CTA Review – my comments to Canada’s Minister of Transport

Dear Minister Garneau,

I am writing to you, to express my disappointment in the recent submission of recommendations under the Marine Section of the Canada Transportation Act Review (CTA), submitted to you, in December 2015, by the review panel’s chair, Hon. David Emerson.

A little about me; I am a Transport Canada Marine Safety certified Marine Engineer; I completed a Marine Engineering apprenticeship at BCIT in Vancouver, and I have been sailing on commercial ships all over the world since 1996, the last 8 years as a Chief Engineer. I am married, and we reside in Nanaimo, where my wife and I raise our three young boys, one with disabilities.

I am known amongst my seafaring peers as the creator of www.dieselduck.net, a website focusing on Marine Engineering and seafaring affairs that affect professionals in our field. With about 27,000 visits every month, it is fair to say that I’ve some success at having my finger on the pulse of our industry.

Through discussions on the website, I recently became aware of the Canada Transportation Act Review (the Review) as submitted to you in Dec 2015, in particular the Marine Section of the report, as this pertain to my livelihood. I instantly devoured it, and immediately recognized the recommendations put forth to you, as long standing demands from selected shipping business interest. Not to say that these are bad things, but I must stress that they certainly are to the benefit of a small group of stakeholders.

Mr. Emerson would have you believe that an extensive consultation of stakeholders was undertaken, but I submit to you that there is no evidence in the report, that anyone other than the shipping business interest, who’s own singular financial interest are of paramount concern, were consulted. I would propose to you that a healthy economy would benefit from varied input with national objectives and benchmarks, set according to a wider metric than just company’s A, B or C profit margin.

I believe that supplier, shipyards, service and equipment providers, educational institutions, government agencies, and of course, labour – workers, like myself, should have a say in planning the future of our industry, and its wide ranging social and economic impacts.

For instance, under the Short Sea Shipping section, page 220, and again on page 230, of Chapter 10 – Marine Transport, the report asserts that young people are not interested in a shipping career, and that “alternative recruitment” be explored.

Mr. Emerson does not expand on what “alternative recruitment” means, but judging from my 20 years of experience, this means engaging third world nationals onboard Canadian flag vessels, to undercut the competition and gain market share. My peers and I get it; cutting crew cost is one way to make more money.

On your dinner plate tonight, you may have seafood from your regular Canadian owned grocery store which may be a product of Thailand. The Thai seafood industry has been recently exposed by numerous media organization, such as the Guardian, for using “alternative crewing” in their drive to increase their “market share”.

The crew of some Thai fishing boats comes in the form of kidnappings, murder and essentially, slaves (mostly from another third world nation – Burma), to be used for their fishing activities, generating huge profits for its fleet owners. This is happening right now. I suspect this is not the “alternative recruitment” Mr. Emerson is speaking of, but without further explanation, one has to wonder, where are the limits?

There are numerous other impacts to Canada’s social and economic well-being that Mr. Emerson recommendation of “alternative recruitment”, seem to gloss over. The impacts that the numerous public and private training institutions would be devastating the demand for Canadian Marine training would plunge – along with the “brain capital” that supports it. Additionally, most of these “alternative recruitment” candidates will pay little, or no tax to Canada, or anyone for that matter; the same Canadian coffers that Mr. Emerson recommend funds numerous initiative to improve shipping in Canada.

Mr. Emerson states the myth that young people are not interested in a shipping career. Yet again, the report offers no data to support this long held belief by some in the industry, which I say is complete rubbish.

I love my work, I always have, and I know many of my peers who do as well. I have had the pleasure of working with many young engineering professionals, who have a great deal of enthusiasm, and skills, that surpass any of their peers that I have experienced with, working on foreign crewed / flagged ships.

