Over the last century there has been a significant increase in the number and size of oil spills to the marine environment due to the global proliferation of oil and gas extraction as well as the number of tankers and other maritime transport infrastructure associated with increased production. Efforts have traditionally been focussed on containment and deflection of oil rather than responding to wildlife. The present study examines total oiled wildlife effort in response to maritime spills for 286 recorded globally. Between 1910 and 1961 there was an average of 1.23 ± 0.43 incidents per year, spilling an average of 114,062 ± 352,512 tonnes of oil per year. These averages increased to 3.83 ± 2.65 events with 123,277 ± 166,735 tonnes of oil spilt per year from 1962 to 1990, and again, from 1991 to 2012 to 6.50 ± 5.17 events with 164,299 ± 290,655 tonnes of oil spilt per year. Offshore platform and tanker spills have accounted for 37% and 27% of this total, respectively. Of the 104 recorded instances where wildlife interactions occurred (40%), spill volume was not related to the total number of animals caught, oiled or pre-emptively; however, it was related to the number of carcasses collected. A lack of planning for Oiled Wildlife Response (OWR) was identified as a contributing factor exacerbating the impact of a spill on wildlife and for resourcing a response. Inadequacies within operator and government contingency planning, to prepare for and sustain a wildlife response for extended periods, can be overcome by using a mobilisation model that integrates wildlife carer networks, government regulatory agencies and operator resourcing via an independent coordinating organisation consisting of a small group of personnel highly experienced and trained in maritime operations and marine science with access to a network of persons with experience in responding to wildlife and their handling, treatment and rehabilitation.
A common shortfall in incidents involving an Oiled Wildlife Response (OWR) is that, despite high conservation value fauna being identified in oil spill plans, they are often overlooked or undervalued during the oil spill response. Most oil spill plans focus almost exclusively on the operational aspects of containment and deflection offshore and shoreline protection and clean-up, while the equipment, expertise and resources needed to deal with oiled wildlife has, historically, been inadequate.
Common issues or gaps in government and operator response to oil spills that impact on the ability to plan for and incorporate a wildlife response have involved:
a failure to plan effectively for large scale spills,
the difficulty involved in containing spills in deep water environments such as the Arctic and offshore,
lack of coordination between federal, state and local government officials resulting in an inability to deliver an effective response, and
a lack of information and understanding concerning the efficacy of specific response measures such as dispersants and booms.
In Australia, recent changes in environmental policy introduced by the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) are aligned with a shift globally in requiring oil and gas operators to prove or demonstrate their capability and capacity to handle Oiled Wildlife Response. NOPSEMA has been insisting on the demonstration of an oiled wildlife “first strike” first response capability within planning documents when approving Environmental Plans (EPs) for offshore oil and gas activities.
The 2010 Montara Blowout Commission of Enquiry Outcomes 45 and 46 (Australian Government, 2011) recommend that a National Oiled Wildlife Capability be developed, and that the Australian Maritime Safety Authority (AMSA) upgrade the Australian Maritime Oil Spill Centre (AMOSC) resources in this regard. Further to these recommendations, Outcomes 42 and 47 endorse the provision of environmental science advice within AMSA management structures (Australian Government, 2011). Also recommended for inclusion within AMSA's national spill response plan (“The National Plan’) was research and development, technology development and research collaboration in oil spill preparedness. There have been limited moves towards developing a full capability, with much of the effort focussed on resourcing the full setup of a complete Oiled Wildlife Centre and all that it entails.
The State of California (USA) Department of Fish and Game Office of Spill Prevention and Response has a Wildlife Response Plan for Oil Spills in California that was published in June 2011 (Department of Fish and Game, 2011). More recently the European Union published a Directive in June 2013 on the safety of offshore oil and gas operations. The directive requires member states to prepare external emergency response plans, including potentially affected areas, and the plans must include “arrangements for the mitigation of the negative impacts on wildlife both onshore and offshore including the situations where oiled animals reach shore earlier than the actual spill (Annex VII 9h)”. Over the last decade ‘Sea Alarm’ has also been advancing the requirement for Oiled Wildlife Preparedness within the offshore oil and gas industry globally (www.sea-alarm.org).
