1. THAT I am a Director of the Vancouver Island Peace (VIP) Society, concerned citizen, and Victoria property owner, 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 attached as Exhibit "A" to this my affidavit is a copy of the Order In Council No. P.C. 1991-2083, dated October 30, 1991, concerning nuclear weapons capable warships. Attached as Exhibit "B" to this my affidavit is a copy of Order In Council No. P.C. 1991-2084, dated October 30, 1991, concerning nuclear-powered warships. Attached as Exhibit "C" to this my affidavit, is a copy of Order In Council No. P.C. 1991-2082, dated October 30, 1991, concerning Canada's prior consent for U.S. nuclear submarines to transit Canadian waters in the Dixon Entrance.

3. THAT I note by a plain reading of the Orders In Council concerning the porting of nuclear-capable and nuclear-powered warships, that both of these Orders In Council, if valid, unreviewed, and unchallenged, would apply to my community and give prior authorization to continued porting of nuclear- capable and nuclear-powered ships to this urban centre. Over one quarter of a million people live within twenty miles of the Esquimalt nuclear base.

   What is the rationale behind Esquimalt, Nanoose, and Halifax being declared the only ports authorized for the porting of nuclear-powered warships? What makes our communities presumed safe, and others not? By just what criteria have we been selected for this? These are unanswered questions not only in my mind, but in the minds of many of my fellow citizens when confronted with the issue.

4. THAT enclosed as Exhibit "D" to this my affidavit, is a "secret" memo titled "Port Visits By Nuclear-Powered Vessels", by David Barnes of the staff of the Federal Environmental Assessment Review Office, and approved by R.G. Connely, Director General of Operations, both senior officials in the federal Ministry of the Environment. This "secret" memo to Cabinet was an answer by Mr. Barnes to a question earlier directed to him of whether the porting of nuclear-powered warships should be submitted to the procedures of the Environmental Assessment Review Process (EARP) Guidelines Order, or whether the Federal Cabinet should attempt to bypass the otherwise applicable requirements of the EARP Guidelines Order, by passing an Order In Council granting prior approval to nuclear warship visits, and to the transit of nuclear submarines through the Dixon Entrance.

5. THAT a fair reading of the David Barnes "secret" memo arouses the concern that the government is apparently knowingly skirting the requirements of their own environmental legislation, and going directly against the recommendations of their own senior environmental officials to whom they had entrusted the question in the first place for their considered opinion. Why is the safety of our community, from such an obvious potential threat, exempted from fair and public scrutiny and review?

6. THAT the David Barnes memo states that the Ministry of National Defence has taken the position that a public review of the porting of nuclear ships would be "unacceptable" for reasons of national security. The citizens of Greater Victoria, myself include, consider our security to be part and parcel of "national security". We cannot fathom why a fair-minded and public review of this potential for immeasurable harm, should be considered by any rational mind to be a risk to national security, especially after the end of the Cold War and the collapse of the Soviet Union.

7. THAT attached as Exhibit "E" to this my affidavit, is a Communique, dated October 30, 1991, from the Federal Caucus of the New Democratic Party. I have read this Communique and it reiterates my, and my community's concerns. It asks why the government coverup, and the avoidance of a fair and public review? I and other citizens ask that too.

8. THAT the New Democrat's Communique comments on the irony of a decision which seems to run counter to a prevailing world mood in which the "great" nuclear powers are on the brink of massive reductions in their overkill capacity to "wage nuclear war" against one another. Why does not Canada demonstrate the courage to show some leadership in this area and at the same time enhance the safety of our citizens and environment?

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