Roberts Bank

The T2 development is likely to cause significant environmental issues and the degradation of Roberts Bank.

Roberts Bank continues to gain recognition, within Canada and internationally, for its natural abundance and wildlife diversity. This recognition stems from its importance to a wide range of wildlife including: bird species, marine mammals, fish, crustaceans, and shellfish. Regrettably it is also now classified by Birdlife International as an Important Bird Area in Danger, as a result of the industrial development that has already taken place as well as projects in the planning stage.

The largest and most damaging of these projects is Port Metro Vancouver (PMV) plans to build a huge man-made island in the Georgia Strait covering almost 300 acres (one third the size of Stanley Park – Vancouver BC), for a second container terminal (T2) on
Roberts Bank, next door to the existing three-berth Deltaport Container Terminal. This is slap-bang in the middle of the Fraser Estuary. Roberts Bank is a dynamic estuarine environment, the very fulcrum of one of the top ten “Most Important Bird Areas” in the
world and the ecological crucible of the Fraser Estuary.

The environmental issues are extensive and include: negative impacts to migratory birds and shorebirds; population level declines or outright destruction of the Western Sandpiper species; impacts to salmon, especially juveniles, as well as herring and other fish; elimination of areas important to crabs and reduction of crab harvesting; impacts to marine mammals – southern resident killer whales in particular which are listed as an endangered species.

Here are the facts about Roberts Bank and its importance:
• Recognized both in Canada and internationally as a critical ecosystem and one of the richest and most important areas in terms of biodiversity and abundant wildlife on the West Coast.
• Identified by Bird Life International as one of the top sites under the Global Important Bird Area designation.
• Recognized internationally under the Western Hemisphere Shorebird Reserve Network as a site of hemispheric importance. Only eight of these sites exist in the whole of North, Central and South America.
• Designated by the British Columbia Government as a Wildlife Management Area (WMA), wherein they state: “Roberts Bank WMA provides crucial wintering grounds for the highest number of waterfowl and shorebirds found anywhere in Canada”.
• Immediately adjacent to the recently designated Fraser Estuary Ramsar site under the Ramsar Convention, an international treaty for the conservation and sustainable utilization of wetlands. In fact there are proposals to expand the designation to include Roberts Bank.
• A vital stop on the Pacific Flyway (extending from Panama to Alaska) for Migratory Birds. There are only six stop over sites and this one is of major importance.
• Provides a nursery environment for five species of juvenile salmon during their seaward migration.
• Critical habitat for the Southern Resident Killer Whales (Orcas) which are listed as an endangered species under Canada’s Species at Risk Act (SARA) whose purpose is to prevent wildlife species in Canada from disappearing. The Southern Resident Killer Whale (Orca) population consists of three pods that are in real danger of extinction unless their habitat is protected.

Previous studies and Panel Reviews have concluded that the whole area of Roberts Bank is an incredibly important ecosystem and must be protected. The 1979 Panel review for port development concluded that: “From the point of view of estuarine ecology, the Panel has concluded that the potential impacts on the Fraser River estuary, of which Roberts Bank is part, are too great to recommend that the port expansion be approved as proposed. The extent and ecological significance of the Fraser River estuary, particularly its use by fish and wildlife, make it unique in North America. A major salmon fishery depends on it preservation as do hundreds of thousands of migratory birds.”

The same panel discussed mitigation and concluded that: “Mitigation measures such as eelgrass transplants and provisions of new habitat have not been proven in practice on a large scale and, therefore, cannot be accepted as compensation for existing fisheries

These recommendations are as relevant today as they were when first made – perhaps even more so given that much more is now known about the importance of Roberts Bank. Yet Port Metro Vancouver chooses to ignore these important Panel conclusions, preferring instead to put Roberts Bank, one of the richest and most important ecosystems for migrant and wintering waterbirds in Canada, at risk from its push for container terminal expansion whose economics are questionable.

Damage to the Roberts Bank ecosystem has been ongoing since the original construction of the pods for the Westshore Coal Terminal, Deltaport Container Terminal and the associated port causeway.

