2022 Levels of Service: Survey Results

Introduction

In 2021, the Canadian Coast Guard (CCG) undertook a review and update of its 2010 Levels of Service (LOS) for its six programs: Aids to Navigation (AtoN), Marine Environmental and Hazards Response (MEHR), Icebreaking Services, Marine Communications and Traffic Services, Search and Rescue, and Waterways Management. The review’s primary focus was to align Coast Guard’s LOS with the current operating environment in regards to the provision of services and its standards.

A bilingual online survey tool was opened for respondents on May 3, 2021 and closed on July 3, 2021, to seek input on Coast Guard’s LOS. Invitation to access the survey to provide input was distributed using social media, Coast Guard’s national and regional advisory boards, regional stakeholder networks, and the Government of Canada consultations pages. The survey divided the Coast Guard’s services and standards by program for comment. Respondents were invited to review any or all of the six programs and provided multiple choice opinions and a comment box to qualify their choice. In concert with the survey, CCG worked with industry partners via the National Maritime Advisory Board (NMAB) Marine Navigation Sub-committee to validate the survey findings and flag where updates were needed.

The results of the survey were reviewed by CCG programs and assessed for practicality and possible implementation. The 2022 LOS document was drafted as a results of these assessments.

This document includes the survey results organized demographically, statistically, and thematically. As such not all comments are reflected. All comments, however, were reviewed by program experts and considered as part of the update process.

Survey results data

Respondents were invited to select more than one category to best describe themselves; for example, a respondent could put “Small Craft Harbour”, “Recreational boater”, and “Other” to represent themselves. As a result, the number above does not reflect the actual number of survey respondents.

The online survey resulted in 242 distinct survey responses from all six programs, 207 of those were English, and 35 were French. Respondents could complete a survey on any or all programs as many times as they wanted.

Aids to Navigation

A total of 67 aids to navigation surveys were completed. The vast majority of responses (83%) identified no proposed amendments to the AtoN LOS. The remaining 17% of responses sought changes for the LOS, which were shared with Coast Guard’s regional operations for consideration.

The AtoN program also identified some general themes arising from the survey comments:

General comment: Promoted an expansion in the use of e-Navigation tools and the inclusion and wide use of Automatic Identification System (AIS) AtoN.

CCG Response: CCG is modernizing its marine navigation services and the provision of AIS AtoN is among several important initiatives linked to Canada’s implementation of e-Navigation. At this time, Coast Guard is in the process of developing national directives and procedures to support operationalizing AIS AtoN.

General comment: AtoN program’s LOS should include a provision of AtoN for municipal and recreational wharves, harbors and users.

CCG Response: The AtoN program’s LOS is underpinned by the program’s mandate and national directives that are aimed at delivering services for the safe, economical, and efficient marine navigation for certain commercial and government ships in Canadian waters. In the design of AtoN systems for serviced waterways, Coast Guard takes into account others users, such as recreational boaters. Facilities not serviced by Canadian Coast Guard AtoN have the option to explore the use of private AtoN, which are regulated by Transport Canada.

General comment: Newer technologies could justify raising the visibility standard for physical aids to navigation.

CCG Response: While technologies like AIS have helped to improve the safety of marine navigation, they do not impact the line-of-site visibility of physical AtoN. The visibility standard informs the design and review of AtoN systems and has an impact on related factors, such as when to introduce RADAR aids and audible aids. An increase in this particular standard would require a national review of all AtoN systems against the standard, involving costs, resources and time in years that would greatly outweigh the benefit of an increase.

General comment: Discontinue the inclusion of audible aids as audible (formerly, aural) aids, are obsolete, ineffective, and a poor indicator of vessel position.

CCG Response: Audible aids such as bell buoys, whistle buoys, and fog horns remain an important component Canada’s AtoN system and of international best practices (IALA standards). They may only be used as a hazard warning in low visibility conditions and a means to augment an existing AtoN system, given that the actual range of a sound signal can be affected by climatic factors (e.g., wind, humidity) and noise levels on a ship.

General comment: De-staff lighthouses (light stations) as they are not cost-effective.

