An open letter to:
Honourable Catherine McKenna,
Minister of Environment and Climate Change
Ottawa, Ontario
Re: Scientific flaws in assessment of environmental risks from the proposed Pacific NorthWest Liquid Natural Gas facility at Lelu Island, Skeena River estuary.
We, the undersigned scientists, conclude that the Canadian Environmental Assessment Agency’s (CEAA) draft report of the environmental risks of the Pacific NorthWest Liquid Natural Gas (PNW LNG) project, proposed for the Skeena River estuary at Lelu Island, is scientifically flawed and represents an insufficient base for decision-making. We urge you to reject the CEAA draft report.
Given that the PNW LNG project is proposed for the Flora Bank area of the Skeena River estuary, an area with economically- and culturally-important fishes, such as salmon, eulachon, and herring, we primarily focus our analyses on risks posed to these species. We have identified five primary scientific flaws in the CEAA draft report:
1. Misrepresentation of the importance of the project area to fish populations, especially salmon. The CEAA draft report has not accurately characterized the importance of the project area, the Flora Bank region, for fish. The draft CEAA report1 states that the “…marine habitats around Lelu Island are representative of marine ecosystems throughout the north coast of B.C.”. In contrast, five decades of science has repeatedly documented that this habitat is NOT representative of other areas along the north coast or in the greater Skeena River estuary, but rather that it is exceptional nursery habitat for salmon2-6 that support commercial, recreational, and First Nation fisheries from throughout the Skeena River watershed and beyond7. A worse location is unlikely to be found for PNW LNG with regards to potential risks to fish and fisheries. Proponents of previous industrial projects and decision makers have historically avoided development in the Flora Bank region because of its known enormous value to fish. Thus, the draft CEAA report has failed to adequately characterize the potential risks of the project to fish and fisheries.
2. Assuming lack of information equates to lack of risks. CEAA’s draft report concluded that the project is not likely to cause adverse effects on fish in the estuarine environment, even when their only evidence for some species was an absence of information. For example, eulachon, a fish of paramount importance to First Nations and a Species of Special Concern8, likely use the Skeena River estuary and project area during their larval, juvenile, and adult life-stages. There has been no systematic study of eulachon in the project area. Yet CEAA concluded that the project posed minimal risks to this fish. It is scientifically indefensible to conclude that a species will not be negatively impacted when it is unknown how it relies on habitat that would be destroyed. Indeed, there are many aspects of this ecosystem and the proposed PNW LNG project for which there is little scientific understanding9. Lack of knowledge does not mean lack of risks.
3. Disregard for science that was not funded by the proponent. CEAA’s draft report is not a balanced consideration of the best-available science. On the contrary, CEAA relied upon conclusions presented in proponent-funded studies which have not been subjected to independent peer-review and disregarded a large and growing body of relevant independent scientific research, much of it peer-reviewed and published. For example, CEAA marginalized a published peer-reviewed study10 that revealed risks of widespread erosion of Flora Bank, a unique marine coastal landform and eelgrass habitat, due to disruption of water currents by the proposed trestle and suspension bridge. Instead, CEAA adopted the conclusions of a proponent-funded model that claimed “no harmful effects” of the PNW LNG project, even though external and professional analyses identified several critical errors in their methods11. Similarly, CEAA did not adequately consider decades of scientific research on salmon in the Skeena River estuary2-7, and instead relied on proponent-funded studies that were substantially more limited in scope and duration and that reached different conclusions compared to the larger body of available science. In these and similar cases, the CEAA draft assessment of the PNW LNG project presents an unbalanced assessment of the project’s environmental risks through the disregard of the larger body of independent science.
4. Inadequate consideration of multiple project impacts and their cumulative effects. The CEAA draft report did not adequately consider the multiple potential impacts of the project and their cumulative effects and thereby provided an unbalanced assessment of risks. The PNW LNG project presents many different potential risks to the Skeena River estuary and its fish, including, but not limited to, destruction of shoreline habitat, acid rain, accidental spills of fuel and other contaminants, dispersal of contaminated sediments, chronic and acute sound, seafloor destruction by dredging the gas pipeline into the ocean floor, and the erosion and food-web disruption from the trestle structure. Fisheries and Oceans Canada (DFO) and Natural Resources Canada provided detailed reviews12 on only one risk pathway – habitat erosion – while no such detailed reviews were conducted on other potential impacts or their cumulative effects.
