Lng Vessel Safety Zones

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LNG Vessel Safety Zones

Safety Zones for LNG Carriers In Atlantic Canada Purpose: ...............................................................................................................2 Background:..........................................................................................................3 Scope of control zones: ........................................................................................6 Exclusion zone...............................................................................................6 Application ............................................................................................................9 Justifications......................................................................................................9 Threats ............................................................................................................12 International ....................................................................................................14 Local Situation:................................................................................................17 Options ...............................................................................................................19 Option A ..........................................................................................................19 Option B ..........................................................................................................20 Option C ..........................................................................................................22 Conclusions ........................................................................................................23 Annex A:..........................................................................................................25 A presentation for the Atlantic LNG and CNG Symposium, June 27 and 28, 2005, Halifax, N.S.

Opinions or assertions expressed in this paper are solely those of the author and do not necessarily reflect the views of the Government of Canada.

Transport Canada Marine Safety Atlantic Region Prepared by Richard Cobanli

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LNG Vessel Safety Zones

Purpose: This paper has been prepared to discuss safety zones for LNG carriers operating to and from the proposed Atlantic Canadian LNG receiving terminals. The requirement for this paper evolved from the work of the TERMPOL Technical Review Process (TRP) in order to satisfy marine safety requirements and provide direction to project proponents and other stakeholders. To achieve this objective, research into the activities and requirements of other ports and regions was conducted with findings appropriately noted. Further, this research sought to determine if any changes were necessary to ensure safe navigation, secure operations and compatibility with functioning of other facilities established in the region. As a conclusion to this work, options are presented that either maintain, augment or supersede existing procedures and protocols for vessel operations in the region. The optimum solution will provide for a reasonable, practical system of safety zone controls for large vessels to ensure the safest possible passage of all vessel traffic using the region’s waterways, harbours and ports.

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LNG Vessel Safety Zones

Background: While a new venture in Canada, the marine transportation of LNG is a mature industry sector worldwide with a fleet of over 1000 specialty vessels serving a network of export and import terminals. Vessels have become significantly larger while technology has advanced in every aspect of design, engineering, construction and operations. Current standard vessel sizes of 135K cubic meters cargo capacity will give way in a few short years to vessels reaching 250K cubic meters. All new terminals proposed in Canada are being designed to accommodate these new larger vessels. Being a new and still unfamiliar industry in Canada, LNG shipping and its unique characteristics are subject to a great deal of attention as the Canadian marine industry and society seeks to better understand the transportation issues for this prized energy source. Transport Canada Marine Safety (TCMS) is committed to promoting robust safety standards for the shipping industry commensurate with the risks associated with the marine transportation of LNG. In harmony with other government agencies sharing responsibilities for the analysis of environmental, operational and social risks and benefits arising from the construction and operation of a new facility, TCMS is focused on safety of navigation and marine pollution prevention through a detailed marine risk assessment called TERMPOL.

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LNG Vessel Safety Zones “The ‘Technical Review of Marine Terminal Systems and Transhipment Sites’ (TERMPOL Technical review process) focuses on a dedicated design ship’s selected route in waters under Canadian jurisdiction to it’s berth at a proposed marine terminal or trans-shipment site and, specifically, to the process of cargo handling between vessels, or off-loading from ship to shore or visaversa.” “The intent of the TERMPOL is to ameliorate, where possible, those elements of a proposal which could, in certain circumstances, threaten the integrity of the ship’s hull and its cargo containment system and consequently, the environment in the vicinity of the design ship when navigating in waters under Canadian jurisdiction.”1

Through conducting a TERMPOL TRP and environmental assessment process prior to issue of the necessary permits, the subject of safety and security exclusion zones have been identified as needing deliberation and definition. Application of safety, security or exclusion zones are found at every port and terminal to some degree however, their rational, scope and application vary considerably. SIGTTO, an association of ship and terminal operators dedicated to safe and reliable operation within a sound environment2, defines safety zones.

