1. THAT I have been employed full-time researching national security issues since the mid-1980s, and as such have knowledge of the following facts and matters deposed to, save and except where same are stated to be based upon information and belief, and where so stated I verily believe same to be true.

2. THAT in 1986 I co-authored a booklet titled "Unsafe Harbours" on nuclear-powered and nuclear-capable ships in Canadian ports for Operation Dismantle, my employer at that time. To our surprise the booklet sold several thousand copies throughout the country: from coast to coast. "Unsafe Harbours" sold well in Victoria. The issue of nuclear ship dangers was and is clearly of great concern to many Canadians and Victorians. It is because our booklet spoke to that concern that is sold so well.

3. THAT for many years I have been submitting Access to Information requests to the Department of National Defence to determine the number and type of nuclear-powered and nuclear-capable ships that were in Canadian ports the previous year. That this information is each year widely distributed and used by concerned citizens from coast to coast, and particularly on Vancouver Island and Canada's West Coast.

4. THAT there has been a great deal of concern expressed to myself, Operation Dismantle, and Project Ploughshares about the safety of nuclear-powered and nuclear-capable ships consistently since the early 1980s, and in particular, from Canada's West Coast and Vancouver Island.

5. THAT I am asked to write articles about nuclear-capable and nuclear-powered warships in Canadian waters and ports on a frequent basis for the nationally-distributed "Ploughshares Monitor". This is the main publication of my employer, Project Ploughshares, one of Canada's largest peace organizations, and itself a project of the Canadian Council of Churches. I attach several of my articles as Exhibit "A".

6. THAT I know of no strategic reason for the visits of nuclear-capable or nuclear-powered warships to Greater Victoria.

7. THAT I believe the main reason why these ships visit Greater Victoria is for "rest and relaxation" and to "show the flag".

8. THAT a public environmental review of nuclear-capable and nuclear-powered warships to Canadian waters is emminently reasonable and badly needed in this country because of the number of concerned citizens, and the lack of knowledge about the alleged safety of these ships.

9. THAT I am unaware of any public study undertaken by the Canadian government to examine the environmental and policy issues surrounding the visits of nuclear-powered and nuclear- capable warships.

10. THAT even a cursory examination of the literature surrounding accidents involving nuclear-capable and nuclear- powered warships demonstrates that environmental and safety concerns about such accidents is warranted and deserves careful, public scrutiny.

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