Memorandum submitted by Dr Jonathan Wills |
"The area of Atlantic Ocean to the West of
Shetland on the edge of the continental shelf, is characterised
by extreme environmental conditions such as strong winds, huge
waves, very low temperatures and significant water depths."
This quotation is from Total Exploration and
describing their new Laggan-Tormore gas project, lying 125km west
in 600 metres of water. These are the harshest conditions in UK
So why go there?
Total's public documents explain:
West of Shetland has the potential to
produce 2.5 billion barrels of oil equivalent;
The area holds around 17% of the UK's
remaining oil and gas reserves;
They contain more than 1 trillion cubic
feet of gas, plus some condensatesequating to about 230
million barrels of oil equivalent; and
Peak production rates are expected to
be about 500 million standard cubic feet per day.
Even though the development costs of the first
group of wells are in the order of £2.5 billion, it is still
worthwhile extracting gas out there. It's going to happen, along
with further development of other gas and oil deposits and fields
not yet discovered.
The question is whether the regulators have
the power, the determination, the staff and the money to ensure
that it is done without unacceptable environmental damage.
Let me first declare a direct and pecuniary
interest in this subject: I make part of my living at Noss National
showing tourists the amazingly rich and varied marine wildlife
of the Shetland Islands.
And I lost a lot of business the one and only time we had a big
oil spill, in 1993. So I have more enthusiasm than most for keeping
the sea clean, even though I work on a boat that burns 21 tonnes
of diesel a year (that's about 10 litres per passenger). I also
have grandchildren in London and Prague and am thus a disgracefully
frequent flyer. So while I may sometimes have been seen as a critic
of the industry, I'm also a very good customer. And I think that
gives me the right to say what I think the oil and gas corporations
ought to be doing better.
I've watched BP at close and critical quarters
in Shetland since the mid-1970s, in my former careers as a journalist
and environmental consultant and, more recently, as a councillor.
I don't subscribe to the view that the initials BP stand for Bad
People. Most of the BP officials I've met were honestly trying
to do a good job. Not all succeeded, of course, but I should also
declare that I believe BP's environmental performance in Shetland
over the past 31 years has been mostly first class. They got off
to a bad start when the 12th tanker
to call at the Sullom Voe oil terminal, in December 1978, collided
with a jetty and spilled 1,142 tonnes of fuel oil. The accident
wasn't BP's fault but the failure to contain and clean up the
spill certainly was. They learned their lesson and in April 1979,
in co-operation with Shetland Islands Council, BP instituted a
pioneering tanker safety scheme and one of the best pollution
prevention and response regimes in the world. It went far beyond
normal best practice and was enforced by the clauses in commercial
contracts for the uplift of oil cargoes. This mechanism to ensure
compliance was very effective but, alas, has not been widely copied
in other oil provinces around the world.
Given BP's record in Shetland I was rather surprised,
in 1989, to find the company up to its neck in the Exxon Valdez
disaster, where a BP-dominated firm, Alyeska Pipeline Service
Company, in association with the US Coast Guard and the Alaska
Department of Environmental Conservation, repeated all the spill
prevention and response mistakes BP had made in Sullom Voe a decade
before. The learning curve clearly had some big steps on it. I
wrote this up in newspaper articles and a book. BP Alaska were
not best pleased with me. They were still upset when, in 1999,
I wrote a paper reviewing the impressive improvements that BP
and its Alaskan partners had belatedly introduced after Exxon
Valdez, and pointed out one or two things they appeared to
have missed. They prevailed on my client, a citizens' advisory
group established in Alaska by President George Bush (The First),
not to publish my paper.
I would be happy to provide the committee with a copy if it is
Each oil or gas disaster brings demands for
new laws and better working practices. Often the disaster could
have been avoided if people had just complied with existing laws
and best practice. In Shetland I have seen with my own eyes that
it is possible to have a profitable oil and gas industry without
causing widespread environmental pollution, ecological catastrophe,
social disruption and the impoverishment of the majority. I admit
this is a fairly uncommon situation, taking the world as whole,
but I insist that it is possible. So I remain an optimist, the
latest Gulf of Mexico blow-out notwithstanding.
We're asked: "Could it happen here?"