Protection and collection of animals becomes secondary to oil spill containment and deflection if an Oiled Wildlife Response team of specialists is not mobilised immediately after the spill and biological spill response efforts and the wider spill response are initially under-resourced. The objective of the present study is to show how oiled wildlife “first strike” first response preparedness is becoming increasingly important globally. This is achieved by;
examining historical global oil spills and total wildlife response effort (animals captured and carcasses collected),
outlining issues in spill contingency planning impacting on wildlife response, and
highlighting key case studies that detail oiled wildlife response.
In addressing this increasing importance, within Australia the Pendoley Environmental Mobilisation Model for Preparedness and Response Operations (PEM2PRO) offers one potential solution. It has been successful in meeting the regulatory requirements within planning documents submitted by operators to NOPSEMA for approval, demonstrating they (the operator) have oiled wildlife preparedness and response arrangements in place.
Historical OWR Response
Over the last 100 years since the 1910 Lakeview Gusher resulted in a major inland oil spill in the USA (Counter Spill, 2011b), millions of tonnes of oil have also been spilt to the marine environment globally. Over this period a lack of preparedness regarding spill response has exacerbated the impact of hydrocarbon spills on the marine environment globally. In 1969 off the California coast near Santa Barbara 10,914 to 13,643 tonnes of crude oil spilt from Union Oil Platform A in the Dos Cuadras Offshore Oil Field, impacting 10km of coast, including the beaches of Santa Barbara County and northern Channel Islands (Counter Spill, 2011c). It ranks third in the world by volume after the 2010 Deepwater Horizon (National Commission of the BP Deepwater Horizon Oil Spill and Offshore Drilling, 2011) and the 1989 Exxon Valdez (United States Environmental Protection Agency, 1989) spills. It had a significant impact on the marine environment, killing thousands of seabirds as well as marine mammals.
Since 1969, further technological advances have led to exponential growth in maritime oil production with concomitant increases in transport and port facilities that have out-paced oil spill planning and preparedness by industry. Globally, research and development for oil spill planning and preparedness, containment and deflection equipment and strategies, removal and processing equipment, chemical and biological dispersant agents, baseline biological monitoring, and techniques for dispersing, collecting, cleaning, rehabilitating and managing threatened wildlife, is seriously underfunded. The lack of planning effort and support of research and development has negatively impacted the preparedness and response arrangements necessary to meet the operational requirements of a spill response, including an effective oiled wildlife response effort.
The impact of planned arrangements on spill response operations and wildlife response effort was evident in the following case studies. In March 1989, the ship Exxon Valdez, in one of the worst maritime spills in history, spilt nearly 35,000 tonnes of oil into Prince William Sound, Alaska during the first 72 hours of the incident. The lack of detailed oil spill response plans including wildlife response, especially for such a remote location and extensive spill, resulted in significant oil contact with the shoreline which expanded the scope of impacted wildlife and the response effort needed (International Bird Rescue Research Center, n.d.; United States Environmental Protection Agency, 1989; Exxon Valdez Oil Spill Trustee Council, 2004; Marine Mammal Commission, 1990).
In contrast, although being a much smaller spill when the 2010 MV RENA spill occurred in New Zealand, the Massey University Wildlife Health Centre was able to respond in an operational capacity immediately. The rapid response was possible due to good planning by the regulatory agency responsible for oil spill response (Maritime New Zealand, 2006). A pre-existing contract was in place with Massey University, which provided training and emergency response to oil spills with assistance from International Bird Rescue (International Bird Rescue, 2012; Maritime New Zealand, 2012a; Maritime New Zealand, 2012b). In addition, an experienced team of Department of Conservation (DoC) staff managed all fieldwork and supervised the immediate collection of pre-emptively caught animals, oiled animals and carcasses. By the time the first oiled birds were brought in for cleaning, a fully functional oiled wildlife facility (OWF) was operational (International Bird Rescue, 2012). Wildlife response costs were fully recoverable from the vessel owners under the Maritime Transport Act and Civil Liability Convention, 1969.
