Transport Canada, Environmental Policy
Place de Ville, Tower C – 26th Floor
330 Sparks Street
Ottawa, ON
K1A 0N5
VIA EMAIL
Eric Huberdeau, Manager and Policy Adviser
Nicole Legault, Director, Sustainable Transportation System Policy
Dear Mr. Huberdeau and Ms. Legualt:
Re: Strategy to address abandoned, derelict and wrecked vessels
Let me take this opportunity to commend Transport Canada for taking the important step to consult with the boating community and move towards a strategy to address abandoned, derelict and wrecked vessels. We thank you for this opportunity to offer our thoughts on the strategy at this time.
Georgia Strait Alliance (GSA) is a charitable organization that works to protect and restore the marine environment and promote the sustainability of the Strait of Georgia, one of Canada’s most at-risk environments, and its adjoining waters and communities. Founded in 1990, GSA has over 1200 members and supporters who work collectively to address root causes of threats to the Strait and find solutions that protect it.
Georgia Strait Alliance is the recipient of two Canadian Safe Boating Awards for our green boating program and for ‘Safeguarding the Environment’. Our Clean Marine BC program has also received the prestigious Yachtsman Spring Thaw Luncheon National Environment Award and the President’s Award from the Environmental Managers’ Association of BC. We are a long-standing member of the Pacific Regional Canadian Marine Advisory Council (CMAC), and we have been a strong advocate for solutions to pollution from recreational boating, including providing insightful input to the initial Vessel Pollution and Dangerous Chemicals Regulations.
Our interest in these consultations relates to protecting the Georgia Strait’s marine and shoreline environments, and the species, communities and economies that depend on them, from the impacts of abandoned and derelict vessels. We are therefore pleased to see that Transport Canada has included risk to the environment among the concerns to be addressed by this strategy.
I took part in the conference call on August 31, 2016 and found it to be a productive discussion of the causes and challenge these vessels pose, with many thoughtful solutions discussed, and I would like to offer the following for consideration:
- Transport Canada has identified approximately 600 abandoned, derelict and wrecked vessels in Canada, but we suspect the numbers to be much higher. Many of these vessels contain toxins and pose an imminent threat to the marine environment and to public safety. This legacy of abandoned, derelict and wrecked vessels needs to be addressed in an expedited manner in order to prevent catastrophic impacts to habitat, species at risk, and to our economy that depends on a healthy marine environment. Of note is that many of these vessels are found in the critical habitat of the endangered southern resident killer whale. Pollutants are one of the 3 primary threats to their survival as laid out in the recovery strategy developed under the Species at Risk Act. It is critical that protecting at risk species and the marine environment be placed as a top priority in strategically targeting vessels to be removed. Toxic leaks are also costly, and removing these threats proactively can save money in the long run, as has been demonstrated in Washington State.
- Prohibition of abandonment of vessels with an associated fine would serve as a strong deterrent, and should go hand in hand with removing barriers to recycling vessels at the end of their life, such as cost and limited recycling facilities. Enforcement is critical in the success of any regulation, with the Coast Guard and RCMP being best positioned to handle enforcement with the appropriate resources. Harbour Authorities are also a valuable resource and should be given authority to remove derelict, abandoned and wrecked vessels.
- In order to hold boat owners responsible for their vessel at end of life, it is critical to have a simple and reliable identification system. New vessels should be manufactured with a vessel identification number. Annual registration would aid in keeping contact information and ownership records up to date, while penalties for failure to transfer ownership would help ensure that paperwork is filed as required. These penalties and a new licensing fee would add funds, all of which would go to tackling this issue.
- To eliminate the jurisdictional nightmare that currently exists when addressing how to remove a problem vessel, designation of a single agency as Receiver of Wrecks regardless of jurisdiction would allow for timely action to address any threats the vessel may pose. A comprehensive coast wide solution will eliminate the risk of these vessels being bounced from one jurisdiction to the next.
- While regulation and enforcement are critical in getting a handle on this issue, preventative measures mustbe taken. Again, we look to Washington State as an excellent example. Through their programs they have shown that identification of potential problem vessels and working with boat owners before a problem occurs can divert vessels from the path of abandonment and reduce costs of dealing with problem vessels at end of life.
- The live-aboard lifestyle is a way of life that is dear to many on our coast, and it is important to avoid penalizing responsible live-aboard boaters.
Finally we would like to thank Transport Canada for the pending removal of the Viki Lyne II from Ladysmith Harbour. The story of this ship highlights the problems of abandoned vessels but also can be seen as an example of how when jurisdictions works together, we can remove these threats from our waters and communities.
Thank you for taking the time to consider our input, and for working to find a long-overdue solution to problematic abandoned, derelict and wrecked vessels. We look forward to further discussions on this strategy.
Sincerely,
Michelle Young, CPA, CA
Clean Marine BC Program Coordinator
Georgia Strait Alliance