BOTH WORLDS MANAGEMENT LIMITED
22nd May 2011

Proposed East Side Bunkering Project

The directors of BWML resolved to “object strongly” to the proposed expansion of Bunkering to the East side of the Rock at our meeting held on the 12th. October 2010. The main thrust of the resolution was to support and participate in any disciplined joint action by responsible groups of like-minded East Side stakeholders.

Our first and foremost concern is for the HEALTH & SAFETY of Both Worlds residents, visitors and contractors, the issues as we see them are:-

Fumes from the Bunkering process being trapped within Sandy Bay and thereby posing a direct threat to health.

Noise pollution accompanying the increase of large ships anchoring off the East side and the Bunkering process itself.

Light pollution particularly on winter mornings & evenings and should Bunkering be increased to a 24 hour service as in the Bay of Gibraltar.

The possibility of East side beaches becoming contaminated following an oil spill as containment equipment would take some time to deploy.
Weather and Sea conditions change considerably & quickly on the East side of the Rock, sometimes with disastrous results, Bunkering activities could potentially increase the prospect of large ships coming to grief, jeopardizing both lives and the Summer recreational beaches of Gibraltar.

Secondary concerns are those of lifestyle as we enjoy an enviable position on the East side:-

The open sea views are in stark contrast to the “Bunkering Factory” of the Bay of Gibraltar

The bathing season and the opportunity to enjoy the beaches and sea in a relatively unpolluted environment

The incredible sightings of dolphins & whales making their way to & from the Straits of Gibraltar

BWML understands and sympathizes with the Ecological issues the prospect of East side Bunkering could inflict and would like to record our support for those concerned with the Environment, Fishing & Diving on the East side of the Rock
BWML

ESG Opposed to East Side Bunkering 27th May 2011

In October 2010, the ESG, along with several other stakeholders, were consulted by EIA scientists1 commissioned by the Port of Gibraltar on behalf of Govt, to hear concerns over the proposed expansion of bunkering activity to the East Side of Gibraltar. The ESG has publicly campaigned for GoG to address existing environmental and health concerns from existing bunkering activity on the western flank of the Rock and therefore sees further expansion as a totally backward step – One that we shall campaign against as we have done on other issues that threaten our health and living environment2. Specifically our key concerns are summarised as follows-

 ESG very concerned that both the Port and GoG have already stated support for east Side Bunkering, even stating the conditions under which this will take place, BEFORE an EIA has even been completed!

 ESG receives reports/complaints throughout the year and especially during warmer months from residents complaining about the intolerable level of fumes in their neighbourhood linked to bunkering activity (wind direction and increased volatility of fuel vapours). Given the 24hr nature of the bunkering activity this problem affects people also on a 24hr basis;

 Existing bunkering activity already affects people’s quality of life, air quality and marine environment; new activity on the East Side will increase this air pollution locally as we shall get the fumes no matter the wind direction;

 ESG has long campaigned for improvements to the Ports “reporting protocol/procedure” as this continues to be inadequate to follow up and investigate sources of pollution from bunkering activity. (New number to call 56001652 – IMPORTANT – Call during the polluting episode);

 ESG has lobbied both the Port and Ministry for vapour recovery technology to be applied to bunkering to stop fugitive fumes from affecting our community;

 ESG has campaigned locally and at cross border level for port co-operation, improved tracking technology and monitoring and for limits to be imposed in our ever increasingly congested Bay;

 ESG and GONHS form part of a cross border NGO group which lobbies the Tripartite Forum on regional environmental issues which includes bunkering activity in Gibraltar (from floating mother ships etc.)

 VTS technology (vessel tracking systems) was installed at the Port to prevent further collisions at sea which were on the increase off the Rock and was long overdue to safeguard existing practice and allow the Port to safely carry out its responsibilities; It’s clear that while VTS can monitor with impressive precision it cannot stop all accidents from happening as was recently seen when two barges collided;

 Authoritative studies3 carried out on Bay sedimentary contamination highlights how chemical pollution from industrial discharge and chronic minor spillages from fuel transfers within the Bay highlight the need to manage all harmful activity – not expand this;

 ESG also concerned about water quality for bathing and marine life reasons;

 Concerned about protecting and conserving local biodiversity – already under growing pressure from maritime activity/reclamation/anchorage impact/dredging/ever present threat of major oil spill;

