1. THAT I am Member of Parliament for Victoria, British Columbia, and Parliamentary Critic on Defence & Disarmament for the New Democratic Party of Canada, and as such have knowledge of the following facts and matters deposed to.

2. THAT I have often called for a moratorium on the visits to the harbours of Victoria and Esquimalt of foreign naval vessels that are powered by nuclear energy or which refuse to advise that they are not carrying nuclear weapons, until a full independent public inquiry is held on the environmental implications of such visits.

   I have also called for a moratorium on such visits until a public review is held on the policy implications for Canada in accepting the visits of military vessels that refuse to reveal whether or not they are carrying nuclear weapons, and that are capable of carrying such weapons.

   I have long held these views and expressed them in the 1984 and 1988 federal election campaigns. This policy has been endorsed by the Victoria Federal NDP Association and has been adopted by the Federal Council of the NDP.

3. THAT it is my belief that no community in or near Greater Victoria would agree to a land-based nuclear power plant in its midst without a full and public environmental review.

4. THAT the Federal Environmental Assessment Review process (EARP Guidelines Order SOR/84-467) was developed to ensure the fullest possible public examination of the environmental consequences of a federal proposal, such as nuclear-capable and nuclear-powered foreign ship visits and transits in Canadian waters.

5. THAT on February 11, 1991, I wrote to the federal Ministers of Defence, Transport, and Environment, requesting them to expedite a decision on holding a public environmental assessment of nuclear ship visits to British Columbia under the EARP Guidelines Order (SOR 84-467). My letters are attached as Exhibit "A". The Ministers did not order the requested review, and their responses are now attached to this my affidavit as Exhibit "B".

6. THAT I have been advised and verily believe that the Ministers of Defence, Transport, and Environment, have received requests from virtually all Greater Victoria municipalities, Members of the Legislature, all local Members of Parliament, and many local peace and environmental non-governmental organizations, for a full public environmental review of visits of nuclear-capable and nuclear-powered ships to Greater Victoria pursuant to the EARP Guidelines Order.

   No Minister has answered the request for a review directly.

   The Minister of Transport has denied responsibility for approval of such visits, although he is responsible for Transport Canada's docking facilities at Ogden Point, the occasional berthing location of nuclear-powered or nuclear-capable ships.

7. THAT the responsible officials within the Minister of Environment's Department have recommended internally that a public review be held. Attached as Exhibit "C" to this my affidavit is a memo to the Federal Cabinet by David Barnes of the Federal Environmental Assessment Review Office, made public on October 30, 1991, by Member of Parliament Jim Fulton. The Federal Government has never disputed the authenticity of the memo or denied that it accurately reflects the views of officials of the Department.

   The memo has never been disputed by the Canadian Government. It was written by David Barnes of the Federal Environmental Assessment Review Office (FEARO), mandated by the EARP Guidelines Order to administer federal environmental assessments. The memo is approved by R.G. Connely, Director General Operations, FEARO.

8. THAT on October 30, 1991, the Federal Government passed three Orders-In-Council (P.C. 1991-2082, 1991-2083, and 1991-2084), to permit, inter alia, the visits to Canadian ports of U.S. or British naval vessels powered by nuclear energy or carrying nuclear weapons.

9. THAT spokespeople of the Department of National Defence have said the visits are safe, but have offered little or no evidence has been provided to support that conclusion. Nor has the Department offered any evidence to support the suggestion that there are Canadian national security reasons for avoiding a public review of the environmental risks of the visits.

10. THAT as far as I am aware, no independent Canadian studies have been done on the safety of nuclear-capable and nuclear-powered ships into which the Canadian public has had input.

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