5. Unsubstantiated reliance on mitigation. CEAA’s draft report concluded that the project posed moderate risks to marine fish but that these risks could be mitigated. However, the proponent has not fully developed their mitigation plans and the plans that they have outlined are scientifically dubious. For example, the draft assessment states that destroyed salmon habitat will be mitigated; the “proponent identified 90 000 m2 of lower productivity habitats within five potential offsetting sites that could be modified to increase the productivity of fisheries”, when in fact, the proponent did not present data on productivity of Skeena Estuary habitats for fish at any point in the CEAA process. Without understanding relationships between fish and habitat, the proposed mitigation could actually cause additional damage to fishes of the Skeena River estuary. Independent scientific analyses indicate that mitigation frequently fails to recover original levels of ecosystem function13.
For these stated reasons the CEAA draft report represents a flawed assessment of the environmental risks of the PNW LNG proposal. While we are not decision-makers, we can assess when decisions would be made based on false premises. This is one of those instances. We urge you to reject this draft report.
The CEAA draft report for the Pacific Northwest LNG project is a symbol of what is wrong with environmental decision-making in Canada. An obvious risk of a flawed assessment is that it will arrive at an incorrect conclusion. Indeed, scientific research from other estuaries has found industrial development, such as that proposed by the PNW LNG project, is associated with lasting damage to salmon populations14,15.
While our assessment finds that the CEAA draft report is scientifically flawed, the greater body of science also demonstrates that protection of the Lelu Island/Flora Bank area would benefit the second-largest salmon-producing watershed in Canada. Protection of the Flora Bank area would demonstrate the Liberal Government’s commitment to protection of marine ecosystems, rights of indigenous people, and scientific integrity.
Sincerely,
Signed,
Jonathan W. Moore, Ph.D., Liber Ero Chair of Coastal Science and Management, Associate Professor, Simon Fraser University.
Marvin Rosenau, Ph.D., Professor, British Columbia Institute of Technology.
Charmaine Carr-Harris, M.Sc., Biologist, Skeena Fisheries Commission.
Matthew R. Sloat, Ph.D., Director of Science, Wild Salmon Center, and Adjunct Professor, Oregon State University.
Michael H.H. Price, M.Sc., Salmon Ecologist, SkeenaWild Conservation Trust.
Allen Gottesfeld, Ph.D., P. Geo., Head Scientist, Skeena Fisheries Commission.
Co-signed,
Otto E. Langer, M.Sc., R.P.Bio., Fisheries Biologist, Former Chief of Habitat Assessment, Department of Fisheries and Oceans Canada.
Patrick McLaren, Ph.D., P.Geo., President, SedTrend Analysis Limited.
John G. Stockner, Ph.D., Emeritus Senior Scientist DFO, West Vancouver Laboratory, Adjuct Professor, University of British Columbia.
Barb Faggetter, Ph.D., R.P.Bio., Independent Oceanographer.
David.W. Schindler, Ph.D., Killam Memorial Professor of Ecology Emeritus, University of Alberta.
Charles Simenstad, Ph.D., Professor, University of Washington.
Janvier Doire, M.Sc., R.P.Bio., Biologist, Skeena Fisheries Commission.
Randall M. Peterman, Ph.D., Professor Emeritus and Former Canada Research Chair in Fisheries Risk Assessment and Management, Simon Fraser University.
R. S. Hooton, M.Sc., Former Senior Fisheries Management Authority for British Columbia Ministry of Environment, Skeena Region.
David Bustard, M.Sc., R.P.Bio., Fish Habitat Biologist, Skeena Region.
Alexander I. Vedenev, Ph.D., Head of Ocean Noise Laboratory, Russian Academy of Science.
Kyla Warren, M.Sc. R.P.Bio., Biologist, Skeena Fisheries Commission.
Mark C. Cleveland, B.Sc., R.P.Bio., Head Biologist, Gitanyow Fisheries Authority.
John D. Reynolds, Ph.D., Tom Buell BC Leadership Chair in Salmon Conservation, Professor, Simon Fraser University.
Daniel Schindler, Ph.D., Harriet Bullitt Endowed Chair in Conservation, Professor, University of Washington.
Jim Pojar, Ph.D., R.P.Bio., Senior Ecologist (ESA), Skeena Region.
Rosamund Pojar, M.Sc., Botanist, Skeena Region.
Kai M.A. Chan, Ph.D., Canada Research Chair in Biodiversity and Ecosystem Services, Associate Professor, University of British Columbia.
Richard D. Routledge, Ph.D., Professor, Simon Fraser University.