 East Side provides a calmer and more natural environment for the community to enjoy and should be preserved;

 Full disclosure of the real economic benefits to the local purse from bunkering activity must be published, building in the potential loss in tourism from increased industrialisation of Gibraltar and the priceless factor of quality of life for ourselves and our families if immediate economic profits are to always take precedence over quality of life;
Contact ESG: www.esg-gib.net Email: esg@gibtelecom.net Tel: 200-48996 Mobile: 54960000
1 Gifford’s
2 www.esg-gib.net
3 Greenpeace Study posted on ESG website-resources-documents

EASTSIDE BUNKERING – GONHS POSITION

The Gibraltar Ornithological & Natural History Society (GONHS) is concerned about the potential effect of bunkering on the eastside.
It is important that no such activity take place before the completion and appropriate consideration of the Environmental Impact Assessment, and of an Appropriate Assessment under the provisions of the Habitats Directive.

The latter is required in view of the area’s status as a Special Area of
Conservation. The assessments should take into consideration all the relevant potential impacts on the environment, which will include the effects of discharges of fuel or fumes, and the effects of anchoring of the vessels. The implication of the activity on the law of Gibraltar, specifically the nature Protection Act, would need to be assessed.

Mitigation and compensation measures would also have to be considered as part of these analyses.
27 May 2011

JOINT STATEMENT BY COALITION OF STAKEHOLDERS ON THREAT OF EAST SIDE BUNKERING
16th AUGUST 2011

STAKEHOLDERS: GONHS, ESG, Gibraltar Federation of Sea Anglers, Caleta Hotel, Gibraltar Sub Aqua Club, Both Worlds Residents Committee and Both Worlds Retirement Committee

It is now two months since the ESG first contacted the Chief Minister on behalf of concerned stakeholders to register strong objections over the possible expansion of bunkering off the east side of the Rock. A folder containing detailed concerns from each party was also sent at the time to No. 6.

No formal response has been received from the Gibraltar Government on this matter so far. All parties submitted their concerns to UK scientists last October during a preliminary EIA consultation exercise.

The groups believe it is critical for this issue to be kept in the public domain in view of the widespread public interest and today issue a joint statement providing many reasons why bunkering expansion to the east side of the Rock should not be allowed. It is important to note that the various groups have specific reasons for objecting to bunkering expansion. However there is a large area of broad agreement which forms part of this statement.

These are centred on five key areas:

1. Environmental legislation and laws
2. Bunkering impacts on the environment
3. Bunkering impacts on quality of life
4. Mitigating issues relating to bunkering
5. Other, more general considerations1.

The most important issue is the continued lack of EIA (Environmental Impact Assessment), or Appropriate Assessment such as required under the Habitats Directive in view of the area’s status as a Special Area of Conservation. Not only has an Appropriate Assessment not been carried out but the initial EIA announced several months ago appears to have faltered and never been produced. This could indicate that the project has also been dropped which would be strongly welcomed by the undersigned groups.

We would however, like to publicly set out why we oppose this type of industrial activity on the east side of Gibraltar.

2. Bunkering impacts on the natural environment in a number of ways. Chronic spills of fuel and chemicals are detrimental to marine life and vegetation. This has a knock-on effect on our local biodiversity. The accidents off Gibraltar’s coastline over the years have starkly demonstrated the lingering impacts of oil pollution on the marine environment which must be avoided at all costs. The severe impacts from dragging anchors on the seabed and reefs are highly damaging and must be minimised not increased. Any significant increase in shipping activity will also automatically increase the risk of a serious accident with the long-term consequences this would have on the natural environment.

3. Quality of life is also a hugely important factor when objecting to east side bunkering activity. Bunkering is also associated with regular impacts such as fumes, noise pollution and general environmental degradation. The East coast being what it is means that the introduction of such industrialised activity would threaten a major recreational and bathing area for a large part of our community. West coast bunkering continues to carry all these impacts which are exacerbated in certain wind directions. If bunkering were to proceed on the east side we would not only be creating a problem on the east but increasing problems to west flank communities who would now receive fumes no matter the wind direction.

