quate standards are met by the oil tankers. Our areas of concern at the present time are by no means limited to the controversy of double bottoms. More important is the question of maneuverability, including stopping. When tankers are still being built with single screws and with inadequate horsepower for maneuvering in narrow seas, we in Alaska become quite concerned. It is our understanding that recommended modifications such as bow thrusters are not in all cases being incorporated. The upper limit for tanker vessel size should not exceed the limits of technology in providing the optimum in maneuverability for operating in and out of Alaskan and west coast ports. Ports possess a finite number of port callings possible in a year's time. At the present time it appears that this finite limitation juxtaposed with physical limitations on the west coast such as vessel draft, on-shore transfer facilities, etc., would not allow the west coast region to receive 2,000,000 barrels of Alaska crude per day. Therefore, ports should be designed to match proposed vessel designs. Also, current tanker standards in conjunction with port practices today do not appear to be sufficient. As the lead time in tanker construction and port development is several years, immediate attention is required in developing the appropriate plans and specifications.

We feel it is necessary to immediately address the above problems in conjunction with the other west coast states concerned and request that you convene in initial meeting as soon as possible to begin a coordinated effort toward solution of these problems.

I would like to repeat that nothing is more vital to us than the continued health of our renewable resources, especially the fisheries, during the development of our oil resources. This is probably the most critical resource developing decision in the nation since it affects our largest remaining source of marine protein within American jurisdiction. These fisheries are worth an extra effort by all of us. Sincerely,

JAY S. HAMMOND,

Governor.

THE SECRETARY OF TRANSPORTATION,
Washington, D.C., May 3, 1975.

Hon. JAY S. HAMMOND,
Governor of Alaska,

Juneau, Alaska.

DEAR GOVERNOR HAMMOND: Thank you very much for the congratulatory messages contained in your letter of March 25, 1975; it was a pleasure to hear from you.

I have carefully reviewed the issues raised in your letter and would like to discuss certain specific portions in addition to providing additional information which I am certain will assure you of this Department's concern in protecting the marine resources of your state as well as those of all of our states.

I am enclosing a document, "The Coast Guard's Approach to Tanker Pollution Abatement," which accurately reflects this Department's position. In concurring with this policy approach, I am fully cognizant of not only the environmental implications of the action but also the legal, economic, and social arguments behind the decision to proceed in the manner outlined.

I do not subscribe to the view that standards for tankers which will be used to transport Alaskan crude are being relaxed. In fact, as is indicated in the proposed rulemaking for Tank Vessels in the Domestic Trade, published in the Federal Register of June 28, 1974, the Coast Guard is planning to significantly strengthen tanker construction and operating standards for environmental protection purposes. Among other things, the regulations will stipulate that new tankers of greater than 70,000 deadweight tons be provided with segregated ballast capacity. The purpose of this regulation is to eliminate the principal source of pollution of the sea by removing the need to introduce ballast water into the cargo tanks of the vessel with subsequent intentional discharge of the oily ballast. The proposed regulatory action would also reduce accidental pollution through the application of cargo tank size limits, subdivision, and stability requirements.

With regard to the subject of double bottoms and other design concepts aimed at the further reduction of outflows due to casualties, I feel that the

content of the enclosure is fully explanatory. It is true that no regulations have been proposed to improve maneuvering or stopping ability. Subsection 4 of the Tank Vessel Act, as amended by section 201 of the Ports and Waterways Safety Act of 1972, points out that the need for regulations is a prerequisite to establishing the regulations. As is pointed out in the enclosure, the Coast Guard has reviewed tanker accident reports and found that few, if any, accidents can be attributed to poor stopping, turning, course changing or course keeping ability—the four facets of maneuverability. The majority of tanker collisions result from inadequate human performance. Therefore, we remain unpersuaded that regulations in this area are needed at this time. On the other hand, steps are being taken by the Coast Guard to reduce tanker casualties in U.S. waters. The methods intended to accomplish this are contained in an Advance Notice of Proposed Rulemaking entitled "Marine Traffic Requirements" published in the June 28, 1974, Federal Register.

