The ESG has learnt of a quayside LNG bunkering transaction that recently took place in Gibraltar from an announcement on Facebook by the previous Minister of the Port. Subsequent enquiries with the Ministry for the Environment confirm that a cruise ship, the Silver Nova, did receive LNG bunker from a barge, at quayside, on her inaugural call to Gibraltar.

The ESG has publicly voiced its strong concerns in the past over the potential for growth of LNG activity at port side from the LNG Storage facility and sought information from the authorities on this announcement.

The group was provided with safety assessment reports commissioned by the Port produced some years ago for such transactions and licensing, as well as a separate detailed report for this specific vessel and date. It appears that a barge supplied the fuel but this needs further clarification.

While it’s clear that safety assessments were carried out this new step has not been processed before DPC, or, to our knowledge, had cross-departmental oversight. Industrial activities do not operate in a bubble and require all impacts concerning public health and the environment to be closely studied with the public informed.

The ESG understands that LNG reduces pollution and believes it has a role to play on the path towards fully renewable and sustainable shipping fuels.

The group strongly urges Government to review this new activity and ensure that full provision of information for intended LNG transactions of this nature go through public process and due protocols before any further transactions are carried out. 

The ESG notes that Shell has been awarded an LNG bunker licence for ship-to-ship operations in Gibraltar. 

It also realises that the Gibraltar Government has always maintained its support for this and for Shells interest in pursuing this course of action.

The group has from the start of Shells presence in Gibraltar advocated highest standards and transparency from the company, and sought the same assurances from the Gibraltar Government believing the safety of the community to be of paramount importance. While it understands that burning LNG as opposed to Diesel will have environmental benefits it does not eliminate Greenhouse Gas emissions or air pollution altogether. Until such time as LNG totally replaces Diesel there will be an increase in pollution arising from this new licence.

With Shell describing Gibraltar as one of the busiest ports in Europe it follows that from a climate change perspective this activity should be fully accounted for, including on its overall carbon impacts today, and for the next 10 and 20 years of the Climate Emergency. At present these are not recorded within City Emissions for action but as ‘Other emissions’.

The group also asks where the supply of LNG will come from for the servicing of ships and tankers entering our Port? It also expresses concern that under normal circumstances our western anchorage points are extremely busy. This means that there will be even more ships being bunkered around our coastline, at least until LNG replaces Diesel as the fuel of choice in the Global Maritime World.

The ESG will be taking up all these concerns directly with the Port and the Environmental authorities.

ESG on recent Government and Port Statements on LNG

 The ESG has been hearing announcements in the local media about LNG developments in Gibraltar. While not surprised that Government is introducing legislation and talking about Gibraltar as an LNG hub, it is a serious concern to the group that even before operations have started at the new Power Station and new LNG Storage Plant, we are now being told the Port is gearing up to allow barge refuelling of LNG from this site also, despite Government assurances repeatedly given that this facility would only service the Power Station.

Given the intensive year-long assessment made by the HSE and an EIA produced solely on the basis of the storage facility servicing the Power Station, the ESG cannot understand how the Port is already discussing the very real possibility of using this land based storage facility as a future barge refuelling point.

Additionally the Port has described LNG barge refuelling as pretty much the same as with any other fuel. The ESG refutes this entirely having read and understood the intricate protocols and safety measures that must be applied whenever an LNG shipment to the storage facility takes place, which, according to Power Station needs, would be twice monthly, at night, and under strict controls and conditions.

Any change to existing plans must follow an equally rigorous assessment and Government must explain its departure from its original thinking on what this facility was originally designed for and what the public was assured would happen at this site.

The group plans to follow up on these issues with the relevant departments’.

ESG Press Release re LNG and Clarification sought 20th November 2015

The ESG would like to voice its view following a number of consultations held with Government and its agencies on the proposed LNG Storage for the new power station.

Naturally we welcomed the opportunity of meeting HSL and Shell and being able to directly place our key concerns and questions to them.

