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HomeMy WebLinkAbout02132017 City Council Laydowns 471fit Birch Horton Bittner & Cherot a professional corporation William A.Earnhart Respond to Anchorage Office T 907.263.7285 • F 907.276.3680 weamhart@bhb.com February 9, 2017 Mayor and Members of the City Council City of Seward P. O. Box 167 Seward, AK 99664 RE: City Attorney Report for the Period January 7, 2017, through February 10, 2017 Dear Mayor and City Council: The following summarizes our activities as City Attorney during the period January 7, 2017, through February 10, 2017: 1. General Matters: The City Attorney's office provided advice and worked on various matters regarding records retention, contracts, resolutions, public process, contracting, and drafted letters related to bond financing. We also advised in regard to several personnel law issues. 2. Litigation: In the Orion litigation, costs and fees of just under $19,000.00 have been awarded to Seward and we prevailed against Orion's Motion for Reconsideration. Orion has appealed the judgment and is unwilling to discuss settlement, even at a court-ordered conference. Orion has posted a bond for the outstanding judgment and had until February 13 to file its brief on appeal, but requested an automatic extension. The brief is now due on February 27, 2017. 3. Electric Utility: We continue advising and participating in negotiations to protect the City's interests regarding the Bradley Lake agreements. There are some upcoming deadlines that will hopefully bring this matter to a conclusion. Please contact me if you have any questions or desire further information on any of the matters discussed above. Sincerely, BIRCH HORTON BITTNER & CHEROT William A. Earnhart WAE:alk cc: Jim Hunt, City Manager 1127 West Seventh Ave.,Anchorage,AK 99501-3301 1156 15th St NW,Ste. 1020,Washington, DC 20005-1754 T 907.276.1550•800.478.1550•F 907.276 3680 T 202.659.5800•F 202.659.1027 50748611002\00586390 Emergent Needs of the Current Animal Shelter February 13, 2017 Priority List# 1 1. Desperate need for the outside kennels to be repaired. The current 2 kennels are collapsing,the latches are broken, and the bottom of each kennel is torn with loose wiring presenting as a huge injury risk for the animals. As well, every huge wind gust knocks them off their concrete foundation. Very dangerous situation for the animals and the staff as well as any visitors in the courtyard. 2. Desperate need for outside electrical outlets x2 to replace current frozen water bowls with heated bowls and to allow a heater to be placed in the " OutHouse ", Shelli's current bathroom. 3. Desperate need for a small indoor/outdoor run so that larger animals do not have to sleep out in the freezing cold during winter and will not be exposed to the flooding on the concrete floor that occurs whenever there is a heavy snow or heavy rain. Flooding also occurs inside the building when 2 small drainage ditches outside are frequently clogged. 4. Desperate need for fixing the door to the front gate and the doors to kennel L where the edges of the doors meet the ground. In winter the doors freeze to the ground and they must be chiseled and chipped until they can swing freely. This is a huge fire hazard and a general safety hazard as it takes a long time to open those doors and animals are then "stuck". Also, a quick entry into the shelter itself is hampered by the frozen gate door. Priority List # 2 1. Inside concrete floors need to be repainted and sealed as the concrete is cracking poising a dangerous situation for animals and staff from an unstable floor. 2. Outside fencing needs replacing since snow load has bent the wiring. 3. Indoor plumbing frequently leaks hot water and needs replacing. Currently the plumbing has been "patched" but has required "patching" multiple times to date. 4. Having an indoor bathroom for Shelli and her staff would be a tremendous gift to her and would be more hygienically appropriate. Thank you in advance for all your compassion and commitment to this project. I will be more than happy to assist in any way that I can. Lila Hurst 941-323-7621 ii. •••:. ' 4'.4--'4 i• . "i' I' • .t•.-.;:l..."14,','.. • - , Li 1 '•-',. '4i • ,t` ; #! . . ; -4'. .• ....'',A ' • ..',;" ---'•..t.1 ',t ',-.- ."' , . •l ..i1V.% .V, • , . • . 'L'''': „'.,4*17' .':'t.'I .',-. ' : ,., - . '•"',,'li ill , •• • * ` 4 ‘• . ... . , I 1., .4,.. . ,. , • . , • ... .,7tv•.... ., ,,,i, i • .. 1 44.,"' -!' ("sty.. , . .,, ,,, •,,,,it ,,,• .: ,, ' '. -0', • ••111100 •...:,..• , ,,... ..•, .. "•,:k• -- „, • • ••i' '' . 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Z`V.,,,, :,•• • ' Seward 50th Anniversary Idea List(ENG) 2018 SEWARD Idea Reason Pros Cons Timing Other If planned during the right time,Obihiro •Can get expensive quickly visitors can see the northern lights when checking out UAF,which gives a special 'Explore different parts of Alaska •More Transportation=more time,money,September?Before it gets too Fairbanks/Seward Tour •Attractive experience(northern endurance discounted tuition rate to students from a cold,but able to see the lights lights) •50th Anniversary should be mainly about sister-city of an Alaskan city.This can be Seward combined with other ideas. - •If someone wins,tax nightmare Silver Salmon Derby Participation Been sending trophies for years,so why not •Experience a very"Seward"event •Safety concerns If anything happens out Late August try it out? •Try fishing outside of Japan at sea •Obtaining permits etc.ahead of time •Simple •Is it enough for the 50th anniversary? Maintain the symbols of our friendship,which •Gives opportunity for those who .Are people willing to go all the way to Summer Mural/Obihiro Park Clean up are already in place. were involved in the planning to Seward to dean up? actually see/feel the piece 'Simple •Is it enough for the 50th anniversary? Sports Event(Softball?) Have a simple friendly game. Summer Could plan alternative activities for Try something a truly"Seward"activity,not •Attractive to the inland people of •Safety concerns Fishing CharterSummer/Fall(Fishing seasons?) those who want to go to Seward,but • during the derby. Obihiro Costly? aren't quite ready to go to sea. •Can serve as PR for the sister-cities •Very weather-dependant Community Parade Great way to get the entire community involved! activities •Need to dose down roads(not sure of all Summer •Many can get involved of the work that goes into that) •Enough for 50th?(Can be combined with Karaoke Party ••Simple and fool other activities) OBIHIRO Idea What Reason Pros Cons liming Other This marathon doesn't get quite the Hokkaido's last(half)marathon of the season. number of international participants as The city runs most of this event.Gets a lot of more major and serious races,but the •Good PR •Have to find runners Food Valley Marathon PR because it's the last race and since it whole town is aware of it.Seward •Comfortable time to visit(cool,leaves •Hotels might be hard to End of Oct/early Nov happens around Halloween,a lot of runners runners can visit and run with the changing) reserve dress up for the race. locals. Obihiro has the only sled-pulling horse track in •Good PR •Team of 5 needed to pull the the world.Every year,the local chamber of Very unique activity to Obihiro.One of •Very very unique event sled(+1 woman to ride the sled) End of September Banei Horse Track"Ningen Banba" commerce holds a weekend of races where our domestic sister<ities(Matsuzaki •Many other activities surrounding the •Finding people who want to instead of horses a group of humans pull the 1 Town)sends a team every year as well. coot pull a 1 ton sled... ton sled) - Obihiro's largest festival of the year.The Suggestion:Make custom exchange students have participated every The entire city Is out and about for the •Super fun time •Hot sister-city happi coats event.The weekend also includes theand light"coat" Summer Heigen Festival year when they visit(this is when the golden •Great chance to experience Japanese •Need to figure out timing Mid-August (loose g Karhimai Firework show,one of the that are traditionally pan is given out).Have adults experience the most famous in all of Japan. culture with the high schoolers high schoolers'trip) worn during festivals) No big race or competition to worry •Not as much exposure as the It's been a while since we had adult visitors,so •Can cater to the visitor(s)'s wants Just visit! about.Can plan around each other' s events it might Just be nice to have a group come! schedules. •Can avoid the busier times of the year } wt LLrAM G SO Q4s# RCAC Regional Citizens'Advisory Council /"Citizens promoting environmentally safe operation of the Alyeska terminal and associated tankers." In Anchorage: 3709 Spenard Road/Suite 100/Anchorage,Alaska 99503/(907) 277-7222/FAX (907) 277-4523 In Valdez: P.O. Box 3089/ 130 South Meals/Suite 202/Valdez, Alaska 99686/(907) 834-5000/FAX (907) 835-5926 MEMBERS November 15, 2016 Alaska State Clare Pavia (on behalf of the ARRT) Chamber of Commerce Alaska Department of Environmental Conservation Division of Spill Prevention and Response Chugach Alaska P.O. Box 111800 Corporation Juneau, AK 99811-1800 City of Cordova dec.cpr@alaska.gov City of Homer Re: Notice of Public Scoping for Possible Updates to State of Alaska Regional Master Prevention and Contingency Plan Boundary Regulations City of Kodiak Dear Ms. Pavia: City of Seldovia Enclosed please find comments on the proposal by the Alaska Department of City of Seward Environmental Conservation (ADEC), U.S. Environmental Protection Agency (EPA), and U.S. Coast Guard (USCG), on behalf of the Alaska Regional Response City of Valdez Team (ARRT), to change the current Alaska Federal/State Preparedness Plan for Response to Oil & Hazardous Substance Discharges/Releases ("Unified City of Whittier Plan") and associated 10 Subarea Contingency Plans. Community of As you may be aware, the Prince William Sound Regional Citizens' Advisory Chenega Bay Council (PWSRCAC) is an independent, non-profit corporate whose mission is to promote environmentally safe operation of the Valdez Marine Terminal and Community of associated tankers. Our work is guided by the Oil Pollution Act of 1990 and Tatitlek our contract with Alyeska Pipeline Service Company. PWSRCAC's 18 member Cordova District organizations are communities in the region affected by the 1989 Exxon Valdez Fishermen United oil spill, as well as commercial fishing, aquaculture, Native, recreation, tourism and environmental groups. Kenai Peninsula Borough These comments are submitted in response to the ARRT's proposal to replace the Unified Plan and associated 10 Subarea Contingency Plans with a Regional Kodiak Island Contingency Plan and four Area Contingency Plans for Alaska. This change Borough will purportedly align Alaska with the National Contingency Plan and National Kodiak Village Mayors Response Framework. While PWSRCAC generally supports bringing Alaska Association closer in line with the rest of the country, these comments outline some of our concerns with respect to the approach proposed. Oil Spill Region Environmental Coalition Enclosed are detailed comments, questions, and recommendations on the ARRT proposal. In summary, PWSRCAC recommends the following: Port Graham Corporation • ARRT conduct outreach to impacted communities prior to combining Subareas into Areas; Prince William Sound Aquaculture Corporation 600.105.161115.ADECareaboundry 4. • A matrix showing where existing information will be transferred into the new plans; • Additional details be provided on the structure and function of the Area Committee; and • Information describing implementation and schedule for the proposed changes. Thank you for the opportunity to provide input on this proposal, and we appreciate your consideration of the enclosed comments. Please contact me if you have any questions at (907) 834-5070. Sincerely, Donna Schantz Executive Director Cc: decsnarplanning@alaska.gov CDR Lally, USCG Mark Everett, ARRT co-chair Chris Field, ARRT co-chair Kristin Ryan, ADEC representative Scott Hicks, Alyeska Pipeline Service Company Steve Russell, ADEC 600.105.161115.ADECareaboundry s flr RCAC Regional Citizens'Advisory Council Prince William Sound Regional Citizens' Advisory Council Comments on the Alaska Regional Response Team's (ARRT) Proposal to Change Area Planning Boundaries and Approach November 15, 2016 Background Prince William Sound Regional Citizens' Advisory Council (PWSRCAC) has prepared this document in response to a public notice by the Alaska Department of Environmental Conservation (ADEC), Environmental Protection Agency (EPA) and United States Coast Guard (USCG), on behalf of the Alaska Regional Response Team (ARRT), requesting comments on an initiative to change Alaska's Unified and Subarea Plans. The ARRT proposes to replace the current system (Alaska Federal/State Preparedness Plan for Response to Oil &Hazardous Substance Discharges/Releases "Unified Plan" and 10 Subarea Contingency Plans) with a statewide Alaska Regional Contingency Plan supplemented with four Area Contingency Plans. In cases where this change from Subarea to Area designation causes Subareas to be combined (which is the case for all but the Southeast and Prince William Sound Subareas), information from the Subarea Contingency Plans will be retained in Geographic Annexes. The rationale provided for this change is to bring Alaska more in line with the National Contingency Plan and the National Response Framework using the Regional Contingency Plan/Area Contingency Plan approach in the Lower 48. The four proposed Areas align with the USCG's Captain of the Port (COTP) zones, with the exception that the Western Alaska COTP zone currently includes the Arctic; the proposed four-area system would separate Western Alaska from the Arctic. The proposed new Western Alaska Area Plan boundaries would encompass the existing Subareas of Cook Inlet, Kodiak, Bristol Bay, Aleutian Islands, and Western Alaska. The Arctic Area Plan boundaries would encompass the existing Subareas of North Slope, Northwest Arctic, and Interior Alaska. PWSRCAC Perspective PWSRCAC's member entities include communities and stakeholders from the Exxon Valdez oil spill impacted region, which encompasses the Prince William Sound, Cook Inlet, and Kodiak Subareas. We have taken an active role in the development and periodic updates of the Prince William Sound and Kodiak Subarea Contingency Plans, and we have provided funding and staff time to support the development of Geographic Response Strategies in our region. While Cook Inlet Regional Citizens Advisory Council (CIRCAC) is the lead on the Cook Inlet Subarea Plan, we have also contributed to the Cook Inlet Subarea Contingency Plan. 600.431.161115.ARRTareaboundry 1 • PWSRCAC's comments on the proposed changes are informed by,our long history of involvement with the Subarea Committees and Plans, supplementedby research into how Regional Response Teams, Area Committees, and planning are accomplished in other regions of the U.S. We are broadly supportive of the stated intent of ADEC, USCG, and EPA to modify Alaska's system so that it is consistent with the Lower 48 while also aiming to reduce the administrative burden to federal and state agency staff associated with maintaining and updating plans. However, we still have some uncertainty about how this proposed approach will achieve those goals, and offer our analysis in hopes that it will provide assistance in clarifying the proposed approach and intended outcomes. Discussion Background The National Response Framework (NRF) describes the doctrine under which the Nation responds to all types of emergency incidents. It is built on scalable, flexible, and adaptable concepts identified in the National Incident Management System(NIMS) to align key roles and responsibilities across the Nation. The NRF broadly designates the USCG and EPA authorities to direct oil spill and hazardous material spill response, and designates EPA as the Emergency Support Function (ESF) coordinator for oil and hazardous materials spills which includes coordination of planning. However, the NRF is broadly focused on Stafford Act disasters, and acknowledges that incidents that fall outside of the Stafford Act (as most oil spills do)would be addressed under other response planning doctrines that are consistent with the NRF. The National Contingency Plan designates 13 regions for oil spill planning purposes; 10 are the same as the federal regions for the Lower 48, plus the Alaska, Caribbean, and Oceania (Pacific Basin) regions. Each region has a Regional Response Team (RRT), which has responsibilities both as a standing body and as an incident-specific team. As a standing body, they are responsible for planning and coordination of regional preparedness and response actions. The RRTs in most regions promulgate a Regional Contingency Plan, which is then supplemented by Area Contingency Plans (ACP). Area contingency planning boundaries for marine spills generally correspond to USCG Captain of the Port (COTP) zone boundaries. The EPA Administrator designates Inland Area Contingency Plan boundaries. Area Contingency Plans are meant to be multi-jurisdictional plans and are typically promulgated by the Federal and State On-Scene Coordinators through an inter-governmental Area Committee. There is no one consistent template for ACPs across the U.S., although many follow the same general organization and numbering system. The USCG has published a lob aid for development of coastal ACPs, and the EPA has issued guidance on inland ACP development. Analysis of Approaches in Lower 48 PWSRCAC reviewed several examples of Area Contingency Plans within the other 12 RRT regions as available through the National Response Team (NRT) website. We found that there is some variability across regions in how Area Contingency Plans are developed, and observed the following: 600.431.161115.ARRTareaboundry 2 4. • Within most regions that include both coastal and inland zones, a single Inland Area Contingency Plan applies to the entire region,but there are usually multiple coastal ACPs (aligned with COTP zones). However, there are exceptions, such as: o A single Area Contingency Plan (Northwest ACP) covers the entirety of Region X (WA, OR, ID) for both inland and coastal spills. o In Region II (NY, NJ), a single ACP applies to both inland and coastal spills. o In Region V (MN, WI, MI, IL, IA, OH), a joint ACP/RCP (similar to the Alaska Unified Plan) is in place for the Inland Zone, with a separate Great Lakes ACP that applies to the entire 9th Coast Guard District (multiple Sectors). • Subarea plans are not the norm, but they do exist in the Lower 48. For example, o In Region III (MD, DE, VA, WV), the Inland ACP is supplemented by nine Subarea Inland ACPs. o Region V (MN, WI, MI, IL, IA, OH) has seven Subarea plans under the umbrella of a joint RCP/inland ACP and 9th District coastal ACP. • Most - but not all - ACPs follow the National Contingency Plan template. ACPs that do not follow the NCP include: o California State ACP (Region IX) does not follow the NCP format,but the three coastal ACPs (San Diego, San Francisco, Long Beach) do. o Region V combined RCP/ACP does not follow the NCP format. • The Western Alaska COTP zone is significantly larger than any other COTP zone in the Lower 48 and therefore an ACP that is based on that zone would cover an area that is significantly larger (and different in many ways) than any other ACP boundary in the U.S. The map below shows the COTP boundaries for U.S. territories in North America.' Irk imairpipedisti — + 14111:111110 Esri, HERE,DeLortit,Mapmy'-d,a,©OpenStreetMapco-t-outo's, r ;i ISuse-cc, u,_ t•, 1 Source:Homeland Infrastructure Foundation-Level Data. https://hifld-dhs- gii.opendata.arcgis.com/datasets/bOaf5c5Oadd04cf282blfec9e176e681 0 600.431.161115.ARRTareaboundry 3 PWSRCAC Comments PWSRCAC agrees that harmonizing Area Contingency Plans across the U.S. makes sense, but we also note that there is not a single consistent standard in the Lower 48, and that owing to the variability across our large country, it is important to balance the need for uniformity with a consideration for the unique geography, population, natural resources, infrastructure, and logistics across planning regions. Changes to the organization of Alaska's plans will necessitate changes to state regulations, and may have unforeseen consequences to local and regional governments, Native organizations, industry, and stakeholder groups. Before the Alaska model is significantly modified and the contents of our present Unified Plan and Subarea Plans are reshuffled into an RCP/ACP model, we ask that the ARRT consider the following factors in evaluating how and whether to deviate from the current system. 1. Aggregating Subareas Moving from 10 Subarea Contingency Plans (SCPs) to a Regional Plan and four ACPs will obviously create an opportunity to take information that is repeated across all 10 SCPs and consolidate it so that it appears in four rather than 10 places. This could reduce the overall number of pages across the statewide plans, but PWSRCAC cannot envision exactly how this will look. Presumably, most of the information in the Unified Plan will be carried into the RCP,but some of it may also belong in the four ACPs, which would cause information that is now in one place to eventually show up in five places. Subarea planning is not the norm in the Lower 48, but there are at least two regions (Regions III and V)where Subarea Contingency Plans are in place. Therefore, there are precedents for including this additional sub-level of planning for a variety of reasons. Size and Scope of Western Alaska ACP The Western Alaska COTP zone is an order of magnitude larger than any other COTP zone in the Lower 48. While in theory aggregating the eight Subareas that now exist into two Areas (Western Alaska and Arctic)will bring Alaska closer to the Lower 48 approach, in reality, the ACPs for these proposed regions will be substantially larger than any other ACP region in the Lower 48. The proposed Western Alaska ACP will combine five SCPs (Cook Inlet, Kodiak, Bristol Bay, Aleutians, Western Alaska) into a single ACP, with five Subarea Geographic Annexes that incorporate sub-regional information that was previously part of the Subarea Plans. This collapses five plans into one, but then it adds five substantial annexes to one plan. From a plan update and administration standpoint, it is not entirely clear whether this will create more or less work. In the short run, the task seems daunting. Given that the SCPs are typically in the 300-page range, the sheer size of the Western Alaska ACP and annexes could exceed 1,500 or even 2,000 pages. PWSRCAC believes that it is important to consider all of the possible implications of creating an ACP this large before making this significant change. We would be interested in seeing some additional analysis that considers how the proposed changes would impact On Scene Coordinators (OSCs) and agency workloads in the short and long term. We would also encourage the ARRT to seek feedback directly from potentially impacted communities and stakeholder groups in the regions where 600.431.161115.ARRTareaboundry 4 Subareas would be combined into larger ACPs, to ensure that they understand the proposal and that their priorities and concerns are addressed. Absorbing Cook Inlet and Kodiak SCPs into Western Alaska ACP PWSRCAC has member representatives from within the Prince William Sound, Cook Inlet, and Kodiak Subareas. Therefore, even though the boundaries for the proposed Prince William Sound Area align with the existing Subarea, aggregating the Cook Inlet and Kodiak SCPs into a single Western Alaska ACP does impact PWSRCAC and our member entities. Even though CIRCAC remains the lead on planning in Cook Inlet, PWSRCAC would expect to retain our current level of involvement with the Kodiak and Cook Inlet SCPs in the context of the new Western Alaska ACP, since we continue to have an interest in spill planning and preparedness in those regions The proposed Western Alaska ACP will cover a massive area spanning a significant part of Alaska, which includes diverse and widespread communities. This may make the process of bringing communities to the table to participate in planning and preparedness activities more cumbersome because of travel expense and logistics to travel within communities in the expanded Western Alaska ACP region. While teleconferencing and webinars provide a solution, this technology is not always reliable. PWSRCAC is concerned that the change to fewer Area Committees may dilute opportunities for meaningful community participation in the oil spill planning process. Additionally, the area surrounding Cook Inlet and Kodiak Island, including Resurrection Bay and the Kenai Fjords National Park, is distinct from the rest of the proposed Western Alaska area in terms of oceanographic characteristics, vessel traffic, oil spill risk, and stakeholder involvement through both the Cook Inlet and Prince William Sound Regional Citizens Advisory Councils. Oil spill contingency planning and response administration for the Cook Inlet and Kodiak Island area for this reason warrants consideration distinct from that for the rest of the Western Alaska area. PWSRCAC encourages a dialogue with the OSCs to consider whether there might be other ways to divide up the state that make more sense from the perspective of response capacity, spill risks, oceanography, Alaska Native concerns, or other considerations. It appears from "Frequently Asked Questions" on ADEC's website that Subarea Committees that previously were only active every five years during plan updates would be replaced by Area Committees expected to be "standing bodies with dedicated membership." PWSRCAC would like more information about the vision for Area Committee membership, meeting schedules, and the types of issues that this standing body would address on an ongoing basis. We are generally supporting of the idea of having standing bodies that focus on oil spill planning, like Local Emergency Planning Committees (LEPCs) do for other types of emergencies, but are also cognizant that the administration of a standing body and organization, conducting more frequent meetings, and updating ACPs more frequently could also create a substantial additional workload. 2. Reformatting the Alaska plans PWSRCAC reviewed a number of ACPs that follow the "standard" NCP approach, which we consider to be the numbering system and organization that is used, for example, in the Northwest ACP. This format is comprehensive and logical, but it is also different 600.431.161115.ARRTareaboundry 5 in some respects from the way information is organized in the existing SCPs, and it is important to PWSRCAC to understand clearly how and where information will be transferred from one format to the other, to ensure that no information is lost in the process. For example, we are unclear as to how information presently in the five SCPs that will become the Western Alaska ACP will be allocated between the ACP and the Subarea Annexes. Conversely, for regions like Prince William Sound where the Subarea boundaries and Area boundaries are essentially unchanged, how would the site- specific information that is appended to the Western Alaska ACP be incorporated into the body of the Prince William Sound ACP? Ensuring no net loss of information from current SCPs PWSRCAC noted with interest the matrix that was presented at the September 2016 Nome ARRT meeting presentation on the proposed changes (excerpted below). This matrix provides a crossroads that indicates how the OSCs intend to relocate information that currently exists in the Unified Plans and SCPs into the new RCP/ACP format. PWSRCAC has requested an opportunity to review this information in more detail, as it will help our understanding of the proposed reformatting and track which information will reside in which plan. We hope that this type of more detailed analysis will be provided as it becomes available. PWSRCAC also has questions about whether the ACPs will follow the USCG or EPA guidance for Area Planning, or whether the plan is to combine the two approaches. Padova w.. +- ar.. uao. n-d..p SUFr.legation-drop dem Currenti.tiwal/ Iasi-" Seam.1....W .-drop Mara Mal Man Hes N,..anrn..M! IPA of r..wwoMW Tom.le /«.tier lr.a/G.. 1....rn r.e.nr00.nJ.J..arn.by USCG _......Iwo.by USCG -. .-- ..error.by USCG APP..*me tis.Ala...r.ri. Com u. msomaad pp.rla t.eweerlwrrAllrale.e+.r..aro.tunur ad...or ...w O-lytinpelaon pMµdr OJMF6 ...pawl I:.oloat4psdc14a aleJy.aslinrl.r.lamts o S u. beb..J --_ —------_..-- n .'. .gone -- --- _- — -- 41w.I Ironer.,e.w.tion O a..Ismok-iomOk Prone.. Tyro Of beamo aAasr w..n A....pdgw%tie%Mw.foo.lna,Mau 0-11 w H. 000(..a..a w ad S mewl doves upopos Ammo -Mb..rm..Aral HI*. *:-1 US M.. 