CHAPTER 7
Conclusions and Recommendations

The committee’s charge was to design a comprehensive risk assessment for evaluating the risk of vessel accidents and spills in the Aleutian Islands and to recommend an appropriate framework for conducting that assessment. To fulfill this charge, the committee reviewed and evaluated available data and information on the current system and the operating environment. The recommendations presented in this report are intended to provide a logical sequence of building blocks that can be used to conduct the assessment in discrete steps so that early decisions can be made about the most important safety improvements and risk reduction options can be considered in priority order. This approach will allow for an efficient and focused study.

During its review of historical data on maritime operations in the Aleutian region and accidents that have occurred, the committee identified a number of areas of concern with respect to the safety of the existing system. Recent trends in vessel traffic in the region, combined with accident data, difficulties in responding to incidents, and the lack of infrastructure that explains many of those difficulties, made it possible to identify where improvements in each of these areas could be considered. Where appropriate, then, the committee developed findings related to accident prevention and mitigation



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CHAPTER 7 Conclusions and Recommendations The committee’s charge was to design a comprehensive risk assess- ment for evaluating the risk of vessel accidents and spills in the Aleutian Islands and to recommend an appropriate framework for conducting that assessment. To fulfill this charge, the committee reviewed and evaluated available data and information on the cur- rent system and the operating environment. The recommendations presented in this report are intended to provide a logical sequence of building blocks that can be used to conduct the assessment in discrete steps so that early decisions can be made about the most important safety improvements and risk reduction options can be considered in priority order. This approach will allow for an efficient and focused study. During its review of historical data on maritime operations in the Aleutian region and accidents that have occurred, the committee identified a number of areas of concern with respect to the safety of the existing system. Recent trends in vessel traffic in the region, combined with accident data, difficulties in responding to incidents, and the lack of infrastructure that explains many of those difficulties, made it possible to identify where improvements in each of these areas could be considered. Where appropriate, then, the committee developed findings related to accident prevention and mitigation 142

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Conclusions and Recommendations • 143 whose implementation could simultaneously enhance the risk assess- ment process and contribute to safer shipping operations. CONCLUSIONS The Aleutian Islands: Natural Resources and Maritime Operations Central to the public concern about improving the safety of shipping in the Aleutian Islands are the unique and valuable natural resources in the region that could suffer damage from shipping accidents. The region also is subject to frequent and sudden storms, high winds, and severe sea conditions that create operational challenges for all mariners. History has shown that spills in the Aleutians have been geographically widespread and that efforts to recover the oil have been ineffective. In its review of existing data on the Aleutians and their envi- ronment, the committee found that the area is home to globally unique natural resources. The vast diversity of species over an expansive region is well documented, and most of the Aleutian Island chain has been designated as a national wildlife refuge. Few marine areas in the world match the Aleutians in marine produc- tivity, and Dutch Harbor is the leading fishing port in the United States in terms of volume. The economy of the Aleutians relies on the fishing industry, which accounts for more than 80 percent of private-sector employment. Large commercial vessels engage in the substantial and grow- ing maritime trade between northwestern North America and northern Asia traveling the North Pacific Great Circle Route, which traverses the Aleutian Islands. About 4,500 ships transit Unimak Pass annually, averaging 12 per day, and a similar number travel just south of the Aleutians annually as well. This number represents a significant increase in just the 2 years since the State of Alaska Department of Environmental Conservation published a report on vessel traffic through Unimak Pass, in which it was estimated that 3,100 ships per year passed westbound through the Aleutians. The ship traffic in the region comprises a mix of large containerships, bulk carriers, car carriers, tankers, and others—most of which are foreign-flagged and on innocent passage through these waters. These vessels carry large quantities of fuel oil and various cargoes, including

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144 • Risk of Vessel Accidents and Spills in the Aleutian Islands chemicals and other hazardous materials. A few significant accidents in recent years have heightened public concern about the risks posed by these vessels, especially as traffic has grown in both volume and complexity. Vessel traffic through Unimak Pass is roughly double that calling on all ports in the 17th U.S. Coast Guard (USCG) District (Alaska). Yet vessels entering those major ports are subject to a set of controls, whereas similar vessels traveling on innocent passage through the Aleutians need not meet comparable requirements. Vessel Accidents and Spills Fishing vessels transit the region near Dutch Harbor, while large commercial ship traffic on the North Pacific Great Circle Route is concentrated in and near Unimak Pass, as are the local fishing fleet, tugs and barges, ferries, and other small ships. Farther out in the Aleutian chain, the traffic is more dispersed, but hazards are always present. Since 2005, USCG has been able to track commercial ships transiting Unimak Pass, and these data can be combined with incident/accident reports to determine historical patterns. Historical data on accidents and spills in the Aleutians show that fishing vessels account for the majority of accidents, result- ing mainly in small spills, while the large commercial fleet has experienced only a few major incidents, but involving much larger spill volumes. Over the past two decades, about 20 fishing vessel accidents with spills in excess of 1,000 gallons have been docu- mented, while just two commercial vessel accidents (the M/V Selendang Ayu in 2004 and the M/V Kuroshima in 1997) spilled 336,000 gallons and 40,000 gallons, respectively. These and other accident and spill data are valuable input for the risk assessment process. In addition, data for the past 20 years on response to spills in the Aleutians have shown that almost no oil has been recovered as a result of attempts made by the responsible parties or government agencies and that in many cases weather and other conditions have prevented any response at all. This evidence and other data on the difficulty of recovering oil from the sea in open ocean environments and severe weather conditions lead the com- mittee to conclude that accident and spill prevention should be given high priority when risk reduction options are selected for evaluation.

