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RE Application for Re-Zoning of The Turf Farm in Delta (Envirosmart Organics Ltd of Delta).

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Hi All: 
I have felt incredibly obligated to address this issue.  Not only is the Turf Farm's composting activities killing eagles and other wildlife it is a major danger to human beings -- both on the adjacent Highway 17 and the Boundary Bay Airport.
Attached please find my submission to the BC Environmental Protection Department.  This states my objection to the active bating of wildlife and then the direct killing of the bated-in birds.
Thanks for your attention to this issue.  Since my last comment on this issue we now know that several eagles have been killed by the adjacent traffic and undoubtedly more will be and it is so likely that humans will also be killed by this irresponsible activity.  I hope the government people responsible will either end such irresponsible baiting or personally get sued by the upcoming grieved parties.  Holding a party and inviting a few thousand birds is OK but holding that party on an active airport runway approach or beside a very busy highway is irresponsible, particularly when you know this is happening.
David Hancock
Hancock Wildlife Foundation Biologist.


Attached report to the BC Environmental Protection Dept:

Acting Deputy Director, Environmental Protection                                                                                    July 28, 2016

200 – 10470  152 Street, Surrey BC V3R 0Y3. 

And to:

Contact person Envirosmart Organics Ltd.,

Daryl Goodwin   604 946-0201

4295 72 Street, Delta BC V4K 3N2


Dear Sirs:         RE Envirosmart Organics Ltd of Delta BC   Application No.  18055:  to compost organic matter and how this application is of danger to protected wildlife and humans.

BACKGROUND:   I have followed the bald eagles’ recovery in BC for 65 years.  More specifically I started aerial surveys of the lower Fraser Valley and specifically the Delta Region in 1963 thru 1966 and now more intensely I have followed the breeding and wintering eagles of our Fraser Valley for the past 20 years.  Today the City of Delta supports the largest breeding and wintering populations of bald eagles in the world.  YES, the largest breeding and wintering bald eagle population in the world!  Over 70 pairs of bald eagles have nested in Delta this season and I estimate that most of the 35,000 bald eagles annually traversing the coast on both their northbound and southbound migration pass through Delta.  Delta is the heartland of the Serengeti for bald eagles.  We host most of the California, Oregon and Washington migrating eagles as well as many of the Alaska, Yukon and northern BC eagles that are driven south each winter by the frozen rivers, in addition to the huge density that breed right here.  Delta is the largest crossroad of this incredible bird – and we have not just benefitted by their incredible clean-up work for us, but we share their benefit and responsibility in maintaining the richest west coast intertidal habitat – the waters of Boundary Bay, Roberts Bank and the Fraser Valley lowlands.   But why is there now a conflict? 

Delta borders the west coast’s richest waterways, the huge intertidal flats of Boundary Bay and Roberts Bank and many miles of the Fraser’s freshwater rivers, creeks and ditches as they disperse into the sea.  No place on earth has the nesting density of bald eagles as does Delta - also supporting the eagle populations of adjacent Surrey, Richmond and Washington State. 

Nesting bald eagles are not just supported by the food produced in these adjacent surrounding shallows but this is greatly supplemented by waterfowl, muskrats, rabbits and particularly voles (the common scourge of the blueberry farmers) that inhabit the adjacent farm fields and ditches.  I will also add we frequently see on our Live Streaming cams (broadcast to the world!) in some of the Delta eagle nests that eagles bring in freshly killed rats. This latter food source is likely largely road killed specimens like those carcasses of raccoons, opossums,  muskrats and even gulls that so frequently show up on our cams.

Wintering eagles, unlike the nesting birds which have to stay close to their nests territories to defend the site from intruders, are free to move great distances daily to scavenge the fall spawned out salmon carcasses on nearby rivers, disperse the coastline to harvest the spring herring and oolachin runs and follow the formerly abundant supply of whale and seal carcasses washed up on most beaches.  Today humans have greatly disrupted these natural events.  Many of the salmon streams are polluted and unproductive, only a few small local runs of herring remain, and seldom does a whale, seal or sea lion carcass wash onto our shores – we have killed them off.  

Our adaptable bald eagles have however shown incredible adaptability.   The nesting birds still largely utilize our abundant shoreline and ditch habitat to secure their food. But more recently, as humans have quit shooting predators, the eagles have moved into the urban environment to utilize human protein waste:  the incredible number of road kills, the farm refuse and to heavily utilize the regional landfill/garbage dump refuse.  I personally see this change of feeding habits of eagles as a fine adaptation of this scavenger-predator to the evolving habitat.  We have simply replaced our wastes for their natural food sources we have depleted.    But there is a problem.

The switch of food sources from natural to artificial can at times present some dangerous outcomes:  dangerous to wildlife and to humans.  This is the unfortunate challenge with the proposed Envirosmart Organics operation in Delta.   For the past 13 years I have followed the winter gathering of bald eagles at the Vancouver Landfill operation in Delta and the surrounding area including the Envirosmart Organics Site.   The Vancouver Landfill site in past years has brought in over 2000 eagles at a time.  My largest one-time counts were just over 1800 eagles.  The Vancouver Landfill Site has been effectively reducing its organic wastes as the contributing Cities force a larger proportion of their people to separate out organic waste.  The problem now arises that this separated organic waste is now being dumped in an even less safe place than at the nearby Vancouver Landfill.  This more dangerous site is the proposed Envirosmart Organics Site.  So why is this Delta site so dangerous? 

