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Regional Campaign of Falmouth FOE

Ship to Ship Oil Transfer Operations in Falmouth Bay

Falmouth Harbour Commissioners (FHC) want to bring 'ship to ship transfer' of Russian bulk crude oil to Falmouth Bay. This proposed activity was revealed in the press in April of this year but FHC had been working on the scheme since 2003 - neither English Nature nor the Environment Agency had been included in any initial consultation process.

Crude oil from the Baltic would be transhipped from small 'feeder' tankers into a Very Large Crude Carrier (VLCC), of up to 300,000 tonnes displacement (not the very largest super-tankers but next tier down - around 330 metres long and with a beam of up to 60 metres). The process would involve 6 or 7 of the feeder ships, each off-loading around 40-50,000 tonnes of heavy crude over about 12 hours. It can take as much as 10 days for the entire VLCC cargo to be loaded. There would clearly be times during this several days' process when multiple shuttle vessels would be offloading, finished offloading and moving away from the VLCC or awaiting offloading nearby.

The VLCCs are unable to enter the Baltic because of their deep draught (22-27 metres). So anchorage is needed that is en route for the trade (to India, China, the US & Japan) - via the North Sea and shorter route of the English Channel/Western Approaches with deep (and sheltered) waters. Very few UK ports meet these criteria; but transfers have also been proposed for Sullom Voe (already with a considerable oil transfer infrastructure), Scapa Flow, the Firth of Forth, Southwold and Lyme Bay. However, to minimise their transhipment costs the shipping companies are evidently keen to undertake the 'ship to ship transfers' in a location to the east of Dover, which works for FalFoE's efforts to oppose the proposals but isn't much comfort to campaigners in the Firth of Forth who've been fighting the plans there.

Transfer operations have already been happening under government licence ten miles offshore in Lyme Bay for a number of years; but a year ago considerable concern expressed by local councils and residents forced the oil companies `voluntarily' to suspend their activities. But the numbers of transfers were very small: during the five years from 1999 to 2003 there were just 11 transfers (with another 7 in other regions of the UK over the same period).

Now the oil transfer companies have given both Devon/Dorset and Fife councils very clear indications that it would be their wish to significantly increase the number of transfers to 100 each year. In Falmouth one operation per month is being talked about initially, but a maximum schedule could lead to anything from 700-1300 shipping movements in and out of the harbour approaches every year.

Should this activity be allowed in Falmouth Bay, the 'supertankers' and flotilla of feeder tankers are likely to be moored a fraction over two miles from the mouth of the Helford River and from Henry VIII's Pendennis Castle - the sentinel entrance to Falmouth harbour. They will be within only a few yards of the boundary of the Fal/Helford Special Area of Conservation (SAC), designated for its rocky shores, salt marsh and Maerl beds and rare marine species such as Couch's Goby, trumpet sea anemones and pink sea fans.

Draft legislation

The Merchant Shipping ('ship to ship transfers') Regulations 1999 -currently with the Department of Transport, will ban all oil transfers at sea within European waters. However this will have the effect of driving the transfers into Port Authority waters - exempted from this legislation. The race is on to find ports that are prepared to undertake these operations.

A proposal to allow 105 visiting VLCC's each year into the Firth of Forth is currently meeting sturdy resistance from both Fife County Council and the Scottish parliament (thanks to its Green MSP's). That site is also adjacent to a Special Area of Conservation (SAC) as well as to two Special Protection Areas (SPA) for birds.

The disadvantages for Falmouth and south Cornwall are fairly obvious. The area is massively dependent, for right or wrong, on tourism - not only hotels, guest houses, shops, cafés etc but from the growing marine tourism industry: the clear waters of the Carrick Roads support several diving businesses plus sailing schools, canoeing, water-skiing, windsurfing, surfing etc as well as cetacean-watch enterprises. There are three Blue Flag beaches within a couple of miles of the transfer site and the harbour/Roads.

While there have been, to date, few major incidents from 'ship to ship transfers' (a pump room explosion and fire aboard super tanker Mega Borg resulted in a spill of 3.8 million gallons of oil in the Gulf of Mexico off Galveston in 1990 whilst engaged in 'ship to ship transfers'), accidents will undoubtedly happen - and usually through simple human or systems error or irresponsibility. The oil is heavy Russian Export Blend Crude Oil (REBCO) - particularly persistent in the environment; Devon CC has in the past raised the issue of the substandard shipping fleet used; there are 6000 moorings in the Fal/Helford area and on a summer day with suitable conditions, there can be hundreds of sailing craft in and out of the harbour - who currently do not class avoidance of multiple super tankers as part of their underpinning knowledge.

There are a number of perils associated with the actual operation: groundings, hoses parting, collisions between the VLCCs and feeder ships and with other shipping. The site where the transfers are likely to happen is a busy channel into Falmouth harbour/docks from the eastern English Channel and continent for commercial shipping. All shipping leaving the Fal will have to avoid an obstacle course of giant ships strung out across this channel - not so difficult on a clear day - more problematic in thick fog. Tankers might be moored close to the 'Three-Mile (Helston)' buoy where ships picking up pilots rendezvous before entering Falmouth harbour. In addition there would be lightering tankers beside each VLCC, others manoeuvring or hove to and a host of mooring support vessels. The mooring area is also subject to not infrequent rough sea conditions and lies next to shallow coastal waters. A mix of an anchor dragging incident - for which the site is noted - and subsequent grounding, would open up an array of disastrous scenarios.

