Vancouver Airport Fuel Facilities Corporation

c/o FSM Management Group Inc.

Suite 103 -12300 Horseshoe.Way
Richmonl1, B.C., Canada, V7A 4Z1
Phone: (604) 271-7113
Fax: {604) 2718006
January 17, 2012
Carrie Brown, P .Geo.
Manager, Environmental Programs
Port Metro Vancouver
100 The Pointe, 999 Canada Place
Vancouver, BC
V6C3T4
Dear Ms. Brown:
Re: PMV Comments, VAFD Project, Agency and First Nations Tracking Table (November 18, 2011
Version)- Proponent Responses
fam writing in response to your letter of 20 December 2011 to Rachel Shaw, Project Assessment .
Dlrector
1
B.C. Environmental Assessment Office (EAO}, which sets out Port Metro Vancouver's (PMV's)
comments on the 18 November 2011 version of the Agency and First Nations Issues Tracking Table for
the Vancouver Airport Fuel Delivery Project's (the Project) application for an Environmental Assessment
Certificate (the Application).
Appendix A to this letter gives our detailed responses to PMV's comments. We also have a few
additional comments, as follows:
Single Point Mooring and Deep Water Fixed Terminal options: Vancouver Airport Fuel Facilities
Corporation (VAFFC} commissioned a detailed and independent comparative analysis of Project
delivery alternatives. A copy of the report has been forwarded for your information. Please contact
me directly ifyou have any further questions on the Single Point Mooring and Deep Water Fixed
Termrnal options.
Southern Resident Killer Whales (S.RKWs}: PMV's statement that they will rely on Fisheries and
Oceans Canada (DFO} to assess Issues rela.ting to SRKWs is noted.
Air Quality Assessment: Following our 05 January meeting where further clarification and rationale
was discussed, we recognize that PMV requires a different approach to modeling Greenhouse
Gasses (GHG's) related to the Project. We are now re-modeling GHG's using the agreed upon US
EPA MOVES madel
1
Instead of the NON ROAD and MOBILE models previously useci and expect the
results will be forwarded to PMV and the EAO by the end of January 2012.
1
Contaminant Risk Potential: We appreciate PMV's comments on the Screening Level Contaminated
Sites A s s e s s m e n ~ In particular the Identification of a site wlth known contamination. This
information is useful and will assist with the management of contaminated sites in the Construction
.Environmental Management Plan to be developed prior to the start ofconstruction. This plan will
be provided to PMV.and EAO for review.
Please do not hesitate to contact me if you have any questions or clarifications regarding our responses.
You can reach me at 604-271-7113.
Sincerely,
Vancouver Airport Fuel Facilities Corporation
Adrian Pollard, P.Eng.
Project Director
CC: Rachel Shaw, Project Assessment Director, BC Environmental Assessment Office
2
Appendix A to the 10 January 2012 letter from VAFFC to Carrie Brown (PMV}
Comment Theme PMVComment Proponent Response
I'D#
3g Project PMV reserves comment until we have had an Noted. VAFFC voluntarily engaged two consulting firms,
Alternatives opportunity to review the "options analysis" that Golder Associates and Ausenco-Sandwell, both with
VAFFC has completed or at least until we have extensive marine and environm-ental engineering
received a compelling rationale for not selecting either experience, to jointly undertake a more detailed and
the single point mooring and deep water terminal independent comparative analysis of these and other
alternatives. Please advise when the analysis report or Project delivery alternatives. Early in this Project review,
rationale wHJ be available. We anticipate that VAFFC both the EAO and CEA Agency clarified that the review of
will provide a copy i r ~ l y to PMV when submitting alternative projects was not within the scope of this
this to the EAO. Project review. We commissioned the study to respond to
the public interest in more information on the selection of
the current project for review. The EAO has not
requested this further study, nor has it been filed as part
of the record for review of this Project. A copy of the
report has been forwarded for your information.
3h Project Same comment as for #3g above. See the response provided to Comment #3g.
Alternatives
3m First Nations PMV will provide comment in respect of the draft First We understand that PMV are discussing this topic
Interests Nations Consultation Summary Report under separate internally with some areas requiring clarifications. We
cover. look forward to receJving PMV's comments, but note that
this topic is best addressed between PMV and the EAO.
3p First Nations PMV wiiJ provide comment in respect of the draft First See the response provided to Comment #3m.
Consultation Nations Consultation Summary Report under separate
cover.
3q Consultation Given that the EA is a harmonized provincial and Pre-Application information distribution and consultation
federal process, the First Nations, municipal and public with government, First Nations and the public is detailed
consultation is intended to satisfy both the provincial in Chapter 3 of the Application. This chapter was .prepared
and federal EA consultation. requirements. In tliis in accordance with the requirements of the coordinated
regard, PMV, as lead for the federal EA review, provincial and federal assessment process as stipulated
requires detailed reports for all open houses, meetings during the reviews of the EAO's draft and approved
3 .
TRACKING DATE OF AGENCY/ SUBJECT AREA COMMENTS/ ISSUES ON THE PROPOSED PROJECT'S dAIR PROPONENT {VAFFC) RESPONSES PROPONENT
No. COMMENTS AUTHORITY / fiRST COMMITMENTS
NAnON PROVIDING
COMMENTS (COMMENTS ON THE dAIR REV.O, OCTOBER 20, 2009) (RESPONSES TO COMMENTS RECEIVED ON THE dAIR REV.O)
(COMMENTS ONTHEdAIR REV.1, MARCH 17, 2010) (RESPONSES TO COMMENTS RECEIVED ON THE dAIR REV .1)
{COMMENTS ON THEdAIR REV.2, JULY 27, 2010) (RESPONSES TO COMMENTS RECEIVED ON THE dAIR REV.2)
03/SEP/10 Voncouvcl' Fraser Pooe I. second bullet -
Port Aulhorily

