Thank you very much, Madam Chair.
Good morning, honourable members.
On behalf of the Association of Canadian Port Authorities, we'd like to thank you for the invitation to speak to you today about the proposed amendments to the Pilotage Act.
Our association has been involved in the Pilotage Act review since its beginning, and we are pleased to have another opportunity to express the views of our members on another stage in this important process.
Our 18-member Canadian Port Authorities work very closely with pilots to ensure the safe and efficient movement of vessels in and out of Canada's ports. With the four pilotage authorities on the east and west coasts, the Great Lakes and the St. Lawrence, our members move over 330 million tonnes of cargo per year, both in containerized, bulk and break bulk form.
Without a doubt, pilots are a critical element in a safe, efficient marine transportation system, and they provide an important service to our members and the marine industry. By working with carriers and ports, pilots share the objective of protecting the marine environment and ensuring fluidity in marine commerce.
With this as a foundation, and given the long-standing challenges within the pilotage system, we are pleased with the Pilotage Act amendments and see them as a step in the right direction. The amendments provide a framework for modernizing pilotage that will reconcile protection of the marine environment, the use of technology, accountability, cost-effectiveness and reliable marine commerce.
To begin, like many of our marine colleagues, we are particularly pleased with the inclusion of a set of principles that will guide decision-making, and hopefully implementation. The principles are a positive example of this collective effort by industry stakeholders and government, and will provide a framework for modernization of pilotage that is safe, efficient, cost-effective, self-sustaining and incorporates tested and proven technologies.
ACPA and its members are also very encouraged by the move to develop a nationally standardized pilot certification program, which would extend and build upon the proven regime now established in the Great Lakes. This would allow crews that have the same knowledge and experience as government-mandated pilots to navigate their ships. Many of these mariners already become pilots and are extremely knowledgeable of local waters due to their frequent transits of such waters. Such a regime could greatly reduce the cost of marine shipping without compromising safety, and could eventually stimulate marine shipping within the Seaway.
Given our positive perspective on the amendments, the remainder of our comments today are aimed at highlighting a few caveats as the implementation of the legislation hopefully moves forward.
One of the biggest changes being brought to the pilotage regime is the centralization of regulatory responsibilities at Transport Canada. While we are supportive of the movement of regulatory authorities to Transport Canada, our members seek reassurance that decisions will be made with a full regard for local knowledge and operating conditions, and that the optional responsiveness that is now the status quo, and that is fundamental to safe and efficient operations, will remain, if not even improve.
To this end, it'll be imperative that Transport Canada receives sufficient funding to support the additional staffing required, that the staffing be done in such a way as to ensure strong links to local port authorities, and that adequate training time be allocated before Transport Canada fully assumes its new responsibilities.
Our members would like to see a mechanism developed that will allow for port authorities' input into the granting of waivers for compulsory pilotage in port waters. In the past, situations have arisen whereby waivers have been issued for vessels that don't have complete knowledge of local regulations, such as those set out in a port information guide.
Given existing strong local relationships, port authorities are able to liaise with the local pilotage authority to manage such vessels to ensure safety of operations within port waters. With the amendments proposing that issuance of waivers be centralized and standardized at Transport Canada, members are concerned that they will not have a local connection to work with to manage any challenges that may arise.
Similarly, our members request the development of a mechanism for ports to participate in the rapid investigation of an incident in port waters. The current system vests primary responsibility for investigating incidents with the Transportation Safety Board, which has the sole regulatory right to collect all relevant details and data related to an incident. The TSB considers this information proprietary.
Given the thoroughness of the investigation process, it takes upwards of a year or more for the TSB to file its report. However, in the interim, the behaviours or conditions that led to the incident can persist while the investigation is under way.
The situation is currently mitigated by the involvement of local pilotage authorities in the investigations, and the pilotage authorities are able to work with the port authorities to more rapidly identify causes and effect interim solutions.