Dear Minister Garneau,
Transport Canada, with the support of the commercial marine transportation sector, the Pacific Pilotage Authority, and the Vancouver Fraser and Nanaimo Port Authorities, has been instrumental in the successful implementation of the six-month Interim Anchorage Protocol established to reduce the impact of anchorage operations on local coastal communities on the South Coast of British Columbia. The Protocol has resulted in a more equitable distribution of vessels using existing anchorage locations and has diminished to a degree of noise and light pollution from vessels anchored in the region.
While it was not anticipated, the launch of the Interim Anchorage Protocol coincided with extreme supply chain congestion as railways encountered significant constraints in their ability to deliver Canadian commodities to the west coast. The trade corridor challenges resulted in a high demand for all available anchorages for an extended duration. During this period of congestion, we believe that the Interim Anchorage Protocol achieved positive results and provided a mechanism with which to collect valuable feedback from industry and community stakeholders.
The Interim Anchorage Protocol has demonstrated its value and we believe that its continued use would provide a framework for further development of best practices and support policy development under the national framework. This additional time could also facilitate the inclusion of data and analysis that may be realized from the Ports Modernization Review. In view of this and the reality that the initial six-month period included a term of extraordinary demand for anchorages, we strongly recommend that its use be extended for an additional twelve months. We have made additional recommendations for consideration in the enclosure to this letter.
Commercial shipping results in $30 billion of economic activity annually in Canada and, at 1.8% of the Canadian economy, ships move more than $200 billion worth of goods to and from global markets. The continued growth in Canadian bulk exports is encouraging and likely to increase with Canada’s efforts to expand and diversify its trading relationships globally. The anchoring of vessels with scheduled cargos is an important component of the supply chain and the member companies of the Chamber of Shipping remain committed to improving efficiencies and reducing impacts on coastal communities and the environment. We look forward to a continued positive working relationship with your team and the other stakeholders.
Recommendations Relating to the Interim Anchorage Protocol
Overall, the Interim Anchorage Protocol has delivered improvements to the management of anchorages on the South Coast of British Columbia. Specifically, the following observations are provided:
- The level of voluntary compliance by vessels to the allocation of anchorages by the Vancouver Fraser Port Authority (VFPA) through the Interim Anchorage Protocol was 100 per cent;
- There are several factors that make some anchorages in the Southern Gulf Islands (SGI) problematic. The combination of daylight-only transit restrictions for certain anchorages, long transit times, and pilot order constraints result in challenges meeting berthing windows and significant additional costs, which decreases the overall competitiveness of the Gateway;
- There were instances when vessels were required to shift anchorages from a VFPA anchorage to the SGI. This results in increased costs to carriers and potentially additional impacts to community stakeholders;
- The distribution of vessels has generally been more equitable throughout the SGI with certain anomalies due to constraints in the size of vessels compared to the capacity of a specific anchorage. For example, there are relatively fewer anchorages available that can safely anchor larger Capesize vessels and this has meant that certain areas received a higher volume of these vessels;
- The behaviour of vessels at anchor related to the management of upper-deck lighting and noise improved throughout the period of the Interim Anchorage Protocol. Notwithstanding, this was frequently as a result of observation and reporting by local community stakeholders. While not quantified through data analysis, it appears that ship owners that use local anchorages frequently have a higher level of compliance as compared to “tramp” operators that conduct single voyages to a local port;
- The communications between the VFPA, Transport Canada (TC), relevant associations, the vessels’ agents, and vessels was significantly improved and frequently resulted in the rectification of concerns raised by community stakeholders when it was feasible;
- There were several instances when community observations and analysis were helpful to improving certain aspects of the Protocol;
- The delay to access information, data sets, and educational information on anchorage operations eroded the trust of some community stakeholders. There were some instances when complaints made by a small number of community stakeholders were exaggerated, which is understandable in view of a lack of experience and knowledge about ship operations. In several instances, complaints were filed with the VFPA when a ship was not at anchor or in advance of the vessel anchoring.
In view of the experience gained during the six-month period of the Interim Anchorage Protocol, the Chamber of Shipping recommends the following actions:
Recommendation One. The period of the Interim Anchorage Protocol be extended for twelve additional months. This would provide further opportunity to improve the collection of data, conduct analysis and research, and possibly benefit from other programming such as the Ports Modernization Review.
Recommendation Two. As community stakeholders have identified concerns with noise, light, and air pollution, Transport Canada should consider monitoring at least one area of the SGI as a pilot project to determine if additional monitoring would be supportive of improved operations and inform the national framework.
Recommendation Three. Transport Canada should facilitate a study that forecasts the demand for anchorages for the next twenty years and accounts for the trend of ship owners to use larger vessels. The demand for suitable and safe anchorages will undoubtedly continue with more trade diversification and further growth in Canadian exports.
Recommendation Four. Transport Canada should consider options for monitoring of anchorages outside of the jurisdiction of port authorities. Monitoring is important in establishing and ensuring minimum standards of care and providing confidence for community stakeholders. Monitoring could also validate and standardize observations made by community stakeholders. This could include remote static technologies, autonomous vehicles, existing on-the-water assets of the Federal Government, or possibly a private sector service. The first six months has demonstrated that improvements to practices by ships at anchor is possible, but it usually happens more quickly with monitoring and feedback to the ship.
Recommendation Five. Transport Canada should approach the Department of Defense with the intent of including the anchorages at Royal Roads (vic. Victoria) as part of the Interim Anchorage Protocol, as many of these anchorages can receive Capesize vessels.
Recommendation Six. The VFPA should determine the feasibility of increasing the number and/or size of anchorages in English Bay to accommodate projected future volumes and vessel sizes.
Recommendation Seven. There should be consideration for the future use of static mooring buoys and Transport Canada should facilitate an initial feasibility study. There are ports globally that use systems to manage vessels awaiting berths, including mooring buoys, dolphins, and deep-water holding berths. As the long-term forecast includes growth in exports and a trend for larger vessels, the management of vessels to and from berths in harbours will grow increasingly complex. A project of this nature and scope may align with the intent of the National Trade Corridors Fund.
Recommendation Eight. The communications with First Nations and community stakeholders should be reviewed with the intent of reducing the time required to access information and data sets and facilitate positive dialogue between stakeholders. Consideration should be given to include all stakeholder correspondence on a TC portal.