.... key stakeholders and regulatory agendas and oulhorlnes {recanmand oddlng

Acl<nowlooged. h ~ change Is now reflected In 1he AIR
S001een Suszezwlez. "-cod g ultlalties" since VFPA Is not on agency).
Senlof PtonnC'H'
Pooo 9 secQOd o g rog m ph 1 roder VfPA-

tho proposed morioo terminal tJpgrodes ore nor on Poet property and would not be

Acknowlcdgod. This change is oow teflected in 100 AJR
part of the Port's dovelopmenr opptoval process. i.e. PMV would oot be Issuing a
develOPment petmit foe marine temino1 wales.
Sl 22/JAN/10 vancouver Fraser Evoluotioo of Pog! 45 S.ctlon 3.2.1 of the Content Regulce.,...nts fot ttle AQQ:Iicotion Document:

Sec-tion 2.6: Alternative Means of Undertaking the Proposed
Port Authority Altemotlves Project of the Application wOI describe the alternative

PJtematlves evoluoted should include olt not just the ones descrlbed in the options means of carrying out the project os described under the
Sharieen Suszezwiez. evauolloo memo os being most wodhy of consideration. Those "not worthy" con CEAA. Subsection 2.3.4: Fuel Delivery System Options of the
Senior Plonnet po<slbly be reo<liy dismissed but should oeve<theies< be identified. revised dAIR specifies that the Application will indude o
brief dlscvssion of oil potential options consldeted leodng
UO IO thO O<OOOSed Proiecl
TRACKING DATE OF AGENCY / SUBJECT AREA COMMENTS/ ISSUES ON THE PROPOSED PROJECT' S dAIR PROPONENT (VAFFC) RESPONSES PROPONENT
No. COMMENTS AUTHORITY / fiRST COMMITMENTS
NAnON PROVIDING
COMMENTS (COMMENTS ON THE dAIR REV.O, OCTOBER 20, 2009) (RESPONSES TO COMMENTS RECEIVED ON THE dAIR REV.O)
(COMMENTSONTHEdAIR RV.1, MARCH 17. 2010) (RESPONSES TO COMMENTS RECEIVED ON THE dAIR REV .1)
(COMMENTS ON THEdAIR REV.2, JULY 27, 2010) (RESPONSES TO COMMENTS RECElVED ON THE dAIR REV.2)
07/APR/ 10 voncouvef Ai'port

The dAJR shouki out11ne plonned pubSc CC1n$lilfotlon rather than waiting for the

See ptevlous response
Authotlly oppficotfoo. Attematlvely, VAFFC ond EAO should J)r'epore o pubk coosul totioo
Simon R o ~ n s o n plan
Environmento1
Speclollst
61 22/JAN/10 Vancouver Akport Project
Alternatives - The re-Aew of oltemotfves described ~ the dAJR (Pages 45- 46) does