Regarding the TAPS trade specifically, I should like to briefly outline certain other actions that are being taken by the Coast Guard which, I feel, will provide additional degrees of environmental protection. As required by section 402 of the amended Mineral Leasing Act of 1920 authorizing TAPS, a complete Vessel Traffic Control System centered at Valdez, with appropriate Coast Guard port safety personnel and facilities, will be placed in operation for the Valdez-Prince William Sound areas. The purpose of this system is to ensure safe, pollution free, marine transportation of Alaskan oil in the waters covered. The system will incorporate VHF-FM communication coverage of Port Valdez, Prince William Sound and 30 miles seaward from Cape Hinchinbrook; radar coverage of Valdez Arm and Narrows and Port Valdez; and a traffic separation scheme emanating southward. The Coast Guard is committed to having this system in effect by the time of the first TAPS tanker movement. This vessel traffic system, coupled with those in operation of our lower west coast ports, will provide necessary vessel traffic management. It is also anticipated that complete LORAN-C electronic navigation coverage will be in operation for the entire west coast and southern Alaskan areas providing extremely accurate shipboard navigational capability for the TAPS tankers and other vessels operating in those areas.

I personally share your concern for the need to protect Alaskan resources. In view of the current and planned actions which I have outlined and which are discussed in the enclosure, I do not feel it necessary to convene a specific meeting as you have suggested. Instead, I have suggested to the Commandant of the Coast Guard, Admiral Siler, that appropriate members of his staff be made available to you at your convenience to further discuss these matters should you so desire.

Sincerely,

WILLIAM T. COLEMAN, JR.,
Secretary of Transportation.

AN ASSESSMENT OF THE PROPOSED PRINCE WILLIAM SOUND VESSEL TRAFFIC SYSTEM, PREPARED FOR: THE STATE OF ALASKA OFFICE OF THE PIPELINE COORDINATOR

I. INTRODUCTION

This report was prepared for the Office of the Pipeline Coordinator of the State of Alaska by Engineering Computer Optecnomics (ECO), Inc. The report discusses aspects of the Vessel Traffic System (VTS), as proposed for Prince William Sound and surrounding waters, including Valdez Arm, Valdez Narrows, Port Valdez as well as the Gulf of Alaska.

The report makes two major points and includes supporting technical material for these recommendations. The two major points can be summarized as follows:

1. The Prince William Sound VTS should incorporate a basic surveillance system in Prince William Sound and the Gulf of Alaska, in the form of a LORAN-C Re-transmission System or an equivalent system.

2. "Operational Guidelines" for oil tankers, as large as 200,000 deadweight tons, operating within the confines of Prince William Sound, Valdez Arm, Valdez Narrows, and Port Valdez, cannot be adequately developed without utilizing real-time simulation.

As requested by the Coast Guard letter dated December 8, 1975, (Appendix A), this information has been developed to serve as input during the hearings on the Valdez Vessel Traffic System.

II. EVALUATION OF VESSEL TRAFFIC SYSTEMS

1

To properly evaluate any VTS, the overall system must be separated into its two major components, the first being the communications subsystems and the second being the vessel surveillance subsystem. (1, 2)) 1 With respect to the communications subsystem of the Valdez VTS, it appears that the Coast Guard controller in the Valdez Traffic Management Center will have adequate VHF-FM communications within all of the subject waters. However, with respect to the presently proposed vessel surveillance subsystem, coverage is limited to only Port Valdez and Valdez Arm. In other words, beyond Valdez Arm the Coast Guard controller, located at the Valdez Traffic Management Center, would not have any means by which to determine the position and/or the course and speed of any vessel operating in Prince William Sound and the Gulf of Alaska, other than by contacting them on the standard communications equipment and requesting that they report their course, speed, and present position. In view of the size, types and number of vessels which are either operating or proposed to be operating in Prince William Sound, such as tugboats, tugboats with barges, fishing vessels, ferries, supply vessels, survey vessels, Liquefied Natural Gas (LNG) carriers, Coast Guard cutters, as well as the TAPS oil tankers, it is apparent that the surveillance subsystem should be designed to permit the controller at the Valdez Traffic Management Center to independently determine the course, speed and position of vessels within Prince William Sound and within the stated range of eighty nautical mile radius of Cape Hinchinbrook.

