Ship to Ship Oil Transfer

An issue in Lyme Bay

What is Ship to Ship oil transfer?

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

Background

From the 1960's ship to ship transfer took
place on an ad hoc basis in suitable locations
all around the coast of Britain. Lyme Bay was
one such location due to its proximity to the
main shipping lanes, and the availability of
shelter in the western half of the bay. These
transfers were for imports/ exports to and from
the UK
Following the 1993 Braer disaster off
Shetland, the Lord Donaldson's inquiry made
a series of recommendations concerning the
safe transport of oil around the UK. Amongst
these recommendations, it was proposed that
ship to ship transfer of oil be restricted to two
areas off the English coast, Lyme Bay and
Southwold, off East Anglia.
However, the ship to ship transfer operations
in Lyme Bay, were only given a semi-formal
status in 1998, when the UK Maritime and
Coastguard Agency published draft
Regulations to control activity in the area. To
date these draft regulations have yet to be
implemented, as the government are waiting
for the publication of the final report identifying
Marine Environmental High Risk Areas
(MEHRAs) before proceeding. (There was an
initial report in 1999 identifying MEHRA’s , but
the methodology behind the report was
questioned and resulted in the reports
withdrawal.)
Between 1999 and 2003 operations in this
area have involved either the emergency
transfers of cargo (such as that salvaged from
the Iveoli Sun) or one to two commercial
transfers per year between a small numbers
of vessels. In the latter cases it was the
transfer of mainly non-persistent cargoes such
as jet-fuel and kerosene from large ocean

Briefing note prepared for the Dorset Coast Forum

November 2004
going tankers to smaller vessel, which then
took their cargoes into European Ports.
The Baltic Oil Trade
In 2003 the situation changed with a different
form of ship to ship transfer operations taking
place. These transfers were at a higher
intensity to those that have taken place
previously and the cargo was different (a
heavy Group 4 oil) . However, the principle
difference was that the operations involved a
'mother-ship' large tanker (single or double
hulled) which is loaded from smaller, single
hulled, tankers. During the operation up to
seven small tankers which originate from the
Draft Regulations and controls
Currently, transfers are regulated by the
Maritime & Coastguard Agency (MCA) under
their 'Quality assurance' system, which
involves an assessment being made, by the
MCA, of a range of factors, relating to the
vessel, type of cargo and sea conditions. For
each transfer an emergency plan is prepared.
Formal control of ship to ship transfers should
be regulated by the “Merchant Shipping (Ship-
Baltic (northern Europe) come alongside and
load the mother-ship over a period of around
10 days. Once loaded the mother-ship
departs for the Far East. Four groups of ship
to ship operations of this type took place
during 2003. In total these four groups
involved a total of 20 transfers which in turn
involved 24 vessels (information from Dorset
County Council, Emergency Planning). Not
only were these transfers a fundamental
change to the type and frequency they are
essentially nothing to do with the UK
economy, as they involve only transshipment
and are neither import or export to the UK and
they also avoid any port charges.
The current Ship to Ship transfer area in Lyme Bay
to-Ship Transfers) Regulations 1999”,
however, after some 5 years of delay, they still
remain in draft form despite considerable
pressure at a variety of levels from both
Dorset and Devon County Councils. A new set
of draft regulations is being prepared by the
Department of Transport and will then be put
out for consultation. Devon and Dorset County
Councils have made a joint written submission
to the MCA detailing their concerns and
proposing control measures.
Briefing note prepared for the Dorset Coast Forum
November 2004
A cause for concern?
The Dorset coastline stretches for over 240
kilometres and is an area of major importance
to the County of Dorset in terms of both the
natural environment and the support it brings
to the local community through recreation and
industry. Recent, major oil spills such as the
Erika and Prestige have shown the huge
impact an oil spill can have on the coast.
Environmental Issues
International, European and national
environmental designations are abundant
along the Dorset and Devon Coastline. These
include World Heritage Site, RAMSAR,
National Nature Reserves, Areas of
Outstanding Natural Beauty, Sites of Special
Scientific Interest, Special Areas of
Conservation and Special Protection Areas.
There are also vulnerable reef habitats
especially in Lyme Bay which are sensitive to
pollution where recovery would either be
impossible or extremely lengthy.
Local Economic Issues
Local economy relies on fishing, tourism, and
those businesses on the coast and in the
hinterland. Oil spill mapping, by Dorset
County Council, Emergency Planning, has
shown that Lyme Bay as far as the east of
Portland could be contaminated within a short
space of time if a large oil spill occurs in
virtually any weather conditions.
Fishing
Fishing is of major local economic
importance to the Dorset area. The fishery
is also of national significance, with 25% of
the UK’s brown crab catch being landed in
the area (information from Southern Sea
Fisheries).
Tourism
One of the greatest attractions to Dorset
for tourists is the coastline. A major oil
spill has the potential to seriously damage
tourism within both counties, through the
impact of a polluted beaches and the
requirement to move large quantities of
oiled waste to disposal. In Dorset,
approximately 45,000 people are directly
or indirectly employed in tourism, with
some £994m income to the county
(information from South West Tourism).
The controls which the local authorities
would have to implement would result in
the closure of beaches and possibly routes
to disposal sites, as well as bans on
commercial and recreational fishing..
The Future It is unlikely that concern as
to the safety of ship to ship
transfers will abate, particularly on the part of
the coastal local authorities led by Dorset and
Devon County Councils.
There are several plans and proposals,
currently under discussion, that could affect
the future of ship to ship transfers in Lyme
Bay.
Marine Environmental High Risk Areas
The Marine Environmental High Risk Area
(MEHRA) final report remains outstanding. No
new date for publication has been made.
Ship-to-Ship Transfers Regulations
The revised regulations for ship to ship
transfer are due to be published in May 2005
for consultation.
Particularly Sensitive Sea Areas (PSSA)
These are areas that needs special protection
through action the International Maritime
Organisation (IMO) because of their
significance for ecological, socio-economic or
scientific reasons and which may be
vulnerable to damage by international
maritime activities.
The 'Western European Waters', (an area of
north western European waters stretching
from the Shetland Isles to Portugal), were
designated as a PSSA in October 2004.
This can enable controls to be imposed on
many types of maritime activity within the
PSSA, including the transport of oil.
Briefing note prepared for the Dorset Coast Forum
November 2004