x"... Che seller (should) retain the right Co reject (a)
Canker on arrival if it is found to not meet the agreed standards
and/or (the seller should retain the right to) enforce the
rectification of any deficiencies..." |

While we acknowledge the responsibility and concern for
safety shown by many oil and shipping companies, we do not
believe that public safety can be left to the goodwill of
individual businesses. It is a public responsibility. This is
an assumpticn we share with the authors of all of the reports
written in the wake of the Exxon Valdez and Nestucca Spills ~-
with the exception of the Port of Vancouver's,

IF THE PORT IS INDEED ARGUING FOR VOLUNTARY CHANGES, WE
BELIEVE IT SHOULD SET THIS OUT CLEARLY AND STATE THE REASONS FOR
TAKING THIS DIRECTION, IF THIS IS No? THE CASE, AND OUR READING
HAS MISINTERPRETED THE AUTHORS! INTENTION, THEN CLARIFICATION Ig

NEEDED.

10. Incensistent recommendation pelicy

There appear to be inconsistencies in the report's choice of
areas it deems suitable for discussion or recommendation. For
instance, the double hull question is left undiscussed because it:
is outside the Port's legislative framework. Tanker on-board
response Capabllity is similarly dismissed as "ultra vires", Yat
the authors see fit to make a recommendation in favour o£
instituting random drug-testing, a matter equally ultra vires.

Such inconsistencies give the impression that attention is
paid to some matters (and not paid to others) on the basis of
whim-- or of bias.

THIS INCONSISTENCY SHOULD SE ELIMINATED OR EXPLAINED.

1l. Implementation

WE BELIEVE THE PORT'S REPORT SHOULD INCLUDE, OR BE
ACCOMPANIED BY, AN [MPLEMENTATION PLAN, A TIMETABLE AND A PLAN
FOR THE CREATION OF AN IMPLEMENTATION COMMITTEE WITH FULL PUBLIC
REPRESENTATION. THE COMMITTEE SHOULD REMAIN IN PLACE FOR ONGOING

OVERSIGHT.

Without this, it will be difficult to feel assured (and it
may even be difficult to know whether) the many worthy
recommendations of the report are being carried out.

12. Public process

The public consultation process employed by the Port for
this study has clearly failed. Few submissions were received and
public meetings were Sparsely attended. This is not because the
public is unconcerned about the risk of marine accidents. Quite

the opposite is true, as has been shown by the gublic outery over
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