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Review of ship safety and pollution prevention measures in the Great Barrier Reef

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3. EXTENSION OF THE COMPULSORY PILOTAGE AREA

3.1 The presence of a pilot on board can enhance the safety of the vessel when it is in confined waters. Pilots provide expert guidance for a vessel through navigationally hazardous parts of the coast or into and within ports.6 A pilot is expected to have highly developed navigation and ship handling skills, as well as intimate knowledge of the local area and its environment. Carriage of a pilot, however, does not relieve the ship's Master from his overall responsibility for the safe operation of the vessel.

3.2 The pilotage area along the Queensland coast falls into three distinct parts (see Figure 3.1):

3.3 There is no pilotage requirement on the Outer Route, and no licensed commercial services are provided, as it is not navigationally challenging and lies within international waters.

3.4 In 1990 the IMO determined that the GBR met its stringent ecological criteria for declaration as a Particularly Sensitive Sea Area and endorsed associated special protective measures. One of these measures was the introduction in October 1991 of the compulsory pilotage regime on the northern part of the Inner Route. At the same time, IMO endorsed the recommended pilotage regime for the Torres Strait and Great North Eastern Channel. This ensured that Australia had effective jurisdiction to implement pilotage requirements on foreign flag ships in our territorial waters without imposing on their right to innocent passage under international law.

3.5 The current compulsory pilotage requirement is given effect under the Great Barrier Reef Marine Park Act 1975. This requires specified vessels to carry a licensed pilot when taking passage through the inner route, specifically between Cape York (latitude 10 degrees 41' south) and the vicinity of Cairns Roads, north of Cairns (latitude 16 degrees 40' South) or when passing through Hydrographers Passage or within the Whitsunday Islands. The requirement applies to all vessels of 70 metres or more in length and all loaded oil and chemical tankers or liquefied gas carriers of any length. Cruise vessels in the Whitsunday Islands also must carry a licensed pilot.

3.6 In the Torres Strait and Great North East Channel, ships of the same length and types as covered by the GBR compulsory pilotage regime are recommended to carry a licensed pilot. It is currently estimated that around 45% of ships to which the IMO recommendation applies proceed unpiloted in this part of the GBR region.8

Where can pilotage reduce risk?

3.7 Over the past 16 years, there were averages of 1 shipping incident per year on the Inner Route North, and slightly less than 0.6 per year on both the Inner Route South and Torres Strait. The DNV risk assessment indicates that the greatest risks of incidents, on a per nautical mile basis, arise in the Torres Strait and the Inner Route North. Incident risks decrease significantly as vessels travel southwards on the Inner Route, proportional to the lessening difficulty of navigation.9

3.8 Powered groundings, and to a lesser extent collisions, are the types of incidents where the influence of a pilot could be expected to improve safety. The DNV analysis indicates that the occurrences of these types of incidents are highest in Torres Strait and the Inner Route North, with Torres Strait being the dominant contributor of powered groundings. All but one of the collision incidents involved a trading ship-fishing boat collision, due to the prevalence of fishing vessels in the area, notably on the Inner Route North.

3.9 DNV estimates decreases in risk can be achieved by 100% compulsory pilotage cover in Torres Strait and the Inner Route South, but that the benefits are more clearly evident in Torres Strait, where risks can be reduced by 35%. DNV concludes that pilotage may not be needed on the Inner Route South as it is not navigationally challenging. DNV also cautions that the estimates of risk assume a constant effectiveness of a pilot on board and that extension of a pilot's duties to the continuous passage of the Inner Route would no doubt compromise his effectiveness through fatigue.

3.10 Conversely, the assumption that the mandatory use of pilots will help to avoid marine incidents has been questioned.10 Pilots have been present during 16 of the 43 (37%) incidents that occurred in the GBR during 1995-2000. Six of the seven serious groundings in the inner route over the past five years were caused by human error, and the remaining one by mechanical failure. Six of those grounded had a coastal pilot on board at the time.