During the 2010 Gulf of Mexico (USA) spill (also called the Deepwater Horizon oil spill or Macondo blowout), only a small percentage of the Gulf shoreline was heavily oiled. However, several hundred kilometres of shoreline were lightly oiled and combined with immediate and long-term impacts to wildlife (particularly cetaceans, turtles, commercial fisheries and associated pelagic food webs) in the offshore environment this resulted in the contamination of large numbers of animals as well as sensitive habitats in areas located over a broad geographic area, complicating the wildlife response effort (Bundesinstitut für Risikobewertung, 2011; United States Coast Guard, 2011; National Commission of the BP Deepwater Horizon Oil Spill and Offshore Drilling, 2011; Marine Mammal Commission, 2012).
Current Response Models
Traditionally, three models of Oiled Wildlife Response have been employed in oil spill response globally (Clumper, 2008). These models all focus on the utilisation of local wildlife carer networks and the development of those oiled wildlife carer networks for OWR. These organisations are able to provide volunteers with experience in wildlife handling and rehabilitation, which are critical skills in OWR.
More recently, planning for OWR has shifted focus from rehabilitation of wildlife by carer networks to development of strategic alliances between specialised coordinating OWR groups (Sea Alarm, Pendoley Environmental), who facilitate the interaction of wildlife carer groups, government and the oil and gas industry in planning and responding to oiled wildlife. These strategic alliances offer a broad resource base in the form of coordinated access to volunteer networks of appropriate persons with animal care experience that often also have specialised skills and local knowledge. However, without access to an independent coordinating organisation that specialises in “first strike” first response and subsequent escalation, the economic costs of responding to a spill and setting up a full OWF are high. Moreover, costs arising from the loss of ecologically sensitive habitats, and flora and fauna cannot be accurately determined if inexperienced or naive personnel form the primary assessment workforce and operate under flawed spill response plans.
As an organisation that has had experience in coordinating and mobilising volunteers and resources to remote, inhospitable locations and sustaining them for long periods, Pendoley Environmental (PENV) was invited by the Australian Maritime Oil Spill Centre (AMOSC) to participate in the 2012 Oiled Wildlife Response (OWR) workshop to assist in identifying gaps in Western Australian Oiled Wildlife response capabilities. Despite the subsequent focus by AMOSC on resourcing an OWF, the conclusions from the workshop were that resources, equipment and the ability to respond to and sustain an oiled wildlife operational capability in remote locations of Western Australia were lacking. In response to this gap, Pendoley Environmental created an oiled wildlife mobilisation model for marine drilling campaigns, and assisted the newly formed NOPSEMA with an audit of the Vermillion Oil and Gas (VOGA) Oiled Wildlife Response Plan (OWRP).
METHODS AND RESULTS:
An online literature search was conducted with the aim of creating an inventory of maritime-based spills. Spill events were characterized by year, location, country and the type of spill, if known. Data was also recorded on the spill volume, approximate total numbers of wildlife captured oiled or pre-emptively (by taxon when possible), and total number of carcasses collected (again, by taxon, when possible). A total of 286 spills were analysed, starting from 1910 (see references and bibliography for a list of information sources). The number of spills was summed for each year, as were the cumulative spill volume (see graph in Figure 1). Different units used between spills makes comparison difficult as does converting mass to volume, which depends on density measurements that vary for different crude oil deposits. Given this, relative size comparisons are determined for the present study. Tonnes were used as a volume proxy to enable standardisation of the data, with one tonne being roughly equivalent to 1165 litres of crude oil, 7.33 barrels of oil, or 308 US gallons of oil.
Published information was often vague or incomplete; therefore, categories were created to aid analysis. There are 6 categories for spill volume, category 1 for information not available and the remaining categories based on volumes increasing by order of magnitude from greater than 10 tonnes up to greater than 100,000 tonnes. Similar categories were created for number of animals captured and number of carcasses collected (see Table 1). All data from the analysed events were assigned to a single category.
