The Honourable Wayne Easter, P.C., M.P.
Chair of the House of Commons Standing Committee on Finance
Via email: firstname.lastname@example.org
Dear Mr. Easter:
Re: Addressing pleasure craft pollution in the 2017 Budget
Our interest in the federal budget consultations is in regards to protecting the Georgia Strait’s marine and shoreline environments, and the species, communities and economies that depend on them, from the impacts of pleasure craft sewage dumping.
Vessel sewage is a harmful pollutant that contains chemicals and pharmaceuticals with particularly adverse effects on the environment and species at risk. Boaters often congregate in anchorages in sensitive areas where pollution can become concentrated, and seasonal surge loading can also occur.
Georgia Strait Alliance (GSA) is a non-profit citizens’ 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 7000 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 most recently the Environmental Managers Association of BC President’s Award. 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 in 2006, and registering our opposition to a proposal to weaken those regulations last year.
A loophole in the regulations permits dumping where there is a distance of less than 6 nautical miles from shore to shore, and no sewage pump-out facility is nearby. This allows vast areas of our shorelines to be used as dumping grounds for raw sewage from pleasure craft, which can include harmful chemicals and pharmaceuticals.
This is of considerable concern given that the proposed Action Plan for the Northern and Southern Resident Killer Whale (Orcinus orca) in Canada identifies environmental contamination as one of the key threats to the survival of this species, as well as the 118 other species at risk in the Salish Sea. Dumping of raw sewage from vessels can also contribute to shellfish closures.
We are concerned that the federal government has made no move to address the issue of inadequate sewage reception infrastructure. With 350,000 to 400,000 pleasure craft on the West Coast, the less than 50 vessel sewage pumpout stations along our coast are not adequate to serve the needs of boaters, to close the loophole in the regulations that allows for sewage dumping, or to protect the marine environment from vessel sewage. The lack of any sort of infrastructure development and funding plan has set the regulations up for failure, a serious shortfall we detailed in our submission in September 2006 when the existing regulations were first proposed.
Small businesses such as marinas cannot be expected to bear a costly burden to solve a public problem. In light of these concerns, Georgia Strait Alliance requests that the 2017 federal budget allocate funds to address the severe shortage of boater sewage reception infrastructure on the West Coast. Washington State Parks Clean Vessel Grant Program is a model of success; grants are awarded for 75% of the cost of pumpout infrastructure, as well as for ongoing operation and maintenance costs.
Boaters care deeply about the waters we cruise, and we want to protect our cruising waters not only for ourselves but for future generations to enjoy. We also recognize that a healthy marine environment is critical not only for the many species that inhabit the Strait of Georgia and all of Canada’s coastlines, but for healthy communities and a strong coastal economy as well.
We strongly urge you to provide funding to put in place the necessary infrastructure, and for ongoing maintenance and operations, so that the regulations provide strong protection from the impact of pleasure craft sewage dumping.
Michelle Young, CPA, CA
Clean Marine BC Program Coordinator
Georgia Strait Alliance
cc. Honourable Marc Garneau, Minister of Transport Canada
cc. Honourable Catherine McKenna, Minister of Environment and Climate Change Canada
cc. Honourable Dominic LeBlanc, Fisheries and Oceans Canada
cc. Mark Strahl, Fisheries and Oceans Critic
cc. Fin Donnelly, Fisheries and Oceans Critic
cc. Honourable Edward Fast, Environment and Climate Change Critic
cc. Nathan Cullen, Environment and Climate Change Critic
cc. Elizabeth May – Leader, Green Party of Canada
cc. Kelly Block, Transport Canada Critic
cc. Clare Frater, Trust Area Policy Analyst, Islands Trust
cc. Paul Topping, Manager, Environmental Protection, Marine Safety & Security, Transport Canada
cc. Russ Smith, Senior Environmental Advisor, Transport Canada
cc. Yvette Myers, Regional Director, Transport Canada
cc. Lisa Geddes, Executive Director, Boating BC Association
cc. Bill Wilson, President, Council of BC Yacht Clubs
cc. Jim McIsaac, Executive Director, T Buck Suzuki Environmental Foundation