Why Canada needs to codify Bill C-48, the Oil Tanker Moratorium Act

Testimony to the House of Common’s Standing Committee on Transport, Infrastructure and Communities.

An oil tanker is hit by a wave in heavy seas.

I traveled to Ottawa last week to give testimony to the House of Commons’ Standing Committee on Transport, Infrastructure and Communities, in support of Bill C-48. Bill C-48 is an Act to regulate tankers that transport crude or persistent oil to or from terminals on British Columbia’s north and central coast. Here is my submission.


British Columbia’s north and central coast along with Haida Gwaii comprise a unique environment that is increasingly uncommon not just in Canada, but in the world. An archipelago where lush forests and granite buttresses greet the sea, where grizzlies dig for clams in sight of the open Pacific, where wolves swim to distant islands in pursuit of seals, where the ethereal calls of resident killer whales are used to pursue salmon as they migrate thousands of kilometers to reach the freshwater rivers of a forest, and where the summer sun sets on the blows of feeding humpback whales that are surrounded by thousands of shearwaters, auklets, and gulls – all in pursuit of tiny fish that spawn on sandy shores or on giant kelps that buffer the fragile shoreline.

All this to say, this assembly of iconic animals makes the BC coast qualitatively different from most other exceptional places in the world. Distinctively, these animals are tied to the sea within a foodweb that knows no boundary between terrestrial and marine. Raincoast Conservation Foundation’s two decades of published science studying coastal species confirms the knowledge that First Nations have held for millennia; the coastal environment is an indivisible blend of land and ocean. What befalls the ocean, befalls the species of the land. It is no place for oil tankers.

Three recent academic publications by Raincoast and our colleagues are directly pertinent to the bill before you. First, is a paper derived from our 10,000 nautical miles of line transect surveys through the waters that Bill C-48 addresses, a region we refer to as the Queen Charlotte Basin.

The paper, Quantifying marine mammal hotspots in British Columbia, is a response to the overwhelming evidence that humans are contributing to rapid declines in marine species, particularly in coastal areas. This reality dictates the urgent need to identify important places for marine species, places where ocean processes and high species abundance interact to create “hot spots”. We found that southeastern Haida Gwaii, outer Queen Charlotte Sound near the Scott Islands, Caamano Sound, Calvert Island, Aristazabal Island, Chatham Sound and Dixon Entrance, were all places of exceptionally high marine mammal importance. These areas all lie within the waters identified in Bill C-48.

A second paper, on Oil Spills and marine mammals evaluates the consequences of potential oil exposure on 21 species of BC marine mammals. All marine mammals are inherently vulnerable to oil spills because they live their lives at the air–water interface, often the location where oil contact, inhalation or ingestion would first occur after a spill. We found that British Columbia’s killer whales, Steller sea lions and sea otters ranked very high in terms of vulnerability to oil spills. Their elevated risk above other marine mammals is due to their small populations, slow reproductive rates, specialized diets, and the tendency for large percentages of the population to be grouped together in space or time.

The third paper, Marine birds and chronic oil pollution on Canada’s Pacific coast along with the book, At sea with marine birds of the Raincoast, by Raincoast’s Dr. Caroline Fox, identify marine bird species considered to be at elevated risk of extinction and those with a pronounced vulnerability to oil spills. Marine birds in this region are vulnerable to oil exposure in any volume, from spills large or small. Bill C-48 reduces the threat of catastrophic oil spills to at-risk marine birds and their habitats.

Lastly, Bill C-48 does not just address the unacceptable risk of oil spills. It also addresses the rising problem of underwater shipping noise disrupting the communication and feeding of cetaceans, as well as the growing threat of ship strikes. Like the east coast, Pacific shipping is a growing concern for large baleen whales like fin, sei, humpback and the handful of critically endangered North Pacific Right whales that inhabit these waters.

Over the last decade, Raincoast has tried to express what this maritime commons of animals, islands, water and forests means to the people of British Columbia. Simply, it is a coastal archipelago that is priceless and irreplaceable; immeasurable in monetary terms.

We have also articulated the unequivocal evidence of decadal-scale biological changes that marine systems and species are undergoing, the ecological debt, and the perils of hidden consequences. But we also held hope – hope that the proposed industrialization of British Columbia’s Queen Charlotte Basin by oil tankers was a step too far. This bill before the house is evidence that it was.

As we move to codify a moratorium on oil tanker traffic into law, whales that were hunted to near collapse a century ago are finally returning to their historic feeding grounds. Bill C-48 honours the ecological legacy of this coast and the First Nations people that existed with this landscape since time before memory. We will continue our work to ensure the priceless and irreplaceable BC coast continues its evolutionary journey, but we will mark Bill C-48 as an important and necessary step in determining that future.

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