Originally the rich ecosystem that supported millions of shorebirds extended all the way along the foreshore. But when the original causeway and pods were built it essentially created a “dead zone” between the port causeway and the BC Ferries causeway (known as the intercauseway). Construction of that port causeway and original terminal had unforeseen habitat impacts that were not identified at the time of construction. Because the causeway did not have culverts it prevented tidal flushing of the intercauseway. As a result there has been a rapid expansion of tidal channels in the intercauseway area and it is therefore unstable, with shifting dendritic channels. Equally there was some diversion of the Fraser Plume and it reduced the wave action, interrupted longshore drift and diverted the Fraser plume resulting in increased salinity. On more than one occasion there have been algae blooms.

Shorebirds Trends

The end result is that the productive shoreline and intertidal areas for wildlife have shrunk and become concentrated north of the port causeway in a much smaller area than originally existed. One result of this can be seen in the reductions of bird populations, for example Western Sandpipers (Peeps). The population of Peeps has declined significantly and if T2 goes ahead further decline will be severe, perhaps leading to outright destruction of the species.

T2 becomes the tipping point, because:
• It is located well out into Georgia Strait and therefore impacts tidal flows across the intertidal area closer to shore that is so important to wildlife
• It will impact on the Fraser River Plume and result in changes in the mudflats supporting biofilm
• The expanded port causeway covers over a significant area of biofilm
• The man-made island covers crab habitat
• It has the potential to turn the area north of the causeway into something similar to what the intercauseway (between the port causeway and the BC Ferries causeway) has become – an area of lesser abundance, not much used by shorebirds, prone to
algae blooms, with dendritic channels that are constantly changing thus moving the flats and sediment around.
The negative impacts from T2 range across shorebirds, migratory birds, marine mammals, fish and other species.

Shorebirds (including Migratory Birds)

Scientists have established the crucial nature of biofilm on Roberts Bank5 as a food source for Western Sandpipers, as noted on the BC Government’s websites and backed by the published, peer-reviewed scientific literature. What we now know – from academic and government biologists – is that T2 presents significant risks to, and could destroy, the biofilm on Roberts Bank. The nightmare scenario is that No biofilm Equals No Shorebirds.

Here is what we know about Roberts Bank and its unique importance to the Western Sandpiper:
• The entire world population of Western Sandpipers (the most numerous shorebird on the Pacific Coast of North America) numbers in the millions and migrates along the coast of North America through the Fraser River Delta, enroute to their Arctic breeding grounds. The Fraser River Delta and Roberts Bank is one of only six major stopover sites for refuelling during this breeding migration.
• On Roberts Bank a small area of the mud surface contains biofilm, produced by diatoms and bacteria that settle out of the seawater and binds to the mud, providing extraordinary amounts of nutrient rich forage for huge flocks of migrating sandpipers.
• The “Science and the Environment Bulletin, April/May 2001” revealed that Western Sandpipers are dependent on the unique conditions of the mudflats at Roberts Bank. Due to tidal currents and nutrients flushing out of the Fraser River, the mudflats at Roberts Bank are unusually rich in a biofilm coating which the sandpipers suck up with specialized beaks. The migratory stopover at Roberts Bank is crucial to the survival and sustainability of this tiny shorebird.
• Most of the entire Western Sandpiper species (80-85 percent of the species) stop to feed on Roberts Bank during their spring and fall migrations with as many as 500,000 appearing on a single day. The majority of their diet is biofilm and they feed on little else during their migration.
• Published research shows that Roberts Bank provides a superior type of biofilm for shorebirds that is not found in Boundary Bay, Sturgeon Bank or Sidney Spit, areas, hence the reason that there are more shorebirds on Roberts Bank than at the other sites.

Why is the Roberts Bank Biofilm so Important?

One of the many failures in Port Metro Vancouver’s Environmental Impact Statement for Roberts Bank Terminal 2 is its incomplete and flawed analysis of the potential impacts on the unique biofilm that is present on Roberts Bank.

It appears from the work that Port Metro Vancouver (PMV) carried out in this area that they identified the outcome that they wanted to portray and then built a series of hypotheses to support that outcome.

