1
Toll-free: 1.855.248.3631
Email: info@lngcanada.ca www.LNGCanada.ca
Page 5.8-59: Table 5.8-10 does not show all areas of permanently altered or destroyed fish habitat (i.e., dredge area, riparian vegetation). This table needs to be revised to provide all areas of the project footprint that will result in the permanent alteration or destruction of fish habitat. DFO requires this information to understand the project impacts and comment on the appropriateness of mitigation, avoidance and offsetting measures.
Serious harm occurs as the result of death of fish, permanent alteration of fish habitat or the destruction of fish habitat. The definition of Serious Harm is provided in the Fisheries Protection Policy . The reference on page
5.8-3 of the application with respect to DFO interpretation of Serious Harm is not correct in that it does not address Permanent Alteration of fish habitat. The loss on benthic community within the dredge area will likely diminish the ability of fish to use the area to carry out one or more of their life processes. The description of
"temporary disturbance" in the application and subsequent memo does not reflect Serious Harm as defined in the Fisheries Protection Policy . To accurately reflect the project impacts, all project components resulting in
Serious Harm should be summarized in a table. Fisheries Act authorization would be required for residual
Serious Harm that results in localized effects. DFO antipates that not all serious harm resulting from the project would require authorization. It is DFO's understanding that the areas summarized in table 5.8-10 of the application represent Serious Harm that LNG Canada anticipates will result in localized effects requiring authorization. The revised table 5.8-10 in the memo Permanent Alteration or Destruction of Marine Riparian
Habitat has also included the area of riparian habitat that LNG Canada does not assume will require authorization. The Conceptual Offsetting Plan focusses on offsets to these impacts that are generally higher value habitat in which there is high certainty that authorization will be required (e.g., eelgrass beds). The intent of including all project components resulting in Serious Harm within summary tables would ensure that DFO,
BC EAO and working group members understand all potential project impacts resulting in Serious Harm.
The title and contents of Table 5.8-10 have been revised to represent all marine habitats that have the potential to be permanently altered or destroyed by Project activities and works (see below). This involved the addition of the final row depicting marine riparian habitat.
LNG Canada Development Inc.
Three Bentall Centre
3113-595 Burrard Street
PO Box 49162
Vancouver, BC V7X 1J1
Canada
Joint venture companies

Table 5.8-10 has been revised to include dredging and disposal at sea activities. With the addition of these activities this table now includes all Project activities that have potential to result in the death of fish or the permanent alteration or destruction of fish habitat defined as Serious Harm to commercial, recreational or aboriginal (CRA) fisheries by the Fisheries Act and DFO’s Fisheries Protection Policy . Death of fish is listed as a potential effect but is not expected to occur on a large spatial scale during Project activities (see Section
5.8.5.4 of the EA Application to review characterization of harm to fish). Not all of the Project activities listed in
Table 5.8-10 are expected to result in localized effects to a fish population or stock and therefore may not require a Fisheries Act authorization. Project activities requiring an authorization will be determined in consultation with DFO.
Table 5.8-10: Total Area of Marine Fish Habitat Types Potentially Permanently Altered or Destroyed
Habitat
Type a
Productive
Capacity
Salt marsh High; important fish habitat
Habitat
Description
Marsh vegetation and tidal channels
Project Activity
• Construction of heavy haul road and materials offloading facility
Intertidal mudflat
Eelgrass bed
Low; marginal fish habitat
High; important fish habitat
Constructed intertidal
Low; marginal fish habitat
Mud and tidal flat
Patchy eelgrass bed
• Dredging
• Construction of heavy haul road and materials offloading facility
• Installation of sheet pile wall
• Dredging
• Altered sediment transport
Rock riprap • Excavation of RTA
Wharf “B” and Methanex jetty
• Construction of early offloading facility and materials offloading facility
Effect Type and Potential for Serious
Harm to Fish c
• Destruction of 84,000 m 2 of salt marsh habitat (see Section 5.8.5.2 of the Application)
• Death of fish (see Section 5.8.5.4 of the Application)
• Permanent alteration of 43,600 m 2 of intertidal mudflat habitat (see
Section 5.8.5.2 of the Application)
• Destruction of 8,068 m 2 of intertidal mudflat habitat (see Section
5.8.5.2 of the Application)
• Death of fish (see Section 5.8.5.4 of the Application)
• Destruction of 3,262 m 2 of eelgrass habitat (see Section 5.8.5.2 of the
Application) d
• Death of fish (see Section 5.8.5.4 of the Application)
• Destruction of 14,193 m 2 of constructed intertidal habitat (see
Section 5.8.5.2 of the Application)
• Death of fish (see Section 5.8.5.4 of the Application)
2