Between 1910 and 1961, the annual averages were 1.23 ± 0.43 spills of 114,062 ± 352,512 tonnes of crude oil (mean ± standard deviation; Figure 1). Between 1962 and 1990, the average annual number of spills tripled to 3.83 ± 2.65 with an average volume of 123,277 ± 166,735 tonnes of crude oil. After 1990, the number and size of spills increased further to an annual average of 6.50 ± 5.17 and 164,299 ± 290,655 tonnes respectively. Over the last 100 years, tanker and platform spills account for over 60% by volume of known and recorded spills (Figure 2). The remaining 40% originated from other vessel collisions or coastal and pipeline spills. Of the 286 spills analysed for the present study, tankers accounted for over 27% of spills by volume, being in excess of 2 million tonnes. Although fewer offshore platform spills occurred, these accounted for over 37% of spills by volume, being in excess of 2.8 million tonnes.
Some examples of the more significant tanker collisions and groundings include the 1967 Torrey Canyon tanker grounding off the Isles of Scilly in the United Kingdom that spilt 119,000 tonnes (International Tanker Owners Pollution Federation Limited, 2013 a). In 1991, the tanker MT Haven spilt 144,000 tonnes into the coastal waters of Italy (International Tanker Owners Pollution Federation Limited, 2013b). In 2004, two vessels collided in the Suez Canal with the tanker carrying 160,000 tonnes spilling over 7,000 tonnes (http://www.marinergroup.com/oil-spill-history.htm). More recently (2013) a downward trend in volume of tanker oil spilt has been found over the last decade (only a sixth of that spilled in the previous decade (http://www.itopf.com/information-services/data-and-statistics/statistics/).
Oil spills from offshore facilities are more infrequent but tend to be larger. A historically significant oil spill occurred in 1969, when more than 10,000 tonnes of crude oil was spilt from a blowout on a platform in the Santa Barbara Channel off the California coast, USA (Counter Spill, 2011c). Another well known, large, offshore spill was the 1977 Ekofisk Bravo blowout in the Norwegian section of the North Sea, which spilled over 27,000 tonnes of crude oil (Oil Rig Disasters, n.d.). Also, in 1983 amidst the Iran/Iraq war, damage to two offshore platforms released 260,000 tonnes of crude oil into the Persian Gulf (NOAA National Ocean Service, n.d.a), and in 1979 the IXTOC blowout released more than 450,000 tonnes of oil into the Gulf of Mexico (NOAA National Ocean Service, n.d.b). And more recently, in 2010 the Deepwater Horizon platform blowout in the Gulf of Mexico resulted in 627,000 tonnes released to the ocean (National Response Team, 2011; Sea Alarm Foundation, 2013).
The following are other significant maritime oil industry spills that have contributed large volumes to the marine environment and highlight the variation both in source and context seen in these events. Starting in 1940 and associated with petroleum processing plants in the Greenpoint neighbourhood of Brooklyn, New York City, USA, an estimated 97,000 tonnes of oil were lost into Newtown Creek (United States Environmental Protection Agency, 2007). Military actions associated with The Gulf War in 1991 spilt an estimated 820,000 tonnes of oil into the Persian Gulf (Baumann, P.R. 2001), and in 1993, the tanker Maersk Navigator collided with another vessel in the Andaman Sea near the Strait of Malacca, Indonesia spilling 255,000 tonnes of oil (Gupta et al., 1995).
Wildlife interactions, specifically quantified data on wildlife capture or carcass collection, were addressed in less than 40% of the 286 oil spills analysed for this study. The categorised (>10 animals to > 100,000 animals) number of animals captured (Figure 3) and carcasses collected (Figure 4) were converted to percentage composition for each spill volume (>10 tonnes to >100,000 tonnes).
The relationship between spill size and the number of live animals collected was analysed (test for independence). A similar analysis was done to test for independence in the relationship between spill size and the number of dead animals collected.
No significant relationship was found between spill volume and the number of live animals captured (df = 25; chi sq. = 0.8). Excluding data from the analysis where spill volume was unknown did not alter this result. The proportion of animals collected was similar for larger spills (>100t to >100,000t), further supporting the claim that live animal collection was not dependent upon spill size (Figure 3).
