Ms. Katherine Bamford
Director, Trade Development
Vancouver Fraser Port Authority
100 The Pointe, 999 Canada Place
Vancouver, BC V6C 3T4
Dear Ms. Bamford,
Re: VFPA Priority Gateway Infrastructure Projects
Thank you for the opportunity to comment on the 13 priority gateway infrastructure projects outlined in the letter and information package distributed on March 8th. The Vancouver Fraser Port Authority continues to play a key role in identifying critical infrastructure projects that aim to improve the movement of goods to and from the port and securing much needed federal and provincial funding to implement these projects.
While we are pleased that the Port is reaching out to its customers and is responding positively to previous recommendations, it remains difficult to differentiate the benefit of specific projects when the overall context and existing supply chain constraints are not fully apparent in the documentation. Furthermore, there appears to be a lack of focus on specific aspects of marine transportation, including capacity for cruise and breakbulk.
The Chamber of Shipping represents ocean carriers that provide the marine transportation component in the trade corridor and from a port infrastructure perspective, our principal members are most interested in projects that will facilitate the safe and efficient movement of vessels calling at the Port of Vancouver. Ocean carriers select ports of call on the basis of a port’s productivity and cost competitiveness, therefore terminal and in-land fluidity are key elements to an attractive gateway. Canadian importers and exporters are dependent on reliable trade corridors to ensure that freight and demurrage costs are minimized.
The projects identified in the Priority Gateway Infrastructure Projects Information Package are relevant but are not of “direct benefit” to our members. Any cost recovery towards pre-funding of the infrastructure projects to be approved requires a comprehensive review and discussion with those that receive the “direct benefit” to the improvements, i.e. the beneficial cargo owner. As per the User Fee Act a “direct benefit means a benefit to the client paying the user fee with that benefit being either unique to that client or distinct from and greater than benefits that could also accrue to any other person or business as a result of that user fee being paid.”
Any associated costs to pre-funding land infrastructure, should not be borne by the international ocean carriers as it will put the Port of Vancouver at a competitive disadvantage to other ports. As noted in our concerns following the implementation of the Gateway Infrastructure Fee (GIF) and more recently on the Container Examination Facility consultation, VFPA should have a mechanism to recover fees directly from shippers of containerized goods.
In the current Fee Document the GIF for non-containerized cargo is “payable by the owner of the cargo” as intended, whereas the GIF for containerized cargo is applied to the carrier, rather than the owner of the cargo. This creates an inequitable distribution of fees where only the foreign owned container carriers are held liable for the Canadian shippers’ share of the infrastructure developments.
From an infrastructure perspective, the Chamber of Shipping would like to encourage a discussion on the application of infrastructure funds to improve the safe and efficient movement of vessels within the Port, and more immediate needs include:
- Development of a pro-active vessel and anchorage management system;
- Investments in berth and other infrastructure to accommodate the increasing size of vessels, particularly container and cruise;
- Provision of adequate port reception facilities as mandated by the International Maritime Organization;
- Funding for the new Container Examination Facility as designed by Canada Border Services Agency; and
- Trialing of a hard-point mooring system to support future additional anchorage/mooring.
Thank you again for the opportunity to comment on our industry’s infrastructure requirements and we look forward to discussing our project proposals with you in the near future.