Trans Mountain Expansion Project 2016
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