1. THAT I am Campaign Coordinator with Greenpeace Canada, and as such have knowledge of the following facts and matters deposed to.

2. THAT from February 1989 until December 1991 I was employed by Greenpeace Canada as the Nuclear Free Seas and Disarmament Campaigner and Campaign Coordinator; and that I continue to be employed by Greenpeace Canada as the Ozone Campaign Coordinator.

3. THAT I have an M.A. degree in Sociology from Simon Fraser University (1972) and a B.A. from the University of British Columbia (1969).

4. THAT I am a member of the B.C. Association of Social Workers, and prior to my employment with Greenpeace I was employed as a Child Care Worker and Social Worker with the Ministry of Human Resources of British Columbia; Instructor at Douglas College in the Sociology and Counselling Departments; Administrator of Student Residences at U.B.C.; Therapist in the Alternative Program for Alcohol and Drug Dependencies; and Social Worker and Group Therapist in Private Practice.

5. THAT Greenpeace is an international environmental organization that was founded in Vancouver, British Columbia, in 1971. It now has offices in 23 different countries, with over five million supporters worldwide, including over 400,000 supporters in Canada, and 55,000 supporters in British Columbia.

6. THAT Greenpeace was born out of the opposition of Canadians to underground nuclear testing in Amchitka, Alaska in 1971. The purpose of the organization is to work for a green and peaceful world. To accomplish this purpose we must rid the planet of the dangers of nuclear technology in every facet of the nuclear cycle including uranium mining, nuclear testing and weapons production, nuclear energy, and nuclear waste.

7. THAT my primary responsibilities in Greenpeace, from February 1989 to December 1991, included organizing and coordinating the Nuclear Free Seas and Disarmament Campaign of Greenpeace International in Canada. The primary purpose of the international Nuclear Free Seas and Disarmament Campaign is to rid the world's oceans from the dangers of nuclear technology-- either in the form of nuclear weaponry or nuclear propulsion. The primary means to this goal is the education of the public, and responsible officials, to the real and current threat from nuclear technology.

8. THAT the Nuclear Free Seas Campaign is based on extensive on-going authoritative research into the nature of nuclear technologies at sea. We study the accident rate of the world's nuclear navies. This research has been published as a series of booklets entitled the Neptune Papers. This series includes the following volumes:

   Neptune Paper 1: The Nuclear Arms Race at Sea, October, 1987

   Neptune Paper 2: Nuclear Warships and Naval Nuclear Weapons-- A Complete Inventory, May 1988

   Neptune Paper 3: Naval Accidents 1945-1988, June 1989

   Neptune Paper 4: Naval Safety 1989-- The Year of the Accident, April 1990

   Neptune Paper 5: Nuclear Warships and Naval Nuclear Weapons 1990-- A Complete Inventory, September 1990

   Greenpeace research indicates that the world's nuclear navies suffered over 1200 accidents between 1945 and 1988, including fires, explosions, collisions, propulsion problems, groundings and sinkings. Such accidents have resulted in the loss of up to 48 nuclear warheads and seven nuclear reactors which are still on the bottom of the world's oceans. That the British, American, and Soviet nuclear navies have all suffered serious accidents and problems involving the nuclear reactors of their ships. At times such accidents have occurred close to civilian centres.

9. THAT in my capacity as the Coordinator of the Nuclear Free Seas Campaign in Canada and in British Columbia I have had the responsibility of representing the Campaign to all levels of government; to commission public opinion polls; to give public lectures; to write articles; to work cooperatively with other peace, environmental, and anti- nuclear organizations; to organize non-violent direct action protests; to retain legal counsel and oversee Greenpeace's participation in the court cases that resulted from such protests; to organize public events; and to be the media spokesperson for the Campaign.

10. THAT on April 11, 1989, in my capacity as Coordinator of the Nuclear Free Seas Campaign, I represented Greenpeace as one of over 30 delegates to Vancouver City Council's special hearings on nuclear warship visits to the Port of Vancouver. These hearings resulted in City Council urging the Federal Government to declare the Port of Vancouver a Nuclear Free Zone.

11. THAT on May 2, 1989, I coordinated the sending of an Open Letter to Prime Minister Brian Mulroney, by 150 prominent British Columbians, who expressed their support for Vancouver City Council's resolution.

