a Fi
fie oy ny inte
Ss,

Vancouver. A risk analysis that does not examine’ the likelihood
or cost of a spill affecting, for instance, Boundary Bay or the
Guif Islands is equivalent to a report on the Exxon Valdez:
disaster that excludes cansideration of Prince William Sound.

It is hard to understand this omission. THE AREA UNDER
CONSIDERATION SHOULD EXPAND TO INCLUDE THE FULL AREA AT RISK. -
FAILING THIS, THE REPORT SHOULD. ADDRESS THE OMISSION OPENLY.

As it stands, one is left with the impression ‘of terms: of
reference chosen to reduce alarm by minimizing the risk ‘figures.

4. Pug Studies,

_- WE CONCUR ABSOLUTELY WITH THE FIRST RECOMMENDATION. OF THE
REPORT, THAT STUDIES BE UNDERTAKEN TO DETERMINE THE POWER
REQUIRED BY TUGS ESCORTING TANKERS (AND OTHER MATTERS RELATED TO
TUG EFFECTIVENESS) . . ) ;

We have been calling for such studies for two years. In the
absence of this information, it is dlé£icult to feel assured that
the tugs attending tankers are indeed adequate for emergency
situations they may face.

The absenc# of this information raises serious questions
about the usefulness of the Second Narrows simulation study
alzeady under way. It also raises questions about:the risk from
large (90,000 to 110,000 DWT) tankers currently carrying crude
oil through the Georgia Basin. See below.

+ ‘

+ ‘

5. fide and Current Studies

The report bases its spill distribution model on ‘the
Vancouver Harbour Tide and Current Atlas, published in 1981..
Studies for the Atlas were conducted in 1972 and 1980. Since
that time there have been significant changes. inthe
configuration of the harbour -- for instance, dredging at First
Narrows and at Vancouver Wharves; construction on the. abutments
of both piers of the First’ Narrows Bridge; the removal of the —
Canadian National Pier; construction of the new Main Street Doct.
According to mariners with whom we have discussed this, these
changes have rendered the 1981 Atlas obsolete. They say. the
currents in Vancouver harbour, particularly on the south shore,
simply do not ebb and flow according to-the Atlas' predictions.

This raises questions of the accuracy of€£ the spill model and
of the Second Narrows simulation study.

WE BELIEVE THAT THE REPORT SHOULD ADD TO ITS RECOMMENDATIONS
A CALL TO UNDERTAKE THE STUDIES NECESSARY TO UPDATE THE CURRENT
ATLAS. .