1 1 Northern Gateway Pipelines Limited Application for Northern Gateway Limited Partnership Project Certificate of Public Convenience and Necessity HO Written evidence of Cheryl Brown #1 I submit this evidence to the review of the Enbridge Northern Gateway Pipeline project as a registered intervenor. I claim no expertise except as an inquiring mind and a member of the public. I have an interest in the environment and have spent time on committees developing the management plan of the Kalum District (known as the Kalum Land Resource Management Plan) that included marine and terrestrial and currently sit on the Plan Implementation Committee. As well I have lived in the Kitimat Valley for more than 30 years - hiking the valley and river and sailing the Douglas Channel. The focus of this evidence is a critic of the Northern Gateway Marine shipping Quantitative risk Analysis. Forward 1. It should be noted that the evidence is developed on the basis of incomplete data by Northern Gateway Pipeline Limited Partnership (NGPLP). The Quantitative Risk Analysis (QRA) is marked as a draft and any subsequent changes to the document could not be included in this evidence. As well the inadequate and incomplete responses from Northern Gateway to information requests have limited the development of evidence as well as the JRP timelines not allowing for the completed information. 2. Marine Shipping Quantitative risk analysis (QRA) of the TERMPOL requires a broad and inclusive approach. The tools used, need to address an in depth analysis of an identified area so that all types of risks are managed effectively. Tools used for the Northern Gateway Limited Pipeline Project (NGPLP) are from Det Norske Veritas (DNV) and estimates the risk associated with the
2 2 marine transportation of oil and condensate in tankers via established marine routes to and from open ocean and the Kitimat Terminal. The QRA also calculates the risk of incidents occurring during the loading and discharge operations at the marine terminal. (Marine Shipping Quantitative Risk Analysis Enbridge Northern Gateway Project 2010 p. 1-1). 3. An information request asked for the specific tool from DNV but the information was not provided. 4. Numerous tools are available for the QRA and the tool used for the NGPLP is limited. Optional tools have been reviewed such as the IALA guideline IALA is the International Association of Marine Aides to Navigation and Lighthouse Authorities and the IALA guideline 1018 on Risk management Edition 2 December 2008 (IALA) has a more inclusive data set and has been used as a comparison to the Det Norske Veritas tool. One of the differing features of the IALA risk analysis is the incorporation of human factors. 5. The IALA document can be accessed at df 6. The IALA states that: a. It is important to stress that a correct, efficient and useful result of hazard identification, assessment of risk and establishment of risk control measures, in fact the output of a risk management process, is dependent on the application of Human Factors disciplines. The concept of Human Factors and references to relevant models is therefore included in this guideline. It is recommended that administrations, organizations and persons involved in a risk assessment process have suitable, updated and in-depth knowledge in the application of Human Factors disciplines (p. 6). 7. Data sets in the IALA 1018 provide additional pieces to the risk analysis that develops a more complete assessment of risk. The following are excerpts from the ILAL 1018 tool with comments made regarding the use of the tool in comparison to the Det Norske Veritas tool (DNV). The risk management process 8. The IALA guideline considers 5 steps that follow standardized management or system analysis approach: 1.identify risks, 2.assess risk 3.specify risk control options, 4.make a decision and 5.take action.
