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A number of participants highlighted the importance of eelgrass beds as marine fish and invertebrate

habitat, as well as providing beneficial ecosystem services. Tsawout First Nation said that eelgrass beds

at James Island and Sidney Island are being lost due to all the wake waves from vessel traffic. As noted

by Marine Use Study Respondents, it is fairly shallow in those areas and the waves are building up the

sediment. The eelgrass then disappears and it affects all the crabs and other spawning fish that depend

upon it. Trans Mountain said that although there are no mapped eelgrass beds within the Canadian portion

of the LSA, any eelgrass beds that are present (i.e., within the eelgrass biobands) would be acclimated to

both natural wave conditions and wake waves from existing vessel traffic. Therefore, it considers unlikely

that any eelgrass beds would be adversely affected by the Project.

Sensory disturbance to marine fish from underwater noise

Trans Mountain said that it did not conduct a detailed effects assessment on the potential impact of

underwater noise produced by Project-related marine vessels on marine fish as there are no standard

criteria or thresholds to assess these effects against and there is a lack of data and knowledge surrounding

the effects of underwater noise on marine fish. Trans Mountain did acknowledge that underwater noise

from Project-related marine vessels could potentially trigger behavioral responses by marine fish ranging

from small temporary movements to large scale change displacements. However, Trans Mountain further

stated that there is no evidence in the literature that vessel traffic will result in the large scale displacement

of fish or invertebrate populations from foraging, spawning, rearing or migrations areas, or will otherwise

affect their distribution or abundance. Trans Mountain said that its conclusion is supported by the existing

overlap of areas of high shipping activity and Pacific herring and Pacific salmon migration areas, such as the

Haro Strait and the Fraser and Columbia Rivers.

Participants raised concerns over underwater noise impacting marine fish. Raincoast Conservation

Foundation said that Trans Mountain failed to consider behavioral changes beyond large-scale

displacements and that underwater noise produced from Project-related marine vessels may result

in sub-lethal consequences, such as cardiovascular disturbances. It noted that the lack of inclusion of

information regarding responses of fish to underwater noise could have served to minimize the potential

Project-related effects.

Ms. A.L. Schwartz commented that Pacific herring, as well as other species, respond negatively to shipping

sounds. Ms. Schwartz further suggested that short-term behavioral changes can lead to long-term

significant changes in populations, spawning locations and extents, and feeding grounds.

DFO said that it would be difficult for Trans Mountain to conduct a detailed effects discussion on the

potential effects of underwater noise on marine fish and invertebrates, given the limited information on

species-specific behavioral responses to marine vessel noise and the absence of Canadian standards or

thresholds established for assessing such impacts. It noted that the presence and magnitude of a residual

effect from underwater noise generated by Project-related marine vessels, in addition to the existing

underwater noise environment in the RSA, is uncertain.

Introduction of aquatic invasive species from Project-related marine vessels ballast water

Trans Mountain said that the release of ballast water in Canadian waters is regulated by the Ballast Water

Control and Management Regulations pursuant to the Canada Shipping Act, 2001 Both Trans Mountain

and DFO noted that compliance with this regulation will minimize the likelihood of aquatic invasive species

being introduced during ballast water exchange.

Participants raised concerns regarding the introduction of aquatic invasive species to Canadian waters

through Project-related marine vessel ballast water. Cowichan Tribes said that no form of mitigation

measures can eliminate the risk of aquatic invasive species introductions. It further recommended that

ballast water discharge should include mandatory treatment of ballast water to standards recommended

by the IMO.

Views of the Board

The Board recognises the concerns presented by participants in regards to potential impacts to

shorelines and associated biota from Project related marine vessel wake waves. The Board notes

that evidence provided by some Intervenors, such as Metro Vancouver, was generic in nature

and was not specific to the assessment areas for Project-related marine vessels. In the context