Sec-Hon 2.6: Alternative Means of Undertoldng the Proposed
Authority Altet'notl ves not sound any mote comprehensive than already ptovided by VAfFC In pte- ProjKt of the revised dAIR specifies the scope of the
Simon R o ~ n s o n application lnformodoo. This l.s a topic that ihouki be d isetJSSed with. other oltematlve means of carrying out the project as described
Environmental ogendes a nd the TWG prior to finollling 1M AIR under the CEAA. The AppHco11on wM describe and assess
Speclollsl the ptoposed Project. not otlemotive projects, consistent
with the ptoclice under the 8CEAA and the CEAA
TRACKING DATE OF AGENCY/ SUBJECT AtEA COMMENTS/ISSUES ON THE PROPOSED PROJECT'S dAIR PROPONENT {VAFFC) RESPONSES PROPONENT
No. COMMENTS AUTHORITY I fiRST COMMffMENTS
NAnON PROVIDING
COMMENTS (COMMENTS ON THE dAIR REV.O, OCTOBER 20, 2009) (RESPONSES TO COMMENTS RECEIVED ON THE dAIR REV.O)
(COMMENTS ON THE dAIR Rv.1, MARCH 17, 2010) (RESPONSES TO COMMENTS RECEIVED ON THE dAIR REY. l)
( COMMENTS ON TilE dAIR REY.2 , JUlY 27, 2010) (RESPONSES TO COMMENTS RECEI VED ON THE dAIR REV.2)
68 26/JAN/10 Clly of Richmond fire Suppression . Richmond Fife Rescue does not hove capacity nor appropriate equiptnent to
Choptet18: Fire hevntlon, Prepcwedrwtss ond Emet"gency
John Irving, And safely conduct shipboard tlreftghting and there is no waterside fire fighting Response of the ce'vised dAIR spedf.es thot the Application
Director, Engineering Are Rghllng capability on the South Aim. Rlchmooo Rre Rescue emergency response lime to will include detailed lnfoonotion and definition of the
Copobily the proposed tonk form site is ovet nine minutes. which k not conducive to specific fire suppr-ession systems or SQfutioos that wll be In
controlling a fire In this Origin. Considering that the City or any other agency cannot place to address the tire hazard potentioJ ptesented by
ptovide adequate covetoge to the proposed tetmiOO o.nd tonk fc:rm proposed Project infrosttuc ture
sites. VAFFC must provide detailed information ond defirirfon of specific tire
suppcession systems ot solutioos that will be in ploc& to oddt'ess fire hazcwd
69 26/JAN/10 Cily of Richmond Analysis

Provide on onotysls that evaluates each option with consistent criterlo (e.g.

Section 2.6: Altemoflve Means of Undertaking the Propos.c:l
John Irving. tooestrlol ond oquotlc habitat impacts, risk analysis. CO$tS etc .) The assess.men1 Project of the revised dAIR specifies tOO scope of the
Oiteclor, tnglneenng curreotty locks transparency of avolvolion from ons option to another. Mooy oltetnatlve moons of carrying out the project as described
options ore sited to have seismic choleoges yet there Is no modelling Of consistent undef CEAA. The Application will descr1be cod assess the
opplicofioo of sdeoce Or' engineering/technical r1g0Uf' to determine the true proposed Project. oot oJternotfve pcojects, consistent with
nature of the sel.stnic issue the ptoctlce under BCEAA and CEAA.

M. ocknowledged by the EAO In the December 2009 TWG
meeting, VAFFC voluntarily provided lnformolion to the
IWG on !he ldentificotlon and evoluolion of the venous fuel
delivety system options. Andysls of alternative project
moons has been modelling is not a
requkement of regutototy outhorilies. Subsec-tion 2.3.-4: Fuel
Delivery System Options of the revised dAIR spedflos that
the Application wil i.oclude o brief discussion potential
options coosidered leading up to the pcoposed Projec t
12/APR/10 Clly of Richmond . The pcoponent has ooi adequately demonstrated to the City that there ore no . AS noted obOve. the Applic-ation wnt describe and assess
John Irving, othet viable options to the-South Arm tertrinol option presented for evaluation. the ptopos&d Project, not o1temottve p(ojects, consistent
Oitector, Engineenng with the pcoctice under the 8CEAA and the CEAA
02/SEP/10 City of Richmond . Nol soti.sfoctorily resolved. TOO City of Richmond's Council rosotution is reiterated . V AfFC Is ow ewe of tOO City of R'ich.mond's Council rosolutlon
John liVing, here os folows: with respect to the ptoposed Ptojoct V AfFC will continue
Ditec1or. Engineering Apl'fl26. 2010 Council Agendo Item 9 VANCOUVER AJRPOR.l FUEL OEUVERY to wort:: ond consult with the City thtough the
PROJECT envb'onmonta1 assessment review pr-ocoss in occotdonco-
Resolution Number RtOn-s with the BCEAA ond the CEAA
Resolution tt wos moved and seconded:
That the Oiy of Richmond odvise the 8C Environmental ASSessment Office and the
v I>J'FC of the follow'ong:
(I) fhotln o nv new Jt fuel supply systems to the Voocouvet lnternotioool Airport
Richmond Council is strongly oppos-ed to:
(al on off.J.ooding fodlity on the south Om'l of the Froser Rivet:
(b} o new jt fuel loo through Richmond farmland o.nd urban oreos of Richmond:
ond
(c) any lnc roose In the number of l rl.Jcks canyiog tuel on City s1reers.