Lt. James W. Gynther, U.S. Coast Guard, suggests real-time simulation as a means of providing a professional method by which to evaluate the overall system. LT. Gynther's article, Appendix G, in the Coast Guard Engineer's Digest of December, 1974, asks the following questions:

1. "Should not each Vessel Traffic System have technical standards based on appropriate human engineering studies of vessel controllability?"

2. "Can we afford not to determine the answers to the above and other related questions?"

He concludes with the following observation :

"It is recommended that the Coast Guard investigate adopting this human engineering system approach to the A/M problem at the earliest opportunity. The United States Coast Guard, with access to the world's most advanced technology, should continue to be a leader in the practical management of this technology to derive solutions for our marine problems."

Subsequent to LT. Gynther's article, a paper entitled, "The Influence of Human Behavior on the Controllability of Ships", was developed based on work in the area of human factors in the marine world. This paper, Appendix H, was presented at the Symposium on Science and Natural Resources in the Gulf of Alaska, sponsored by The Arctic Institute of North America and the University of Alaska, during October, 1975. This paper documents the success of real-time simulation and stresses the importance of considering the human aspects in designing and operating Vessel Traffic Systems. As a result of real-time simulation assessments of other Traffic Systems, which have been conducted to date, it can be stated that:

1. The success of any Vessel Traffic System depends on both the technological effort and the consideration of the human operators, both shipboard and shoreside.

2. The proper allocation and structuring of individual tasks, which are required to be performed by either men or machines, require extensive knowledge of the capabilities and limitations of human operators within any of the subsystems.

3. Only real-time simulation can accurately and safely portray certain "emergency conditions" which should be experienced through simulated conditions by both shipboard and shoreside personnel, prior to experiencing the actual emergency condition.

Real-time simulation of the Prince William Sound Vessel Traffic System in order to establish adequate "Operational Guidelines" and to properly train personnel is also an efficient tool for the following practical reasons:

1. The elements of the system can be tested in the preconstruction stage. 2. Design alternatives can be studied in order to develop the optimum system design.

3. Measurements of system performance can be established in a controlled way, without contamination from uncontrolled sources as is the case in real life situations.

4. The allocation and structuring of the tasks to be performed by men and machines can be facilitated by proper research on general purpose simulators. 5. The human operators which become part of the system can be trained to achieve a skilled level of performance, before the system is put in operation.

Given the foregoing observations on human factors in ship control, it is clear that no ship transportation system can be analyzed without considering the critical interaction man plays. Moreover, there is no historical data within the waters of Prince William Sound which will allow decisionmakers to quantify this interaction within the basic ship control system, much less make judgments as to the effect of "Operational Guidelines" on a future system configuration. Certainly experience and judgment can in a directional sense provide qualitative insight as to what "Operational Guidelines" might be instituted to enhance safety. They will not, however, be quantified so that a decisionmaker may select among options except in his own subjective opinion. The problem becomes even more exaggerated when there is no experience upon which to draw such as in the case of operating large tankers in Prince William Sound with a VTS present.

Only real-time simulation allows decisionmakers to quantify the effects of "Operational Guidelines" to control ship movements. Simultaneously, the realtime simulator can provide the necessary training to both shipboard and shoreside personnel within the system.

LIST OF REFERENCES

(1) Hill, R. C., "Collisions and Groundings: Preventing the Preventable," U.S. Naval Institute Proceedings, December, 1974.

(2) Benkert, W. M. and R. C. Hill, "U.S. Coast Guard Vessel Traffic Systems, A Status Report", paper presented at Marine Services Assembly Meeting, Radio Technical Commission, New Orleans, Louisiana, April, 1972.

(3) United States Coast Guard Study Report, "Vessel Traffic Systems, Analysis of Port Needs", Washington, D.C., August, 1973.

(4) Comptroller General of the United States, "Vessel Traffic SystemsWhat is Needed to Prevent and Reduce Vessel Accidents?" A Report to the Congress, January 21, 1975.

(5) Department of Transportation, U.S. Coast Guard, "Final Environmental Impact Statement, Prince William Sound Vessel Traffic System".