Had Mr. Emerson bothered to counter this claim by a few, and truly cared about this “major red flag” in the Marine industry in Canada, he would have actively sought the thoughts of young people on the subject, but again, there is absolutely no evidence of this in the review. We are led to believe that this report is to be a vision for the next 20-30 years, for you to adopt, yet the people to live with these recommendations, have not been consulted.

Had Mr. Emerson and his team done the simple task of talking to young people, objectively, at our nation’s (mostly) public funded marine training facilities, perhaps he would have realized that the same high amount of schooling and costs dedicated to being a seafarer in Canada, would yield equivalent results, if not more financial reward, in a shore based position. On that level alone, the marine industry fails miserably to attract young people.

Regardless, I meet a continuous stream of young passionate professionals who persevere through this major drawback, only to be demoralized by working on dangerous, old ships, with little comforts, often found on Canadian flagged ships. Even now, some Canadian operators are still refusing to offer internet access to their crew, due to cost. In this day and age, it is nearly inconceivable to find a worksite on land that has no internet access.

Then there is the very relevant issue of Transport Canada Marine Safety’s interpretation of International Maritime Organization (IMO) Marine Engineering Officer Certification requirements, which has nearly halted paths of career progression for Marine Engineers in Canada. Our Canadian system is very unique in the world, deeply prohibitive and irrelevant. A topic of discussion on its own; if you are interested.

Many of my peers are actively working outside of Canada, because the conditions in the Canadian shipping industry are considered subpar and archaic, for the various reasons stated above. Many of those peers working internationally also have equal time 1/1 system contracts – usually meaning one month on the ship, one month off the ship. While Canadian operators expect 6 months on, 2 or three months off – a 2/1 system.

Canadian seafarers have a long history of unrecognized dutiful service to crown, and ship owners, they have made great stride in increasing shipping productivity in Canada. There has never been so much cargo moved by ship, with such low crewing requirements. Unfortunately, this means for all seafarers, long hard working hours, with little social interaction. These long, isolated hours of arduous work, going unrecognized, are, I would propose to you, the main culprit in industry failing to attract young people.

Work aboard a Canadian ship is not attractive to a young person, not (just) because of money, but because it prevents a person’s ability to find a mate, grow a family – a basic human need. The industry, and its steady but aging labour force, has not had to think about how to accommodate this fact, for a generation. The lack of constant intake and progression through the ranks, onboard and ashore, over the last thirty years, has now created a massive culture shock within business, which “alternative crewing” from third world labour force will not change.

A little further on, in the Short Sea Section of the CTA Review, Mr. Emerson states another long held, convenient, assertion that Canadian crews are more expensive than their global competitors. Again, there is no supporting data given, and I find this, again, to be complete rubbish.

The main reason (apart from the exploitation of people such as the Burmese) we, Canadian workers like myself, may be considered less competitive, is that Canadian seafarers have to pay income tax on their income, no matter where in the word it is made. Comparatively, most of our seafaring peers – and not just from third world nations – pay no income taxes on their seafaring earnings. To not include the tax load on Canadians seafarers – again, taxes that are paying for the infrastructure shippers in Canada rely on, is another reckless and unsupported assertion of Mr. Emerson’s review that Canadians seafarers are not global competitors.

As I write this, I am working as Chief Engineer on a Canadian built (duty paid), Canadian flagged ship, crewed entirely by Canadians, and for the third year in a row, this ship is working in the Caribbean, on the global stage.

We are currently working a sub-contract for a Brazilian construction company, building a power plant in the Dominican Republic. We are competing with multinational entities with global reach, and a Canadian ship, its Canadian crew, win contracts time and time again. I am positive that our company is not performing charitable acts by doing so, and therefore I find Mr. Emerson’s “industry boilerplate” assertion completely groundless, highly questionable, at best.

