Legislative Office:

Room 145, Parliament Buildings

Victoria, B.C. V8V 1X4
Phone: 250 952-7594
Fax: 250 952-7598
e-mail: vicki.huntington.rnla leg.be,ca

Legislative Assembly
Province of Brit sh Columbia
Vicki Huntington, M.L.A.

(Delta South)

Constituency Office:
4805 Delta Street
Delta, B.C. V4K 2T7

Phone: 604 940-7924

Fax: 604 940-7927
www. vicki hu nti ngton ,ca

February 15, 2016

B.C. Environmental Assessment Office

836 Yates St.

Victoria, BC V8W 1L8
To whom it may concern:

Re: Massey Tunnel Replacement Project, Project Description and Key Areas of Study
Please consider the following my comments on the Project Description and Key Areas of Study
Document for the proposed George Massey Tunnel Replacement Project.
As a general comment, I am concerned that the timeline of the environmental assessment

process is too short to give proper consideration and deliberation on the project s potential
effects. I am concerned this will undermine the credibility and quality of the project assessment
and suggest the timeline should be extended.
Additionally, I trust that the concerns identified by Corporation of Delta staff will be given due
attention as part of the assessment process, including hedgerow loss, irrigation, post

construction air quality monitoring, cycling linkages, and heritage resources.

I would also like to highlight Delta's concern about assessing and mitigating temporary effects
during construction, which will directly affect residents and wildlife. Noise due to pile driving
and other activities, as well as the effects of construction delays, should be minimized as much
as possible. Details on mitigation efforts for noise and construction delays should be identified
during the assessment process. Temporary environmental effects for staging and temporary

road-use activities should also be minimized and fully reversible. Finally, 1 support Delta's
statement that the Marina Gardens development must be included as part of the assessment,
looking at both human health impacts and cumulative environmental effects.
I have provided a number of comments on specific sections on the Project Description and Key
Areas of Study document below.
2.3 - Reduced congestion - The proponent should be required to quantify and
consider the impacts on congestion beyond the scope of the project. It is plausible that

traffic may be improved at the crossing itself and this may have benefits for those
making trips between Delta and Richmond. But the government s documents show 40
per cent of northbound morning traffic is destined to Vancouver1. A key concern
expressed by many stakeholders, including myself, is that the traffic bottleneck that
exists at the Massey Tunnel will simply move north to the Oak Street Bridge, which
already faces significant congestion issues.
2.3 - Improved transit - The proponent should offer travel time savings estimates
across all road users. Time savings for transit users, in comparison to the current

baseline, should be quantified to better understand the extent of improvement offered

by the project. The proponent should provide estimates of any increased demand
expected to TransLink as a result of the improved transit for planning purposes. Further,
the proponent should develop high-level planning documents that outline future rapid
transit options enabled by the project.
2.3 - Enhanced environment - A 2014 government-commissioned report by MMK

Consulting noted the new bridge scenario would not appreciably reduce greenhouse gas
emissions in comparison to other replacement options for the Massey Tunnel. The
bridge option was projected as having higher levels of traffic growth than [maintaining
the existing tunnel]. 2 Though it was noted that reduced travel times would result in less
idling times and therefore better fuel economy on average, On balance, total emissions
[were] expected to be similar to [maintaining the existing tunnel]. 3 Given this
discrepancy, the proponent should be required to quantify the amount of greenhouse
gas reductions expected from the bridge, if any. The analysis should look beyond the
footprint of the actual project and include the expected effects the project will have on
other congestion areas across the Lower Mainland, including at the Oak Street Bridge. In
particular, it is critical that the analysis estimate and consider any induced traffic
demand the bridge may enable as part of its scope, and not simply the reduced idle
times. If the project is found to increase emissions, the proponent should be required to
offer potential mitigation options, including increased investment in local transit service.
Finally, the analysis should control for increased fuel efficiency brought about by
changes in automotive technology, so as not to skew conclusions.

5.1-7; 5.9-14 - Marine Shipping and Cumulative Effects - The Ministry notes that
studies will be conducted to determine marine traffic frequency and volume." There is
widespread concern that replacing the tunnel with a bridge could increase marine vessel
traffic beyond the bridge location, up the Fraser River, especially as new industrial ports
come online. Any studies of marine use related to the project must examine this
possibility. If marine vessel traffic is likely to increase as a result of this project, then the
1 Government of British Columbia (November, 2012). George Massey Tunnel Replacement Project - Planning for
the Future. Phase 1: Understanding the Need, Consultation Discussion Guide. Online at
http://engage.gov.bc.ca/masseytunnel/files/2012/ll/George-IVlassey-Tunnel-Replacement-Project-Discussion-

Guide.pdf
2 MMK Consulting (March, 2014). George Massey Tunnel Replacement Project: Evaluation of Crossing Scenarios.
Online at http://engage.gov.bc.ca/masseytunnel/files/2015/06/GMT-2014-March_Evaluation-of-CrossingScenarios.pdf
3 Ibid.

induced effects of that traffic on all aspects of the environment and human health need
to be evaluated as part of the cumulative effects assessment for the project even if
those effects are beyond the physical footprint of the project. This would include any
effects on vulnerable marine species, including endangered Southern Resident Killer
Whale populations.
5.1 - Land and Water Use - The proponent anticipates no-net-loss of agricultural

land , but exactly how this will be achieved will require more detail. This commitment is
welcome, but the proponent should be required to offer further detail on the range of
land loss or gain anticipated by the project.
5.8 - Terrestrial Wildlife" - The proponent notes the Ministry is documenting the
presence of different bird species along the project alignment, and identifying the
collision risk for bird species due to the construction of the bridge and associated
infrastructure. The proponent should be required to mitigate any increased risk of
collision with species-at-risk, such as the barn owl.

5.9 - "Air Quality" - The proponent should be required to consider the effects the
project will have on greenhouse gas emissions, in addition to the air contaminants
identified in this section. As mentioned in my earlier comments on section 2.3, the
analysis of emissions should include not only the effects of reduced idling time and
increased fuel economy, but of increased traffic brought on by induced demand enabled
by the bridge. It should also consider any added congestion brought about at locations
outside the project boundaries, including the Oak Street Bridge.

Thank you for consideration.

Best regards,

Vicki Huntington, MLA

Delta South