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The RSC is unique to Alaska; in most other parts of the U.S., there is a Multi-Agency Committee (MAC) that provides primarily for government agencies not directly involved in managing the incident to be connected to the Unified Command. In Alaska, the RSC provides recommendations to the Unified Command on incident priorities and objectives, and conveys information to the Unified Command relating to the authority, concerns, and expertise of its members. PWSRCAC understands through discussions with OSCs that the intent of the ARRT is to maintain the RSC approach and language through the transition to RCP/ACPs. This 600.431.161115.ARRTareaboundry 6 is a high priority to PWSRCAC, and we expect access to information on a response through this process be preserved in the appropriate sections of the new RCP and ACPs. As indicated in our previous comments on this issue, we suggest a collaborative work group approach to address improvements in engaging communities and other stakeholders during oil spill responses. Initial and ongoing information updates PWSRCAC understands that part of the impetus for changing from 10 SCPs to four ACPs is to reduce the administrative burden of maintaining plan contents. PWSRCAC supports the idea that contingency plans - regardless of whether they are ACPs or SCPs - should be regularly reviewed and updated. At present, many of the SCPs contain information that has not been updated in a decade or longer. It would make sense to use this reorganization process as an opportunity to vet and update the contents of the SCPs before they are carried into the ACPs; however, PWSRCAC is concerned that the timelines established for this process may not allow for substantive evaluation of the quality of information in the SCPs before they are carried into the ACPs and geographical annexes. This is less of a concern in Prince William Sound, where our SCP was recently updated, but for other regions - such as Kodiak - there are sections of the SCP that have not been updated for several years. Examples of areas where Kodiak and other SCPs may contain outdated or inaccurate information include the hazardous materials/chemical inventories in Part C of the SCPs, and much of the information in the Sensitive Areas Sections (Part D). The equipment lists in many of the SCPs have not been updated. Conversely, there is information in the SCPs now that was included at the time they were written(1990s)in print format because it was not digitized at the time the plans were written,but now some or all of that information(e.g., sensitive resources, community profiles) may be available through geospatial data platforms. It is not clear whether the ARRT and OSCs envision a review of information sources as part of this information migration, but if updating the information is not done and the ACPs are published with a 2017 version date containing 1997 information, this has the potential to mislead responders or decision-makers during an incident. Once the new Area and Regional Contingency Plans are published and Area Committees established, PWSRCAC believes that establishing a regular schedule for plan review and update could be very beneficial. This will ensure that ACP contents remain current, while also establishing a predictable schedule for when reviews and updates will occur, so that other levels of government, the RCACs, and other groups with an interest in ACPs can plan their workloads accordingly. This would also align with the State of Alaska's approach of trying to coordinate the five-year update cycles for industry plans. Separating inland and coastal ACPs PWSRCAC found through our research that most regions have separated out inland ACPs from coastal ACPs, with a single inland ACP for the entire region(in this case, it would be the entire state) and coastal ACPs for the sub-regions (COTP zones). We presume,but are not entirely certain, that the ARRT intends that the four ACPs that will be developed for Alaska will each be a joint inland/coastal ACP, and that there will not be a separate inland ACP. We would be interested in understanding whether the 600.431.161115.ARRTareaboundry 7 Federal OSCs considered also splitting out the inland and coastal boundaries, and whether this would address any of the concerns driving the proposed changes. 3. Area Committee and Planning Process The planning process is often as valuable as the plans that come out of it. PWSRCAC has invested time and institutional knowledge in the Subarea contingency planning process over the years, including the 2014 update of the Prince William Sound SCP. While the Subarea Committees do not meet as standing bodies on a regular basis, our experience working on the Prince William Sound, Cook Inlet, and Kodiak SCPs over the years has been that the groups that have worked cooperatively to develop the plan contents have included representation from municipalities,boroughs, Alaska Native organizations, oil spill response organizations (OSROs), and State and Federal resource agencies, along with OSCs. The proposed change to ACPs and Area Committees does not provide any information on how the planning process would proceed. PWSRCAC understands that the intent is for the OSCs to promulgate the ACPs - which is also how the SCPs are promulgated (signed by EPA, USCG, and ADEC). It is not clear how the ARRT envisions the Area Committee composition, and specifically how local governments, Native organizations, Local Emergency Planning Committees (LEPCs), the oil industry, and local and regional stakeholder groups (such as tourism, fishing, etc.) will have the opportunity to participate. For the proposed Prince William Sound ACP, PWSRCAC would hope and expect to continue to actively participate in any future updates to the plan through working groups or similar processes. Likewise,we hope that the proposed change will be accompanied by an initiative to have a regular, standing meeting schedule for each ACP, as is done in the Lower 48. Using the proposed Western Alaska Area as an example, it is hard to foresee how members of the public, government, and stakeholders across this large region would be able to meaningfully participate in Area Committee meetings. Travel between the communities that would be combined into this Area would be expensive and in some cases, logistically challenging as there are few ways to travel directly from one remote Alaska community to another. This could create a barrier to participation based on funding or logistics. PWSRCAC would like to see additional detail provided about the intended membership and structure of the Area Committees, and a proposed schedule for meetings (i.e., quarterly,biannually). It would also make sense to develop a work plan for each Area Committee that identifies the intended review and update schedule for each ACP and, where appropriate, its SCP annexes. Recommendations PWSRCAC supports the concept of improving oil spill contingency planning in Alaska. We understand the general need to harmonize Alaska's plans with the rest of the U.S., and we agree that creating standing Area Committees that meet regularly to maintain and update plans could be a more effective approach. We also recognize that state and federal agencies are seeking ways to reduce workload and staff time required to manage oil spill contingency plans and the broader planning process. However, while we understand and support the general rationale that has been presented, we have some substantial concerns about how the proposed change will be implemented and what the resulting ACPs and Area Committees will look like once this transition is complete. 600.431.161115.ARRTareaboundry 8 PWSRCAC has been actively involved with the Unified and Subarea Plans since they first came to be, and we are proud that Alaska has been a national leader in initiatives like geographic response strategy and places of refuge planning, which have all been accomplished through the Unified and Subarea Plans. In the spirit of ensuring that the proposed changes serve to strengthen and not dilute the current system, we recommend that the ARRT consider and address the following issues as you move forward with this initiative. 1. Conduct additional outreach with impacted communities before aggregating Subareas into Areas. PWSRCAC's membership includes representatives from Kodiak and Cook Inlet communities, and in speaking with them,we find that there is a degree of uncertainty regarding what the shift from SCPs to ACPs will mean in terms of their ability to review and provide input into the plans. We believe that special consideration is warranted for these areas as they are distinct from rest of the Western Alaska area. Additionally, there may be extra costs incurred by local governments or other organizations who wish to attend Area Committee meetings that require in-state travel, which can be expensive and cumbersome. We suggest that the ARRT engage in a more fulsome dialogue with communities in the five Subareas that would be aggregated into the new Western Alaska ACP to explain the rationale for the expanded Western Alaska Area and foster a better understanding of how the outcomes will or will not impact their communities. 2. Provide a matrix or crossroads that clearly shows how existing information in the Unified and Subarea Plans will be transferred into the new ACP format. The table that was displayed at the Nome ARRT meeting appears to be the start of this process; PWSRCAC would like to have the opportunity to review the entire completed matrix. We would also like more information about how the Geographic Annexes to the ACPs will be structured for regions like Western Alaska where multiple Subareas would be combined under a single ACP. 3. Provide more detail about the Area Committee structure and function. PWSRCAC agrees in concept that a standing body with regular, public meetings might be an improvement over the current system, particularly for regions where the Subarea committees have not been meeting consistently. We are specifically interested in membership beyond the On-Scene Coordinators from the federal and state governments, and also in the proposed approach to scheduling meetings for regions like Western Alaska with widely dispersed communities and limited options for traveling between communities. 4. Provide a more detailed implementation plan and schedule for making the proposed changes. PWSRCAC believes that the proposed effort will require significant staff time to reorganize the existing Unified and Subarea plan information to fit the new ACP model. We have seen some very ambitious timelines for this effort, and are concerned that the attempt to undertake such a massive reorganization on such a short timescale may result in mistakes or oversights. While the request for comments that is ongoing now has been framed as a scoping tool, it appears that the work has already been started, without considering the input that may be received. We are likewise concerned that adequate time be allocated for public review of draft plans, which is an important issue to our membership. We caution the ARRT to consider the importance of buy-in to any effective plan; these plans are not only important to the federal and state OSCs; they are also relevant to local and regional governments, Alaska Native organizations, industry, stakeholder groups, and spill response organizations. 600.431.161115.ARRTareaboundry 9 \\ 1 1 1 r e l t � RCAC '• Regional Citizens' Advisory Council /"Citizens promoting environmentally,sate operation of the Alyeska terminal and associated tankers. In Anchorage: 3709 Spenard Road/Suite 100/Anchorage,Alaska 99503/(907)277-7222/FAX(907) 277-4523 In Valdez: P.O. Box 3089/ 130 South Meals/Suite 202/Valdez,Alaska 99686/19071 834-5000/FAX(907)835-5921 MEMBERS January 9, 2017 Alaska State Avoidance Areas (hamtx l r>t('atwnc"e c/o Mark Janes P.O. Box 191 Chugar h Alaska Seldovia, AK 99663 Corporation Email: mark@nukaresearch.com City of Corrtrri.l Re: Comments to the Alaska Regional Response Team on Dispersant Use City of Horner Avoidance Areas in the Prince William Sound, Cook Inlet, and Kodiak Subareas City of Kodiak The Prince William Sound Regional Citizens' Advisory Council (PWSRCAC) is an city rw Seldovia Independent, non-profit corporation whose mission is to promote environmentally safe operation of the Valdez Marine Terminal and associated City of Seward tankers. Our work is guided by the Oil Pollution Act of 1990 and our contract with Alyeska Pipeline Service Company. PWSRCAC's 18 member organizations City of Valdez are communities in the region affected by the 1989 Exxon Valdez oil spill, as well as commercial fishing, aquaculture, Native, recreation, tourism, and City of Whinier environmental groups. Crwrm,t,nity rd PWSRCAC provides the enclosed comments to the U.S. Coast Guard (USCG), Chenega B.,, Environmental Protection Agency (EPA), and the Alaska Department of Environmental Conservation (ADEC), on behalf of the Alaska Regional Crwrwnnnity ret Response Team (ARRT) in response to the USCG's November 2, 2016 news Talitlek release. The news release solicited public input to help guide developing Dispersant Use Avoidance Areas within the Preauthorization Area required by irdova Uisnir t tishennen United the Dispersant Use Plan for Alaska signed January 2016. PWSRCAC appreciates the opportunity to provide input on identifying areas where dispersants are Kenai t'enitwula not recommended, and hopes the Dispersant Use Avoidance Areas Technical Koiough Committee finds that the sites selected merit additional consideration prior to using dispersants. Kodiak Island Burry/til, Our comments focus on a discussion of the oceanography in the areas of rrhak Village Mayrr> Prince William Sound, Cook Inlet, and Kodiak Subareas, as well as a discussion KAssrr iatlrw, on the significance of seamounts, continental slope areas, troughs, canyons, and banks. Attached to these comments are the Areas to be Avoided Public Oil spin Region Input Forms for 17 areas in these three subareas. Env irrnlnwnlal (ualitir n As you may be aware, the council in 2006 adopted the position against the use Pert Whamof dispersants in the Exxon Valdez region. However, PWSRCAC acknowledges ('rwtwwatirm that the decision on whether or not to use dispersants is complex and can have significant, long-term impacts on the environment, and cautions that I'rinr v\hrlliant Sound these decisions are based on the best available science for decision-makers. An understanding of ocean physics, marine ecosystem dynamics,namics, and the Page 1 of 2 600.105.170109.ARRTdispUseAvoid effects of oil and dispersed oil on individual organisms is critical. As our comments indicate, the areas 24 nautical miles off shore to 200 miles off shore are highly biologically productive, and are the same areas where oil or dispersed oil would be transported by vertical upwelling and horizontal currents. In addition to consideration of the areas nominated for the Dispersant Use Avoidance Area in the Preauthorization Area, PWSRCAC recommends that a plan for long-term studies be developed to document and better understand areas where the use of dispersants is considered. PWSRCAC recognizes the efforts by the ARRT to update the Dispersant Use Plan for Alaska, and looks forward to providing input based on our over 25 years of experience in oil spill prevention and response planning. Thank you for considering these comments. Please feel free to contact me at 907-834- 5070 with any questions or if any of our comments need clarification. Sincerely, Donna Schantz Executive Director Cc: Mark Everett, USCG, ARRT Co-Chair Chris Field, EPA, ARRT Co-Chair Kristin Ryan, ADEC Co-Chair CDR Joe Lally, USCG LCDR Matthew Robbie, USCG LT Jason Scott, USCG Page 2 of 2 600.105.170109.ARRTdispUseAvoid W 1 L L l,4 M jig' SG RCAC Regional Citizens'Advisory Council Proposed Avoidance Areas for the use of chemical dispersants within Preauthorized Areas of the Prince William Sound, Cook Inlet, and Kodiak Subareas January 9, 2017 Prepared for the Prince William Sound Regional Citizens' Advisory Council by Pegasus Environmental Solutions-Alaska Proposed Avoidance Areas: The following list contains areas nominated for inclusion in the Dispersant Use Avoidance Areas in the Preauthorization Area. The Preauthorization Area is defined in the Dispersant Use Plan for Alaska dated January 27, 2016, whose boundaries are based on the common shipping routes of crude oil vessels. The inner boundary begins at 24 nautical-miles (NM) offshore, extending southerly to the Exclusive Economic Zone 200 NM offshore, and northerly 100 NM north of the Aleutian Island chain. Note separate Areas to be Avoided Public Input Forms are being submitted with this cover document for each area nominated. List of Areas Nominated 1. Prince William Sound (PWS) Subarea a. Hinchinbrook Canyon b. Montague Trough c. Contingency Shelf Brief and Slope (in all Subareas) d. Gulf of Alaska Seamount Province: Giacomini and Quinn Seamounts 2. Cook Inlet (CI) Subarea a. Resurrection Trough b. Amatuli Trough c. Portland Bank (also in Kodiak Subarea) d. Continental Shelf Break and Slope (in all Subareas) 3. Kodiak Subarea a. Portlock Bank (also in CI Subarea) b. Stevenson Trough c. North Albatross Bank (also known as Marmot Flats and Lock Island Bank) d. Chiniak Trough e. Middle Albatross Bank f. Barnabus Trough g. South Albatross Bank h. Continental Shelf Break and Slope (in all Subareas) i. Patton Seamount Province: Patton Seamount Page 1 of 17 1. Introduction There is a great deal more about ocean physics, the marine ecosystem, and the effects of oil and dispersed oil on individual organisms that need to be understood when making decisions about using chemical dispersants in the "Preauthorization Area." Robust scientific research is essential to understanding the risks of chemical dispersants and impacts on ecosystems and organisms, especially in the off shore area of the Gulf of Alaska. The density of biological and oceanographic data declines rapidly with the distance off shore and depth. Information generally falls into two categories: it is either large scale gathered by aerial or satellite remote sensing, or it is at very specific transects or survey grids. A synthesis and integration of biological and oceanographic information into a coherent ecosystem picture is crucial when asking the question: "Is this area at risk from dispersant application in an oil spill?" The areas of greatest productivity are also where oil, or dispersed oil,would be transported by both vertical (upwelling) currents and horizontal ones (Alaska Gyre, the Alaskan Stream, and Alaska Coastal Current (ACC)). The areas Prince William Sound Regional Citizens' Advisory Council (PWSRCAC) identifies where dispersants should be avoided fall into three general categories: 1. Seamount and continental slope areas; 2. Glacial sea valleys (also known as troughs or canyons) in the continental shelf; and 3. Relatively shallow, flat areas between canyons (banks). 2. Oceanography of northwestern Gulf of Alaska The oceanography of the northwestern and Central Gulf of Alaska (CGOA) is a complex blend of deep, sub-surface, and surface currents. These currents combine to influence the tremendous productivity of the north Pacific. This productivity starts with a deep, dense, nutrient-rich current which brings nutrients from equatorial waters across the abyssal plain into the CGOA. In that area, a blending of ocean physics, weather, and tidal factors creates an anti-cyclonic circulation (Alaska Gyre) north of the West Wind Drift (see Figure 1). The Alaska Current is a typical eastern boundary current, rich with eddies and meanders. At the head of the CGOA, the Alaska Current turns southwestward following the isobaths. This is the beginning of the Alaskan Stream, the western boundary current of the Alaska Gyre. Near the southwestern edge of Kodiak Island(-155°W), the Alaskan Stream is a narrow (-50 km), high speed (>50 cm s-') current that flows southwestward along the slope of the Alaska Peninsula and Aleutian Islands to 180°W, where the Aleutian Arc turns northwestward. The ACC, driven by winds and freshwater runoff, dominates circulation of the shelf and controls the transport of dissolved substances and planktonic material across the shelf(Stabeno 2004). Page 2 of 17 • Pridce WII Ilam 1 • Sound4 4 'S Kayak 1. 7 �: /e-- ��kal ♦ 60 N + / / \ Bering Sea ♦ I� ! 1 ,. • ::.Nt 55 tr. _st7tIrnai — IS stream � r1asKa --� A Sams* Oueen Pass r—, -- Choi'one Is. West Wind Drift 50° 170° 160° 150° 140°W 130°W Figure 1: Shallow Currents in the Gulf of Alaska (Stabeno, 2004, Figure 1) Figure 1 diagrams the major shallow currents contributing to the mixing of nutrients along the continental shelf. Throughout Southeast Alaska and the Central Gulf of Alaska, the ACC is very low density (salinity)within a shallow, near-shore, surface layer (Stabeno 2004, Mundy 2005). A coastal current with a marked freshwater core is evident along the Alaska coast from Icy Point to Unimak Pass. Along its course, the current is impacted by both broad scale cross-shelf Ekman transport and episodic entrainment from the slope, as well as by topographic steering at a variety of sites, including Kayak Island, Hinchinbrook Canyon, and Amatuli Trough (Figure 2). The large freshwater discharge from numerous rivers and streams along the mountainous Alaska coastline is confined along the coast by downwelling favorable winds. This combination provides a strong density-dependent signal to the ACC. While thousands of conductivity-temperature and depth (CTD) casts have been made in the CGOA, only two sites (separated by -.500 km) on the shelf have sufficient data to evaluate a seasonal signal. The longest record exists at GAK1 (the innermost station on the Seward Line)which has been maintained by the University of Alaska since 1970. The second site is at Cape Kekurnoi, the exit of Shelikof Strait, which has been maintained since 1984. Both stations are near shore and thus are impacted by the low salinity water of the ACC (Stabeno 2004). There is a strong consensus that most nutrients on the CGOA continental shelf come from the nutrient-rich waters off the continental slope. However, some nutrients, especially iron, are contributed by the fresher waters of the ACC. Topographic steering is a major factor in determining where the deep ocean nutrients rise into the photic zone. Most residents of coastal Alaska are accustomed to hearing weather forecasts predicting more extreme winds "through bays and passes". Similar physical drivers affect the upwelling and movement of nutrient-rich waters up the continental slope and through its many glacial troughs and canyons. Similar upwelling, eddies and turbulence occur when currents meet volcanic seamounts. With sufficient Page 3 of 17 sunlight (e.g., summer), phytoplankton grow using the available nutrients and produce chlorophyll. Chlorophyll can be measured by the SeaWIFS satellite (Hermann et al., 2009). Geophysical modeling shows strong upwelling along the continental slope concurrent with the outer edge of the productive zone (green, yellow and red in Figure 2). Note the outlying spots of productivity (green)in the otherwise blue CGOA. These correspond to the Giacomini and Patton Seamounts. 15M•W 152.W 150W 145•W 110W 144W 1121n, rwwrr ?w.nwr, 9; vrw of 61' �n Ke W - f • : C.° • N Figure 2: Seafloor bathymetry including dll prominent features in PWS, CI and Kodiak Subareas. Zimmermann, 2015 i ,.. yin n t i •y'iQ� cp_ L — ._i ALASKA sr " e.M4.1. I .. s.a r� N - -•J' GURtlA4W IWW 167'5 150•W 1465 1452W tuw Figure 2 illustrates most of the bathymetric features proposed for avoidance of chemical dispersant use. Nutrients approach the continental shelf from the deep blue waters of the abyssal plain and are mixed with the coastal currents on the shelf. Some nutrients are transported up the shelf in sea valleys, also known as canyons or troughs, and into coastal features such as Prince William Sound (PWS) and Cook Inlet (CI) (yellow color or intermediate depths in Figure 2). A series of shallower, relatively flat banks (shown in red) are seen between the sea valleys which historically are areas of high productivity of commercial and forage fishes. 3. Seamounts There are two chains of volcanic seamounts extending across the 200 NM of the outer line of the Preauthorization Area (Figure 3). The Gulf of Alaska Seamount Province starts with Giacomini and Quinn Seamounts in the southeast corner of the PWS Subarea and extends southeast toward the Alaska/British Columbia border. Patton Seamount, the oldest and tallest of the Patton Seamount Province, sits in the southeast corner of the Kodiak Subarea. This seamount province extends southeast to a current hotspot off the Oregon coast. Page 4 of 17 I1- Figure 3. Seamounts of CGOA. • Seamounts of the GOA and Patton Seamount Provinces are Gulf fAla,kl shown. Outer contours of the . continental slope, and Exclusive 15«/ \N.:10 Econimic Zone (EEZ) help delimit \'" '0 the "Preauthorized Area". •, o•••• ' •�� `' (Maloney 2004, Figure 1) o 4.' r QV In ways similar to the Aleutian Islands making their own weather, seamounts perturb the nutrient-rich water flowing around them. Primary productivity shown by the SeaWIFS satellite data (Figure 4) is significant around the seamounts, thus, documenting the rise of nutrients into the euphotic zone shows there is significant primary productivity in the euphotic zone above these seamounts. Giant'Gtr 1.tUi..1u4l-8" mc. • 41• .` Figure 4. Primary production, as measured by • "+' „a chlorophyll production, is shown in this SeaWIFS ` �' 4`� }�,* image. Like Figure 3, it shows the CGOA including a _ GOA and Patton Seamount Provinces. The primary • - production around the seamounts is shown as green. \ .\ • (Proctor 2005, Figure 1) An initial survey of commercial fishing potential (Hughes 1981) found harvestable quantities of some species, most notably sablefish, in midwater trawls as shallow as 12 m - 33 m. A variety of benthic fish and shellfish species were also found. A more recent survey (Maloney 2004) concentrating on sablefish and longline gear confirmed the presence of sablefish, and determined the populations to be mostly male greater than five years in age. a. Gulf of Alaska Seamount Province. Giacomini Seamount is the only major seamount within the PWS Subarea "Preauthorization Area." It is located 40 NM west of Quinn Seamount and approximately 198 NM east southeast of Cape Chiniak (Kodiak Island), Alaska. Giacomini Seamount's center is positioned at lat. 56°27'30"N, long. 146°24' 00" W. Giacomini rises from abyssal plain depths exceeding 3,600 m to within 640 m of the ocean surface. Giacomini has a rather symmetrical flat-topped shape comprised of about 20 NM' of surface area at depths primarily of 640 m to 730 m. The substrate is predominantly soft with scattered rock pinnacles. Quinn Seamount is within the 200 NM limit but is just east of the eastern edge of the Preauthorization Area. It is located 33 NM west northwest of Surveyor Seamount and Page 5 of 17 approximately 220 NM south of Cape St. Elias (Kayak Island), Alaska. Quinn Seamount's center is positioned at lat. 56°18' 18" N, long. 145°13'07"W. Quinn rises abruptly from abyssal plain depths of about 3,600 m to within 659 m of the ocean surface. The top is rather oval, measures 3 x 4 NM, the surface being 730 m - 820 m below the surface. This seamount is characterized by considerable soft sediment, an apparent absence of rock pinnacles, and extremely steep edges which plunge to the abyssal plain. b. Patton Seamount Province. Patton Seamount is major seamount within the Kodiak Subarea Preauthorization Area. It is located 175 NM southwest of Giacomini Seamount and approximately 166 NM southeast of Cape Sitkinak (Sitkinak Island), Alaska. Patton Seamount's center is positioned at lat. 54'34'22"N, long. 15029'30" W. Patton rises from abyssal plain depths exceeding 3,500 m to within 168 m of the ocean surface at the northeast corner of the seamount's top. The topographical features of Patton are much different from other major seamounts in the Gulf of Alaska. The top measures 4 x 6 NM; however, the surface area consists of an endless series of rocky mountain peaks and canyons ranging from 180 m to 900 m depths. Areas at depths less than 470 m are primarily mountain peaks. Areas of relatively flat and soft substrate are uncommon but occur mainly over the southwest quadrant. - Figure 5. Multi-beam sonar bathymetry map of Patton 1000 14 ,'• 11111111111 Seamount(Huff 2005, Figure 1) • boo ,eo , ;4� , 3100 f cm As shown in Figure 5, the volcanic origin of the Patton Seamount is clearly evident. These general geological features are typical of other seamounts in CGOA. Page 6 of 17 Figure 6. Depth distribution and species composition of three assemblage groups on Patton ,00 0011011/ - - Seamount. (Huff 090 2005, Figure 3) 060 vr 070-/ j 060 i _' ..7...;=1 'al�roral w� noon crabs CA 7 r� ► a aaMnt I V"Crabs heck bur. Carob 1' -1111111a` �w - -G 03041 4Snarteia unah e garbaaWPC r alik r asearar 020 TIAir 1ae Tbamybaed'°`*h,"" 010 Sermon Golden km*crab 000 I i I I I 1 I I r I I , , , I RosiAabe 200 400 600 B00 1000 12� 1410 16)20 tsbo 2050 2200 11460 ?6k ?910'3060'3.100'3100 Depth A 2005 survey of faunal assemblages on Patton Seamount by Huff and Stevens found three depth communities. A shallow (151 m -950 m)was quite aggregated. The mid-depth community (400 m -1,500 m) had similar structure to the shallow community. The deep community(500 m - 3,375 m)had no distinct aggregations and consisted of species broadly distributed over depth ranges (Huff, 2005). Figure 6 compares the species and their abundance within these three depth assemblages. Unlike geothermal vents, these data show greatest faunal density nearest the primary and secondary production in the euphotic zone above the seamounts. In 2011, McNight and coworkers used data logger technology to track the movements and behavior of post-breeding black-legged kittiwakes. They found about one-third of the population stayed at relatively near shore locations in the CGOA, and about one-third migrated to coastal areas in the Pacific Northwest. What was most surprising was that the remaining one-third over-wintered near seamounts well off shore. Page 7 of 17 16011/ 140- 120° 100' LASKA �_ Figure 6. Kernel density map of black-legged iffik BRITISH , COLUMBIA Kittiwakes exhibiting three different wintering strategies. (McKight 2011, Figure 3) 1 wASHI TOs 1 OREC, c 40° O 30 - 0 250 500 1000 1500 2000 km Kittiwakes are shallow diving seabirds, so they must be feeding on forage fish near the surface in these over-wintering areas. A number of prominent oceanographers and sea lion ecologists (NAS 2003, Mundy 2005, Trites 2007) assessed the role of production at the bottom of the food chain in the persistent decline of Steller sea lions. Their strong support for this hypothesis suggests high importance for protecting sites of high primary and secondary production such as the shelf break and seamounts. As research indicates the area around seamounts provides abundant productivity, the use of dispersants in these areas is not recommended.Avoidance Areas for each seamount should include the full seamount which is approximately 30 NM across at the base. 4. Continental Shelf Break and Slope The continental shelf break and slope are central to making the CGOA one of the most productive marine ecosystems in the world (Stabeno 2004, Mundy 2005). This is where nutrients being carried north along the abyssal plain are first subject to topographic steering toward the surface. Different oceanographic teams favor the following mechanisms for the mixing of this nutrient-rich water onto the shelf(Schroeder 2007): • Nutrients transported from central Gulf of Alaska in the Ekman Layer (Stabeno et al. 2004) • High nutrient water is brought onto the shelf in the bottom boundary layer triggered by the weakening of the alongshore geostrophic transport (Weingartner et al.) • Surface offshore flow due to alongshore pressure gradients and entrainment cause onshore flow in the bottom(Royer et al) • Increased salinities and nutrients measured in Hinchinbrook Canyon (Childers et al.) • Large anticyclonic eddies can enhance shelf-slope exchange and promote upwelling (Okkonen) The Topex/Poseidon/Jason/ERS satellite provides precise measurement of sea surface height which allow eddy kinetic energy to be calculated which in turn equates to mixing energy. Page 8 of 17 cm2/s2 59.0°N - r leo ,.