Some of our issues were allayed – some not. Arising from those meetings, and in the knowledge that additional hard facts and information will emerge from the many reports, assessments and EIA coming up, the ESG is taking the opportunity offered to ask Shell a number of unanswered questions which we believe need clarification in what is Gibraltar’s largest project today.

The questions which we are asking directly to Shell at this juncture are based on: making available previously requested documentation; for worst case scenarios to be technically explained and resourced; and for all alternative or potentially alternative sites to the North Mole for LNG storage to be presented including risk evaluation, costings, designs and explanations on decision given.

All this is especially pertinent given an unexpected development this week when Mr. Joe Bossano stated clearly that Shell’s only interest in supplying LNG for the power station is the bunkering business it will facilitate – something that has been consistently denied when raised by the ESG. Also very worrying to us is the declaration that the storage tanks at the North Mole could be servicing the bunkering requirements, with the necessary increase in the re-fuelling frequency this will represent. This has again been categorically denied at the highest level in Government when raised by the ESG in recent meetings. The ESG therefore calls for urgent clarification on these comments.”

10th January 2014

ESG is very concerned with the bunker storage tanker (Floating fuel station) being brought into the harbour with the immediate safety implications this entails. Concerns include the potential for major oil spill, fire, explosion in an area in close proximity to Shell storage tanks, the berths of military vessels and nuclear submarines, and that will also see the natural gas storage for the new power station.

The group believes there will be a probable increase of small oil spills on connecting and disconnecting fuel lines within the harbour in an enclosed area where some of our desalination plant intakes are located, leading to the deterioration of our harbour waters.

“There will be an inevitable increase in nauseating smells from bunker fumes as a result of the air displacement of fuel tanks in the tanker as well as the bunkering barges as these are filled and emptied leading to a deterioration of our air quality standards and to the quality of life of Gibraltar residents,” said a spokesperson.

The ESG has always advocated on-shore bunkering but this is not it. This is the worst of all scenarios where the bunkering industry is not brought onshore but the ship-to-ship oil transfers are brought port side within the harbour area.

The group believes that the concept of expanding the detached mole to create a bunkering fuel storage tank farm is the wrong one for Gibraltar. Once the visual impact of this is realised by the Gibraltarians, (it will look as if the refinery has been brought to the detached mole), and the emissions and risks associated with this are understood, it will not be welcomed. Gibraltar saw the effects of an explosion of a relatively small storage tank when the Nature storage tank exploded and how the local capabilities to control this were severely stretched. This makes a fuel storage tank farm of such a massive capacity at the detached mole simply not good for Gibraltar.

An option the ESG has always advocated is the complete dismantling of the old Kings Lines fuel storage area within the Rock and its external infrastructure, and for this to be rebuilt using the latest best available technology. This new storage facility would then be connected by new underground piping to the fuel connection points with proper on shore vapour recovery systems and for the connections to be within spill control bunding enclosures at the detached mole. There would then be no visual impact for the fuel storage in a much safer location within the Rock and no added visual impact at the detached mole, and no need for reclamation as there would only be fuel connection points there for the refuelling of the bunker barges.

If the fuel storage tanks necessary for the fuelling of the Royal Navy could be safely done within the Rock in the 1940’s there is really no reason to believe it could not be done in a much better and safer way today also within the Rock. Any new arrangement and infrastructure would be self-financed in what is a very profitable industry.

The ESG has followed the impact and practice of bunkering in Gibraltar for a considerable time and hopes that serious consideration will be given to all available alternatives that exist to bring fuel supply ashore in the safest and least environmentally impacting way, with quality of life safeguarded and public consultation exercised.

Check out ESG interview on GBC at:- http://www.youtube.com/watch?v=cnZgu9APZ9E

News that all political parties will NOT allow bunkering on the East Side of the Rock is met with delight by all the groups who campaigned duriing 2011 for this decision. Brief reaction below:

“The Coalition against Bunkering on the East Side, made up of the undersigned which includes Associations, NGO’s and businesses are delighted with the announcement made today by all political parties that they will not allow Bunkering activity on the East Side of Gibraltar to go ahead.
This is great news.
A fuller statement will be issued over the next few days.”