However, a significant relationship was found between spill volume and the number of carcasses collected (df = 25; chi sq. < 0.0001). Excluding data from the analysis where spill volume was unknown did not alter this result. The proportion of carcasses collected varied more between the different spill volume categories, indicating that the number of carcasses collected was dependent upon the size of a spill (Figure 4).
Spill Size and Oiled Wildlife Preparedness
The proliferation of oil production through the 1960s, 70s and 80s, as well as the shipping of this oil across the global oceans, has contributed significantly to total spills to the marine environment over the last 100 years. The results of this study suggest that ecological risk from oil spills is growing globally, because spills are in geographic locations that are increasingly remote and environmentally hostile (offshore, remote coastal locations, developing countries, extremes of heat and the Arctic), which may inhibit ready access to response resources. As follows, with respect to oiled wildlife response, there is a significant need to match this growing risk by planning for and maintaining preparedness for immediate mobilisation of effective response resources (“first strike” capability), and to plan for and maintain an effective and escalated response over extended periods of time.
The results of this study show that the overall proportions of animals either preemptively captured or caught oiled were not significantly influenced by the size of the spill. The Royal Netherlands Institute for Sea Research status report on the effects of chronic oil pollution on seabird populations found similar trends (Camphuysen, n.d.). Conversely, in the present study the overall proportions of carcasses collected were influenced by the size of the spill. Despite this, regardless of the spill size (in excess of 100 tonnes), for dead and alive wildlife collected in an OWR, each was most often between 1,000 and 9,999 animals. The reason for this cannot be determined from the available data; however, it may be related to a natural animal concentration consistent across a range of habitat types and therefore spill locations, or to a finite capacity for resourcing collection that is exhausted within the same timeframe in all spills. Furthermore, the majority of data regarding oil spill wildlife casualties was restricted to bird species and only a few spills (Exxon Valdez, Amoco Cadiz, Deepwater Horizon, Cosco Busan, and Arthur Kill pipeline) quantified other wildlife species captured or carcass collected (for example, marine mammals, turtles, and fish species).
Most evident in the present study was that a “small” spill did not equate to a ‘small’ number of oiled animals. Seemingly intuitive, it is not true and needs to be put aside; the degree of wildlife impact and by extension the degree of preparedness and first response is not related to potential spill volumes (spill size). In the interest of smoother, more effective and more cost efficient oiled wildlife responses, it is essential that preparedness for the initial response, OWR “first strike”, and subsequent resourcing for an ongoing OWR operation is integrated with government and operator oil spill contingency planning. The identification of environmental sensitivities (flora, fauna and habitats) within Zones of Potential Impact (ZPI) through trajectory modelling, both planned (scientific) and real-time (operational), is essential (see Singhran, 2013). The use of Oil Vulnerability Indices (OVI) can assist in this regard (Camphuysen n.d.) as species are ranked in terms of vulnerability to oil by behaviour, exposure, biogeographical population, reproductive potential, and reliance on the marine environment.
Evidence presented in the following case studies compared to MV Rena suggests that regional oil spill contingency plans (OSCPs) not only fail to identify environmentally sensitive areas and species, which results in high conservation value habitat being excluded from protection planning, but they also fail to identify coordination roles within a hierarchical response strategy, and to identify the equipment, experienced personnel and resources required to implement an effective spill response strategy that incorporates a sustained wildlife response.
Wildlife Response Case Studies
The resourcing of OWR and understanding of the impact oil has on the ecology of living resources (organisms and their habitats) needs to be demonstrated through preparedness, including plans for “first strike” and a scaled response to wildlife oiling, within OSCP documents. The requirement to demonstrate an OWR “first strike” and escalation capability is now a key component of acceptance of environment plans (EPs) and their associated OSCPs by NOPSEMA. The following case studies highlight issues that could have been avoided with good OWR planning and preparedness when compared to the MV RENA wildlife response.