I further would like to use the above statement to highlight one additional point of great importance, which I hope you will heed to as the leader of Transport Canada. I think that bureaucracies tend to forget that not all the world operates in their reflection. I would propose to you that a large portion of Transport Canada’s client base is similar to me. Persons who are absent from home, for extended periods of time at unpredictable worksites; they have very limited, if any communication means, and have delayed intake of information, due to these circumstances. I suspect this to be true, from train engineers, to aircraft crews, truck drivers, etc, and I am sure, even astronauts, as much as it is for us seafarers.

I urge you to consider these worker’s schedules, when Transport Canada makes statements, regulations, or seeks input. It is physically difficult for us to be able to respond in a timely fashion. I encourage your leadership in letting Transport Canada to come out of its hardened shell, make genuine efforts to seek out stakeholders in a meaningful way.

I don’t have the resources from my family’s meager budget to attend the CMAC conferences, I wish I did, nor do I have ability to hire lobbyist to promote my seafarer’s needs to you. I ask that you consider implementing a communication strategy for Transport Canada that truly affords stake holders a true voice, on the future of our share industry.

I love what I do, and I am excited to think we could have a marine sector in Canada that truly respects all stakeholders and that is the envy of world. I have a feeling that you will appreciate my passion for the marine industry in Canada, and if you are interested, I have many more thoughts on solutions to the problems of our industry, that Mr. Emerson speaks of in his review.

In conclusion, the narrow scope of input sought in the production of this review, evident to me by the issues brought up in the Marine Transport section, leads me to be highly suspicious of the biased recommendations given to you. I believe the marine transport system in Canada is currently unsustainable due to the narrow mindset that has prevailed. Sadly, I see this continued mindset go even further as illustrated by such recommendations put forth by Mr. Emerson’s Canada Transportation Act Review.

Thank you for your time.

Yours truly,

Martin Leduc

Cc: Sheila Malcomson, MP, Nanaimo Ladysmith, [email protected]

Some additional material you may be interested to provide context to this letter, and the shortage of seafarers in Canada.

• Reap what you sow – https://www.dieselduck.info/library/01 articles/reapwhatyousow.html
  In this article written in October 2012, I explore how many engineers have been able to progress through the ranks of Marine Engineering over 20 years, on the West Coast of Canada, and its impact.
• Upgrading A view from the bilge – https://www.dieselduck.info/library/01%20articles/upgrading-view-from-the-bilge.html
  In this article written in January 2013, I explore what some of the challenges are to upgrading a certificate of competency under the Marine Engineering Certification system in Canada. To support A view from the bilge, I tabulated the costs associated with a Marine Engineering career in Canada, and they are summarized using the two current stream of entry.
  • Costs of becoming an Engine Room Rating (2013)
    https://www.dieselduck.info/training/doc/2012.01.10-ME%20Career%20Costs%20-%20Rating.pdf
  • Costs to becoming TC 1st Class COC using the Cadet Stream (2013)
    https://www.dieselduck.info/training/doc/2012.01.10-ME%20Career%20Costs%20-%20Cadet%20Stream.pdf
  • Costs to becoming TC 1st Class COC using the Alternate Path (2013)
    https://www.dieselduck.info/training/doc/2012.01.10-ME%20Career%20Costs%20-%20Alternate%20Stream.pdf
• A fork in the career road – https://www.dieselduck.info/library/01%20articles/career_development/career_options.html
  With the difficulties of advancing my Marine Engineering career, I explore what the options are for us as a family. Written in Aug 2013.
• One option is the Blue Riband project, a theoretical business model for the year 2020 of a professional Marine Engineering organization and how it may address some of the current issues. www.blueriband.ca gives a brief intro, but can send full presentation if interested
• Australian Adventure – https://www.dieselduck.info/library/01%20articles/career_development/australian-adventure.html
  In this Aug 2013 article, I tell the story of our “drastic” attempts to immigrate to Australia, for professional reasons.
• The Seafarers and the Taxman – https://www.dieselduck.info/taxes/index.htm
  Explores the income tax applied to foreign going Canadians and how this puts them at a major competitive disadvantage