3 3 Identify Risks 9. The process includes a consultation and reporting element throughout the process with stakeholder and users being consulted and receiving feedback continuously. This process verify decisions and checks to see if initial conditions have changed and to constantly monitor if control measures are implemented effectively, The tool emphasizes that a central element is to understand how human factors influence the risk management process. (IALA p. 7). 10. Within the NGPLP QRA an ongoing monitoring system is not suggested to determine and scrutinize the effectiveness of the TERMPOL suggestions. 11. Within Step 1 of the IALA in identifying hazards, consulting stakeholders (IALA 2.1.3) is one of the first steps. Consultation with identifies stakeholder help to validate and define the scope of the issues. Decisions- makers in an organization often perceive the importance of an issue differently from external stake holders. The greater the effect of a decision, the greater the concern and the greater their involvement should be. When dealing with a more complex problem, in order to explain the resulting decision better, greater stakeholder involvement is required. (IALA p. 8). 12. Information request 2.2 from Cheryl Brown asked 2.2 Reference: The technical data report of the Marine Shipping Quantitative Risk Analysis for Northern Gateway TERMPOL - Preamble: The QRA report references interviews with Stakeholders that were held in Prince Rupert and Kitimat in 4.3 pg 46 Request: a. Were the interviews done in a group session or individually? b. How many people from each sector and place were interviewed? Response: a. Each stakeholder was interviewed individually. b. Number of people interviewed in each sector: tour boat operators - 2 interviewed logging contractors - 2 interviewed sports fishermen - 2 interviewed environmental groups - 2 interviewed terminal operators - 2 interviewed tug and barge operator - 4 interviewed
4 4 Number of people interviewed in each place: Prince Rupert - 1 interviewed Kitimat - 9 interviewed Vancouver - 4 interviewed 13. The NGPLP QRA interviewed 14 stakeholder individuals of varying backgrounds. Interviews were done individually and no ongoing consultation has been considered. HAZID with 7 experts was done as part of the QRA. The stakeholder consultation however is limited considering the complexity of marine component of the project. 14. There is limited incorporation of the human component in the NGPLP QRA. 15. Hazard identification methodology of the IALA 1018 (2.1.4) includes hazard identification process and the incorporation of the human element Hazard Identification Methodology The approach used for hazard identification generally comprises a combination of both creative and analytical techniques, the aim being to identify as many relevant hazards as possible. The creative element is to ensure that the process is proactive, and not confined only to hazards that have materialized in the past. It typically consists of structured group reviews aimed at identifying the causes and effects of accidents and relevant hazards. Consideration of functional failure may assist in this process. The group carrying out such structured reviews should include experts in the various appropriate aspects, such as navigational aid design, and specialists to assist in the hazard identification process and incorporation of the human element. A structured group review session may last over a number of days. The analytical element ensures that previous experience is properly taken into account and typically makes use of background information (e.g. applicable regulations and codes, available statistical data on incident categories and lists of hazards to personnel, hazardous substances, and ignition sources) (IALA p.8).
5 5 Hazard Identification 16. Within the risk analysis IALA identifies and incorporates a large base of: a. types of hazard identification and b. types of loss. Types of hazards Types of Hazards In general terms, five types of hazards generate risks: 1 Natural hazards such as floods, wind storms, earthquakes, biological hazards, and other natural phenomena; 2 Economic hazards such as inflation, depression, and changes in tax and fee levies; 3 Technical hazards such as system or equipment failure, fire, explosion, obsolescence, and air/water pollution; 4 Human factors such as errors or omissions by poorly trained, fatigued or stressed persons, or violations, sabotage or terrorism; and 5 Operational hazards such as groundings, collisions, striking and other unwanted events (IALA p. 9) 17. The NGPLP assessed natural hazards but limited its assessment to wind, current, visibility and wave height. Other phenomena are at play as well. For example the distance of the approach to the marine terminal (290 KM) is a greater distance than other ports using VLCC s and has not been factored as a hazard. The increased length increases the opportunity for other hazards such as change of weather, crew and pilot fatigue to become a factor and the compounding of hazards to occur. 18. The NGPLP QRA has not incorporated the compounding of hazards in the statistical analysis of hazards. It is well within the possibility to have compounding hazards. Multiple causation is common place in casualties, often taking the form of the casualty would not have occurred unless A and B and C all happened (Devanney, J, The Limits of Marine Quantitative Risk Analysis. Draft 2011). 19. In Operational hazards the NGPLP QRA did not consider other unwanted events and in technical hazards did not factor in obsolescence. It is limited in that it did not consider economic hazards that may compromise the project, or the full range of human factors. 20. Studies have shown that human factors are the main cause of incidents and the NGPLP QRA did not consider them as a hazard.