Table 5.8-10: Total Area of Marine Fish Habitat Types Potentially Permanently Altered or Destroyed
Habitat
Type
Productive
Capacity b
Habitat
Description
Project Activity Effect Type and Potential for Serious
Harm to Fish c
Subtidal mudflat
Low; marginal fish habitat
Shallow water mud seabed
•
•
Dredging
Soil improvements and scour protection
• Installation of piles and sheet pile wall
• Permanent alteration of 190,800 m 2 of subtidal mudflat habitat (see
Section 5.8.5.2 of the Application)
• Death of fish (see Section 5.8.5.4 of the Application)
Subtidal soft substrate
Low; important fish habitat
Deep water basin with mud seabed
• Disposal at sea • Permanent alteration of up to 1.2 million m 2 of subtidal soft substrate habitat (see Section 5.8.5.2 of the
Application) d
• Death of fish (see Section 5.8.5.4 of the Application)
Marine riparian
Low; marginal fish habitat
Terrestrial vegetation
(grasses, sedges, trees)
• Construction of heavy haul road and early offloading facility
• Installation of sheet pile wall
• Permanent alteration and destruction of 16,049 m 2 of marine riparian habitat (see Section
5.8.5.2 of the Application)
NOTES: a See Table 5.8-8, Section 5 of the Application, for definitions. b Definitions from Table 5.8-9 DFO (1998) Classifications for Productive Capacity, Section 5 of the Application:
• Critical fish habitat – Habitats considered to be rare, to have high productive capacity, and to support fish during sensitive life stages.
• Important fish habitat – Habitats used by fish for feeding, growth, and migration that, while important to the fish stock, are not considered critical. This may be because there is a relatively large amount of similar habitat that is readily available to the stock, or because the habitat has been disrupted by past human activity.
• Marginal fish habitat – Habitat considered to have low productive capacity and to contribute only marginally to fish production. c “Serious harm” includes: (1) the death of fish; (2) a permanent alteration to fish habitat of a spatial scale, duration or intensity that limits or diminishes the ability of fish to use such habitats as spawning grounds, or as nursery, rearing, or food supply areas, or as a migration corridor, or any other area in order to carry out one or more of their life processes; and (3) the destruction of fish habitat of a spatial scale, duration, or intensity that fish can no longer rely upon such habitats for use as spawning grounds, or as nursery, rearing, or food supply areas, or as a migration corridor, or any other area in order to carry out one or more of their life processes (DFO 2013). d Based on a total disposal volume of 3.5 million m 3 with a thickness of 3 m on the seabed.
The alteration and destruction of marine riparian habitat in the LSA was not considered to constitute serious harm to fish in Section 5.8.5.2.4 of the Application because CRA fishery species do not rely on this marginal habitat to carry out their life processes and its loss is not expected to result in localized effects to local fish populations. In comparison to salt marsh and eelgrass habitats, marine riparian habitat was determined to contribute relatively little to the overall productive capacity of adjacent marine fisheries. It was assessed as marginal fish habitat (Figure 5.8-8, Table 5.8-8) because it is not an important factor in temperature regulation
3

(i.e., shade) or an important source of food and nutrients, though coarse debris inputs may contribute to cover and it may filter eroded sediment from upland areas.
Table 5.8-10 now identifies dredging and disposal at sea as having the potential to cause serious harm to CRA fish (i.e., the death of fish, permanent alteration of fish habitat). At the time the Application was submitted to the
EAO, dredging and disposal at sea were anticipated to result in a temporary alteration of fish habitat, and not a permanent alteration. DFO has clarified that these activities should be considered as permanent alteration because they are likely to limit or diminish the ability of certain fish species to use affected habitats for carrying out life processes for the duration of the activity.
Bilkovic, D.M. 2011. Response of tidal creek fish communities to dredging and coastal development pressures in a shallow-water estuary. Estuaries and Coasts 34:129–147.
Fisheries and Oceans Canada (DFO). 1998. Habitat Conservation and Protection Guidelines , 2nd Edition.
Fisheries and Oceans Canada. Ottawa, ON.
Fisheries and Oceans Canada (DFO). 2013a. Fisheries Protection Policy Statement . Fisheries and Oceans
Canada. Ottawa, ON.
Newell, R.C., L.J. Seiderer and D.R. Hitchcock. 1998. The impact of dredging works in coastal waters: A review of the sensitivity to disturbance and subsequent recovery of biological resources on the sea bed. Oceanography and Marine Biology 36:127−172.
4