CCG Response: The Canadian Coast Guard considers a range tools, such as the use of light stations, in the design and delivery of AtoN systems specifically tailored to the waterways and users they serve. Whether a light station should be staffed is a program management and system design consideration that would not be reflected in national LOS. These comments have been passed to regional program experts.

General comment: Monthly NOTMAR should become a weekly publication and paper versions of the program’s publications reintroduced.

CCG Response: Internationally and domestically, the preparation, distribution and use of maritime safety information (MSI) continues to be transformed by digitization and automation. Accordingly, the CCG is modernizing its marine navigation programs and services. Currently, there is no capacity to increase the frequency of publications; however, it is among a broad array of considerations as we establish new capabilities that leverage these technologies. Currently, MSI provided by the AtoN program is freely accessible on the Canadian Coast Guard’s internet site and includes the Monthly Notices to Mariners (NOTMAR), the Annual NOTMAR, and the List of Lights, Buoys and Fog Signals. From the Canadian Coast Guard’s website, users can access and download these publications, and if desired, print them at their own expense.

Icebreaking Services

There were 28 respondents to the Icebreaking services portion of the survey. The majority of respondents identified “no change/no opinion” on the services provided.

Where there were requests for changes to the service, they fell within several categories such as faster and more frequent icebreaking service delivery, availability of icebreakers, improved monitoring and flood prevention, and greater clarity on icebreaking response variables.

Respondent Comment Themes:

General Comment: There needs to be more icebreaker vessels and the service needs to be provided at a greater frequency.

CCG Response: The addition of new icebreaking assets to the CCG’s fleet falls outside the scope of the Level of Service (LOS) review. The Icebreaking Program has been made aware of areas where respondents notes a lack of sufficient icebreaking capacity. In the LOS, icebreaking services are measured against the time allotted for an icebreaker to arrive at the scene of a request. In order to better communicate predictable response times to Canadians that better reflect operational realities, the following changes have been made to CCG’s Service Standard:

• The response to Labrador Coast, North East and East Coasts of Newfoundland has increased from 8 to 12 hours
• The response to St. Lawrence and Saguenay Rivers has increased from 5 to 6 hours
• We added a response time of 12 hours in Nova Scotia and Bay of Fundy areas

The CCG always strives to be on site as quickly as possible. However, due to the vast distances in our waters and remote coastal areas, environmental factors, and priorities management, CCG response may be delayed closer to the updated times.

General Comment: CCG needs to provide more monitoring services and flood prevention activities in the St. Clair and Detroit Rivers.

CCG Response: CCG monitors ice conditions and actively works to preventing flooding in the St. Clair and Detroit Rivers. Two CCG icebreakers are assigned to that area throughout the season to maintain the rivers and prevent flooding. This work is collaborative with the United States Coast Guard, who usually assign additional cutters to support operations.

When required, a CCG helicopter conducts daily ice reconnaissance flights with an ice service specialist to provide an overview of the river conditions. This helps assess risk and support operational decision-making.

General Theme: Greater frequency of Canadian Ice Service (CIS) products, particularly for the Arctic.

CCG Response:  The CCG and the Canadian Ice Service, as part of Environment and Climate Change Canada, work closely to provide products as quickly as possible. The CIS meteorologists and forecasters provide daily ice charts and forecasts in areas with active or planned navigation in the next five days. These areas are prioritized in consultation with industry. Regional ice charts are produced weekly, year-round, for the entire Arctic. Target image analysis charts are created based on satellite images on areas with active marine navigation. Long-range forecasts are produced bi-weekly over a 30-day timeline, when marine navigation is expected. Further support is provided by Ice Service Specialists on-board CCG icebreakers, who observe and record daily ice conditions.

General Theme: Indigenous People need to be consulted during the ice season.

CCG Response: During the ice season, as part of regional CCG communications, the CCG connects with communities when the breaking fast ice may impact local activities to ensure they support the operation. If the community does not support an icebreaking operation, the CCG ice office will discuss options with the client requesting the service. In season, CCG ice offices are open seven days a week and are available to support all stakeholders and communities.

