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THE REPORT SHOULD. ADDRESS THE RELATION BETWEEN TANKER SIZE
AND SPILL RISK AND/OR RECOMMEND A THOROUGH, PUBLIC ASSESSMENT TO
DECIDE THE MAXIMUM SIZE OF TANKER THAT CAN SAFELY TRANSIT ETRST
AND SECOND NARROWS.

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7. Increased crude oil exports

Tncreasing crude oil exports by tanker is of major public
concern, yet it is scarcely mentioned in the report. Where it is
briefly addressed in 16.3, the model shows that, if an additional
one: million tonnes of crude oil are exported, the risk of a 1000
barrel spill goes up by 64% and the risk of a 10,000 barrel spill
goes up by a whopping 92%. Of course, in absolute terms, if the
report's estimate is correct, the risk remains small -- almost
3000 years between 10,000 barrel spilis. Unfortunately, we have
a very different and much more disquieting estimate of spill
probability from the Environment Canada analysis undertaken for
she BC\States task force. I~ Environment Canada's analysis is
correct, the risk of a major spill under Che increased traffic
conditions of section 16.3 is frighteningly high. Indeed a major
Spill from a tanker outbound from Vancouver becomes likely in the
lifetime of many of those living on the coast today.

THE REPORT PAYS INSUFFICIENT ATTENTION TO THE QUESTION OF |
INCREASED TRAFFIC IN CRUDE OIL. IT IS AN IMPORTANT MATTER THAT
SHOULD BE DISCUSSED IN THE EXECUTIVE SUMMARY AND NOT HIDDEN AWAY
900 PAGES INTO THE REPORT. ,

8. Discrepancy between risk analyses

The discrepancy between the Port's estimate of the risk of a
Spill and Environment Canada's estimate is disconcerting.
Having read the report's brief comment on the discrepancy and the
subsequent correspondence with Environment Canada,’ Dr. Cohen,
etc., we see nothing to indicate that Environment Canada botched
the job. As Dr. Cohen concludes in his September 13, 1991
memorandum, Enironment Canada's “estimates are more plausible
than those of (The Port's study) and their criticism of
(Environment Canada's) work is ... unsubstantlated."

Until the discrepancies are resolved the only prudent course
is to proceed on the basis of the more conservative assessment
~~ Environment Canada's.

Unfortunately, it is tempting to assume a correlation
between the Port's interest in maximizing the use of its
facilities and the rosier picture painted by the risk analysis it
has commissioned. IF THE CURRENT STUDY IS TO HAVE PUBLIC
CREDIBILITY, If IS IMPORTANT TO RESOLVE THE SIGNIFICANT
DISCREPANCY BETWEEN THE PORT'S AND ENVIRONMENT CANADA'S FIGURES.

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