Fwd: Public consultation on Proposed Dredging in Burrard Inlet

[Karl Perrin]

Hi BROKE Core Group and Allies, and VanU Enviro Team and Allies

The public engagement period for the planned dredging in Burrard Inlet is over March 22, 2026.

The motivation for this dredging is to allow tankers at Westridge Marine Terminal (TMX) to fill up to 100% capacity instead of 80%.

Without going into the weeds, I offer my letter below as a sample of a letter you could send to p...@portvancouver.com to oppose this dredging.  Even an email that quotes my first paragraph would be a big help. Send it to p...@portvancouver.com

If you do want to go into the weeds a bit, read John Boyle’s letter included in my letter.

Also, this page 

 includes FAQ about the dredging project.  Included in the FAQ are links to some very thorough plans to reduce ecosystem damage.  Unfortunately, as John Boyle points out below, there’s no enforcement mechanism.  So please write and demand enforcement of damage reduction plans.  Contractors only must do what they have promised to do in contracts.

All the best, Karl

Begin forwarded message:

From: Karl Perrin <per...@shaw.ca>

Subject: Public consultation on Proposed Dredging in Burrard Inlet

Date: March 11, 2026 at 4:19:00 PM PDT

To: p...@portvancouver.com

From: Karl Perrin

Sent: Wednesday, March 11, 2026

To:  'P...@portvancouver.com' <P...@portvancouver.com>

Subject:  Proposed Second Narrows Dredging Project

Dear sir/madam,

I would prefer that the channel for large ships east of the Second Narrows Railroad Bridge not be dredged to allow tankers from Westridge Terminal to increase their Tar Sands petroleum capacity from 80% to 100%.  A large oil spill of a fully loaded Aframax tanker could destroy Burrard Inlet ecosystems virtually forever.

The disruption from dredging itself would also negatively impact the marine ecosystem which the Tsleil Waututh Nation (TWN) have been working to restore.  The “free, prior, and informed consent” of the TWN is constitutionally required before any dredging in Burrard Inlet can take place.

However, if Canada’s federal government overrides the TWN and dredging proceeds, I would like you to respond to my concerns with the Draft Construction Environmental Management Plan (CEMP).  After reviewing various documents released about this project, my concerns are the same as John Boyle’s as expressed in his response to you for the Public Consultation on Proposed Dredging in Burrard Inlet below:

"From: John Boyle 
Sent: Saturday, March 7, 2026 12:46 PM
To: 'P...@portvancouver.com' <P...@portvancouver.com>
Subject: PER Comments on Second Narrows Dredging Project

 

Good Afternoon,

 

I have reviewed the various documents released about this project and have the following comments to make, and some questions.

 

Environmental Studies

 

These studies are quite comprehensive and professionally done.  What is missing, however, is any characterization of water quality in and around the dredge site, especially of contaminants such as metals and PCBs.  This baseline information is needed to assess impacts on water quality during dredging.

 

The modelling of sediment dispersion during dredging persuasively demonstrates that there should be no short or long term suspended sediment concerns in the Rockfish Conservation Area and at other sensitive receptors in the eastern and western Burrard Inlet, the mouth of the Seymour River, and Maplewood Flats.  This is reassuring.

 

However, concerning other water quality impacts such as the release of contaminants like metals and PCBs, the Marine Ecological Overview Impact Assessment is decidedly unpersuasive.  It concluded that they “are not expected” (page 24, paragraph 2), but the rationale for this conclusion seems illogical.  It reads.

 

“To assess the potential concentration of these metals in the water column during dredging, the sediment concentration was multiplied by the CCME short-term concentration of TSS of 25 mg/l, which is used as the water quality criterion for the Works. The resulting potential concentrations are below the CCME short-term water quality guidelines for all three metals and therefore impacts to marine life, including nearby kelp, are not expected.”

 

How does multiplying the expected sediment concentrations from dredging by the CCME TSS criterion indicate the expected concentration of metals in the water column?  The rationale seems illogical and needs to be explained.  One would think the rate at which metals dissolve out of the suspended sediments needs to be considered.

 

Will the Marine Ecological Overview Impact Assessment be revised to address this water quality concern?

 

Draft Construction Environmental Management Plan (CEMP)

 

The Draft CEMP is quite comprehensive and thorough.  However:

 

1. Water quality monitoring is for turbidity (i.e., suspended sediments) only, and for pH around concrete pours.  There is no requirement to monitor for other contaminants (e.g., metals, PCBs) released into the water column by the works, a legitimate concern for some stakeholders.  

 

Will the CEMP be amended to require water quality monitoring for metals and PCBs?

 

2. “Should” needs to be changed to “will” in all instances where behaviour is being specified.  One example is “In the case of emergencies, the EM, the Contractor and VFPA (the Owner) should be notified immediately” (page 33).  Otherwise the CEMP is just advising and not requiring behaviour, and compliance may be problematic.

 

Will these changes from “should” to “will” be made to the CEMP?

 

The CEMP states (page 1) that it “…provides guidance to the Contractor and all sub-contractors undertaking the Works. The Contractor is ultimately responsible for ensuring all conditions of Permits, Licenses and Approvals (PLAs) are fulfilled.”  This is not strong enough for the CEMP to be operationally effective, and “guidance” needs to be replaced with “direction.”  Also, the latter sentence needs to be revised to read “… Approvals (PLAs) and this CEMP are fulfilled.”  Otherwise, the Contractor can argue that the CEMP is merely advice and not specifying obligatory behaviour.  Again, compliance may be problematic. 

 

Will the VFPA make these changes to the CEMP?

 

Most importantly, based on my several decades of environmental management experience, the CEMP will have no operational effect unless the works contract documents contain clear statements requiring the Contractor to adhere to the provisions of the CEMP.  Contract documents are a contractor’s “bible” – anything else is merely reference material not legally included in the terms and conditions of his work and thus not enforceable.  Without strong linkages between the works contracts and the CEMP, there may well be compliance challenges with the Contractor.

 

Will the VFPA ensure strong statements in the contract document(s) requiring compliance with the CEMP?

 

Archaeology

 

The CEMP notes in Appendix A1 on archaeological chance finds that an Archaeological Overview Assessment is being undertaken by Campfire.  

 

Will the VFPA soon release the archaeological assessment for public and First Nations review and comment?

 

Best regards,

 

John Boyle  BApSc MNRM PhD  “

Please respond to the italicized questions above to me as well as to John Boyle.

I have additional concerns as expressed by Flossie Baker of the Sierra Club of BC:

“...

Further increasing oil shipping through Burrard Inlet raises the risk of spills in a sensitive and culturally significant marine ecosystem. 

I am also concerned that the scope of the project assessment does not adequately address the cumulative impacts of increased marine shipping and associated industrial activity in the inlet. Any environmental review should fully consider these broader impacts, including spill risk, habitat disturbance, and long-term ecological consequences. “

The increased loads carried by tankers leaving Westridge Terminal will mean increased damage from greater wave action

to shoreline ecosystems including kelp beds and eelgrass and the biota which depend on them.  

Dredging the Second Narrows area will encourage further industrialization of the Port Moody Arm and Indian Arm inlet areas, which will result in even further future damage to the Burrard Inlet ecosystem.  

What will the Vancouver Fraser Port Authority do to prevent cumulative and future damage to the Water Quality Objectives which the Tsleil-Waututh Nation has negotiated with the B.C. government?

Thank you for your consideration of my questions, Karl Perrin, per...@shaw.ca