Important Lessons Learned From an Oil Spill

On Saturday, September 17th, the fishing vessel ALEUTIAN ISLE was successfully lifted more than 200 feet from the ocean floor, five weeks after it sank off the west side of San Juan Island. On September 20th the remaining fuel onboard the vessel was removed.

Friends of the San Juans is grateful that the threat of a larger oil spill has been eliminated. Our appreciation and thanks go out to everyone involved in this very challenging and ultimately successful response to the sunken vessel and oil spill.

The sinking of the ALEUTIAN ISLE, the resulting oil spill, and the threat of a larger spill provide an important opportunity to evaluate the response that occurred and identify what needs to be done to be better prepared to respond to the next oil spill. As you probably know, Friends of the San Juans is a proactive champion for improving oil spill prevention and spill response preparedness in the San Juan Islands and across the Salish Sea. We have studied these issues extensively and learned from and worked with our many partners and colleagues in these efforts. The risk of accidents and oil spills in the San Juans is high: In addition to being used extensively by recreational boats and fishing vessels like the ALEUTIAN ISLE, the San Juan Islands are surrounded by commercial shipping lanes. Recreational and fishing boats operate in close proximity to large commercial ships in these narrow waterways. All of the Salish Sea’s ocean-going vessel traffic passes through or around some portion of San Juan County. As vessel traffic increases, so do the risks of accidents and oil spills in the waterways surrounding these islands, especially given the significant increase in oil tanker traffic from the Trans Mountain pipeline expansion and the potential increase in container ship traffic from the proposed Roberts Bank Terminal 2. If oil spill response in the San Juan Islands is going to be effective, urgent upgrades in our response capacity are needed.

Another oil spill could occur tomorrow. The bottom line is that we need to be better prepared. We mustn’t settle for response scenarios that are “good enough” — lowering our expectations is not an option, given everything that can be done to protect these islands and the Salish Sea.

With this in mind, Friends of the San Juans has identified some of the “lessons learned” from this incident and the next steps needed to be better prepared.

1. Oil spill response resources in San Juan County need to be increased:

The apparent oil spill response delays that occurred following the sinking of the ALEUTIAN ISLE highlight the need for more oil spill response resources – equipment and personnel – to be located in San Juan County.

The ALEUTIAN ISLE was not required to have an oil spill contingency plan, which is required for larger commercial vessels. The oil spill response resources that are identified in oil spill contingency plans – the equipment and personnel that are contracted to be prepared to respond to an oil spill from a commercial ship – should be mobilized with compensation when needed to respond to any oil spill, and should ideally be on scene within the timeframes identified in contingency plans (see Chapter 173-182 WAC). This would verify that oil spill response resources can comply with contingency plan requirements.  Ecology should also implement requirements for unannounced equipment deployment drills on a regular basis. In addition to demonstrating compliance with state regulations, this would go a long way towards reassuring the public that oil spill response resources are well-prepared to meet the challenges of a future oil spill.

The spill response resources that are required to be located or staged in San Juan County include a safety assessment of the spill by a work boat with a trained crew and appropriate air monitoring, with 1000 feet of boom, to be on scene within two hours. Additional boom must be able to be on scene within three hours. All other spill response resources are expected to cascade in from other locations (see WAC 173-182-370).

San Juan County’s remote location presents challenges for the required response equipment to arrive at all locations in the County, especially the resources required within the 4- and 6-hour timeframes. (See the San Juan County Oil Spill Response Capacity Evaluation.) Since a 2012 rulemaking, there has been advocacy for requiring that the equipment and personnel needed to be on the scene by four and six hours be resident or staged in San Juan County. (See the San Juan County Council’s September 25, 2012, letter to Ecology)

The Islands Oil Spill Association (IOSA) exists to help our community respond to oil spills. Friends of the San Juans supports additional, sustainable funding for IOSA. A strong and sustainably funded IOSA could be especially important in addressing future oil spills.

2. Resources to keep Southern Resident killer whales away from a spill are inadequate:

When an oil spill occurs, there are approved whale deterrence or hazing operations to keep Southern Resident killer whales away from the spill. Whale deterrence operations could be critical in protecting the Southern Residents from potential extinction. When the ALEUTIAN ISLE sank and the oil spill was reported on August 13, Southern Residents were headed towards the spill. Fortunately, they decided on their own to turn in another direction – if the orcas had encountered the oil spill, the impacts could have been severe, and whale deterrence operations were not yet ready to be implemented. Dedicated and funded resources for whale deterrence in the event of a spill are needed, year-round, at multiple locations in Washington State, including the west side of San Juan Island. 