3.11 However, more detailed analysis of grounding incidents indicate that while vessels that have grounded were under pilotage, crew errors were the greatest factor in the incidents by a large degree.11 On balance, a coastal pilot on board is seen as a positive risk mitigation measure against collision or grounding, however a pilot will not eliminate the potential for such incidents to occur.12

Proposals to Extend Compulsory Pilotage

3.12 Following the grounding of the container ship Bunga Teratai Satu south of Cairns in November 2000, outside of the compulsory pilotage area, there were calls for compulsory pilotage to be extended for the entire length of the Great Barrier Reef Marine Park. It has been suggested that a blanket approach of this nature, with appropriate safeguards written in for effective pilotage, would instil recognition of the importance of the GBR and Torres Strait to the maritime industry worldwide.13

3.13 Specific proposals have been considered for:

Torres Strait

3.14 There has been strong support for the introduction of compulsory pilotage in the Torres Strait, where many shipping incidents have occurred and where the demand for accurate navigation is more exacting.14 Channel depths and widths are limited and there are some awkward "dog legs" to negotiate. The area is subject to strong tidal currents, and complex tidal patterns due to the confluence of two oceans systems. Careful calculation of tidal windows is required for passage by deep draft vessels.

3.15 The review notes the DNV risk assessment study concludes that compulsory pilotage would significantly reduce the risk of a shipping incident in the Torres Strait.

3.16 Due to concerns about rights of transit passage through international straits, however, implementing compulsory pilotage for the Torres Strait poses complex questions of international law and foreign relations.

3.17 Under Articles 38-44 of the UN Convention on the Law of the Sea (UNCLOS), ships of all nations enjoy the right of transit passage through international straits, which shall not be impeded. A coastal State has a right to designate sea lanes and traffic separation schemes through an international strait, and to adopt laws relating to the safety of navigation. However, such laws shall not have the practical effect of denying, hampering or impeding the right of transit passage.

3.18 Many IMO member States are adamantly opposed to the concept of compulsory pilotage regimes within international straits, as they regard it as a clear contravention of UNCLOS provisions. Accordingly, action to extend compulsory pilotage in an international strait, which requires the approval of the IMO, is likely to be a difficult and time consuming process.

3.19 Nevertheless, the review supports sustained efforts through the relevant channels to elevate the status of Torres Strait, including the Prince of Wales Channel and Great North East Channel, from recommended to compulsory pilotage. It is considered that the prospects for persuading the IMO to adopt compulsory pilotage would be enhanced if Torres Strait is included in the IMO designated Particularly Sensitive Sea Area for the Great Barrier Reef. Torres Strait shares many of the same environmentally important features and has similar importance to indigenous populations as the GBR.

Recommendation 6
The review recommends that Australia should immediately initiate the process for seeking endorsement by the IMO for upgrading the current recommended pilotage area in the Torres Strait to compulsory pilotage and an extension of the Great Barrier Reef Particularly Sensitive Sea Area to encompass the Torres Strait to support introduction of compulsory pilotage.
Recommendation 7
In the interim, the review recommends a concerted campaign be conducted by AMSA and Queensland Transport to reinforce the existing recommended pilotage regime for all applicable ships transiting the Torres Strait. This could include notes on charts, reinforcement in Reef Guide, an international education campaign and advice by the Ship Reporting System to all ships operating in the region.

3.20 Intermediate measures to encourage the greater usage of pilots in Torres Strait could also include exploration of economic options and incentives.

3.21 The review notes that this would necessitate a complete restructure of AMSA levies to ensure that, while providing an encouragement to use pilots, the overall and distributional impact on the shipping industry is fully justified.

3.22 As well, consideration could be given to banning ships from Australian ports if they do not comply with the IMO recommended pilotage regime for Torres Strait. It could reasonably be expected that ships that do not comply with the IMO recommendation are those at the lower end of the market and represent a greater risk of an incident. While any such ban would only be enforceable on ships that intend using an Australian port, it would nevertheless help to reduce the numbers of vessels transiting Torres Strait without a pilot, pending development of an IMO agreed compulsory pilotage regime for all ships in the region.

3.23 To ensure the broadest possible coverage of ships transiting Torres Strait and proceeding to ports other than those in the Great Barrier Reef region, agreement from all State and Northern Territory Governments should be sought through the Australian Transport Council

Recommendation 8
The review recommends that consideration be given to raising at the Australian Transport Council the proposal that any vessel transiting the Torres Strait and arriving at an Australian port will not be given access at that port unless a pilot was used throughout the passage through the Torres Strait.