The groups involved in the Campaign are: GONHS, ESG, Gibraltar Federation of Sea Anglers, Gibraltar Sub Aqua Club, Caleta Hotel, Both Worlds Retirement Committee and Both Worlds Resident Committee”.

BOTH WORLDS (RETIREMENT) MANAGEMENT COMPANY LIMITED
22 May 2011

PROPOSED EAST SIDE BUNKERING

1. We applaud all initiatives which contribute to the prosperity of Gibraltar but believe that short term developments must be viewed not only in terms of commercial gain but also in terms of long term expense:
1.1. To the environment
1.2. To the people who live in the vicinity
1.3. To all the people of Gibraltar

2. We are concerned that no environmental impact study has been undertaken. An in-depth study should be undertaken and the results made public.

3. We are concerned that the number of vessels anchoring on the East Side will increase and will destroy the natural seabed environment with loss of flora and fauna.

4. We are concerned that there is a very real risk of a major oil spill which could ruin our beach and the adjacent coastline for years to come. This area is of prime recreational value for the whole Gibraltar community and must not be exposed to these dangers.

5. We are concerned that minor oil spills will accumulate and in the end be just as destructive as one major spill.

6. We are concerned that an additional number of vessels will also produce vastly more quantities of sulphur in our air as ships’ fuel is renowned to be of low quality and thus produces excessive atmospheric pollution.

7. We are concerned that the proposal will expose us to pungent odours when the wind direction is from south to south westerly.

8. We are concerned that the increased air pollution will effect the residents of our retirement home. Older people, like young children, are very susceptible to asthma, allergic reactions and bronchial infections.

9. We are concerned that there is no comprehensive long-term strategic plan for the development of Gibraltar in general and for the East Side in particular.

Patricia Hayward – Director Roy Smith – Director

24th May 2011

To Whom It May Concern

Re : Eastside
After being briefed by the company that was appointed to carry out an environmental
impact study on the possibility of east side bunkering and after having considered the
consequences of this activity, at the Caleta Hotel we can only be against any kind of
bunkering.

Bunkering is totally against the nature of our industry and certainly not an environmentally
friendly activity. The consequences of such activity will result in water pollution, noise
pollution and smells. This is totally detrimental to our business and will spoil forever the
only unpolluted coast left in Gibraltar.

While we can understand and appreciate the commercial opportunities that such activities
might bring to Gibraltar PLC,it is totally detrimental to the environment and our industry. It
will jeopardise any future tourism development in Gibraltar and affect the residential areas
enormously.

The hotel will vigorously oppose such activity.

Franco Ostuni
General Manager
P.O. Box 73, Catalan Bay, Gibraltar • T: (350) 20076501 • F: (350) 20042143 (Reservations). E: reservations@caletahotel.gi
E: sales@caletahotel.gi • www.caletahotel.com

Gibraltar Sub-Aqua Club
BSAC 888
Parson’s Lodge
Rosia Road
Gibraltar

Date: 27th May 2011 Re: East Side Marine Bunkering

The GSAC is opposed to the expansion of marine bunkering activities to the east side for the following reasons:

1. Anchor and chain damage. Every time an anchor is dropped onto a reef or other underwater formation, it damages these structures by breaking pieces away, eventually demolishing them to nothing.

The ship at anchor releases a length of chain which is approximately 3 times the depth of the water at that point. Once there is a change of tide the chain scrapes a radius along the bottom, destroying and removing all marine life on the bottom and that attached to any formations.
Eg: the kelp forest at ‘el lomo’ (a popular dive site on the East side) has been depleted to almost zero because of this. Removal of kelp results in a loss of sheltered habitat for immature marine creatures and the loss of a critical breeding ground. This loss leads to lesser fish stocks in the area and also less biodiversity. Although not an environmental consideration, there is a reduced fish stock for local fishermen.

