Public Review of the

Federal Moratorium on
Oil and Gas Activities
Offshore BC

Assessing Risk
and the
Precautionary
Approach
Victoria
May 14, 2004

Jeff Ardron
Marine Analyst
Living Oceans Society
What is an Environmental Risk Assessment?
The Risk Management Assessment Process
•Resource assessment (current human and ecosystem health)
•Societal values assessment
•Hazard assessment
•Dose/physical change-response assessment
•Exposure response assessment
•Prevention and control cost assessment
•Benefit valuation assessment
•Risk, cost and benefits characterization (including marginal or incremental
benefits-
•Presentation of analytical results, uncertainties, and implicit social and
professional
•cost comparison of risk management alternatives
•values and biases

Schnare, d. 1996. Risk and Rationality in Decision Making: exposing the underlying
values used when confronted by analytical uncertainties. Chapter 16, In; Cothern, C.R.
(ed.), Handbook for Environmental Risk Decision Making; Values, Perceptions and
Ethics. CRC Press.
Three Steps to Decision-Making
Risk Assessment
1. How Safe Is It?
Scientific & Technical Models / Expertise

Public Debate
2. Is That Safe Enough?
Policy Development

Precautionary Principle
3. Are We Overlooking Something?
Directed Research /
Moratoria

Freudenburg, W.R. 1996. Strange chemistry: Environmental risk conflicts in a world of

science, values and blind spots. Chapter 2 In:  Cothern, C.R. (ed.), Handbook for
Environmental Risk Decision Making; Values, Perceptions and Ethics. CRC
Press.
How Safe Is It?
There are inherent human biases in perceptions of risk…

• White males consistently rate risks as more acceptable

than either white females or members of minority groups.
Flynn, J., P. Slovic and C.K. Mertz. “Gender, Race, and Perception of Environmental Health
Risks”, Risk Analysis 14:llOl-1108.

• “It won’t happen to me…” Most of us under-rate the risk

of everyday activities, such as car accidents.
Newcomb, M.D. “Nuclear Attitudes and Reactions: Associations with Depression, Drug Use
and Quality of Life,” J. Pers. SOC. Psychol. 50:906-20 (1986).
How Safe Is It? …cont’d
Underestimation of risk is a pervasive characteristic in
“risky” occupations…

Parachute jumping…

Epstein, S. and W.D. Fenz. “The Detection

of Areas of Emotional Stress through
Variations in Perceptual Threshold and
Physiological Arousal,” J. Exp. Res.
Personality 2:191-99 (1967).

High Steel Work…

Haas, J. “Binging: Educational Control among High

Steel Ironworkers,” Am. Behav. Sci. 16:27-34 (1972).

Haas, J. “Learning Real Feelings: A Study of High Steel

Ironworkers’ Reactions to Fear and Danger,” SOC.
Work Occupations 4: 147-72 (1977).
How Safe Is It? …cont’d
Underestimation of risk is a pervasive characteristic in “risky”
occupations …cont’d
Coal Mining…

Fitzpatrick, J.S. “Adapting to Danger: A Participant

Observation Study of an Underground Mine,” SOC.
Work Occupations 7:13 1-80 (1980).

Lucas, Rex A. Men in Crisis: A Study of a Mine

Disaster (New York: Basic,1969).

Fishing…

Tunstall, J. The Fishermen (London: MacGibbon &

Lee, 1962).
How Safe Is It? …cont’d
Underestimation of risk is a pervasive characteristic in “risky”
occupations …cont’d
Offshore Oil & Gas…
Heimer, C. “Social Structure, Psychology and
the Estimation of Risk,” Ann. Rev. Sociol.
Offshore Production -
14:491-519 (1988).
NASA of the Sea
“Offshore Drilling Technology - The offshore oil and gas Source: Anadarko Petroleum
Corporation
production sector is sometimes referred to as 'NASA of the Sea',
due to the monumental achievements in deepwater drilling that Challenger Space
have been facilitated by state of the art technology. Natural gas and Shuttle Disaster:
oil deposits are being found at locations that are deeper and deeper loss of 7 lives,
underwater. Whereas offshore drilling operations used to be some January 28, 1986.
of the most risky and dangerous undertakings, new technology,
including improved offshore drilling rigs, dynamic positioning
Has it been
devices and sophisticated navigation systems are allowing safe, forgotten already?
efficient offshore drilling in waters more than 10,000 feet deep. To
learn more about offshore drilling, click here.” http://www.naturalgas
.org/environment/technology.asp
How Safe Is It? …cont’d
Underestimation of risk is a pervasive characteristic in “risky”
occupations …cont’d
Offshore Oil & Gas…
Khafji Rig Disaster, Oct. 2002
Aramco said the rig fell over during the first weekend
of October 2002. The accident occurred in the Neutral
Zone between Saudi Arabia and Kuwait, the rig was
one of the offshore platforms that Aramco took back
from the Japanese. It fell on the platform it was
working on and damaged the wellheads, which are
leaking oil, gas, and H2S. Three people were killed, one
decapitated. Aramco is now trying to figure out how to
repair the platform.