The answer seems to be "Yes". But we really don't know
how likely a seabed blow-out is in the West Shetland oil and gas
fields. The Macondo experience is telling us that there may be
serious and hitherto unsuspected problems with blow-out preventers
(BOPs). The record in the shallower waters of the North Sea over
the past 40 years should be encouragingthere has been only
one very prolonged, serious blow-out that I can recall (Ekofisk),
although there have been some close calls. The Piper Alpha disaster
caused terrible loss of life but the pollution was neither extensive
A question the technical experts surely must
now answer is this: are the blow-out preventers properly designed
for the much higher pressures of deep water drilling? And does
the industry have credible contingency plans to deal promptly
and effectively with deep sea blow-outs? In the relatively shallow
North Sea it is usually possible to send down saturation divers
to tackle problems. In the very deep waters west of Shetland it
is not. As in the Gulf of Mexico, any response to a seabed blow-out
would depend to a large extent on remotely-operated vehicles (ROVs).
These submarines are ingenious machines and can do a great deal
but, as we have seen with the Macondo well, they are slow and
cumbersome. Contingency plans ought to reflect this.
If a damaged wellhead has to be sealed off permanently,
the only way to do it is to drill a relief well. As we saw in
the Gulf of Mexico (and north of Australia not long ago), this
can take months. The technology is impressive but progress is
necessarily slow. Because it takes so long, should relief wells
be drilled alongside every group of new wells? And what would
Of course, seabed blow-outs are relatively rare.
Most spills come from exploration rigs, production platforms and
floating production, storage and offloading vessels (FPSOs) at
the surface. Most leaks are small and many are chronic. They have
been a daily occurrence in the North Sea for almost four decades,
although performance has improved with the progressive implementation
of the OSPAR
accords by member states.
In the early 1970s we were very worried about
the potential for massive pollution from submarine pipelines but,
as far as I am aware, there have been no large, prolonged leaks
from the thousands of miles of seabed pipeline laid since the
1970s. In fact, submarine pipelines in the North Sea appear to
have a much better safety record than pipelines on land.
We mainly learn about leaks of oil and gas from
the polluters. This self-reporting is a problem because under
the present enforcement regime there is no such thing as a surprise
inspection to check on compliance. Ronald Reagan's principle of
"Trust but Verify" is not applied offshore. It ought
to be. It might have helped at Macondo.
Another concern is the use of FPSOs in the "Atlantic
Frontier" oilfields west of Shetland for the past dozen years.
There have been several incidents, including a ship collision,
and this system of oil production in deep water appears to be
inherently more accident-prone than fixed or tethered platforms
with subsea wellheads connected to pipelines. Should it be allowed
Numerous official reports
on accidents and incidents in the offshore oil and gas industry
suggest that the biggest danger to safe operations is in fact
routine interference in the work of expert drillers and other
technical staff, often by shore-based managers chasing financial
targets, resulting in repeated failures to follow industry best
practice. This seems to have been the case, yet again, with the
Macondo disaster in the Gulf of Mexico. Some managers fail to
ensure compliance with safety regulations; others turn a blind
eye to corner cutting; and some even order operations staff to
ignore the rules in order to get the job done on time and under
budget. This seems to be what was happening on Transocean's Deepwater
Horizon rig. Perhaps someone in government should have noticed.
If they did, nothing was done in time.
Other questions that can be answered by witnesses
more qualified than I am include:
Are the pollution prevention plans for
West Shetland adequate? In partnership with the oil and gas industry,
Shetland Islands Council has drawn up a pollution contingency
although it is not obliged to do so by law. However, it only extends
a short way out to sea and deals mainly with tanker traffic in
the port of Sullom Voe and with potential spills from the onshore
oil and gas terminal there.
Are the government and industry response
plans adequate for dealing with a deep-water spill?
Do we have an adequate compensation regime
in the event of a spill from a wellhead, pipeline, production
platform or drilling rig? The recent report by Client Earth
would suggest not.
What I can try to tell the committee, from my
personal experience and knowledge, is:
How the Gulf of Mexico and West Shetland
offshore environments differ.
Where seabed and surface spills are likely
to end up.
What's at risk in those stormy waters
off the west coast of Shetland.
Why this area is so exceptionally rich
Why conventional oil spill response techniques
are unlikely to be effective west of Shetland.
And, last but not least, what the economic
effects of a major, prolonged spill might be.
How do the Gulf of Mexico and West Shetland offshore
Much of the Gulf of Mexico is far deeper than
the area beyond the edge of the continental shelf west of Shetland.