With or without a major disaster, a very sizeable increase in international shipping will increase the risk of alien species introduction by ballast water, and lead to numerous minor oil spills - a less visible impediment to the land based tourism industry but catastrophic for the Fal and Helford's rare marine biological communities and to their shell and other fisheries; the two rivers host economically and culturally significant oyster, crab, mussel and lobster fisheries and the Fal is an increasingly important nursery for Sea Bass. After the 'Prestige' oil spill off Galicia (also involving heavy crude), mariculture businesses were forced to close and all food stocks were destroyed.

Where do we stand now?

Falmouth Harbour, like many other port facilities around the UK is a trust port administered by a harbour commission and not answering to local shire/planning authorities. Falmouth Harbour Commissioners (FHC) are not the most open of bodies - it's taken over two months just to get an acknowledgement to several hundred signatures of opposition. Divergent opinions are considered wilful and malicious and when the Management Committee for the Fal/Helford SAC noted their disappointment that they hadn't been informed of the potential 'ship to ship transfers' operations, FHC replied that in future the committee better watch their website in future.

The timetable for 'ship to ship transfers' to commence is a mystery; in FHC's view it should be predicated on a commercial judgement only. Both county and district authorities are largely against the operations. A policy decision passed by Cornwall County Council in April 2004, opposes any proposal to allow 'ship to ship transfers' of crude oil at sea in UK waters, other than for mitigating the effects of an emergency. Carrick District Council has passed a vote of no confidence against operations. But FHC is not reliant on local authority support.

They have not as yet undertaken an Environmental Impact Assessment or Appropriate Assessment - absolutely required for a project that might significantly impact on an SAC. FHC are notorious for their negative view of environmental protection and resisted undertaking an Appropriate Assessment for maerl dredging in the Carrick Roads until a court ruling forced them to abandon granting licences just a few months ago. The pressure to carry out an AA this time round will be massive and hopefully unavoidable.

They have commissioned a risk assessment, but it is an absurdly flimsy document - almost just an introductory brief.

They haven't done an economic impact assessment - despite claiming on air that not being allowed to undertake 'ship to ship transfers' in Falmouth Bay would cost £50m. They say its too difficult because they're not sure how many transfers there will be! All that they have done is made an assumption that payment per tonne of oil will equate to Orkney transfer tariffs (this intensely investigated figure they got off Orkney Council's website!). This would give, at one 'ship to ship transfers' operation per month, an annual income of £1.25m per year for FHC's coffers; the operation would be handled by a cradle-to-grave company from eastern England (mooring masters, vessels, shipping agency services etc) - so that there would be no new - or very few - jobs created, little income for local marine businesses and any benefits to Falmouth and south Cornwall would come from trickle down, if you believe the dribbling fairy exists. And Russian crew are not renowned for their spending sprees if they ever do get ashore.

FHC have made themselves - with not much help from us - extremely unpopular, largely by utilizing the support of a shipping column writer in the local newspaper who spews out the FHC line on 'ship to ship transfers' verbatim and regularly attacks people rather than deals with the issues.

Most recently - Alistair Darling has announced that his department will be involved in the Firth of Forth consultations on sts. However the entire process is mired in muddle. His department is currently in the process of drafting secondary legislation to regulate transfers within UK territorial waters, which are planned to be ready early in the New Year. At that stage, they say, they will issue the draft for full public consultation. So statutory regulation is a long way off. We could end up with a decision on the transfers - in Falmouth or the Firth of Forth - before the rules are even in place let alone have been consulted on!

Should we be opposing 'ship to ship transfers'?

Not as obvious a question as it first seems. We don't have the power to stop the international buying and selling of oil. Even if all the UK campaigns stopped transfers here, Russian companies would just go elsewhere. Our campaigning on climate change and the need to reduce oil dependency and therefore quantities of transfer will not affect these operations in the near future.

The crude could travel by pipeline to the far east (Russia has built an immense array of lines) - but transfer by this means (payments being levied by all the countries the oil travels through) is considered too expensive. Should we campaign for this anyway? There's absolutely no way of judging whether it is safer/environmentally friendlier than 'ship to ship transfers', and a risk assessment based on these two massive options is not going to happen. Both have distinct and very different potential impacts.

The transfers will happen somewhere. The last thing we want to do is mount a nimby campaign that dumps the problem on someone else's doorstep. Most of our coastal waters are environmentally valuable - the Firth of Forth also has SAC's; the colder waters of Shetland would fare worse in recovery terms if a spill occurred - though the infrastructure in place makes the transfers safer.

There are no easy answers; so we tend to bypass these issues and stick to the dangers and lack of benefits with mild mutterings about not wanting to be connected with a trade at the heart of accelerating climate change lunacy. Ideas for a solution to this quandary very welcome!

Betty Levene - 11th December 2005
(with thanks to John Ellis)