6 6 21. An example of the complexity of the human factor in a marine incident is the Cosco Busan. Rajesh Joshi Lloyds List Friday 20 February 2009 AN ineffective master, a cognitively degraded pilot and poor management all contributed to the Cosco Busan hitting a San Francisco bridge, causing over $70m worth of damage, a new report has concluded. But it was the lack of communication between all involved that ultimately led the US National Transportation Safety Board to recommend that the International Maritime Organization include a segment on cultural and language differences and their possible influence on mariner performance in its bridge resource management curricula. The NTSB report on the Cosco Busan casualty may have included 30 conclusions spreading the blame equally among all parties involved, but it was cultural differences that prevented the Cosco Busan s master from asserting his authority over the pilot. The report also found fault with the quality of communications between the two. The newness of the crew to the 5,447 ton, 2001-built ship, and to the ship s operating company Fleet Management, and the crew s lack of proficiency with English, were also cited as factors. Overall, the report cites a pilot who was cognitively degraded, an ineffective master, an operating company that did not properly train its crew, and the US Coast Guard s inadequate medical oversight of the pilot as contributors to the incident. Other recommendations include a finding that, in its radio communications, the Vessel Traffic Service needs to identify the vessel and not only the pilot; and that the US Coast Guard needs to provide guidance to VTS personnel that defines expectations for when their authority to direct or control vessel movement should be exercised. The ship hit the San Francisco-Oakland Bay Bridge in heavy fog on the
7 7 morning of November 7, 2007, after leaving the Port of Oakland for South Korea. According to the NTSB, the damage ran to $70m for the ecological clean-up, $2m for the ship, and $1.5m for the bridge. A 26 mile patch of shoreline was smeared with the oil spilt, and more than 2,500 birds of 50 species were said to have died. The San Francisco Bay pilot, John Cota, while trying to needle the ship through the Delta and Echo support towers, directed that the ship head straight for the Delta tower, whose base it struck. The fendering system at the base worked as intended, protecting the pier structure and limiting damage to the Cosco Busan to the area above the waterline. The NTSB report agreed that the pilot s order for hard port rudder at the time of the collision was appropriate, and possibly limited the damage to the vessel and the fendering system. However, the pilot s medical history came in for harsh scrutiny. Although the pilot had been diagnosed with sleep apnea, there was no evidence that he was sleep-deprived, the NTSB said. However, it added: The pilot was most likely taking a number of medications, the types and dosages of which would be expected to degrade cognitive performance, and these effects were present on the day of the accident. The pilot, at the time of the collision, experienced reduced cognitive function that affected his ability to interpret data and that degraded his ability to safely pilot the ship under the prevailing conditions. The report said the pilot and the master failed to engage in a comprehensive master-pilot information exchange before the ship departed the dock, and failed to establish and maintain effective communication during the voyage. The interactions between the pilot and the master were likely influenced by a disparity in experience in navigating the San Francisco Bay and by cultural differences that made the master reluctant to assert authority over the pilot. Nonetheless, the master also did not implement several procedures found in the company safety management system related to safe vessel operations, which placed the vessel, the crew, and the environment at risk.
