What is ship to ship oil transfer?

In the context of this paper ship to ship oil transfer is the transferring of a cargo of oil between vessels in the open sea and not in a port or harbour. The need for ship to ship transfer arises because some modern tankers are so large that they are unable to enter some ports.  If a cargo of oil is intended for a port which the large ocean going tanker cannot enter, then the oil will need to be transferred to smaller tankers to take it into harbour. Similarly if the exporting port cannot accommodate deep hulled tankers then they may  wish to export the oil from the port in small tankers, then transfer it to the larger vessel for the rest of its journey.

Background

From the 1960's ship to ship transfer took place on an ad hoc basis in suitable locations all around the coast of Britain. Lyme Bay was one such location due to its proximity to the main shipping lanes, and the availability of shelter in the western half of the bay. These transfers were for imports/exports to and from the UK

Following the 1993 Braer disaster off Shetland, the Lord Donaldson's inquiry made a series of recommendations concerning the safe transport of oil around the UK. Amongst these recommendations, it was proposed that ship to ship transfer of oil be restricted to two areas off the English coast, Lyme Bay and Southwold, off East Anglia.

However, the ship to ship transfer operations in Lyme Bay, were only given a semi-formal status in 1998, when the UK Maritime and Coastguard Agency published draft Regulations to control activity in the area. To date these draft regulations have yet to be implemented, as the government are waiting for the publication of the final report identifying Marine Environmental High Risk Areas (MEHRAs) before proceeding. (There was an initial report in 1999 identifying MEHRAs , but the methodology behind the report was questioned and resulted in the reports withdrawal.)

Between 1999 and 2003 operations in this area have involved either the emergency transfers of cargo (such as that salvaged from the Iveoli Sun) or one to two commercial transfers per year between a small numbers of vessels. In the latter cases it was the transfer of mainly non-persistent cargoes such as jet-fuel and kerosene from large ocean going tankers to smaller vessel, which then took their cargoes into European Ports.

The Baltic oil trade

In 2003 the situation changed with a different form of ship to ship transfer operations taking place. These transfers were at a higher intensity to those that have taken place previously and the cargo was different (a heavy Group 4 oil) . However, the principle difference was that the operations involved a 'mother-ship' large tanker (single or double hulled) which is loaded from smaller, single hulled, tankers.  During the operation up to seven small tankers which originate from the Baltic (northern Europe) come alongside and load the mother-ship over a period of around 10 days.  Once loaded the mother-ship departs for the Far East. Four groups of ship to ship operations of this type took place during 2003. In total these four groups involved a total of 20 transfers which in turn involved 24 vessels (information from Dorset County Council, Emergency Planning). Not only were these transfers a fundamental change to the type and frequency they are essentially nothing to do with the UK economy, as they involve only transshipment and are neither import or export to the UK and they also avoid any port charges.

Draft regulations and controls

Currently, transfers are regulated by the Maritime & Coastguard Agency (MCA) under their 'Quality assurance' system, which involves an assessment being made, by the MCA, of a range of factors, relating to the vessel, type of cargo and sea conditions. For each transfer an emergency plan is prepared.

Formal control of ship to ship transfers should be regulated by the 'Merchant Shipping (Ship-to-Ship Transfers) Regulations 1999', however, after some 5 years of delay, they still remain in draft form despite considerable pressure at a variety of  levels from both Dorset and Devon County Councils. A new set of draft regulations is being prepared by the Department of Transport and will then be put out for consultation. Devon and Dorset County Councils have made a joint written submission to the MCA detailing their concerns and proposing control measures.

A cause for concern?

The Dorset coastline stretches for over 240 kilometres and is an area of major importance to the county of Dorset in terms of both the natural environment and the support it brings to the local community through recreation and industry. Recent, major oil spills such as the Erika and Prestige have shown the huge impact an oil spill can have on the coast.

Environmental Issues

International, European and national environmental designations are abundant along the Dorset and Devon Coastline.  These include World Heritage Site, RAMSAR, National Nature Reserves, Areas of Outstanding Natural Beauty, Sites of Special Scientific Interest, Special Areas of Conservation and Special Protection Areas. There are also vulnerable reef habitats especially in Lyme Bay which are sensitive to pollution where recovery would either be impossible or extremely lengthy.

Local Economic Issues

Local economy relies on fishing, tourism, and those businesses on the coast and in the hinterland.  Oil spill mapping, by Dorset County Council, Emergency Planning, has shown that  Lyme Bay as far as the east of Portland could be contaminated within a short space of time if a large oil spill occurs in virtually any weather conditions.

Fishing

Fishing is of major local economic importance to the Dorset area. The fishery is also of national significance, with 25% of the UK's brown crab catch being landed in the area (information from Southern Sea Fisheries). 
Tourism

Tourism

One of the greatest attractions to Dorset for tourists is the coastline.  A major oil spill has the potential to seriously damage tourism within both counties, through the impact of a polluted beaches and the requirement to move large quantities of oiled waste to disposal. In Dorset, approximately 45,000 people are directly or indirectly employed in tourism, with some #994m income to the county (information from South West Tourism). The controls which the local authorities would have to implement would result in the closure of beaches and possibly routes to disposal sites, as well as bans on commercial and recreational fishing.

The Future

It is unlikely that concern as to the safety of ship to ship transfers will abate, particularly on the part of the coastal local authorities led by Dorset and Devon County Councils.

There are several plans and proposals, currently under discussion, that could affect the future of ship to ship transfers in Lyme Bay.

Marine Environmental High Risk Areas

The Marine Environmental High Risk Area (MEHRA) final report remains outstanding. No new date for publication has been made.

Ship-to-Ship Transfers Regulations

The revised regulations for ship to ship transfer are due to be published in May 2005 for consultation.

Particularly Sensitive Sea Areas (PSSA)

These are areas that needs special protection through action the International Maritime Organisation (IMO) because of their significance for ecological, socio-economic or scientific reasons and which may be vulnerable to damage by international maritime activities.

The 'Western European Waters', (an area of north western European waters stretching from the Shetland Isles to Portugal), were designated as a PSSA in October 2004. 

This can enable controls to be imposed on many types of maritime activity within the PSSA, including the transport of oil.