % of Area Total Area 29-6 Avg Trap Hauls Per Vessel 15 Trap Hauls 1 5 25 21 215 22 Area 29-6 Avg Trap Hauls Per Vessel