A Spill Risk Assessment of the Enbridge Northern Gateway Project

amount to the omission of over 624,000 nm to Asia markets and over 147,000 nm
to markets in the US per year.
Table 20: Differences in Nautical Miles used to Estimate Tanker Spills and Actual Nautical
Miles to Key Export Markets
Key Export Market
One-­‐way
Distance to
Market
(in nm)
Average One-­‐
way Distance
in Study Area
(in nm)
One-­‐Way
Distance
Shortfall Per
Tanker
(in nm)
Total
Distance
Shortfall Per
Year
(in nm)
Asia Markets
Shanghai, China* 4,865
4,631 690,044
Yokohama, Japan*
Ulsan, South Korea*
4,041
4,363
233
3,808
4,129
567,342
615,246
Average
US Markets
4,423 4,189 624,211
San Francisco** 1,051
818 121,832
Los Angeles** 1,391 233
1,158 172,492
Average 1,221 988 147,162
Source: Brandsæter and Hoffman (2010 p. 3-­‐1); Enbridge (2010b Vol. 2 App. A p. 13); http://sea-­‐distances.com/
* We calculate nautical miles as half of the round-­‐trip distance to all three regions in Enbridge (2010b Vol. 2 App A. p. 13).
** We calculate nautical miles from Kitimat to San Francisco and Los Angeles using the calculator from http://sea-­‐
distances.com/
Failure to consider spills outside the study region is contrary to CEAA, which
requires an assessment of environmental effects that would occur “outside
Canada” (CEAA Sec. 5). Thus, DNV’s methodological approach that ignores the
majority of the distance sailed by tankers to key export markets significantly
underestimates spill likelihood and prohibits decision-­‐makers from determining
significant adverse environmental effects of the ENGP outside Canada required
under CEAA.
2. Failure to adjust tanker incident frequency data to correct for underreporting
Literature in peer-­‐reviewed sources suggests that vessel accident data reported in
the LRFP database, which DNV uses to determine tanker incident frequencies in
the marine shipping QRA, have serious deficiencies. Hassel et al. (2011) examine
the LRFP database for underreporting of foundering, fire/explosion, collision,
wrecked/stranded, contact with a pier, and hull/machinery accidents for merchant
vessels exceeding 100 gross tonnes registered in particular states (flag states)
including Canada, Denmark, Netherlands, Norway, Sweden, United Kingdom, and
the US from January 2005 to December 2009. Using various statistical methods,
the researchers estimate that reporting performance by LRFP ranges between 4%
and 62% for select flag states compared to actual accident occurrences, suggesting
that as few as one in 25 accidents were reported in the LRFP database for a
particular flag state over a five-­‐year period 17 . In the best-­‐case scenario for vessel
17 Hassel et al. (2011) suggest that results should be interpreted with caution due to assumptions and
estimation methods used by the authors. However, according to Hassel et al. (2011), their findings are
consistent with those made in the study by Psarros et al. (2010).
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