South of Cairns

3.24 Extension of compulsory pilotage south of Cairns to the southern limit of the Great Barrier Reef will approximately double the length of pilotage for vessels proceeding to or from southern ports. Navigation in this part of the GBR is relatively straightforward, with wider channels and relatively sheltered waters (see Figure 3.2). There is more sea room for corrective actions against unexpected developments, and competent watch-keeping officers would have little difficulty in navigating this area.15

3.25 Accordingly, it has not previously been considered necessary to mandate pilotage in this region. However, as there are a number of significant course changes required for safe passage, the Reef Guide recommends pilotage for masters who are unfamiliar with the region, for added safety.

3.26 Palm and Grafton Passages have a similar profile to the area south of Cairns with plenty of sea room and assistance from navigation aids. The risk of incidents and the estimated benefits of risk reduction through pilotage are relatively low in the Passages. However, these areas could be serviced by pilotage providers, given their proximity to the existing pilotage service area and support base in Cairns, although some additions to infrastructure and equipment would be required.16

3.27 The review notes the DNV risk assessment study concludes that compulsory pilotage would only marginally reduce the already small risk of an incident in the Cairns to Townsville sector of the Inner Route South, given the low degree of navigational difficulty in this region. Conversely, DNV warn that extension of compulsory pilotage in this area has the potential to exacerbate pilot fatigue and raise pilotage costs with little commensurate benefits in reduced incidents.

3.28 The main danger area in this stretch is Sudbury Reef. AMSA has received 5 incident reports over the past twelve months of vessels that failed to make the 26 degree course change to the south after dropping the pilot at Cairns and were in danger of running on to Stagg Patches, Sudbury Reef or Scott Reef.17 Once clear of Sudbury Reef, the remainder of the route Cairns-Townsville is almost entirely straight with one course alteration of 32 degrees. Ships have plenty of sea room and few navigational hazards.

3.29 The shipping industry and practising mariners do not support an extension of compulsory pilotage in this region. Practising pilots also do not support an extension of compulsory pilotage from a navigational perspective. Several submissions raised concerns about exacerbating pilot fatigue, which has been a contributing factor to a number of incidents in the existing compulsory pilotage area.18

Recommendation 9
The review recommends the promulgation of a recommended pilotage regime through IMO for the inner route and the entrances to Palm and Grafton Passages.

3.30 Implementation of a pilotage regime for Palm and Grafton passages will require the development of proposals for provision of such services by pilotage providers. AMSA and Queensland Transport will need to consider the requirements for practical application of a pilotage regime for the passages, in consultation with pilot providers.

3.31 The review also supports immediate action by AMSA, GBRMPA and Queensland Transport to implement a package of other safety measures covering the southern part of the Inner Route, as outlined elsewhere in this report.

3.32 The Review noted with concern that there have been five cases in the past 12 months similar to the Bunga Teratai Satu, involving other vessels which have failed to make the course alteration at Fitzroy Island. In these cases a grounding has been averted as a direct result of advice provided by REEFCENTRE or by the crew.

3.33 The review notes the high number of track violations in the area of Fitzroy Island, and the sensitivity associated with Stagg Patches and Frankland Islands. The Frankland Islands area is a highly protected zone within the Marine Park. There are reduced navigation difficulties and associated hazards south of the Frankland Islands, and navigation is further simplified by ensuring that vessels transit outside (to the east) of the Whitsunday Islands group.

3.34 The review considers that an appropriate option is to extend pilotage to or from the Inner Route north of Cairns past the Frankland Islands, to a point off Mourilyan (see Figure 3.3). This is a relatively short additional steaming time from the present pilot boarding ground off Cairns and would not add to fatigue. It also has the advantage of having a port with berths for pilot boats and an airport at Innisfail for helicopter and pilot access. The launch trip from Mourilyan to board a ship would take about 20-30 minutes.