Photo's provided by Thomas Brinsko with Bic Alliance

Magazine

http://www.ocsbbs.com/Khafji_%20Rig_Disaster.asp
Surprises Happen…

• It is common to find a “surprise index” on the order of 20% - 40%

Lichtenstein, S., B. Fischhoff and L.D. Phillips. “Calibration of Probabilities: The State of the Art to
1980,” in D. Kahneman, P. Slovic and A. Tversky, Eds., Judgment under Uncertainty: Heuristics
and Biases (New York: Cambridge University Press, 1982), pp. 306-333.

Fischhoff, B., P. Slovic and S. Lichtenstein. “Knowing with Certainty: The Appropriateness of Extreme
Confidence,” J. Exp. Psychol. 3552-64 (1977).

Freudenburg, W.R. “Nothing Recedes Like Success? Risk Analysis and the Organizational Amplification
of Risks,” Risk 3: 1-35 (1992).
Accounting for the Unexpected
“Where uncertainties are defined, the probability density of low
frequency events is routinely under-estimated. In other words,
infrequent events are far more frequent than we model them to be.
Functionally this invalidates using log-normal distributions
favouring heavy-side and other functions than can be specified with
“thicker tails” 3.2
“Figure (Shlyakhter
showsand Kammen 1992)
a horizontal ” indicating various levels
scale
of risk, enumerating only one of the aspects of
~Submission to the Royal Society Expert Panel, Nov. 13, 2003
risk, the probability of occurrence. In this a “log” scale has
Dr. Hadi been added, in which the probability is the
Dowlatabadi,
Canada Research Chair, in Applied Mathematics, Integrated Assessment
Exponent…”
and Global Change
University Fellow, Resources for the Future, Washington DC.
Adjunct Professor, Dept. of Engineering & Public Policy, Carnegie
~Section 3.3, Risk Assessment, Report of the Expert Panel on Science Issues Related to Oil
Mellon University, Pittsburgh, PA.
and Gas Activities, Offshore BC, 2004.
Shlyakhter, A. I. and D. M. Kammen (1992). "Sea-level Rise or Fall." Nature 357(6373): 25.
The Poetry of D.H. Rumsfeld
The Unknown
As we know,
There are known knowns.
There are things we know we know.
We also know
There are known unknowns.
That is to say
We know there are some things
We do not know.
But there are also unknown unknowns,
The ones we don't know
We don't know.
—Feb. 12, 2002, Department of Defense news briefing
Recent works by the secretary of defense.
By Hart Seely
http://slate.msn.com/id/2081042/#ContinueArticle
What We Know We
Know & What We
Know We Don’t
Know…
There are over 6,500 known
spp of invertebrates, 400 spp of
fish, 161 spp of birds, & 29 spp
of marine mammals in BC…

Total: 7,087
Less what we (sort of)
know, say three or
four dozen…
7,087 – 48 = 7039
0.07% Governments of Canada and BC, 1998.
Marine Protected Areas: A Strategy for Canada’s Pacific Coast. Discussion Paper.
What We Know We Don’t Know …cont’d
• Spatial pelagic biological data are almost non-existent
• Offshore biological data are weak or non-existent
• Non-commercial spp largely unknown (e.g. sand lance)
• Many older datasets remain in non-digital & non-spatial
formats
• Bird surveys dated; foraging largely unknown
• Eelgrass poorly surveyed in most areas
• Local knowledge largely uncollected
• Fishing Use only partially understood (spatially) for most
fisheries

• Regionally: QC Sound remains largely unstudied, very poor;

N Central Coast also very poor; N. Coast poor; QCI fair.
But, we do know…

“Drifter studies show evidence of eddies that retain water

(and by extension, oil spills) in the basin…”

~Executive Summary, Report of the Expert Panel on Science Issues Related to Oil and Gas
Activities, Offshore BC, 2004.

