Enbridge Response in Vancouver Sun to Gunton's NGP spill report. Copy.

Gunton's NGP spill report: http://research.rem.sfu.ca/papers/gunton/NGP%20Spill%20Risk%20Report.pdf Response by Keith Michel and Audun Brandsaeter: http://www.vancouversun.com/business/bc2035/Pipeline+report+fails+real+world+test/8378993/story.html Follows: As professionals in the field of risk assessment, we’re faced daily with the task of separating legitimate risk from its misinterpretation. A recent paper claiming Enbridge Northern Gateway’s risk assessment underestimated the likelihood of future marine spills is an example of a report that makes serious errors in its assumptions and as a result, significantly inflates the risks involved in the future operation of the project. Lead author and Simon Fraser University professor Tom Gunton, along with co-author and PhD student Sean Broadbent, have failed to recognize the number and volume of tanker spills are declining markedly worldwide — even as the total number of tankers plying the world’s waters increases. All data seem to point to the fact that this trend will continue. (SEE FIG. 1 and FIG. 2) This downward trend in marine spills is due to a number of positive developments in marine safety, including the phased-in acceptance over the past two decades of double-hulled tankers as the absolute industry standard in liquid fuel transportation, as well as a raft of new marine transportation regulations that have come into existence over the past 20 years, and a wholesale shift in the safety culture of the industry. Yet authors Gunton and Broadbent, in their criticism of findings we presented at the Joint Review Panel examining the pipeline project, fail to recognize the significant downward trend in oil spills from tankers, neglect the positive impact of double-hulled tankers by applying spill statistics dominated by single-hulled tanker accidents, and incorrectly apply combined in-port and at-sea spill statistics when assessing spills during transit from Kitimat to the Pacific. The report authors further criticize Northern Gateway for not using the U.S. Oil Spill Risk Analysis (OSRA) model drafted in 1975 and originally designed to assess the risks of offshore drilling. But Northern Gateway chose not to use this model to assess the risk of its project for a simple reason: it does not properly assess the localized conditions specific to B.C. For example, the OSRA model fails to account for important regional factors such as the size of ships and local B.C. environmental variables. By contrast, based on expert judgment, Northern Gateway’s assessment of oil spill risk specifically accounts for these regional factors. Furthermore, the chosen methodology enables assessment of risk and risk reducing measures for each segment of the route, something that would not be possible using the OSRA model. Even more curious is Gunton’s and Broadbent’s focus on only a small subset of historical failure incident data. Their failure frequency analysis is based on data from only two pipelines. Spill incidents on these pipelines are reflective neither of the industry experience nor of the new technology proposed for Northern Gateway. But perhaps what’s most telling in the Gunton-Broadbent paper is the fact that its claims fail the real-world test. Based on Gunton’s and Broadbent’s estimates, we would expect 21 to 77 large tanker spills every year around the world. Instead, there are now on average fewer than two large spills per year worldwide. In 2012, there were none. Had the authors made their paper available to the Joint Review Process for scrutiny — as in fact Northern Gateway did with its reports — then these flaws might have been more openly reviewed and discussed. The public would no doubt have gained from the interaction. Employing flawed methodology, the authors fail to account for a range of mitigating factors that will make Northern Gateway truly world class — including a commitment to double hulls both for the crude being transported as well as for the fuel driving the vessel, two-tug escorts for laden tankers, enhanced navigational technology, better marine transportation procedures, improved ballast coatings, reduced speed requirements and tough environmental limits. At the end of the day, readers should know our own peer reviewed analysis finds no reason to think the probability of marine spills here is any greater than the probability anywhere else in the world, where improvements continue and spill incidents are in a steady decline even as tanker traffic increases worldwide. Keith Michel and Audun Brandsaeter are experts in maritime and oil and gas risk assessment. They appeared before the Joint Review Panel on behalf of Northern Gateway Pipeline project to present their detailed risk assessment findings.

