Environment committee  I am very pleased to be appearing before you. I would like to thank the committee for taking the time to listen to us. I would also like to thank Mr. Radford for organizing this meeting. My name is Kaity Arsoniadis Stein and I am the president and secretary general of the Intern

Environment committee  I will ask Peter Lahay, from the ITWF, to give the full history, because he was involved during the Bill C-15 days and is currently involved in Bill C-16.

Environment committee  In terms of consultation from Transport, when I read about this bill in the paper, I immediately e-mailed the people from Transport who we work with and the director general at Environment Canada and his group. They were in London at the time for the IMO meetings. They e-mailed m

Environment committee  The DG, and in addition to the DG, the people who work at IMO for Transport Canada.

Environment committee  Yes, just briefly. Mr. Giaschi has not been retained on behalf of the International Ship-Owners Alliance or our community to speak on these issues. Our issues—

Environment committee  On behalf of CMLA, the Canadian Maritime Law Association.

Environment committee  Okay. I'd like to focus on the point of the presumption of innocence and the reverse onus.

Environment committee  We don't have an issue with that at all. We don't even mention that in our submission.

Environment committee  I should apologize. I thought he wanted some sort of response to the strict liability/absolute liability charter point.

Environment committee  Are you referencing the three letters that were sent, in the brief?

Environment committee  Just this morning? Yes, I didn't reference any sections.

Environment committee  Yes, I'm aware, and I think the way we'd like to put this forward is that with Bill C-16 raising the penalties now to $6 million, with aggravated to $12 million on a strict liability basis, we're not arguing about this increase in penalties.

Environment committee  And I'll get to that. Our concern is that, given that we're increasing enforcement in that capacity and that we're allowing for very heavy fines, which—

Environment committee  No, under the Bill C-16 enforcement provisions.

Environment committee  I think I'm confusing the question.