“…an area of sea space is established around the tanker into which no other traffic is permitted to enter. Hence the tankers progress will never be immediately hindered by encounters with other traffic, nor will it encounter traffic having the potential to penetrate its hull. The dimensions and shape of an exclusion zone should be determined in the context of the specific conditions of the port.”3

1

TERMPOL Review Process 2001, Transport Canada TP743E, part 1 SIGTTO mission statement 3 LNG Operations in Port Areas, Best Practises for the industry, SIGTTO, Witherby’s Publishing, 2003, p15 2

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LNG Vessel Safety Zones

In Canada, seven LNG receiving terminal projects are presently at various stages of design development, approval and construction. This paper was initiated based on the circumstances surrounding safe navigation and operation at the projects under review in Atlantic Canada. The proposed locations are, for the most part, heavily industrialised with existing oil terminals, gypsum, coal, aggregates, paper, forest products and other general cargo imported and exported to and from the region. Shipping details and patterns have been reviewed in the proponent’s project scoping and Environmental Assessment documents and therefore will not be revisited in this paper. In support of safe navigation for all marine traffic serving the industrial import and export activities in the region, vessel traffic control systems (VTS) have been in place for many years. There are also established IMO adopted traffic separation routing schemes in the approaches and entrances to most proposed ports. All vessels greater than 20m LOA are required to comply with and participate in the systems. The ports and approaches are compulsory pilotage zones (with one exception) served by the Atlantic Pilotage Authority for Canadian vessels over 1500 GRT and all foreign vessels however, subject to certain exceptions as described in Annex A. Therefore, with few exceptions, all marine traffic in the region is well monitored and controlled by Coast Guard and marine pilotage services.

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LNG Vessel Safety Zones

Scope of control zones: The terms safety zone and exclusion zone have been liberally applied in many arenas without a uniform appreciation of what they are or the implications of such. Generically, safety zone best describes the regulated or controlled space around a ship when in transit, at an anchorage or alongside the pier. From the TCMS publication “Routing Standards TP 1802”, definitions are provided as they deal with routing systems. Routing systems developed under this standard may or may not be adopted by the IMO, however, if they are IMO adopted, they then become part of the international program of ship routing systems. IMO adopted routing systems exist in the approaches and entrance to the Bay of Fundy and Chedabucto Bay. While not directly applicable in the two specific VTS systems noted the following definitions are taken from the quoted publication for consideration when assessing the requirement and scope of any safety zone. Exclusion zone An exclusion zone is an area within defined limits which is prohibited for certain ships to keep them far enough offshore to give sufficient time to rescue a disabled ship from going ashore and to protect the coastline from any pollution caused by a casualty. Security Zone A security zone is a defined area, which for safety and environmental purposes access is limited to persons, ships or objects authorized by the Coast Guard. Such a zone may be stationary and

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LNG Vessel Safety Zones described by fixed limits, or it may be described as an area around a ship or object in transit.4

The conduct of vessels within an adopted traffic separation scheme and routing system is governed by the Collision Regulations globally as well as in the subject regional waters with the addition of Canadian modifications. All vessels entering Canadian waters must be familiar with the requirements and carry complete information respecting the local systems, routes and procedures as they would for any port visited elsewhere. Canada

Standards

Association

C-Z276

“establishes

essential

requirements and minimum standards for the design, installation, and safe operation of LNG facilities” however does not address the marine shipment of LNG. It does require that a dock used for the transfer of LNG to or from a ship must be no less than 30 meters from any bridge crossing a navigable waterway and the loading / unloading manifold is no less than 61 m from such a bridge.5 From the USA statutes 33CFR-165 (the regulations dealing with regulated navigational areas), definitions provide clarification on the types of zones that are applied in US waters and under the jurisdiction of the USCG. Safety Zones “ A safety zone is a water area, shore area, or water and shore area to which, for safety and environmental purposes, access is limited to authorized persons, vehicles, vessels. It may be stationary and described by fixed limits or it may be described as a zone around a vessel in motion”

4 5

TCMS Publication #TP 1802, Routing Standards 1991 CSA Z-276, July 2003.