The many PMV failures in carrying out a robust assessment of the importance of the Roberts Bank biofilm are becoming all too clear. Notably a number of submissions to the Canadian Environmental Assessment Agency (CEAA) on the RBT2 environmental
assessment identify and document a flawed and incomplete environmental assessment. Perhaps one of the more important submissions (June 15 2015) comes from Environment Canada: (
who state: ”… that recent work on Roberts Bank by international scientists has provided new information on the nature of the intertidal diatom community at the time of the spring breeding migration of Western Sandpipers. The global population of Western Sandpipers, a migratory bird, is dependent on the habitat found in the Roberts Bank area. This new information may better explain why these shorebirds (and likely other migratory bird species) concentrate at this site, as opposed to other sites in the Fraser River delta. Further, the occurrence, abundance and nutritional value of these diatoms may have broader implications across trophic levels in relation to ecosystem productivity of the Fraser River Estuary. This new information casts reasonable doubt on some of the Proponent’s key conclusions with respect to biofilm and migratory birds as presented in the EIS.”

Furthermore Environment Canada notes that: “It is unclear how changes in coastal geomorphological processes relating to tidal currents and sedimentation rates over the upper intertidal of Roberts Bank will affect biofilm productivity including in relation to the recently identified diatom”.

Not only that but in reviewing the PMV-created Environmental Impact Statement the Port appears to have lumped diatoms into “marine” and “freshwater”, which based on other research papers that are available seems to greatly oversimplify the complexities of the Roberts Bank system and is a further indication that their analysis is incomplete.

From the published material of the Port Metro Vancouver Technical Advisory Groups (TAG) reports and presentations it would appear that Port Metro Vancouver set out to “prove” that no damage will be done to critical feeding areas on Roberts Bank. The messaging and content of these TAG reports are controlled by Port Metro Vancouver. This is not independent and credible science. Their reports indicate that they are not tackling the key issues and the impact of the T2 man-made island, specifically:
• How is the Roberts Bank biofilm maintained and what changes will result from the T2 man-made island?
• Will T2 alter the predominant tidal current in Georgia Strait, causing it to move closer inshore and impact the biolfilm that is unique to Roberts Bank?
• What are the impacts of destroying a significant portion of that biofilm altogether by widening the causeway?
• What are the impacts on the Fraser River plume – a major contributor to the biofilm?
• What negative impacts will occur as a result of footprint scour, and channel formation?
• What about indirect impacts such as sediment distribution and sediment grain size?

Port Metro Vancouver knows about these impacts, but appears to downplay them.Many of these issues were identified by the Port’s own working groups but then brushed aside. One of their technical working groups, commenting on assessment of potential impacts on shorebird populations, went as far as to state that it was not feasible to carry out such an assessment. They have been told that their approach is not a satisfactory method of understanding the potential for biofilm destruction. Studies which Port Metro Vancouver conducted in the early 2000s, when T2 was first advanced (and then withdrawn), showed that changes in tidal currents and flows could indeed have a negative impact on the Roberts Bank biofilm.

Port Metro Vancouver appears to be trying to downplay the importance of Roberts Bank. In its research reports the importance of biofilm is minimized, implying that it is peripheral and that there are other food sources. They also state that the Sandpipers can go elsewhere to alternate feeding areas and alternative food sources. The Roberts Bank biofilm is a different composition from other biofilm found in lesser abundance nearby; it is scientifically preposterous to suggest that the Sandpipers could switch to alternative food sources.

Their reports suggest that the environmental focus should be on the overall productivity of Roberts Bank. This is a false assumption. Biofilm makes up only 10 percent of the area on Roberts Bank; therefore looking at overall productivity is an invalid approach. The biofilm is close in to shore. On a falling tide the Western Sandpipers feed out to the edge of the biofilm – about 300 metres – but no further. They do not feed on the invertebrates that exist further out and this is proven by the fact that 80 percent of their stomach content is made up of biofilm. The Port Metro Vancouver experts state that “ …. Biofilm can be compared to the salad that accompanies the meat and potatoes”. This is untrue. For Western Sandpipers biofilm is the whole meal.