8 8 22. Information request 2.3 asked by Cheryl Brown 2.3 Reference: The technical data report of the Marine Shipping Quantitative Risk Analysis for Northern Gateway TERMPOL - Preamble: In , the report refers to causes of a powered grounding usually due to navigator's inability to follow the correct course or correct a steering malfunction. The reasons may include misjudgment, lack of attention or the navigators condition (illness, intoxication etc). Request: Could you please indicate how these factors were actually tabulated in the risk assessment for powered groundings? Response: Accident statistics and the applied base frequencies for powered grounding presented in the Marine Shipping Quantitative Risk Analysis ( QRA ) are inclusive of incidents caused by misjudgement, lack of attention or the navigator's condition, amongst other reasons. Scaling factors are only applied to take local external conditions into account (e.g. bathymetry, topography, wind, waves, current, visibility, etc.) Reference: Det Norske VERITAS ( DNV ) Marine Shipping Quantitative Risk Analysis Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB. 22. The NGPLP QRA assesses human factor of accidents as inclusive elements of accident statistics and the applied base frequencies. None of the factors that would be unique to the situation being assessed were noted. The results are unauditable. The incidents such as groundings are consequences not causes. Other factors such as human error are the causes and need to be presented. 23. Incidents are coded for statistical reasons but do not reflect fully the cause. In other words what caused the lack of attention of the navigator. 24. The IALA goes on the say that The analytical element ensures that previous experience is properly taken into account and typically makes use of backgrounds information (e.g., applicable regulation and codes, available
9 9 statistical data on incident categories and lists of hazards to personnel, hazardous substances, and ignition sources) (IALA p. 9). 25. The NGPLP QRA does not include available statistical data on incident categories nor lists hazards to personnel, the hazardous substances that are shipped within the Douglas channel nor what would be potential ignition sources. 26. An information request by Cheryl Brown 2.6 asked: 2.6 Reference: The technical data report of the Marine Shipping Quantitative Risk Analysis for Northern Gateway TERMPOL - Preamble: In the reports sensitivity analysis 7.4.2, projected increased traffic density with current and future projects increased the incidence of collisions. Request: As the cargoes on these vessels would have risk factor that should be factored into the risk analysis of a collision, would you please indicate the current and projected traffic of vessel type, the volume of vessel along with type of cargo. Response: Please refer to TERMPOL Section 3.2, Chapter 6.4, Other Commercial Proposals in the Region. Please also refer to Northern Gateway's response to C. Brown IR Though the question referred the intervenor to the TERMPOL document, the NGPLP did not utilize the information regarding the risk that other ships and their cargoes presented to the oil and condensate carriers if a collision occurred. 28. The following answer to the next information request 2.5 from Cheryl Brown indicated that type of cargo was irrelevant. 2.5 Reference: The technical data report of the Marine Shipping Quantitative Risk Analysis for Northern Gateway TERMPOL - Preamble: The Marine QRA report does not assign a risk factor to the cargo oil nor is the risk of spilling oil
10 10 Request: Response: rated with comparison to other types of hazardous cargo spills. Can you compare within the risk analysis the risk of oil spill with other hazardous cargos that are being transported within the assessed water way?. The Marine Shipping QRA by DNV examines the risk of an incident related to Project marine transportation and marine terminal operations. The QRA does not assess spill volumes from non- Project traffic and does not examine spill effects. Please refer to the Application (Volume 8C). Reference: Det Norske VERITAS ( DNV ) Marine Shipping Quantitative Risk Analysis Technical Data Report. Prepared for Northern Gateway Pipelines Inc. Calgary, AB. 29. In other words the answer indicates that there was no risk analysis of concurrent cargoes that will transport on the designated marine way. 30. IALA considers the types of losses as a consideration of risk. Types of losses Types of Losses The five types of hazards have the capability to generate seven different types of losses: 1. Health losses including death and injury; 2. Property losses including real and intellectual property; 3. Economic losses leading to increased costs or reduction to revenues; 4. Liability loss resulting when an organization is sued for an alleged breach of legal duty, such cases must be defended even if no blame is assigned. Liability losses are capable of destroying or crippling an organization; 5. Personnel loss when services of a key employee is lost; 6. Environmental losses (negative impact on land, air, water, flora or fauna); and 7. Loss of reputation or status. (IALA p.9) 31. NGPLP QRA does not acknowledge the breath of losses including: property losses and ability to create income and sustain lively hoods from those properties and traditional lands, economic losses of others other than the proponent, environmental losses and the loss of status and reputation of not only the proponent but the marine area and its status as a world class icon of marine environment.