Marine Communications and Traffic Services

A total of 32 surveyors reviewed Marine Communications and Traffic Services’ (MCTS) LOS. The majority of respondents indicated that they did not see a need for change or had no opinion on MCTS services. Many of the surveyors requested improved radio coverage across Canada and standardized use of radio frequencies. In many cases, surveyors provided requested service enhancements to specific regions. Those comments have been passed along for regional consideration.

General Comment: Upgrade software and user experience that streamlines information into mariner’s navigational systems.

CCG Response: MCTS is providing the service to receive and distribute relevant marine navigational information in accordance with the LOS, Government of Canada, and international regulations. The comments on upgrading user experience and enhancing delivery of navigational information is an ongoing process within Coast Guard.

General Comment: Enhanced service continuity across Canada, dead-zone removal, standardization of radio frequencies along Canada’s coastline.

CCG Response: MCTS relies on radio technology to receive and distribute navigational information to mariners. Canada’s coastline is complex and presents challenges that increase cost to provide Very High Frequency (VHF) along all of Canada’s coastline. Coast Guard assesses the needs of mariners and the area to create a network that provides radio coverage as best as can be achieved.

General Comment: MCTS should expand their services everywhere in Canada.

CCG Response: MCTS services are provided along all of Canada’s coastline. Similar to the general comment above, radio technology is deployed to meet mariners needs and operate effectively within its environment.

General Comment: MCTS infrastructure is dated and needs repairs across Canada. Respondents expressed frustration that certain services were not able to meet LOS or that dead spots still existed.

CCG Response: Comments received on not meeting existing LOS were passed along to the MCTS program for consideration.

General Comment: Directional Finding service is no longer needed because the system has been replaced by user’s onboard GPS systems.

CCG Response: Directional Finding service is used to triangulate the position of a vessel or object. GPS has not replaced this service. That said, Direction Finding will be removed from the LOS as it is primarily an internal service utilized by Coast Guard’s search and rescue (SAR) program. The LOS document will focus on services that are public facing.

General Comment: MCTS should receive sail plans via email in additional over the phone. Filing a sail plan to an MCTS officer is time consuming for both MCTS and the mariner.

CCG Response: In the event that a mariner wants to file a sail plan with a MCTS Officer it must be done over the phone or via marine radio. A MCTS Officer is better able to receive the plan and ensure its accuracy and thoroughness while speaking to the responsible mariner. Should an error be discovered during the exchange, the issue can be rectified immediately. This avoids any confusion that could be generated from email chains, guarantees that the sail plan was received and reviewed, and confirms both parties are working with the same information.

General Comment: Provision of Commercial Marine Telephone Call Service is no longer needed.

CCG Response: The Provision of Commercial Marine Telephone Call Service will be removed from the LOS. Coast Guard still offers the service but with no cost recovery . The cost-recovery was based on a dated pricing for long-distance calls.

Marine Environmental and Hazards Response

There were a total of 432  responses from a variety of respondents representing Coast Guard employees and the shipping industry. The majority of respondents didn’t request a change in service, but some enhancements were suggested. The overall consensus is that the current LOS is outdated and that the National Marine Spills Contingency Plan needs more information and needs to reflect an updated Levels of Service.

General Comment: Current LOS is outdated and needs updating.

CCG Response: CCG agrees that the current 2010 LOS is outdated and needs modernization. The updated LOS will accurately reflect what the Coast Guard can provide in terms of preparedness and response services to the Canadian public and provide reliable data streams to measure whether or not these services are being delivered. Furthermore, service standards need to be redefined to be more meaningful and measurable. Current service standards are too vague and broad and do not accurately capture whether or not the MEHR program is effectively meeting its LOS.

General Comment: The National Contingency Plan needs to be updated and include more information.

CCG Response: The National Marine Spills Contingency Plan is currently being updated.

General Comment: The role of industry in marine pollution response.

CCG Response: Respondents have stated that industry’s (Response Organizations) resources should be more coordinated with Coast Guard’s and that industry should take a more proactive role in a response. CCG’s policy is that they may contract with Response Organizations or other industry partners after the initial assessment, if necessary. Coast Guard intends to continue implementing this policy. With respect to coordinating resources, as part of the Oceans Protection Plan initiative, Coast Guard is upgrading its equipment response capacity to be more compatible with industry’s. 

General Comment: Marine Environmental and Hazards Response’s enforcement role should be enhanced.