��` 150 ,�,�t _____________I 57.0°N - i 55.0°N 110 410. 100 . \ A. 00 53.0°N 51.0°N - 00 so 40 49.0°N 30 t 1 1 I i 1 20 165°W 155°1.V 145°W 135°W 125°W Eddy Kinetk Energy Figure 7. Eddy Kinetic Energy averaged over October 1993-October 2007 calculated from satellite altimetry (Mundy 2010, Figure GA-12) As shown in Figure 8, the greatest mixing energy occurs along the outer break in the continental shelf. The greatest mixing occurs in the eastern and central CGOA with isolated areas with high mixing energy further west along the shelf break. Satellite-tracked drifters verify the convoluted tracks of near-surface currents in the winter. Figure 9 shows the actual and averaged tracks for two drifters released just off the edge of the shelf. The western drifter followed the continental shelf while staying just off the shelf break. Its convoluted movement is due to eddies and turbulent mixing. 62 Figure 8. Convoluted tracks 4•' of satellite tracked drifters in 60 � ly .� �''� � Jf'i eastern and western GOA. \( ::' .•LG ---....0.---,- 05-D,c-2o `,14; � 4 1. Drifter's drogue at 30 m. se i �r +--. k CV ti s f✓t` �.�' .;, ,f, 10-Jen-2007 �0��' �' `�� �� ' 60 I 41 ..-,f r'i' r4 � 1; '.:'' 10-Jan-2007 4 -_ ii1 r 23-Jan-2002 52 ` I i • 1 Poo 205 210 215 220 225 230 East Longitude The chlorophyll signal in Figure 10 shows the Yakutat eddy has significant primary production even while significantly outside the shelf break. Page 9 of 17 60'N f 'vh.—.yr Chlorophyll Composite, 140 Flogs Applied -s / Coy* 1 17- 118 2003 81..108:IMO ,� •i✓,�. , T dilly:- - / o f . 'Tx' Viet Nik 41/4.; , ,_ .„ lea ‘ at ik,‘,. eirPP;- it • . Illo 1 - " 55'N ,�. 1 �. - .,• .: .I 155'W 150'W 145'W 140'W 135'W Figure 9. Surface chlorophyll from SeaWIFSdata composited over 27-28 April 2003.The white arrow marks the Yakutat eddy. (Ladd 2005, Figure 6) Figures 8-10 provide strong evidence that the initial mixing of deep ocean nutrients occurs outside the continental shelf break, along the continental slope. Two large Exxon Valdez Oil Spill Trustee Council funded projects (Piatt 2002, Day 2004) documented the importance of the abundance and location of forage fish populations to the health of seabird and fish eating marine mammal populations. In 2005, Hunt et al. published a study comparing the breeding and non-breeding seasonal distribution and prey consumption of several species in the Gulf of Alaska. T f r _ 1 ! 4: 1 LIU �a} At,+.4a itei Mite 11 i i . • i • • I. k� Cpl.–D�c. 1981 i 2,212 riaut=: 1 i ti Figure 10. Location of recorded Alaska pollock hauls for domestic and foreign trawlers during the fall (i.e. non-roe season) (NAS 2003, Figure 5.11c) For their analysis of the reasons for the decline of the western population of Steller sea lions, the National Academies of Science (NAS) committee estimated removals of Alaska pollock during the initial period of the decline. The fall fishery was chosen because at that time the spring roe fishery occurred primarily in Shelikof Strait. The data shown in Page 10 of 17 , Figure 11 is for the 2,212 hauls documentable for fall 1984. Note that most of the harvesting effort was focused along the outside of the shelf break on the continental slope; presumably this is where the most fish were being harvested. Application of chemical dispersants for oil spill response should be avoided in the entire shelf break and continental slope area for all subareas as these areas are some of the most productive marine ecosystems in the world. 5. Troughs and Banks As shown in Figure 12, the continental shelf throughout the PWS, CI, and Kodiak Subareas is a series of alternating deep glacial sea valleys and rounded ridges or banks. Like glacial valleys on land, sea valleys are also called canyons and troughs depending on the topography. Ocean banks are often rich fishing grounds due to upwelling of a tidal influx of nutrients. Banks are usually comparatively flat and shallow compared to the surrounding sea valleys. As discussed in the section on oceanography of northwestern Gulf of Alaska, the greatest upwelling and mixing turbulence occurs on the western side of the CGOA. The highest productivity banks are Portlock Bank and Northern Albatross Bank(also known as Marmot Flats or Long Island Bank). These have a long history as rich commercial fishing grounds, especially for halibut, Pacific cod and Alaska pollock. 154"W 152'W 150•W 148'W 148•W 144•W 142•W BaMymctry , /�y`,4ncnota a f;/ ,�r v ez \�, , n'neters tl� 4. 61 N- - )., b Kenai f, fPnnce- �1 WiHrom , for -.m Peninsula • Bey .1 N r — �lso cd )S Sewn. ''4.) '''I r , t C.41sPi- ,,,,,,0 b0'N- 111.41) So-0y +4)rh*, )' �( ' ,, ,. , \ , i IlM1 000 k.f. Crook _1g15Y ! liorM M'1'boughTht ; Sc! N Ink t. -.000 1) 1 j',. �•. ...i \ Rxy 573 T`nD Pampbna -tato ,*e (`. s - .,� - Mddktnn Island SP,), 59 N- -'KC ''°3 •, C r --' ��n°ro°'''E"""'. Central -5a{R ) S '$q, „t. .wa .,,, - ..tn id -•'�_ f 4.. ,.- ' .ti` Gulf i— ''r^ 1144 raven Islands of 58'N 74,-l?o1/44s y' +f' Alaska 58 N-' , ,C=v- _* o I►/' 5 > t,1.KOAtak eeo 4iDaPu»9anw r.RY* -M• 7•N 4• Lr-J ALASKA'' 1. 5� 'n,rnyw 7.ou , - - 5TN- - te A111,0OD)Elan /1%IQ C\ • lir . ri .. &dr AdU1IJ T:p,,.• Jae ' -. �, 41/1—, ., Abatmssna r / Gulf of Alasq1/4ka 56°N 1 . t 154'W 152'W 150'W 148'W 146'W 144'W Figure 11. This is a duplicate of Figure 2 Seafloor bathymetry including prominent features in PWS, CI and Kodiak Subareas. (Zimmermann, 2015, Figure 2) Page 11 of 17 z �r, Average chlorophyll 1998 - 2002 `..*� July 12-26 `P'•, 111 "'T.-. ...fit, 01 23456 IP.. \ lir 044 60' Vir ‘...*)fdji, C .. '1 r-/'- ,56 154 ,61 16U ,4!'W 1 I I 1 I 1 1 1 1 1 Figure 12.Average surface chlorophyll from SeaWIFS data for the late July 1998-2002.Values near the coastlines are less reliable due to combination of color signal by sediment (Hermann 2009, Figure 2) As indicated in Figure 13, the highest primary production measured by the SeaWIFS data was above the troughs and banks of the continental shelf in the northern part of the Kodiak Subarea. Figure 14 illustrates that salinity and chlorophyll measurements across Portlock Bank showed a high degree of stratification with primary production directly above Portlock Bank. Gore Point CTD Sections of Wa er Density and Chlorophyll Cebt: 22 23 24 25 28 27 28 29 30 32 33 34 35 36 0 7 • • • • • • • ' •i • 27 A 40 2R 0 80 /Bank \ tl k za 180, 4111114L 3 in 200 I I I f 122 0 5 40 4 m o BO— — 3 ortlock a 120_ / Bank Chlorophyll - 2 0 180 / Gig I.1) — 1 200 1 1 1 1 1 1 1 0 0 40 80 120 180 200 X (KM) Figure 13.Vertical sections along the Gore Point line where it crosses Portlock Bank in 2003. Salinity and chlorophyll were measured from the surface to 200 m. (Proctor 2005, Figure Sb) Page 12 of 17 Orliih.r • ‘ ' 1111% diA,ii 111P 7 59°N G —'' 58°N Y NoOptt' i tic 154°W 150°W Figure 14.Trajectories of satellite-tracked drifters(depth of drogue—40 m). Convoluted flow along the Kenai Peninsula and over Portlock Bank. (Stabeno 2004, Figure 10b) The drifters used to depict trajectories in Figure 15 show a tendency to congregate over Portlock Bank as would nutrients and less motile larval and prey species. In their forage species report for the North Pacific Fisheries Management Commission (NPFMC), the National Marine Fisheries Service (NMFS)Alaska Fisheries Science Center reported on the distribution and abundance of over 50 forage species (Ormseth 2014). Figure 16 is an example of just one species, eulachon. The fish were spread widely along the continental shelf, including several off shore areas of significance. ,b ,}rw ,Taw Mt,/ SOW ,law 11r* 14rw 4.1:w 13}w ,3rw ,Mw a1„,C,1O112007_,°„ � Figure 15. Mean bottom trawl survey """""E'er"”" CPUE (kg/hectare) of eulacon in the O'Ir —0 - - � y}w aM �°:; 1" CGOA 2007-2013. Grid cells are 40 x 40 _1.1.3a3 ti�'n "" =301 "' Lj..a ar tea^ km. (Ormseth 2014, Figure 7) .0- NEear•a T, 1. ro3e YM, _:TY-1,T. _Y T6.3124 a • -!!w M 2° 511. XV }\. : bM • .04,4 NI li. LI , 02F GULF OF ALASKA 31 N. -Mw Page 13 of 17 s Both the banks and troughs throughout the Kodiak Subarea support major commercial and substance fisheries (Mundy 2005). Juvenile fish and forage fish species in turn are necessary for the health of numerous fish eating sea bird and marine mammal species (NAS 2003, Mundy 2004, Mundy 2010). Members of the Auk family made up the vast majority of bird carcasses retrieved from areas oiled by the Exxon Valdez oil spill (Hunt 2009). In an effort to determine the post breeding season distribution of two Auks, common murres and tufted puffins, satellite transmitters were implanted in these deep diving seabirds (Hatch 2000). As shown in Figure 17, common murres tagged at the Barren Islands (East Amatuli Island) stayed within a 100 km radius of the islands for the duration of the study. Movements were mainly in a north-south direction, ranging from the mouth of Kachemak Bay to waters around Marmot Island. In contrast, tufted puffins ranged 100 km west and more than 150 km east of West Amatuli Island (Hatch 2000). Many of those foraging trips to the east were to the waters over Portlock Bank(Hatch unpublished results). 20 0 20 Kachemak y tS�J Bay a taksnews `, 8 7.71:777^ 0 8 e° Figure 16. At-sea distribution of Common murres from s t ,4 East Amatuli Island by sex, 17 July-21 September 1995 W.AmnduH °r ` (Hatch 2000, Figure 2) Island � • , rz t_ _ E Amatuli Island • Shuyak Island;A> t A 1♦� s. .pg ... . . . L nd .• , -,3& 3. '�' :{ t 8 o r1 Ii k f ' e o 0 ° I'd o Females t+l! �.i,,t,1 Mamat Island • Males Using more traditional survey techniques, a study was undertaken to determine the location and prey choices of a number of diving and surface feeding marine birds (Hunt 2005). Three findings of the study include: 1. Both in "summer" and in "winter," the consumption of prey by marine birds over continental shelf waters was much greater than that over the basin of GOA; 2. Seabird densities in both summer and winter were much greater over the southwestern shelf around Kodiak Island; and 3. Prey consumption rates were greater in the "winter" than in "summer", both on and off the shelf(Hunt 2005). Page 14 of 17 SEABIRD DENSITY sSEABIRD DENSITY I..1.m11 INAy•A000s1/ / // `\ IS•41s049r-AONI /:4 o•no / h • 015 // D ,51-s0O .• ♦. o +s+.soo U 501 5000 ., i•+• ?• O wl.sooo ,t yt 4 i Q soot Al - o %'• .,�'''• O mol,Alt 0.'-' 2 :* ..•."*. .f Eki ,2 .. 2 y� C.• ,! • •• • M�F 4.5- k E w E Figure 17. Distribution and abundance of all marine birds combined within the study regions.The left survey results from May-August; right survey results from September-April(Hunt 2005 Figure 2). The banks and troughs from Portlock, which is also in the CI Subarea, are Stevenson Trough, North Albatross Bank, Chiniak Trough, Middle Albatross Bank, Barnabus Trough, and South Albatross Bank. The use of chemical dispersants is not recommended in any of these areas. These highly productive areas are important for many human uses of the abundant living resources, including commercial fishing, a plethora of recreational uses, and traditional and customary uses of the Alaska Natives of the area. They also provide habitat and food sources for endangered cetaceans and pinnipeds. 6. Requirements for Co-management under the Marine Mammal Protection Act (MMPA) The Marine Mammal Protection Act of 1972 as amended in 2007 (MMPA) provides for both protection of traditional and customary use (a/k/a subsistence) of marine mammal resources in Alaska and for co-management and consultation with tribal governments regarding these resources. Under MMPA Section 109(f), transfer of management authority to the State of Alaska for any species of marine mammals is prohibited unless priority is established for "the customary and direct dependence upon the species as the mainstay of livelihood." (MMPA Sec 109(f)(A)(iii)(III)). The Alaska Supreme Court has ruled that prioritizing resident's access to substance resources violates the equal rights clause (Article I, sectionl) of the Alaska Constitution. Thus, Alaska has an unusual mixture where federal rules apply to traditional and customary use of resources on federal lands and waters, while the State of Alaska manages those resources elsewhere. With respect to oil spill response planning, this applies to all federally-managed off shore waters. The 1994 amendments to MMPA included in Section 119 allow Secretaries of Commerce and the Interior to "enter into cooperative agreements with Alaska Native organizations (ANO) to conserve marine mammals and provide co-management of subsistence use by Alaska Natives." Since 1994, the NMFS and the FWS have entered into agreements with 10 ANOs involving 11 marine mammal species. In 1997, NMFS and FWS entered into an "umbrella agreement" with the Indigenous People's Council for Marine Mammals which was revised in 2006 (NMFS 2006). The "Guiding Principles" for this agreement include: A. Alaska Natives have a long history of self-regulation, based on their need to ensure a sustainable take of marine mammals for food and handicrafts. The best way to conserve marine mammal populations in Alaska is to provide full and equal participation by Alaska Natives in decisions affecting the subsistence management to the maximum extent allowed by law. Page 15 of 17 G. The best available scientific information, and traditional and contemporary Alaska Native knowledge and wisdom (TEW), will be used for all decisions regarding Alaska marine mammal co-management, to the extent allowed by law. Existing ethical principles for the conduct of research shall be applied. H. The goal of shared decision-making shall be through consensus, based on mutual respect. Opportunity will be provided for all issues of concern to be heard. Any decision-making structures created as a result of this agreement for co-management shall have equal representation of Alaska Native/Federal agency representatives unless mutually agreed upon by the parties. Marine mammals which are used by Alaska Natives for traditional and customary uses are directly affected by the impacts of oil and dispersed oil throughout the area from the coastline to the lower edge of the continental slope. The process for implementing the use of chemical dispersants in the event of an oil spill within the "Preauthorization Area" does not follow the co-management collaboration with Alaska Native tribal entities required by MMPA. Therefore, none of this area should be considered "preauthorized" for chemical dispersant application. 7. References Day, RA and Prichard, AK. 2004. `Biology of Wintering Marine Birds and Mammals in the Northern Gulf of Alaska". EVOS Trustee Council Final Report Restoration Project 00287. 314p Harwell, MA., Gentile, JH. Cummins, KW., Highsmith, RC. Hilborn, R., McRoy, P., Parrich, J. and Weingartner, T. 2010. "A Conceptual Model of Natural and Anthropogenic Drivers and Their Influence on the Prince William Sound, Alaska, Ecosystem". Human and Ecological Risk Assessment 16, 672-726. Hatch, SA. Meyer, PM., Mulcahy, DM. and Douglas, DC. 2000. "Seasonal Movements and Pelagic Habitat use of Murres and Puffins Determined by Satellite Telemetry". The Condor 102:145-154. Hermann, Al, Hinckley, S, Dobbins, EL, Haidvogel, DB, Bond, NA, Mordy, C, Kachel, N, and Stabeno, PJ. 2009. "Quantifying cross-shelf and vertical nutrient flux in Coastal Gulf of Alaska with spacially nested, coupled biophysical model" Deep-Sea Research H 56, 3474-2486 Hughes, SE. 1981. "Initial U. S. Exploration of Nine Gulf of Alaska Seamounts and Their Associated Fish and Shellfish Resources". Marine Fisheries Review 42, 26-33. Hunt, GL Jr., Drew, GS, Jahncke, J. and Piatt, JF. 2005. "Prey consumption and energy transfer by marine birds in the Gulf of Alaska". Deep-Sea Research II 52, 781-797. Hunt, J. 2009. "Mission without a Map". Revised ed. Exxon Valdez Oil Spill Trustee Council. Anchorage, AK. 282p Huff, GR. And Stevens, B. 2005. "Faunal Assemblage Structure on Patton Seamount (Gulf of Alaska, USA)". Alaska Fishery Research Bulletin 11, 27-36. Maloney, NE. 2004. "Sablefish,Anoplopoma fimbra, Populations on Gulf of Alaska Seamounts". Marine Fisheries Review 66, 1-12. Page 16 of 17 McNight,A., Irons, DB., Allyn, AJ., Sullivan, AM. And Suryan, RM. 2011. Winter dispersal and activity patterns of post-breeding black-legged kittiwakes, Rissa tridactyla, from Prince William Sound, Alaska" Marine Ecology Progress Series 442, 241-253. Mundy, PR (ed) 2005. "The Gulf of Alaska: Biology and Oceanography". Alaska Sea Grant College Program, University of Alaska Fairbanks. 214p. Mundy, P.R., Allen, D.M., Bo1dt, J.L., Bond, N.A., Dressel, S., Farley Jr., E.V., Hanselman, D.H., Heifetz, J., Hoperoft, R.R., Janout, M.A., Ladd, C., Lam, R.C., Livingston, P.A., Lunsford, C.R., Mathis, J.T., Mueter, F.J., Rooper, C.N., Sarkar, N., Shotwell, S.A.K., Sturdevant, M.V., Thomas, A.C., Weingartner, T.J., Woodby, D. 2010. "Status and trends of the Alaska Current Region, 2003-2008", pp. 142-195 In, S.M. McKinnell and M.J. Dagg [Eds.] Marine Ecosystems of the North Pacific Ocean, 2003-2008. PICES Special Publication 4, 393 p. NAS. 2003. "The Decline of the Steller Sea Lion in Alaskan Waters: Untangling Food Webs and Fishing Nets" The National Academies Press, Washington, D.C. 216p. NMFS. 2006. NMFS, FWS &IPCoMM. Memorandum of Agreement for Negotiation of Marine Mammal Protection Act, Section 119 Agreements. https://alaskafisheries.noaa.gov/sites/default/files/umbrellaagr06.ndf Ormseth, OA. 2014. `Forage species report for thr Gulf of Alaska". Appendix 2 of the NPFMC Gulf of Alaska SAFE Report. 37p. Piatt, JF. (ed) 2002 "Response of Seabirds to Fluctuations in Forage Fish Density". Final Report, EVOS Trustee Council Restoration Project (APEX) 00163. 453p. PICES. 2004 Marine Ecosystems of the North Pacific. PICES Special Publicationl, 280p. Proctor, P., Cokelet, ED., Mordy, CW. and Stabeno, PA. 2005 "Surface nutrients over the central Gulf of Alaska in summer: Final report for project 030654 and 040654" EVOS Trustee Council. 15p Schroder, ID, Royer, TC..and Grosh, CE. 2007. "Ekmann pumping along the Seward Line in the Northern Gulf of Alaska". Presented at PICES 16th Annual Meeting. Stabeno, PJ., Bond, NA., Hermann, AJ., Kachel, NB., Mordy, CW., and Overland, JE. 2004. "Meteorology and Oceanography of the Northern Gulf of Alaska", Continental Shelf Research 24: 859-897 Trites, AW., Miller, AJ, Maschner, HDG, Alexander, MA, Bograd, SJ, Calder, JA, Capotondi, A, Coyle, KO, DiLorenzo, E, Finney, BP, Hare, SR, Hunt, GL, Jr., Jahnke, J, Kachel, NB, Kim, H-J, Ladd, C, Mantua, NJ, Marzban, C, Maslowski, W, Mendelssohn, R, Neilson, DJ, Okkonen, SR, Overland, JF, Reedy-Manschner, L, Royer, TC, Schwing, FB, Wang, JXL and Winship, AJ. 2007. "Bottom-up Forcing and the Decline of Steller Sea Lions (Eumeopias jubatus) in Alaska: Assessing the Ocean Climate Hypothesis", Fisheries Oceanography 16, 46-67. Zimmermann, M. and Prescott, MM. 2015. "Smooth Sheet Bathymetry of the Central Gulf of Alaska". USDC, NOAA Technical Memorandum NMFS-AFSC-287. 271p. Page 17 of 17 a t I. t. 1, • RCAC `* Regional Citizens'Advisory Council /"Citizens promoting environmentally safe operation of the Alyeska terminal and associated tankers." In Anchorage: 3709 Spenard Road/Suite 100/Anchorage,Alaska 99503/(907)277-7222/FAX(907) 277-4523 In Valdez: P.O. Box 3089/130 South Meals/Suite 202/Valdez,Alaska 99686/(907)834-5000/FAX (907)835-5926 MEMBERS MEMORANDUM Alaska State Chamber of Commerce DATE: February 10, 2017 Chugach Alaska Corporation SUBJECT: Prince William Sound Regional Citizens' Advisory Council Report: "A Review of the Proposed New Escort and Support Tugs for City of Cordova Tanker Operations in Prince William Sound" City of Homer FROM: Donna Schantz, Executive Director s 1/4., City of Kodiak By July 2018, Edison Chouest Offshore will replace Crowley Maritime as Alyeska City of Seldtrvia Pipeline Service Company's marine services contractor. The services under this contract include providing escort tugs, general purpose tugs, oil recovery City of Seward storage barges, and associated personnel, all of which are key oil spill City orValder prevention and response assets for the Valdez Marine Terminal and associated oil tankers operating in Prince William Sound. As part of this transition, Edison City of Whittier Chouest Offshore is building five escort tugs, four general purpose tugs, and two oil spill response barges. This report is a review of the new tug designs and Community of specifications by Robert Allan Ltd., a naval architecture and marine engineering Chenega Bay company, commissioned by the Prince William Sound Regional Citizens' Advisory Council (PWSRCAC or Council). Community of Tatitlek The Council is an independent non-profit corporation whose mission is to promote environmentally safe operation of the Valdez Marine Terminal and Cordova District Fishermen United associated tankers. Our work is guided by the Oil Pollution Act of 1990, and our contract with Alyeska Pipeline Service Company (Alyeska). PWSRCAC's 18 Kenai Peninsul., member organizations are communities in the region affected by the 1989 Borough Exxon Valdez oil spill, as well as commercial fishing, aquaculture, Native, Kodiak Island recreation, tourism, and environmental groups. Borough The Council commissioned this report in an effort to verify that each vessel Kodiak Village Mayors design is optimal for providing the highest level of oil spill prevention and Association response capability to protect Prince William Sound and the downstream communities. The drawings and other reference materials analyzed as part of Oil spill Region this review wererovided byAlyeska in earlyNovemberthrough December 14, Environmental p y g Coalition 2016. Additional information on the vessels may exist, but was not provided to the Council as part of this review. Because information provided to the Council Port Graham may have been limited, issues identified in this review may have already been Corporation Prince William Sound Aquaculture corporation Page 1 of 2 0 Printed on Recycled Paper addressed. The Council welcomes additional information from Alyeska, and we may modify our concerns and recommendations as appropriate. While this report is complete, the review process for the vessels is ongoing. Some key concerns noted in the report include: • The bow height is low for operation in Gulf of Alaska conditions. • Design of forecastle deck invites pooling of ice and water during heavy weather. • The performance predictions for the large escort tugs are limited in scope and do not verify performance in the full range of operating conditions. • The accuracy of the seakeeping predictions for the large escort tugs is uncertain. • The indirect performance analyses were done only for calm conditions and for wind directly astern. Information provided does not identify performance in any cross-wind conditions. • A large skeg, an extension of the vessels' keel, moves the lateral center of pressure towards the back. • Mooring lines, tow lines, winches, and decks need to be free of ice and protected from freezing spray. The Council acknowledges that the transition to Edison Chouest Offshore will bring many improvements to the oil spill prevention and response system for Prince William Sound. However, we have strived to provide our concerns and recommendations early in the construction process to allow the incorporation of additional design features or modifications. It is a goal of the Council that information contained in this report be used to ensure the highest standards for oil spill prevention and response systems used to protect Prince William Sound and the people who live and work in the region. The Council believes that Alyeska's oil spill prevention and response system is one of the best in the world, and we will continue to work with industry and regulators in an effort to maintain these high environmental safeguards. The Council appreciates the information provided thus far by Alyeska to facilitate this review, and we look forward to additional information, participation, and dialogue as the transition progresses. Page 2 of 2 • ROBERT ALLAN LTD. fijr NAVAL ARCHITECTS AND MARINE ENGINEERS 230-1639 WEST 2"D AVENUE, VANCOUVER, B.C. CANADA V6J 1H3 A Review of the Proposed New Escort and Support Tugs for Tanker Operations in Prince William Sound Prepared for: Prince William Sound Regional Citizens' Advisory Council (PWSRCAC) Anchorage,AK Reference 216-036C Revision 5 February 2, 2017 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC. ROBERT ALLAN LTD. Project 216-036C Rev.5 Revision Control Sheet Prepared by: Robert G. Allan Date February 1, 2017 Revision 5 Checked by: Mike Phillips Date February 1, 2017 Revision 5 Approved by: R.G. Allan Date February 1, 2017 Revision 5 Engineer of Record: Robert G. Allan, P. Eng. Rev. Date Description By Checked Approved 1 December 12, 2016 Draft issued for Client review RGA RGA RGA 2 January 10, 2017 Some additional comments, plus revised to RGA MP RGA reflect comments from reviewers _ Text alterations to reflect late addition of 3 January 11, 2017 Alyeska memo 11/21/16 to reference mate- RGA MP RGA rial. No substantive change to conclusions Addition of discussion re dimensional dis- crepancies and impact on performance pre- 4 January 18, 2017 diction. Some minor edits and reference RGA MP RGA corrections. Notes added re low specific BP of escort tug and impact Minor text edits per Owner feedback. Ref. 5 corrected for source. Disclaimer added 5 February 1, 2017 RGA MP RGA per contract. Comments adjusted to reflect updated GA drawings received Feb.1, 2017 Confidential All information contained in or disclosed by this document is proprietary and the exclusive intellectual property of Robert Allan Ltd. This design information is reserved for the exclusive use of the client identified herein. All further use and sales rights attached thereto are exclusively reserved by Robert Allan Ltd., and any reproduction, communication or distribution of this information is prohibited without the prior written consent of Robert Allan Ltd. Absolutely no modifications or alterations to this document may be made by any persons or party without the prior written consent of Robert Allan Ltd. The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC. ROBERT ALLAN LTD. NAVAL ARC“...AND MARINE ENGINEERS Project 216-036C Rev. 5 Contents 1.0 BACKGROUND 1 2.0 REFERENCE MATERIAL 1 3.0 SCOPE OF WORK 2 4.0 DESIGN REVIEW—FINDINGS AND OBSERVATIONS 3 4.1 Escort Tugs—Damen Model 4517 3 4.1.1 Design 3 4.1.2 Performance Predictions 7 4.2 Support Tugs—Damen Model 3212 11 4.2.1 Design 11 4.2.2 Performance Predictions 14 5.0 QUESTIONS TO BE ANSWERED 14 5.1 Escort Tugs 14 5.2 Support Tugs 16 6.0 REQUIREMENTS FOR TESTING ON COMPLETION 17 6.1 Escort Tugs 17 6.2 Support Tugs 17 7.0 SUMMARY 18 7.1 Escort Tugs 19 7.1.1 Performance Predictions 19 7.1.2 General Design Configuration 19 7.1.3 Suitability for Alaskan Environment 20 7.2 Support Tugs 20 7.2.1 Performance Predictions 20 7.2.2 General Design Configuration 21 7.2.3 Suitability for Operation in Alaskan Environment 21 ANNEX A—RCAC's comments on Robert Allan Ltd.'s Review of Tugs ANNEX B—Robert Archibald's comments on Robert Allan Ltd.'s Review of Tugs * * * ROBERT ALLAN LTD. NAVAL APCnIlECIB ANO MAPINE ENtaINEEP6 Project 216-036C Rev.5 EXECUTIVE SUMMARY This review has identified many aspects of both proposed tug designs that indicate: a. A lack of thoroughness in proving suitability for purpose of the tugs, particularly in terms of overall performance and seakeeping, and b. Failure to properly address the requirements for safe and sensible operation in the Alaskan cli- mate. The latter issues are perhaps not all critical to the vessel base mission but will certainly render the boats difficult to operate and to maintain well. Some issues are critical to the safe operation of the boats and must be clarified with some urgency. Many other issues are raised that are simply good de- sign practise issues that could be revised at minimal cost to provide a safer and better operating envi- ronment for the crew, and result in less downtime and lower long term maintenance. The most critical aspects of the design review are summarized below, categorized for each vessel type according to: • Performance Predictions, • General Design Configuration, and • Suitability for Operation in Alaskan Environment A. ESCORT TUGS 1. Performance Predictions • Indicated specific Bollard Pull (BP) (tonnes/kW) is about 15% lower than what would be considered "normal" for a large Z-drive tug. Difference to be resolved. If result is actually higher than stated this could adversely affect stability analyses and winch design • There was no evidence presented to indicate that this new hull form has been model test- ed to prove that all performance objectives will be met, or to verify fitness for purpose, as one would expect in a fleet investment of this magnitude. • The existing performance predictions for the large escort tugs are very limited in scope and do not prove performance in the full range of operating conditions • The seakeeping predictions are suspect in their accuracy • The indirect performance analyses were done only for calm conditions and for wind direct- ly astern. This does not identify what happens in any cross-wind condition. Discrepancies in vessel dimensions between referenced documents indicate that the indirect escort per- formance must be re-calculated for the latest vessel dimensions ROBERT ALLAN LTD. NAVAL PCNiTECiB ANO xPINf ENOIxEEP4 Project 216-036C Rev.5 2. General Design Configuration • The forecastle deck area presents a significant "pool" to hold water when operating in heavy seas. This could result in serious seakeeping issues • Given the high windage of this tug, and the presence of a very large skeg which will hinder lateral mobility/manoeuvrability, a bow thruster should be strongly considered for ship- handling operations at low speed • Experienced tug Masters familiar with the SERVS tug operations advise that the fendering arrangement shown on the GA drawings will be insufficient for the PWS operations. • No information has been provided with respect to the structural design of these tugs, and in particular with regard to the ice-strengthening of the hulls. Some ice-reinforcement is es- sential • The bow height (to the knuckle at the bottom of fender) is extremely low for operation in the Gulf of Alaska: one should be very concerned about how this shape will perform in 4 to 6+metre seas • Refrigerators oriented transversely (doors opening athwartships) will spill their contents regularly; relocate • The galley range/oven is oriented transversely (facing athwartships) and thus represents a hazard to galley crew. Suggest relocate to a transverse bulkhead as close to CL as possible. • Consider providing lavatories close to bridge and to machinery