VIRGIL F. KEITH,

DEPARTMENT OF TRANSPORTATION,

Engineering Computer Optecnomics Inc.,
Arnold, Md.

U.S. COAST GUARD, Seattle, Wash., December 8, 1925.

DEAR MR. KEITH: As you are probably aware, the Coast Guard is in the process of establishing a Vessel Traffic Service (VTS) in Prince William Sound. This service will be implemented in mid-1977 in conjunction with the startup of tanker traffic from the TAPS terminal in Valdez. Basically the VTS will monitor and control marine traffic in Port Valdez, Prince William Sound and the approaches thereto.

The Coast Guard is currently in the initial stages of developing the regulatory package for the Vessel Traffic Service. Following the development of a set of "Operational Guidelines" the Coast Guard plans to hold preliminary informal hearings with interested parties prior to drafting proposed regulations. These informal hearings are tentatively scheduled for February of 1976.

If your organization is interested in providing input during the upcoming regulatory development process, it is requested that you identify a contact by name and address for our future use. If you choose to do so, your organization will be placed on our permanent mailing list for future correspondence and your participation in any hearings or meetings will be invited.

Adm. OWEN W. SILER,

Commandant, U.S. Coast Guard,
Washington, D.O.

DEAR ADMIRAL SILER: The following testimony represents the State of Alaska's concern regarding the Coast Guard's final environmental impact statement for tanker construction standards. It should be noted now that while we are reviewing an environmental impact statement, that the word "environment" is not merely a rhetorical device used by the State of Alaska to condone or condemn certain actions. The advent of significant volumes of petroleum transport through some of the world's richest sources of marine

protein brings us face-to-face daily with the potential of serious economic risks.

The Trans-Alaska pipeline was authorized by Congress only after strong assurances by the federal administration that only the most rigid requirements for tanker design would be tolerated for the marine leg of transport for the North Slope oil. Specific statements included communications and double hulls. The State of Alaska is addressing its comments today only on the design of the tanker while recognizing that the design of the tanker is only an element of the total marine transportation system. These statements are meant in addition to the statements which I, along with other governors of west coast states, have already presented in written testimony. It is also our intent, by virtue of this testimony, to put the tanker industry on notice that in the future the State of Alaska will not tolerate marine vessel standards being perpetuated wholely for the benefit of marine operators. In this light, it should be noted that Alaska is particularly interested in seeing that the Coast Guard promulgate regulations which will require ALL vessels involved in the carriage of hazardous cargo to process the following design characteristics. Tank vessels of 70,000 deadweight tons and greater must meet the subject requirements by January 1, 1980, by rulemaking if necessary, and ALL tank vessels engaged in the transportation of hazardous materials meet the subject requirements by January 1, 1985. We believe that these standards are realistic allowing industry enough time to design and build accordingly to respond to schedules of demand for vessels in the carriage of Alaskan petroleum resources as well as allowing industry to recover, to a major extent, its current investment as the fleet ages to obsolescence. The proposed federal schedule for outer Continental Shelf development will require extensive use of vessels smaller than 70,000 DWT in Alaskan waters. It is our present position that all oil development on the Outer Continental Shelf must meet the highest possible standards for environmental protection, and the tankers are a most critical element in this development since onshore pipeline delivery will probably not be a feasible alternative for most of the proposed OCS lease areas in Alaskan waters.

Safety and pollution control within a tanker transportation system are inseparable; antipollution measures are only an extension of what is kept "safe". The problem of containment of bulk liquid cargoes is the same whether you are concerned that they will escape and burn or escape and damage the environment. Alaska has addressed the tanker standards as they relate to conditions which are known to exist as they relate to resource development plans and supporting transportation systems. Subsequent exploitation of resources will require an ongoing review of existing standards to see if they reflect adequate protection for the environment when considering the impacts of increased congestion, location, weather conditions (icing, etc.) and such support facilities as communications, etc.

Therefore, Alaska strongly recommends that the following design features be incorporated into self-propelled vessels operating in waters contiguous to our State:

1. Flue gas inerting systems.-Are considered to be an essential item, not only a principal environmental protection device, but also as a major safety device for the crews working aboard these vessels.