Evelyn Pinkerton, Ph.D., School of Resource and Environmental Management, Professor, Simon Fraser University.
Julian D. Olden, Ph.D., Associate Professor, University of Washington.
Hadi Dowlatabadi, Ph.D., Canada Research Chair in Applied Mathematics and Integrated Assessment of Global Change, Professor, University of British Columbia.
Phil LePage, M.Sc., R.P.F., Research Silviculturist, Skeena Region.
Karen Price, Ph.D., Consulting Ecologist, Skeena Region.
Michael Nelligan, B.Sc., R.P.Bio., Biologist and College Instructor, Northwest Community College.
Mary E. Power, Ph.D., Professor, University of California, Berkeley.
Chris T. Darimont, Ph.D., Associate Professor, University of Victoria.
Karen Kubiski, M.Sc., P.Ag., Dragonfly Ecological Services.
Dana Lepofsky, Ph.D., Professor, Simon Fraser University.
Dawn Remington, M.Sc., R.P.Bio., Aquatic Ecologist.
Peter B. Moyle, Ph.D., Professor, University of California.
John Volpe, Ph.D., Associate Professor, University of Victoria.
Nicholas Dulvy, Ph.D., Canada Research Chair in Marine Biodiversity and Conservation, Professor, Simon Fraser University.
Len Vanderstar, B.Sc., R.P.Bio., Consulting Ecologist, Skeena Region.
Ken Lertzman, Ph.D., Professor, Simon Fraser University.
Sarah P. Otto, Ph.D., Professor and Director, Biodiversity Research Centre, University of British Columbia.
Michael Doebeli, Ph.D., Professor, University of British Columbia.
Charles J. Krebs, Ph.D., Professor, University of British Columbia.
Alexandra Morton, B.Sc., Biologist, Pacific Coast Wild Salmon Society.
Jack A. Stanford, Ph.D., Professor of Ecology, University of Montana.
Isabelle M. Côté, Ph.D., Professor, Simon Fraser University.
Martin Krkosek, Ph.D., Assistant Professor, University of Toronto.
Gordon F. Hartman, Ph.D., Fisheries Scientist.
Kevin Koch, B.Sc., R.P.Bio. Fish and Wildlife Biologist, Gitanyow Fisheries Authority.
Daniel L. Bottom, M.Sc., Estuarine Ecologist.
Amanda Vincent, Ph.D., Professor, University of British Columbia.
Aerin Jacob, Ph.D., Postdoctoral Fellow, University of Victoria.
Mark Novak, Ph.D., Assistant Professor, Oregon State University.
Jon Armstrong, Ph.D., Assistant Professor, Oregon State University.
Susan Johnson, Ph.D., Fisheries Biologist.
Suzanne Bayley, Ph.D., Emeritus Professor, University of Alberta.
Karen Diemert, B.Sc., R.P.Bio., Ecosystem Biologist, Skeena Region.
Lynn Westcott, M.Sc., R.P.Bio., Independent Biologist, Skeena Region.
Tania Millen, B.Sc., Environmental Scientist, Skeena Region.
P. Sean McDonald, Ph.D., Research Scientist, University of Washington.
Peter Westley, Ph.D., Assistant Professor of Fisheries, University of Alaska Fairbanks.
Anne Beaudreau, Ph.D., Assistant Professor of Fisheries, University of Alaska Fairbanks.
Douglas A. Holdway, Ph.D., Canada Research Chair in Aquatic Toxicology, Professor, University of Ontario Institute of Technology.
Briony E.H. Penn, Ph.D., Adjunct Professor, University of Victoria.
Natalie Ban, Ph.D., Assistant Professor, School of Environmental Studies, University of Victoria.
Nick Gayeski, Ph.D., Aquatic Ecologist, Wild Fish Conservancy.
Jennifer Harding, Ph.D., Aquatic Ecologist.
Jack E. Williams, Ph.D., Senior Scientist, Trout Unlimited.
Travis G. Gerwing, Ph.D., Postdoctoral Fellow, University of Victoria.
Michelle C. Nelson, Ph.D., Fisheries Ecologist.
Brendan Connors, Ph.D., Senior Systems Ecologist, ESSA Technologies Ltd., Adjunct Professor, Simon Fraser University.
Lawrence Dill, Ph.D., Professor Emeritus, Simon Fraser University.
Bill McMillan, Fisheries Biologist, Wild Fish Conservancy.