11 The information request 2.13 from Cheryl Brown asked for the marine area in the socio economic analysis be extended to the marine communities and the risk due to loss be included.. Reference: Vol. 6C Environmental and Socio-economic assessment Preamble: Parameters for the setting of the Socio-economic assessment found in are based on criteria that include a number of factors such as. A population greater than 1000 within 40 km of the ROW or the Kitimat Terminal A population less that 1000 within 10 km of the ROW or the Kitimat terminal Presence of traditional land and resource use area that could be directly affected by the project Request: Figure of coastal British Columbia Region demonstrates these criteria. As A result communities that are affected on the coastal region such as Hartley Bay are not been considered within this assessment piece. The project for consideration for the JRP includes the marine component and this has not been included here. Please extend the setting for the Socio-economic assessment and complete so that the effected marine communities are included. Response: The Application (Volume 6C, Section 4.4) addressed the potential socio-economic effects of constructing and operating the pipelines and the Kitimat Terminal, and the setting was chosen to identify those communities that could be expected to provide the labour, goods and services needed to construct and operate the Project. While the community of Hartley Bay did not fall within the criteria listed in Section 4.4.1, it was recognized that Hartley Bay could be affected by marine transportation and it was included in the socioeconomic region defined in the Application (Volume 8C, Section 9). Table 9-1 of the Application (Volume 8C, Section 9.5.1) specifically identifies Kulkayu (Hartley Bay) 4 as one of the reserves in the Prince Rupert Region of
12 12 the Skeena-Queen Charlotte Regional District that was included in the Open Water Area. Thus, the marine communities have been included in those parts of the Project assessment related to marine transportation. 33. The following is the complete social economic piece referred to in Enbridge s response to in the information request noted in bullet 32 above. This is the extent of assessment and comments and is not adequate. As well no assessment of this risk was factored into the QRA. All of the regions in the SER rely on marine resources to some extent and could be adversely affected by a spill should it occur in their particular area, and be of sufficient size to create measurable effects. The extent of commercial dependence on marine resources is evident from the percentages of total income (after tax) directly attributed to fisheries and tourism. This information is available for some of the larger communities and regions (see Table 9-2) and indicates that regional residents rely on employment for between 64% and 86% of their annual incomes, with the balance coming from government transfers and other sources. Sec. 52 Application Volume 8C: Risk Assessment and Management of Spills Marine Transportation Section 9: Effects of Hydrocarbons on the Human Environment May 2010 Page 9-23 Table 9-1 Communities, Indian Reserves and Rural Areas included in the OWA Kitimat-Stikine Regional District Haida Gwaii Communities Kitimat Skeena- Queen Charlotte Regional District _Masset _Port Clements _Queen Charlotte Central Coast Regional District Prince Rupert Region _Prince Rupert _Port Edward Mount Distric Indian Reserves Kitamaat 2 (Kitamaat Village) _Masset 1 _Skidegate 1 _Lax Kw'alaams 1 _S1/2 Tsimpsean 2 _Dolphin Island 1 (Kitkatla) _Kulkayu (Hartley Bay) 4 _Bella Bella 1 _Bella Coola 1 _Katit 1 Rural Areas Kitimat-Stikine D RDEA _Skeena-Queen Charlotte D RDEA _Skeena-Queen Charlotte A RDEA _Central Coast A RDEA
13 13 _Skeena-Queen Charlotte E RDEA _Skeena-Queen Charlotte C RDEA _Central Coast C RDEA _Central Coast D RDEA _Central Coast E RDEA Third Party Review and Validation 34. In the IALA model a third party review (step ) along with validation (step ) by trusted outside experts is an included step lending further credibility to the results Third-Party Review Having technical analysis reviewed and validated by trusted outside experts lends further credibility to the results. Universities and government agencies tend to be trusted because of the public perception that they are independent and, therefore, unbiased. It is important for the decision-maker to understand whom stakeholders trust vis-à-vis the particular issue being considered. This is accomplished through dialogue with stakeholders and is an important component of the stakeholder analysis. It is recommended that a formal third-party review be used to confirm the integrity of the analysis process. This review can be accomplished using internal or external resources, depending on the situation, but not by the analysts themselves. For example, it can save the organization embarrassment if analyses are vetted internally for accuracy prior to the information being given to outside stakeholders. It may also be necessary to have the analyses vetted by some credible external body as a matter of policy, and especially if trust is an issue for stakeholders Validation Validation should include the following steps: checking that the scope is appropriate for the stated objectives; reviewing all critical assumptions and ensuring that they are credible in light of available information; ensuring that the analysts use appropriate models, methods, and data; checking that the analysis is reproducible by personnel other than the original analyst(s); checking that the analysis is not sensitive to the way data or results are formatted; and checking to ensure that all assumptions and uncertainties associated with the estimation process have been acknowledged and documented (IALA p.14).
