An Ontario shipyard is accusing the federal government of trying to unfairly award Quebec's Chantier Davie shipyard potentially billions of dollars in work without a competition.

The allegation is contained in a complaint from Hamilton-based Heddle Marine to the Canadian International Trade Tribunal over the government's search for a third shipyard to add to its multibillion-dollar shipbuilding strategy.

The winning yard, which will join Halifax's Irving Shipbuilding and Seaspan Marine in Vancouver in the massive naval procurement process, will be tasked with building six new icebreakers for the Canadian Coast Guard.

However, Heddle alleges in its complaint that many of the requirements the government says shipyards must meet to qualify for consideration are not legitimate or reasonable — and will disqualify virtually every yard but Davie.

It is asking the tribunal to order the removal of the requirements or the launch of a new search process.

The federal procurement department did not immediately respond to questions Friday. Davie declined to comment.

One of the requirements flagged by Heddle is that qualifying shipyards must have a contract now or recent experience in building a ship weighing more than 1,000 tonnes.

"No shipyard in Canada that is eligible to apply for the contract is capable of satisfying this requirement except Chantier Davie Canada," the complaint reads.

Davie confident

Qualifying shipyards must also be able to launch vessels wider than 24 metres, which Heddle says disqualifies all Ontario-based shipyards because vessels must be 23.8 metres or less to traverse the St. Lawrence Seaway.

Yet Heddle says the requirement also doesn't make sense because the icebreakers the third shipyard will be tasked with building must be able to access the Great Lakes — meaning they must be able to fit through the Seaway.

Those requirements and others "appear to pre-determine and/or unduly favour Davie as a qualifying supplier and unreasonably disqualify all other shipyards, but specifically Ontario-based shipyards," the complaint reads.

Heddle also takes issue with a lack of industry consultation before the search was launched on Aug. 2 and the 15-day deadline shipyards were given to respond. The deadline was later extended to Aug. 26.

There are also concerns about comments made by a Davie official and Prime Minister Justin Trudeau when he announced the government's plan to add a third shipyard to the national shipbuilding strategy.

"We recognize that it's an opportunity for Davie to apply to become that third shipbuilding facility because there will be a tremendous amount of work in the coming years," Trudeau said in May.

Davie, which received several federal contracts without a competition in recent years and whose surrounding is likely to be hotly contested in the fall federal election, has expressed confidence it will become the third yard.