The Honourable Lisa Raitt
Minister of Transport
Tower C – 330 Sparks St.
Ottawa, Ontario K1A 0N5
Via e-mail: firstname.lastname@example.org
Dear Minister Raitt:
Re: Proposed Changes to Vessel Pollution and Dangerous Chemicals Regulations
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 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’. Clean Marine BC has also received the prestigious Yachtsman Spring Thaw Luncheon National Environment 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.
Our interest in the proposed regulatory changes 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.
After the considerable amount of effort put in to creating the new shipping regulations, which we and other communities in the region have found to already be woefully inadequate to protect our marine environment, we are dismayed that Transport Canada is considering now weakening them. This is of considerable concern given the recent devastating losses of southern resident orcas, their population being at such a critical low of only 78 members, and the threat that pollutants pose to this endangered species and the118 others in the Salish Sea.
The current regulations already permit dumping where there is a distance of less than 6 nautical miles from shore to shore, and no sewage pump-out facility is nearby (a distance is not currently specified in the regulations). 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 and the proposed changes would only make this worse.
We are also concerned that the federal government has made no move to address the issue of inadequate sewage reception infrastructure. The lack of any sort of infrastructure development and funding plan has set the existing regulations up for failure, a serious shortfall we detailed in our submission in September 2006 when the existing regulations were proposed. Transport Canada must allow boaters to be in a position to abide by regulations by supporting infrastructure development and not weaken regulations to make pollution easier.
It has also been brought to our attention that existing pump-out infrastructure in some cases is poorly used. This is not surprising as there is decreased incentive to use the facilities that exist when already weak regulations are not backed up by rigorous enforcement –making discharge of sewage into the marine environment a low risk activity. Businesses cannot be expected to bear a costly burden to solve a public problem, and with little incentive to do so with lack of enforcement and weakening regulations that do not require existing pump outs to be utilized. We would like to note that in addition to supporting better infrastructure, we support the proposal to allow for the use of composting toilets on vessels.
Transport Canada has indicated that the establishment of further Designated Sewage Areas may be considered for defined areas with an expressed need for protection, after the proponent undertakes stakeholder consultations and provides information on available pump out facilities. Not only is a consultation process extremely onerous and costly, but it is a government responsibility that should not be pushed onto concerned citizens and organizations who do not have the capacity to undertake meaningful engagement.
In light of these concerns, Georgia Strait Alliance requests that Transport Canada:
1. Maintain the 3 nautical mile from shore sewage discharge exclusion zone.
2. Restrict the dumping of vessel sewage within 3 nautical miles of sewage pump-outs.
3. Remove the burden of stakeholder consultation from proponents for new designated sewage areas and the need to provide information on available sewage reception areas.
4. Rename the confusing misnomer ‘Designated Sewage Area’ to a more appropriate title such as ‘No-discharge Zones’ that implies that sewage discharge is restricted.
5. Improve enforcement efforts and develop a plan for increasing compliance with the regulations.
6. Implement a sewage receptacle infrastructure development and funding plan as soon as possible.
We have attached two illustrations developed by the Islands Trust, the first being the potential effect of Transport Canada’s amendments to Section 96 of the Vessel Pollution and Dangerous Chemicals Regulations, and the second an illustration of the potential effect of our recommendations numbered one and two above.
The first illustration demonstrates that weakening of regulations as currently proposed provides virtually no protection from pleasure craft sewage dumping in the entire Islands Trust region, and other regions where the regulations apply. The second illustration demonstrates that our request is in fact simply a small level of protection until such time that the necessary infrastructure is in place.
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 abandon plans to weaken the Vessel Pollution and Dangerous Chemicals Regulations, to add a restriction on vessel sewage dumping within 3 miles of pump out facilities, put in place the necessary infrastructure, and enforcement compliance so that the regulations provide strong protection from the impact of pleasure craft sewage dumping.
Clean Marine BC Program Coordinator
Illustration of Potential Effect of Transport Canada’s Proposed Amendment to Section 96 of the Vessel Pollution and Dangerous Chemicals Regulations in the Islands Trust Area.
Illustration of Potential Effect of Islands Trust’s Proposed Amendments to Section 96 of the Vessel Pollution and Dangerous Chemicals Regulations in the Islands Trust Area.
cc. Honourable Leona Aglukkaq, Federal Minister of Environment
cc. Honourable Gail Shea, Fisheries and Oceans Canada
cc. Honourable Lawrence MacAulay, Fisheries and Oceans Critic
cc. Honourable John McKay, Environment Critic cc. Elizabeth May – Leader, Green Party of Canada
cc. David McGuinty, Transport Canada Critic cc. Hoang Mai, Transport Canada Critic
cc. Megan Leslie, Environment Critic cc. Robert Chisholm, Fisheries and Oceans Critic
cc. Jean Crowder, MP cc. Clare Frater, Trust Area Policy Analyst, Islands Trust
cc. Paul Topping, Manager, Environmental Protection, Marine Safety & Security, Transport Canada
cc. Paul Mudrock, Senior Environmental Advisor, Transport Canada
cc. Yvette Myers, Regional Director, Transport Canada
cc. Lisa Geddes, Executive Director, Boating BC Association
cc. Sheila Boutcher, President, Council of BC Yacht Clubs
cc. Jim McIsaac, Executive Director, T Buck Suzuki Environmental Foundation