Recommendation 10
The Review recommends that ships transiting the inner route of the GBR north of Cairns should be required to embark or disembark pilots at a new pilot boarding ground off Mourilyan.

3.35 Any more substantial extension of compulsory pilotage on the Inner Route South should not be mandated without a clear and enforceable fatigue management system in place.

Whitsunday Islands

3.36 The Queensland Government submitted its strong support for compulsory pilotage for the Whitsunday Islands area, given its navigational difficulties, density of traffic and environmental sensitivity. The shipping route through Whitsunday Passage is used by a large number of local charter and recreational vessels, creating higher risks of collisions due to the high levels of cross-traffic.19

3.37 Recent studies20 also recommended the introduction of compulsory pilotage arrangements for the Whitsunday Islands for cruise shipping. Under the GBRMPA Whitsundays Management Plan, which has been in place since October 1999, cruise ships already are required to carry pilots to comply with their GBRMPA permit to operate in the area. On 19 July 2001, the GBRMPA declared it illegal for ships carrying oil, chemical or liquefied gas cargoes or for vessels over 70 metres in length to traverse Whitsunday waters without an Australian accredited pilot (Figure 3.4).21

3.38 As this area comprises internal waters within the GBR over which the Queensland Government has jurisdiction, subject to the operation of the Great Barrier Reef Marine Park Act 1975, compulsory pilotage could be further extended under Queensland legislation by declaration of a Pilotage Area under the Queensland Transport Operations (Marine Safety) Act 1994. This will have a wider effect than is achieved under the GBRMPA legislation for compulsory pilotage, as it will also apply to vessels smaller than the 70 metre size covered by the GBRMPA legislation.

3.39 Queensland is proceeding with the declaration of a Pilotage Area and is attempting to make the boundary similar to the GBRMPA compulsory pilotage area in order to minimise confusion among industry.

3.40 The review supports the establishment of an integrated traffic management regime for vessels in the Whitsunday Islands region through the declaration of a Pilotage Area under the Queensland Transport Operations (Marine Safety) Act 1994.

3.41 This option could be implemented unilaterally and quickly without the need for international sanction to be effective over foreign flag ships. The extension of compulsory pilotage for all commercial trading vessels using waters around the Whitsunday Islands will substantially extend use of pilots into the southern part of the GBR beyond the existing compulsory pilotage area. Ships not wanting to engage a pilot would have to take less hazardous but marginally longer routes outside the Whitsunday Islands.

3.42 The review strongly endorses the extension of compulsory pilotage to the Whitsunday Islands region, which was implemented under the GBRMPA on 19 July 2001.

Recommendation 11
The review recommends that shipping be further discouraged from transiting the Whitsunday Islands region by removing "preferred" routes for shipping through the area from charts.

Implications of Extending Compulsory Pilotage

Increased transport costs

3.43 Transport costs can be expected to increase because of additional pilotage fees associated with extending the compulsory pilotage areas. Similar cost considerations also will apply if more shipping is strongly encouraged to voluntarily adopt pilotage that is recommended, rather than mandatory.

3.44 The extent of costs will depend on the operational approach taken by pilotage service providers for making services available, any additional infrastructure and equipment needs, training and commercial decisions on rates of fees and charges. Estimates of pilotage fees range from $8,000-$10,000 for Inner Route pilotage from Torres Strait to Brisbane. The current cost of pilotage from Torres Strait to Cairns is $3,850.22

3.45 Additional costs may be incurred in making up time lost from picking up and discharging additional pilots. These costs will depend on type of ship and cargo and cannot be easily quantified.23

3.46 Alternatively, higher costs also will be involved if ship operators decide to use the Outer Route, where no pilotage considerations apply. These costs relate to the longer steaming times on the Outer Route and safety consequences of adverse weather and sea conditions. It is estimated that transit via the Outer Route can add as much as an extra day to transit time, depending on weather conditions and vessel characteristics. The estimated average additional cost of an extra day's vessel charter time is around US$20,000.24

3.47 These costs are likely to be passed on to consumers, unless Governments provide incentives to industry to adopt recommended pilotage or to offset increased compulsory pilotage costs. Acceptance of compulsory pilotage by the international shipping industry could be enhanced if costs were ameliorated. The ability to remove commercial considerations in using a pilot would be a quick and effective tool in reducing risk ahead of any IMO sanctioned agreement to extend compulsory pilotage.

