Introduction

On 18 February 2016, the House of Commons Standing Committee on Fisheries and Oceans (the Committee) agreed to “undertake a study to review the imminent closure of the Comox MCTS [Marine Communications and Traffic Services] station of the Canadian Coast Guard; and that the Committee report its findings to the House.”[1]

The Committee began its study on 10 March 2016. It held two meetings and finished hearing from witnesses on 12 April 2016. Witnesses included officials from the Canadian Coast Guard (CCG), representatives of Unifor Local 2182, the Officer in Charge at the Comox MCTS centre, and Mr. Fred Moxey, retired Coast Guard superintendent.

The Committee would like to express its sincere thanks to the witnesses who appeared before it to share their perspectives. This report is based on their testimony.

Background

A. Role of Marine Communications and Traffic Services

Marine Communications and Traffic Services centres provide “distress and safety call monitoring and coordinate responses, broadcast maritime safety information (weather and navigational warnings), screen vessels entering Canadian waters, deliver information and advice to regulate marine traffic movement, and take appropriate action to ensure the safe and efficient movement of vessels in Canadian waters.”[2]

B. Committee interest in Marine Communications and Traffic Services

Marine Communications and Traffic Services have been the focus of this committee’s work in 2003 and 2004.[3] At that time, the Committee believed that short staffing and equipment rust-out were “compromising the efficient and effective functioning of MCTS.”[4] Therefore, in its 2003 report, the Committee recommended an increase of staffing levels, the modernization of equipment and proper backup capacity to reduce the risk of service blackouts.

C. Modernization of MCTS infrastructure

In 2007, the CCG began modernizing the MCTS infrastructure.[5] The project involves, in the Western Region, the consolidation of the five MCTS centres in Tofino, Comox, Vancouver, Victoria and Prince Rupert into two updated centres in Victoria and Prince Rupert.[6] To date, the consolidation of the Tofino and Vancouver centres has been completed and the integration of the Comox centre into the Victoria centre represents the final element of this modernization project.[7]

Closure of the Comox MCTS Centre

During the hearings, the Committee heard conflicting opinions regarding the impacts of the planned closure of the Comox MCTS centre on safety of mariners, safety of the environment, sustainability of the MCTS infrastructure and human resources, efficiency of operations, and backup capacity.

A. Safety of mariners

The Committee heard from the CCG that the consolidation project is based on the principle that there would be no change to existing radio towers and radar installations.[8] The CCG also stressed that there will be no change in response to distress situations.[9]

Unifor mentioned that there have been audio quality issues with the new communications system that could impact safety of mariners.[10] The CCG acknowledged these technical issues but indicated that there has also been progress in resolving them.[11] Unifor agreed that technical issues will eventually be fixed but added that one of its crucial concerns is the greater noise level in the Victoria centre’s operations room resulting from increased radio transmissions volume.[12] According to Unifor, the high noise level could impede the detection of certain distress calls.[13] The CCG, for its part, reassured the Committee that, post-consolidation, the ratio of responding officers and radio transmissions volume will remain unchanged.[14]

Unifor stated that knowledge of the local geography is another important factor for ensuring the safety of mariners.[15] Given that a number of officers will not relocate from Comox to Victoria, Unifor was concerned about the potential loss of local knowledge. The CCG indicated, however, that the consolidated Victoria centre will have officers trained to monitor specific areas “just as if the Comox station was still opened.”[16]

B. Safety of the environment

The Committee heard from Unifor that the Regional Marine Information Centre (RMIC) responsible for pollution alerting was moved to Comox when the Vancouver centre was closed.[17] The CCG informed the Committee that the consolidation project will have no impact on safety of the environment since RMIC will be transferred to the Regional Operations Centre.[18] It also mentioned that the response to environmental incidents “has not changed anywhere across the country because of our consolidation efforts.”[19]

C. Sustainability of the MCTS infrastructure and human resources

The Committee heard that long-standing short staffing, workload and overtime problems at MCTS could be exacerbated with the consolidation project.[20] The Officer in Charge of the Comox centre indicated that 50% of vessel movements in Canada occur in the Western Region, and that the consolidated Victoria centre will handle 83% of vessel movements and the highest concentration of incidents in the Western Region.[21]

Mr. Dale Gross added that the CCG has not been able to staff safety and traffic positions with the required 5.5 persons on average which resulted in “excessive” overtime.[22] Unifor pointed out that the 2003 Committee report made a recommendation to staff seven persons per position.[23] It also predicted a loss of 20% to 30% of officers due to retirements and departures within the next two to three years in Victoria and informed the Committee that the process to hire and train a new officer could take up to two years.[24]