The Envirosmart Organics has now proposed to receive up to 150,000 tons annually of this pure organic waste.    This equals over 410 tons per day (How many hundred trucks per day is this?).  That amount of restaurant and supermarket food waste every day will certainly attract and feed thousands of gulls, crows, pigeons, blackbirds and bald eagles.  As an environmentalist I don’t even mind this shift in food supply for these scavenging birds.  However, the Envirosmart Organics Site in Delta is perhaps the most dangerous site possible to wildlife and human life.  To attract thousands of gulls with willful baiting and then seek a “kill permit” to reduce the number of attracted gulls is totally irresponsible.  The issuance of such a Federal “kill permit” only admits to and spreads the liability that such an artificial attraction and hazard causes.  Surely this kill permit authorizes that attracting thousands of birds by artificial feeding and then killing them is acceptable and at the same time is admission of the liability that will follow from such actions.  That the British Columbia Ministries involved with protecting specifically our bald eagles or other departments protecting people from health issues caused by dispersion of rotting waste to neighbors or adjacent parks seems not just disgraceful but ads to their legal culpability and liability. 

Two major challenges and dangers to people and wildlife have been artificially created. 

1)  Air Strikes Risk:    I started my commercial life as a pilot before becoming a wildlife biologist.  Attracting huge numbers of gulls and bald eagles to a site directly at the west end of the Airport’s only two active runways (runways:  07/25 and 12/30) seems both careless but more importantly totally irresponsible.  To encourage a flock of gulls and eagles 100 or 1000 feet above the end of the active runway seems insane.  How will the Delta Mayor, the Council and the other bodies that could have prevented this unnecessary danger not be charged with legal liability, privately and collectively, when someone is killed due to a collision with these birds?

For about 5 years I have watched this “Lawn Factory” produce fine green fields – which were a minor attraction of gulls and even a few eagles would occasionally use the open space to sit and rest.  Then, in addition to bringing in the pre-processed soil to spread on the land to replace the soil layer removed with the lawn crop, the operation started to occasionally accept truck loads of organic waste.  A few years back the local photographers started to show images of eagles picking up and carrying large rib bones from abattoir remains.  Increasingly over the next few years the increased waste products attracted more bald eagles and gulls as the site increased the importation of unprocessed organic waste materials.    

For the last year and a bit, during each fall, winter and spring day hundredsof eagles can be seen feeding upon the increased organic wastes, flying in wondrous attacks across the sky as several eagles harass each other or gulls for scavenged scraps and dropping such waste over the entire region, particularly into the adjacent “Dog Park” immediately across the road.  I have seen the flocks of over 100 eagles and probably in excess of 3000 gulls circling directly over the end of the Boundary Bay Airport runways.   This is unacceptably dangerous to people in aircraft, let alone totally and logically an unacceptable way to kill eagles or gulls – even under permit.  Several gulls have collided with local aircraft.  I am told by airport officials that to date no one has been killed in such a collision -- as has happened at many other such sites.  Are the Mayor, council and other Safety governing and permitting bodies only going to act when several people are killed?  You will probably not have to wait long.  I have heard from airport people that no big commercial flights come to Boundary Bay Airport – regularly.  So apparently we are most likely to only kill off a few pilots in training or the instructors.  Is that really acceptable?

When the Vancouver Regional Landfill facilities just a couple of kilometers to the north seriously had the contributing Cities separate out ‘compostable refuse’ – protein and vegetable matter – this certainly reduced the food available to eagles at the Vancouver Landfill.  However it simply moved and is continuing to move more eagles to the Turf Farm location.  The solution is quite simple.  Remove the organic waste material from the vision of gulls, pigeons, blackbirds and eagles. Either they should totally operate the waste facility under cover or move the operation to a place where it is not a health and safety hazard to people or a totally unnecessary attraction and hazard to wildlife.

2.  Highway 17 Auto-Human Risks:     Immediately west of the Envirosmart Organics dump site is the new high speed Highway 17, the South Fraser Perimeter Road.   Several bald eagles and gulls have recently been killed as they flew off the Envirosmart Organics Refuse piles directly (10 mm away!) onto the adjacent Highway.   Surely it is only a short time before some driver swerves to miss an eagle and hits a semi-trailer.  The solution here is so simple.

 Again, while I am asked to frequently “speak for eagles” I do so but always with the understanding that eagles are simply a conspicuous part of our ecosystem.  I wish to see us preserve our lands and the creatures it supports.  The primary species in our environment is of course we -- the people. This report is surely about eagles and wildlife but it more importantly is about us!  It is totally unacceptable to pass off the risks that this dump site and its artificial baiting of wildlife, as not just one of the highest and most easily prevented risks to wildlife but is a totally preventable risk to human life as well.

I pose this question:  How does a farm simply growing wonderful lawns, not unlike most farm crops, change to becoming an industrial processing plant that poses huge contamination problems and fully  preventable risks to wildlife and our community people?   Someone’s judgment is terribly wrong.  Do we have to continue to kill eagles and gulls etc. and endanger people until enough people are killed to get commonsense regulations?  If you are going to allow a “change in the land use” then either totally enclose the processing site to exclude gulls, eagles, rats and even smell or don’t allow the Land Use Status to change.   The only other option is to simply leave the site for growing lawns -- not to allow waste processing.

Thank you.

David Hancock

Hancock Wildlife Foundation
19313 Zero Avenue
Surrey, BC
V3Z 9R9
Phone:   604 538-1114 Cell:  604 761-1025

PS  On this Envirosmart Organics dump site, right beside the active Airport Runway is an active bald eagle nest that last week fledged two young.  This nest should also be removed.









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