Amy Haak, Ph.D., Conservation Biologist, Trout Unlimited.
Leslie M. Johnson, Ph.D., Professor, Athabasca University.
John E. McCosker, Ph.D., Chair of Aquatic Biology, Emeritus, California Academy of Sciences.
Eric Higgs, Ph.D., Professor, University of Victoria.
Paul C. Paquet, Ph.D., Senior Scientist, Raincoast Conservation Foundation, Adjunct Professor, University of Victoria.
Aaron C. Hill, M.Sc., Executive Director, Watershed Watch Salmon Society.
Heather Tallis, Ph.D., Chief Scientist, The Nature Conservancy, Adjunct Professor, University of California, Santa Cruz.
Richard A. Cunjak, Ph.D., Professor, University of New Brunswick.
Jeremy Kerr, Ph.D., University Research Chair in Macroecology and Conservation, Professor, University of Ottawa
Eduardo Martins, Ph.D., Liber Ero Postdoctoral Fellow, University of Waterloo.
Wyatt F. Cross, Ph.D., Associate Professor, Montana State University.
Hugh MacIsaac, Ph.D., Canada Research Chair Great Lakes Institute for Environmental Research, Professor, University of Windsor.
John McMillan, M.Sc., Steelhead Science Director, Trout Unlimited.
Emma J. Rosi-Marshall, Ph.D., Senior Scientist, Cary Institute of Ecosystem Studies.
Megan V. McPhee, Ph.D., Assistant Professor, University of Alaska Fairbanks.
Stan L. Proboszcz, M.Sc., Science Advisor, Watershed Watch Salmon Society.
Brian Cumming, Ph.D., Professor, Queen's University.
James A. Estes, Ph.D., Professor, University of California.
Andrew Whiteley, Ph.D., Assistant Professor, University of Montana.
Eric P. Palkovacs, Ph.D., Assistant Professor, University of California-Santa Cruz.
Michael Healey, Ph.D., Professor Emeritus, University of British Columbia.
Craig Orr, Ph.D., Conservation Advisor, Former Executive Director, Watershed Watch Salmon Society.
Andrew Hendry, Ph.D., Professor, McGill University.
Colden V. Baxter, Ph.D., Associate Professor, Idaho State University.
F. Richard Hauer, Ph.D., Professor and Director, Center for Integrated Research on the Environment, University of Montana.
Davide Latremouille, M.Sc., Fisheries Habitat Biologist, Skeena Fisheries Commission.
Emily Bernhardt, Ph.D., Professor, Duke University.
James K. Rowe, Ph.D., Assistant Professor, University of Victoria.
Eric M. Anderson, Ph.D., Faculty, British Columbia Institute of Technology.
Gail McCabe, Ph.D., University of Toronto.
Justin D. Yeakel, Ph.D., Assistant Professor, University of California.
Barrie Gilbert, Ph.D., Wildlife Ecologist, Former Professor, Utah State University.
Taal Levi, Ph.D., Assistant Professor, Oregon State University.
Nikolaus Gantner, Ph.D., Adjunct Professor, University of Northern British Columbia.
Claudia R. Copley, M.Sc., Biologist, Royal British Columbia Museum.
Jeff Stuart, Ph.D., Biological Sciences, Brock University.
Rachel Malison, Ph.D., Marie Curie Fellow and Research Ecologist, The Norwegian Institute for Nature Research.
Alejandro Frid, Ph.D., Science Coordinator/Ecologist, Central Coast Indigenous Resource Alliance.
Abby Lippman, Ph.D., Professor Emerita, McGill University.
Steven J. Cooke, Ph.D., Canada Research Chair in Fish Ecology and Conservation, Carlton University.
Faisal Moola, Ph.D., Adjunct Professor, Faculty of Environmental Studies, York University.
Richard Bailey, Ph.D., Microbial Geneticist (Retired).
M. Jake Vander Zanden, Ph.D., Professor, University of Wisconsin-Madison.
Alexander Shubin, M.Sc. Fisheries Biologist, Sakhalin Research Institute of Fisheries and Oceanography.
Ian C. Colquhoun, Ph.D., Associate Professor, Western University.
David Lesbarrères, Ph.D., Associate Professor, Laurentian University.
Alicia Fernando, B.Sc., Biologist, Gitksan Watershed Authorities.
Tessa Francis, Ph.D., Research Scientist, University of Washington.
Donna Macintyre, B.Sc., Fisheries Director, Lake Babine Nation.
Ian A. Fleming, Ph.D., Professor, Memorial University of Newfoundland.
