Vancouver Island

BC, Canada

Attention: National Energy Board

RE: Comment on Trans Mountain Pipeline Marine Shipping related Projects


We are presenting this comment to alert the NEB of a recent and dramatic increase in traffic of large bulk carriers in and out of Vancouver Fraser Port Authority within the 12 miles area of interest defined by the NEB.


Since the end of 2016, a scheme has been put in place to re-route bulk carriers (coal, potash, grain, etc.) at a destination of Vancouver Fraser Port to an outside of Port anchorage and discontinue the business practice to provide parking as needed for these freighters while they wait for loads.


There are currently 33 outside of Port anchorages located in the South Gulf Islands and East Coast of Vancouver Island that have seen an abnormal increase in use; these anchorages are located in Cowichan Bay, Plumber Sound, Captain Passage, Trincomali Channel, Kulleet Bay, Houston Passage, and Ladysmith/Stuart Channel.


The traffic of vessels sent to and from one of the 33 anchorages has increased as follow (as per Pacific Pilotage Authority (PPA) assignments of BC pilots):


  • 2015: 210
  • 2016: 223
  • 2017: 386
  • 2018: 554 (estimate based on the first six months with 277 assignments)


The overall increase in traffic is 160% in 3 years; the traffic of Bulk carriers sent to anchor outside of Ports has increased between 2015 and 2018 by about 340 vessel trips. This increase is abnormal and well above the increase in business (approx. 15%) and is the evidence of a scheme to re-route these freighters outside of Vancouver Port.


Another metrics that reflects the change in practice is the number of vessels that were removed from a Vancouver Port anchorage and were sent to anchor in one of these 33 outside of port anchorages:

  • 2015: 6
  • 2016:  24 (all of them after October 1, 2016)
  • 2017: 37
  • 2018: 38


This metric shows an increase of 530% and demonstrates that bulk carriers are 5 times more likely in 2018 than in 2015 to be removed from an anchorage in English Bay and Vancouver Port and then sent out to park in one of the 33 outside of Port anchorages.


These important changes in business practice were done with no prior environmental studies and with no consultation with First Nations and coastal communities impacted.


We respectfully request that the NEB investigates why all these Bulk carriers at a destination of Vancouver Fraser Port are no longer offered to stay at an anchorage within the confine of the Port and sent away to outside of Port anchorages.


The recent increase of traffic of these vessels coming and going to South Gulf Island and East Coast of Vancouver Island anchorages has created a lot of stress on these areas with industrial nuisance and negative environmental impact. A typical vessel trajectory sent to anchor in Ladysmith is shown on the infographics.


Figure 1: Trajectory of vessel sent to anchor in East Coast of Vancouver Island

Furthermore, an Interim Protocol for the Use of Southern B.C. Anchorages was initiated by Transport Canada on February 8, 2018. This Protocol has continued the scheme of increasing the number of bulk carriers sent outside of Port. In addition, under the Interim Protocol, several historical anchorages that were designated in the 70s and had seldom been used were re-activated to host large modern vessels. This change was implemented with no risk assessments and no environmental studies despite many of these historical anchorages are located in very close proximity to eco sensitive areas, estuaries, and coastal habitats and are impacting marine life.


This Interim Protocol is still in effect and has disastrous consequences for the environment in the Southern Gulf Island and East Coast of Vancouver Island and we believe it was put in place in direct correlation with the change of practice of Vancouver Fraser Port as described above.


Outside of Port anchorages are now used by many more large commercial vessels despite there is no physical surveillance, no spill response, no monitoring and measurement of sound and light disturbance. While at anchor, crews are engaging in maintenance operation, discharges, and scrapping toxic paint and are putting at risk the Environment.


Because so many vessels are sent to anchor outside of Port, the number of bulk carriers using an anchorage in Vancouver Port and English Bay is currently underestimated. The bulk carriers anchoring need is not sufficiently taken into account.


The current plan is not allocating a sufficient number of anchorages available for Bulk carriers within the Port’s boundaries and underestimates the risks associated with this shipping marine need.


We respectfully request that the Trans mountain plan is amended to take into account the anchorage needs for bulk carriers within the confine of Vancouver Fraser Port.