CS1. Numerous failings in the response to the Exxon Valdez oil spill have been recognised (United States Environmental Protection Agency, 1989). Significantly, none of the oil was collected and the initial response was delayed 24 hours because “Alyeska equipment shortages and casualties delayed any opportunity to contain the spilled oil early on”. The Alyeska Pipeline Service Company had responsibility for the OSCP for Prince William Sound. The subsequent OWR effort was launched 6 hours after the spill in Prince William Sound when the International Bird Rescue Research Center (IBRRC) was contracted by Alyeska to set up a bird rescue operation. They arrived on site at Valdez, Alaska within 12 hours to set up a bird centre and evaluate impacts on wildlife, and despite not developing an overall oiled wildlife response plan (OWRP) during the initial stages of the spill or having access to one, four wildlife centres were subsequently established (Table 2). (International Bird Rescue Research Center, n.d.; Environmental Protection Agency, 1989; Exxon Valdez Oil Spill Trustee Council, 2004).
These issues could have been avoided if an OWRP had been put together by the administering authority for the region focussing on funding preparedness and resourcing of oiled wildlife “first strike” as part of expanded OSCP requirements prior to the spill occurring.
CS2.When the MV RENA container ship grounded in New Zealand (NZ) on 5 October 2011, the Massey University Wildlife Response Unit was activated immediately and experts from the University and the NZ Department of Conservation arrived on site the same day. During the first few hours of the grounding, blue penguins oiled offshore by spilt bunker fuel were recovered during first response operations from the shore by personnel from these organisations. An Oiled Wildlife Facility (OWF) was subsequently established and rescue teams (8 teams with a total of 85 people) continued to collect dead birds and live birds, both pre-emptively and oiled, from 8 October onwards until the clean-up operation ceased (Maritime New Zealand, 2011; Maritime New Zealand, 2012a; Maritime New Zealand, 2012b). Although the initial response by Maritime New Zealand (MNZ) to the actual spill was flawed it subsequently adapted well to events as they unfolded (Murdoch, 2013).
The focus on oiled wildlife preparedness and “first strike” by Massey University and the Department of Conservation (DoC) staff under contract to MNZ and subsequent integration of wildlife response efforts with an Oiled Wildlife Facility assisted in limiting the potential for oiling of significantly higher numbers of wildlife and avoiding issues likely to impact on wildlife resulting from any delays in the response to the spill.
Following the MV RENA spill, public involvement was actively encouraged in long-term beach clean-up. Once the worst of the oil had been removed, the ‘Adopt a Beach’ scheme was launched alongside ‘Operation Beach Clean’ (Bay of Plenty Regional Council, 2012). Local volunteers were supplied with beach cleaning equipment and protective gear and formed teams that became the primary resource of the RENA response for ongoing beach cleaning operations until termination of the official clean-up in December 2010. Over the period of the RENA response, 100 beach clean-up events were undertaken in the first four weeks, and 36 wildlife organisations participated in the rescue and rehabilitation of oiled wildlife. In addition, 150 local businesses and corporate organisations donated time, services and products to the response.
CS3.When the Deepwater Horizon incident happened in the Gulf of Mexico in 2010, the United States (US) National Contingency Plan directed area committees to focus environmental protection efforts on sensitive areas (Bundesinstitut für Risikobewertung, 2011). However, regional OSCPs had failed to identify these environmentally sensitive areas; and when they were subsequently identified in response to the spill the compiled list of the areas was not prioritised. Furthermore, the equipment, trained personnel, and other response resources needed to implement protection strategies were also not included in any contingency plans (United States Coast Guard, 2011; National Commission of the BP Deepwater Horizon Oil Spill and Offshore Drilling, 2011).
These issues could have been avoided if the OSCP had included a comprehensive environmental sensitivity matrix detailing Oil Vulnerability Indices (OVI's) and linking them to resourcing preparedness and the training needed to meet the operational requirements of “first strike”.