12. THAT on April 22, 1989, in conjunction with End the Arms Race Coalition, I organized the program for the annual Walk for Peace, which saw up to 80,000 people rally around the theme of making the Port of Vancouver a Nuclear Free Zone.

13. THAT during the summer and fall of 1989, I organized numerous non-violent direct action protests against nuclear warships in Vancouver, resulting in some individuals being arrested.

14. THAT I arranged for Rear-Admiral Eugene Carroll, U.S. Navy (retired), from the Center for Defense Information in Washington, D.C., to testify as an expert witness in the December 28, 1989, trial of Greenpeace anti-nuclear activists. I heard Admiral Carroll testify that these nuclear warships do pose a danger fo the public and that an accidental fire aboard the ships could result in a plutonium cloud spreading radioactive contamination over a wide area.

15. THAT I witnessed Judge Wallace Craig of B.C. Provincial Court acquit four of the activists who painted the international radiation symbol on the hull of the warships, and acquit a fifth activist for chaining himself to the stern ladder of the nuclear-capable ship USS Independence. Judge Craig gave a conditional discharge to another for climbing the anchor chain of the USS Independence before it was lowered. He stayed proceedings against three other activists with foreign citizenships.

    I also heard Judge Craig chastize Ottawa for allowing nuclear weapons into Vancouver Harbour, stating "It is a remarkable thing that the government has seen fit to invite this type of equipment into Vancouver, in view of the serious concern that people have about it. It really invites protest."

16. THAT in the spring of 1990 I commissioned Viewpoints Research Ltd. of Winnipeg to research the opinions of British Columbians regarding nuclear issues. The summary of the May 14, 1990 poll, appended as Exhibit "A" to this my affidavit, is as follows: 68.7% of people in the Lower Mainland favoured banning all warships which may be carrying nuclear weapons from entering Vancouver Harbour. 68.8% of all British Columbians favoured declaring the Province a Nuclear Weapons Free Zone. 60.9% of all British Columbians favoured banning nuclear-powered ships from travelling in B.C. waters or visiting any of the ports or harbours in the Province.

17. THAT on May 15, 1990, I was part of a delegation that met with then Premier William Vander Zalm and his Cabinet, and I presented the results of the above poll to the Premier. I also mailed the results of the poll to the Minister of National Defence.

18. THAT on August 29-30, 1990, I participated in a protest against the presence of the nuclear-powered aircraft carrier the USS Nimitz inside Whiskey Gulf in the Straight of Georgia. The protest occurred two weeks after four sailors from the Nimitz testified publicly that the nuclear reactors aboard the Nimitz were unsafe. They had stated that there is frequent falsification of certification papers for sailors who work with the reactors.

19. THAT on August 31, 1990, an AWOL sailor from the USS Finback presented himself in my office with a similar story to the Nimitz sailors concerning lack of safety standards and inadequate training for sailors aboard a nuclear submarine. I arranged for national media coverage of this issue.

20. THAT on September 15, 1990, I participated in a protest at Esquimalt Naval Base to oppose the visits of nuclear warships to that port. Our protest, which involved the Greenpeace flagship the Rainbow Warrior, received strong support from the public in Greater Victoria.

21. THAT in May 1991, as Coordinator of the Nuclear Free Seas Campaign, I agreed to join the "Sub Conscious Campaign", which is a coalition of British Columbian organizations that are in opposition to nuclear submarine traffic through Dixon Entrance.

22. THAT in August 1991, I coordinated a delegation of British Columbians who sailed aboard the Rainbow Warrior, from Prince Rupert, B.C., to Ketchikan, Alaska, in opposition to a nuclear submarine accoustical testing facility in Behm Canal. That facility is now drawing nuclear submarine traffic through B.C. waters in the Dixon Entrance. Our delegation included fishermen, environmental and peace activists, leaders of the Haida Nation, Raging Grannies from Victoria, and elected officials from Prince Rupert.

23. THAT it is my understanding that the majority of British Columbians are opposed to nuclear-capable or nuclear-powered warships transitting B.C. waters or visiting B.C. ports. There exists widespread public concern over the safety of these ships and the dangers they pose to the environment and to the public. There exists widespread disapproval of the October 30, 1991, Orders-In-Council of the Federal Government, which give consent for foreign nuclear warships to enter Canadian waters and ports. The broad democratic will of the people of British Columbia favour a thorough environmental impact assessment and public review concerning the presence of nuclear warships in the Province.

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