3.48 Direct subsidy of coastal pilotage services, however, is not consistent with Government policies, which have promoted the commercially competitive provision of services in the Great Barrier Reef region since the early 1990s.

3.49 Another option is to implement a differential charging scheme for maritime levies based on trading patterns and ports visited. If such a differential scheme were established, it may be possible to provide rebates on payment of the levy to offset any reasonable additional costs of pilotage, within the constraint of revenue neutrality, so that the use of a pilot is not affected by commercial considerations. There would, however, be a potential issue of cross-subsidy from shipping that does not need or use pilots, and whether such a cross-subsidy is legally defensible.

3.50 There also would be an issue with the use (and cross subsidy) of pilots by ships transiting the Torres Strait and/or GBR and not calling into an Australian port. Transiting ships already use Australian provided navigation services, but make no contribution to levies if they do not call at an Australian port during the relevant charging period. Similarly transiting ships not trading with Queensland ports make no contribution to the State's ship safety regimes. If there is potential to impose levies on transiting ships it would enhance equity and also expand gross revenues to offset any rebates.

3.51 AMSA levies presently are collected on the basis of a sliding scale of rates for different vessel tonnages, irrespective of the number and location of ports visited. It is not within the scope of this review to make specific suggestions about the structure and level of future levies.

3.52 The review notes that the AMSA has commissioned a review of the existing levies. The last comprehensive review of AMSA levies was conducted in 1997. The application of AMSA efforts and resources is increasingly focussed towards risk such as poorer quality shipping and environmentally sensitive areas and the current review is examining pricing policy from a strategic viewpoint taking into account this change in focus.

3.53 The terms of reference of the levy review include consideration of the need to establish a pricing regime that more closely reflects risk and the absorption of revenues by users of or those most closely regulated by AMSA levy funded activities. The levy review provides scope for examining a differential charging regime that encourages the use of pilots or other risk reduction measures in high risk areas such as the Torres Strait and GBR.

Recommendation 12
This review recommends, as an intermediate step, the review of levies should also explore economic options to encourage greater usage of pilots.

Availability of skilled pilots

3.54 If pilotage is made compulsory throughout the Inner Route and the Great North East Channel, one estimate places the requirement for additional licensed pilots at around 30.25

3.55 The increased demand for pilotage services will have an impact on the availability of suitably trained and qualified pilots. Coastal pilots have substantial training and experience in the maritime industry before entering the pilotage profession. The pool from which they are drawn is relatively small, comprising senior navigational officers who have had or aspire to ship command positions.

3.56 The average age of existing pilots is 54 years, with 55% over age 55 and 20% over age 60 years.26 With a similar aging profile in the maritime industry from which pilots are drawn, indications are that there may be a lack of suitably trained and qualified pilots to meet any increased demand caused by extending the compulsory pilotage area.

3.57 The current licensing standards, including Master Class 1 requirement for pilots, may need review for certain classes of vessel transiting the GBR. Pilotage through the GBR requires high-level navigation skills combined with familiarity with local conditions. There are many competent seafarers currently transiting the GBR who do not possess Master Class 1. Internationally similar jurisdictions to Australia, such as the British Columbia coastal pilotage region, deliver a high standard of pilotage without Master Class 1 qualifications.

3.58 In order to redress the possible lack of pilots, it may be necessary to recruit pilots from a different base and adopt a new framework for the qualification and experience levels of pilots. Issuing of a pilot's licence should still be subject to qualifications, experience, training, medical and testing.

3.59 There is merit in considering a range of different recruitment/training/career structures. A tiered level of pilotage licensing whereby pilots have endorsements for certain classes of ship and area endorsements would assist in reducing the gap of available pilots. For example, a pilot may be licensed for vessels to a certain LOA or draft.

