Terra Nova PROTECTED FROM SCRUTINY

Begin forwarded message:

From: "Abraham, Christine" <Christine.Abraham 'atsign' dfo-mpo.gc.ca>
Date: May 5, 2010 9:51:41 AM NDT
To: <iljones 'atsign' mun.ca>
Subject: Re: oil spill response in Canada

Good morning Ian,

I am closely following the oil spill in the Gulf of Mexico, and read the article in the Winnipeg Free Press containing your interview this morning. I have been trying to gather information regarding wildlife response to oil spills in Canada. So far, I've communicated with some folks at EC/CWS and others at DFO, but so far have not received the information I am looking for. In any case, I thought perhaps you might be able to lead me in the right direction.

I am already familiar with the CWS regional response plan basics; what I am after are the logistical details of spill response in Canada in terms of wildlfe operations. To provide some context and background, I was involved in oil spill response in California for many years prior to my return to Canada in 2008. The organization I worked for (Point Reyes Bird Observatory) has held an MOU with California Dept. of Fish and Game for more that 3 decades, and our responsibility was to provide scientific expertise in the asessment, and data and evidence collection, of dead and debilitated wildlife impacted by oil spills. These efforts are of course critical for modeling the actual impacts of a spill on wildlife populations, and therefore essential for any subsequent Natural Resource Damage Assessment. Through an additional contract with CDFG, I also co-managed a team of ~65 biologists throughout California, and provided annual team training regarding the state spill response protocols for data and evidence collection and also offered drill scenario training. Our team, called the Wildlife Processing Unit, is an integral component of the state of California's Incident Command System (see attached). I have responded, as co-coordinator of this group, to three significant spills in California since 2001 and also to the Prestige oil spill in Spain (at the request of Birdlife International) in 2002.

Now, as marine mammal science advisor at DFO, I have a keen personal and professional interest in all stakeholder roles in oil spill response in Canada. The CWS plan specifically identifies DFO as being responsible for providing advice regarding marine mammals to the "Lead Agency" (although there is no mention of fish or inverts in the plan). However, I am not familiar with any of the specific protocols for documenting the impacts of oil on dead and debilitated wildlife in Canada, including marine mammals. As outlined in the attached document, the state of California has extensive infrastructure and protocols (with trained personnel for all components) in place dealing specifically with all aspects of wildlife operations, and these are available publicly at http://www.dfg.ca.gov/ospr/report/wildlife_response_plan_6-30-2005.pdf and http://www.dfg.ca.gov/ospr/report/wlp_appendicies6-30-05_final.pdf. I would like to know if any of the regional plans in Canada have similar operational and data collection protocols for documenting the impacts of oil on dead and debilitated wildlife (and if they are available publicly), and if there is a similar spill response mechanism (e.g. the Incident Command System), and how each of the response agencies (and appropriate strike teams) fit in to this structure?

I was asked by senior management on Friday, what would DFO's role be, who are our contacts in place regarding wildlife response, and how would our Minister respond if there were a significant spill in Canada that threatened, for example, migrating belugas, or tuna, or the lobster fishery, or threatened cod stocks? I could not answer these questions. As a former (and always in my heart) seabird biologist, I am also personally interested in spill response as it pertains to seabirds. As you also may know, there are plans to begin drilling in Baffin Bay this summer, and as far as I know, we do not have any capacity to deal with potential spills in that region (although apparently Harper has said there will never be a spill in the Arctic because of our strict regulations, so clearly we shouldn't be at all concerned). In addition, there are now concerns of potential interactions between the oil spill in the Gulf of Mexico and the Canadian stock of bluefin tuna. Unfortunately, the timing couldn't be much worse, as the adult fish are in that area and spawning now. This is the only known spawning area for fish that support the Canadian fisheries, as shown by recent otolith microchemistry work.

As I said above, I have many years of experience and an intense personal and professional interest in oil spill response and would like to become involved and more familiar with spill-related wildlife operations in Canada. Any information you can provide to help guide me to someone with answers will be most appreciated.