control room • Berths on the main deck level should be relocated to inboard bulkheads if possible and NOT be oriented transversely • Consideration should be given to providing natural light to all crew cabins • Consideration should be given to a crew lounge area separate from mess room • Consideration should be given to fitting a crew exercise room 3. Suitability for Alaskan Environment • In the absence of a Specification for this vessel it is unclear what measures have been taken in the design to cope with the heavy snow and sub-freezing temperatures prevalent in the operating area in winter. The following, in particular, are of serious concern: - measures to prevent ice/snow plugging the freeing ports in the fore deck well - measures for deck heating in all exposed working areas to prevent ice/snow accu- mulation. - methods/locations for protected/heated storing of mooring and other working lines - means of protecting winches from water ingress into shelters and from freezing spray - prevention of freezing in potable water and fresh water ballast tanks adjacent to the shell - protection from freezing in ALL piping systems and especially those exposed to weather such as drain lines - eliminate any topsides deck drains routed inside deckhouses - all window wipers must be equipped with heating elements and provision for adding anti-freeze to window-washing solution ROBERT ALLAN LTD. NVI•PCXITECl9 AHD MPINE ENOINEEPB Project 216-036C Rev.5 • In many locations berths are placed adjacent to outboard bulkheads. This is poor design practise for cold climates, especially on a larger vessel such as this. Outboard locations are coldest,and have maximum motions leading to crew discomfort and fatigue B. SUPPORT TUGS 1. Performance Predictions • Very little information is provided about performance beyond the indicated BP of 65.8 tonnes from 4,480 kW. These figures indicate a very poor specific performance. Typically, that much power (6,005 BHP) should deliver closer to 75 tonnes BP. This discrepancy should be explained/resolved soonest. • This performance should also be compared to that of the Crowley "Invader" class tugs to verify that equivalent BP performance is being offered. • Provide evidence that the tug complies with USCG Towline Pull Stability criteria. • Provide full details of Fs and Fb capability at 8 and 10 knots, within recognized escort sta- bility criteria • Demonstrate that the fixed pitch propellers will not stall the main engines in the full range of operating conditions • The performance of this tug in all its intended roles should be clearly demonstrated by thor- ough analysis BEFORE the tugs are delivered 2. General Design Configuration • The interior layout of the support tugs is inappropriate for the Alaskan environment and should be reviewed in detail. Specific issues are: - lack of a wet room or even wet gear lockers at the entry - the small tables in the mess will accommodate two people each at best,not the total of six persons indicated - bunks in the staterooms are located against the cold exterior bulkheads and some are oriented transversely; definitely not advisable, especially in a cold climate and where high seas are expected • Provide details of the Fi-Fi system • Review/approve details of the forward winch for indirect escort operations • The arrangement of the stern tow-pin/roller system is vulnerable to contact damage when barge handling. Configuration should be reviewed and submitted for review/approval • Ladder from fore deck to boat deck is too steep and potentially dangerous. Recommend that all ladders and gratings be GRP to minimize risks in snow/icy conditions • Details of stern fendering and towing arrangement to be provided and reviewed/approved by Masters familiar with local towing operations and conditions • Deck locker space is inadequate for mooring and towing gear,etc. in the cold climate ROBERT ALLAN LTD. Project 216-036C Rev.5 3. Suitability for Operation in Alaskan Environment • Provide details to demonstrate suitable drainage, ventilation and heating in ALL gear lock- ers to ensure lines are all readily usable in all weather conditions • Accommodation arrangement must be addressed to deal with cold climate and keeping inte- rior of the tug clean. Arrangement is completely inadequate as shown • Define the measures taken to ensure safe operation in the Alaskan environment, and specif- ically: - hull strengthening measures for operation in ice - measures for deck heating in all exposed working areas to prevent ice/snow accu- mulation. - methods/locations for protected/heated storing of mooring and other working lines - means of protecting winches from water ingress into shelters and from freezing spray - prevention of freezing in potable water tanks adjacent to the shell - protection from freezing in ALL piping systems and especially those exposed to weather such as drain lines - revising any topsides deck drains routed inside deckhouses - ensure all wipers are equipped with heating elements and provision for adding anti- freeze to window-washing solution In conclusion, neither design is sufficiently well-defined in terms of its expected performance to be declared unreservedly as "fit for purpose". Both designs suffer from design/layout issues which will render the tugs difficult and potentially unsafe to operate in Alaskan sea and weather conditions. The issues of performance verification must be addressed quickly in order to prove that the entire op- eration will provide at least the same degree of safety as the existing operation long before the new tugs arrive on station. The design issues must be addressed immediately before construction is so far advanced as to render changes impossible to accommodate without significant cost and delays. The measurement of actual performance cannot be performed until the vessels are delivered, but more extensive analysis can and must be done to prove that the necessary performance can be achieved in all the boats before delivery. It must be stated that waiting until completion of these vessels is much too late to identify any potential shortcomings in the designs. The deficiencies identified in this report should be re- solved immediately in order that changes can be made during production design/construction at lower cost and time impact than if only considered on completion. ROBERT ALLAN LTD. NAVAL ANL n„LL,s,NM. .LN41Nk 5 Project 216-036C Page 1. Rev.5 A Review of the Proposed New Escort and Support Tugs for Tanker Operations in Prince William Sound For: Prince William Sound Regional Citizens' Advisory Council (PWSRCAC) Anchorage,AK 1.0 BACKGROUND Robert Allan Ltd. was retained by the Prince William Sound Regional Citizens' Advisory Council (PWSRCAC) (the Client), "To advise and provide input to PWSRCAC with regard to the design, testing and commissioning of the proposed new ECO (Edison Chouest Offshore) es- cort and support tugs for Prince William Sound.” This report comprises the findings as related to the pre-construction and required testing of the subject vessels. Further analysis will be required upon completion and trials of the vessels. The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC. 2.0 REFERENCE MATERIAL The following information was provided by the Client and was used as the basis of this evalua- tion: a. Escort Tug Drawings: • Damen 4517 - General Arrangement(in 10 constituent parts) - Specification Sheet - NAS Dwg. # 0315-331-002-00 "General Arrangement Design Plan" (received February 1, 2017) b. Support Tug Drawings: • Damen 3212 - General Arrangement(in 9 constituent parts) - Specification Sheet - NAS Dwg. # D2 "General Arrangement-Tethered Es- cort Tug" (received February 1, 2017) ROBERT ALLAN LTD. NAVAL•PCNiIECIf AND Y�PINE ENDINEf PB Project 216-036C Page 2. Rev.5 c. Other Material/References: • [1] Valdez Tug Escort Simulations-Rudder Failure Simulations(Glosten- July, 2016) • [2] TugSim Calculation report—Damen Shipyards • [3] ASD 4517 Seakeeping Analysis Rev.10 • "Tug Comparison Slide" -Powerpoint Slide • D2_Ross Utility AHTS for Alyeska Pipeline,Rev. P1 • Transition Plan • Marine Contract Transition(pages 1 and 2) • New Vessels Description(08/25/16)-Powerpoint Slides • [4]New Vessels Description(09/12/16) -Powerpoint Slides • Participant Team Meeting 08/18/16-Powerpoint Slides • [5] Alyeska Memorandum: 11/21/2016 from M. Day to P. La Pella re "Vessel Intend- ed use" Additional material was provided describing the planned oil recovery barges, but those vessels were not defined as part of the mandate for this work and have not been reviewed. 3.0 SCOPE OF WORK The following is the mandate given to Robert Allan Ltd. with respect to this review: a. To review the design drawings provided and comment on overall configuration of both the escort and support tugs as to suitability for purpose. b. To provide a list of items/questions which PWSRCAC may raise with the Propo- nents/Service Providers to verify that the performance objectives for these tugs will in fact be met. c. To provide a list of items which PWSRCAC should ask to be verified during the com- pletion,testing and trials of the vessels before fmal acceptance. d. To review and comment on fmal Tests and Trials data to identify any shortcomings. This report obviously can cover only points (a.), (b.) and (c.)until such time as the vessels are built and tested. ROBERT ALLAN LTD. NAVAL ARCHIVES'S AND YARINE ENGINEERS Project 216-036C Page 3. Rev.5 4.0 DESIGN REVIEW—FINDINGS AND OBSERVATIONS 4.1 Escort Tugs— Damen Model 4517 4.1.1 Design The profile and main deck plan views of the proposed vessel are illustrated in Figure 1 below: It u< n; u: IE -- #1-a a=' r. _ au► ice_ ��/il .111111‘,I".t�s"7i 0 —g vielkiQ—�� 11)))11)))) )l��I►)�►» UUc _—-- tri, , t7I '✓IMOI•' __ a_ '_, iur1 .� 1a.9s0 •r .• y ami C *itiru. ," wini n 51 Lw.p d ; --iii 1714 w - I 7. Milo; --=-Iii,;..iiil i 1':, - I 04 1�,1 ;,w nom., �s����\� Figure 1 General Arrangement of Damen 4517 Tugboat ROBERT ALLAN LTD. NVI•xDXITECT3 AND YxINE ENDIxEEN3 Project 216-036C Page 4. Rev.5 The following are the most critical observations concerning the overall design and general con- figuration of this tugboat in order to assess "fitness for purpose". There are numerous other minor design critiques which could have been included, but are not in this review as they are not related to primary escort or towing performance or basic safety, but relate more to crew comfort and general operational sensibilities based on experience, and thus may be construed as too "personal" a critique of the design. The following issues however are critical to the success of the tugs in the intended operation and must be addressed: a. The 5.45 metre draft noted on the General Arrangement is presumably the moulded draft to the moulded keel line (USK) and NOT to the underside of the skeg. ECO to advise the total maximum navigational draft as this is the value most critical to the safe navigation of the tug. (Note: Based on other dimensions given, the max. draft is calcu- lated as 8.15 metres(26.75 ft.)) b. The skeg is inordinately large for this type of tug, and accordingly moves the centre of lateral pressure further aft than desirable for efficient escort operations. ECO should be asked to present calculations defming why such a large skeg is necessary and how "fail- safe" operations are assured in the event of any tug propulsion or towline failure during indirect escort operations. c. The forecastle deck area presents a significant "pool" to hold water during heavy seas, even with the freeing ports shown there. When this area fills with water the added trapped weight will severely impede the ability of the tug to rise back up in time to avoid the next large wave. ECO/Damen should define how long it will take to clear wa- ter from this space in a rough weather transit, and relate that to typical wave heights and wave periods in the area? d. In the absence of a Specification for this vessel it is unclear what measures have been taken in the design to cope with the heavy snow and sub-freezing temperatures preva- lent in the operating area. ECO must present detailed information with respect to the following measures, and revise the design accordingly to ensure safe operations in Alaska: 1. Prevention of ice/snow plugging the freeing ports in the fore deck. 2. Measures for deck heating in all exposed working areas to prevent ice/snow ac- cumulation. Note: experience has shown that the ONLY really effective means to accomplish this is by use of a substantial steam generator and the fitting of heating lines in a composite compound poured on the decks, in combination with a hose/steam lance which can be used to clear any build-ups on deck quick- ly. 3. Methods/locations for protected/heated storing of mooring and other working lines. 4. Means of protecting winches from water ingress into shelters and from freezing spray. 5. Prevention of freezing in potable water and fresh water ballast tanks adjacent to the shell. 6. Protection from freezing in ALL piping systems and especially those exposed to weather such as drain lines. ROBERT ALLAN LTD. NAVAL•PGNitECtB,PO NPiNE ENOINEEPB Project 216-036C Page 5. Rev.5 7. Clarify whether any topsides deck drains are routed inside deckhouses. Note: although this is common practise in many shipyards it is an absolute "No-No" in the design of ships for arctic/subarctic conditions. Downpipes MUST be exter- nal to deckhouses in their entirety and should be designed to be easily remova- ble/replaceable in the event of plugging/freezing. 8. All window wipers must be equipped with heating elements and with provision for adding anti-freeze to window washing solution? e. There is no bow thruster on this tug. It is our experience that when a tug of this size is used for ship-handling, as these will be, Owners find that a bow thruster is highly desir- able and even essential. Even though the Z-drives give significant control of heading, a bow thruster can provide a significant controlling influence over lateral movement at low speeds and reduce the amount of stem thrust needed to control the tug. Given the high windage of this tug, and the presence of a very large skeg,hindering lateral mobili- ty, a bow thruster should be strongly considered. f. There is only one primary means of access/egress each to the crew spaces on the main deck and on the fo'c'sle deck. On the fo'c'sle level this access is only on the port side. Has this arrangement been approved by Class for compliance with SOLAS? Do the Owners consider this configuration to be safe for the crew? Direct access/escape routes on both sides of the tug should be standard and safe practise on a tug of this size. (Not- ing that other routes DO exist in the design but involve rather convoluted egress through multiple doors and corridors) g. Good design practise would place the refrigerators in the pantry on a transverse bulk- head(rather than on the longitudinal bulkhead as shown), as tugs pitch far less than they roll. With the refrigerators/freezers located as they are, their contents will be regularly found on the deck. Re-arrangement strongly advised. h. The galley stove/range is also located on a longitudinal bulkhead which is potentially very dangerous for the galley crew during open water transits when the tug will be roll- ing. Strongly advise this be located on a transverse bulkhead and as close to CL as pos- sible i. This vessel will not satisfy current crew accommodation standards for a tug of this size in any country signatory to the Maritime Labour Convention (MLC) 2006. Although the USA is not a signatory to this ILO document, it is nevertheless a very useful refer- ence to current modem and good practise in designing vessels for safe and comfortable crew operations. If the crew are uncomfortable or unable to get proper rest they will be fatigued and make poor judgments in critical situations. While some exemptions to the MLC requirements are permissible on vessels< 3,000 GT, such exemptions can only be granted by a "competent authority" which would presumably be the US Coast Guard(if applicable). The following aspects of the present arrangement are of particular concern, and should be addressed: ROBERT ALLAN LTD. NAVAL.NGXIlELTB AND Y.NINE ENOINEENE Project 216-036C Page 6. Rev.5 i.(1) Standard A3.1 — Accommodation and Recreational Facilities — Paragraph 11 b calls for "...sanitary facilities within easy access of the navigating bridge and the machinery space or near the engine room control centre." No such facilities are indicated on this large tug in either location. Given the critical nature of its role such an oversight could be considered as po- tentially dangerous or at the very least highly inconvenient if the officers in charge need to leave the bridge or control areas for any period of time. i.(2) Crew Fitness Space: MLC Guideline B3.1.11 — Recreational Facilities, Mail and Ship Visit Arrangements — Paragraph 4d calls for "sports equipment, including exercise equipment...". While this may not be man- datory, it has been standard practise to include this sort of facility on mod- em tug designs for the past 5 years at least, and especially so in a large vessel like this. This contributes to crew alertness and general well-being. Nothing is shown on the GA. An alternative (possibly preferable) would be to provide suitable facilities ashore which are readily accessible to the crew. i.(3) Although not a strict requirement of MLC 2006, it is strongly advised to provide a crew lounge space, distinct and separate from the mess area. This is good design practise in any vessel of this size and provides crew the option of a quieter rest area than just the confined mess space. j. Berth Arrangements: The arrangement of sleeping berths is not conducive to crew comfort or safety in the Alaskan environment. Numerous bunks are located outboard against the cold ship's side and where motions are at their maximum. This will lead to crew discomfort and fatigue especially on any Sentinel missions in the open gulf. Sev- eral other berths are oriented transversely which is potentially dangerous in a rolling ship. The crew rooms on the main deck are now shown(latest GA) without any source of natural light via portlights or similar. That may lead to crew complaints. k. Fendering: Experienced Masters familiar with the PWS tug operations advise [Annexes A and B] that the fendering arrangement shown on the GA drawings will be insufficient for the PWS operations. Their recommendations include: 1. increase the fendering by adding 2,000 mm x 900 mm tires forward of frame 52 (on top of the cylindrical fenders), and 2. replace the 1,600 mm x 590 mm tires aft with 2,000 mm x 900 mm tires 1. Ice Strengthening: No information was provided with respect to the structural design of these tugs, and in particular with regard to the ice-strengthening of the hulls. Periodic ice impact damage is a fact of life with the present tugs in the area and measures must be taken to mitigate that risk. ECO must provide details of any ice-strengthening measures taken with regard to the hull, appendages (such as bilge keels) and the Z- drives and propellers.). ROBERT ALLAN LTD. NV.E.ENLNiTECt9 AND NRiNE ENDINEENB Project 216-036C Page 7. Rev.5 4.1.2 Performance Predictions a. This vessel is quite different than any tug previously built by Damen and much larger than any of their standard tug designs. The hull shape also has considerable side flare, different to almost all other Damen tug designs which are wall-sided. There was no evidence presented to indicate that this new hull form has been model test- ed to prove that all performance objectives will be met or to verify fitness for purpose, as one would expect in a fleet investment of this magnitude. Some calculations have been done to demonstrate the escort performance, [1], [2], and sea- keeping performance [3] of the tug, but there are serious reservations concerning the com- pleteness and adequacy of these evaluations. Model tests or some equivalent analysis should be conducted to verify: i. Free running speed at 50, 75,and 100%power in calm conditions. ii. Free running speed in 1, 2, 4 and 6 metre seas to establish response speed and wet- ness. iii. Self-propulsion tests to verify thrust deduction, manoeuvrability, and directional control. iv. Seakeeping in head, stem and oblique seas at a range of speeds, with measurement of motions and accelerations at key control and working deck locations. v. Steering and braking forces in calm conditions and in waves for a range of speeds. b. It is noted that Reference [2] describes the desktop analysis (using "TugSim") of the tugs capabilities in calm water escort, but it is debatable whether such an analysis is viable for this design when all the hydrodynamic coefficients used are (presumably) based on much smaller vessels. At the very least a Class-approved CFD analysis should have been per- formed to predict the escort forces,but as noted above a comprehensive model test program really is required to demonstrate that all aspects of this design satisfy the mission demands. c. Ref. [1]uses Glosten's "ShipMan" and "TugMaster"programs to identify the distances trav- elled by a disabled tanker under various emergency response scenarios. These all assume either calm conditions or winds only directly astern. Offset distances will be significantly different under any beam-on or oblique wind directions. The results given must therefore be considered inconclusive. Alyeska should require that the analysis include some cross-wind elements in order that the boundaries of safe operation can be properly defined for all operational areas. As- sumptions of direct astern or zero wind are extremely limited in order to declare this tug as fully capable for the intended service. ROBERT ALLAN LTD. x.LV,L,NCNiEC18 AMD M.VNINE ENOINEEx6 Project 216-036C Page 8. Rev.5 In his review of Rev. 1 of this report, [Annex A], Capt. Leonard makes the point that during the development of the current PWS tug system the omission of sufficient testing and proof of performance at the initial stages ultimately resulted in extensive delays to the project, and he reinforces the need for further performance review in this case. d. Ref. [3] reports on the predicted seakeeping performance of this tug. The analysis however is based upon the use of the software program Shipmo PC. That software was developed for the motions predictions of ships with relatively high length/beam ratios and of more normal hull form. It is our direct experience that this software can be extremely unreliable for predicting motions of vessels such as tugs with low length/beam ratios (<3) , and espe- cially so when the vessels have large appendages such as an escort skeg and Z-drives, and is even more unreliable in more extreme sea states. It is our opinion that the results pre- sented are unreliable unless they could be correlated directly to some physical model test- ing. The roll and pitch amplitudes and accelerations at the control centres and on the working deck positions should be carefully analysed by a verifiable method (model testing or similar) in order to properly consider crew safety and fatigue issues for these critical missions, and to verify the design criteria for the critical winches. Captain Leonard in his review [Annex A] makes the point that a CFD analysis could be considered to assess the performance of both vessels. This is partly true,but it is important to note that any such CFD analysis of indirect towing performance in particular can only be accurate if the analysis method has been validated against a sufficient number of full-scale and model-scale tests results. To our direct knowledge there are a very limited number of organizations worldwide which have this ability with methodologies approved by Class, of which Robert Allan Ltd was the first. e. There are discrepancies concerning the vessel main particulars between the documents pro- vided which could have an important bearing on the predicted performance results. The ta- ble below illustrates the differences encountered within various references. While some of these can be explained by different load conditions at which different analyses were per- formed, the critical difference is in the overall length. The length used in calculating the indirect steering forces is almost 2 metres longer than that shown in the other documents. This would have a significant difference in the calculation of indirect steering forces which are directly proportional to underwater lateral area. The discrepancies in overall draft are al- so concerning as this affects force predictions as well as being a potential major navigation- al limitation. ROBERT ALLAN LTD. MAXNAVAL L,IS AND « s Project 216-036C Page 9. Rev.5 Discrepancies re particulars-Damen 4617 Class tug Tug Sim Seakeeping Tanker Escort Source Data Sheet Analysis Analysis (Ref.2) Simulations (Ref. 1) (Ref.3) item Dimension m. m. m. ft m. a Loa 42.79 44.5 42.77 140.4 42.79 b Lwl 40.99 n/a 41.25 c Beam,moulded 16.50 16.42 16.48 54.1 16.50 d Depth,moulded 7.00 7 7.01 23 7.00 e Total Depth(incl. skeg) 9.70 9.70 f draft,hull 5.45 4.75 15.6 5.00 g draft overall 8.15 7.25 7.70 h freeboard 1.55 2.00 i Displacement (tonnes) , 2158 1639 1885 1856 1993 (Tonnes) (L.Tons) =calculated value from other particulars given At the very least the TugSim analysis should be re-done to reflect consistent dimensions with the other documents, and proof of performance be verified. Actual maximum operat- ing draft must be clearly defined. f. The bow height (to the knuckle at the bottom of fender) is extremely low for operation in the Gulf of Alaska; one should be very concerned about how this shape will perform in 4 to 6 metre seas. It is strongly recommended that at the very least the knuckle be raised as high as possible to just support the fenders. In addition, details of fender attachment and support should be provided to demonstrate that the significant vertical wave forces which will im- pinge on the fendering can be properly resisted. ROBERT ALLAN LTD. ", MAI 1e ',Li, Project 216-036C Page 10. Rev.5 g. The bow form is extremely bluff as illustrated in Figure 2 below showing a model of this boat: • 1 t .;?•. 1 ) Figure 2 Model of Damen 4517 Tug, Indicating Bluff Forward Shape and Low Effective Bow Height to Bottom of Fenders (see also 0/B Profile Drawing) The combination of the bluff shape and low knuckle height will result in high speed loss in waves and a generally wet boat. Model testing should be performed in order to define speed loss in waves, particularly for any Sentinel tug mission. ROBERT ALLAN LTD. NEVEE PCxI1EC16 AND MhxiNE ENOINEExB Project 216-036C Page 11. Rev.5 4.2 Support Tugs-Damen Model 3212 4.2.1 Design The Damen 3212 is a standard harbour tug produced by that company. The General Arrange- ment for this design is indicated in Figure 3 below. uc; - IIE 11$ !11u,•_ _e1; 107 tti sl n r_•.m n6 !Tmeii�a .illai.� la Li mum 0 0 e Adp• itia,*111...ii '1------Teitti*.), )' __0 Ate, "t--�� w�-.*� 4PT�•-��a1�1-��si.••• 1 i- --a I 1 r 'I ' - r T T1-�---- 1101011.111 WIM ;y,1 ________- .--77......., morti._, I iiir4 .1... r, r____ 4 _____ % . -r , n ligic- . i 111' `!1 -r:: 1: .SII I J pry K.,.................._ II - i ii 14 irl -. ....:. .... ..... int' 77_ .10,, ..,-,, -ok .....