Air pollution scrubbing and dumping from vessels

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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 604.660.2421.  Elsewhere in BC 
1.800.663.7867 
Email  information@islandstrust.bc.ca 
Web  www.islandstrust.bc.ca 
 
 
March 30, 2022          File No.: 5020-30 Major Vessels 
 
Via Email:  omar.alghabra@parl.gc.ca 
TC.MinisterofTransport-MinistredesTransports.TC@tc.gc.ca 
 
 
The Honourable Omar Alghabra 
Minister of Transport 
330 Sparks Street 
Ottawa ON, K1A 0N5 
 
 
Dear Minister Alghabra: 
 
Re:  Air pollution scrubbing and dumping from vessels 
 
I am writing on behalf of Islands Trust Council to request Transport Canada take further action on air 
pollution and dumping from marine vessels, including stopping the use of exhaust gas cleaning systems 
(scrubbers) and mandating a stricter fuel standard in Canadian waters. This would prevent ships from using 
the current workaround of using scrubbers on marine exhaust systems, which result in large discharges of 
acidic waste and toxic pollutants into the water column instead of the atmosphere. You may wish to look at 
requirements implemented in California which include requiring or incentivizing the use of marine gas oil, 
instead of heavy fuel oil with scrubbers. 
 
According to a November 2020 report by the International Council on Clean Transportation entitled “Air 
Emissions and Water Pollution Discharges from Ships with Scrubbers”, 85% of scrubbers are open-loop 
systems. Meaning, they continuously dump toxic, acidic wastewater straight into the ocean. From the same 
report, it is noted that Vancouver is the fourth most scrubber-polluted port in the world. 
 
In a 2022 National Vessel Dumping Assessment Report by World Wildlife Fund Canada, ships generate 143 
billion litres of scrubber wash water annually in Canadian waters. Approximately 10 per cent of this, or 14.5 
billion litres, is produced and subsequently dumped in marine protected areas and other effective area-
based conservation measures (OECMs). 
 
We are concerned about the impact of wastewater discharge into the Salish Sea. The Salish Sea’s highly 
productive waters are one of the world’s most biologically diverse, including species that are economically 
and culturally significant to Coast Salish Indigenous Nations.  The Salish Sea ecosystem supports large 
numbers of marine birds, as well as iconic species such as Southern Resident Killer Whales and Pacific 
salmon. The ecosystem includes the Fraser River estuary, providing key habitat for many species of animals 
including salmon and migratory birds. 
 
 

 
 
 Preserving and protecting over 450 islands and surrounding waters in the Salish Sea 
Bowen  Denman  Hornby  Gabriola  Galiano Gambier  Lasqueti  Mayne  North Pen

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