Recent research papers support these concerns. In one: “Intertidal biofilm distribution underpins differential tide-following behaviour of two sandpiper species during northward migration” published in the “Estuarine, Coastal and Shelf Science Journal” – an international multidisciplinary journal – the research shows the critical importance of Roberts Bank in supporting internationally significant populations of migratory shorebirds and Western Sandpipers in particular.

Key points in the paper include:
• Western sandpipers and dunlin follow ebbing tides while foraging on stopovers.
• Tide following foraging behaviour is stronger for dunlin than western sandpipers.
• Western sandpiper foraging distribution matched biofilm availability. (meaning that this is their preferred food despite other options being available)
• Biofilm, an energy source for shorebirds, merits conservation consideration.
As the paper documents, shorebird species rely on habitats like Roberts Bank, yet these species are becoming increasingly threatened by industrial development, such as the massive Port Metro Vancouver Terminal 2 development.

In another: “Biofilm Consumption and Variable Diet Composition of Western Sandpipers (Calidris mauri) during Migratory Stopover” it notes that major estuarine stopover locations supporting biofilm are often strategic places for transport and other industrial developments (as of course is the case for Roberts Bank). The paper goes on to note that there are a number of important factors to be considered where biofilm is known to exist, because biofilm is such an important food source at key stopover and feeding sites. It is therefore critical to identify the impacts on these important feeding sites in terms of what further industrial development means and indeed whether it should even be allowed.

According to the Western Hemisphere Shorebird Reserve Network the number one cause of shorebird decline is habitat loss and degradation – hence the reason T2 is the tipping point. This is one of the reasons that Birdlife International lists this as an Important Bird Area in Danger. Advances in understanding biofilm and its importance to shorebird feeding have progressed significantly in recent times and the longer term impacts relating to the status and availability of biofilm were simply not known. Neither – until very recently – were the unique nature of the biofilm on Roberts Bank, its properties and importance to shorebirds. Therefore any changes resulting from the existing port complex – facilities built before anyone recognized the global ecological significance of the area and its biofilm – were simply not known, only that Western Sandpipers and certain other species were in decline.

We also know that the Western Sandpiper population has been in decline. It is ranked as ‘High Concern’ in the U.S. Shorebird Conservation Plan and of ‘Moderate Concern’ in the Canadian Shorebird Conservation Plan. We simply cannot afford to risk the
destruction of migratory and shorebird feeding grounds on Roberts Bank by development of a second container port.

Marine Mammals

Six marine mammal species (southern resident killer whales – orcas, transient killer whales, harbour porpoise, humpback whales, fin whales and grey whales) are frequent users of the waters surrounding Roberts Bank as well as the shipping channels used by
vessels calling at terminals on Roberts Bank (as well as other PMV terminals).

These mammals use the deeper waters off the banks and river channels to feed on herring, salmon and eulachon during spawning migration runs. Orcas reside in the area year round and are listed as an endangered species. PMV admits in their Environmental
Impact Statement that the orcas are likely to be further endangered by T2, but then preposterously suggests that T2 impacts are of no consequence since the orcas are already listed as endangered.

Not only will T2 impact marine mammals’ abilities to access food sources (especially orcas that depend on Chinook and chum salmon), but in addition they are increasingly impacted by both physical disturbance and noise from port vessels that both transit the
precise area where they tend to reside as well as when they are at dock. T2 will increase the number of vessel transits – 520 additional transits per year – and thus the noise will be much worse. The noise has been shown to impact the whales’ ability to both communicate and navigate.

The Centre for Whale Research found an increase in the population of Southern Residents over last year to 81 from 79 in its most recent census of killer whales. Whilst this is a small amount of good news, underlying trends are a cause for concern:
• Between 1998 and 2015, the Southern Resident Orca population has declined by about 20% (from almost 100 down to 81).
• During the same period, there have been 40 births and 61 deaths or disappearances. (
• Threats to the Orcas include lower reproduction; general pollution and contaminants; depleted food sources and vessel traffic scaring off their food sources; contact with vessels; acoustic disturbance from vessels and construction noise. See

The Fraser River Estuary and its importance for Fish and other Species

The Estuary is British Columbia’s greatest estuary; the Fraser River is the largest stream in British Columbia. It has global recognition as a wetland of international significance. It is the largest on the Pacific coast of North America (21,703 hectares) and the intertidal wetlands, alone, cover roughly 17,000 hectares. The freshwater flows from the river are so great that, technically the entire southern Strait of Georgia is an estuary.