III. A BASIC LORAN-C SURVEILLANCE SUBSYSTEM

Recognizing that it is one thing to state that the surveillance subsystem should be designed to include this added capability and quite another matter to add this capability into the presently designed surveillance subsystem, the State of Alaska, through the Office of the Pipeline Coordinator, directed ECO, Inc. to examine various alternatives, and recommend a cost-effective solution. After conducting a detailed examination of the alternatives and after meeting with both engineering and operations personnel at Coast Guard Headquarters in Washington, D.C., it appears that the optimum solution, from a viewpoint of both safety and cost, is to utilize the Coast Guard's national navigation system, LORAN-C. Since it is the U.S. Coast Guard's intention to require LORAN-C receivers when LORAN-C coverage becomes available in 1977 (Appendices B and C), the addition of an interface unit between the ship's LORAN-C receiver and the VHF-FM communications equipment allows the ship's LORAN-C time differences (position) to be re-transmitted to the Valdez Traffic Management Center.

What makes this LORAN-C Re-transmission System so attractive is that the major components, such as the LORAN-C receivers, the VHF-FM transceivers, and the display device at the Valdez Traffic Management Center are already existing within the proposed Prince William Sound VTS and only the interface units, one on each ship and one at the traffic center, need to be added to produce a cost-effective surveillance subsystem.

IV. VESSEL TRAFFIC SYSTEM EFFECTIVENESS

An estimate of the effectiveness of a VTS in reducing vessel casualties was completed by the Coast Guard in August, 1973. (3) Figure 1. shows this estimate, based on an analysis of vessel casualties in 22 United States ports and waterways during fiscal years 1969 through 1972. This estimate indicates that a system which incorporates a bridge-to-bridge radio-telephone, navigation regulations, traffic separation, and a vessel movement reporting system is expected to reduce vessel casualties resulting from collisions by approximately 50 percent. On the other hand, the addition of basic surveillance should reduce collisions by an additional 10 to 15 percent.

It is also interesting to note from Figure 1. that simple bridge-to-bridge communication will reduce collisions by approximately 20 to 25 percent while the addition of navigation regulations and traffic separation without vessel

1 Numbers in parentheses designate references at the end of this report.

movement reporting has a negligible effect on the percent reduction in vessel casualties. However, as previously noted, inclusion of a vessel movement reporting system increases the effectiveness of the VTS to approximately 50 percent; or nearly a doubling in effectiveness.

ALL VESSEL

VESSEL CASUALTIES INVOLVING COLLISIONS, RAMMINGS O° GROUNDINGS.

SURVEILLANCE

AUTOMATED ADVANCED

The issue then becomes the cost effectiveness of any of these steps; i.e., the cost and effect of going from the bridge-to-bridge communication level to the vessel movement reporting level to the basic surveillance level. The Comptroller General of the United States in a report to the Congress (4) concluded that from a national viewpoint it would be more cost effective to use funds planned for surveillance within one VTS to provide simpler VTS at additional locations. This conclusion was predicated upon the utilization of electronic surveillance in the form of radar and television at an incremental cost increase of $1 million over the initial $2 million capital cost to the government. With only an attendant decrease in collisions of 10 to 15 percent, with the incorporation of surveillance, it is not difficult to arrive at the Comptroller General's conclusion that a 50 percent increase in cost was not justifiable. That same report and other documents (5), however, do not consider any alternatives to television and radar as a means to conduct basic surveillance, such as, a LORAN-C Re-transmission System.