4. In the course of any analysis conducted on the possible bunkering expansion, a number of mitigation measures would need to be considered. “Vapour Recovery Technology” (VRT) is such a measure that, if applied, could eliminate some of the fumes entering our common airspace when servicing vessels. The long awaited “Vessel Tracking Technology” (VTS), introduced long after the boom in bunkering business should now play its role in safely policing shipping movements within and adjacent to the Bay area and not be used to pave the way for further shipping activity. Increased monitoring should also involve close liaison with regional port authorities which needs to be actively pursued. Mitigation could also be applied by introducing fixed anchorage points to limit the destructive impacts of lowering anchors onto fresh areas of seabed and ensuing dragging. It’s clear that response time to any future marine accident on the east side would throw up problems of time, distance and weather conditions. Any spills would be impossible to contain in open waters and absence of adequate response equipment locally for a major incident would result in disastrous long term impacts to the natural environment, residents and the tourism trade.

5. Hotel owners in the area are totally opposed to such bunkering activity due to the degradation of the environment this will bring and how this will affect their business as well as jeopardise any future tourism development in Gibraltar. The special environment which exists on the east side of the Rock deserves sensitive development and management given it provides a much needed haven in an otherwise densely populated and busy urban environment that Gibraltar is today. Developing the east side with these points in mind would bring long term, sustainable benefits to both the local community, the tourism industry and to the environment.

In conclusion the groups reiterate that the social marginal utility gained from the 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, coastline and quality of life are.

The groups call upon all political parties, including the present Government, to publish their policy on bunkering expansion to the East Side of Gibraltar. This massively important social and environmental issue represents a critical time for balancing industrialisation in Gibraltar with preserving our quality of life and natural environment and as such deserves full transparency by all political parties ahead of the next general election.

Please visit the ESG and GONHS website where full statements by all stakeholders will soon be posted

Kindly note that the number to call for bunkering fumes is as follows:-

56001652  this is the number for the new Bunkering Superintendent called Mr John Ghio

Please contact the ESG if you continue to have problems once you have attempted to report a problem to the Port via the above  number.

ESG stresses EIA MUST be published- 

The ESG has now seen not one but two reports in Europa Sur (see below) confirming that bunkering on the east side of the Rock will commence this summer. This from the mouth of the Captain of the Port himself, Peter Hall. According to the article Mr Hall is saying the findings of the Environmental Impact Assessment (EIA) have not yet been published but understands that it will permit daytime bunkering conditional to good weather etc. It is absolutely scandalous that we get to hear such news via the Spanish media. The ESG, along with various others in the community were last year consulted by the visiting scientists carrying out the EIA. It is quite unacceptable that after such consultation the green light is announced in the Spanish press sweeping aside all concerns and serious misgivings held by the consulted parties.

The ESG has already contacted the Port to establish authenticity of the media reports but has so far not been able to get further clarity on the matter.

The ESG calls upon the Gibraltar Government to explain itself to the community over an issue which will cause many waves. The concerns placed before Government and the EIA specialists are too numerous to go into here but suffice to say that the community will not allow this expansion to be passed through in this underhand manner. It makes an absolute mockery of the public consultation exercise authorised by the Port last autumn. Where is the EIA Report?

Europa Sur Reports:

http://www.europasur.es/article/maritimas/909324/gibraltar/autorizara/bunkering/la/zona/levante/este/verano.html

http://www.europasur.es/article/maritimas/905369/gibraltar/permitira/bunkering/lado/este/con/luz/y/buen/tiempo.html

Please make a note of the following number which I am now reliably told by the port will pick up on a 24hr basis and receive your genuine report on bunkering fumes  in Gibraltar.

Its important that you call the number while the pollutionis taking place so there is a better chance of identifying the culprit-

NUMBER IS: 56000545

KIND REGARDS

ESG Committee

June 30th 2010

“Increased bunkering will further degrade our quality of life”

Just 10 days ago the ESG issued a press release urging Govt to address the problem of invasive fugitive fumes (OFFENSIVE SMELLS) related to offshore, ship to ship bunkering, affecting many south and west district residents. Not only has our plea on behalf of the many callers and complainants been ignored, but it appears that Government is now opening the way for expansion of this activity on the eastern side of the Rock.

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Whilst the Government has said that the plans are subject to an environmental impact study the mere fact that Government is prepared to extend bunkering to the Eastside is worrying in the extreme.