3.60 However, MIIU investigations indicate that less experienced pilots are more likely to be involved in incidents. In recent years the MIIU reports indicate a greater number of incidents have occurred on ships where the pilots has had less than four years' experience piloting on the GBR. Pilots from the two main service providers consider there has been a fall in the standards of experience and knowledge of new pilots.27

Recommendation 13
The review recommends that an expert task force comprising AMSA, Queensland Transport, GBRMPA, training providers and pilot representatives undertake a reassessment of recruitment and licensing practices for coastal pilots. The task force should examine the training and qualification system for coastal pilots, including on the job specialised training and the potential for tiered levels of pilot licensing.

Exemptions from Pilotage

3.61 Another means of offsetting the costs of compulsory pilotage, without affecting risks of an incident, is to grant exemptions from the pilotage requirements for ships that can demonstrate clearly superior levels of performance and consistent compliance with regulations. These may include regular coastal traders, and well-found ships with highly trained crews and fitted with state of the art navigation technology.

3.62 Provision is made in the GBRMP Act for exemptions from compulsory pilotage requirements to be granted. AMSA provides the technical assessment of temporary applications for exemptions under the Great Barrier Reef Marine Park Act 1975. The Chair of the GBRMPA is currently the designated authority for approving compulsory pilotage exemptions.

3.63 Dispensations for vessels that trade frequently in the region are supported by the shipping industry and reef pilots.28 GBRMPA supports extending the list of exemptions in new compulsory pilotage areas and reviewing exemption criteria in existing areas.29

3.64 Any exemptions should be subject to examination of the ship's Master's knowledge of the region and medical fitness. Consideration may also need to be given to assessing the competency and knowledge of watch-keeping officers other than the Master. Exemptions could also take into consideration any port State control reports of the vessel.

Recommendation 14
The review recommends that the proposed reassessment of recruitment and licensing of pilots should encompass the criteria for issuing pilot exemptions.

Dual Watch Systems

3.65 Another proposal for enhancing safety of navigation, which could potentially be considered either in conjunction with compulsory pilotage or as a grounds for an exemption for compulsory pilotage, is for mandatory requirements for ships to have two qualified officers on watch on the bridge at all times on a voyage through the GBR.

3.66 There are some concerns that such a proposal would raise crew fatigue during the remainder of the voyage, including the critical time of entering a port. Nevertheless, good passage planning and Bridge Resource Management should support consideration of dual watch officers at strategic navigational points during a voyage.

3.67 The review notes that the DNV risk analysis concludes that it was difficult to assess the impact of a dual watch system on reduction of risk for a shipping incident in the GBR.

3.68 The review supports adoption of a dual watch system to ensure that two qualified navigating officers are on the bridge during all strategic course change points in the course of the ship's transit of the GBR, and that such measures should be incorporated as part of a ship's passage planning.

Fatigue management

3.69 Pilot and or crew fatigue has been identified as an issue of concern in many submissions.30 On a number of occasions, crew have been offline while they should have been at key operational stations and alert.31 Aspects of current GBR pilot work practices and scheduling, as well as conditions on board individual ships, also contribute to fatigue, are described by the 1999 DNV report on GBR Pilot Fatigue Risk Assessment.32

3.70 It is very difficult to quantify the risk attributable to fatigue. DNV indicated that it is impossible to make a reliable judgement on the contribution of pilot fatigue to the various incidents in the GBR, as incident investigations have not specifically addressed fatigue as an issue. Nevertheless its study indicated that the percentage of accidents attributable to fatigue lies in the range 10-25%.

3.71 DNV concluded that improved pilot fatigue management should reduce the risk of an incident, but there is greater potential for risk reduction in addressing other causes of incidents. A proactive approach by all parties towards risk reduction was recommended.

3.72 There are existing measures in place to manage fatigue, including a need for each pilotage company to have a safety management system that addresses matters such as fitness and availability for duty and rest periods. Pilots have a responsibility to ensure they are sufficiently rested and medically fit before commencement of pilotage duties.33

3.73 On 1 July 2001 AMSA implemented a Great Barrier Reef Pilotage Safety Management Code, which is mandatory under Marine Orders Part 54 (Coastal Pilotage) and subject to audit, verification and certification by AMSA. The Code is designed to facilitate effective and safe management of pilotage services on the Queensland coast. It sets objectives for Safety Management Systems that ensure observance of safe working practices, identification of risks and provision for continuous improvements. It defines the responsibilities of each party involved in the provision of pilotage services.