Around our islands the seabed is less than 200 metres deep, gently
shelving down to a depth of about 500 metres. It doesn't reach
1,000 metres until midway between Shetland and Faeroe, part of
the area currently being developed for oil and gas extraction.
Whereas the Gulf of Mexico is a basin, in which
the main currents rotate in what oceanographers call a "gyre",
the West Shetland sea area has more complicated currents, due
to a broad, undulating ridge between Shetland and the Faeroe Islands.
Here the relatively warm surface currents mostly run from south-west
to north-east all year round, while the cold, dense, saltier water
of the bottom currents spills over the Faeroe-Shetland ridge from
north to south. However, there are significant variations and
near the edge of the shelf the current may flow in the same direction
on the seabed as on the surface.
describe these currents as "complex" with "various
strong non-tidal currents interacting with relatively weak tidal
flow". At the surface, wind and waves certainly dominate
the water movement: "On the surface, the deep water over
the West of Shetland continental slope is exposed to a large fetch
and strong winds, particularly from the west and southwest. These
conditions generate an extreme wave regime in the area which is
more severe than that experienced in the northern North Sea. The
area is also affected by long periods of ocean swells generated
from Atlantic storms."
Where are seabed and surface spills likely to
The bathymetry of the Gulf of Mexico basin and
the prevailing winds mean that most oil spills will stay in the
Gulf of Mexico. Things are rather different in the North-east
Atlantic, where the remains of any spill are likely to end up
in the Arctic Ocean. We now have a good idea of the probable track
of oil spills at the surface west of Shetland. The research
done for the Foinaven and Schiehallion oilfields in the 1990s,
together with more recent work in connection with the environmental
assessment for Total's new gas fields, confirms that surface currents
and wind will tend to take surface slicks in a generally north-easterly
direction, parallel to the edge of the shelf, past the coast of
Shetland and out into the Norwegian sea. This prediction is based
on the prevailing south-westerly winds but strong winds may blow
from any quarter at different times of year. The Meteorological
Office wind rose data
make this very clear. A strong and sustained north-westerly wind,
very common at some seasons, would blow any oil slick ashore on
the west coast of Shetland within two or three days.
The track of a seabed spill from a wellhead
or pipeline, on the other hand, is harder to predict. The cold,
bottom current flowing to the south and south-west is not uniform
and it is difficult to calculate its effect on a wellhead spill,
although Total have tried.
However, being warmer than the surrounding water, any leaking
oil or condensate would tend to rise towards the surface, where
the current would certainly carry it in a predominantly north-easterly
direction. But, once on the surface, it would be subject to the
dominant influence of the wind.
Further research may be needed if we are to
model accurately the probable tracks of seabed spills in this
area. We also have no clear idea of what proportion of a seabed
spill would reach the surface in these cold, northerly seas. But
it is interesting to note that seabed water temperatures in the
Gulf of Mexico are surprisingly similar to the cold depths west
although surface temperatures are, of course, much higher all
What we can be sure of (although Total say it
is "unlikely" as far as the condensates from their gas
fields are concerned)
is that at least part of any large and prolonged spillage, whether
it occurred on the seabed or at the surface, would be very likely
to hit the shoreline somewhere in the 100 miles between Fair Isle
at the southern end of Shetland and Muckle Flugga at the northern.
Any beachcomber knows that.
What's at risk on the west coast of the Shetland
When oil spills come ashore they generate words
and pictures as the media reports the latest wildlife disaster
to the world. The media coverage of the Braer oilspill,
which took place in midwinter when most of the seabird population
was well away from Shetland, gives some idea of the publicity
firestorm that could result from a midsummer spill in idyllic
islands made justly famous by Simon King's wildlife TV shows.
And the Braer was before the internet, Facebook and Twitter.
Shetland's high media profile, as one of the best places in Europe
to watch seabirds and marine mammals at close range, guarantees
that any spill, let alone a blow-out, will make global front pages
for many days, and for legitimate reasons.
The public naturally becomes enraged when confronted
with footage of thousands of oiled and dying seabirds on a beach.
It is harder to feel sympathy for microscopic plankton and ugly
anglerfish. Oil dispersed under the surface, particularly when
it is 70 miles from shore, is unseen by reporters and camera crews
but may have even more serious effects on marine ecology than
a high profile coastal spillage.