____ „Ili, MAI' DECK - In Figure 3 General Arrangement of Damen 3212 Tugboat ROBERT ALLAN LTD. uv •ncMirecre•uo ur.niue euaiucana Project 216-036C Page 12. Rev.5 The following are observations regarding this design for the intended application,which, ac- cording to Ref. [4], includes barge towing, fire-fighting(two tugs only), and oil"detection" (no mention of spill response or recovery capability). Reference 4 does not mention tanker escort operations at all,but Reference 5 describes a rather more extensive role for these smaller tugs which includes the following: • Tethered escort of ships under—90k DWT(Primary Escort) • Untethered escort of ships(Secondary Escort) • Ice Reporting Vessel • Ice Scout Vessel • Sentinel Escort • Emergency Towing • Off-vessel fire-fighting(two tugs only) • Ship docking and undocking • Recovery, storage, lightering,and nearshore barge towing, support, and operation For purposes of this review it has been assumed that Ref. 5 is the operative document which de- fines the full mission of these tugs. This assumption/conclusion however results in some serious issues with respect to the suitabil- ity of this 32 metre (105') tug design for all of these roles, and in particular in what weather conditions is it able to perform each of these roles safely. It is also alarming to read in Ref 5 that "We do not intend to prove or test this [tethered escorting of< 90K dwt tankers] during contract transition. Our intention is to perform testing following a successful transition." (em- phasis added). It is strongly recommended that this position be challenged. It should be imperative that the performance of these tugs in all intended roles be clearly demonstrated by careful analysis and/or simulations at the earliest possible stage of this transition in order that there can be confidence in the end result. To wait until everything is in place and only then verify vessel performance invites significant technical risks to the project which could then result in delays. The following are the more critical aspects of the 3212 design requiring review: a. The tugs are fitted with fixed pitch (not controllable pitch) propellers. This will be problematic for indirect escort work, as the probability for stalling the engines is very high. An analysis of available engine torque vs propeller load should be presented to show that there is no risk of engine stall throughout the full operating range of rpm and azimuth angles b. Details must be provided demonstrating the expected indirect and direct towing perfor- mance at 8 and 10 knots, in compliance with a recognized standard for escort towing stability ROBERT ALLAN LTD. ....w „Ea .o MwE Eo.EEas Project 216-036C Page 13. Rev.5 c. Details must be provided for the escort winch and all associated cordage; the winch must have a render-recover capability in keeping with the escort rating of the tug. The data sheet indicates a "dynamic line force" of only 15 tonnes for this winch which is se- riously inadequate for escort work in Alaskan waters. It is strongly recommended that this winch be electric driven rather than hydraulic for the required performance, as well as being far superior in cold climate operations. It is further noted that this is a single drum winch only which provides no quick backup in case of a line break. That seems an inappropriate selection for such a critical mission. Winch specification must be re- viewed/revised in the context of predicted indirect forces d. The drawings provided do not indicate the Fi-Fi system described for two of the tugs. Details should be provided, including: one pump or two? driven from main engine PTO(s) or by independent engine? In addition, details of how the system can be thor- oughly drained, flushed and purged to cope with the effects of(a) residual salt water, and(b)freezing conditions, must be provided e. The arrangement of the stem tow-pin/roller system as shown is problematic: it will snag towing gear in the right angle space created between the pin "table" and the bul- warks. The top surface needs to extend diagonally outward to intercept the bulwarks at about a 45° angle and have no corners or overhangs to catch SWR sockets, shackles or similar towing fittings. Also, the position of the roller portion of these two-pin set is ex- tremely vulnerable to contact damage when barge-handling. These rollers are normally set well forward of the contact area and are protected by fendering. Detailed drawings should be provided for approval f. The main deck accommodation layout is inappropriate for the Alaskan climate: i. There is no wet room or even wet gear lockers at the entry. The main entry leads directly into the tiny mess area with no place to put wet boots, coats, etc. Maintaining this area in a semi-clean condition will be impossible. The mess space is tiny and abuts the main access corridor ii. The small tables in the mess will accommodate two people each for meals at best, not the total of six persons indicated. Although seats for six are indicated the table area will not be sufficient for all those people to eat comfortably iii. Bunks in the main deck staterooms are located against the cold exterior bulk- heads and are oriented transversely which can be very dangerous for crews in heavy seas; alternate configurations should be evaluated g. Ladder from fore deck to boat deck is very steep ... potentially dangerous, especially in snow or icy conditions. It is also strongly advised that any exterior ladders and gratings be constructed of GRP to minimize potential for snow and ice accumulation. ECO to define what is presently specified for ladders and gratings and if necessary change for best crew safety h. Fendering on the stem looks inadequate. Details of fendering and towing arrangement to be provided and reviewed/approved by Masters familiar with local towing operations and conditions i. Configuration of quarter bitts aft: it is suggested that these bitts are too far aft and pre- sent a risk of the towline being snagged on the forward side. Bitts should be positioned closer to Frame 18, at least abeam of the spooling gear ROBERT ALLAN LTD. NAAAE ARGNITEG TS AND MARINE ENGINEERS Project 216-036C Page 14. Rev.5 j. Deck locker space is totally inadequate for towing gear etc. in the cold climate. Provide details to demonstrate suitable drainage, ventilation and heating in ALL gear lockers to ensure lines are all readily usable in all weather conditions 4.2.2 Performance Predictions Very little information is provided beyond the indicated BP of 65.8 tonnes from 4,480 kW. However these figures seem to indicate a very poor specific performance. Typically, that much power (6,005 BHP) should deliver closer to 75 tonnes BP. This discrepancy should be ex- plained/resolved soonest as it indicates that excessive fuel will be used for the defined per- formance. If the BP is under-predicted then the overall stability of the tug and the winch per- formance could be affected. This performance should also be compared to that of the Crowley"Invader" class tugs to verify that equivalent BP performance is being offered. Contrary to the statement in Ref. [51,the performance of this tug in all its intended roles should be clearly demonstrated by thorough analysis BEFORE the tugs are delivered, and ideally be- fore they are even built. 5.0 QUESTIONS TO BE ANSWERED Based on the previous observations, the following are the critical questions that need to be an- swered, ideally long before the vessels are delivered and better yet before construction advanc- es any further. 5.1 Escort Tugs a. Explain why this new unproven design(for multiple vessels)was not model tested to verify all aspects of performance for such a critical mission. b. Advise the total navigational draft,not just the moulded hull draft. c. Ask to have Damen/ECO resolve the discrepancies regarding the main dimensions of the escort tug and re-analyze escort forces to reflect true size d. Advise why the specific BP performance(tonnes/kW power)for this tug is as low as it is. e. How long will it take to clear water from the forecastle deck space in a rough weather trans- it, assuming a green water event? Relate this time to associated wave heights and wave pe- riods in Gulf of Alaska storm conditions f. Has the arrangement of accesses and escapes to the main deck accommodation been ap- proved by Class and USCG for compliance with SOLAS? Do the Owners consider this configuration,with only one primary access on each deck level,to be safe for the crew? ROBERT ALLAN LTD. PweE encnnacre eno wnninE EPOIPk EPB Project 216-036C Page 15. Rev.5 g. Good design practise for modern tugs should demonstrate compliance with the require- ments of the Maritime Labour Code-2006 (MLC-2006), even if in this instance the USA is not a signatory to that ILO standard. "Although the Convention has not been ratified worldwide, it has widespread effect because vessels from non-signatory states that attempt to enter ports of signatory states may face arrest and penalties for non-compliance with the MLC." (Source —Wikipedia). In particular the designers should address the perceived shortcomings with MLC-2006 sections: • B3.1.5; Paragraph 7 • A3.1; Paragraph l l b • B3.1.11; 4d h. Expand the indirect towing/tanker save analysis to include some cross-wind elements in or- der that the boundaries of safe operation can be properly defmed. Assumptions of direct astern or zero wind are extremely limited in order to declare this tug as fully capable. The analysis should reflect the full range of Met-Ocean conditions existent at the designated lo- cations,not just two very limited conditions. i. Provide evidence that the Shipmo 3D motion predictions for this vessel can be verified through correlation to full-scale or model-scale measurements. How have the effects of skegs, bilge keels, and thrusters been accounted for in the prediction? Ideally predict the motions based on a seakeeping model test rather than on this computer analysis. j. Provide predictions of speed loss in waves (at least for Hs = 2, 4, and 6 metre) for this hull form to prove it can perform the Sentinel tug role adequately, particularly with regard to sustaining response speed in waves. k. Define the method by which towline force information will be relayed to the tug Master during escort operations. Describe how the hawser winch complies with the Class require- ments for rendering/recovery at defmed stability limits for the tug. 1. Provide evidence that the tug can perform reasonable station-keeping or some side-stepping in the ship-assist mode without the aid of a lateral bow thruster m. Describe all measures that have been taken to equip these vessels for year-round operation in the Alaskan climate; specifically address issues of deck heating, line storage and heating, prevention of shell tank contents and water line freezing throughout the ship n. Describe what measures will be taken to protect hydraulic lines and control components to the winches in cold weather, and to ensure winch operation in such conditions. o. Describe the full details of all towing lines, towing gear and hawsers to be fitted aboard the vessel. Provide SWL and breaking strengths for each component, and the criteria used to establish the relationships between components relative to winch brake capacities and line pulls. p. Describe what ice-strengthening is incorporated into the hull. ROBERT ALLAN LTD. MV1L•RCNilEClB AMD YRixE EROixEEP6 Project 216-036C Page 16. Rev.5 5.2 Support Tugs a. Advise why the predicted BP for this standard tug is only 65.8 tonnes with 4,480 kW of in- stalled power. b. Describe in detail the predicted Fs and Fb at both 8 and 10 knots? c. Provide evidence that the tug complies with USCG Towline Pull Stability criteria and a recognized escort stability criteria. d. .Define the arrangements for fire-fighting on two of these tugs. e. Provide full details of the escort winches and the associated cordage. Prove the winch capa- bilities are commensurate with the intended escort missions in the full range of intended sea conditions. f. Describe all measures that have been taken to equip these vessels for year-round operation in the Alaskan climate: specifically address issues of deck heating, line storage and heating, prevention of line freezing throughout the ship. g. Describe what measures will be taken to protect hydraulic lines and control components to the winches in cold weather,and to ensure winch operation in such conditions. h. Describe the full details of all towing lines, towing gear and hawsers to be fitted aboard the vessel. Provide SWL and breaking strengths for each component, and the criteria used to establish the relationships between components relative to winch holding and brake capaci- ties and line pulls. i. Describe what ice-strengthening is incorporated into the hull. ROBERT ALLAN LTD. HVL PCHIIECIE AND YIPINF ENDINEEPE Project 216-036C Page 17. Rev.5 6.0 REQUIREMENTS FOR TESTING ON COMPLETION It must be stated that waiting until completion of these vessels is much too late to identify any potential shortcomings in the designs. The deficiencies identified in this report should be resolved immediately in order that changes can be made during production de- sign/construction at lower cost and time impact than if only considered on completion. The following are critical performance parameters that should be established on final testing and trials of the tugs in order to establish the benchmark for all subsequent performance moni- toring: 6.1 Escort Tugs • Full range of stability conditions; intact,towing, escort operations • Damaged stability analysis(is a one-compartment standard of subdivision achieved?) • Bollard pull, ahead(over range of rpm): Provide Class certificate • Bollard pull, astern(over range of rpm). Provide Class certificate • Maximum Indirect Steering Forces at 8 and 10 knots, (within Class stability limits) and the tug position and attitude at which these forces are generated. Provide Class certification of maximum F3 • Maximum Indirect Braking Forces at 8 and 10 knots, (within Class stability limits) and the tug position and attitude at which these forces are generated • Maximum transverse arrest force at 6 and 8 knots • Maximum direct astern braking force at 6 knots • Fi-Fi system performance measurements proving compliance with Class Notation • Free running speed in calm conditions at 50, 75, 90, and 100% rpm. Proof of directional stability/controllability during typical manoeuvres, running ahead and astern, and specifi- cally while manoeuvring alongside the shoulder, quarter and approaching the bow/stern centreline of a tanker at 6, 8, and 10 knots while making way ahead and astern • Crash stop manoeuvre(time and distance) at full speed ahead • Time delay from full ahead command to commencement of astern movement • Fuel consumption measurements at bollard condition and free running at 8, 10, 12 knots and at max. free running speed 6.2 Support Tugs • Full range of stability conditions; intact,towing, escort operations • Damaged stability analysis(is a one-compartment standard of subdivision achieved?) • Bollard pull, ahead(over range of rpm). Provide Class certificate • Bollard pull, astern(over range of rpm). Provide Class certificate • Maximum transverse arrest force at 6 and 8 knots • Maximum direct astern braking force at 6 knots ROBERT ALLAN LTD. NAVAE AP(:NIlEGTB AND 4APINE ENOINEEPS Project 216-036C Page 18. Rev.5 • Provide details of: - maximum Indirect Steering Forces at 8 and 10 knots, (within Class stability limits) and the tug position and attitude at which these forces are generated. Provide Class certification of maximum F . Provide Class certification of maximum FS - maximum Indirect Braking Forces at 8 and 10 knots, (within Class stability limits) and the tug position and attitude at which these forces are generated • Fi-Fi system performance measurements proving compliance with Class Notation • Free running speed in calm conditions at 50, 75,90, and 100%rpm • Proof of directional stability/controllability during typical manoeuvres, running ahead and astern, and specifically while manoeuvring alongside the shoulder, quarter and approaching the bow/stern centreline of a tanker at 6, 8 and 10 knots while making way ahead and astern • Crash stop manoeuvre(time and distance)at full speed ahead • Time delay from full ahead command to commencement of astern movement • Fuel consumption measurements at bollard condition and at 8, 10, 12 knots and at max. free running speed 7.0 SUMMARY This review identifies many aspects of both proposed tug designs that indicate (a) a lack of thoroughness in proving suitability for purpose of the tugs, and (b) unfamiliarity with the re- quirements for safe and sensible operation in the Alaskan climate. The latter issues are perhaps not all critical to the vessel base mission but will certainly render the boats difficult to operate and to maintain well. Many other issues are raised that are simply good design practise issues that could be revised at minimal cost to provide a safer and better operating environment for the crew, and result in less downtime and long term maintenance. The most critical aspects of the design review are summarized below, categorized for each ves- sel type according to: • Performance Predictions • General Design Configuration, and • Suitability for Operation in Alaskan Environment ROBERT ALLAN LTD. x.VV.E.PCnIi EDTB AND x.PixE ENDIx EEPB Project 216-036C Page 19. Rev.5 7.1 Escort Tugs 7.1.1 Performance Predictions • Indicated specific BP is about 15% lower than what would be considered "normal" for a large Z-Drive tug. Difference to be resolved. If result is actually higher than stated this could adversely affect the current stability analyses • There is no evidence presented to indicate that this new hull form has been model tested to prove that all performance objectives will be met or to verify fitness for purpose, as one would expect in a fleet investment of this magnitude. • The existing performance predictions for the large escort tugs are very limited in scope and do not prove performance in the full range of operating conditions • The seakeeping predictions are suspect in their accuracy • The indirect performance analyses were done only for calm conditions and for wind direct- ly astern. This does not identify what happens in any cross-wind condition, a serious omis- sion considering the full extent of the escort route. • Discrepancies in vessel dimensions between referenced documents indicate that the indirect escort performance must be re-calculated for the latest vessel dimensions 7.1.2 General Design Configuration • The forecastle deck area presents a significant "pool" to hold water during heavy seas • Given the high windage of this tug, and the presence of a very large skeg which will hinder lateral mobility/manoeuvrability, a bow thruster should be strongly considered for ship- handling operations at low speed • Experienced Masters familiar with the tug operations advise [Annexes A and B] that the fendering arrangement shown on the GA drawings will be insufficient for the PWS opera- tions. • No information was provided with respect to the structural design of these tugs, and in par- ticular with regard to the ice-strengthening of the hulls. Some ice-reinforcement must be required • The bow height (to the knuckle at the bottom of fender) is extremely low for operation in the Gulf of Alaska: one should be very concerned about how this shape will perform in 4 to 6 metre seas. • Galley range facing athwartships will be a safety hazard in rough seas • Refrigerators oriented longitudinally will spill their contents regularly. • Should consider providing lavatories close to bridge and to machinery control room • Bunks should be arranged, wherever possible, away from exterior bulkheads and not orient- ed transversely • Consideration should be given to a lounge area separate from mess room • Consideration should be given to fitting a crew exercise room ROBERT ALLAN LTD. NAVAL•PCMITECTt AMO MPINF ENOIMFEPt Project 216-036C Page 20. Rev.5 7.1.3 Suitability for Alaskan Environment • In the absence of a Specification for this vessel it is unclear what measures have been taken in the design to cope with the heavy snow and sub-freezing temperatures prevalent in the operating area. The following in particular are of serious concern: - prevention of ice/snow plugging the freeing ports in the fore deck - measures for deck heating in all exposed working areas to prevent ice/snow accu- mulation. - methods/locations for protected/heated storing of mooring and other working lines - means of protecting winches from water ingress into shelters and from freezing spray - prevention of freezing in potable water and fresh water ballast tanks adjacent to the shell - protection from freezing in ALL piping systems and especially those exposed to weather such as drain lines - avoid any topsides deck drains routed inside deckhouses - all wheelhouse windows should be heated type - all wipers should be equipped with heating elements and provision for adding anti- freeze to window-washing solution? - hull strengthening must be provided to cope with ice conditions - Crew berths should, wherever possible, be located away from exterior bulkheads and defmitely not be oriented transversely in order to maximize crew comfort and safety and to minimum fatigue 7.2 Support Tugs 7.2.1 Performance Predictions • Very little information about performance is provided beyond the indicated BP of 65.8 tonnes from 4,480 kW. These figures indicate a very poor specific performance. Typically, that much power (6,005 BHP) should deliver closer to 75 tonnes BP. This discrepancy should be explained/resolved soonest • This performance should also be compared to that of the Crowley "Invader" class tugs to verify that equivalent BP performance is being offered • Provide evidence that the tug complies with USCG Towline Pull Stability criteria • Provide evidence that the tug complies with a recognized escort stability criteria • Provide full details of Fs and Fb capability at 8 and 10 knots, within recognized escort sta- bility criteria • Demonstrate that the fixed pitch propellers will not cause the engine to stall in the full range of operating conditions during indirect escort operations ROBERT ALLAN LTD. .,..,a•c• •�%••�••�tN• Project 216-036C Page 22. Rev.5 In conclusion, neither design is sufficiently well defined in terms of its expected performance to be unreservedly declared fit for purpose at this time. Both designs as reviewed suffer from design/layout issues which will render the tugs difficult and potentially unsafe to operate in Alaskan sea and weather conditions. The issues of performance verification must be addressed quickly in order to prove that the en- tire operation will provide at least the same degree of safety as the existing operation long be- fore the new tugs arrive on station. The design issues should be addressed immediately, and before construction is so far advanced as to render changes impossible to accommodate without significant cost and delays. The measurement of actual performance cannot be assessed until the vessels are delivered, but more extensive analysis can and must be done to prove that the necessary performance can be achieved in all the boats before delivery. for ROBERT"A 4.11,041; • 011 Rob; G.Allan, P. Eng. Executive Chairman RGA:da Attachments: • Annex A—RCAC's comments on Robert Allan Ltd.'s Review of Tugs • Annex B—Robert Archibald's comments on Robert Allan Ltd.'s Review of Tugs This page intentionally left blank. Annex A PWSRCAC's comments on Robert Allan Ltd.'s Review of Tugs - � S ‘, RcAc • Regional Citizens' Advisory Council Comments on Robert Allan Ltd.'s A Review of the Proposed New Escort and Support Tugs for Tanker Operations in Prince William Sound Prepared for: Prince William Sound Regional Citizens'Advisory Council Valdez, Alaska Prepared by: Little River Marine Consultants P.O. Box 504 East Boothbay, ME 04544 Date: December 22, 2016 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC Contents 1.0 BACKGROUND 3 2.0 REFERENCE MATERIAL 3 3.0 SCOPE OF WORK 3 4.0 DESIGN REVIEW—FINDINGS AND OBSERVATIONS 4 4.1 Escort Tugs—Damen Model 4517 4 4.1.1 Design 4 4.1.2 Performance Predictions 7 4.2 Support Tugs—Damen Model 3212 8 4.2.1 Design 9 4.2.2 Performance Predictions 10 5.0 QUESTIONS TO BE ANSWERED 11 5.1 Escort Tugs 11 5.2 Support Tugs 11 6.0 REQUIREMENTS FOR TESTING ON COMPLETION 12 6.1 Escort Tugs 12 6.2 Support Tugs 12 7.0 SUMMARY 13 2 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC Comments on Robert Allan Ltd.'s A Review of the Proposed New Escort and Support Tugs for Tanker Operations in Prince William Sound 1.0 BACKGROUND Little River Marine Consultants was retained by the Prince William Sound Regional Citizens' Advisory Council (PWSRCAC)to review and provide input of"A Review of the Proposed New Escort and Support Tugs for Tanker Operations in Prince William Sound"by Robert Allan Ltd. 2.0 REFERENCE MATERIAL The following information was provided by the Client and was used as the basis of this review: a. Escort Tug Drawings: • Damen 4517 - General Arrangement (10 pages) b. Support Tug Drawings: • Damen 3212 - General Arrangement(9 pages) c. Other References not provided by the Client • International Labour Conference-Maritime Labour Convention, 2006 3.0 SCOPE OF WORK The following is the instruction given to Little River Marine Consultants with respect to this review and comment: a. To review the report from Robert Allan Ltd. and provide comment for additional insight, input and observations. b. Review vessel drawings and simulations as to performance and suitability. 3 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC 4.0 DESIGN REVIEW—FINDINGS 4.1 Escort Tugs-Damen Model 4517 4.1.1 Design a. The Escort Tug dimensions list the draft at estimated 98 percent consumables as 5.45 meters. It could be inferred to mean from the underside of the skeg or keel or navigational draft,but the numbers do not correspond to that premise. Clarification from ECO. b. Agreed,the size and position of the skeg will impact the tugs maneuverability when coming alongside a tanker at speeds in excess of 5 kts due the pressure wave caused by the tankers hull through the water. Additionally,this type of skeg may interfere with course stability when the tug approaches the stern of the tanker to pass the working line to the ship at higher speeds due to the skegs interaction with the propeller wash from the tanker. c. The pooling effect mentioned in Robert Allan's report is a valid concern which will be further complicated in winter icing conditions when spray freezes on the bulwarks, fittings,winches, and deck.The unknown effects of the"pooling"on the rise of the tugs could cause delays in the timing to provide the intended service to the tanker, and could add potential safety issues when approaching the disabled vessel. In addition to being a crew safety hazard and possible water egress into the tug interior spaces, the breaking or"sluffing"of ice onto the inside of the bulwarks could congest the freeing ports and allow additional water to accumulate in the foredeck area,thus further impeding the ability of the vessel to rise back out of the seaway. This is particularly applicable in the Hinchinbrook Entrance where the waves are more confused and stack up in comparison to the more open Gulf of Alaska. Vessels returning from escort(or other duties)are subject to pitching while transiting the Valdez Arm in the winter,which produces heavy icing on the forward area of the vessel.A very important system that appears to be overlooked is a means of heating the weather decks to minimize snow and ice accumulations,which can cause a considerable crew safety hazard as well as a crew effectiveness issue when trying to handle lines. Another concern with the accumulation of water on the forward deck is that the escort winch is partially open to head seas during escort operations and lite boat transits. This will require that some protection should be installed above and below the plane of the working line, or a winch cover installed to keep the winch brake and drum free from freezing in the open or closed position thus preventing the working line from retrieving or paying out properly, in addition to freezing in place on the winch. The potable water tanks between Frames 59-64 adjacent the hull will be subject to freezing 4 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC during the winter period without consideration of heating elements. The same concern holds true for the freshwater ballast tank forward of Frame 64. Additionally,heated decks and line lockers will be an absolute must during the coldest periods of the winter. d. Agreed,clearing of both the forward and after decks of ice and snow are crucial to the safety of the crew and vessel. Low voltage deck heating is generally ineffective during the coldest periods of the Valdez winter. Lack of sufficient heat to completely melt the ice and snow build up on deck causes a dangerously slippery deck as the slush accumulation is not melted. e. Agreed, a bow thruster is always a helpful tool to have, especially when holding the tug in position during wind events from either the east or west in the Port of Valdez, enhancing oil spill recovery operations to keep equipment on station during deployment and recovery or making tow to a disabled tanker. General consensus from the tug industry is that bow thrusters become ineffective at speeds above 5-7 kts. With that being said,the current Prevention and Response Tugs of similar size,but 2,000 hp less,were able to handle the maneuvering demands required of them with minimum impact. The deep skeg forward on the 4517 is additional evidence for rigorous tank testing of the vessel design. f. There is some question as to what Robert Allan is implying in this paragraph. As it appears he is pointing out that each stateroom has only one access, if so,this may be a difference in construction regulations between countries. Most tugs in our experience been aboard generally have one access in each stateroom unless there is a common head between the two. i. The drawings indicate there are three hatches to the weather deck from the main deck: One just forward of the winch, one on the port side of the galley, and one on the forward house bulkhead on the port side of the centerline. ii. On the boat deck,plans indicate there is one access on the port side aft of the Masters room, and one forward between the two mate's rooms of the forward house bulkhead. iii. It will ultimately be up to ABS to assess access/egress during examination of the plans for Class. g. Agreed,the same goes for the galley range and stove. h. Agreed. i. Although Robert Allan's comments are helpful and good practice,the United States is not a signatory to the Maritime Labor Convention(MLC 2006)and therefore would not be a concern of the USCG or ABS. i. Berths on an outboard bulkhead in the winter are intolerable and cold. In addition,the heads located on the forward bulkhead of the house, aft of the store rooms,will also be 5 Project No: 8020-16-01 Revision:1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC cold and plumbing subject to freezing. Suggest the store areas be heated, first to keep the line and general stores from freezing, second to keep the plumbing from freezing and fracturing. The same holds true for the locker adjacent to the changing room on the starboard side. ii. [RAL topic: sanitary facilities within easy access of the nay. Bridge&machinery space] Sanitary facilities in the machinery space and navigation bridge are valuable in allowing the navigational watch or engineer to remain close by the area of responsibility. The importance of this concept on tugs built in the U.S. is not generally recognized. In addition,the manner in which the vessel watches are arranged also can assist in filling the vacancy of someone using the sanitary facilities. In the engineering department,there are sufficient alarm systems to notify both the navigation bridge and engineer's stateroom that an issue needs attendance. In the Prince William Sound service,it is expected that there will be two mates and a non-watch standing Captain. This is done to allow strict adherence to the 12-hour rule due to additional ancillary duties for the vessels designed in the system. This allows the watch stander to call an off-watch officer to cover while the facilities are used. It is worthwhile to mention that the United States is not signatory to the Maritime Labor Convention(MLC 2006)and therefore would not be a concern of the USCG or ABS. iii. Crew fitness space: When recreational facilities have not been included in a vessel design utilizing equipment suitable for a dynamic environment,the crew will typically cobble one together of their own. This,in our experience,poses a significant safety risk because machines are not secured properly to the bulkhead and deck, improper athletic material is used,or machines are not suited for the dynamic environment. This generally leads to injury,or worse,to crewmembers using the equipment. Based on our experience, it is best to have an"off ship"exercise area. In that way costs of providing such equipment are minimized,there is reduced risk of crew injury, and it is accessible to all vessel personnel. One last note on exercise,if an injury does take place, there is a fair chance it might be deemed an OSHA recordable or Lost Time Injury resulting in an elevated OSHA recordable rate. Crew lounge spaces are helpful on larger vessels. On board a tug with current crew levels,generally the on-watch is working and off-watch are resting or are generally considerate of the crew that are resting. The one concern on the Model 4517 is the fact that one berth on the opposite(forward) side of the mess area bulkhead(Fr 53)is not only transverse,making sleeping uncomfortable in a heavy sea,but is directly against the mess area bulkhead making it very noisy to rest during meal times. 