[Editor's Note: Captain Mal Walsh is a Master Mariner from Comox, BC. He has over 40 years of experience in the international oil exploration and shipping industry—both commanding vessels on the seas and working ashore in management. He served on deep-sea ships in the British Merchant Navy before working in the offshore oil industry in the North Sea. When he came to Canada, he worked for Dome Petroleum during their exploration in the Beaufort Sea then came ashore and became General Manager of Marine and Environmental Services with Canadian Marine Drilling (CANMAR).
This letter was originally published in Western Mariner to express Captain Walsh’s professional concerns about the proposed tanker routes associated with the Enbridge Northern Gateway pipeline terminal in Kitimat, BC. The author has provided his permission to re-publish the letter in The Vancouver Observer. Some parts have been bolded for emphasis.]
I write this in response to the article Tanker Routes & Terminals: the Kitimat-Enbridge Northern Gateway Pipelines Proposal in the April 2012 issue of Western Mariner. I am drawing on my background in the marine industry, first as a professional Master Mariner with world-wide seagoing experience (including ocean salvage tugs) and my experience ashore in ship management. I have reviewed the Marine Shipping Quantitative Risk Analysis produced for Enbridge by Det Norsk Veritas. There are many concerns with the proposal’s marine components which I will outline below.
I have no negative opinion about the transportation of petroleum products by pipeline.
Many thousands of miles of pipeline around the world have, in general, proven it to be the safest method per ton/mile available. However, the transport of oil by tanker has not been as safe a method. When problems occur with tankers they can result in large, often catastrophic, releases of oil into the marine environment and onto coastlines.
The Enbridge tanker transport proposal, in its current form, represents too great a risk to a remote and still pristine area of BC’s Central Coast, a region of this coast that is exposed to the most severe winter weather conditions.
Enbridge proposes a high level of tanker traffic through the approximately 140 nm (nautical miles) of confined channels between the open ocean and Kitimat, the location of the pipeline’s terminal.
- Enbridge initially proposes some 220 tanker (minimum size 140,000 deadweight tons, or dwt) loadings of crude oil (bitumen) annually at Kitimat.
- Enbridge projects that bitumen tanker sizes and frequencies will be: Aframax (120,000 dwt) - 50; Suezmax (up to 200,000 dwt) - 120; Very Large Crude Carrier (VLCC; up to 330,000 dwt) - 50. In addition to these numbers there is already an average of 55 product tankers (up to 40,000 dwt) which deliver condensate to Kitimat. Condensate, hauled by rail from Kitimat to Alberta for the last 20 years, is used to dilute the tar sands petroleum product (bitumen) so it can be pumped through pipelines. Product tanker traffic will increase with the volume of bitumen shipments.
- Enbridge proposes using tankers for the bitumen trade that are no older than 20 years. Generally tankers will change ownership at 8-10 years with the cycles of ship surveys for IMO and Marpol regulations and ship classification societies’ major hull and machinery surveys. As tankers approach 20 years in service, they can be in the third ownership tier and at the end of their service lives. Ships Monthly (March 2012) reports that the number of first generation of double-hulled tankers (launched through the mid-1990s in response to new regulations after the Exxon Valdez oil spill) going to scrap is currently increasing. The reason cited is low VLCC rates. A growing body of evidence describes microbially-induced corrosion in double-hulled tankers as contributing to shortened ship life-spans.
- Tankers will return to this coast in ballast. The water ballast they take on prior to crossing the Pacific will need to be discharge once they get into the sheltered waters of this coast. Marpol 2006 deals with segregated or dedicated ballast and the treatment to kill marine species in this class of ballast. However, Marpol 2006 does not come into force until 2016 and is still being type approved.
Enbridge states how they will oversee their ballast operations but do not say if they intend to pump take it ashore for treatment before release back to the ocean. Marpol 1978 holds detailed regulations on tank washing etc and limits on oily water discharge and it is in force now. But those regulations allow 15 ppm (parts per million) oil discharge. Canadian Coast Guard regs for inland waters are 5 ppm and for Arctic waters are zero oil discharge. Details of ballast operations are yet to be provided by Enbridge.
- Two routes are proposed for inbound/outbound tankers. The northern route is from Dixon Entrance into Hecate Strait, Principe Channel via Browning Entrance, Nepean Sound, Squally Channel, Wright Sound then Douglas Channel. On the southern route tankers enter Queen Charlotte Sound, Hecate Strait, Caamano Sound then joining the northern route (Squally Channel, Wright Sound, Douglas Channel) to Kitimat.
- The northern route requires picking up/dropping off the proposed two pilots (required by law) at Triple Island, then it’s a 140 nm, 14-20 hour run to Kitimat. The southern route is a few hours less, but the Enbridge proposal has pilots being picked up from and dropped off on tankers by helicopter off Caamano Sound and not using the Pine Island pilot station. This will be extremely challenging in winter periods of low visibility and winds.
- Two pilots on board tankers does not mean there are two additional sets of eyes on the bridge. Standard practice would have, on the long Kitimat run, one pilot on the bridge and the other pilot off-duty.