Even in summer, the open Atlantic west of Shetland
is, more often than not, a grey, cold, stormy place. From the
deck of a ship it can look deserted, apart from scattered flocks
of seabirds. Most people find it hard to imagine its cold depths
as anything other than cold, deep and empty. In fact this ocean
and its seabed are teeming with life-formsequipped to thrive
where we cannot survive.
To quote the Atlantic Frontier Environmental
Network (AFEN): "Contrary to general expectations, the abundance
of animal life in the deep waters of both the Rockall Trough and
Faeroe-Shetland Channel is not markedly lower than that encountered
in shallower waters. In the Rockall Trough and the waters to the
north of Shetland, animal abundance appears to increase with depth."
Over 2,000 different species of animals were recorded during seabed
surveys in 1996 and 1998.
Total's Environmental scientists
have found the same:
"In general, deep sea habitats demonstrate
a decrease in biomass and abundance with increasing water depth
but the West of Shetland area, because of its dynamic currents,
temperatures and contours and trenches
on the seabed, does not follow this trend
Various species of sea urchin are the most common
seabed animals here, along with burrowing worms, polychaete worms,
shrimps, hermit crabs, sponges, sea anemones and colonial, encrusting
animals such as bryozoan crinoids ("sea fans") and cold-water
The Atlantic margin west of Shetland is an important
nursery and feeding ground for many commercial fish species, including
haddock, monkfish, whiting, cod, saithe, ling, herring and mackerel.
Valuable shellfish landed from this area are brown crabs, scallops,
squid and prawns.
The most abundant seabirds here are the northern
fulmar, the black-legged kittiwake and the gannet. Common guillemots,
arctic terns, puffins and storm petrels are seasonal visitors,
on passage to and from their breeding colonies ashore in Shetland.
In observations over the past 20 years, 16 species
of whale and dolphin have been sighted in the West Shetland oil
and gas fields. The edge of the continental shelf has been described
as "a whale motorway".
Why is this area so biologically rich?
The best summary of Shetland's ecological significance
that I have seen is in J. Laughton Johnston's book, A Shetland
Naturalist (Poyser, 1999):
"Shetland is a spectacular group of islands
with a varied geology, a wonderful landscape and a special flora
Shetland remains one of Britain's national
The most outstanding features include the following:
The inshore waters around Shetland are
still pristine, and certainly the cleanest in the North Sea (although
marine litter is a significant problem).
The unusual "jigsaw" shape
of the islands packs a profusion of coastal and marine life into
the 1600-mile-long coastline of a land area of just 567 square
miles. There is about 20 times as much coastline per square mile
of land in Shetland as in Sussex or Norfolk.
The variety of inshore habitats over
short distances is remarkablefrom seabed over 120m deep
to cliffs over 200m high; from tidal lagoons and sandy beaches
to caves and kelp forest; from oxygen-depleted waters at the head
of Sullom Voe to the turbulent, oxygen-rich waters of Bluemull
Sound. It is doubtful if such a wide variety of coastal geomorphology
could be found in an area of similar size anywhere in Britain.
Unlike much of Scotland, Shetland has
a "drowned" coastline, due to a rise in relative sea
level of some 120 metres since the end of the last glaciation.
This has provided material for the outstanding diversity of sand
and shingle bars, spits and "tombolos" (causeways),
not found in such numbers anywhere else in the UK. All of these
features are highly vulnerable to oil pollution. The submarine
topography is extraordinarily varied over short distances, creating
rich habitats for inshore sea life, particularly in the kelp forest,
which may have an area of over 200 square miles (no-one has yet
charted it accurately).
The continental shelf around the islands
is one of the richest and most productive seas in the world. As
a plankton producer it ranks with the Grand Banks of Newfoundland,
Russia's Sea of Okhotsk and the Gulf of Alaska. Like the deeper
waters west of the shelf edge, it is far more "biodiverse"
than a casual observer might suppose.
One reason for this is the extreme turbulence
of our coastal waters, due to the mingling of Atlantic, Arctic
and North Sea currents, the churning effect of tide races in the
narrow sounds between the islands, and the upwelling of bottom
water as tides and currents run over the drowned cliffs and ridges
extending offshore from many headlands. Some of these submarine
obstructions rise 30-40m from the seabed. In addition, Shetland
experiences an average of about 100 days a year when the wind
is Force Seven (near-gale) or higher.