6 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC 4.1.2 Performance Predictions a) Tank modeling of this design is critical to assure the stakeholders the Escort and General Purpose tugs will perform as required at different power settings and sea conditions. Deck wetness calculations are critical in order to establish stability in icing conditions and the ability of the crew to work on deck in the event of a tanker causality in heavy weather. Calculations done on the escort performance are based on best case vessel attack angles, and vary significantly from operator to operator based on their ability to understand and apply the proper vectors to develop optimal vessel performance. Therefore,real time exercises must be executed in various weather conditions to prove the actual "live"performance of the vessels. b) Agreed. c) Ref. [1] Modeling scenarios,the premise used when David Gray designed the"Shipman" program was that the two areas with minimum room for tanker track transfers are the Valdez Narrows and Valdez Arm. When weather events occur in those areas,the wind will generally blow through the passes from a NW direction,thus putting the wind directly on the stem of the tanker. Since the only maneuver available in Valdez Narrows is a retarding(braking)maneuver, consideration of anything but winds from astern might confuse the findings. Once the tether is released at buoy#9,the traffic scheme widens into Prince William Sound allowing additional room for maneuvering.Winds from other directions other than the Northwest,which would considerably affect the results of the simulation,must be considered. This plays a significant role when"sea room" is reduced in the sound or in the vicinity of Cape Hinchinbrook due to a tug's difficulty attaching a line to a ship. During the design of the current tug system in PWS,this became an issue.Both winds and currents became topics for additional testing during the design of the previous system. Several months of delays were experienced while additional tests were designed and agreed upon by all parties before Glosten could run the additional model tests.As the different wind and current conditions were modeled,the results led to the need for additional testing,which led to more delays.It is suggested that sufficient emphasis be placed on this shortcoming to ensure that potential changes to the tugs could be made,if necessary,prior to final construction. d) In this section, Robert Allan's group discussed the uncertainty of predicting seakeeping performance using Shipmo PC mentioning the motions of a vessel with a large skeg. One factor that has not been examined by simulation,that will be an important factor in the manner that the tugs handle, is the ability of the tug to safety cross the pressure wave alongside the tanker as she makes way. 7 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC It might be worthwhile for the PWSRCAC to undertake an independent review of modeling both vessels using Computational Fluid Dynamics. This type of modeling would provide a verification of assumptions made in the vessel design. This service is relatively inexpensive and can be researched at http://cfdanalvsis.com/about-us/. The current ETT's have a small skeg forward in the direction of tethered movement and the ability to simultaneously and instantly control both longitudinal and transverse thrust angles, allowing the vessel to "push through"the pressure wave, and once inside, remove the transverse thrust needed to overcome the opposite force of the hull pressure of the tanker. Since the PRT's have no skeg forward, this force does not significantly affect the maneuvering of the vessel. In the case of the Model 4517 escort tug, there is a significant skeg that extends aft from Frame 60 to Frame 17. As ASD propulsion has a notable lag time to azimuth direction, this may cause the tug to come alongside the tanker with considerable force risking inset to the tanker hull plating or cracked welds. It will be absolutely necessary to increase the fendering by adding 2000 mm x 900 mm tires forward of frame 52 and replace the 1600 mm x 590 mm tires aft with 2000 mm x 900 mm tires to absorb the weight of the tug. e) Agreed. f) The bow shape and low height are concerns for both a reduction in high running speeds and making a "wet" boat and harder for the crew to perform tasks on the foredeck. In addition, there is no apparent indication that the Shibata fendering has any saddle foundation to support it. This will be necessary to stabilize the fender in head seas and when pushing on a tanker in swell conditions. There are many concerns that would be potentially eliminated (bow wetness, performance, seakeeping, etc.) by model testing of this vessel. It is strongly recommended that model testing be conducted at the soonest opportunity to identify any potential issues that could be rectified at this early stage. At a bare minimum, a class-approved CFD analysis should be conducted. Additional details on the winch, how the towline forces are relayed to the master, and how the winch complies with the class requirements for render/recovery need to be provided. 4.2 Support Tugs-Damen Model 3212 These tugs are proposed to be used as primary escort tugs for tankers under 90,000 DWT. hi order for them to be effective as such,these tugs must be outfitted with a skeg. At this point there are no plans to conduct any type of modeling. If in fact they are included in the C-Plan as a primary escort, it is 8 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC absolutely necessary to have modeling scenarios run to verify the suitability of the tugs to perform safely. a) Fixed pitch propellers are less than suitable for any type of indirect maneuvers at or above 8 knots. The slow rotation of the ASD units and inability of the units to reverse the thrust delays the time for the master to react in the event the tug reaches a critical stability condition due to deck edge immersion by applying corrective forces to right the vessel quickly and overcome the lift created by the attack angle of the skeg through the water flow. Under the assumption that the 3212 will be used as a primary escort,torque versus propeller load analysis should be conducted on the fixed pitch propellers to determine if there is the potential for engine stalling with the intended use. It appears that these tugs may be called on to perform tethered escorts,and as such, additional analysis is needed to establish predicted performance,suitability,and conformity.To say that this will be done at a later date may be extremely limiting(if there is greater potential for engine stalling)for the escort system where maximum flexibility should be maintained. b) As ABS, DNV, Lloyds and BV all recommend full scale testing at 6, 8, and 10 knots, it would be advisable to adopt the standards of the classification societies for consistency. Although 6 knots is the lower threshold for an effective indirect maneuver it is important to test the tugs performance as the results may be used in designing emergency maneuver protocols. c) Agreed, ABS has requirements for the minimum breaking strength of deck fittings and towline. Without listing the details of the winch and line it is impossible to determine conformity to the ABS requirements. d) Without the controllable pitch control of the ASD units,the fire pump will have to be a separate power system. If the intention is to use a main engine,the engine used to power the pump would have to be declutched from the ASD unit and run at a specific RPM specified by the pump manufacturer. A note on FiFi system piping: Proper post use draining is critical in both mild steel and stainless steel systems. Salt water accumulated in low sections of the piping causes corrosion in mild steel and worm holes in stainless. The fire monitor system must have proper drains and a means to blow out remaining water to prevent this condition,or be constructed of bronze or suitable material. e) A more detailed drawing of the tow pin and roller is needed to visualize any operational challenges. 9 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC f) The main deck living area for the Captain and Engineer have several areas for concern. i. Agree with Robert Allan's review regarding gear lockers. This also presents a safety concern as not having a gear room brings water into the house from crew entry, and makes the decks very slippery leading to slips and falls of the crew. ii. Without seeing the exact measurements of the mess table, it would be hard to determine if it would accommodate more than two people. However,the seating arrangements indicate that seven people could be seated between the two tables. iii. The common head and shower are on an outboard bulkhead; this could potentially result in the waterlines freezing and bursting in cold temperatures. Other than the freezing of pipes,repairs to the system would take the vessel out of service until complete. Additionally,the bunks in both staterooms are on the same outboard bulkhead. This placement will expose the occupants to the cold radiating from the thin insulation between the interior and exterior of the house. g) There is no indication as to the material used in constructing the ladders exposed to weather. It is beneficial to use non-skid fiberglass grating to prevent icing and snow accumulation on all exterior ladder treads. Since the vessel executes contact with the tanker on the bow,the stern is mainly used for towing operations due to the travel across the transom during towing operations Fendering across the transom is problematic, especially when towing out of the tow pins.The wire must have unrestricted travel across the transom when connected and getting underway with a tow. During this period the tug must have the ability to adjust its heading in order to prevent getting in irons and controlling the tanker. (Refer to the reports from in Sound towing drills with the PRT class tugs.) h) The main deck quarter bitt arrangement seems to be not represented in the drawing properly for each side of the vessel. The Robert Allan review has a point in that the bias could be moved forward to Frame 17. Additionally, a bulwark chock on the Frame 7 line would be helpful when making up to response barges,docks, and alongside other tugs. i) Heated line lockers for deck lines on this vessel will be an absolute necessity in the winter. Any line left on deck will be frozen and covered with snow. It will also be necessary to fabricate heavy Arctic grade covers for both the tow and bow winches. If covers are not fitted,the winch brakes, gear,s and line will freeze during the cold season and become unusable for ship or barge work. 4.2.2 Performance Predictions With the expectation of these tugs serving as Primary Escort Tugs for tankers less than 90,000 DWT,hydrodynamic simulations are required at a minimum,with tank testing being optimal. There must be some evidence that Model 3212 is capable of meeting the demands of that mission. 10 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC There should also be confirmation of the bollard pull for the 3212 as the tugs are rated as 65.8 tons with 6008 hp at 1800 rpm as the Crowley Invader class has a bollard pull of 75 tons with 7200 hp at 900 rpm. Equally as important is the fact that the fire pumps, if run from a PTO off the main engines, will reduce the bollard pull of the 3212 significantly depending on the maximum RPM the pump is rated for. The Crowley docking tugs equipped as fire boats all have a separate engine to power the fire pump. 5.0 QUESTIONS TO BE ANSWERED • Since the model 3212 is an"off the shelf' model, Damen must have performance calculations and validation, in addition to hydrodynamic testing. The PWSRCAC should request this information be obtained by SERVS from ECO or Damen at the earliest opportunity. • Obtain more detailed drawings of the stern tow pin area so a proper evaluation of tow wire travel may be assessed. • Obtain a revised drawing of the main deck showing proper bitt configurations and locations. 5.1 Escort Tugs a) Included in Robert Allan's questions, additional questions as follows: i. Are heated decks(fore & aft)planned, and if so,what is the method of heating? ii. What additional lines do the 4517 carry(e.g., 12" dia.Nylon/AmSteel emergency tow hawser)to connect into the ship's Prince William Sound Package? iii. Is there an easily deck-accessible, protected storage for this line? iv. Specify type and construction of escort line and any sacrificial pennant connected to the escort line. v. Will the tug carry any surge chain of proper size and length? vi. What are the ABS certified Safe Working loads and Breaking Strengths of all tow connecting gear? vii. In what manner will the termination connections for the tow wire be attached? viii. Has the hull been strengthened in way of the waterline to prevent ice damage or breaching of the hull? (The Nanuq and 0/S Ohio suffered impact and damage from contact with a bergy bit.) 5.2 Support Tugs a) Included in Robert Allan's questions, additional questions as follows: i. Will the difference in bollard pull between the 3212 and the Invader be a reduction in the system? 11 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC ii. Are heated decks (fore& aft)planned, and if so, what is the method of heating? iii. What additional lines does the 3212 carry, (e.g., 10" dia.Nylon/AmSteel emergency tow hawser)to connect into the ship's Prince William Sound Package? iv. Is there an easily accessible,protected storage for this line? v. Specify type and construction of working/escort line and any sacrificial pennant connected to the working/escort line. vi. What are the ABS certified Safe Working loads and Breaking Strengths of all tow connecting gear? vii.Will the tug carry any surge chain of proper size and length? viii. In what manner will the termination connections for the tow wire be attached? ix. Has the hull been strengthened in way of the waterline to prevent ice damage or breaching of the hull? (The Alert suffered impact and damage from contact with a bergy bit.) 6.0 REQUIREMENTS FOR TESTING ON COMPLETION Agree with Robert Allan's review. 6.1 Escort Tugs In addition to Robert Allan's suggestions, additional items are identified below: • ABS Certificate of Bollard Pull Test(ahead). • ABS Certificate of Bollard Pull Test(astern). • Proof of directional stability/controllability maneuvering alongside the shoulder, quarter, and approaching the bow/stern centerline of a tanker at 6, 8, and 10 knots while making way ahead and astern. • Maximum transverse arrest force at 6 and 8 kts. • Maximum braking force at 6 kts. 6.2 Support Tugs In addition to Robert Allan's suggestions, additional items are identified below: • ABS Certificate of Bollard Pull Test (ahead). • ABS Certificate of Bollard Pull Test(astern). • Proof of directional stability/controllability maneuvering alongside the shoulder, quarter and approaching the bow/stern centerline of a tanker at 6, 8, and 10 knots while making way ahead and astern. • Maximum transverse arrest force at 6 and 8 kts. • Maximum braking force at 6 kts. 12 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC 7.0 Summary In addition to Robert Allan's suggestions, additional items are identified below: A major concern that comes forth from this report is the ability of the tugs to use their design capabilities and for the crews to be able to carry out their responsibilities and do so safely. In order to avoid the modeling problems that came up during the first escort(ETT/PRT)tug design, it is suggested that this report more clearly emphasize modeling and potential design changes for operation in the Prince William Sound tanker operational conditions up to closure As Robert Allan's review stated, it appears both the 4517 and 3212 vessels are inadequately outfitted for the rigors of the Alaska winter environment. Transiting Prince William Sound or standing by/escorting a tanker during a Cape Hinchinbrook closure will cause the vessel to develop heavy icing conditions on both the deck equipment and working lines. Loitering in Port Valdez will generate deep snow accumulations on the deck of the tug. The ability to clear the decks of snow, ice, and water is of paramount importance for the safety of the vessel,crew,and mission of the tug. Access to pliable deck lines when making up to a response barge and docking is imperative as frozen lines will not hold on cleats bitts and bollards. Heated store rooms or deck boxes will be the single manner to provide line in an acceptable condition. Adequate fendering in the form of large earth mover tires on the shoulder and large aircraft tires in line with the ASD units on both class of tugs,will lessen the chance of heavy impact to tankers and response barges. If PWSRCAC believes these areas are addressed insufficiently for this stage of the project,they may wish to emphasize these concerns in more detail during their interactions with industry. It will be very important to have the PWSRCAC represented by a Subject Matter Expert (SME) at initial tank testing, all sea trials,full scale trials and bollard pull testing. Furthermore,it is absolutely necessary to conduct intensive tether and towing exercises at all speed ranges,weather conditions,and failure recognition times to validate the performance of these vessels. 13 Project No: 8020-16-01 Revision: 1.2 The opinions expressed in this PWSRCAC-commissioned report are not necessarily those of PWSRCAC Annex B Robert Archibald's comments on Robert Allan Ltd.'s Review of Tugs Comments on Robert Allan Ltd. Review and Little River Marine Consultants Comments on ECO New Escort and Support Tugs By Robert Archibald The following are comments that I have on the above reports.In general, I agree with all comments provided and add the following observations. Escort Tugs-Damen Model 4517 4.0 Design 4.1.1 a.Agree with Robert Allan Ltd., (RA)and Little River Marine Consultants (Little River). b.Looking at the design of the foredeck area,there is no doubt that drainage could be a problem.The provided drawing shows four freeing ports on each side of the foredeck.The Shibata Fendering System may hamper the free water flow out of these ports.During freezing weather operations,ice build up will further reduce water-shedding ability. The tether line opening through the winch room forward bulkhead will allow water ingress during rough weather escorts.The deck drain scuppers inside the winch room will have to be designed to allow adequate service to prevent flooding during freezing conditions. Not mentioned is weather deck heating to help shed ice and snow.This is a major operational and safety concern for personnel working out on deck during winter months. The tether line will pass through the forward staple and in cases where this line angles down from the bow of the escort tug to a barge or dock it will ride on the Shibata Fender.There is no Panama Chock to run tether line through to provide a clear lead as is on a PRT. Design consideration must be given to sub-zero temperatures and freezing seawater.This includes all piping and fresh water tanks that will be exposed to freezing temperatures.The potable water tanks appear to have side shell for a boundary.Tank heat will be needed to keep these tanks from freezing. c.Agree with Little River comments. A bow thruster is open to conjecture.As RA points out with wind area and large keel forward,it would be desirable for close maneuvering. The PRTs do not have a bow thruster and operated with success,however they do not have the hull configuration of the ECO escort tugs.This new tug design with its large bow skeg, rigorous tank testing should be required to demonstrate the performance of this vessel. d.I agree with Little River. e.I agree with RA&Little River. f.I agree with RA.Galley seems excessively large fore and aft. g.I agree with Little River. h. i.I agree with Little River. ii.&iii Non-issue as crew will work this out with Edison Chouest(ECO). iv.I agree with RA.This tug has a small mess area and no crew lounge. It is considered good practice to have a lounge TV area. i.Ice strengthened hull or water line ice belt is not mentioned.The tug design should incorporate society design to permit contact with expected ice conditions in Port Valdez and brash from Columbia Glacier.Damage has occurred to a tanker and a tug as a result of collision with glacier ice. j.These vessels are noted as Fire Fighting Vessels,FIFI 2. Requirements for this notation include an onboard SCBA Compressor. I see no mention for off vessel firewater conections.Current vessels have 8 ea.2 '/z inch fire hose connections,supplied from the fire monitor pumps.There are four connections on each side of current escort vessel fleet. k. Have bilge keels been designed so they will not make contact with tanker side shell if tug maneuvers alongside in rough weather or has to make a radical maneuver while alongside? 4.1.2 Performance Predictions a. Agree with RA&Little River. This is a new,powerful vessel that will have operational limitations.The technology is available to test this design and PWSRCAC should pursue agency&Alyeska requirements for testing this new hull design. b. Agree with RA. Simulations for hull performance should represent actual conditions for entire escort at just under closure conditions. c. Agree with Little River. d. Agree with RA and Little River. The conversation on the tanker generated pressure wave is of vital importance as the performance of this new tug coming alongside a tanker doing 8 to 10 knots will be influenced by its large skeg.This is where crew simulator training will be imperative. I would say that maneuvering alongside underway ships with a tug is a major cause of significant damage to ship's side shells. e. I agree with RA and Little River and am at a loss as to why tank testing has not been carried out on this new hull design. •rteilk ii l 1 r / \\\ Fiirit, . 1 :; 'N \1 • I, i•' Hull repairs underway at regular yard period to replace set-in plating from contact with glacier ice,which made initial contact near waterline and rolled down to strike vessel again below the water line.After close inspection of vessel in the water it was determined there was no breach of hull plating but very close. Vessel icing does happen in Valdez Tugs at SERVS Dock -T- . . ,. r :. ,. / A wsuz, ....„.,,..,, „ , .t ;I .� Tug Protector de-icing at SERVS Dock. Tug Nanuq christening at SERVS Dock. Crew used ball bats to uncover name. 4�F. s k wt Mid-Sound ice from Columbia Glacier Near closure weather at Hinchinbrook ERV Gulf Service 4.2 Support Tug-Damen Model 3212 a.Agree with RA&Little River,Additionally if these tugs are to be used primarily for docking tankers,the forward skeg design may hinder the vessel coming alongside an underway tanker. If these vessels are to be used for primary escorts on small tankers and expected to perform indirect maneuvers,all scenarios need to be modeled for safe operation. b.Agree strongly with RA&Little River. c.Agree with RA&Little River. d.Agree with RA&Little River. e.Agree with RA&Little River on all subjects.These look to be very uncomfortable vessels. f.Agree with RA&Little River. g.Agree with Little River.All docking and tether jobs will be over the bow. Fendering around stern may interfere with tow wire. h.Agree with RA&Little River. i.Agree with RA and Little River.The bow on these vessels will be very wet resulting in cold weather icing.To keep bow winch functional a good cover will be needed to protect it from icing up. 4.2.2 Performance Predictions Agree with points made by RA&Little River. 5.0 Questions to be answered I agree with all questions RA and Little River have presented. The lack of proper tank testing of the escort tugs is problematic.When these tugs arrive in Valdez they must be made to demonstrate contracted requirements,as past vessels have had to demonstrate.PWSRCAC should request these demonstrations before the Crowley vessels depart. As pointed out by Little River,it will be imperative that PWSRCAC has oversight at all performance tests to ensure all equipment is operated to normal operating specifications. This is pointed out in their following statement,which I strongly support: It will be very important to have the PWSRCAC represented by a Subject Matter Expert (SME) at initial testing,all sea trials and bollard pull testing.Furthermore,it is absolutely necessary to conduct intensive tether and towing exercises at all speed ranges,weather conditions and failure recognition times to validate the performance of these vessels. Thank you for the chance to comment on these two reports. Robert E.Archibald Chief Engineer of Motor Vessels, Unlimited(Retired) PWSRCAC Board Member from The City of Homer,Alaska Go to www.PWSRCAC.org 2015 _ 2016 REPORT TO THE STAKEHOLDERS . -- CITIZENS PROMOTING ENVIRONMENTALLY SAFE OPERATION OF THE ALYESKA TERMINAL AND ASSOCIATED TANKERS f ' k‘..-..40 illik, ' 1u. , 9 'At 7 ' 5710'`_ ' . `4-‘ kit• " _ �� �� 1' % , �� t ` _ -% it % i ';''' ,'"%e'7" - — ' ':.*: ':: • ‘ . , "-i- ' .'t • 4-,,,. . iirt, . . . _ 4.,(40,06.i.,,-. . '. t ..; _ r • IV g • _.nom i j . 11,,,' ;#1g- ' 1 - :0,i •,,Ar, ' i - - ' :' - :—,p,*,,,F. ;# ... ...r 1-11-4---1,111W--xl --','-'- - Pr ILLI A44 GF, SS O (J 4— 1'16 FlAiiiillCAC Regional Citizens' Advisory Council • • • ;•• • , ./ Content '���a 02 / Letter from the President and Executive Director f !�. 04 / Mission and Responsibilities 06 / Preventing Oil Spills r ` :• 08 / Planning and Preparing for an Oil Spill • 12 / Responding to an Oil Spill 14 / Protecting the Environment 20 / Outreach 30/ Board of Directors • 32 / Advisory Committees 34 / Staff • 36 / Papers, Presentations, Reports and Media Releases 1-•;‘, • . t,.• • • • ' This report covers the period from July 2015 through June 2016. mai' letter from the In 1990,just after the worst oil spill the U.S.had ever seen,Congress was tasked with creating legislation that would prevent such a disaster from happening re s I e n again.One goal of the resulting legislation,the G G I Oil Pollution Act of 1990,was to foster long-term partnership and build trust between industry, Executive i r e c o r government,and local communities.To help accomplish this,the Act Mandated regional citizens' advisory councils to help monitor the oil industry in Prince William Sound and Cook Inlet. Great visionaries began this experiment in building partnership and trust.While some of these people are no longer with us,we still share the vision that motivated them. Today,the council still works to find common ground between citizens,the oil industry,and regulators in �:4 order to develop the trust necessary to build and maintain the safest marine transportation system in the DONNA SCHANTZ AMANDA BAUER world.For example,this past year representatives from Executive Director President of the Alyeska Pipeline Service Company joined council staff, Board of Directors 90 Seward residents,and local media on a public tour to show how the oil industry trains mariners to respond We dedicate this edition of the annual if there should be another oil spill.Read more about report to all those who came before us and that tour on page 23. worked tirelessly to put safety measures in place since the 1989 oil spill to protect THE YEAR AHEAD Prince William Sound. We also recognize CHANGES TO THE ESCORT SYSTEM those who are continuing the journey by REQUIRE PARTNERSHIP The future of the system of escort and oil-spill response Carrying the mission forward. tugs and barges in Prince William Sound is perhaps the most crucial issue we face in the immediate future. Alyeska recently announced it is hiring a new contractor to provide these important oil spill prevention and response services.Crowley Marine Services has held the contract since 1995,and has provided docking services for oil tankers at the Valdez Marine Terminal since start-up in 1977.As of June 2018,the new contractor will be Edison Chouest Offshore. t 2 PWSRCAC/ANNUAL REPORT -. ' `w'""�'RI ;�. -- Major efforts to cut costs include changes to staff and a reduction in the number of oil spill drills and exercises. /i We have also seen some positive changes,such as: .11 • An update to the dispersant use plan for Alaska that had not been updated since the Exxon Valdez oil spill. —- _ — -- — •— ■ Alyeska has embarked upon a major effort to �"fiEr_ - — _�--- - internally inspect all of the underground piping - _ _ _ at the Valdez Marine Terminal,some of which had not been inspected since the terminal was This transition must be handled carefully,as it will entail built in the 1970s. extensive training for new crews on complex equipment in Other good news,as well as issues of concern,can be the challenging,and potentially unfamiliar,environments found elsewhere in this report. of Prince William Sound and the Gulf of Alaska. The lack of crude oil spills in Prince William Sound since While our concern is heightened over the coming changes, 1989 should be celebrated as a sign that the partnership we are dedicated to working with Alyeska,regulators,and envisioned after the Exxon Valdez spill has been a success. the new contractor,to develop the trust and partnership It indicates that the prevention measures put in place since that will make sure the highest of standards of care are then have been effective.Even the best of systems can preserved for oil spill prevention and response in Prince be improved,so now,more than ever,we at the council William Sound and the Gulf of Alaska. will remain vigilant,and work together to combat the complacency identified as a root cause of the Exxon spill. OTHER CHANGES In this report,we focus on the work we have done this year to monitor and advise industry and regulators on oil spill prevention and response plans as well as changes to government policies,permits,and regulations.We have also shared our recommendations to improve safety, "...many people believe that complacency on the part environmental protections,and the process for citizen of the industry and government personnel responsible involvement with our industry and government partners. for monitoring the operation of the Valdez terminal and Some of our concerns included in this report include: vessel traffic in Prince William Sound was one of the ■ A recent proposal by the federal and state group contributing factors to the Exxon Valdez oil spill..." that plans oil spill response in Alaska that could "...only when local citizens are involved in the process have weakened how the public gets information will the trust develop that is necessary to change the and provides input during an oil spill response. present system from confrontation to Consensus..." • Low oil flow through the trans-Alaska pipeline has resulted in a severe reduction in state FROM OIL POLLUTION ACT OF 1990 revenue,leading to serious budget problems. , tr a y iif ___._ 1PWSRCAC/ANNUAL REPORT 3 — —i r- -- mac: - MISSION AND RESPONSIBILITIES The Prince William Sound Regional The council's 18 member organizations are com- munities in the region affected by the 1989 Ekon Citizens' Advisory Council is an Valdez oil spill,as well as Alaska Native,aquacul- independent non-profit corporation ture,commercial fishing,environmental,recre- guided by its mission: citizens promoting ation,and tourism groups. environmentally safe operation of the Consistent with its mission,the council's structure Alyeska terminal and associated tankers. and responsibilities stem from two documents. The council was formed after the Exxon The first is a contract with Alyeska Pipeline Service Valdez oil spill to provide a voice for Company,which operates the trans-Alaska pipeline as well as the Valdez Marine Terminal.Most of the citizens affected by decisions related to council's operating funds come from this contract. the Alyeska pipeline in Valdez and the The second guiding document,passed after the oil tankers that use it. council was created,is the Oil Pollution Act of 1990 (the Act),which required citizen oversight councils for Prince William Sound and Cook Inlet.Their purpose is to promote partnership and cooperation .; ; among local citizens,industry,and government;to build trust;and to provide citizen oversight of oil terminals and tankers. The Act allows pre-existing organizations to fulfill - the requirement for citizen oversight,which our %'" _ council has done for Prince William Sound since . - 1990.Each year,the U.S.Coast Guard certifies that 'r\ \ tdill, the council fosters the general goals and purpos �. \ . err N IT f ,„,-,,,. . ,. .._ . .. . ,,,,..