- The southern route is a poor choice in winter for any vessel, let along a laden tanker. This area of the central Coast experiences frequent gale to hurricane force winter winds from the open Pacific. On April 2 2012, a mid-latitude depression with a 958 millibar low pressure centre just off the west coast of the Queen Charlottes had forecasted hurricane force winds with seas in excess of eight metres off northern Vancouver Island and into Hecate Strait.
- Inbound tankers are in ballast but have greater freeboard than when fully-laden with cargo, so are more susceptible to the forces of windage. They can be harder to control in heavy weather as they reduce speed while making approaches to the channel entrances Both inbound and outbound ships could be set northward by strong prevailing southeast winds towards shoaling ground.
- On the southern route a laden tanker leaving the coast must head southwest to clear Cape St. James then proceed off the lee shore of the Queen Charlotte Islands to get on the circle route across the North Pacific.
- Both the north and south routes include ‘sheltered waters’ between Hecate Strait and Kitimat. However the Douglas Channel/Wright Sound waters are subject to severe Arctic outflow winds. In addition there are maximum flood and ebb currents generated by the six-metre tidal range in Douglas Channel.
- Enbridge proposes one tug to escort each inbound tanker in ballast. This tug will not be tethered to the tanker. Outbound laden tankers will have two escort tugs in the confined channels, one tethered to the stern of the ship and the other will be available to assist as required. Once out of the confined channels one tug will continue untethered with the tanker to the pilot station. Given the potentially challenging weather conditions, combined with currents and the necessity for many course changes by the tankers in the confined channels between Hecate Strait and Douglas Channel, and the busy crossroads of vessel traffic in Wright Sound, the safest procedure would be two escorts tugs (at least, one tethered) with inbound tankers and both tugs tethered to outbound tankers through all confined channels. In the final analysis it is the pilots of the Pacific Pilotage Authority, not Enbridge, who will determine the number of tugs and the total horsepower required to escort a tanker.
- The Enbridge proposal states that tanker speed will be reduced in confined channels to between eight and 12 knots. Laden outbound tankers, once up to speed, have a long reach if required to slow. However, on any vessel under pilotage it is the pilot who determines the ship’s speed. Ships under escort in Haro Strait and Boundary Passage in BC’s southern waters are not permitted to ever exceed 10 knots.
- Enbridge proposes escort tugs (they say the cycloidal propeller tractor tugs are best for escort) with 100-ton bollard pull. Particularly for the proposed VLCCs, these tugs need to have minimum of 120 tons bollard pull (140 tons is optimal) and need to be capable of operation in all sea conditions. As proposed, with tankers inbound and outbound simultaneously, at least three escort tugs will be required. With the long escort distances and transit times each tug will need to carry double crews, living and working aboard in rotations, to remain fully operational and ready to respond to an emergency.
- There are presently no large high-powered (170-ton bollard pull) privately-owned or Canadian Coast Guard salvage tugs stationed on this coast to respond to vessels in difficulty in the offshore waters. A loaded disabled 250,000 ton tanker in adverse conditions off the BC coast will represent a huge challenge to the best-trained salvage tug crew. Large salvage/response tugs have been built by the French (2) and the British (4) to protect their coasts. China has four very large salvage vessels presently under construction. Twenty years ago, Canada’s fleet of large Coast Guard cutters was aging and only one (the Terry Fox) had heavy towing capability.
- All tankers, regardless of age, will need to be fitted with high-strength tow points capable of withstanding the full pulling power of the escort tugs and the proposed shipdocking tugs (two with 50-ton bollard pull) to be stationed at the Enbridge terminal in Kitimat. By Canadian law and international maritime convention, Transport Canada is required to conduct regular Port State Inspections of all foreign-flagged tankers (and other ships) entering Canadian waters for their seaworthiness. With the increased Kitimat tanker traffic a fully-funded Transport Canada Ships Safety division must be established at Kitimat to conduct continuous fully-transparent Port State inspections and maintain the additional services required (navigational aids, pollution response, vessel traffic services, etc). This cannot be achieved out of Vancouver and will require significant investment by Transport Canada.
- The navigational aids on the proposed northern and southern routes are currently inadequate for increased large ship traffic. There is presently no marine traffic radar coverage on the north and central BC coasts. Enbridge has proposed that they will install new navaids and land-based radar systems, however they are now in discussion with Coast Guard and DFO as to who would be funding, constructing and maintaining these services. It’s the responsibility of Coast Guard Marine Communications and Traffic Services (MCTS) to monitor traffic in Canadian waters. Currently the federal government is cutting the Coast Guard budgets, not preparing them to deal with increased traffic in large tankers in confined waters.
- There is no separate and large pollution clean-up fund as in the Arctic where petroleum producers are required to establish such a fund. There is no ‘user-pay’ system in place and the producers of bitumen will not accept liability for spills of their cargo. And the Coast Guard is underfunded and not equipped with the resources required to deal with significant oil spills, on behalf of the Canadian taxpayer.
Kitimat is a poor choice for a major new Gateway port for the shipment of crude oil. The questions about tanker transits in confined waters and in severe West Coast winter weather conditions are too many and the risks to the marine environment too great.
Capt. Mal Walsh