The turbulence caused by all these factors traps
large amounts of nutrients (mainly from rotted seaweed and dead
plankton) in sunlit water less than 30 metres deep (the "photic
zone"). Underwater visibility in Shetland is therefore surprisingly
poor between March and September, due to the plant plankton "blooms"
fed by the profusion of nutrients. This phytoplanktonic "fog"
is in turn eaten by swarms of animal plankton. This zooplanktonic
"snow", including the larvae of all our commercial finfish
and shellfish, is food for fish, basking sharks and baleen whales.
These blooms and swarms of plankton extend out
to and beyond the continental shelf margin, well into the area
currently being explored and exploited for oil and gas. Research
into the effects of oil spills on plankton suggests very serious
and long-lasting damage can occureven if we don't spread
the pollution throughout the water column by spraying dispersant
on surface slicks or injecting it into plumes of oil leaking from
a seabed wellhead. The plankton may be out of sight and, for most
people, out of mind, but it is the basis of the coastal ecosystem.
The plant plankton also produces a significant
proportion of the oxygen we breathe. Without it the oxygen level
in the atmosphere would drop below the 21% level at which we have
evolved. This surface layer indeed gave rise to the first plants
and still contains most of the world's flora, by mass. It is extraordinarily
thin and fragile, rarely more than 30 metres deep. In comparison
with the diameter of the Earth, the phytoplankton layer is thousands
of times thinner than the skin of a bubble. The precautionary
principle strongly suggests that we should make all possible efforts
to avoid damaging or disrupting it.
At the top of the plankton-based food chain,
Shetland's seabird breeding colonies
are of international significance and among the largest in the
North Atlantic. The Hermaness National Nature Reserve,
for example, lies directly downwind and downstream of the Foinaven
and Schiehallion FPSOs that have been producing oil since 1998.
The island of Foula
is another ornithological jewel, lying in the track of spills
from the West Shetland fields when the wind is between west and
north-west. A single spill during the breeding season could cause
severe and widespread damage, all along the west coast of Shetland,
to populations of gannets, fulmars, puffins, guillemots, black
guillemots, razorbills, kittiwakes, arctic and common terns, great
and arctic skuas, shags, cormorants, eiders, red-breasted merganser
and red-throated divers.
A prolonged spillage from a blow-out, lasting
weeks or months, could easily develop into a major ecological
catastrophe. Even in winter, there are large populations of vulnerable
seabirds inshore around the islandsincluding rare winter
visitors such as great northern divers, slavonian grebes and long-tailed
Shetland is a vital staging post for migratory
birds and has a world-famous ornithological observatory on Fair
Isle. Shore birds and wintering wildfowl are particularly vulnerable
to coastal oil pollution.
Our populations of grey and common seals and
otters are nationally important. Shetland has the highest density
of otters in the UK. Grey seals have been recorded as far as 70
miles out in the Atlantic.
The coastline is also of special botanical interest,
with some surviving rarities such as oyster plant, surprisingly
lush cliff meadows and very interesting plant communities now
developing on more than 60 small holms where sheep are no longer
Geologically, Shetland is more varied than almost
any area of similar size in Europe. The islands have recently
gained Unesco Geopark
status because of this. The rock exposures along the shoreline
range from basalt cliffs and ancient oceanic crust through almost
every major rock type to Devonian fossil beds and desert sandstones.
Classic sites include major structural features such as the northern
extension of the Great Glen Fault and glacial overflow channels.
Shetland's long ridges of hills and voes (sea lochs) are a textbook
example of "Appalachian" landforms, related directly
to the underlying geology. Coastal geological exposures of international
scientific significance are all critically exposed to oil pollution.
As the most northerly stretch of coast in Britain,
Shetland is literally a place on the edge. The shoreline lies
in the frontier zone between temperate and sub-arctic marine ecosystems.
For some northern species it is the southern limit of their range,
and vice versa. It is an ideal place to monitor and measure
the ecological consequences of climate change, which is likely
to have extreme effects in Shetland, particularly with the expected
further rise in sea level.
Shetland's environment is exceptionally well
documented, with a larger literature about it in the natural sciences
than for any similar-sized area in Scotland. A bibliography, which
I compiled in 2003 for Shetland College and UHI, ran to 63 pages
and over 1,000 books and papers. It was by no means exhaustive.