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LNG Vessel Safety Zones Security Zones “(a) A security zone is an area of land, water or land and water which is so designated by the captain of the port or district commander for such time as is necessary to prevent damage or injury to any vessel or waterfront facility, to safeguard ports, harbours and territories, or waters of the United States or to secure the observance of the rights and obligations of the United States. (b) The purpose of a security zone is to safeguard from destruction, loss or injury from sabotage or other subversive acts, accidents, or other causes of a similar nature: (1) Vessels, (2) Harbours, (3) Ports, and (4) Waterfront facilities: In the United States and all territory and water, continental or insular, that is subject to the jurisdiction of the United States.”6

In the above definitions please note the distinction between safety and security although the spaces described are essentially the same. The regulations arising from these definitions allow the USCG ‘Captain of the port’ (COTP) or District Commander’ the authority to make rules for the application of controls or restrictions on vessel movements in waters, harbours and roadstead, at anchorage and alongside the pier.

6

USA statutes 33CFR-165

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LNG Vessel Safety Zones

Application The application and scope of controlled zones for LNG vessels has been diverse in different jurisdictions depending on the calculated risk. One has only to look at ports such as Boston, USA and Barcelona, Spain to see the range of safety zone controls applied to LNG carriers and other traffic transiting and using LNG facilities and adjacent waterways. For example, in brief, the port of Boston restricts all other traffic movement in the area, closes overlying road bridges and adjusts flight paths for aircraft approaches to and from the nearby international airport. Additionally, the USCG provides, at cost, aerial and marine escort and surveillance throughout the harbour passage and port turnaround period of an LNG carrier at the Everett terminal. On the other hand, traffic movements in the port of Barcelona continue as normal regardless of the presence of an LNG carrier.

Justifications The determination of need for safety zones can be broken into three specific themes however; the application is essentially the same. Ultimately, the function of the zones is to maintain the integrity of the vessel, terminal, community, personnel and other neighbouring facilities, places or vessels operating in or transiting through adjacent waters.

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LNG Vessel Safety Zones

1. Safety zones can be established for navigation safety when underway in transit as addressed through the use of traffic separation schemes, vessel traffic control systems and the isolation of vessels underway, anchored or berthed. The intent is to create an appropriately sized space around the vessel to minimise the risk of hindrance from or collision with another vessel or grounding.

2. The next safety zone application is for the protection of both adjacent property, personnel and vessels from accidental or operational spill or other unplanned events such as cargo leakage as well as elimination of ignition sources from the leakage and spill areas. For example, the release of LNG overboard with the resulting cryogenic issues, vaporisation and risk of pool fires would be detrimental to health and safety of passing craft up to a calculated plume dispersion distance. Therefore imposition of a safety zone for the protection of all things and people external to the ship may be considered. Application of safety zone in this case would provide protection for small vessels, fishing craft, yachts, tugs, service craft and any other vessels likely to pass at a close distance. Elimination of potential ignition sources within the plume

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LNG Vessel Safety Zones area is also a critical factor in determining this safety zone for the vessel alongside the pier and at anchorage.

3. Security zones can be applied to vessels to create a sterile area around a vessel for security purposes. Prohibiting any vessels, vehicles or personnel within a defined area when underway, anchored or alongside provides a visible buffer whereby anyone entering could be considered entering for the purpose of terrorism or other malicious intent. This type of security zone must be actively enforced if it is to have any effect and does go beyond the normal scope of vessel operations. Security zones could be applied under the requirements of a port or ship security activation of MARSEC levels 2 or 3 under the ISPS code. The intent of a security zone would be to ensure a space around the ship is maintained as a buffer or no-go zone in order to minimize the likelihood of any undesirable entity contacting the vessel. The security zone for potential targets such as LNG carriers, allows for an intervention period against the approaching vessel or craft such as in the case of a military vessel secured alongside a pier at a naval base maintaining an active security perimeter with on-water patrols. This requires an intervention capability such as high-speed small craft, police, military etc. The determination of the security zone will be

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LNG Vessel Safety Zones carried out during the proponent’s security assessment and planning exercise leading to ISPS certification of the terminal by the TC Security directorate.