Sincerely,
Christine

Christine Abraham
Marine Mammal Science Advisor / Conseillère scientifique
Fish Population Science / Science des populations de poissons
Fisheries and Oceans Canada / Pêches et Océans Canada
12S048-200 Kent Street / 12S048-200 rue Kent
Ottawa, Ontario, K1A 0E6
Tel: 613-990-0308/ Fax: 613 954-0807
Christine.Abraham 'atsign' dfo-mpo.gc.ca

From: Ian Jones [mailto:iljones 'atsign' mun.ca]
Sent: Wednesday, May 05, 2010 8:35 AM
To: Abraham, Christine
Cc: Greg [St. John's] Robertson; Sabina [St. John's] Wilhelm; Tony Diamond; Pierre [St. John's] Ryan; Grant [NCR] Gilchrist; Tony [NCR] Gaston; Mark [Iqa] Mallory; Doug [Sackville] Bliss; Richard [Sackville] Elliot; gfinney 'atsign' bsc-eoc.org; Mawhinney,Kim [St. John's]; Phil Taylor; Fifield,David [St. John's]; Thomas,Graham [St. John's]; Scott [St. John's] Gilliland
Subject: Fwd: oil spill response in Canada

Hi Christine,

Thanks for your correspondence. You pose several very important questions to which we urgently need answers. I would be happy to speak on the phone or meet with you to discuss these questions.

In the meantime, I think it would be useful for you to examine how CWS/EC has responded to past Newfoundland oil spills as that likely predicts how they would respond today and in the future.

Please study the following materials carefully and let me know if you have any questions:

my offshore oil web pages:

Terra Nova oil spill (Nov 21, 2004) http://www.mun.ca/serg/acwern/TerraNova.html

White Rose oil spill (Sept 8, 2008) http://www.mun.ca/serg/WhiteRose2.html

CBC Crosstalk (audio podcast, May 4, 2010) discussion of matters closely related to your questions.

http://podcast.cbc.ca/mp3/nlradionoon_20100503_31735.mp3

CBC interview (online video, April 30, 2010) discussion of matters closely related to your questions.

http://www.cbc.ca/video/#/News/Canada/NL/Web_Exclusive/ID=1482043151

Thanks for your interest and good luck to you.

Ian

Ian L. Jones

Professor
Department of Biology, Memorial University
St. John's, Newfoundland, A1B 3X9, CANADA

phone (709) 737-7666
fax (709) 737-3018
web: http://www.mun.ca/serg

From: "Abraham, Christine" <Christine.Abraham 'atsign' dfo-mpo.gc.ca>
Date: May 5, 2010 10:44:35 AM NDT
To: "Ian Jones" <iljones 'atsign' mun.ca>
Cc: "Greg [St. John's] Robertson" <Greg.Robertson 'atsign' EC.GC.CA>, "Sabina [St. John's] Wilhelm" <Sabina.Wilhelm 'atsign' EC.GC.CA>, "Tony Diamond" <diamond 'atsign' unb.ca>, "Pierre [St. John's] Ryan" <Pierre.Ryan 'atsign' EC.GC.CA>, "Grant [NCR] Gilchrist" <Grant.Gilchrist 'atsign' EC.GC.CA>, "Tony [NCR] Gaston" <Tony.Gaston 'atsign' EC.GC.CA>, "Mark [Iqa] Mallory" <Mark.Mallory 'atsign' EC.GC.CA>, "Doug [Sackville] Bliss" <Doug.Bliss 'atsign' EC.GC.CA>, "Richard [Sackville] Elliot" <richard.elliot 'atsign' EC.GC.CA>, <gfinney 'atsign' bsc-eoc.org>, "Mawhinney,Kim [St. John's]" <Kim.Mawhinney 'atsign' EC.GC.CA>, "Phil Taylor" <ptaylor 'atsign' resalliance.org>, "Fifield,David [St. John's]" <David.Fifield 'atsign' EC.GC.CA>, "Thomas,Graham [St. John's]" <Graham.Thomas 'atsign' EC.GC.CA>, "Scott [St. John's] Gilliland" <Scott.Gilliland 'atsign' EC.GC.CA>
Subject: RE: oil spill response in Canada

