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Initial feedback sessions
In early 2021, Transport Canada held a series of feedback sessions with groups that would be directly impacted by the Voluntary Guidance for Relevant Authorities on In-Water Vessel Cleaning.
This included a feedback session with the Association of Canada Port Authorities to get comments on a draft of the proposed voluntary guidance and to find out whether the guidance would help their decision-making process.
We also presented an overview of the voluntary guidance, including recommended criteria, to the Canadian Marine Advisory Council’s (CMAC) Standing Committee on the Environment in April 2021. At the meeting, we announced that we would be running online public engagement on the voluntary guidance.
Our engagement approach
In June 2021, Transport Canada published the voluntary guidance on the Let’s Talk Transportation webpage. The public had 60 days to submit feedback. The website also included a list of frequently asked questions. To guide the conversation, we asked participants three questions:
- How is the proposed Voluntary Guidance relevant to you, and how would you implement it?
- What are some of the industry’s best practices to manage biofouling?
- What other options can we look at to support the development of an environmentally safe in-water cleaning industry?
“Biofouling” happens when microorganisms, plants, algae, and animals build-up on structures that are exposed to an aquatic environment, like a vessel’s hull.
A vessel’s biofouling can transport foreign species to Canadian waters, or between ecosystems within Canada. These species can then become invasive and harmful in their new environments. This build-up can also increase vessel’s drag, which means it needs to use more power to move. This leads to more fuel consumption and higher operating costs.
To get comments and feedback from stakeholders, we:
- emailed the Canadian Marine Advisory Council's distribution list and 137 other stakeholders a link to the online consultation. Other stakeholders included municipal governments and their associations, academics, providers of in-water cleaning services, and international stakeholders,
- posted a bulletin at GreenTech 2021, a marine industry conference, and
- promoted the consultation via Transport Canada’s social media accounts.
We also contacted specific stakeholder groups to engage with them further. This included sending 63 follow up emails to stakeholders that we hadn’t heard from yet, like companies that offer in-water cleaning services and environmental non-governmental organizations.
We shared information with Indigenous communities through existing Oceans Protection Plan regional engagement activities. We also sent information to national Indigenous groups as part of a broader Transport Canada engagement update email.
In total, we received three submissions and two comments online. Eleven additional stakeholders emailed their submissions directly to us. We’re pleased with the amount of feedback we received from a diverse group of participants.
In all, we heard from:
- industry stakeholders
- the ocean technology sector, including companies that offer in-water cleaning services
- Canadian Port Authorities
- Indigenous communities
- international experts and stakeholders
Feedback we received
The feedback we received represents a broad range of viewpoints. In general, participants agreed that Transport Canada should support environmentally responsible in-water cleaning and that these services should be available in Canada.
However, there were differing opinions on how strict these standards should be and how Transport Canada could support the availability and development of cleaning technologies.
The themes that emerged from the comments are presented in the following sections. The themes are listed in no particular order.
Protecting Canada’s environment
Participants agreed that Canada should have voluntary guidance to protect our environment from invasive species. Several participants felt that the proposed voluntary guidance didn’t go far enough.
We received several comments on water quality. Some participants were worried that the proposed guidance isn’t strong enough to make sure that contaminants aren’t introduced into the environment from in-water cleaning. Participants suggested a few ideas to help reduce risks even more:
- raising the proposed capture percentage
- having a stricter definition of “locally accumulated biofouling” having vessels tell the relevant authority the last ten ports they visited
- requiring capture technology to be used at all times, or
- recommending in-water cleaning only be performed on vessels with non-biocidal hard coatings
Some participants suggested we either require service providers to explain how they dispose of cleaning waste in an environmentally safe way, or to add more detail on how waste should be disposed. They also suggested that cleanings should stop if the hull has more biofouling than expected, or if an invasive species is found on the hull.
Technology and services
Some participants stated that while they want the environment protected, it’s important that Canada’s standards aren’t higher than what’s possible with current cleaning technologies. Participants want cleaning services to be widely available since they’re an important part of managing biofouling.
Others felt that technology standards should be stricter to force the cleaning industry to innovate and protect the environment during cleanings.
There was minor confusion around some technical requirements, like if organisms separated from the effluent must go through secondary treatment. Participants also suggested that some requirements be broadened so they can be applied to a wider variety of technology. For example, replacing “filtration” with “separation” so that systems without a filter can meet the requirement.
Testing and approving technology
There were several comments on how we will make sure that cleaning technologies comply with the voluntary guidance. Participants suggested that Transport Canada develop more detailed testing, inspection, and approval procedures.
One participant suggested that Transport Canada identify locations where testing can occur. Some participants also recommended the federal government create a national program instead of relying on relevant authorities to make decisions.
We’ve documented the comments we received through this engagement and presented a summary of the comments at the Canadian Marine Advisory Council’s Standing Committee on the Environment in December 2021.
We will consider all comments as we continue to develop the voluntary guidance. We will continue to engage specific groups if follow up information is needed. The final version of the voluntary guidance will be published online in 2022.