The overall rational is simply safeguarding a cushion or buffer zone around the vessel. The conventional approach to this solution is through the use of VTS and separation zones, compliance with Collision regulations, compulsory pilotage, escort and assist tugs and development of operational manuals with predetermined decisions satisfying urgent and emergency situations. Therefore, the requirement and scope for safety zones around LNG carriers or other vessel traffic in the subject area is brought into question.

Threats Two scenarios drive the threats to vessel or environment. The first deals with an accident or incident related to ship operation such as grounding, collision, onboard or terminal deficiency; while the second threat category relates to an external threat such as terrorist or other subversive activities such as bomb, missile, pirate actions, ramming, etc. Operational threats can be mitigated through controls, monitoring and corrective actions. These components would be consistent with other shipping in the area such as VLCC and ULCC traffic also using the same waterway.

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LNG Vessel Safety Zones Similarly, an additional threat to local interests results from an operational or accidental leak including those that may be relatively minor in nature. A leak of LNG puts workers, crews or passing vessels at risk of exposure to the cryogenic LNG. This event presents a serious risk of injury, death or structural failure of the vessel due to the rapid cooling on contact and the absorption of heat away from contacted bodies as the LNG flashes off to vapour and the likelihood of the vapour cloud contacting an ignition source prior to dispersing into the atmosphere. The vapour dispersion patterns and risks are thoroughly addressed in the project proponent’s Environmental Assessment documents. Safety zones provide a buffer around the ship and facilities to protect people and assets from this potential however low it may be.

The recently released SANDIA Report concludes that: Due to the existing design and equipment requirements for LNG Carriers, and the implementation of navigation safety measures such as traffic management schemes and safety zones, the risk of accidents is generally low. The most significant impacts to public safety and property from an accidental spill exist within approximately 250m of a spill, with lower impacts at distances beyond approximately 750 m from a spill.

The potential breaching of an LNG cargo tank due to an accident, such as a collision or grounding, appears to be minimal. Such a breach can be easily reduced through a number of operational mechanisms, including managing ship traffic, coordinating ship speeds, and by active ship control in inner and outer harbours where the consequences of a potential LNG spill might be most severe… Therefore, the safety and hazard issues that can lead to an accidental breach appear manageable with current safety policies and practices.7

7

SANDIA Labs report 2004, p

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LNG Vessel Safety Zones The second threat scenario, which describes the intentional subversive, malicious or terrorist act on the vessel, would only serve the perpetrators cause if there were a significant public or economic impact resulting from their actions. The facilities in Atlantic Canada being remotely located offer little value to this end as compared to other facilities in populated or industrialised areas such as the Distrigas Corp. terminal in Boston. Therefore a reasonable observation respecting the threat of an intentional act against a ship in Atlantic Canada would be that, it may be unlikely and of little value. However, the proponent’s preparation of an approved security assessment and security plan under the requirements of the ISPS Code and Canadian Marine Transportation Security Act and regulations would confirm the nature and scope of any security threat exposure on facilities and calling vessels.