2. Lateral thrusters.-Alaska is concerned that vessels involved in the carriage of hazardous cargoes should have maneuverability characteristics compatible with conditions which may require greater maneuverability than is normally associated with other marine systems in the U.S. Wind characteristics commonly experienced in Prince William Sound suggest that all possible technological assistance be available in the vessel to complement tug boat assistance.

3. Loran-C.-With the construction of LORAN-C transmitting stations on the west coast of North America to provide LORAN-C coverage for the Gulf of Alaska, Prince William Sound, the West Coast of Canada, and the West Coast of the "lower 48", it is Alaska's intention to assure that the tank vessels be equipped with LORAN-C receivers to enable them to utilize this navigational system.

4. Collision avoidance system.-Alaska endorses the policy of the U.S. Maritime Administration and the U.S. Coast Guard which requires a Collision Avoidance System on all new tankers. Alaska further endorses the National Transportation Safety Board which recommends that ALL vessels be equipped with a Collision Avoidance System.

5. Segregated ballast incorporating double hulls/bottoms.-Alaska recalls the promises made by then Secretary of Interior, Rogers C. B. Morton, to the U.S. Congress stating that the Trans-Alaska Pipeline System tanker transportation system would incorporate the latest technological advances. Alaska feels that oil tankers operating in the Trans-Alaska Pipeline System trade must utilize segregated ballast and incorporate a double hull/bottom design to meet this premise.

Sincerely,

DEAR GOVERNOR HAMMOND: It was a pleasure to see you on 20 November 1975 and to have the opportunity to discuss our areas of mutual concern. I am writing to amplify our discussion and to reply specifically to your letter of 10 November 1975.

The problem of oil pollution from tankers is complex and there are no elementary, inexpensive or speedy solutions. As you correctly point out, safety is an all-inclusive term and includes environmental safety as one aspect. Unfortunately, public discussion has created some misunderstanding of the Coast Guard position on marine pollution. We believe the regulations published 14 October 1975 represent a quantum step forward in environmental protection from tank vessel generated pollution. When fully implemented, these regulations will practically climinate operational pollution and will also be statistically effective in cases of accidents where the more stringent subdivision and damage stability requirements and tank size limits operate to reduce outflows or prevent the total loss of a ship and its cargo.

The same day, 14 October 1975, the Coast Guard published a proposed rule concerning the distribution of required segregated ballast spaces, which when placed into effect will also reduce outflow from a tanker in case of accident. As much as I dislike the term "statistically reduced," it is the only proper way to address the risk of oil spillage caused by accidents. Tank vessel accidents are statistically small numbers and randum, unpredictable events by definition. The number of accidents that result in spillage are even smaller, on the order of one-fourth of the accident events. Further, there has been no disagreement with the accident analysis which shows that about 80 percent of the pollution outflow from acidents is caused by approximately two percent of the events. One can, and many have, then assert that all very large spills, catastrophic if you will, and accidents where the vessel ultimately sank should be withdrawn from the data base, leaving only smaller spills where total loss of the vessel did not result. This approach is not considered sound for two reasons: (1) a blanket assumption is made that nothing could be done which would have altered the outcome of those events and (2) also those events by their very magnitude are most deserving of attention. Nevertheless, if one uses this approach, it is immediately apparent that the total amount of oil pollution from groundings, rammings and collisions that remains is relatively small, on the order of 30,000 tons per year worldwide.

It is also appropriate to ask where "oil" fits on the relative scale of risk posed to the general public and port areas, the vessel and its crew, and to the environment. We certainly appreciate, and I know the responsible persons within the marine industry are aware, that the days of "business as usual" are gone. Oil cargoes are being rightly treated with a great deal more respect, but I feel that we must approach this subject in proper perspective. The Coast Guard philosophy with respect to bulk liquid vessels has for a number of years recognized differing levels of care necessary to counter perceived different levels of hazard depending upon the bulk cargo involved. This concept recognizes four categories of bulk liquid cargoes. One category may be described as "unregulated," i.e., those liquids that do not fall within the definition of "bulk dangerous chemicals." These cargoes do not have to be carried in a chemical tanker. A second category of cargoes consists of

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