„:, - �. - 4,m. 1...m . 4 • __ ,_,: ,4„ ,,.,..., .1ir .'t,., % 1 ,..4 ' ti 4 1C s 111/ - -. - PURPOSE OF CITIZEN OVERSIGHT COUNCILS •��'~ es of the Act and is broadly representative of the communities and PROMOTE PARTNERSHIP interests as envisioned in the Act. & CO-OPERATION The council's contract with Alyeska predates the Act,but the similarities in the powers and duties given the council in the two documents are not coincidental.Many people who helped establish the council also promoted citizen involvement requirements in the BUILD TRUST federal law FUNCTIONS In accordance with the provisions of the two documents,the council PROVIDE OVERSIGHT performs a variety of functions aimed at reducing pollution from OF ENVIRONMENTAL crude oil transportation through Prince William Sound and the Gulf COMPLIANCE of Alaska: • We monitor,review,and comment on oil spill prevention and response plans prepared by Alyeska and shipping compa- nies moving oil through Prince William Sound. • We monitor,review,and comment on the environmental protection capabilities of Alyeska and the tanker operators,as well as on the environmental,social,and economic impacts 0 of their activities. • We review and make recommendations on government OBSERVE VERIFY policies,permits,and regulations relating to the oil terminal and tankers. As part of these undertakings,the council regularly retains experts in various fields to conduct independent research and technical analysis on issues related to oil transportation safety. The Alyeska contract also calls for the council to increase public INFORM ADVISE awareness of the company's capabilities for oil spill prevention and response and environmental protections,as well as the actual and potential environmental impacts of terminal and tanker operations. The contract states that the council may work on other related issues not specifically identified when the contract was written. FUNDING f a The council was initially funded at$2 million a year.The funding is • 4 f renegotiated every three years;current Alyeska funding is approxi- mately$3.6 million a year. Although the council works closely with and is funded chiefly by Al- 111. yeska,the council is an independent advisory group.The contract is • explicit:"Alyeska shall have no right...to have any degree of control over the formation or operation of the corporation:' Pictured on left:Board members in Kodiak for annual September meeting.Each year the council meets in Valdez and Anchorage,and rotates through one of seven communities affected by the Exxon Valdez oil spill. PWSRCAC/ANNUAL REPORT 5 PREVENTING OIL SPILLS To ensure a maximum level of safety,the council reviews all aspects of the oil transportation system in Prince William Sound. These include operations of oil tankers and the Valdez Marine Terminal, oil spills and other incidents, and the adequacy and maintenance of the Coast Guard's Vessel Traffic Service. WEATHER AND CLIMATE RESEARCH IN to develop three different scenarios that reflect PRINCE WILLIAM SOUND "typical"wind patterns found in the Sound. Weather and climate have a larger impact on These scenarios can be replicated in the ship maritime operations in Prince William Sound bridge simulator to train students. every year.Accurate forecasts are critical when The second part of the effort is to develop graphics making decisions about oil transport,terminal that show historic wind data,termed"wind roses:' and port activities,spill planning,spill drills,and spill cleanup.Wind,waves,sea currents,and other N environmental factors can affect the safe naviga- NNW NINE tion of vessels and the ability to prevent,respond � 20% NE NW' to,contain,and clean up an oil spill. ,IOW, Speed(km) Alert ENE 0.5 The council has been working closely with weath- WNW . 5-10 er scientists at the University of Alaska Anchor- 10-15 igkffLage's Experimental Forecast Facility.The facility's ' t5-20 researchers help us with accurate accounts of yy �..� E 2025 climate conditions. EFFECTS OF WIND ON SAFE MOORING WSW ♦..♦refESE 0k 3035 LOCATIONS AND SPILL RESPONSE In one current project,the university's fore- 4t,. SW ,' �0 SE cast facility is studying potential safe mooring locations for a Th k r.an disabled aredevel-e tanker.They de el SSW SSE oping two weather-related products.The first is Wind roses like the one above can help determine where a disabled tanker or oil sic is likeioratieftilve'at a particular tint year. - Zia ""4 gwW .,kM!'"d4.'�_. -ate►-_- =11111111111.161MORM .1111•1 WiNW 6 •VVSRCAC/ANNUAL REPORT 4111111k- These wind roses are based on five years of historic leaves Prince William Sound,one tug remains as climate data and give a graphical depiction of the a sentinel,or rescue tug.That tug stays stationed prevailing winds in both magnitude and direction. near the entrance until the tanker is 17 miles out Thirty-two sites were evaluated in the Sound for to sea,and is an important measure to prevent each of the four seasons and for the entire year. a spill in the narrow passage of Hinchinbrook Entrance and in the Gulf of Alaska. MESOSCALE METEOROLOGY In another partnership with the university's This project will help the council make recom- forecast facility,the council is helping develop mendations to the industry and regulatory agen- "mesoscale"weather models for Prince William cies about: Sound.Mesoscale meteorology studies the atmo- ■ Performance capabilities of the rescue tug sphere at scales of five to 5,000 miles,a finer scale stationed at Hinchinbrook Entrance than traditional weather forecasting.Most of the • Improvements to the tugs'firefighting and weather phenomena of interest to mariners occurs towing capabilities at this scale.This mesoscale modeling provides • The rescue tug's distance from a tanker easy-to-understand graphic depictions of weather as well as its position and location during forecasts in the Sound. poor weather at Hinchinbrook Entrance. WEATHER MONITORING The council operates weather stations at Cape St. Elias and Nuchek,runs a satellite-based camera at Nuchek,and supports four mesoscale weather s • Valdez forecasts daily in Prince William Sound.The data from these projects can help make informed de- cisions and give scientifically justified advice to our industry and government agency colleagues. • dova HOW FAR MIGHT A TANKER DRIFT Nuchekdie WITHOUT POWER? The council collaborated with the university's al�c • forecast facility and naval architects from the firm Robert Allan Ltd.to evaluate the distance • d°o �o0f. and direction,under various weather conditions, gue • that a disabled tanker could drift before running island aground at the Hinchinbrook Entrance. GULF OF ALASKA Cape St.Elias Two tugs are required to escort loaded tankers through Hinchinbrook Entrance.After the tanker wow— PWSRCAC%ANNUAL REPORT 7 PLANNING AND PREPARING FOR AN OIL SPILL The council and our industry and State and federal laws require operators of oil tankers regulatory counterparts devote and the Valdez Marine Terminal to prepare detailed plans showing how they will respond to oil spills should considerable resources to preventing prevention measures fail.The council devotes signifi- oil spills, and reducing the likelihood cant resources to ensure plans are in place to prevent of another spill, but the risk cannot and respond to spills both in Prince William Sound be eliminated entirely. A quick and and at the terminal.Other planning and preparedness effective response must be ready if efforts of interest to the council include the Alaska Regional Response Team and associated committees,as 14 prevention measures fall. well as government response plans for Prince William 34 Sound,Kodiak,and Cook Inlet. t r , ` The council promotes compliance,enforcement,and r •1 funding for state and federal regulations and oversight. Along with local communities,the council encourages incorporating local knowledge of sensitive areas into •,II, ,,, contingency planning. , !st ' ' UPDATES TO OIL SPILL CONTINGENCY ' '� � PLAN FOR THE TERMINAL AND TANKERS -14 , ,'; . During the past year,the council reviewed and submit- ; `� 1 ' y� , w. ted comments on changes to the oil spill contingency • • ' , � i plan for the Valdez Marine Terminal on how a response ' r would proceed.The contingency plan covering the k H • I. ` • terminal is valid until 2019. ittet • ` tel• ' '}, �,»4 , y! 711 _ ; .. i :AC 11 ' ,..y f is ., .,1 ..`1 '': .� NI • p R a 8 PWSRCAC/ANNUAL REPORT y. The council is currently reviewing and pro- viding feedback on a proposed updated to the spill contingency plan for oil tankers in Prince William Sound.That plan is up for renewal in 2017.The first public review period began in May, and contained modifications due to the r,-' introduction of a new,improved type of oil skimmer that is more efficient. The council's review focuses on availability of equipment and personnel to respond to a spill. EDUCATING OUR STAKEHOLDERS ABOUT OIL SPILL MANAGEMENT The council continued a series of community workshops this year to educate stakeholders about M°�.. ' R;' how large oil spills are managed,and how corn- munities can interact with response leaders to stay informed and share their concerns during a Crucial Skimmer large incident. According to recent testing,this new type of skimmer is These workshops cover the basics of the incident more efficient than older weir skimmers,meaning less command system.This system,first developed in water will be skimmed up along with the crude oil.This the 1970's to manage rapidly moving wildfires,is means less storage would be needed for the oil/water a standardized structure that has been adopted to mix collected from oil spills. manage a variety of emergencies and incidents. The workshop instructors describe the process as it pertains to oil spills,and how stakeholders fit into the system. MONITORING ALYESKA'S SPILL RESPONSE PROGRAM FOR FISHING The workshop also covers the various responding VESSELS agencies'roles and jurisdictions,current preven The council met with a group of mariners who tion and response capabilities in Prince William are under contract with Alyeska's Ship Escort/Re- Sound,and how these have improved since 1989. sponse Vessel System,or SERVS,to train and help Workshop participants included city officials such respond in case of an oil spill.The group discussed as mayors,harbormasters,city managers,local the general health of the program,and any con- emergency responders,and representatives from cerns or topics of relevance with the fleet.The local agencies and other non-profits who would be fishermen represented the ports of Kodiak,Homer, affected by a spill or large incident.This year,work Seward,Whittier,Cordova,and Valdez. shops took place in Kodiak and Valdez. .► .. a ,, rV • ,41 jt� r PWSRCAC/ANNUAL REPORT 9 - iaew - a - xwT fi r. 46. re 1 ,t* 1 40 i,c. I i, *-t.e. - -- . / } , _ -. ....''''' (Of(((((((( Ilk. ' Other topics included the upcoming review for the tankers'oil spill contingency plan,the transi- .i tion of the spill response contract from Crowley 44 to Edison Chouest,and council projects such as spill surrogates(see page 13)and mesoscale weather modelling(see page 7)• Intern Researches Crude rup EVALUATING ALASKA NORTH SLOPE Oil Properties Effect on Spill CRUDE OIL FOR SPILL RESPONSE Response Technologies PLANNING Council intern Seth Suydam,originally from Seldo- - w. Properties of crude oil,such as viscosity(how via and currently studying petroleum engineering P thick the oil is) or density(the ratio between at the Colorado School of Mines,investigated how • r- mass and volume) can vary over time.Under- the physical and chemical properties of crude oil standing these properties and how they change would influence the effectiveness of those spill is vital in predicting how oil would behave in remediation technologies including in-situ burning, the marine environment in the event of a spill, dispersant application,and using skimmers.Suy- as well as predicting the effectiveness of both dam's work looked at how the properties of 2015 - mechanical and non-mechanical spill reme Alaska North Slope crude oil would influence when diation technologies.The council obtained those spill remediation technologies would be most a sample of Alaska North Slope crude oil in effective in Prince William Sound. His work helped 2015 and sent it to Environment Canada for confirm that spill remediation technologies current r ly available for response in Prince William Sound testing of its physical and chemical properties. are appropriate for the current properties Environment Canada provided the Council of Alaska North Slope crude. t with analytical results for a wide variety of r properties including viscosity,density,disper- ` sant effectiveness,and the tendency to form an emulsion. Current,accurate,and compre- ...:: hensive understanding of these chemical and - physical properties is critical for useful spill `= response planning. The results from Environ- 11 n ment Canada were shared with local regulators ' i i q {1r W, 4 and industry partners involved in Prince Wil Liam Sound oil spill response planning. ,, MONITORING DRILLS AND EXERCISES Both the Oil Pollution Act of 1990 and the coun- . cil's contract with Alyeska task the council with A monitoring the operational readiness of SERVS and the oil shipping companies. The council observes,monitors,and reports Intern Seth Suydam(right)worked with council project manager Austin on spill response drills,exercises,and train- Love(left)to analyze properties of crude oil. "PWSRCAC/ANNUAL REPORT Cr / to 411040._ U • DRILLS AND tf�. EXERCISES , OBSERVED IN '''c.',,'"',� /. ONE YEAR / A- . Vague y land / .4:'tThis map shows the location of the mock spill from the animal shippers'exercise. A Annual Oil ShippersExercise Every year,the companies who ship oil from the Valdez r terminal take turns conducting a major oil spill drill in part- - .' ' ' nership with SERVS.Last year,BP and the Alaska Tanker us. .� fi *.\' .,: "' . . `"-`' Company took their turn,conducting a multiple day exer- v F cise with SERVS.This exercise focused on a worst-case --. r.. scenario of over 500,000 barrels,or 21 million gallons,of = = ' crude oil spilled near Montague Island.The spill respond - .= had to simulate how they would take shelter with J -t .IL- their equipment during a storm,and then resume oil spill e- 112 recovery response operations once weather subsided. I I41ing in the Prince William Sound/Northern Gulf iI i ?` ?-- t----- - *' ` _... . .1'• I O _ of Alaska region to provide citizens,regulatory agencies,and oil spill responders with informa- • \�\ i , tion about readiness as well as recommendations ,, —� - -- 4s,.. , for improvement. I = The council's staff attended 13 drills and exercis- 4 es in Prince William Sound over the past year. Some of the exercises drilled response tactics for protecting sensitive areas as well as near the shore and in open water,and a large response by the Y{ Prince William Sound shippers. Oil spill exercises were also conducted at the Val- " 7 dez Marine Terminal during the past year.In the of fall,responders conducted an exercise focused on r t� sensitive area protection in Shoup Bay.That exer- i- , - I,r r '- ! cise included a newly developed response strategy ,, s `, for protecting the head of the bay.Alyeska also conducted an equipment deployment for a large ;: _`/ simulated oil spill from a pipeline breach near the pipeline's entranceto the Valdez Marine Terminal. r „,, - .. _ _, ...�(. ANNUAL REPORT it Ni . ,,, ..,,, I , i ' —� "" �� _� .•. , e, .b • al � a ,y� ,\te F .pi r '. ti•r,s 3, • , ,. ., # ,.. RESPONDING TO AN 011 SPILL To respond effectively to an oil spill or to an emergency that could cause one, it takes more than volumes of carefully written and reviewed contingency plans. It also takes equipment, trained people, and a management system to implement the plan. The council's Oil Spill Prevention and Response CHANGES TO DISPERSANTS RULES Operations program monitors the operational IN ALASKA readiness of Alyeska's Ship Escort/Response Vessel The Alaska Regional Response Team,or ARRT, System,called SERVS,and the tanker companies, established a new plan earlier this year for how oil and makes sure the council itself is prepared to spill dispersants,an alternative spill response op- respond to oil spills and other emergencies as a tion,would be used during an oil spill.The ARRT conduit for public concerns and as an indepen- is a group of federal and state agencies that share dent monitor. responsibilities for managing oil and chemical The council's staff,volunteers,and contractors spill responses in Alaska. monitor and report on spill response drills,exercis- The new plan was effective 2016,although parts of es,and training throughout the region to provide the plan will not go into effect until 2018. citizens,regulators,and responders with informa- The new plan describes two different processes tion about the state of readiness and any lessons for dispersant use.Dispersants will be"preautho- that may lead to recommendations for improve- rized"in certain areas,with all other areas marked ment.The council staff presents annual reports as"undesignated."Approval to use dispersants summarizing each year's activities,lessons learned, in both areas requires consultation between recommendations,and outstanding issues. governments,communities,and stakeholders. 12 PWSRCAC/ANNUAL REPORT y 5- A"' oil - 44,e- ,..,Yi 414 le . X, •' + . - Pr 11116__ , i . In undesignated areas,however,dispersants will be authorized on a case-by-case basis.A list of Y. " trade-offs must be considered for each location s� where dispersants are being considered:sea depth, ,�— loor distance from shore,salinity,temperature,sen- _ sitive species,and habitat.These considerations affect the decision whether to use dispersants in y undesignated areas. - The Coast Guard intends to hold meetings in a number of affected communities to gather public input to identify areas where dispersants are not communication with the authorities that make recommended.The council will be participating decisions about the response. in the process in our region. The council worked to raise awareness about this issue during the public comment period.Based on CONCERNS ABOUT CHANGES TO THE comments received from the council,and com- REGIONAL STAKEHOLDER COMMITTEE munities and stakeholders potentially impacted by Earlier this year,changes were proposed to the the proposed changes,the Alaska Department of Regional Stakeholder Committee,or RSC,that the Environmental Conservation announced that the council believed would reduce public involvement proposal had been withdrawn. in oil spill response and cleanup.The RSC is a fo- While the council's concerns have been alleviated rum for communication between spill responders for now,monitoring of a new proposal that could and stakeholders affected by an incident,which affect stakeholder input continues. has been practiced during drills since the Exxon Valdez oil spill. SIMULATING OIL ON WATER DURING The ARRT had proposed replacing the RSC with DRILLS two groups,the"Affected Stakeholders Group'; The council is leading a workgroup to find a or ASG,and the"Tribal and Local Government suitable,environmentally friendly surrogate for oil Group."The council would have become a mem- to be used during drills and exercises.A material ber of the ASG,unable to access information such as wood chips would provide a floating target allowed for in the current plan.The council would for responders to practice with during on-water no longer have access to the Incident Action Plan exercises and training events. (which provides details of the response)or direct PWSRCAC/ANNUAL REPORT 13 Lai.:,,. PROTECTING THE ENVIRONMENT The Oil Pollution Act directs our council to review, monitor, and comment on Alyeska's environmental protection capabilities, as well as the actual and potential environmental impacts of terminal and tanker operations. The Act also calls on the council to develop recommendations on environmental policies and permits. Under the leadership of the Scientific Advisory Committee and the Terminal Operations and En- vironmental Monitoring Committee,the council commissions scientific studies to determine actual or potential risks,document levels of pollution I\ and biological effects,and better understand new LAll technologies and the environmental costs or bene- 1 '..._ fits that might be associated with their use. MONITORING OPERATIONS AT THE - - _ "-"`-"' -,...,,.e... TERMINAL `- ,Y Besides posing the risk of a major oil spill caused INSPECTIONS OF CRUDE OIL STORAGE TANKS by an earthquake or accident,the Valdez termi- As part of our regular work,the council monitors nal produces ongoing air and water pollution the aboveground crude oil storage tanks at the from routine operations,as allowed by its per Valdez Marine Terminal.This year,the council mits from regulatory agencies.The council mon reviewed inspection records for Tank 12. itors terminal operations to minimize the risk of spills and ensure that the pollution emitted is The review,conducted by Harvey Consulting, within or below regulatory limits and encourages indicates the integrity of the tank is being well agencies to set limits at the lowest feasible levels. maintained. The inspection reports were thorough, `a _ ....1.. s a ` _ ..� ars u M r M. Crude oil storage tanks at the Valdez Marine Terminal. i - - • 411111.0111P, ----__.. 14 PWS, -REPO: .... • ;Rn- _ - - ANNUAL TANKER EMISSIONS REDUCED BY SWITCHING FROM 2.7% TO 0.1% SULFUR FUEL Am PARTICULATE iing sle33 `" ,, MATTER - . �., TONS ,. r - O ra ' SULFUR ''' --... �, 426 TONS OXIDES '~' � ~- ' 4'` /4 mss: .:. • 1 1 Nile 29 NITROGEN . 4 ' TONS OXIDE REDUCTION COM ° !SON 426 SULFUR OXIDES technically justified,and completed in accordance with industry standards by certified inspectors. The review further indicated that corrosion mitigation measures,such as cathodic protection and internal coatings,are being properly monitored and main- tained according to standard industry practice. EMISSIONS FROM APPROXIMATELY Based on the results of this review the council made HEAVY-DUTY two recommendations to Alyeska to improve the DIESEL TRUCKS maintenance of Tank 12. First,increase the number of inspection points on the tank's shell and roof. Second,evaluate corrosion trends using all available inspection records. IPPMIFIIIENVIRONMENTAL SCIENCE f The council monitors the environment of Prince William Sound and adjoining waters for impacts from oil-industry operations.Scientific research into such impacts,as well as research into the .0 - 4411110E- ;:" .'` -•,- _ effects of some oil spill response tactics,makes up a 4 a large part of the work done under this program. ; , AIR POLLUTANTS REDUCED BY HUNDREDS OF TONS PER YEAR This year,a council study found that using low-sulfur fuel has resulted in far less air pollution A* emitted from Prince William Sound's oil tankers than just a few years ago.The study,conducted by i // /, Starcrest Consulting Group,compared the air pol- `i PWSRCAC/ANNUAL REPORT 15 . ----- .. .;1-'off` � n ; �,�� tea+- , Cpl�1 1 '; INIh�.i� F B. M! 7 �� p , lution data from tankers that traveled through the cold waters of our region,as well as the tox- Prince William Sound during 2014 to data icity of the chemicals,especially when mixed from previous years.The researchers found with oil.This concern has led to a number of that nitrogen oxide emissions are somewhat studies on subjects including swirling flask lab- reduced but particulate matter and sulfur oratory testing,photo-enhanced toxicity,test dioxide emissions are substantially reduced. tanks,re-surfacing of dispersed oil,dispersants By switching to 0.1 percent sulfur fuel from policy,and other related subjects. the 2.7 percent sulfur fuel used prior to 2012, tankers in the Sound reduced emissions by DATABASE OF RESEARCH ON DISPERSANTS approximately 426 tons of sulfur dioxide,33 Every year,the council updates a comprehen- tons of particulate matter,and 29 tons of ni- sive database of research about dispersants. trogen oxides annually.A reduction of 33 tons The database is complemented by an overview of particulate matter is the equivalent to the of recent science conducted on dispersants, emissions from about 5,000 heavy-duty diesel including key points,new trends,and areas trucks in a year,while a reduction of 426 tons where research is lacking. of sulfur dioxide would be equal to the emis- STATE OF THE SCIENCE FOR DISPERSANTS IN sions from approximately 444,000 heavy-duty ARCTIC WATERS diesel trucks. The council,along with the State of Alaska,the CHEMICAL DISPERSANTS U.S.Coast Guard,the Oil Spill Recovery Insti- For many years,the council has been con tute,and others,were invited by the Coastal cerned about the effectiveness of dispersants in Response Research Center to participate on the Continued on page 18 , • •1, ' fi ' .. , G P s- . ---- _ • ••:.�, / ti ., "tee.. 6 .,,c ,.._. tom, r.� , d ` e,, - - 7 ,a`'.' ,t'1, ,1. R' ,tfit. , - _=.:._. -.r. 0 !" _ , f y�""�-- -- -.. :.;,: -,-,. - ,.,„,.a. hili► - /� 16 PWSRC-^C ANNUAL REPORT "' ,. y r 3j , r . ,'i'{ ; y ••, over many years,does not support the claims of dispersant 4 ` WIIIIF proponents regarding effectiveness ?` `, ‘iii( , ... of dispersants in our cold and low 'l•. � , 7, salinity waters. New research also .11;1(:,y• . , w ''t. l'ill `• -'•'�., . -- reveals increasing concerns about l • low-level chronic toxic effects from 15, .; A ;�` oil and dispersed oil(see page 18). 1{ Because of these concerns about �' ;- •„, whether dispersants actually work, r.. ,moo w 'p ��. . >� as well as the toxic effect they have t on sea life,the council does not ' support the use of dispersants. oft The council supports mechanical recovery,which remove_, ' -..,..- . ;x from the water,as th•, 1) I method of oil spill '�7 Environmental Monitoring MONITORING INVASIVE SPECIES ., _ " i Invasive species, such as the o `' �N. European green crab,can sometimes catch aP P a ride in the ballast water or attach to the hull of a tanker into a new 4 M 'r., , .., ' + environment where there are no native predators to keep populations in :444 check. If the invaders become established,they can have a significant • economic and ecological effect on the area.They can destroy local �'' species and habitat, including commercially important species that are of value to local economies,such as Alaska salmon.Some ports visited 1 � �` , ' , . by the Prince William Sound oil tankers have known marine invasive { �` y._ ,, 1;,,t+ ,- species populations. -.{ \ ,.,► The council supports citizen-based monitoring for marine invasive species, particularly the European green crab and invasive tunicates.The green 1 crab,a known ballast-water-borne invader,is an efficient and voracious • ' s predator that has invaded the West Coast from San Francisco to Vancouver I. Island. It is feared that the green crab will find its way to Alaska waters. , • ',' The monitoring program has evolved into a self-sustaining grassroots s - / ' 'i, system since the council initiated it in 2000.The council continues to f ;)1 support some of the smaller communities to encourage participation for 1 * , those areas. No green crabs have yet been captured in the council region by these efforts. j BALLAST WATER ,t The council has been studying the amount and sources of ballast water dis- ` charged into Port Valdez and Prince William Sound.This study identifies the `. number of unique and repeat voyages arriving at the terminal and analyzes r 7^.:•-sw.wyn! .: the volume,source,and type of ballast water discharged by these vessels �'#tJl• r ,.. I , !"a � /t �. into Prince William Sound between 2005 and 2015.This data helps us bet ,• ter understand the risk of aquatic invasive species arriving in our area.One 1 • „ ,,.r'� ° ` ,,,,,fir ' '1 ,F way to reduce invasive species arriving in our waters is to exchange ballast L •'� ,, t, ..r) ,+ ' � water in open water outside of Alaska,where there are fewer species that 4. 'n 1i' r`�`` =":IN.11 :' ' could survive in Prince William Sound.The study showed that the amount of ` -'-e sT„ Cii " ' "'M :. ballast water exchanged in open water is increasing. .Z "il 1 /� ' iI ( t PWSRCAC/ANNUAL REPORT 17 nl �, EFFECTS OF CRUDE OIL .vgirEXPOSURE ON THE EMBRYOS OF PINK SALMON AND PACIFIC HERRING Permanent changes in heart anatomy and physi- ological performance AFTER 7-10 MONTHS OF _... GROWTH IN CLEAN WATER Continued reduction in aerobic capacity and permanent changes in the heart's anatomy and performance Rb�lr 4 Ape • i Organizing Committee for the State of the Science was found to for Dispersants in Arctic Waters Initiative,an cause cardiac initiative funded by NOAA and U.S.EPA.This led abnormalities . 