As with the Exxon Valdez, despite these issues and their subsequent impact on wildlife and the initial OWR effort, four bird rehabilitation centres and three bird stabilisation centres were eventually established. A further seven marine mammal and sea turtle rehabilitation centres were open at the peak of the spill response effort. The initial response phase occurred between 30 April, and 2 November 2010. Response actions were reinstated between 3 December 2010 and 24 May 2011 because of continued stranding of visibly oiled dolphins. On 25 May 2011, the marine mammal response phase of the spill ended, although oiled cetaceans were subsequently found. The Wildlife Branch of the response effort relied heavily on existing stranding networks in the Gulf region for animal and carcass collection as those organisations were authorised under the Federal Marine Mammal Protection Act to respond (United States Coast Guard, 2011; National Commission of the BP Deepwater Horizon Oil Spill and Offshore Drilling, 2011).
Despite efforts to resource the spill response, British Petroleum's response capability was ineffective and some aspects of its response plan were inaccurate (United States Coast Guard, 2011). For example, in its plan British Petroleum named a wildlife expert, on whom it would rely for advice, who had died several years before the plan was submitted for approval. British Petroleum also listed seals and walruses as two species of concern in case of a spill in the Gulf when these species never see Gulf waters. Response plans by ExxonMobil, Chevron, ConocoPhillips, and Shell that were submitted for approval were almost identical to that of British Petroleum (United States Coast Guard, 2011), suggesting poor review and assessment of all of these plans by the regulatory agencies.
These issues could have been avoided by the responsible authority implementing a documented procedure for funding and handling, and staff reviewing and assessing of an OSCP against objectives-based regulations that had comprehensive accompanying guidance notes for the operator, focussing on environmental outcomes.
The problems surrounding contingency planning, assessment and approval, and the problems in integrating government agencies and wildlife carer networks involved in a coordinated response were numerous. While the US Marine Pollution Act 1990 has driven development of spill prevention programs nationally in the U.S., it has also contributed to atrophy in contingency planning and resourcing. For example, fewer Coast Guard personnel have large spill experience because the perception with respect to spill planning, at the time of the Deepwater Horizon spill was that fewer resources were required to accomplish effective spill prevention and response objectives (United States Coast Guard, 2011).
Such atrophy and complacency in preparedness and response due to regulatory reform could be avoided by ensuring OSCP assessment criteria are focussed on an implementation strategy that demonstrates risk reduction through maintenance of the capacity and capability to respond to a spill inclusive of interagency coordination of oiled wildlife preparedness and cooperation of carer networks by the operator.
Mobilisation Model Solution
The degree to which OWR is incorporated into OSCPs and preparedness and response arrangements impacts on the effectiveness of the initial response, “first strike”, and subsequent escalation of operations. In order to operate an effective OWR, the following aspects are critical:
OWR core group coordination training procedures,
development of trained core group personnel, coordination of other volunteers, contracted labour force and OWR paid staff,
maintenance of a core group training matrix and access to personnel information prior to and during an oil spill response,
development and updating of a database about oil spill response equipment,
retention of equipment availability and accessibility,
maintenance of a culture of high standards in health, safety and environment,
development of knowledge about geographic location on accessibility and thereby response effectiveness,
awareness of climatic and meteorological challenges and their potential impact on response operations,
development of hands-on wildlife and spill response expertise,
maintenance of information about the effect of spill response operational procedures on animal hazing and deterrence, capture and casualties,
development of “best practices” by keeping detailed wildlife response evaluations following spills, and
access to funds to support maintenance of the coordination of oiled wildlife preparedness across carer networks.
In remote locations, hostile environmental conditions are often encountered both on- and offshore, and the development of Standard Operating Procedures (SOPs) needs to take this into account (Pendoley Environmental, 2012b and c). A mobilisation model and planning package (PEM2PRO) has been developed in-house by Pendoley Environmental to maintain a core group of trained personnel capacity, and capability for a scaled operational response to a spill in such environments (remote and offshore) (Pendoley Environmental, 2012a). The scope of this model is designed to meet the needs of Western Australian offshore oil and gas operators working within the regulatory framework for environmental approvals governing the industry. However, the methodology and approach have been designed to be adapted and used more widely through the Indo-Pacific and Asia-Pacific region.