There is a vast amount of "baseline" information about
Shetland's coastline, due in part to the work of the Shetland
Oil Terminal Environmental Advisory Group
(SOTEAG) which for over 30 years has carried out regular biological
sampling and monitoring under the auspices of Aberdeen University,
to accumulate some of the longest-running, most detailed and methodologically
consistent data sets of their kind in the world. Scottish Natural
Heritage also has a long-running programme of wildlife and habitat
monitoring, while the North Atlantic Fisheries College marine
in Scalloway, Shetland, has recently completed a major piece of
baseline research for the Shetland Marine Spatial Plan.
This is part of the Scottish Sustainable Marine Environment Initiative
(SSMEI) and one of the firstand certainly the most detailedsuch
projects in Britain. The Marine Atlas in the plan is a remarkably
valuable data set, compiled in collaboration between scientists,
fishermen and other marine industries, including tourism operators.
So we know what we have at present and we would
be able to say with some accuracy what we had lost if a major
spill occurred, whether or not it beached. Unfortunately, there
is no known way of compensating for such a loss.
Will conventional oilspill response techniques
work west of Shetland?
The simple answer is "No". The reason
is the weather. The Macondo slicks have shown us, yet again, that
even in calm weather in the Gulf of Mexico the best containment
booms, skimmers and other oil recovery techniques are unlikely
to recover more than 20% of a spill, and much of that will in
fact be a water/oil emulsion. This has been detailed in the US
Government and Congressional inquiries into the disaster. Few
floating booms can hold oil in waves of more than one metre. Such
small waves are almost never found in the West Shetland oil and
gas fields. So most oil spilled will not be contained. Nor will
it be recovered, as there is currently no open ocean skimmer capable
of recovering more than insignificant token amounts, and then
only during rare weather windows. Even if it were recovered, how
could it be transferred to tankers and barges in the open ocean?
Natural evaporation is far slower in the cold
water of the North-east Atlantic than in the Gulf of Mexico and
may be largely discounted, at least insofar as a spill reaching
the coast in a few days is concerned.
Burning oil at sea is possible in the Gulf of
Mexico but impracticable in the rough, cold seas of the North-east
Atlantic. So we can forget that also.
The only practical way to deal with an offshore
seabed spill is by injecting dispersants into the plume of oil
at the wellhead or pipeline leak, and to spray the surface slicks
as they appear. However, the risk of causing serious ecological
damage to the plankton may outweigh the largely cosmetic benefits
of dispersing a slick. It looks good on television but it's fairly
ineffective and that's about all you can say for spraying dispersants.
That leaves Nature to clean up. And sometimes
she can. Although Gulf of Mexico/Caribbean hurricanes have long
since blown themselves out by the time they have crossed the Atlantic,
the remains of these storms do reach Shetland, where hurricane
force winds of Force 12 are sometimes recorded several times a
year. The Braer oil spill in January 1993
showed that prolonged, violent storms can be more effective than
human efforts at cleaning up (or, at least, dispersing) some types
of oil spill. This may also prove to be the case in the Gulf of
Mexico during the 2010 hurricane season. Violent storms can disperse
some oil but for best effect their energy needs to be concentrated
by topography, as happened when a sustained (and rather unusual)
Force 11 storm dispersed most of the Braer's 85,000 tonnes
of oil by churning it up with the sea in two sandy bays less than
15 metres deep. This natural mechanism for dispersing spills is
likely to be less effective in the open ocean.
In summary, only a very small fraction of any
open Atlantic spill west of Shetland is ever likely to be recovered
or dispersed by human agency. Various snake oil salesmen and perpetual
motion machine inventors will try to convince us otherwise but
there is, in fact, almost nothing useful we can do once it happens.
That is the awful truth and we would do better to face it and
concentrate on preventing spills rather than entertain technological
fantasies about mega-skimmers funded by celebrities and slurping
up thousands of tonnes of oil. In your dreams
What are the likely economic effects of a major,
Shetland's fisheries (including salmon and mussel
farms) were worth £225 million in 2006, in the most recent
detailed economic study. The figure is now probably about £250
million. This is about four times the annual value of the Sullom
Voe oil and gas terminal to the local economy.
We know from experience in Cornwall (Torrey
Canyon), Brittany (Amoco Cadiz), Alaska (Exxon Valdez)
and Shetland (Esso Bernicia and Braer), that oil
spills, particularly large ones, usually have some or all of the
closure of fishing grounds;
massive destruction of farmed fish and
loss of markets in the short and longer
loss of product reputation built up over
bankruptcies among boat owners, fish
farm companies, processing factories, sales agents and local suppliers;
widespread unemployment among boat crews,
fish farm workers, factory hands and employees of local suppliers;
and that's before we consider the mental
and physical illness caused to local people and cleanup workers.