International Research for this paper included an Internet review of international LNG information sources, port contacts and anecdotal accounts from personnel working in the industry. Several contacts have been established within the industry that will continue to serve in supporting further dialogue, research and analysis. With few exceptions, the international approach to safety zones for LNG carriers is not substantially different from other large tonnage vessels. Navigation safety is the core issue surrounding the isolation of vessels in transit by way of a

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LNG Vessel Safety Zones safe zone around the vessel. Security requirements, if different, are addressed through the ISPS Code security plan requirements for ships and ports and would be invoked when heightened security is required during MARSEC levels 2 or 3. The American approach, given the high threat level exposure of their facilities and society includes significant security protocols, in addition to the basic navigation safety parameters described. US legislation through 33CFR 165 places a responsibility on the USCG Captain of the Port or District Commander to identify the threats and risks, and implement operational and geographic controls that defuse the perceived threat for the particular port, approaches and vessels. This authority extends to include controls (through cooperation with other responsible authorities) on adjacent areas that may allow access to the target vessel such as road bridges, adjacent lands, airspace, and marine waterways. Extensive monitoring and patrol form an integral part of that regime. Further examples of safety and security zone applications in US ports include the following: •

Cook Inlet, Alaska export terminal maintains a 1000 Yard radius zone around its terminal and berthed ships. Ships transiting to and from the terminal are protected by a 1000 Yard radius zone;



Boston (Everett terminal) ships in transit are escorted with a safety and security zone extending 1000 yards fore and aft and 100 yards each side;



Cove Point, Chesapeake bay maintains a 500 yards radius zone around the full extent of its large terminal and ships alongside;

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LNG Vessel Safety Zones



Savanah River, Elba Is terminal is located in a narrow channel and so presents a greater challenge. Ships less than 1600 GRT are not to approach closer than 70 yards while larger ships must have two tug escort throughout their passage in the area of the terminal.

Other international jurisdictions such as those of Western Europe, Britain and Australia have not pursued the American model for safety and security zones in their import and export trade of LNG or other hydrocarbons. National legislation for safety zones is dealt with as in Canada with traffic control and separation systems. Local requirements for safety zones are dealt with by the harbour authorities in their own port specific procedures, manuals and systems. Each port will perform a risk analysis and develop operations rules based on the findings of the assessment. For example, the UK port of Milford Haven maintains a moving exclusion zone around LPG vessels over 20,000 GRT. All ships lying alongside any hydrocarbon berth enjoys a 100 m exclusion zone. The risk analysis conducted determined controls for ship types, size and cargo hazard potential therefore, all ship types and cargoes are considered in the analysis.

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LNG Vessel Safety Zones Local Situation: The proposed Atlantic Canadian sites are in relatively remote locations adjacent previously industrialised areas and natural accessible ports. The approaches are deep and wide however, as the course of the waterway leads to the inner reaches of the harbours, the waters become relatively sheltered while the predominant winds tend to follow the alignment of the shipping channels and proposed wharf facilities. The sites enjoy many natural characteristics as well as infrastructure components that contribute to their suitability for large vessel shipping. A variety of vessels including many general cargo, dry bulk, and tankers up to ULCC in size visit the region regularly. Existing controls effecting the safe operation and traffic flow in the region have been determined to be adequate for the existing volume and type of shipping. Future changes in frequency, type and size of ships and introduction of new cargoes and their inherent characteristics are presently under review as part of the TERMPOL review and environmental assessment process and will define any required changes needed to ensure continued safe operations. Pilotage in the region, where compulsory, is by way of experienced pilots engaged by the Atlantic Pilotage Authority. Local pilotage practice includes slotting traffic in the narrow stretches of a waterway so as to avoid passing, overtaking or close proximity meeting of large vessels. Timing of ship movements