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Clearly relying on a passive public reaction, Government heralds this step as good for the economy, more money in the coffers, and that, seems to be all that matters. The ESG and we believe, many in our community, will disagree and so we are considering launching a petition. The purpose would be to gauge what the local community thinks of Government’s management of this issue particularly as it had promised, in its last manifesto, (among many other unfulfilled green promises), that it was strongly considering relocating bunkering operations onto land to minimise impact on people and the environment. Was this seriously intended, or was Government merely responding to the concerns of voters at the time!!

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The ESG calls upon GOG to inform the public what are the economic benefits to Gibraltar and whether they have also factored in the loss of revenue from tourism activities due to the increased unattractiveness of our beaches and sea front due to the presence of tens of tankers a short distance from shore plus the effects of noxious smells on our beaches in the east side. This is without even considering oil pollution from the many potential small oil losses on fuel transfers washing onshore during the prevailing Levante.

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The ESG has been reasonably fair in its campaigning and lobbying for safer bunkering practices in Gibraltar, recognising progress at the Port and a clear intent even within the Tripartite system, to consolidate preventative measures at a cross-border level. However we still do not know if full implementation of VTS (vessel tracking systems) on both sides of the Rock is now operational. (This along with organising channels for ship movements and many other recommendations were made in subsequent accident reports into collisions on the eastern side of Gibraltar).

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We also do not yet know if the Tripartite Forum will be delivering on its proposed programme of environmental protection and coordination in all maritime activity as it pledged to do back in July 2009. Surely this planned bunkering expansion ahead of a Tripartite “plan” can only be seen as a retrograde step to what the Forum is planning and even a slap in the face of the Forum’s efforts in working towards a safer environment.

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The ESG considers it premature of the Gibraltar Government to make this announcement. It demonstrates its lack of sufficient care over environmental issues. At the same time it has yet to deliver on the promises it has made along the way which can only be seen as quelling public criticism and fobbing off political backlash.

The ESG is considering a petition because we believe this step is one too far.

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ESG Press Release 19th June 2010

Re Bunkering Fumes and General Pollution on the Rock

The ESG wishes to draw attention to an issue that has begun to affect many local residents once again, that of bunkering fumes. While efforts by the agencies responsible for regulating this activity have been noted positively by the ESG, the recurring nature of the fumes issue strongly suggests that much more needs to be done to stop this smell nuisance and at times, heavily impacting activity, from affecting our quality of life.

Vapour Recovery Systems:
The ESG has approached Government and technical officers to legislate for vapour recovery systems to be applied to all fuel bunkering activity. This would eliminate much of the fumes problem which offends and affects many residents especially in the summer months.

Reporting Details:
In these last few weeks the ESG has rec’d numerous calls and has also witnessed heavy pollution from the port and offshore bunkering sites. We have established that there isn’t an immediate response facility at the Port although an out of hour’s mobile number was given to the group by the Port Authority ( see below).

These two areas continue to present serious issues to the community and the ESG urges the Captain of the Port and his team to accelerate all such improvements during the modernising and upgrading programme which is currently going on at the Port.

ESG Advice:
Please note that any offensive fumes on land should be reported to the Environmental Agency daytime Mon-Frid 200-70620. Outside these times, and at weekends, you are to call 200-72500 (Police Station) and ask for the Environmental Monitor on duty.

Obviously seaborne activity or pollution arising from the Port area needs to be reported to the Port directly. First call: 200-46254 during normal office hours and ask to speak to a Senior Port Officer. The number to call to report any issues “out of hours” is the duty Senior Port Officer on- 58669000
You are also advised to call the Environmental Agency so they can log the incident and help out as needed in any investigation.

Please feel free to telephone ESG if you still need assistance.
Tel: 200-48996, 43156, 5496000 and if you have email please send information to:
esg@gibtelecom.net

Recent fumes affecting Gibraltar residents from bunkering operations were investigated by the ESG. Port Authority advised that it had detected a problem on one of the vessels and was carefully monitoring the situation especially now the hot weather is upon us which doesn’t help the situation at all.

Port advises for any future complaints to be made to Port Authority on 200-46254 during office hours and ask to speak to a Senior Port Officer-
If outside “normal hours” you can call mobile: 58669000 to reach a port official.
Please cc any report or complaint to the ESG as we can also help follow up any incident.