In addition, any spill gives an area massive
bad publicity, which persists long after the oil has ceased to
be visible. This depresses markets for all local products and
particularly for tourism, which is likely to be severely affected
for a full year after the spill and may take many years to recover.
Tourism is a growing industry in Shetland, currently worth about
£18 million. Its growth is mainly spurred by wildlife tourism,
helped by some carefully targeted and highly effective publicity
organised by the new Promote Shetland
On top of these losses to private businesses
and individuals, a spill inevitably creates costs for local authorities
and voluntary organisations who try to respond, often when they
have no statutory duty to do so. A spill such as the Braer
can mean bills far beyond the means of a small coastal local authority.
In the end central government has to pay up if, as in the case
of the Braer, the shipowners and their insurers contrive
to escape full liability.
So all spills cost the taxpayer.
Compensation for victims of oil tanker spills
is typically, slow, grudging and inadequate. But at least some
of those who suffered financially from the Amoco Cadiz,
Exxon Valdez and Braer spills eventually got something.
And the spills I have mentioned are all "single-point"
incidents where all the oil was in the water within a few days
of the grounding. An uncontrolled leak from a seabed blow-out
in the open Atlantic west of Shetlandpumping thousands
of tonnes of oil a day into the ocean over many weekscould
devastate the Shetland economy, cripple the finances of the local
authority and have long-lasting and far-reaching financial effects
that are, literally, incalculable.
With a spill from an offshore installation,
it appears that there is little or no compensation available from
the polluters or their insurers and the whole cost could well
fall on the public. This surely amounts to the nationalisation
of risk and the privatisation of profit, a phenomenon with which
we are all wearily familiar in this country.
The Gulf of Mexico spill appears partly to have
been the result of lax enforcement and excessive familiarity (not
to say conviviality) between the regulators and the regulated
but in one respect at least the USA is ahead of us: in American
courts it is possible to win exemplary damages (if the Supreme
Court doesn't intervene) and also to sue for damage to environmental
assets like birds, whales, seals and even plankton. It is a sad
irony that in Shetland, where we have far better baseline information
about our world-class environmental treasures than almost anywhere
else in the world, the gannets, fish and plankton are not worth
a penny in the eyes of the law.
So I'm glad Parliament is looking into these
problems and I hope you will propose some practical solutions
soon. A good place to start would be Europe-wide laws on adequate
compensation for spills from rigs, platforms and production ships.
A firm but fair enforcement regime would be useful. A law to allow
pollution victims to sue for environmental damage would help.
And we should not forget the extraordinary power the insurance
industry can wield, if it chooses, to require and enforce compliance
with the highest standards of design, operation and maintenance.
We are going to need quite a lot of oil and
gas for at least a century, by the look of things, so the sooner
we minimise its adverse effects on the marine life that sustains
us all, the better.
Thank you for the invitation to take part in
your inquiry. It is much appreciated.
12 See Total's "Project Overview" at: http://www.laggan-tormore.com/project.cfm
and also their "West of Shetland Environmental Statement"
at http://www.laggan-tormore.com/pdf/West_of_Shetland_Environmental_Statement.pdf Back
For an introduction to the Shetland Islands, see: http://visit.shetland.org/about-shetland Back
See: http://www.nnr-scotland.org.uk/reserve.asp?NNRId=3 Back
See: http://www.seabirds-and-seals.com Back
The Exxon-owned tanker Esso Bernicia. For an account of
this incident and the parallels with the Exxon Valdez clean-up,
see Wills, J, 1991. A Place in the Sun-Shetland and Oil.
