hae ets ‘ 1. Envixonmental cost of a spill It is clear that terms employed by risk analysts have specialized meanings quite different from those in general parlance. If the conclusions of this report are going to be presented to the public in a way that will address public concerns, these discrepancies need to he acknowledged. Consider the concept of "environmental cost"; ; The report calculates anvironmental cost of a Spill ina particularly strict way. For example, in 7.4.1.3, the cost of a Spill to bird-life is valued as "the actual expenditures on bird ‘processing and rehabilitation." To the public this is an unacceptably narrow measure, the equivalent of judging the human cost of a disaster by counting only. the money spent ona field hospital. The real cost, about which the public is worried, goes far’ beyond such a circumscribed figure. . oo — Similarly, in 7.4.3, the cost of the loss of wetlands is. reduced to the "rehabilitation (replanting) component." Other values are dismissed as "intangible". Yet it is precisely these values that the public wants recognized in development decisions. If the purpose of these cost figures is to add to. a common understanding of what is involved in a spill, than THE REPORT SHOULD INCLUDE AN OPEN AND "UP FRONT" DISCUSSION OF WHICH ENVIRONMENTAL COSTS. (IN THE GENERALLY ACCEPTED SENSE) ARE INCLUDED AND WHICH ARE NOT. 2. Adequacy of Environmental Data. Researchers have told us again and. again that the information available on coastal environments is inadequate. It is clear that the authors of the Port study were themselves: frustrated by this. For instance, in 7.1 they write, “Major data gaps still remain for'many areas precluding a full. - biocharacterization of the Inlet." In 7.4, om marine flora and invertebrate: communities, they refer to the "patchiness of the . information available." In 7.4.3 they write that “dacumentation of extent and distributions of saltwater marsh and eel-grass beds... is very limited." | WE BELIEVE A RECOMMENDATION I8 IN ORDER CALLING FOR. THE NECESSARY STUDIES TU FILL IN THE GAPS IN THE ENVIRONMENTAL DATA. ‘The inadequacy of the available jnformation also indicates to us. that the environmental cost of a spill in. Burrard Inlet could.be much greater than the costs calculated by. the study. 3. Risk west of First Narrows. The narrow geographic .focus. of the risk analysis‘-- nothing west of First Narrows is considered. -~ is inadequate and misleading. In fact it is down-right pre-Columbian: the Lions Gate Bridge does net mark the edge of the world. known to be at. risk from an accident involving a tz# ~out=-haund from —_