The letter said: “The global shipping industry fully recognises the importance of robust environmental protection measures, and is committed to the goal of zero pollution, consistent with the comprehensive global regulatory framework adopted by IMO in accordance with the United Nations Law of the Sea (UNCLOS), to which Canada of course is a State Party.
“The environmental record of the shipping industry, especially the tanker sector, is impressive. On average, worldwide, there are fewer than two significant oil spills (over 700 tonnes) per year, compared to around 25 such incidents 30 years ago, despite a doubling of the amount of oil transported by sea.
“Our primary concern in writing to you is to emphasise the great importance of Canada adhering to its obligations under UNCLOS, in particular the rights to freedom of navigation and ‘innocent passage’ through a Party’s territorial waters as enshrined in Articles 87 and 90.
“We believe that a moratorium applicable to Canadian waters would be draconian step that could lead to serious concerns being raised by Canada’s international trading partners. Such a measure would set an unwelcome precedent that might be emulated elsewhere, including by individual US states, with the potential to impact greatly on the efficiency of world trade as well as that of Canada.
“We would therefore be very grateful if you could take full account of the comments submitted by the Canadian shipping industry, in particular the Chamber of Shipping of British Columbia, including the suggestion that the Government of Canada might consider alternative approaches to managing risks associated with coastal shipping.
“As suggested by the Canadian industry, such alternatives could include the establishment of marine transportation corridors to assist in the prevention of any risk of maritime incidents,” the ICS said.