Mainstream, Edinburgh. Back
Wills, J, 2001. Partners or Regulators? Prince William Sound/Sullom
Voe Comparisons, 1989-99. Prince William Sound Regional Citizens'
Advisory Council, Contract Report No. 400.00.1, Valdez, Alaska. Back
The Oslo-Paris Convention to protect the environment of the North-east
Atlantic, the North Sea and the Baltic. See: http://www.ospar.org/ Back
See, for example, the Cullen Report into the Piper Alpha disaster,
at: http://hansard.millbanksystems.com/commons/1991/mar/07/piper-alpha-cullen-report-1 Back
See also the records kept by the Offshore Industry Liaison Committee
(OILC), now the offshore workers' branch of the RMT trade union
See the recently updated version at: http://www.shetland.gov.uk/ports/contingencyplans/marinepollution.asp Back
See: Luk, S & Wilks, S, September 2010. Legislative Briefing:
International and EU regulation of oil rigs and other offshore
activities. Analysis and proposals for reform. Client Earth, 274
Richmond Road, London E8 3QW. http://www.clientearth.org/reports/legislative-briefing-international-and-eu-regulation-of-offshore-drilling.pdf Back
See: "West of Shetland Environmental Statement", Section
6, at http://www.laggan-tormore.com/pdf/West_of_Shetland_Environmental_Statement.pdf Back
See: Bett, B J & Masson, D G, 2000. Main discoveries of the
AFEN research project. Section 6.1. http://www.noc.soton.ac.uk/obe/PROJECTS/DEEPSEAS/pdf_files/AFEN61.pdf Back
See wind rose on foot of web page at: http://www.metoffice.gov.uk/climate/uk/ns/print.html Back
The two regions even share similar cold-water corals of the Lophelia
See pp.193-196 of the Laggan-Tormore Environmental Statement at:
Bett, B J & Masson, D G, 2000, op. cit. Back
These trenches-and there are hundreds of them-are plough marks
made by icebergs that grounded thousands of years ago when the
sea level was much lower. Back
See: Patin, S A, 1999. Environmental Impact of the Offshore
Oil & Gas Industry. EcoMonitor Publishing, East Northport,
New York. ISBN 0-967 1836-0-X. http://www.offshore-environment.com/synopsis.html
and Wills, J. W. G. 2000. Muddied Waters A Survey of Offshore
Oilfield Drilling Wastes and Disposal Techniques to Reduce the
Ecological Impact of Sea Dumping. http://citeseerx.ist.psu.edu/viewdoc/summary?doi=10.1.1.133.3403 Back
See: Gage, J D, 2000. Deep-sea benthic community and environmental
impact assessment at the Atlantic Frontier.http://www.sciencedirect.com/science?_ob=ArticleURL&_udi=B6VBJ-435KF21-B&_user=10&_coverDate=05%2F31%2F2001&_rdoc=1&_fmt=high&_orig=search&_origin=search&_sort=d&_docanchor=&view=c&_searchStrId=1458538542&_rerunOrigin=google&_acct=C000050221&_version=1&_urlVersion=0&_userid=10&md5=945df722b331062481287b273f6df97c&searchtype=a Back
SOTEAG = Shetland Oil Terminal Environmental Advisory Group. See
the annual reports of SOTEAG's monitoring programme, 1978-2000. Back
The plan is available online at http://www.nafc.ac.uk/WebData/Files/Part%20One%20Policy%20Framework.pdf
with the marine atlas section at http://www.nafc.ac.uk/WebData/Files/Part%20Two%20Marine%20Atlas.pdf Back
There has been an interesting debate about this in the US press.
For example, see: http://green.blogs.nytimes.com/2010/06/02/more-dispersant-asking-hard-questions/and
For a non-technical description of this incident see Warner, K
and Wills, J W G, 2003. Innocent Passage-the Wreck of the Tanker
Braer. Mainstream, Edinburgh. The scientific work is summarised
in Kingston, P et al, 1994. Recovery of the Marine Environment
following the Braer spill, Shetland. Ecological Steering Group
on the Oil Spill in Shetland (ESGOSS), available online at: http://www.iosc.org/papers/01800.pdf Back
See two books by Dr Riki Ott, an Alaskan marine toxicologist who
studied the health effects of the Exxon Valdez spill: Ott, R,
2005. Sound Truth & Corporate Myth$. Lorenzo Press-http://www.chelseagreen.com/bookstore/item/sound_truth_and_corporate_myth/and
Ott, R, 2008. Not one Drop. Chelsea Green-http://books.google.co.uk/books?id=b-TWppwB_RwC&printsec=frontcover&dq=Riki+Ott&source=bl&ots=gMEPLzqHc5&sig=GV7-1x2D
See: http://www.shetland.org/ Back
See: Wills, J W G, 2001. What Really Happened on the Braer.
Shetland Post, Lerwick. Back
Although many Amoco Cadiz and Exxon Valdez claimants
had died before the final payouts were made, 18 and 21 years respectively
after the events. Back