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LNG Vessel Safety Zones is planned and scheduled to ensure availability of pilots and the least potential for conflict of vessels manoeuvring in the stream. Deployment of tugs for escort, berthing and departure of vessels are controlled by the pilots in order to support their planned ship movements. Tug availability is presently aligned to local need and will require an increase in number and capability to manage several additional large vessel movements within a port area. Additional tug capacity will be required to stand-by for emergency or heavy weather requirements particularly when two or more large vessels are in the port area at the same time. In addition to the procedural and communications protocols in place to support local shipping, an extensive buoyage and beacon system has been in place for many years. Leading lights and ranges mark the navigation channels entering and leaving these ports. Prior to opening the LNG import terminal, a review of terminal lighting will be required to ensure the piers are adequately marked for navigation in the area and so that terminal lighting does not interfere with other navigation aids, beacons etc serving the navigational channel. Existing regulations, procedures and guidance notes are provided through Notice to Mariners and other Canadian and International publications. These sources provide critical quality information respecting the traffic control, separation, and monitoring systems, communication and guidance information for Mariners. Safety and security information including threats, traffic reports, vessel movement controls etc. are currently distributed using these systems and

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LNG Vessel Safety Zones will be fundamental in the application of any safety or security zones applied to transiting, anchored or berthed vessels.

Options The approaches to the regions proposed LNG receiving facilities already enjoy an established network of navigational controls put in place for existing oil, dry bulk, paper, general cargo and other import and export shipping. An analysis of shipping traffic in the area of each proposed project is contained in the proponent’s environmental assessment submission. Navigation and operation of LNG carriers in the region shall be in accordance with international and Canadian legislation. In addition, local pilots serving all compulsory pilotage vessels in the area have established protocols for the movement of vessels through the region. The following options are presented for discussion and represent a range of solutions for the safety zone question.

Option A The Chedabucto Bay, Strait of Canso and Bay of Fundy VTS and traffic separation systems already support a significant volume of shipping traffic serving several facilities in their areas including a variety of large and very large tankers. The existing navigation support systems in place address the requirements of the current volume and nature of traffic. As a first option for

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LNG Vessel Safety Zones consideration, no changes are made to the existing systems. In this option, the increase in shipping traffic volume is absorbed into the mix of vessels with no additional measures taken to isolate or minimize risks of grounding or contact / collision. The existing systems would apply equally to all forms of future shipping including the passage of laden and light LNG carriers through the region. Given the significant increase in traffic movements, the size and handling characteristics of LNG carriers and the hazardous nature of the cargo carried, this option may not be a viable solution.

Option B The suggestions in this option are made to formalise and augment the procedures for all vessels transiting and operating in the subject region. These suggestions are provided for existing traffic in addition to the new LNG carrier traffic in the region, as the requirement for safe vessel traffic management will impact on all vessels equally. The following procedures could apply to all large vessels such as, for example, those over 10,000 GRT when navigating in the region and all vessels regardless of size operating in the vicinity of LNG carriers, and other large traffic such as VLCC and ULCC traffic. 1. LNG vessels will execute a normal sea passage to Canadian waters, the approaches to proposed harbours and in accordance with the local traffic separation scheme and VTS;

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LNG Vessel Safety Zones 2. Pilot will embark at the outer pilot station and conduct the vessel within the parameters of the VTS and traffic separation system to its inbound end; 3. Normal passage under pilot guidance throughout the approaches and harbour manoeuvres; 4. Single vessel passage in inner harbour, narrow channels or restricted areas. No vessels are permitted to pass or overtake in the course of this passage. 5. Active tug escort including tug assist with a suitable number of high capacity tugs during inner harbour manoeuvres and to the berth (to be determined from modelling conclusions and subsequent design ship analysis) 6. Minimum of 1 mile fore and aft distance between vessels transiting in same direction; 7. Restrict all vessel movements during LNG carrier berthing, turning and departure; 8. Minimum passing distance from an LNG carrier at anchorage and alongside the unloading terminal pier should be 250m* for any other vessels while in transit; 9. VTS control shall broadcast a local notice to shipping regarding the operation of LNG or other very large traffic in the effected waters including notice of passing distances and restrictions.

*

250 m suggested based on minimum safe distance conclusion in SANDIA report.

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LNG Vessel Safety Zones

Formalization of existing pilotage practises and development of a port operations manual including the above basic parameters would provide a reasonable and practical approach to safe vessel operation in the subject waters with a minimum impact on the movement of existing traffic.