world wildlife federation (wwf) on DDT

from http://wwf.panda.org/about_our_earth/teacher_resources/webfieldtrips/toxics/our_chemical_world/ddt/ WWF's Efforts to Phase Out DDT DDT should be phased out of use and ultimately banned While banned decades ago in industrialized countries, thousands of tons of the deadly pesticide DDT are still produced each year, causing health and environmental hazards in the U.S. and throughout the world because of its long life and ability to travel great distances. Currently, DDT's only official use, as specified by the World Health Organization (WHO), is for the control of disease vectors in indoor house spraying - although other (illegal) uses are suspected. Because of the availability of safer and effective alternatives for fighting malaria, WWF is calling for a global phaseout and eventual ban on DDT production and use. Due to the well-documented hazards of DDT, WWF has been involved in a special effort to inform, educate, and convince the public and policymakers about the dangers of DDT and the need to phase out and ban its use. Because DDT can travel long distances and accumulate in the body, millions of humans and animals worldwide have buildups of the chemical in their tissue, even though it may have been used on another continent. WWF-supported research, for example, has found that black-footed albatrosses on Midway Island are contaminated with DDT, as well as PCBs and dioxins. There are no known uses of these chemicals on Midway Island, which is located 3,100 miles from Los Angeles and 2,400 miles from Tokyo. Further studies have linked DDT to feminization and altered sex-ratios of gulls, and eggshell thinning in birds of prey. As a part of the effort to raise awareness about the threats associated with DDT and the available, viable alternatives, WWF has issued a series of reports on DDT. The first report, "Resolving the DDT Dilemma," released in June 1998, notes that DDT is linked to effects in animals or humans such as reduced lactation and reproductive problems. Thousands of tons of DDT are produced each year in at least three countries and it is legally imported and used in many more. "Resolving the DDT Dilemma" offers a framework to guide malaria control programs toward reduced reliance on all pesticides, and a 'tool kit' of alternative techniques, along with several recommendations including: DDT should be phased out of use and ultimately banned; Targeted programs emphasizing reduced reliance on pesticides and better environmental protection should be developed by WHO, World Bank, UNEP, and other multilateral and bilateral assistance agencies; Adequate financial and technical resources must be provided to undertake integrated vector management programs; Research is needed on the hazards from chronic exposure to synthetic pyrethroids being used as alternatives to DDT for indoor spraying and to impregnate bednets. WWF's second DDT report, "Hazards and Exposures Associated with DDT and Synthetic Pyrethroids used for Vector Control," finds sufficient scientific evidence of hazards to human health and wildlife to justify a global ban on the production and use of DDT. This report summarizes the current state of knowledge regarding the health and environmental effects of DDT and its most popular alternative - synthetic pyrethroids. It dramatically illustrates the persistence and pervasiveness of DDT. Some of the more recent scientific findings summarized in the report include damage to the developing brain, causing hypersensitivity, behavioral abnormalities and reduced neural signal transmission, and suppression of the immune system resulting in slower response to infections. Investigations in Mexico and South Africa reveal that human breast milk contains DDE (the breakdown product of DDT) at concentrations that exceed the acceptable guidelines for infant intake set by the WHO. The third report released by WWF, "Disease Vector Management for Public Health and Conservation" demonstrates that a variety of innovative mechanisms can control malaria and other diseases just as effectively as DDT. These alternatives are less harmful to the environment and human health. Detailed case studies in six areas? Africa (Botswana, Tanzania, and Western Africa), India, the Philippines, and Mexico? focus on a variety of alternative techniques. They include pesticide-impregnated bednets (which reduce the need for indoor spraying); odor-baited cloth targets to attract and destroy disease-carrying insects; lower-risk pesticides used in rotation to avoid the development of resistance; and widespread elimination of mosquito breeding grounds and introduction of natural predators. WWF initially called for a global phaseout and eventual ban on DDT production and use by the year 2007, together with financial and technical assistance to the developing world. The 2007 deadline was intended as a motivational tool to encourage the necessary financial and technical assistance. The proposal of a 2007 deadline drew considerable public attention to the scope of the world's malaria problem and the need to implement alternatives to DDT. However, it also raised fears that DDT would be phased out without sufficient guarantees of protection of public health from malaria. To allay these fears, WWF has set aside discussion of the 2007 deadline, while retaining its commitment to eliminating DDT. Both the UNEP and WHO recognize that such elimination can be a "win-win" situation for public health and environmental protection. DDT and the POPs Treaty The Stockholm POPs Convention, a treaty to phase out persistent organic pollutants (POPs), including DDT, is currently open for ratification. WWF welcomes this historic agreement which involved provisions for phasing out DDT, while still allowing for its continued limited use for malaria control. Evidence continues to accumulate about the dangerous health effects associated with DDT. The treaty provisions appropriately balance the need to reduce these hazards while promoting stronger malaria control programs. The accord states that "with the goal of reducing, and ultimately eliminating the use of DDT," individual countries may continue to use the chemical for controlling malaria. However, these countries will also be encouraged to prepare national implementation plans to reduce their reliance on DDT. Specifically, the national plans would promote methods for reducing illegal uses of DDT, such as agricultural applications. Countries would also identify steps to implement alternative approaches and promote measures that strengthen health care and reduce the incidence of malaria. The parties to the treaty will periodically review the status of alternative approaches to determine whether DDT is still needed or whether it can be eliminated completely.