Carrying on from our previous theme of debunking the port’s STS update you don’t have to look far down what effectively is the first page (p5):
“Ship-to-ship oil transfer regulations are a positive environmental story
Ship-to-ship oil transfer operations are a commercial necessity for world trade. They also reduce overall tanker movements. Prior to 2010, they were unregulated in the UK and could take place almost anywhere. In practice, this often meant transfers were undertaken offshore, in exposed conditions and without close proximity to an oil spill response team.
The Merchant Shipping (Ship-to-Ship Transfers) Regulations were introduced in 2010 to ensure ship- to-ship oil transfer operations are properly monitored and regulated. These regulations prohibit the transfer
of oil unless it is carried out within harbour authority waters and by those in possession of an oil transfer licence (OTL). This change in regulations was supported by RSPB Scotland; WWF Scotland; Scottish Wildlife Trust; WDC, Whale and Dolphin Conservation (formerly Whale and Dolphin Conservation Society); National Trust for Scotland; The Hebridean Whale and Dolphin Trust and The Marine Conservation Society. (See http:// www.scotlink.org/files/policy/ConsultationResponses/ LINKmtfConsultShip2ShipReg10.pdf)“
Firstly – STS are a necessity for a couple of reasons – when oil price is low, instead of sending oil to a refinery oil companies stick it on a tanker effectively “banking” the value of the oil when the price goes up and it can be sold on and transferred to another tanker – this happened a lot with North Sea production last year. Then you have the actual reason that we have the regs (see http://www.legislation.gov.uk/uksi/2010/1228/pdfs/uksiem_20101228_en.pdf). If you don’t feel like reading the full explanatory text for the 2010 STS regs, here is the relevant part:
“The problem under consideration is how to prevent pollution from ships engaged in ship-to-ship transfers. Government intervention is required because cargo transfers, consisting wholly or partially of oil, and bunkering operations between ships at sea are currently unregulated in the UK. There is no statutory requirement for parties engaged in such transfers at sea to notify the UK authorities or have the necessary resources in place should a pollution incident occur. At present, there are no powers in place to prevent such operations taking place. The introduction of the Regulations would seek to bring these transfers within statutory harbour areas, where there already exists a statutory responsibility to have oil pollution contingency plans in place, thus reducing the risk and impacts of any potential spills.
Historically, STS transfers have been carried out in the UK territorial seas in locations off Southwold (Suffolk) and in Lyme Bay (Devon/Dorset), as well as in the Harbour Authority areas of Scapa Flow, Nigg and Sullom Voe. In recent years, there has been an increase in STS transfers in UK waters, brought about by new trading patterns within Europe and Russia, namely the noted increase in trade through European waters of Russian export blend crude oil and heavy fuel oil.
The specific reason for the requirement to carry out the transfers is that the oil emanating from Baltic and Russian ports initially has to be shipped using relatively small tankers due to the shallow waters of the Baltic Sea and some of the approaches to the Northern Maritime Corridor ports. However, once this stage of the journey has been negotiated it is then more economically viable to transfer the oil into larger tankers for the onward journey to its eventual destination in either the Americas or the Far East.”
So its all about economics. That’s fine, but note that it refers to historic STS transfers at Nigg – not in the middle of the Cromarty Firth. Yes the NGO’s listed in the port document (RSPB, WWF etc) did undoubtedly support these regulations as they considered that it would afford protection of the environment from what they saw at the time as an increasing problem (unregulated transfer of crude oil). However, ask any of those organisations if they think the CFPA’s plan to take STS transfer to the open sea is a good idea and I guarantee that none of them do – more media spin written by people who really do not understand the issue. So go on, if you are a member of any of these organisations, write to them and ask them what they think, how they feel about having their names used in this way and moreover what they are going to do about a new licence application? That’s not just about responding to the consultation and thinking that’s enough. How will they actively use their power to put a stop to this idea once and for all.
In the UK government’s own words:
“The intended effect of the Regulations is to ensure that the UK would have the ability of prevent ship to ship transfers within the 12 nautical mile limit if they are considered a risk to the environment, economy or local communities.”
We would contend that CFPA’s application present a risk to all three!