Option C This option presents a more extreme approach similar to the USCG protocols in certain US ports whereby navigation safety is overlaid with extensive security precautions. The purpose being to prevent access to the LNG vessel throughout its passage and visit in Canadian waters through absolute isolation. A high security approach to a safety zone for an LNG carrier could include suspension of all traffic in the area during the passage of the LNG vessel to and from the terminal. This exclusion could extend seaward to the pilot station or beyond. Given the relatively narrow channels adjacent the proposed terminals, the shipping channels could be closed during the presence of the LNG carrier. The unfortunate consequence of this high level of control is its negative impact on other shipping in the region. Further, to be effective, this level of control requires significant and onerous investments in monitoring, patrol and enforcement as mentioned previously for the Distrigas Corp terminal in Boston

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LNG Vessel Safety Zones Through proper analysis, evaluation of risks and preparation of the required port and ship security plan, a lesser level of security threat during normal operations would likely make this degree of control unnecessary and undesirable.

Conclusions Through the course of this paper the rationale for safety zones has been explored as they relate to LNG carriers calling at the proposed Atlantic Canada LNG receiving terminals. Critical infrastructure supporting the safe movement of vessel traffic in the region has been well established for many years and will serve as the foundation upon which any future activities or systems may be built. Safety zones are presently exercised through compulsory pilotage, VTS, traffic separation and communication systems. The American model is security based with active controls on all vessel, vehicle and personnel movements. While port specific in its application, rules for harbour safety and security zone controls emanate from national regulation. Some facilities are located in populated areas resulting in a much higher threat exposure that must be dealt with through enhanced controls. Safety zones in other international jurisdictions are applied as required following a risk analysis of each ship type; size and cargo thus are not limited to LNG carriers exclusively. The primary function for both safety and security zones

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LNG Vessel Safety Zones is to maintain a buffer zone around vessels allowing time for mitigating or evasive actions to be taken when difficulties are encountered. The determination of an appropriate safety zone or other operational measures, for LNG and other traffic in the area must consider the impact on other port and waterway users. Thorough consultations with stakeholders will be critical. Broad based risk analysis, modelling and development of operations and contingency manuals are essential for developing measures for the safe movement of marine traffic. Safety and / or security control zones should only be applied on a case-by-case basis when a real need has been identified and they will enhance the safety and efficiency of all operations and movements in the area.

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LNG Vessel Safety Zones Annex A: An Extract from Pilotage Regulations for Atlantic Pilotage Authority.

Ships Subject to Compulsory Pilotage 4. (1) the following ships or classes of ships are subject to compulsory pilotage within the areas referred to in section 3: (a) Canadian registered ships of more than 1,500 gross registered tons, except (i) Canadian government ships, (ii) ships employed in catching or processing fish or other living resources of the sea, and (iii) ferries that operate on a regular schedule between two terminals, manned by (A) Canadian masters and officers, or (B) masters and officers who are permanent residents; (b) ships not registered in Canada, except (i) pleasure yachts of less than 500 gross registered tons, and (ii) tugs of less than 500 gross registered tons, manned by Canadian masters and officers;

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LNG Vessel Safety Zones (c) floating oil rigs; (d) floating cranes not registered in Canada; and (e) any combination of tug and tow, where more than one unit is being towed without regard to gross registered tonnage. (2) Notwithstanding paragraph (1)(a), Canadian registered pleasure yachts of more than 500 gross registered tons are subject to compulsory pilotage within the areas referred to in section 3. (2.1) Notwithstanding subsections (1) and (2), a ship that is not over 223 m (731.62 feet) in length is not subject to compulsory pilotage (a) in the Cape Breton compulsory pilotage area (Zone D, Strait of Canso); or

Transport Canada Marine Safety Atlantic Region Prepared by Richard Cobanli

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