Transport Canada
Let’s Talk Transportation online submission
Re: Regulatory Charge (Fee) Proposal for Vessel Remediation Fund
We’d like to acknowledge the great progress that has been made in recent years by the Government of Canada in addressing the problem of wrecked, abandoned and hazardous vessels. As 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, we have long advocated for solutions to the growing number of problem vessels on B.C.’s coast. This includes a written submission to Transport Canada in 2016 during public consultations on a strategy to address abandoned, derelict and wrecked vessels, in which we voiced our support for penalties and fees to be directed to a dedicated fund for addressing problem vessels, and working with boaters on prevention. We appreciate another opportunity to provide further insight toward finding solutions.
Founded in 1990, Georgia Strait Alliance (GSA) has over 11,000 members and supporters who support the collective work to address root causes of threats to the Strait and find solutions that protect it. GSA 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 long been a strong advocate for solutions to addressing sources of pollution from recreational boating. Our experience means we are well positioned to provide expert comment on the proposed Vessel Remediation Fund, and we hope you will take our insights into consideration.
Firstly, we would like to reiterate our support for the establishment of a Vessel Remediation Fund created with revenues generated from fees to vessel owners (both recreational and commercial). We also support that revenues be generated for this fund from the penalties collected under the Wrecked, Abandoned or Hazardous Vessels Act (WAHVA) from increased enforcement.
With 60% of problem vessels identified in the National Inventory of Vessels of Concern being located along B.C.’s coast, this poses a significant threat to the health of the habitat that supports the more than 125 marine species at risk in and around the Strait of Georgia. In particular, one of the three major threats to endangered Southern Resident Killer Whales is toxic contaminants which can be released from problem vessels into the habitat critical to their survival. It is of utmost importance that environmental protection from the release of contaminants be a top criteria in assessing problem vessels for risk-based prioritization.
With the increasing volume of wrecked vessels and marine debris threatening the marine environment and shorelines, we also are in support of the proposed Vessel Remediation Fund being used for the proposed preventative measures, namely:
- raising public awareness of responsibilities of vessel ownership, and proper disposal at its end of life;
- improving methods of environmentally friendly recycling and disposal, and vessel remediation techniques;
- increasing local capacity for vessel risk assessments, recycling, dismantling and disposal, including in Indigenous communities;
- and, a voluntary turn in program for at risk vessels.
It is our hope that this focus on prevention will also consider the issue of lack of affordable housing in BC, an issue that intersects with problem vessels. While we work to find solutions to the threat that is problem vessels, those who have turned to living on a problem vessel as a last resort, or by choice, must be treated with compassion, and assistance should be provided as appropriate. Efforts should also be made to raise the issue of ‘liveaboards’ when solutions to the lack of affordable housing are being discussed.
Finally, we support the use of the proposed fund to assess and remove problem vessels from marinas, harbours and ports, where they often end up abandoned or wrecked. We also appreciate that in order to maintain adequate resources in the Vessel Remediation Fund, that the fund would not be used to address outlier commercial problem vessels of a complex and costly nature.
The Government of Canada is to be commended on the successful removal of so many problem vessels on the B.C. Coast, and beyond, through both the Abandoned Boats Program and the Small Craft Harbours Abandoned and Wrecked Vessels Removal Program, scheduled to end in March 2022. We support the long term funding that the Vessel Remediation Fund would provide for continuing the removal of the significant backlog of legacy problem vessels, and for new vessels of concern as they continue to arise, which they will. This work is critical to the health of the Salish Sea and B.C’s entire coast, and the many species and people that call this region home.
Sincerely,
Michelle Young
Clean Marine BC Coordinator
Georgia Strait Alliance