Currently, a core group of about 12 and wider group of approximately 15 to 20 people are listed as active on-call members in PEM PRO, available to respond to an incident, integrate into an Incident Command and Control structure and oversee field operations and OWR personnel and equipment deployment and use, and setup of facilities and their operation in the event of an emergency. The PEM2PRO model includes alignment with, and coordination of, wildlife carer networks and the parent organisations that core group personnel belong to, creating access to a wider and much larger large group of highly organised volunteers and technical experts as well as other facilities and equipment. However, in order to maintain this capacity funding is crucial.
The PEM2PRO model is further strengthened by the operational and logistics emergency management skills of ex-military naval officers working in-house. The level of field experience and prior training of those staff members and supporting marine scientists is unparalleled in civilian organisations working in environmental management where marine-based fieldwork is a significant component of the business. Key elements of their experience include
an intuitive understanding of Incident Command structures and how OWR roles fit seamlessly within such structures,
trained to deal with, and respond to, maritime emergencies in remote locations with few resources,
an understanding of the impact living and working offshore has on personnel,
sound maritime industry and emergency management experience, and
an affinity for the need for a strong HSE culture in the maritime industry.
The Pendoley Environmental OWR arrangements for mobilisation are presented in Figure 5. “First Strike” first response and follow-on personnel are also capable of coordinating the setup and operation of an OWF by the operator and its contractors. A larger labour force can be coordinated by additional core group members and associated wildlife carer network technical specialists should one be required. Additional facilities and OWR equipment for hazing, pre-emptive capture, oiled capture and transport stockpiled by operators can be mobilised, as needed, on short notice. Key is that a scalable approach means it is not necessary to maintain a large and cumbersome organisation or move straight into setting up and running a large OWF. Rather, a small group of highly trained, well-organised and responsive individuals, aware of the key requirements and infrastructure needed to manage an incident response is developed and maintained and can be deployed immediately (within 24 hours of initiation of the spill). For remote and offshore locations a full mobilisation of the wider group if needed is achievable by day 3. Less prepared individuals or volunteers can be brought up to speed on-site as needed by leaders (coordinators) in the core group.
To ensure an effective response, the Pendoley Environmental mobilisation model (PEM2PRO) is not limited to rapid “first strike” first response actions but can sustain and resource a scaled operational response for extended periods. Its sustainability relies on an Oiled Wildlife Response Plan (OWRP) developed and implemented for the operator as a condition of an Environmental Plan (EP) approval for the ‘activity’ (e.g., drilling, seismic, construction, etc.). In Australia, the EP must be approved by NOPSEMA, Australia's federal agency charged with regulating offshore health and safety, well integrity and environmental management. The associated OWRP must demonstrate escalation of resourcing, coordination of a funded core group, access to wildlife carer network technical experts, and a wider contracted labour force to achieve alignment with an operator OSCP. An OWRP identifies fauna equipment systems to be used by the operators and development of Standard Operating Procedures (SOPs) that integrate Health, Safety and Environment (HSE) elements for the safe use of equipment and wildlife interactions and handling in the field (Pendoley Environmental, 2012b and c). The OWRP and SOPs demonstrate that risks to wildlife and personnel from the use of equipment are reduced to As Low As Reasonably Practicable (ALARP) in achieving objectives-based environmental outcomes. In order to demonstrate maintenance of a capability, the successful implementation of Oiled Wildlife Plans requires consideration of the ‘how to’ operational elements of preparedness and response arrangements.
The significance of preparedness for various spill scenarios and the impact of preparedness on wildlife casualties and response efficiency cannot be underestimated. Critical to maintaining OWR capability and the capacity to resource and sustain a response is funding by the operators. The recent changes in environmental policy by NOPSEMA and the ‘Financial Assurance’ legislation [OPGGS (Environment) Amendment (Financial Assurance) Regulation 2013] make this a mandatory requirement of the offshore oil and gas industry. Operator environmental policy appears to be largely driven by legislative reform rather than a focus on protecting fauna as part of spill response arrangements. Consequently, OWR success relies on alignment of government regulatory agencies, operator resourcing and wildlife carer network involvement. Sustaining OWR coordination and maintaining a capability and the capacity to respond effectively is achieved through funding an organisations that develops and coordinates the appropriate expertise and human resources to sustain a scaled response.