54 North and the plan to nowhere (Part 1)

The proposed Enbridge Northern Gateway pipeline project has already raised more than eyebrows and the hearings have only really just begun. Enbridge has provided assurance after assurance that the whole show will be completely safe including the movement of ships through BC's  north coast access to Kitimat arm at the head of Douglas Channel.

I've made the trip Enbridge is suggesting is completely safe, in a chemical tanker, more than a few times. And given that my ship was considerably smaller than what Enbridge is proposing even my eyebrows started lifting.

Stephen Harper's Feb 2012 visit to China saw him pumping hard to promote the Northern Gateway project. Listening to him it sounded like a fait d'accompli and the regulatory review currently underway is little more than a time-consuming annoyance.

This is the same Stephen Harper who has taken a rake to the funding of federal departments and has forced them to either reduce or cut operations, including the Canadian Coast Guard and DFO, the increased presence of which will be critical to the prevention of any future disaster in light of the enormous expansion in large tanker traffic being proposed.

Enbridge has offered public assurances of a high standard of maritime safety in a summary here. Many of the statements they offer are motherhood:

All vessels entering Kitimat Marine Terminal will be modern and double-hulled

As if they couldn't be? That is a standard of the International Maritime Organization. Enbridge is not doing anything.

Operational safety limits will be established to cover visibility, wind and sea conditions

Again, not something over which Enbridge has any say. Such limits are established by international rules and Canadian government regulation. Not to mention the standard practice of seafarers. Since Enbridge does not appear to be building a fleet of their own to transport bulk bitumen they will have no additional control over shipping.

The escort tugs will have extensive first response capabilities to provide immediate assistance if required (available to any ship in distress)

Good. That bit in brackets however, is not something Enbridge is doing to increase their goodness. It is the statutory obligation of all mariners, when able, to come to the aid of any vessel in distress. This little part of the Enbridge "plan" is written in law.

Northern Gateway will install an advanced radar system to cover important route sections to provide guidance to pilots and all marine traffic on the Northwest coast

Will they now?  On 16 January 2012, in response to a question posted on the Enbridge website, they said this:

Northern Gateway has had preliminary discussions with the Department of Fisheries and Oceans, Canadian Coast Guard to assess how future additions to aids to navigation and the introduction of land-based radar coverage to the north coast may be paid for, constructed and maintained.

That doesn't sound definitive at all. It sounds like a plan to develop a plan. We'll get back to that a little later on.

Additional navigational aids will be installed, such as navigation beacons, buoys and lights throughout the confined channel area

Given that this is a DFO/Canadian Coast Guard responsibility the question now rises: who is expected to pay for all these new nav aids? More on that later, too.

Prior to arrival in Canadian waters, all vessels will be vetted by independent, third-party agencies and will be required to meet Northern Gateway's safety and environmental standards

How very nebulous. In further statements Enbridge introduces a "Tanker Acceptance Program". This is an industry standard and is in place in every major liquid cargo transfer terminal in the world. An old tanker master would look at this statement and immediately think SIRE program from the Oil Companies International Marine Forum. One would expect that Enbridge would be chin deep in the OCIMF library learning how to implement a TAP and develop "best practices" for the safety and environmental standards they are suggesting.

Enbridge, however, is not a member. 

Vessel speed will be reduced in the marine channels to between 8 and 12 knots

Which is one of those kinds of statements that dismisses the reality of conditions. Given the length of the transit and the time involved every ship, in both directions, will encounter changing conditions such as a tide change. Given the range of tide in Douglas Channel, for example (in the 6 meter range), that means a period of maximum flood or ebb currents. The speed over the ground will differ from the speed rung on. At times ships will be carrying revs for more than 12 knots just to maintain that speed. Laden outbound tankers will take time to get up to speed and once there will have a long reach if there is a requirement to slow. The speed of any vessel under pilotage however, may well be determined by the pilot. Ships under escort in Haro Strait and Boundary Passage are not permitted to exceed 10 knots - ever. How does Enbridge propose to see even larger ships permitted to achieve 12 knots when current rules existing in southern waters do not allow it?