Dr. William Crawford, Institude of Ocean Sciences, Sydney BC

http://www-sci.pac.dfo-mpo.gc.ca/osap/projects/QCI/qci_e.htm
Actually, this is
Inshore Oil &
Gas…

Distance from Shore

0 Km
50 Km

100 Km
150 Km

200 Km
250 Km
 BC Coast Information
Team (CIT)
Marine Analysis

Model Results

 Yellow: Places almost always

chosen.
 Pink: Areas chosen about ½ the
time.
 Blue: Areas can be considered
useful in only some reserve
networks.
 93 data layers

6 different size targets

x 4 levels clumping
x 100 runs each
= 2,400 solutions
Summary So Far…
•We don’t know much at all about the biology or ecology

•But, we do know that a lot of species live in and migrate through

the region, and it contains many ecological values

•And, we do know that the currents tend to circulate such that oil
spills anywhere in the QCB would almost certainly end up on
shore

•And, we do know that weather forcasters cannot give sufficient (6

hr) warning of extreme events (s. 4.1.2 Report of the Expert Panel on Science Issues
Related to Oil and Gas Activities, Offshore BC, 2004.)
California to Maintain Moratorium
So, why would we lift the moratorium?
Precautionary Approach
“In order to protect the environment the
precautionary approach shall be widely applied by
states according to their capabilities…”

 ~The Rio Declaration on Environment and

Development, 1992 (emphasis added)

30. The national strategy will be based on the

principles of…

(c) the precautionary approach, that is, erring on the

side of caution.
 
~Canada’s Oceans Act, 1996. (emphasis added)
Donald’s Definition

…But there are also unknown unknowns,

The ones we don't know
We don't know.

Don’s Stated Position

“I will fight to have the oil and gas moratorium lifted which
will create jobs."

Mr. Don Scott, current member of the Federal Offshore Oil & Gas Public
Review Panel. Mayoralty campaign advertisement, The Daily News,
Prince Rupert. Oct. 18, 1999.
The Most Commonly Accepted Definition…
"We believe existing environmental regulations and other decisions,
particularly those based on risk assessment, have failed to protect
adequately human health and the environment…
"While we realize that human activities may involve hazards, people
must proceed more carefully than has been the case in recent
history...
“…In this context the proponent of an activity, rather than the
public, should bear the burden of proof.
 
“…The process of applying the Precautionary Principle must be
open, informed and democratic and must include potentially affected
parties. It must also involve an examination of the full range of
alternatives, including no action.”
~the Wingspread Statement on the Precautionary Principle, Jan. 1998. (emphasis
added) Also in Appendix 4 of Report of the Expert Panel on Science Issues
Related to Oil and Gas Activities, Offshore British Columbia, 2004. (Emphasis
added)
The Expert Science Panel’s Definition…
“…in the face of scientific uncertainty, it is preferable to err on the
side of caution. It is also noted here that the absence of full
scientific certainty shall not be used as a reason to postpone
decision-making.”

“…We reiterate that the precautionary principle does not require

absolute verification of safety. In any human activity there are risks
and such a requirement would halt all technological development.
The obligation is rather to demonstrate that a reasonable and
acceptable level of risk has been attained.”

~ Report of the Expert Panel on Science Issues Related to Oil and Gas Activities, Offshore British
Columbia, 2004. Ch 3; pp 31-32. (Emphasis added.)

Is the Precautionary Principle really the same thing as a Risk

Assessment?
Conclusions
1. Risk assessment is not the same thing as the precautionary approach.
Rather, they are two sides of the same coin, and both should be applied.
To date, we have only seen a (preliminary) risk assessment approach.
2. The precautionary approach dictates that areas of no or little data should
be treated as de facto exclusion zones.
3. Since we have little data for most of the region, it should be treated as an
exclusion zone; i.e. the moratorium should be maintained.
4. The question should not be where activities might be excluded. Rather,
given the present uncertainties, is there any place where the data will
allow us to fully assess the risks? (Not yet…)
5. Even if there were exclusion zones (marine protected areas), our coasts
and biota would remain vulnerable to many of the most serious risks
associated with offshore oil.
6. Being “reasonable” sometimes requires great humility and the realization
that no, we should not do this, alluring though it may be…
More Information…

Main Map Gallery

www.LivingOceans.org/map_gallery.htm

Offshore Oil & Gas Map Gallery

www.LivingOceans.org/oog_maps.htm

CIT Report (marine and terrestrial)

Rumsey, C., Ardron, J., Ciruna, K., Curtis, T., Doyle, F., Ferdana, Z., Hamilton, T.,
Heinemyer, K., Iachetti, P., Jeo, R., Kaiser, G., Narver, D., Noss, R., Sizemore, D., Tautz,
A., Tingey, R., Vance-Borland, K. 2003. An ecosystem analysis for Haida Gwaii, Central
Coast, and North Coast British Columbia. Coast Information Team.