The CCG indicated that it has added “surge capacity” at each centre to deal with peak periods and that the overtime issue will “normalize” within six to eight months after

completion of the modernization project.[25] According to the CCG’s 2009 workload study,[26] “staffing levels and workload at the new centres are appropriate for the area that they cover.”[27] In addition, it was pointed out that modernized equipment enabling text-to-speech marine weather broadcasts would decrease officers’ workload and allow them to focus on distress duties.[28] The Committee also heard from the CCG that a succession plan is in place to address expected retirements and departures.[29]

With respect to the sustainability of the MCTS infrastructure, the CCG emphasized that this modernization project will result in a system that would be “not only more reliable, but flexible and adaptable.”[30]

D. Efficiency of MCTS operations

The CCG measures efficiency in its delivery of services by the number of staff and funds allocated for a particular operation.[31] According to the Commissioner, the implementation of the new technology, by allowing the merging of 22 centres into 12 without change in services to mariners, “increased efficiency of the overall MCTS program.”[32]

In contrast, Unifor indicated that the cost associated with the relocation of staff and equipment to Victoria, which includes overtime costs due to staffing shortage in Victoria and new officers’ training expenses, “far outweighs” the cost of keeping the Comox centre opened.[33] The union added that it is not opposed to the modernization project but, if it had been consulted, it would instead suggest to consolidate the Vancouver centre with Victoria and to move Tofino’s operations to Comox due to low staff retention in Prince Rupert and in Vancouver, and the need to replace the building in Tofino.[34]

E. Backup capacity

Unifor stated that the Comox centre currently acts as emergency backup for British Columbia’s Emergency Preparedness, Response & Recovery as it broadcasts tsunami warnings for the provincial agency.[35] Mr. Fred Moxey added that it is necessary to have the Comox centre as backup for the Victoria and Prince Rupert centres.[36] He characterized the Comox centre as a “lifeboat” that is more likely to survive a disaster since it has been “seismically upgraded”. Unifor also indicated that, if either the Victoria or Prince Rupert centre goes down or blackouts, the workload and vessel traffic complexity would be “too great” to handle for the sole remaining MCTS centre in the Western Region.[37]

Concerning tsunami risks, the CCG informed the Committee that the Victoria centre is not located in a tsunami planning zone and that the Prince Rupert centre is “sheltered due to the number and location of islands at the entrance to the port.”[38] In Prince Rupert, the tsunami risk was judged as “acceptable” by the CCG since it predicts that the “traffic will not be there in the event of a tsunami.”[39]

Conclusion

The Committee notes the often diametrically opposed views between witnesses. Mr. Fred Moxey summed the perspectives of opponents to the closure of the Comox centre by stating that “it all depends on how much risk the government [is] willing to take.”[40] For its part, the CCG noted the success of previous MCTS consolidations across Canada and deemed its decision as a “reasonable” one as it “does not compromise safety.”[41]

Recommendations

Recommendation 1

The House of Commons Standing Committee on Fisheries and Oceans recommends that the Canadian Coast Guard monitor the performance of the MCTS system in British Columbia for a period of 24 months. This will allow for the resolution of issues related to technology, mariner safety, workload and training.

Recommendation 2

The House of Commons Standing Committee on Fisheries and Oceans recommends that the Canadian Coast Guard and Unifor continue to work together in monitoring and resolving technical issues (e.g. audio quality problems) and take appropriate actions to ensure the safe and efficient movement of vessels.

Recommendation 3

The House of Commons Standing Committee on Fisheries and Oceans recommends the Canadian Coast Guard to proceed with the planned closure of the Comox MCTS centre with caution. The Committee has been sufficiently reassured that the capacity of the Canadian Coast Guard to respond to emergency situations has not diminished.

Recommendation 4

The House of Commons Standing Committee on Fisheries and Oceans recommends that, given the significant differences in opinion expressed by the Canadian Coast Guard and the other witnesses, all stakeholders collaborate on post-consolidation assessments that will include:

• working conditions at the consolidated Victoria MCTS centre in Sidney;
• records of staffing levels on all shifts, records of overtime and records of staff attrition/turn-over;
• the efficacy of the MCTS officers recruiting process; and
• the nature, scope and causes of communications system outages, noting unique and recurring issues,

and that a risk assessment of the consolidation project in the Western Region be completed on an annual basis.

Recommendation 5

The House of Commons Standing Committee on Fisheries and Oceans recommends that reports compiled by the post-consolidation assessments (included in Recommendation 4) be submitted to the Minister of Fisheries, Oceans and the Canadian Coast Guard and the House of Commons Standing Committee on Fisheries and Oceans on a quarterly basis for the next 24 months.

Recommendation 6

The House of Commons Standing Committee on Fisheries and Oceans recommends that Fisheries and Oceans Canada establish a mechanism for continuous feedback from stakeholders on the overall performance of the MCTS system across Canada and be part of the department’s annual performance report.