CCG Response: MEHR does not  currently have enforcement authorities under the Canada Shipping Act, 2001, however this may be introduced in future amendments to the Act.

General Comment: The Duty Officer function should be enhanced

CCG Response: The Duty Officer role is currently being enhanced to train Regional Operations Centre (ROC) officers as Duty Officers. The goal is to have ROCs become a 24/7 incident reporting notification and coordination centre which will be responsible for notifying the MEHR Program of incidents and conducting the initial assessments and call-outs. This will allow the MEHR program to effectively respond to marine pollution incidents.

Search and Rescue

A total of 52 responses were received for Search and Rescue (SAR). The responses were received evenly across Canada. The majority of responses received were focused more on improvements of the SAR system as a whole and were not directly related to LOS.

The Coast Guard has a different mechanism for reviewing SAR delivery. The comments received will be used as part of Risk-Based Analysis of Maritime SAR Delivery (RAMSARD) process and any other initiative to improve the SAR system

Responses focused on extension / flexibility in seasonal SAR coverage based on regional vessel traffic. Responses highlighted in particular in the Arctic.

General Comment: Seasons are longer and longer. SAR seasons need to be extended or adjusted according to conditions. More assets need to be available.

CCG Response: The Coast Guard has a different mechanism for reviewing SAR delivery. As part of the Government of Canada’s Oceans Protection Plan, the RAMSARD project was initiated to ensure that SAR response is adequate and that CCG resources are being used effectively and efficiently. The comments received will be used as part of RAMSARD process and any other initiative to improve the SAR system.

General Comment: Service should be measured by the time to the incident - it will take a maximum of two hours to have a unit on-scene, no matter where the incident is located.

CCG Response: The CCG requires that vessels programmed as primary SAR vessels maintain a 30-minute standby posture. Service standards focus on the time between notification and departure of a SAR unit and does not factor in transit time. Transit time is highly variable, and is affected by geography, weather and accuracy of the last known position of the distress alert. The evaluation of transit time remains challenging and CCG will continue to look into ways to enhance response time with more controllable factors.

Waterways Management

The majority of respondents requested no change to service standards or had no opinion. Those that requested changes were interested in channel design guidelines for larger vessels and considerations for impacts on climate change, greater frequency of water level forecasts, and improved public communications on waterways services. Overall, respondents want to see Waterways Management modernized and relevant to the marine community.

General Comment: Channel guidelines should take into account larger vessels along with shipping and channel maintenance effects on the environment.

CCG response: The Channel Guidelines are currently under review and the new guidelines will be reflective of the current and future shipping trends.

General Comment: CCG should be providing dredging services beyond the Great Lakes connecting channels and the St. Lawrence.

CCG Response: In a 1998 decision, CCG removed dredging services from its suite of Waterways Management services except in the St. Lawrence River and the Great Lake connecting channels. These dredging services ensure safe vessel traffic through the St. Lawrence River and uphold an international bi-lateral agreement with the United States to ensure safe navigation along the St. Clair, Detroit, and St. Mary’s rivers.

General Comment: Improve communications with local residents regarding dredging services and disposal of dredging material.

CCG Response: CCG has added a section to the LOS which acknowledges the duty to consult with Indigenous groups as per section 35 of the Constitution Act and the United Nations Declaration on the Rights of Indigenous Peoples. Beyond Indigenous engagement, Waterways Management is taking these comments under advisement to expand the public’s awareness of the program’s activities.

General Comment: Waterways information, should be streamlined into mariners navigation systems for ease of use.

CCG Response: Waterways Management is involved in the development and implementation of the S-100 framework. The S-100 framework allows the user to incorporate hydrographic information into their navigation systems and easily update data standards. This will enable mariners to better integrate information in their navigation systems to help plan optimal routes and make critical decisions while navigating.

General Comment: Water level forecasts should be provided at a greater frequency than twice a week.

CCG Response: CCG is not able to provide more frequent forecasts as the data collection and processing cannot allow for it. Forecasts are currently produced twice a week, Monday and Thursday, for the St. Lawrence River, weekly for the Fraser River, and three times a week for the Mackenzie River during the ice-free season.