Thanks so much for your prompt reply, Ian. I will indeed review the information you provided and will let you know if I have any questions. Ultimately, I am really hoping to find a plan that is similar to what California has in place, including details (and I mean the real minutia) of all aspects of wildlife operations in spill response. I helped to write (and periodically revise) these protocols, and a review of just the table of contents in the California plan provides a sense of what the entire spill response community has contributed over the past few decades in terms of experience, preparedness, planning and forethought. This is arguably the the most complete and effective framework for oiled widlife response globally, and we should learn as much as we can from it.

Hopefully I will find what I'm looking for, but if not, perhaps we could all think about conducting a workshop to facilitate the development of specific regional plans and protocols. There is no need to reinvent the wheel here; several months ago I spoke with Mike Ziccardi, who is the Director of the Oiled Wildlife Care Network (OWCN; housed at UC Davis in California), regarding the possibilities of providing advice and guidance (Mike's credentials can be found at http://www.owcn.org/about-us/staff), and he was thrilled with the idea. He is, however, quite busy setting up wildlife operations in Louisiana at the moment.

Again, thank you for the information, and I'll let you know what I find out.
Cheers,
Christine

Christine Abraham
Marine Mammal Science Advisor / Conseillère scientifique
Fish Population Science / Science des populations de poissons
Fisheries and Oceans Canada / Pêches et Océans Canada
12S048-200 Kent Street / 12S048-200 rue Kent
Ottawa, Ontario, K1A 0E6
Tel: 613-990-0308/ Fax: 613 954-0807
Christine.Abraham 'atsign' dfo-mpo.gc.ca

From: Ian Jones <iljones 'atsign' mun.ca>
Date: May 6, 2010 10:40:52 AM NDT
To: "Abraham, Christine" <Christine.Abraham 'atsign' dfo-mpo.gc.ca>
Cc: "Greg [St. John's] Robertson" <Greg.Robertson 'atsign' EC.GC.CA>, "Sabina [St. John's] Wilhelm" <Sabina.Wilhelm 'atsign' EC.GC.CA>, Tony Diamond <diamond 'atsign' unb.ca>, "Pierre [St. John's] Ryan" <Pierre.Ryan 'atsign' ec.gc.ca>, "Grant [NCR] Gilchrist" <Grant.Gilchrist 'atsign' ec.gc.ca>, "Tony [NCR] Gaston" <Tony.Gaston 'atsign' EC.GC.CA>, "Mark [Iqa] Mallory" <Mark.Mallory 'atsign' ec.gc.ca>, "Doug [Sackville] Bliss" <Doug.Bliss 'atsign' EC.GC.CA>, "Richard [Sackville] Elliot" <richard.elliot 'atsign' ec.gc.ca>, gfinney 'atsign' bsc-eoc.org, "Bob [PYR] Elner" <Bob.Elner 'atsign' ec.gc.ca>, "Mawhinney,Kim [St. John's]" <Kim.Mawhinney 'atsign' EC.GC.CA>, Phil Taylor <ptaylor 'atsign' resalliance.org>, Bill Montevecchi <mont 'atsign' mun.ca>, David.Schneider 'atsign' mun.ca, "Fifield,David [St. John's]" <David.Fifield 'atsign' EC.GC.CA>, "Thomas,Graham [St. John's]" <Graham.Thomas 'atsign' EC.GC.CA>, "Scott [St. John's] Gilliland" <Scott.Gilliland 'atsign' EC.GC.CA>
Subject: EC/CWS's plan for oil spill response

Hi again Christine,

Here are my thoughts (briefly) on EC/CWS's plans for response to offshore oil spills in Newfoundland and Labrador, re seabirds.