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Conclusions and Recommendations • 145 Safety Infrastructure and Its Limitations The 1,200-mile-long Aleutian Island chain is remote and sparsely populated, with few sizeable harbors and minimal maritime infra- structure, especially of the kind that can respond to vessels in dis- tress. Together with a harsh climate and other hazards to shipping, these conditions challenge mariners to maintain safe operations. The committee therefore reviewed the current status of safety measures (such as practices on board and in port, regulations, and the use of ves- sel monitoring systems and tracking) and infrastructure in the region to ascertain key areas for improvement that should be considered in assessing risks. Reliable communications are vital to safe shipping. In the Aleutian Islands region, however, reports of radio network gaps that hinder both ship-to-ship and ship-to-shore communications are frequent. Several accident reports cite poor communications as a contributing factor in a chain of events leading to serious problems. As noted, the committee also reviewed the status of vessel monitoring and track- ing systems, which can enhance safe operations in remote areas such as the Aleutians. The advent of automatic identification system (AIS) and long-range tracking technologies has opened up new traffic management opportunities and has the potential to allow active monitoring of the system and early identification of problems. In the Aleutians, the placement of a single AIS station on Scotch Cap at Unimak Pass has produced valuable information and demonstrated this potential. Finally, history has shown that when vessels at sea do experience problems, it is important to have an effective response capability. Tug capability for assisting large vessels in distress does not exist in the Aleutians, and there is no oil spill response organiza- tion (OSRO) in the area; the closest OSROs are in Kodiak and Anchorage. The small harbor tugs stationed in Dutch Harbor are not capable of responding to vessels in distress; they are not rescue- capable. Dutch Harbor authorities have prepared emergency towing packages that can be deployed when needed. While this Emer- gency Towing System (ETS) represents an important step forward in improving shipping safety in Dutch Harbor, its coverage is pri- marily local, and other areas in the Aleutians remain vulnerable. Furthermore, the ETS is not adequate to respond to large commercial vessels in distress outside of the harbor.

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146 • Risk of Vessel Accidents and Spills in the Aleutian Islands RECOMMENDATIONS Risk Assessment Framework The committee developed a risk assessment framework for analyzing the commercial shipping system in the Aleutian region, both in its current state and projected into the future, with respect to accidents and spills resulting in harm to people and the environment. The proposed framework can be used to evaluate hazards, identify current levels of risk, investigate risk reduction measures, analyze the costs and benefits of those measures, and justify safety improvements to the system. The committee recommends that a structured risk assessment be performed with two major phases—a Phase A Preliminary Risk Assessment and a Phase B Focused Risk Assessment. This process would include a specific, stepped approach to collecting and catego- rizing available data; development of a logical sequence of events defining key scenarios; and use of a risk matrix for an initial qualitative evaluation of risk levels. The Phase A Preliminary Risk Assessment should begin with semiquantitative studies aimed at traffic characterization and pro- jections and spill estimates, and identification of the highest risks. This information should then be used for a qualitative assessment and prioritization of risk reduction options. The Phase B Focused Risk Assessment should entail detailed, in-depth assessments of individual risk reduction options in order of priority. The time and resources dedicated to Phase A should be limited to ensure that it is completed in a timely manner and that sufficient resources have been reserved for Phase B. Phase B should be accomplished in discrete steps as necessary in accordance with the priority of measures to be investigated and the level of risk reduction possible. The committee believes that this frame- work would enable risks to be evaluated effectively and efficiently within the resources available. It would also allow for explicit and comparative evaluations of risk reduction measures using more analytical techniques, such as modeling and cost–benefit studies, when warranted. The committee also recommends that the risk assessment include a quantitative fate and effect consequence analysis to yield an under- standing of the damage to natural resources and socioeconomic

