This letter from the Concerned Citizens of Baynes Sound was sent to Port Alberni city council on Jan. 23, 2025.
Dear Members of the City Council,
Subject: Urgent Caution Regarding the Proposed Shipbreaking Facility in Port Alberni
I am writing to you on behalf of the Concerned Citizens of Baynes Sound (CCOBS) to express our serious concerns regarding the proposed shipbreaking facility in Port Alberni. Based on the lessons learned from unregulated shipbreaking activities in Baynes Sound, we strongly caution city council to thoroughly consider the long-term risks to the environment, public health and the community before granting approval for such a facility.
CCOBS has been actively involved in efforts to address the harmful impact of unregulated shipbreaking, and we have worked closely with organizations such as West Coast Environmental Law (WCEL)
https://www.wcel.org/ and the NGO Shipbreaking Platform https://shipbreakingplatform.org to advocate for the adoption of international shipbreaking regulations in British Columbia and Canada.
The research and work we have done for the last five years in Baynes Sound has revealed several key issues and shortcomings in the current regulatory landscape, and we urge the city council to take these into account when considering the proposal for Port Alberni. Although Canada has not adopted the EU or Hong Kong Convention for the safe recycling of ships, we urge you to use the principles of these conventions to ensure that operations are conducted in an environmentally safe manner. Self governance does not work.
Lack of Regulatory Framework and Oversight: In British Columbia and Canada, shipbreaking currently operates without specific, comprehensive regulations to govern the disposal of hazardous materials, worker safety, and environmental protections specific to shipbreaking. This regulatory gap has led to dangerous practices in Baynes Sound, where shipbreaking activities have been carried out without permits, oversight, or enforcement of regulations. Specifically, there have been ongoing issues with the discharge of acutely toxic heavy metals into the waters of Baynes Sound, yet the Canadian Ministry of Environment and Climate Change (ECCC) and the Department of Fisheries and Oceans (DFO) have not taken meaningful enforcement action.
1. Environmental and Health Risks: The disposal of ships at the end of their life involves the release of a range of hazardous materials, including asbestos, PCBs, and heavy metals.
https://www.osha.gov/sites/default/files/publications/shipbreaking-factsheet.pdf
Shipbreaking in water exacerbates these risks, allowing toxic substances to leach directly into the marine environment. The impact on local ecosystems is devastating, and the risks to human health are significant.
In Baynes Sound, the lack of regulatory enforcement has resulted in ongoing contamination and threats to public health, which are further compounded by the absence of any clear protocols for the safe disposal of hazardous waste.
City council must ask: How will hazardous materials be safely removed, stored, and disposed of in Port Alberni? What infrastructure exists on Vancouver Island to handle these materials, and is it sufficient to protect the environment?
2. Crown Lease and the Change of Use: In Baynes Sound, the BC Ministry of Forests (now the responsibility of the Ministry of Land, Water and Resource Stewardship) changed the Crown lease from its original purpose of storing logs to a lease that permits the storage of end-of-life ships. This change occurred without consultation with the local community, which had no opportunity to voice concerns about the environmental risks associated with shipbreaking. End of Life ships are considered hazardous waste, and the proposed shipbreaking facility in Port Alberni should not move forward without a similar level of scrutiny.
City council must ask:
Local – Do the current bylaws include shipbreaking within the zoning?
Provincial – What is the intended purpose of the Crown water lease in Port Alberni, and how will it be used?
Provincial – Will the lease allow the facility to store ships in the water, and if so, how many vessels will be stored at any given time?
Local, Provincial and Federal – Will the facility require a permit, if so, what will it be?
What regulatory oversight and measures will ensure that this facility does not cause harm to the local environment or community?
3. Lack of Community Consultation: One of the most significant failures in Baynes Sound was the absence of meaningful community consultation before the lease change occurred. Local residents were not informed, and their concerns were not considered. As a result, the community was left to deal with the environmental fallout from unregulated shipbreaking. Port Alberni must avoid making the same mistake. It is imperative that the City Council engages with local residents and stakeholders before making any decisions regarding the approval of a shipbreaking facility. The community must be given a chance to express its concerns, especially when it comes to such a potentially harmful
industry.
4. Lessons from Union Bay and Vancouver Port Authority, The Need for Government Communication: Shipbreaking is a multijurisdictional issue, involving local, provincial, and federal governments. In Union Bay, the lack of communication and coordination between these levels of government has contributed to the failure to enforce regulations and protect the environment. The result has been ongoing toxic discharges into the water, without any meaningful consequences for the responsible parties. In Vancouver, the Vancouver Port Authority filed action with the BC Supreme Court to halt breaking apart vessels in the water.
City council must consider:
What assurances can be made that Port Alberni will not face the same lack of enforcement and oversight as Union Bay?
Is Port Alberni going to permit the dismantling of ships in the water? If so, what is the difference between the situation in Vancouver and Port Alberni?
How will the City of Port Alberni ensure that the ECCC, DFO and other relevant agencies are held accountable for enforcing regulations and taking action in the event of violations?
5. Impact on Local Economy and Aesthetics: In addition to the environmental and health risks, shipbreaking facilities can have a devastating impact on the local economy and quality of life. The aesthetic impact of having large ships stored and dismantled in close proximity to the community can detract from the natural beauty of Port Alberni, negatively affecting tourism and property values.
Please review granting permission. We urge the city council to exercise caution and thoroughly assess the risks associated with the proposed shipbreaking facility in Port Alberni. The lack of regulations, the potential for hazardous discharges, and the lessons learned from the failures of oversight in Baynes Sound and Union Bay should not be ignored. CCOBS would be happy to meet with Port Al berni city council to provide further insights and guidance on this critical issue. Please refer to our website to learn from the mistakes made in Baynes Sound, and to learn more about the shipbreaking industry in Canada.
Thank you for your attention to these concerns. We trust that you will make the right decision to protect the health and well-being of Port Alberni’s residents and the environment.
Sincerely,
Marilynne Manning, CCOBS

https://concernedcitizensofbaynessoundorg.wordpress.com/

Note: CCOBS is a society developed in Baynes Sound dedicated to the protection of its delicate ecosystem. We are a group of retired and working professionals who have over 200 years of expertise in heavy industrial construction and regulatory compliance in the oil and gas, mining, power, petrochemical and pulp and paper industries in Canada and the U.S.