14 The QRA of the TERMPOL does not have a Third Party review. Contractors hired by the NGPLP do the actual TERMPOL. Those hired by NGPLP have interested gains and reputations to maintain in terms of ability. Decision Making 36. The IALA tool within the decision making step compares costs to benefits as does the NGPLP QRA but a difference occurs in the comprehensiveness of the risk assessed. The IALA states Compare Costs to Benefits and Make a Decision When monetary estimates of benefits and costs are available, discounting can be used to rank options in terms of benefit/cost ratios, net present values, and so on. Where monetary estimates of the benefits are not directly available, threshold values can be used to at least rank the options. Even so, balancing estimated risk-reduction benefits against option costs is never straightforward. Society usually demands more risk-reduction effort where human life and health are at risk than where only property is involved; and the public usually demands a high level of effort be expended to prevent environmental damages. Public perception of the risks involved often plays as much or more of a role as does the actual estimate of the expected losses. Balancing risk-reduction benefits against risk-reduction costs is an important issue today. In a risk-averse organizational setting, people minimize expected losses, to the extent possible, irrespective of the probability or impact of the risk. In a risk-taking environment, people compare expected risk-reduction benefits to the cost of the initiative which would produce these benefits. They take actions that would optimize the overall benefit to society (e.g. keeping in mind the type of losses involved, whether associated with life, health, property, the environment, revenue). A risk-smart organization does not simply take more risks; it takes calculated risks that optimize the benefits derived from its risk-reduction activities. It is important here to consider more than the obvious, hard, financial benefits and costs of the activity. There may also be a number of associated indirect benefits and costs that may not be readily recognized - for example, ecosystem health, sustainable development, employment benefits or other spin-off benefits. These so-called soft benefits and soft costs should also be considered, in the Risk Assessment process. It is important that both direct and indirect effects of an activity be considered and factored into any analysis of acceptability. The use of a multidisciplinary risk management team, coupled with an extensive consultation program, may aid this effort. (IALA p.21)
15 The DNV tool does not consider the soft benefits or costs such as ecosystem health, sustainable development, or economic benefits that exist currently or in the future that may be jeopardized by the project. The NGPLP QRA states The consequences that could result from an incident as well as the conditional probability of a spill are assessed in the QRA. Not all incidents will necessarily lead to a release of oil, condensate and/or bunker fuel. Consequences, for the purpose of this QRA, are defined as physical damage to the tanker or the marine terminal and the amount of cargo or bunker fuel that may be released. The environmental, social and economic impacts resulting from an incident are discussed in documentation provided to the National Energy Board (NEB). (Pg 1-2 Marine shipping Quantitative Risk Analysis ) 38. In other words the analysis of the shipping risk is divided into separate components. This leads to an incomplete assessment that is not a comprehensive integrated perspective of risk of the project. 39. The added component of the IALA QRA tool is the incorporation of the human element Incorporation of the Human Factors The Human Factors are one of the most important contributory aspects to the causation and avoidance of incidents. Human Factors issues should be systematically treated within the Risk Management framework, associating them directly with the occurrence of incidents, underlying causes or influences. Appropriate techniques for incorporating human factors should be used. Some of the most common techniques used are listed below: Questionnaires; Observations; Interviews; Simulation studies; Hierarchical Task Analysis; Cognitive Walk-Through (CWT); Cognitive Task Analysis (CTA); Expert Judgment / Expert Evaluation; Human Reliability Assessment (HRA). Without the application of Human Factors based techniques and taking Human Factors aspects into consideration in any of the five steps in the risk management there is a great risk that vital elements will be inadequately carried out. When missing the Human Factors elements it is also likely that