There are about 80 species of fish and shellfish that spend at least part of their life cycles in the estuary along with 300 species of invertebrates. Juvenile salmon spend days, weeks or months in the estuary before going to the ocean.


Key to the productivity of salmon utilizing the Fraser estuary is the large, shallow tidal flats that are abundant in the estuary but especially at Roberts Bank —fish production is reduced when the young salmon are partially or completely restricted from these rich
feeding grounds. Juvenile salmon in particular use the area around the current Deltaport for feeding and refuge. Port Metro Vancouver refused to install culverts in the port causeway, thus causing the juvenile salmon to have to swim around the terminal. This situation would become even worse if T2 were to be built as the salmon would then have to also swim around the T2 man-made island.

T2 will make a bad situation for salmon rearing even worse, not only because of the obstruction of the terminal but also with the destruction of eelgrass beds that are used by the salmon when feeding and to hide from predators. T2 will increase the loss of
shallow-water areas for feeding of juvenile salmon and further block access of fishes to feeding grounds to the south. T2 and its expanded causeway is effectively a dam across the estuary. That coupled with the T2 man made island will force the juvenile salmon out into the deeper waters of Georgia Strait.



Forage fish, such as herring and sand lance, have declined in the Georgia Strait and around Roberts Bank in recent years. They are an important prey for many seabirds. A corresponding decrease in diving birds that predate on forage fish has also been noted.
This decline is as a result of industrial development and T2 will only make matters worse. Herring are important as a food source for many species and their decline is likely to have cumulative impacts on a number of bird, fish and mammal species that rely on them for food.



The area around Roberts Bank used to be one of the best for crab habitat and crab harvesting. Previous port development on Roberts Bank has negatively impacted the crab habitat. However the T2 development will destroy and further displace crab habitat by paving over part of the remaining habitat, with little likelihood that the crabs will be able to sustain this level of damage to their habitat.

Crab harvesting in the immediate vicinity is important to both First Nations as well as to commercial operators. The changes that result from T2, both in construction as well as in operation are likely to cause significant disruptions. Of equal concern is the likelihood of increased vessel traffic causing sediment disturbance that contains coal dust. It is known that considerable quantities of coal dust sit on the ocean floor adjacent to the Westshore Coal Terminal. If this sediment is disturbed it will further impact the crab habitat and their potential to breed.


Eelgrass, Sandflats, Mudflats, and Marshes

The habitat types that make up Roberts Bank are all inter-connected by the fluvial processes originating in the Fraser River and the marine processes that are brought onto Roberts Bank with each tide change.

Eelgrass is prevalent in the lower sandflats and mudflats and is a highly productive habitat that traps sediment and provides direct feeding for waterfowl and invertebrates as well as providing large inputs into the detritus based food web. The eelgrass beds also provide refuge and nursery areas and physical attributes that protect the shoreline.

Sandflats are washed by marine waters from the Georgia Strait during flooding tides, bringing in marine plankton, fishes and fresh water from the Fraser that are rich in nutrients. Whilst submerged at high tide these sandflats provide feeding and resting areas for water birds such as ducks, diving birds and gulls.

Mudflats occur from the middle to upper tidal zone and are less exposed to wave action. Exposed to longer periods of sunlight they are productive and support a diverse range of food sources for invertebrates fish and water birds. They are also important feeding areas for shorebirds, especially the Western Sandpiper due to the presence of nutrient rich biofilm.

Marshes provide shoreline protection from storms and are sources of nutrients to other habitats. They also provide direct grazing areas for ducks, geese and swans.

If the T2 man-made island is ever built it will have huge negative impacts on the interconnectivity of these various habitats. Such a massive construction will alter tidal flows, change the Fraser River plume and alter the whole area thus reducing its overall productivity. It is also likely that the area on the north side of the causeway will develop attributes similar to those now found in the intercauseway, which has much lower environmental values.