Roberts Bank Terminal 2 Project - Environmental Impact Statement - Comments on Completeness

The Canadian Environmental Assessment Agency (the Agency) is conducting a completeness review of the Environmental Impact Statement (EIS) submitted by Port Metro Vancouver for the Roberts Bank Terminal 2 project. The review will determine whether information required by the updated Guidelines for the Preparation of an Environmental Impact Statement (EIS Guidelines) is present in a manner that would allow for the Review Panel to begin its technical review of the Project.

Purpose of this resource document

This resource document provides a template (see links below) to assist participants in the environmental assessment to undertake their own completeness review of the proponent's EIS, and to prepare comments they wish to submit to the Agency for consideration in deciding whether and what additional information to request from Port Metro Vancouver. Use of the template is not mandatory. All written comments provided will be considered by the Agency in determining whether the EIS contains enough information for the Review Panel to begin its technical review, or whether additional information is required. Documents submitted for the completeness review will be considered public and posted on the online public registry.

Guiding questions for the completeness review

When reviewing the EIS, the following questions can be used as a guide for the completeness review:

  1. Are there any information gaps that would prevent the Review Panel from undertaking its technical review of the EIS?
  2. Is baseline information detailed enough to appropriately understand the proponent's predictions of the environmental effects of the project?
  3. Is information that was raised during Aboriginal or public consultations missing from the EIS without a rationale as to why?

Examples of comments indicating that additional information may be required by the Agency:

  • A species at risk was not considered in the assessment without a rationale provided for its absence;
  • Valued components suggested by an Aboriginal group are not included in the EIS without a rationale provided for its absence;
  • The proponent did not consider some reasonably foreseeable future projects in its cumulative effects assessment.

At this time, the Agency is NOT seeking a review of technical aspects of the proponent's information, whether the information is correct or whether or not you agree with the conclusions of proponent. These matters will be discussed after the Review Panel is appointed.

Examples of comments that would be more appropriate for later in the process:

  • You agree or disagree with the proponent's conclusions on the significance of the Project's effects on a species, based on the information provided;
  • You recommend the proponent use a different model to predict the potential effects of the Project;
  • You believe the proponent should have included additional measures to mitigate specific environmental effects of the Project.

On April 17, 2015 the Agency requested that Port Metro Vancouver provide additional information as specified in sections 17 (Marine Shipping) and 18 (Provincial Socio-economic Assessment) of the updated EIS Guidelines. The Port has not yet provided information on marine shipping associated with the Project and so this completeness review will focus on sections 1-16, and 18 of the EIS Guidelines. The Agency will consider the completeness of information for section 17 after it has been submitted by the Port, and provide an opportunity for participants to conduct their own review and provide comments.

How to complete the comment template:

Use the headings provided in the table, and to the best of your ability, identify: the general issue; section of the EIS Guidelines where the information is requested; the section of the EIS where the information is, or should be; a rationale as to why information should be present; and, if possible, a request for what additional information you feel is required. If it is not possible to identify sections of the EIS Guidelines or the EIS, please leave those spaces blank, or write "unknown".

Please email your comments or a completed comments template to, or print and mail to:

Debra Myles, Panel Manager – Roberts Bank Terminal 2 Project
Canadian Environmental Assessment Agency
22nd Floor, 160 Elgin Street, Ottawa ON K1A 0H3

SAMPLE Comments on Completeness of Information in the EIS



(if possible, please include reference to the relevant section of the EIS Guidelines)

Reference to EIS

Requested Completeness Information


Provide what you think is the appropriate issue or topic

Provide section(s) or page from the EIS

Clearly and concisely state the additional information being requested from the Proponent

Provide an explanation of the deficiency and include a rationale for why the stated deficiency is important for environmental assessment purposes.

For example:


(EIS Guidelines; 9.1.6, Wildlife)

Volume 7

Chapter 43

Section 7.5.6

Provide a description of calving habitats for moose in the project area.

The EIS does not describe potential or confirmed moose calving habitats as required by the EIS Guidelines.


For example:


(EIS Guidelines: Unknown)

Hunting p. 1208

For each potentially-affected Aboriginal group, assess whether predicted residual effects may interfere with the group's hunting rights and the predicted level of seriousness of that interference.

The EIS Guidelines require the Proponent to describe the potential adverse impacts of the Project on the ability of Aboriginal peoples to exercise their potential or established Aboriginal rights and related interests.

The EIS only provides a description of the predicted residual effects to Aboriginal hunting rights. It does not assess whether the predicted residual effects may interfere with the group's ability to exercise their hunting rights and the predicted level of seriousness of that interference.


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