Islands Trust Council Chair Writes to Transport Canada re Second Discussion Paper \"Potential regulations to increase access to marine emergency services and to improve response to pollution incidents\"

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Preserving and protecting over 450 islands and surrounding waters in the Salish Sea 
Bowen Denman Hornby Gabriola Galiano Gambier Lasqueti Mayne North Pender Salt Spring Saturna South Pender 
Thetis 
 
 
 
 
200 – 1627 Fort Street, Victoria BC V8R 1H8 
Telephone (250) 405-5151 Fax (250) 405-5155 
Toll Free via Enquiry BC in Vancouver 660-2421  
Elsewhere in BC 1.800.663.7867 
Email information@islandstrust.bc.ca 
Web www.islandstrust.bc.ca 
 
 
April 15, 2026                                    File No.: 11-5020-30-Oil Spills 
Via email: OPP.EMEM.HNS-PPO.AGUM.SNPD@tc.gc.ca 
 
Oceans Protection Plan  
Transport Canada  
300 Sparks Street 
Ottawa ON K1A ON5 
 
To Whom it May Concern: 
 
Re: Discussion Paper “Potential regulations to increase access to marine emergency 
services and to improve response to pollution incidents” 
 
I am writing, on behalf of the Islands Trust Executive Committee, to express our support for the 
direction Transport Canada is taking towards increasing access to marine emergency services 
and to improve response to pollution incidents, as expressed in its second discussion paper. 
 
Islands Trust is a special-purpose government representing over 30,000 people living within the 
Islands Trust Area and 10,000 non-resident property owners. The Islands Trust Area, is located 
within Coast Salish territory, covers the islands and waters between the British Columbia mainland 
and southern Vancouver Island. It includes 13 major islands and more than 450 smaller islands 
with over 1,300 kilometres of shoreline. Islands Trust is responsible for preserving and protecting 
the Islands Trust Area and its unique amenities and environment through conservation-oriented 
land use planning and regulation, education, and cooperation with First Nations and others.  
 
We are supportive of bold actions towards requiring certain vessel types to have arrangements in 
place to access marine emergency services such as marine firefighting and disabled vessel 
assistance (e.g. salvage and emergency towing) and towards improving how vessels and handling 
facilities prepare for and respond to marine incidents that involve hazardous and noxious 
substances. 
 
We wish to note that within a context of growing vessel traffic volume and increasing vessel sizes in 
the Salish Sea, we are concerned there is likely insufficient emergency capacity with respect to 
towing tugs of opportunity in the region with the necessary bollard pull capability, the necessary 
equipment, and properly trained crews ready to respond at a moment’s notice in poor weather and 
heavy seas. There is a need for an equivalent in Canada to Washington State’s Neah Bay 
emergency response towing vessel, and one that is equipped to respond to the largest vessels that 
transit the region. 
 
The Tanker Safety Expert Panel’s report stated that the waters around the southern tip of 
Vancouver Island were one of four areas in Canada with the highest probability of a large marine 
spill. Th

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