't to a workshop held January 2015 in Seattle titled that lead to per- the"State of Science for Dispersant Use in Arctic manent changes in Waters."While the council's work is focused on the heart anatomy and Exxon Valdez oil spill impacted region,the science physiological perfor- on dispersant use in the Alaskan Arctic is related mance.When assessed after and increases our knowledge about the effects of 7 to 10 months of growth in clean water,both using dispersants in the subarctic waters and on species showed reduced aerobic capacity and species of Prince William Sound. abnormalities in the heart that lead to permanent TOXICITY OF OIL changes in the heart's anatomy and performance. Recommendations from the report have been The council researches and addresses the gaps in transmitted to industry and agency stakeholders knowledge about the chronic toxic effects of oil, and the report has been posted on the council's dispersed oil,and"in-situ"burn(burning spilled website. The peer review version of the paper was oil)residue under study conditions similar to the published at Scientific Reports for Nature.com in cold marine waters in our region. August 2015.Since being published it has received LOW LEVELS OF CRUDE OIL SHOWN TO HAVE a great deal of media attention locally,nationally, LONG-TERM EFFECTS ON SALMON AND HERRING and internationally. This past year the council worked with NOAA Fisheries'laboratories to determine the effects of MONITORING FOR LINGERING OIL low levels of crude oil exposure on the embryos In 1993,the council started monitoring the region of pink salmon and Pacific herring.The exposure affected by the Exxon Valdez oil spill to assess the 18 PWSRCAC ANNUAL REPORT gg-S� status of hydrocarbon levels in Port Valdez,Prince genetic changes in mussel species,tests for how William Sound,and the Gulf of Alaska.This pro- those genetic changes occur,and how to deter- gram monitors the long-term downward trend of mine whether the"animals"have been exposed to, lingering oil in the Sound from the Exxon Valdez or injured by,hydrocarbons.They also looked at spill,as well as any new oil spilled since that time. contemporary methods for evaluating the effects The Oil Pollution Act of 1990 directs the council of hydrocarbons on the genome of mussels,iden- to"devise and manage a comprehensive program tified gaps in existing knowledge,and pinpointed of monitoring the environmental impacts of the areas for future research.This report will help us operations of terminal facilities and crude oil improve and update the technologies used in our Sound." long term environmental monitoring efforts,while tankers while operating in Prince William This project fulfills this directive. continuing to use mussels as the target species. Today,samples are periodically collected at select- DETECTING POLLUTION BY SATELLITE ed intertidal sites in Prince William Sound and the The council is investigating the potential of using Gulf of Alaska.Mussel tissues and sediments from satellite data to detect oil spills in the region. Sev- the sites are analyzed in a laboratory to determine eral European countries use satellite technology whether hydrocarbons are accumulating and,if as a regular part of their spill detection strategies. so,the source of the hydrocarbons.The result is This demonstration project gathered information the largest chronological data set ever compiled about systems,costs,and availability of various for hydrocarbons in Prince William Sound.The satellite detection capabilities available at this council reports on this data annually.Every fifth time.The costs continue to come down and public year,a more in-depth report summarizes the data access to satellite data is becoming more easily and trends of the previous five years.A new five- available.The Sentinel One,a satellite launched year trend report was completed this year. in April 2014 by the European Space Agency,now provides free data access to non-profit organiza- EFFECTS OF HYDROCARBONS ON MUSSELS tions. Technological advances in radar also pro- This year,the council began studying the effects of vide the capability to identify and track oil spills, hydrocarbons on the genes of mussels and related proven useful in Europe and Canada. species.Researchers compiled knowledge about .. - 1K - pirt , A tillik ,�+,� J ' ► APs•r• C 1.1 -."' .g ; .. '. ' 41 0 ick,i, i - . 'if ° ; Stdt. . - i 1�'J L-. _-...... - , , 'yr ' ilia iiiiiiiiii 1',� . . 7„. as- - - i-' . Vis' ;e a 'fir 1 • 3 5 OttCi RCACIANNUAL Rv• . ld ,. i- r ,, 0 , The council maintains productive relationships with 1, its 18 member entities, which include communities •�-= within the region affected by the 1989 Exxon Valdez oil spill, as well as aquaculture, commercial , • fishing, environmental, Alaska Native corporations, recreation, and tourism groups. •oidP .•_ MJF 4 C 14 ;i - _ lit 1 8 , . _ , ,,I, 4s 1410.- , G ,x 4. ., , , , _ ,,_ 1 -- OIL SPILL SCIENCE STATIONS ` - ' OF HANDS-ON FUN TO `' '��� �'� �� � '� ,d FAMILIES IN KODIAK, ,, CORDOVA, AND VALDEZ I `-' 1 ENGAGING THE NEXT GENERATIONS TO PROTECT PRINCE - WILLIAM SOUND Viiiir FUNDING YOUTH EDUCATION ment opportunities.This year,one high PROGRAMS school and two college students helped us The Information and Education Committee educate kids in schools using our oil spill helps support regional partners'programs curriculum,monitor Cordova for invasive which teach youth about topics related green crab,and study the properties of to the council's mission.Youth of all ages Alaska North Slope crude oil(see participate in a variety of settings to learn page 10). about oil spill prevention and response, - citizen oversight,the response capabilities MASTER OF DISASTER in Prince William Sound,and more. This year the council started a new out reach program that will travel with our INTERNS HELP COUNCIL ACHIEVE board meetings each fall.Volunteers and . — OUR MISSION staff worked together to bring eight oil x u ,. The committee recruits youth interns spill science stations of hands-on fun to 6 from our region to complete council proj- families in Kodiak,Cordova,and Valdez ;`b ects that also incorporate career develop- this year. ! *. ' 'c nt PWSRCAC/ANNUAL REPORT trirt=„ ' ' 111111111P. . s-. t I ,4110 11 4 i _ ',. 576 -- \ 1 , I .iikikill. ..... ..iir :,,.,, , .i., KIDS AND TEACHERS ;4 t ''�. REACHED THROUGH •`.�� 4 YOUTH INVOLVEMENT ' •_ � Ccsisit. i„---- -----.2-I /.. ......._ [ r ! ii-, i ' •'' J NIi At :.'ill'illitillill '41 \ I .. I ,Olk.016. , , _ 14 6 ,_____....,....... N \., _____44 , L , L REGIONAL PARTNERS PROJECTS AFFECTING., INVOLVED IN OUTREACH DIFFERENT COMMUNITIES -' , AND EDUCATION PROJECTS COMPLETED BY rf AND PROGRAM THREE INTERNS ate. "`: Ail a i OW Ce .a,4, CO P A ANNUAL OR " h 7. :—.*tiett: 1 ;, ,,„, , , , , ,,,,. ,,,,t-.....,,..' ., _ 117:4hit ,, 7 ,iii i , . , 4 ,,t, , _ _ _ .; , ,, i , , ,..... , ,...., _ ...,.._ ..--- 1 w , i , ,,, ei :. „.:. , , . . , , ,.... ,. . . , ... .,, I\ i 4 I rib S A e- rit l F COMMUNITY OUTREACH The council's dedicated outreach coordinator works with staff and volunteers to visit communities in the council's region,attend group member functions,give presenta- 1 tions,coordinate special events involving the council and -4,. . its member groups,and encourage citizen involvement in _ _ _ ri the council's work. The council's Information and Education Committee '``�'�� -r,s.=--Amm , teams up with staff to support the council's mission by: - ,-.--' ■ Fostering public awareness of our work - o• Building participation of current and future gen- _ erations in the council's environmental steward- ship responsibilities pi im it �w ir4ii , is ,wr kill - R _ . : ' a. '-Nii, t mi, 22 PWSRCAC/ANNUAL REPORT at' e_,---_-._;_- � •.yam\ 0 r_, �` _ TOURING FISHING VESSEL SPILL RESPONSE L= ' e TRAINING - ' � ..., - , ,f This spring,the council partnered with Kenai Fjord Tours ��'��= —*w and Alyeska to take Seward residents out to see SERVS'lo- cal fishing vessel responders'annual oil spill response train- ing.Ninety people spent two hours with us on the water in 4_this pilot project,including curious members of the general .. public,two high school biology and chemistry classes,and local and statewide media.They learned how local fisher- men take part in Alyeska's oil spill response team.Alyeska helped us narrate the oil spill response training,equipment and tactics being used,and the reasons this unique pro- gram exists.The council plans to host similar tours in other communities with the SERVS fishing fleet in coming years. COMMUNITIES REACHED BY OUTREACH ACTIVITIES o, 't .t R y, ire+ 4 - r.," -----..._. 1� n n 11 oars __ I rr 1/00...- 41111016.000111111.011.11* ,•' .011 , i :*:'-:-- . iiiiiikilH„.",,,----"' .11,1)4 y ^ l iii V T \ '✓ t e 411 .. 7 Ai I i e �` • ', .KC'" •NNUAL REPORT 23 6 OUTREACH ACTIVITIES KODIAK ISLAND PORT LIONS Incident Command for Stakeholders,Community Member Participation at Public Workshop in Kodiak Rural Salmon&Science Camp, Youth Involvement Project LARSEN BAY Incident Command for Stakeholders,Community Member Participation at Public Workshop in Kodiak "West Side Stories"Oral History Interviews, Youth Involvement Project ,zUK Incident Command for Stakeholders,Community Member Participation at Public Workshop in Kodiak KODIAK ISLAND Incident Command for Stakeholders,Community Member Participation at Public Workshop in Kodiak OLD HARBOR Incident Command for Stakeholders,Community 110C Member Participation at Public Workshop in Kodiak r- 24 PWSRCAC,/ANNUAL REPORT BOARD OF DIRECTORS Our 18 member entities include state-chartered cities and boroughs, tiny Alaska Native villages with tribal governments, Native corporations, commercial fishing organizations, an environmental consortium, and groups representing the tourism industry. HOW IS THE BOARD ORGANIZED? WHO SERVES ON THE BOARD? Each member entity chooses one representative The names and faces change,but current to our board.The lone exception is Valdez.It and recent board members have included has two representatives,giving our board a total commercial fishermen,a schoolteacher,the of 19 members.The board meets three times a chief executive of a regional Native cor- year.The January meeting is in Anchorage,the poration,tour-boat operators,an oilfield May meeting is in Valdez,and the September engineer,small business owners,scientists, meeting rotates among other member commu- and a village mayor. nities in the oil spill region. Executive Committee 41114 111 AMANDA BAUER THANE MILLER BOB SHAVELSON WAYNE DONALDSON President Vice President City of Valdez Prince William Sound Oil Spill Region City of Kodiak Aquaculture Corp. Environmental Coalition Ex-Officio Board Members (Non-Voting) • Steve Russell,Alaska Dept. of Environmental • Chris Field, U.S. Environmental Protection Agency Conservation • Phillip Johnson, U.S. Department of the Interior • Lee McKinley,Alaska Department of Fish and ■ Commander Joe Lally, U.S. Coast Guard,Marine Game,Division of Sport Fish Safety Unit, Valdez • Robert Skorkowski, U.S. Forest Service • W.Scott Pegau, Oil Spill Recovery Institute, • Graham Smith,Alaska Dept. of Natural Resources Cordova • Kevin Kearney, U.S. Bureau of Land Management • Catherine Berg, U.S. National Oceanic and • Colin Blair,Alaska Div. of Homeland Security& Atmospheric Administration Emergency Management 30 PWSRCAC i ANNUAL REPORT -me- ' ' ' ode :.. 4v � A c ye , ,g� # n, ,� ALP A. r '`d . fi,+.. .� ' y ., r, ._ '' ����e.1, ` t d "► itt. 1,44 :1. r _ -ammer Irk - - - - _ . I -4,- - cz, _ t _U# t • e ON THE WEB The council also monitors federal government actions The council's online presence,including our website and issues through its Legislative Affairs Committee and social media,serves as a public communications and a contract representative in Washington,D.C. tool and educational resource to increase public awareness of the council,the history of the council RECERTIFICATION and citizen oversight of the oil industry,and the envi- The Coast Guard certifies the council as the federally ronmental impacts of the transportation of oil through approved citizens'advisory group for Prince William Prince William Sound.The use of such technologies Sound,pursuant to the Oil Pollution Act of 1990.The help us foster dialog and engagement between the council has been the certified group since 1991. council,our constituents,and the online community. Under the annual recertification process,the Coast GOVERNMENT RELATIONS Guard assesses whether the council fosters the general goals and purposes of the Act and is broadly represen- The council monitors state actions,legislation,and tative of the communities and interests as envisioned i ''''- regulations r_regulations that relate to terminal or tanker opera- in the Act. , tions,or to oil spill prevention or response.To track developments in the state capital,the council retains a As part of its recertification process,the Coast Guard monitor under contract during the legislative session. considers comments from industry,interest groups, This area of council activity is coordinated by a Legis- and citizens.The council fulfills the Act's require- lative Affairs Committee made up of members of the ment for an industry-funded citizens'advisory group, , council board. although it was established before the law was enacted.1W Arr r alik aj .,,,._ R- „ „ - . , ,, * ,. ..., .. s _ „..... , , .,, iiiiiii.„ PWSRCAC/ANNUAL REPORT 29 i . , * , ' ' 1 1 4 - I A ' t L ,.. •4,. ir , „ , , • :i 1 .. - 1 /1.-----.'4 .tJ,,„r I .t1 � R' '1 P '• -41P"--:-.4' z:y.- : �1 ; , . 1 i 4 ..... • Ali!I. j ;- rts`fir `. r ' 1, g PUBLICATIONS4...- The council increases public awareness on a wide range of issues `: pertaining to crude oil transportation through printed and online publications,such as The Observer and this annual report. THE OBSERVER NEWSLETTER ,- The Observer is a free newsletter with nearly 5,000 printed copies ow ' distributed throughout Prince William Sound,the northern Gulf of Alaska,lower Cook Inlet,and the Kodiak archipelago,and by request to interested citizens around the world,including regula- tors.. and industry.It covers council activities,developments in the oil transportation industry related to our mission,and news about i policy and operational issues related to marine oil transportation ham+, ; , in Prince William Sound.Major oil spill drills are covered,and Al- .-';401,114 yeska is invited to submit a column for each issue.In the course of 1 preparing articles for The Observer,the council frequently invites feedback from industry and regulatory personnel.The Observer is I, - available on the council website and as an email newsletter. • .,��1 psw Ou^Iw� 1/ //I)< '� Y ~� ,` .y4;_.i^ i So,,,42'0'1,7"--11::;:"17----71‘57:‘-'61,' Alyeska ^c. ,+n^e l) 1'. ., +,,, Ti •ly; M 1 ie::: 1,;�n 2018 If 4, 1' L /orlo Wali edClY o/Va1,..„...".....1.4%.1 eF yhfng reoIO Plan.a .e _ '-t�` r -----. �°�01w nka . _ 1 viv k .r . t ,L Y'kr 's, , \N.t. 38 RCAC/ANN i PORT *le WHITTIER VALDEZ • Xploration Awesome Planet, Television Gold Rush Days,Booth Outreach OP Series Interview ■ Alaska Oil Spill Curriculum Program,Presentation • Alaska Oil Spill Curriculum Programs, • Crooked Creek Chum Salmon Incubation Project, Youth Internship Presentation Youth Involvement Project City Council,Presentation 4 Valdez Schools Career Fair,Booth Outreach • Public Reception f • Alaska North Slope Crude Oil Properties Project Report, Youth Internship Presentation • Public Family Outreach Event, Youth Involvement 4 Outreach&Youth Internship Presentation a City Council,Presentation • Incident Command for Stakeholders,Public Workshop i ■ Board Meeting and Public Reception w x �, . ,• ,_:._ ,� ! ,, TATITLEK 110 .4 4,4 ■ Peksulineq Cultural Heritage Day,Attendance Incident Command for Stakeholders,Public Workshop(in Valdez) at : , CHENEGA BAY AI CORDOVA Alaska Oil Spill Curriculum Programs, J Alaska Historical Society and Museums Alaska y Youth Internship Presentation Conference,Presentation&Booth Outreach a Community Visit&Public Reception Copper River Nouveau,Support&Attendance a Incident Command for Stakeholders, Discovery Room Oil Spill Education, Youth Public Workshop(in Valdez) Involvement Project a Chenega Memorial,Support Aquatic Invasive Species Monitoring, Youth Internship City Council,Presentation SEWARD ■ Tsunami Bowl, Youth Involvement Project a Remotely Operated Vehicle(ROV)Challenge, Youth Involvement Project ■ Marshall Memorial Fellowship Program, Presentation a Fishing Vessel Program,Public Outreach Event& Television News a City Council,Presentation PRINCE WILLIAM SOUND EVENTS OUTSIDE THE REGION a Alaska Geographic Teacher Expedition, Youth Alaska Math&Science Conference,Sitka Involvement Project Clean Gulf,New Orleans a Copper River Watershed Stewardship Expedition, Pacific Marine Expo,Seattle Youth Involvement Project Oil Spill Technology Symposium,Fairbanks ■ Alaska Geographic Youth Expedition, Youth International Conference on Aquatic Invasive Involvement Project Species, Winnipeg a Arctic Marine Oilspill Program Technical Seminar,Halifax a U.S.Coast Guard Change of Command,Juneau a Clean Pacific,Seattle PWSRCAC/ANNUAL REPORT 27 OUTREACH ACTIVITIES PRINCE SOUND AND OUTSIDE • Coffee with a Scientist,Presentation • Oil Spill-themed Certified Interpretive Guide Course,Presentations • World Wildlife Fund Workshop,Presentation • U.S.Coast Guard Foundation Dinner,Support &Attendance • Alaska Forum on the Environment,Oil Spill Track Presentations, Youth Internship Presentation,&Booth ' • Incident Command for Stakeholders, Public Workshop KENAI • Alaska SeaLife Center Marine Gala, Support and Attendance • Alaska Science and Engineering Fair, PENINSEA IEC Youth Involvement Project i • Board Meeting KEN • Salmonfest,Booth Outreach • American Fisheries Society—Alaska Chapter 4 Conference,Presentation lb 41 • Aquatic Invasive Species Monitoring, Youth Involvement Project _, ■ City Council,Presentation /. SELDOVIA Aquatic Invasive Species Monitoring, PORT GRAHAM Youth Involvement Project • Alaska Oil Spill Curriculum Programs, Youth Internship Presentation • Community Visit&Public Reception • Aquatic Invasive Species Monitoring, 1111 PRINCE W I L L I A M Youth Involvement Project SOUND • REPORT IIIkI wr •, • OUZINKIE . J J a Rural Salmon&Science Camp, Youth Involvement Project . KODIAK ■ Incident Command for Stakeholders,Public Workshop .--*' • Board Meeting and Public Reception • Public Family Outreach Event, Youth Involvement Outreach ■ "West Side Stories"Oral History Interviews, Ilk Public Radio Spots&Youth Involvement Project At a City Council,Presentation 4 • Crab Festival,Booth Outreach .. , h1- y dee • littio:4‘) wv r� I t w 3 ' If +w,;;= r,ill ' 001:- . ' -'. 6t ° - _ '—.-- assakiima -_. «-- i ,_� Acia- . 4 _ 1 j" .444.0..........:tr-..—,z,.... . '-, --, ..- - 7 ....... i,.. . . ..... ......... .. I ,- sx� PWSRCAC,ANNUAL REP• ...... e R(AC - ` f4411' .4 , 7..-r- , . ,_ . ,_ , i , .if, ,., '"-- , i 4 . .". 1 _ +1, IF I ill.- � .400\ 11 .S.3 u ::41.:4r4 lit :,..., ' Other Directors N t1 ; 3 p ROBERT ARCHIBALD ROBERT BEEDLE MIKE BENDER MELISSA BERNS Mayors Association ...4:414,: s j Ilk iiiiiiiiiiiki t AL BURCH PATIENCE ANDERSEN MAKO HAGGERTY LUKE HASENBANK FAULKNER of Commerce J w 4 +; JOHN JOHNSON JIM LABELLE DOROTHY MOORE 0''0 Seward 10 . I '1 ALISHA CHARTIER ROY TOTEMOFF k Chenega Corporation .... ,..,, Chenega IRA Council - ° , 7 ANNUAL REPORT 31 ADVISORY COMMITTEES Five standing committees advise the Board of Directors and the council staff on projects and activities. Committee volunteers also assist the staff on individual projects. The advisory committees are made up of interested citizens, technical experts, and members of the council board. Committee volunteers are selected through an annual application process. They are appointed to two-year terms and may serve consecutive terms. OIL SPILL PREVENTION AND RESPONSE PORT OPERATIONS AND VESSEL COMMITTEE TRAFFIC SYSTEMS Mission: Minimize the risks and impacts associated Mission:Monitor port and tanker operations in Prince with oil transportation through strong spill preven- William Sound and recommend improvements in the tion and response measures,adequate contingency vessel traffic navigation systems and monitors the planning,and effective regulations vessel escort system • Chair:John LeClair,Anchorage • Chair:Amanda Bauer,Valdez* ■ Vice-chair:Jerry Brookman,Kenai • Vice-chair:Pat Duffy,Valdez ■ Robert Beedle,Cordova* • Robert Archibald,Homer* ■ Mike Bender,Whittier* • Cliff Chambers,Seward • Colin Daugherty,Anchorage • Pete Heddell,Whittier • David Goldstein,Whittier • Orson Smith,Seward* • Jim Herbert,Seward • Jeremy Talbott,Valdez ■ Gordon Scott,Girdwood • Alisha Chartier,Seldovia* r / _ 1l > -moi , �'_ - v y (P. _,«I/ ; ` : • " ..... ' am-' 17' 40 r ;' ,,, _ate :ter. - - Mt•J'..'r .r '. — -.icor •I _ .i *' ,..$ n,+In—..,•iy r .� .,. *..nlMi"' ' / "'"`• ,.. �.r"- :4" t1+� (. • r .,• ' _ - .,. .mer a . '— ' • I* f µ rr c t• - y .4 • der' ' mac..r+- y,,y� t s- ''" TERMINAL OPERATIONS AND r ENVIRONMENTAL MONITORING r Mission:Identify actual and potential sources of episodic and chronic pollution at the Valdez ` Marine Terminal • Chair:Harold Blehm,Valdez .ra = ' ''■ • Vice-chair:Mikkel Foltmar,Anchorage • Amanda Bauer,Valdez* • Steve Goudreau,Valdez SCIENTIFIC ADVISORY COMMITTEE • Tom Kuckertz,Anchorage Mission:Promote the environmentally safe operation • George Skladal,Anchorage of the terminal and tankers through independent scientific research,environmental monitoring,and review of scientific work INFORMATION AND EDUCATION COMMITTEE Mission:Foster public awareness,responsibility,and ■ Chair:John Kennish,Anchorage participation through information and education ■ Vice-chair: Paula Martin,Soldotna • Sarah Allan,Anchorage • Chair: Cathy Hart,Anchorage • Jeffrey Brooks,Anchorage ■ Vice-chair:Linda Robinson,Homer • Wayne Donaldson, Kodiak* ■ Trent Dodson, Kodiak • Roger Green, Hope • Jane Eisemann, Kodiak • Davin Nolen,Anchorage • Patience Andersen Faulkner,Cordova* • Dorothy M.Moore,Valdez* • Ruth E. Knight,Valdez • Debasmita Misra,Fairbanks • Andrea Korbe,Whittier ■ Mark Udevitz,Anchorage • Kate Morse,Cordova *member of board of directors ‘I.*.7 I I I I I ih I lb'T. 1 6. , \ —— ' illik It Ali - Iiii vt.:4411Ike11111411110 .. . 4 ,0 r i 0p,..:;410Ic,_ _ _i-,.. •...' ,, Al , ,,,,, . 9' ' rif:-• 'fit , , '---'' - '- * . 4111111, ^ r� . V •, el 4°3 ta° j."-1.1 . j� i ,_J f , � , z1 � ( � / :� -;: ‘: 1"::'-':,* r F'r 3 /!'' j��r r . s fly•, Y. �. y e ., ''' --.:04 '''s - e• . ._- ,, ..,, , ,,,.. ._ ... ., , „de ' ,-. - , , .. ‘55 ,I i z.-..," 'Are* ift-41°*s r, 1f e �s I ,moi . ,, �` _ i ' L ' • mac.. �+t 1 #tiF y d .` __.a_ • �'�. eil ���t 4+w•t.�; ; :- ,^•-Z,rt _ "SFW ,t il Staff • Donna Schantz, Executive Director • Natalie Novik,Administrative Assistant • Joe Banta,Project Manager ■ Shawna Popovici,Project Manager Assistant • Gregory Dixon,Financial Manager ■ Roy Robertson,Project Manager • Jennifer Fleming, Executive Assistant ■ Jeremy Robida, Project Manager • Amanda Johnson,Project Manager ■ Alan Sorum,Project Manager • Austin Love,Project Manager • Linda Swiss, Project Manager • Leigh Lubin,Administrative Assistant • Nelli Vanderburg,Project Manager Assistant • Lisa Matlock,Outreach Coordinator • Walt Wrede, Director of Administration O WORLDWIDE WEB www.pwsrcac.org O EMAIL:anch©pwsrcac.org O FACEBOOK:www.facebook.com/PWSRCAC O TWITTER:twitter.com/PWSRCAC ® Sign up for the email version of The Observer newsletter:www.bit.ly/TheObserverByEmail 34 PWSRCAC/ANNUAL REPORT ' I 1 • �� , ; Sr\ �': r " \N ' �0 No. ` ` -111% 40i-r i ,...-,....,,,, v . .alba ,3 hv �` Photo Credits Key:t:top;b:bottom;c center;r:right;1:left; P13:c:Shawna Popovici b/l:Lisa Matlock;b/r:courtesy Lisa Matlock bg:background P14:b:Nelli Vanderburg;t:Shawna Popovici P23:t/r and bg:Cathy Hart Cover photo:Amanda Johnson P15:t/r:Jennifer Fleming P24-25:bg:Nelli Vanderburg P1:Bill Rome P15:bit:Cathy Hart P25:t/r:Michael Vigil;c/l:Poppy Benson; P2-3:bg:Ryan Johnson P16:l:Bill Rome;c:Linda Robinson; b/l:Amanda Johnson;b/r:Lisa Matlock P3:t/l:Bill Rome b/r:Cathy Hart P26-27:bg:Lisa Matlock P4:bg:StockPhoto P17:l:Bill Rome P28-29:bg:Shawna Popovici P4-5:b/c:Amanda Johnson P17:t/r:Nelli Vanderburg P29:Courtesy of the Office of Governor Bill P6-7:bg:Nelli Vanderburg P18 l:Cathy Hart Walker P8-9:bg:Cathy Hart P18:c:by Lisa Kaaihue P31:t/l:Natalie Novik;t/c:courtesy Lisa P9:t/l:Roy Robertson P19:b:Marybeth Phyllis Matlock;t/r:Nate Svoboda P10:t/l and t/r:Jeremy Robida; P20:t/l and t/r:Amanda Johnson P32-33:bg:StockPhoto b/r:Amanda Johnson P20:c/l:Lisa Matlock P33:t:Amanda Johnson P10-11:Jeremy Robida P21:t/l,t/r,b/l,and c/r:Amanda Johnson; P34-35:Cathy Hart P12-13:bg:Shawna Popovici b/r:Lisa Matlock P36:bg:Nelli Vanderburg P13:t,and b:Jeremy Robida P22:t:courtesy Lisa Matlock;c/r:Jim Herbert; Credits Editor:Amanda Johnson Designer:Shaila Abdullah PWSRCAC/ANNUAL REPORT 35 PAPERS, PRESENTATIONS, REPORTS, AND MEDIA RELEASES 2015 Prince William Sound RCAC Annual meets).Citizens'Council.February 2016.Document Prince William Sound Dispersants Monitoring Pro- Drill Monitoring Report(report).Citizens' number:651.105.160204.ADECvmtCmts.pdf tocol:Implementation and Enhancement of SMART council.January 2016.Document number: (Special Monitoring of Applied Response Technologies) 752.431.160101.2015AnnualRpt.pdf Comments on the 2016 Applications for Renewal (report).Citizens'council.July 2016.Document Number: of the Prince William Sound Tanker Oil Dis 955.431.160731.SMARTwhitepaper.pdf ADEC Spill Prevention and Response Division, charge Prevention and Contingency Plan(Core Prince William Sound Unit Staffing(comments). Plan),Alyeska's Ship Escort Response Vessel System Recommendations for revising title 18,Chapter Citizens'council.June 2016.Document number: (SERVS)Technical Manual(SV-140(,and individual 75 of the Alaska Administrative Code(report 600.105.160613.ADECStaffing.pdf Vessel Response Plans for Alaska Tanker Company,BP and letter).Citizens Council.July 2015.Document Analysis of Crude Oil Tanker Ballast Water Data Oil Shipping Company,Polar Tankers,Inc.,SeaRiver number:600.105.150701.18AAC75Cmts.pdf and Maritime,Inc.,and Tesoro Maritime Company(corn- 600.431.150701.18AAC75Cmts.pdf for Valdez and Prince William Sound,Alaska meets).Citizens'council.July 2016.Document number: (report).Danielle Verna.February 2016.Document 651.105.160701.PWStkrCmtCvr.pdf Review of Best Available Technology(B.A.T.) number:952.431.160229.VernaBWTdata.pdf For a Sentinel Tug Stationed at Hinchinbrook Comments on the Valdez Oil Discharge and Entrance(report).Robert Allan,LTD.May 2016 Call for Agreement on Exxon Valdez Oil Spill Contingency Plan,ADEC Plan Number 14-CP- (Revision 2).Document number:801.431.160504. Restoration under Reopener for Unknown 4057,Amendment 2015-1,Facility Oil Piping RALsentinelBAT.pdf Injury(comments and resolution).Citizens'council. BAT Amendment(comments).Citizens'Council. September 2015.Document number:210.105.150922. August 2015.Document number 651.105.150814. Satellite-Based Pollution Monitoring in Prince Wil- EVOSReopener.pdf VMTcPlanCmts.pdf liam Sound(report).C-CORE.January 2016.Document number:900.431.160101.SatBasedMon itor.pdf Comments and Requests for Additional Information Comments to Federal and State Regulators on the 2016 Application for Renewal of the Prince on Changes to Annex D of the Unified Plan Sentinel Tug Requirements for Gulf of Alaska: William Sound Tanker Oil Discharge Prevention and (comments).Citizens'Council.June 2016.Document Ship Drift Study(report).Robert Allan,LTD.May Contingency Plan and SERVS Technical Manual number 600.105.150615.ARRTAnnexD.pdf 2016(Revision 1).Document number:801.431.160504. (comments).Citizens'council.July 2016.Document RALdriftStudy.pdf number 651.431.160701.PWStkrCmts.pdf Comprehensive Review Alyeska Pipeline Service Company API Standard 653 Inspections for Supplemental Comments on the Proposed Comments on ADEC's report titled"Response Amendment to the Alaska Unified Plan(Annex Tanks 12,13 and 14(various reports and comments Exercise Program Improvements—DRAFT"(whiteB)that would eliminate the Regional Stake- letters).Harvey Consulting and Citizens'Council. paper and letter).Citizens'Council and the Cook Inlet January 2016.Document number 500.105.160610. holder Committee(comments).Citizens'council. Regional Citizens'Advisory Council.April 2016. Docu- April 2016.Document number:600.105.160531. APSCtankl2Rpt.pdf,500.431.160122.HarveyTkl2insp. ment number:752.431.160413.JointWhitePapr.pdf and pdf,500.431.150523.HarveyTk14lnsp,500.431.150523. RSC 600.105.160429.AKDeIRSCchange.pdf and 651.105.160413.ADECdrillsDB.pdf 600.105.160421.GOVrscChange.pdf HarveyTk14lnsp,and 500.105.150803.ADECTanks1314 Comments on Alyeska Pipeline Service Company, Effects of Hydrocarbons on Mussel Genomics Supporting the Installation of a Weather Station Valdez Marine Terminal Oil Discharge Prevention (report).US Geological Survey.December 2015.Docu at the Valdez Marine Terminal(comments and and Contingency Plan,ADEC Plan Number 14-CP- resolution).Citizens'council.February 2016.Document mens number 951 A31.151201.MusselGenomic.pdf 4057,Amendment 2016-01,Scenarios 1,2,and 3 number:800.105.160208.VMTwxStation.pdf (comments).Citizens'Council.April 2016.Document Hydrocarbon Research Internship(report).Council number:651.105.160407.ADECvmtScenario.pdf Intern,Seth Suydam.May 2016.Document number: Tanker Pollutant Loading to the Prince William 500.431.160501.InternHCResearch.pdf Sound Airshed(report).Starcrest Consulting Comments on notice of proposal to change Group,LLC.October 2015.Document number: regulations dealing with oil and other hazardous Physical Properties,Behavior and Composition 557.431.151001.TnkrPollution.pdf substance pollution control cost recovery(com- of Alaska North Slope 12015]Crude Oil(report). Tug Bollard Pull Requirements for Rescue Towing meets).Citizens'Council.December 2015.Document Environmental Canada.June 2016.Document number: in Prince William Sound(memo).Robert Allan, number:600.105.151215.ADECRegUpdate.pdf 500.431.160601.MFrvwANSprops.pdf LTD.April 2016.Document number:801.109.160426. Comments on Tank Transfer Procedures and Best Polar Compounds in Alaska North Slope Oil&Other RALTugPullReq.pdf Available Technology(BAT)for Source Control Oils:A Literature Survey and Syntheses(report). Methods-Conditions of Approval#4a and#4b Mery Fingas,Spill Science.February 2016.Document Winter Species in Prince William Sound 1989 Alyeska Valdez Marine Terminal Oil Discharge number:959.431.160201.PolarCompLitSurv.pdf 2016(report):Prince William Sound Science Center. Prevention and Contingency Plan,ADEC Plan July 2016.Document number:900.431.160901. Number 14-CP-4057,Amendment 2015-4(com- WinterSpecies.pdf These are just a few of the many reports,papers,presentations,and media releases produced or compiled by the council in the past year.For further information,or to obtain copies,visit the council website or contact our Anchorage office(see back cover for contact information). .. ^ i Sfir- ANNVAL.REPQRr__ _ • z vw"W..a 1 � IPrIssmitmImo'."r_._'..y.,..,..,