All tankers visiting the Kitimat Marine Terminal will be safely guided by certified marine pilots

One would hope so, since that's the law. I have every confidence in BC Coast Pilots. Recent comments from the president of BC Coast Pilots Ltd. suggested that there would be no problem meeting the demand of increased tanker traffic. I will wonder, until the first transfer has happened, how pilots will join the ship outside the entrance to Caamano Sound in gale or storm force winds. One of the items out of the marine safety video that was interesting is that every ship will have two pilots thus providing the bridge with two more sets of independent eyes.

No.

The requirement for two pilots has to do with watchkeeping needs. The standard practice is that there is always one pilot on the bridge while the other one is resting. On occasion there is a mandatory requirement for two pilots on the bridge under pilotage rules set by the Pacific Pilotage Authority but no such rule exists outside Haro Strait and Boundary Pass at southern Vancouver Island.

At about this point one has to shift over to the marine safety fact sheet to get more information.

All laden tankers in the CCAA will be accompanied by one tug tethered (attached) to the tanker, and a second tug in close escort. Ballasted tankers within the CCAA and all tankers (laden and ballasted) travelling between the pilot boarding stations and the CCAA will be accompanied by one close escort tug.

The "CCAA" is an abbreviation for the Confined Channel Assessment Area. That isn't terribly clear on the Northern Gateway public website. Now, as to the escort tugs, let's face one simple fact: there is no legislation regarding escort tugs. Rules governing escort tugs in the waters around southern Vancouver Island come from the Pacific Pilotage Authority - not Transport Canada. And you would be hard pressed to find a copy of any such rules unless you knew where to look. Further, there are several things necessary to make an escort tug useful. There needs to be tanker/tug matching. An escort manual needs to be developed and extensive crew training undertaken. I'll have more on this subject in a future post.

Tankers will be subject to regular Port State inspections by Transport Canada

As for any foreign-flagged vessel of any type. This is not an Enbridge initiative - it is Canadian law and international maritime convention. The problem here, however, is Transport Canada. Port State Control inspections are anything but transparent and Transport Canada will not make public the result of any inspection without a Freedom of Information Request. Given that the seaworthiness of foreign-flagged vessels in Canadian waters is a matter of public interest in this country, and particularly where it applies to something like a Very Large Crude Carrier (Supertanker), Transport Canada's secrecy around such inspections is an abomination.

Earlier I pointed out that Enbridge stated that they would install land-based radar systems to facilitate traffic management. Since that appeared they have subsequently responded that they were in discussions with DFO and Coast Guard as to who would be funding, constructing and maintaining such a system. In the response they added this:

It is the responsibility of the Canadian Coast Guard, Marine Communications and Traffic Services (MCTS) to monitor traffic in Canadian waters via radio call-in and the newly implemented Automatic Identification System (“AIS”). The introduction of land-based radar with the support of Northern Gateway and proponents of other shipping projects would enhance the ability of MCTS to verify AIS and radio call in data. 

Right, because there is no marine traffic radar coverage on the north and central BC coast. None. The Marine Communications and Traffic Services of the Canadian Coast Guard has been subject to the same budget cutting measures as all other federal departments. Far from being ready to deal with increased vessel traffic involving ships of up to 320,000 DW tonnes, the Coast Guard is already under stress and the MCTS system has undergone staffing cutbacks.

Enbridge, who originally trumpeted that they would install radar is now appearing to waffle. And they're quite correct - there are other shipping projects for exactly the same area which will see a tripling of traffic into Kitimat. In fact, there are three of them.

If Stephen Harper is such a proponent of the Northern Gateway project and demanding it be built, despite any objections, he'd better be prepared to put his money on the table. The entire central and northern BC vessel traffic management system is need of attention now. If the upcoming federal budget fails to address the requirement to increase vessel safety on a huge scale it is a demonstration that the Harper government is not terribly serious about the Enbridge proposal or it is ignorant of the inherent risks or it just doesn't care. If a complete overhaul of the northern BC vessel traffic system doesn't begin within the next few months, nothing will be ready when the first big honkin' tanker shows up.

There's more, but that should be enough to start you thinking. Part two later.