When a spill occurs in the Southern Residents’ critical habitat, and especially when the Southern Residents are known to be in the vicinity, the USCG should immediately authorize payment from the Oil Spill Liability Trust Fund for whale deterrence resources to be on standby, ready to implement deterrence operations as needed and authorized by NOAA. In the case of the ALEUTIAN ISLE oil spill, whale deterrence boats with equipment and personnel were on stand-by in Snug Harbor by August 15th. However, a means to compensate the whale deterrence vessel owners for their time and costs supporting the response wasn’t approved until August 31st. See Additional information about wildlife deterrence, below.

3. Resources for monitoring airborne hazards are also inadequate:

By the evening of the day the ALEUTIAN ISLE sank, the smell from the spilled diesel fuel was awful to the people living and vacationing near the spill; however, we don’t know if those fumes were affecting their health. At that time, not surprisingly for a Saturday night in August, San Juan County Park’s campground, which was close to the spill, was packed with campers and other visitors. Air-quality monitoring equipment didn’t get delivered to the island and installed until Monday, two days after the accident occurred. By that time, the monitors revealed enough dispersion of the fumes that the levels weren’t high enough to impact human health. But what about the impacts to all those campers and to the kayakers that launched at San Juan County Park over the weekend? San Juan County needs to have air-quality monitoring equipment and technicians at the ready for when an accident occurs. 

4. Require salvage response resources within certain timeframes when needed to address the threat of an oil spill:

When the ALEUTIAN ISLE sank, it reportedly had approximately 2,500 gallons of diesel, 60 gallons of hydraulic oil, and 20 gallons of engine oil on board. The threat of a spill of these oil products necessitated salvage response resources. We were fortunate that a larger oil spill did not occur. If salvage response resources are needed to prevent an oil spill, contingency plans should require these response resources to be on-scene within specific timeframes in order to prevent environmental, cultural, and economic damages.

Again, Friends of the San Juans appreciates and thanks everyone who responded to the sinking of the ALEUTIAN ISLE and resulting oil spill! As a community, we must take this opportunity to be grateful for the ultimate success of the response, and to also identify what additional resources are needed for next time. Oil spill risks are steadily increasing, and we need to be better prepared for any spill, small or big. We look forward to working with partners and decision-makers from local, state, and federal agencies and governments, and Tribes, to better protect the San Juan Islands and the Salish Sea.

Additional information about wildlife deterrence:

Wildlife deterrence operations rely on dedicated equipment and personnel that are trained and ready to respond when needed, and our state is overdue to implement the requirements for these resources. January 18, 2022 was the deadline for the 24-month phase-in requirements in WAC 173-182-540(2)(d) to have occurred:

Vessels and facilities that operate or transit in areas with the potential to impact whales, including Southern Resident killer whales, must have access to vessels of opportunity, equipment, and personnel to conduct monitoring, and deterrence operations to prevent whales from encountering spilled oil. 

Also, WSR 20-01-165 states, regarding WAC 173-182-540, Planning standards for wildlife response:

The planning standard establishes requirements for enhanced wildlife response capacity in the region through contracts, and investments in equipment and training of key personnel. The process for vetting and equipping vessels to conduct hazing of whales, including southern resident killer whales, will be further detailed in the rule implementation plan.  

In addition, the Department of Ecology’s April 2018 Curriculum Plan for a Killer Whale Deterrence Program documents the long-term lead-up to the 24-month phase-in requirements.

However, Ecology has only provided the Marine Mammal Monitoring and Deterrence Options webpage as a means for Oil Spill Contingency Plan (C-Plan) holders and/or Primary Response Contractors (PRCs) to comply with the 24-month phase-in requirements. This webpage lists the name, location, equipment and phone number for resources that could be used for marine mammal monitoring and deterrence. Importantly, the list implies that C-plan holders and/or PRCs could rely on wildlife response assets with contracts that do not include compensation, which is necessary to ensure that wildlife response providers have sustained capacity. The website also includes volunteer Vessels of Opportunity (VOO) which should not be relied upon to meet state mandates. The same resources listed on the Marine Mammal Monitoring and Deterrence Options webpage may also be identified/dedicated for spill response and/or other wildlife response requirements in ways that would exceed their actual capacity to cover multiple demands in the event of a spill.

Friends has many partners in advocating for improved wildlife response resources and especially those needed for whale deterrence operations: See the April 5, 2022, letter to Ecology.

Header Image: USCG Sector Puget Sound

It’s important to us that any organization we are involved with actually gets things done, and the work that the Friends takes on so capably really does make a difference.

Ken and Mariann Carrasco

members, Orcas Island