16 16 the result of a risk assessment, related to any incident, accident, near miss or observations of undesired conditions, will fail as e.g. the root causes may be completely missed. To understand the concept of Human Factors in a socio-technical system and what it includes you could refer to the following Septigon Model. The model describes seven basic areas to be considered as well as the interaction between any of the elements; (p. 25) The IALA model includes the following: 1. Vessel, equipment, instruments, machines, tools, automation, manuals,operational material, signs 2. Physical workspace environment, air quality, temperature, lighting conditions, noise, smoke, fumes, vibration, weather, visibility 3. Policies, norms, formal rules, procedures, company and management, organisation of work 4. Socio-political and economic environment, regulatory issues, cultural aspects and barriers, nationality and language 5. Custom and practice, informal rules; how we do things here 6. Human components, psychological capabilities and limitations, personality, personal workload management, experience, knowledge and currency 7. Other individuals. Relational and communicational aspect, interactions, teak skills, crew team resource management, supervision.( IALA p.25) 40. The NGPLP QRA does not consider all these components. Issues that need to be considered are factors such as language used of the captain and crew of the vessel, length of shift of the pilots with adequate breaks, fatigue of the crew, use of drugs both prescription and non prescription and effect on those operating the ship and tugs, effect of adverse weather on the crews. 41. The NGPLP assess the risk of hydrocarbon spills happening but does not assess the effects of a spill and its consequences as part of the QRA.
17 IALA offers a more integrated model. The risk matrix estimates relative score to the frequency and consequences associated with identified hazards (e.g. low, medium, high) and plots them on the matrix. IALA states that Usually, these assessments must be based on intuition experience and expert knowledge where no data are available or quantitative analysis is not warranted. Table 1 shows their matrix risk model and table 2 shows the scoring that is used and table 3 shows an example of the matrix used. Table 1 source power point presentation Ports and Waterways Safety Assessment (PAWSA) by Mike Sollosi
18 18 Table 2 Source power point presentation Ports and Waterways Safety Assessment (PAWSA) by Mike Sollosi
19 19 Table 3 Source power point presentation Ports and Waterways Safety Assessment (PAWSA) by Mike Sollosi 43. The model then allows for evaluating mitigations and recommended measures. The point of the matrix and its example is to demonstrate the complexity of QRA and the need for a comprehensive tool Additional data and information 44. IALA recommends a list of data and information that should be considered in evaluation risks, specific to marine aids to navigation in the Annex II (IALA guideline 1018). In Maritime traffic, IALA looks at traffic statistics #2 in 1.1 (IALA) and a number of data set are required. Specific data of current movement of traffic in the area is part of the data set.
20 20 #2. The number of vessel traffic movements in the area concerned including trends in the number of vessel movements, base on e.g. AIS- data covering the past 3-5 years. (IALA p. 29) Limited information was available in the NGPLP QRA due to the lack of AIS coverage and Vessel Tracking System over a 5 year period. Vessels can enter the port of Kitimat and not be noted on the Marine Tracking system. This lack of data inhibits the ability of the QRA to make a complete evaluation. There is inconsistent data due to blind spots in the area and ships not reporting to Prince Rupert 45. Below is a Goggle map with the tracking stations in red and communication stations in green. Google Earth Map showing the location of the 5 Base Stations (Red Balloons) and 9 Communication Sites (Green Balloons) comprising the Prince Rupert MCTS (Marine Communications and Traffic Services Centre)