Brett Favaro, Ph.D., Liber Ero conservation fellow, Memorial University of Newfoundland.
Patricia Gallaugher, Ph.D., Adjunct Professor, Simon Fraser University.
Victor Afanasiev, Ph.D., Russian Academy of Sciences.
S. Misty MacDuffee, B.Sc., Conservation Biologist, Raincoast Conservation Foundation.
Anne Salomon, Ph.D., Associate Professor, Simon Fraser University.
Arne Mooers, Ph.D., Professor, Simon Fraser University.
Walter Duffy, Ph.D., Adjunct Professor, Humboldt State University.
Walter Joseph, Fisheries Manager, Office of the Wet’suwet’en, Wet’suwet’en Nation.
John L. Largier, Ph.D., Professor, University of California Davis.
Lynne M. Quarmby, Ph.D., Professor, Simon Fraser University.
Wendy J. Palen, Ph.D., Associate Professor, Simon Fraser University.
Citations
1 Canadian Environmental Assessment Agency (CEAA). 2016. Pacific Northwest LNG draft environmental assessment report. Available: http://www.ceaa.gc.ca/050/document-eng.cfm?document=104785.
2 Manzer, J.I. 1956. Distribution and movement of young Pacific salmon during early ocean residence. Fisheries Research Board Progress Report #106, 24-28.
3 Higgins, R.J., and Shouwenburg, W.J. 1973. A biological assessment of fish utilization of the Skeena River estuary, with special reference to port development in Prince Rupert. Northern Operations Branch, Fisheries and Marine Service, Department of the Environment. Technical Report 1973-1.
4 Hoos, L.M. 1976. The Skeena River estuary status of environmental knowledge to 1975. Report of the Estuary Working Group, Department of the Environment, Regional Board (Pacific Region). Special Estuary Series No. 3.
5 Carr-Harris, C., Gottesfeld, A.S., and Moore, J.W. 2015. Juvenile salmon usage of the Skeena River estuary. PlOS one 10: e0118988.
6 Moore, J.W., Carr-Harris, C., and Gordon, J. 2015. Salmon science as related to proposed development in the Skeena River estuary. Report to Lax Kw’alaams Band Council.
7 Moore, J.W., Carr-Harris, C., Gottesfeld, A.S., MacIntyre, D., Radies, D., Barnes, C., Joseph, W., Williams, G., Gordon, J., and Shepert, B. 2015. Selling First Nations down the river. Science 349: 596.
8 Committee on the Status of Endangered Wildlife in Canada (COSEWIC). 2016. Eulachon (Thaleichthys pacificus) Nass/Skeena River population. Available:
9 Pickard, D., Porter, M., Olson, E., Connors, B., Kellock, K., Jones, E., and Connors, K. 2015. Skeena River estuary assessment: technical report. Available: http://skeenasalmonprogram.ca/library/lib_433/.
10 McLaren, P., 2015. The environmental implications of sediment transport in the waters of Prince Rupert, British Columbia, Canada: a comparison between the kinematic and dynamic approaches. Journal of Coastal Research. In-Press. Available: http://www.jcronline.org/doi/pdf/10.2112/JCOASTRES-D-15-00134.1
11 McLaren, P., 2015. An assessment of the “Supplemental Report for 3D Modelling Update” prepared by Hatch for PNWLNG, November 2015.
12 Canadian Environmental Assessment Agency (CEAA). 2016. From Fisheries and Ocean Canada and Natural Resources Canada to the Canadian Environmental Assessment Agency re: request for advice and comments on Pacific Northwest LNG Ltd.’s November 10, 2015 submission. Available: http://www.ceaa.gc.ca/050/document-eng.cfm?document=104462.
13 Rey Benayas, J.M., Newton, A.C., Diaz, A. and Bullock, J.M. 2009. Enhancement of biodiversity and ecosystem services by ecological restoration: a meta-analysis. Science 325: 1121-1124.
14 Magnusson, A. and Hilborn, R. 2003. Estuarine influence on survival rates of coho (Oncorhynchus kisutch) and chinook salmon (Oncorhynchus tshawytscha) released from hatcheries on the U.S. Pacific coast. Estuaries 26: 1094-1103.
15 Meador, J.P. 2014. Do chemically contaminated river estuaries in Puget Sound (Washington, USA) affect the survival rate of hatchery-reared Chinook salmon? Canadian Journal of Fisheries and Aquatic Sciences 71: 162-180.