Thank you.
I'll start by giving a preface here. The purpose of the MTSA is to address risks and threats to the marine transportation system and the health of persons in it.
In addition to the concerns identified, establishing a blanket prohibition against anchorages in this area without any exceptions could lead to situations of increased environmental safety and navigational risks. Vessels regularly use anchorages as part of their day-to-day activities. While the average time for a ship at anchor is less than 14 days in this area, there are many circumstances in which it may be necessary for ships to anchor for a longer period of time.
As the act is currently drafted, if a storm or other weather event posed a risk to the operational or navigational safety of vessels anchored in the areas, the minister would be unable to exempt a vessel from this prohibition. This could cause catastrophic impacts on the local marine ecosystem. Likewise, a ship might be required to stay at anchor to effect repairs or address deficiencies identified by Transport Canada in order to ensure the safety and security of the ship and its crew.
Adoption of this amendment as is would interfere with the Government of Canada's ability to manage emergency situations and conduct follow-up investigations activity.
In the case of the Zim Kingston, for example, that was a container ship that caught fire off the coast of B.C. in 2021. It needed to be held at anchor while the fire was put out and then for repairs and the resulting investigation.