Letter re Towing Needs Assessment

Extracted text (beginning)

200 - 1627 Fort St., 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 
 
June 14, 2019 
 
File Number: 5020-30  
 
via e-mail:  DFO.CCG.OPP.Towing-GCC.PPO.Remorquage.MPO@dfo-mpo.gc.ca 
 
Ocean Protection Plan 
Canadian Coast Guard 
 
 
To whom it may concern: 
 
Re: West Coast Towing Needs Assessment 
 
Thank you for the opportunity to comment on the West Coast Emergency Towing Needs Assessment. Oil spill 
prevention and response became a strategic advocacy priority for the Islands Trust Council in 2009 after the bulk 
carrier, the Hebei Lion, grounded in Plumper Sound, located between Saturna, Mayne, North Pender and South 
Pender Islands. Our initial concern was compounded by two more near-groundings in Plumper Sound in 2010 and 
2011. Since that time, the Islands Trust Council has dedicated significant resources to advocating for strong ship 
safety measures and oil spill prevention measures.  
 
In May 2018, the Islands Trust Council wrote jointly with San Juan County Council to request that a standby rescue 
tug be located in Sidney, British Columbia and available to Turn Point, off Stuart Island. Our two governments made 
this joint request because we share a belief that there is insufficient emergency towing capacity in the Salish Sea to 
meet the current or future risks associated with vessel traffic.  
 
In the narrow waterways and anchorages of the Salish Sea, there is a very limited window of time to respond before 
a vessel experiencing a loss of propulsion or steering might potentially run aground on the many unmarked reefs, 
islets or shoreline, or worse, collide with another vessel. Quick, effective help for a disabled or drifting vessel is key 
to preventing oil spills in this ecologically-significant region characterized by fast moving currents and significant 
tidal changes. 
 
The Canadian federal government’s Tanker Safety Expert Panel’s 2013 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. The report also stated that the southern coast of British Columbia, including Vancouver Island, 
was one of two areas in Canada with the highest potential impact from a marine spill. The Assessment report 
reached similar conclusions. The Salish Sea is a special region in need of special consideration and 
precautionary measures. 
 
We are pleased that the issue of emergency towing is being considered by the federal government through this 
report and have the following comments: 
 
 As the report stated that emergency towing is not a recognised term in international convention and law, 
there appears to be a need for a clear definition for "emergency towing" that can be used internationally as 
the term "salvage" is inadequate. 
 
.../2 
 
Bowen  Denman 

First 3,000 characters. Open the original for the whole document.