The chain and anchor damage also destroys fish egg deposit grounds, in particular the cephalopod (molluscs) family and species of dogfish. Hence population recovery takes even longer.

The removal and cleaning up of reefs also reduces entanglements otherwise experienced by Spanish trawler fishermen, thus further creating an incentive for netting and the destruction and capture of the few remaining marine life.

All scallops and other shellfish living above the surface of the sand are also damaged and destroyed by the chain action.

The amount of anchoring now is already excessive and if one considers the total surface area which the radius of a 100m chain can describe at it moves, then even if there is just a small increase in anchoring, the reefs will soon be depleted to levels which can only lead to a recession of life with no chance of ever regenerating.

2. Oil spillages in the top part of the watch column will undoubtedly affect spawning success rates as many eggs/sperm will be contaminated.

Local fish stocks depend on surface migratory crabs and small fish to feed on. These always travel on the surface. They will die from feeding on contaminated particles and/or subsequently contaminating the fish that eat them.

If in the event of an oil spill, dispersants are used, the globules formed will sink in the water column and over the years will destroy the reefs and kill filter feeders (ie. shellfish) in the sandy areas outside the reefs. In effect it destroys reef and non-reef sandy area marine life.

Marine life in the coastal water column is destroyed by the continuous deposits of oil slicks – no matter how small these are.

Oil is many times observed on the seabed by divers. This oil takes the form of balls ranging in size from a tennis ball to a handball. This no doubt kills sensitive plant life and corals besides being a disgusting eyesore.

Surface oil and other contaminant slicks damage expensive diving equipment and present a hazard to the diver. We can presume that these slicks are also hazardous to bathers.

Oils are harmful to passing cetaceans.

3. Every time a vessel anchors, rubbish is dumped overboard. As divers we encounter this at the bottom quite frequently.

4. Bay waters are often out of bounds for divers because of heavy maritime traffic, and we prefer the East side. Increased traffic here is clearly a hazard to submerged and decompressing divers.

Conclusion:

The social marginal utility gained from this increase in commerce is clearly outweighed by the social marginal disutility brought on by the environmental risk exposure. At what social and environmental cost will this relatively small % increase in GDP be enjoyed?
£ is not the scarce resource – our waters, marine life and coastline are.

Chris Riddell
Chairman

Vinod Khiani
Vice-chairman

GIBRALTAR FEDERATION OF SEA ANGLERS

GFSA is totally opposed to bunkering because of its detrimental and destructive effects on marine life and the marine environment. However it recognises that this activity currently takes place in Bay of Gibraltar. Whilst it would prefer that the activity does not take place at all the reality is that it exists. In this context GFSA supports the ESG’s attempts to try and bring this activity under more robust regulation and control to ensure that there are no negative impacts on the environment. This week there was another incident reported when a Chinese owned ship that had taken bunkers in the Bay had a small collision with one of the floating fuel petrol stations anchored in the Bay.

This is a stark reminder that without proper controls there is the potential for a very big incident to happen in Gibraltar waters. The marine environment and the seabed around our small coast line will not sustain such an accident.

To extend bunkering to the East Side is totally opposed by the Federation. This contravenes totally the environmental stance of GFSA . To extend this activity is not be compatible with the Government’s designation of the Southern Waters of Gibraltar as a marine reserve. GFSA does not understand how the Government can make a case for it given this designation.

Enough harm has already been done in the Bay and any attempt to extend this to the East Side will be opposed vigorously. GFSA does not agree with the continuing destruction of reefs and the sea bed caused by the use of anchors and anchor chains and calls for all the introduction of fixed anchorages. Not only will these put a stop to the destruction of reefs but they will promote and create new habitats where marine life can develop and thrive.

There has been a sharp increase in the number of spillages and other accidents in the Bay and off Europa Point in recent years that have polluted the seas surrounding Gibraltar. If bunkering takes place on the East side the risks will increase and with it the chances of causing irreversible damage to the marine environment. GFSA does not want a repeat of these incidents.

GFSA is totally opposed to East Side bunkering.