V. FEASIBILITY DEMONSTRATION OF A LORAN-C RE-TRANSMISSION SYSTEM ON

THE GREAT LAKES

A paper entitled, "An Automatic Vessel Traffic Control System Utilizing LORAN-C", was originally developed for the Second Annual Technical Symposium of the Wild Goose Association in October, 1973, and clearly demonstrates the feasibility of re-transmitting LORAN-C time differences. Moreover, it establishes the reliability and accuracy of a LORAN-C Re-transmission System. It is reproduced in its entirety and is presented as Appendix D. Appendices E and F, whose subject matter complements the foregoing paper, are also presented in their entirety.

VI. COST EFFECTIVENESS OF THE PROPOSED LORAN-C RE-TRANSMISSION SYSTEM

As previously shown within Section IV of this report, the addition of a basic surveillance system, such as a LORAN-C Re-transmission System, should reduce the collision probability of the proposed Prince William Sound VTS by some 10 to 15 percent.

With regards to economics, the cost of a single LORAN-C interface unit has been estimated at $15,000. In orders of ten or more, the cost has been estimated at $12,000 per unit. The overall incremental system cost (i.e., shipboard units and the shoreside unit) would be divided between the government and the individual shipowner, since each would be required to obtain a LORAN-C interface unit to implement the suggested LORAN-C Re-transmission System. With the incremental cost to the United States Government being less than five percent of the one million dollars that the Comptroller General estimated would be required for a basic surveillance system and with the incremental cost to the shipowner being less than one half of one tenth of one percent (0.0005) of the capital cost of an average TAPS oil tanker, it is apparent that the proposed Prince William Sound VTS should include this basic surveillance system by making full use of the LORAN-C chain and thus claim the stated 10 to 15 percent reduction in collision probability.

VII. THE UTILIZATION OF REAL-TIME SIMULATION IN DEVELOPING "OPERATION GUIDELINES" FOR THE PRINCE WILLIAM SOUND VESSEL TRAFFIC SYSTEM

A critical consideration in all phases related to the design and the operation of Vessel Traffic Systems must always include the role of the human beings who play a part in one or more of the subsystems forming the specific vessel traffic system. Within the design stage of the system it must be decided which tasks are to be allocated to human beings and which to machines and automated control devices; subsequently a specific training program must then be developed to prepare the human operators for the tasks assigned to them.

The type of capabilities or skills which are required by the human operators of any subsystem depends on the task to be performed. For example, within the ship handling subsystem, a master/pilot involved in executing a maneuver with a 200,000 DWT. tanker must have a high degree of training, with his particular ship, under the anticipated "Valdez" environmental conditions, and most important within the parameters and confines of the Prince William Sound/Port Valdez waters. On the other hand, within the vessel traffic subsystem, a person controlling the movement of a 200,000 DWT. tanker must be well aware of the capabilities and limitations of the man-machine subsystem that he is controlling, for various environmental conditions. Thus the ship controller, like the master//pilot, must possess a high degree of training for several tasks; even though he is not required to handle a ship. Figure 2. is a block diagram of the overall system.

In general, operators of advanced technical systems meet specific problems of a perceptual and decisive type. To handle these problems they are trained in particular skills. These skills do possess three characteristics:

1. They consist essentially of the development of an organized and coordinated activity in relation to an object or a situation.

2. They are learned, in that the understanding of the object or situation and the form of the action are built up gradually in the course of repeated experience.

3. They are serial, in the sense that within the overall pattern of the skill many different processes or actions are arranged and coordinated in a temporal sequence. Within any skilled performance these characteristics are inter-related. Therefore, a performance can only be called a skill when all three of the above characteristics are fulfilled.