Environment Canada's plan, as far as I can tell, is to collect seabird distribution data by haphazard sampling (observers on government and industry ships of opportunity) to build a large model of mean seabird density offshore for different times of year (e.g., see the attached map). When an offshore spill occurs, this model will be compared to remotely sensed data on spill trajectory, and effects (e.g., on seabirds) will be inferred from how the spill trajectory overlaps modeled mean seabird density. Environment Canada will produce a report, similar to the one produced after the Terra Nova spill, the estimates the number of seabird "put at risk" by the spill. The concept of "put at risk" has not been properly defined and has no confidence limits. No actual mortality estimate, with confidence limits, is planned and few or no appropriate direct measurements of mortality offshore is anticipated. The density model is interesting in relation to seabird ecology but will be of little to no use in assessing damage by an offshore oil spill, large of small. The reason is that the 'mean' density of birds in any location has little relevance when the hour to hour, day to day, and week to week variation in bird numbers is extremely high. In other words, the number of birds at a particular spot, even in a rich area near the rigs/shelf break, could be in the tens, hundreds, thousands, or more, or less, depending on the day - we simply wouldn't know how many birds interacted with the spill by this method.

To quote David Schneider:
"Monitoring prior to a blowout is an expensive fool's errand (type I error). Which may explain the lack of response to your requests for a protocol. The only thing you will get from counts before and after a blowout is that a well-paid statistician will force you to accept the null hypothesis, no change in average (because of hyper variance of counts at sea). And even if the before vs after was significant, a competent statistician could nullify you on the CI (control impact) side."

Therefore, I believe Environment Canada's current plan to estimate damage to seabirds by offshore oil spills off Newfoundland is poorly thought out, statistically indefensible, and will be basically useless in achieving its intended ends.

A rigorous response to an oil spill (in relation to quantifying damage to seabirds) would involve, at a minimum:

1) Presence of independent trained biologist seabird observers on the rig to begin observations immediately when a spill occurs (only useful during the actual release of oil, not afterwards).

2) Immediate presence of independent trained biologist seabird observers on dedicated ship(s) at the spill scene within hours of the spill. These vessels would follow the oil as it drifts away from the rig, until the oil was sufficiently dispersed to be no further danger to wildlife. These observers would (among other things) measure seabird density in and near the oil slick, observe birds going in to the oil, observe and collect carcasses, and collect drift blocks released from the rig and at sea in the oil to quantify mortality. One vessel with a team of observers could probably handle a small spill (e.g., White Rose, Sept 8, 2008). For a larger spill two or more vessels and teams would be required. This would produce an actual mortality estimate with confidence limits.

This (not Environment Canada's plan) would be the only way to estimate damage to seabirds by offshore oil spills off Newfoundland. This would apply equally to Marine Mammals that are the concern of DFO. These points were made by me and others to Environment Canada after the Terra Nova oil spill in 2004. For political reasons, Environment Canada has not followed outside expert advise, and no effective means is in place to quantify damage.

It would be acceptable to me if Environment Canada simply publicly acknowledged that it is currently neither prepared or able to properly quantify damage to seabirds by offshore oil spills off Newfoundland. However, I would again offer to work with you and with Environment Canada to produce a rigorous, defendable, quantitative plan for offshore response that would produce the numbers we urgently need (and in fact that Canadian laws require) to assess environmental impact. Alternatively, we can work with the independent inquiry into spill response in Newfoundland, that Danny Williams is suggesting will occur soon. Or we can take our concerns directly to the public via the media if all else fails.

Let me know if you have any questions of comments on the above.

Sincerely,

Ian

Ian L. Jones

Professor
Department of Biology, Memorial University
St. John's, Newfoundland, A1B 3X9, CANADA

phone (709) 737-7666
fax (709) 737-3018
web: http://www.mun.ca/serg

From: "Abraham, Christine" <Christine.Abraham 'atsign' dfo-mpo.gc.ca>
Date: May 5, 2010 10:54:14 AM NDT
To: "Ian Jones" <iljones 'atsign' mun.ca>
Subject: RE: response in Canada

Thanks Ian...I am getting the feeling that I am being ignored by EC/CWS, although I'm not sure if it's my premature paranoia or their fear of not being able to answer the questions.

Cheers,
Chistine