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Conclusions and Recommendations • 147 impacts associated with different hazards, sizes of spills, and accident locations. The committee believes that a preliminary consequence analysis should be conducted in Phase A and a more detailed analysis, including biological impacts, in Phase B. Organization of the Risk Assessment Study An effective study organization is vital to the success of a risk assess- ment. The committee reviewed various risk assessment approaches and techniques, including those employed in recent marine risk assessments, that are relevant to the problem at hand. This experience points to the importance of certain elements: the problem should be clearly defined, and a contractor should be provided with the specific scope of the study and explicit goals; a peer review group should be given responsibility for reviewing and commenting on the study methodology and the handling of uncertainties; and a stakeholder group should be included in framing the issues, identifying local expert knowledge, suggesting risk reduction measures, and reviewing final results. The committee recommends that the risk assessment be organized and managed by a team consisting of USCG, its designated fund management organization (the National Fish and Wildlife Founda- tion), and the State of Alaska. The Management Team should provide oversight of the contractor(s) conducting the risk assessment. The committee recommends that the Management Team appoint a Risk Assessment Advisory Panel with a facilitator and members consisting of experts and key parties with an interest in furthering the goals of the risk assessment. Recognizing the importance of stakeholder involvement to the success of the risk assessment, the committee suggests that the Advisory Panel represent all major Aleutian Islands stakeholders, who would provide relevant local knowledge and expertise to the contractors. The panel should review and comment on the framing of the study and its conduct at key stages and help identify and provide input on the risk reduction measures to be evaluated. The committee also recommends that the Management Team appoint a Risk Assessment Peer Review Panel with a facilitator and members consisting of experts in the techniques and method- ologies of risk assessment to ensure that the study will be conducted with sufficient attention to completeness, accuracy, rigor, and

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148 • Risk of Vessel Accidents and Spills in the Aleutian Islands transparency. This panel would also help identify and consider the consequences of uncertainties. Finally, the committee’s charge was to develop the framework for a risk assessment. The committee believes that ongoing risk man- agement is a critical part of the risk assessment process. Thus, the framework proposed in this report is structured to ensure effective implementation of the most cost-effective risk reduction measures by establishing Phase B as a detailed risk management project. Interim Actions to Enhance the Assessment During its review of existing data, the definition of the problem, and the current state of safety in the system, the committee identified interim actions that would help ensure a successful risk assessment, in particular by providing data to build a better foundation for the assessment process. The committee is also aware of the urgency of taking actions to improve the safety of shipping operations in the Aleutian Islands. Accordingly, the committee recommends that USCG take appro- priate action to expand the AIS tracking network along the Aleutian chain and covering the southern North Pacific Great Circle Route. The process for taking this action is already in place, and USCG has the authority to proceed as funding is made available. It would be valuable to implement these systems and to make available the data they yield as soon as possible so the complete traffic system can be described and analyzed with confidence as part of the risk assess- ment. Collection of additional AIS data should not delay this risk assessment. If it is not possible to install additional receivers and collect sufficient data to contribute to the study, the augmentation of the AIS system should be given careful consideration when the Phase A study results become available. When long-range identifica- tion and tracking data become available, USCG should take steps to utilize these data to further improve vessel tracking in and around the Aleutian chain. Having an adequate rescue tug capability in the region has been identified in the past as a risk reduction option with obvious benefits for responding to large commercial vessels in distress. This capabil- ity has been established in other locations where the potential for maritime accidents exists, and local stakeholders in the Aleutians have advocated this solution for many years. The committee has

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Conclusions and Recommendations • 149 not evaluated the costs and benefits of this option, and such an evaluation could not begin without more information about costs and possible financing mechanisms. Therefore, should the Phase A assessment conclude that rescue tugs have potential risk reduction benefits, the committee recommends that USCG and the State of Alaska be ready and available to investigate funding levels, sources, and mechanisms for an Aleutian Rescue Tug, with the expectation that the Risk Assessment Management Team and Advisory Panel might request this information for early consideration within the risk assessment process. The committee further recommends that USCG be ready and available to investigate the possible structure and costs of a Vessel Traffic Information System within and near Unimak Pass and Dutch Harbor, with the expectation that the Risk Assessment Manage- ment Team and Advisory Panel might request the information thus generated early in the risk assessment process. This action would facilitate the risk assessment and provide needed data for cost–benefit analyses of selected options. Subject to the findings of the Phase A Preliminary Risk Assess- ment, the committee also recommends early consideration of options for tracking and monitoring vessel traffic in certain congested areas, as well as for employing some common traffic management schemes that have shown merit in similar locations worldwide. Implementing voluntary vessel traffic systems, establishing traffic lanes, and identifying particularly sensitive sea areas or areas to be avoided are among the measures that USCG could pursue without new authority. Some of these measures might require International Maritime Organization consideration, while others might be adopted unilaterally. FINAL THOUGHTS Despite the complexity of the system and the open-ended nature of the problem, the committee is confident that a rigorous and comprehensive risk assessment of shipping in the Aleutian Islands can be conducted within the available resources and that needed safety improvements can be justified in the process. The committee also understands that, while certain historical and time-series data are limited, they can be enhanced and supplemented by relevant

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150 • Risk of Vessel Accidents and Spills in the Aleutian Islands worldwide data and local expertise and judgment. This report pre- sents a framework for conducting such a risk assessment, explaining the underlying principles and offering guidelines for applying both qualitative and quantitative techniques where appropriate. Finally, throughout this report, the committee emphasizes principles that are key to ensuring a successful outcome. These include keeping the work focused on a clear definition of boundaries and scope, design- ing the assessment process to incorporate continuous involvement of local stakeholders, and applying a phased approach to set priorities for early action and allocate resources efficiently.