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 ITEM | PAGE 4 8