3.74 The Code applies to all operations involved with the provision of pilotage services to shipping off the Queensland coast covered by Part IIIA of the Navigation Act 1912. It requires every pilot service provider to develop, implement and maintain a Safety Management System (SMS) which must include:

3.75 AMSA reports that the Code has provided a timely reminder to pilot service providers on their obligations to address fatigue and other safety issues.

Recommendation 15
The review recommends that pilotage service providers continue to be expressly included in the regulatory framework covering coastal pilotage services. The review endorses the safety systems approach promulgated in the Great Barrier Reef Safety Management Code, which encompasses both pilots and pilotage service providers.

Infrastructure

3.76 Additional infrastructure may need to be provided if compulsory pilotage is extended throughout the GBR. This may include embarkation management of pilots joining and leaving vessels requiring pilotage services, including the availability of ancillary services such as pilot launch and helicopter services, and the need for pilot houses to provide for adequate rest for pilots.

3.77 Provision of this infrastructure would be the responsibility of the relevant service providers, and it would be reasonable for such additional costs to be recovered in charges for the services on a commercial basis.

Impact of Competition

3.78 Pilot representatives submitted that the deregulation of the coastal pilot market in 1993 has increased operational pressures on pilots, contributing to fatigue, declining competency, reduced capital investment and making the industry less attractive to new entrants. Similar claims previously have been made to the DNV Risk Assessment Study, the Neville Inquiry on Fatigue in Transport, and the Navigation Act Review among others.34

3.79 The Commonwealth Government made it clear at the time of agreeing to regulate coastal pilotage that it considered it was not appropriate for governments to directly control the supply or pricing of pilot services, and that appropriate review mechanisms are available through the Trade Practices Commission and the Price Surveillance Authority (now the ACCC).

3.80 Provided appropriate safety audit and control mechanisms are in place and functioning, the absence of direct commercial regulation should not pose a threat to the safety of the GBR and Torres Strait. The Holden Review noted that shipowners are in favour of the benefits that competition has delivered and that pilots indicated that service providers were the primary source of competitive pressures on pilots.35

3.81 The review supports the adoption of the Safety Management Systems approach under Marine Order 54 (Coastal Pilotage) as an effective way to address safety outcomes in the competitive environment for pilotage services.

Education and Awareness

3.82 There is currently uncertainty among many ship operators about the current compulsory and recommended pilotage requirements within the GBR. Given this uncertainty, pilotage requirements should be more widely promulgated with the objective of encouraging the uptake of pilots in recommended areas.

3.83 Pilotage requirements are detailed in the Reef Guide, with the fourth edition published in December 2000. This publication now needs updating to reflect recent changes, particularly around the Whitsunday Islands.

3.84 There is scope for recommended and compulsory pilotage areas to be shown on charts, particularly on layered arrays in electronic charts, although there are some concerns that paper charts may become too cluttered.

3.85 Other mechanisms for promulgating information include the REEFREP and AUSREP ship reporting systems, Notices to Mariners, international maritime publications and direct notification of ships' agents and shipping companies operating in and around the Reef.

Recommendation 16
The review recommends that AMSA, GBRMPA and Queensland Transport undertake extensive promulgation of pilotage requirements to promote awareness of both compulsory and recommended pilotage zones.

6 This chapter addresses the provision of pilotage services along the coast of Queensland through the GBR region.  It does not address pilotage requirements within and into ports in the region, which are regulated by the Queensland Government.

7 Queensland Government and AMSA, 2000, Reef Guide - A Shipmaster's Handbook to Torres Strait and the Great Barrier Reef, 4th edition.

8 This represents a significant increase on the 30% of ships transiting Torres Strait without a pilot noted in the Department of Transport, 1995, Great Barrier Reef and Torres Strait Shipping Study, Vol III.

9 Det Norske Veritas, 2001, Risk Assessment of Ship Safety Controls in the Torres and Great Barrier Reef Inner and Outer Routes

10 Submission No 24 Environment Australia and Submission No 6 Australian Chamber of Shipping

11 Marine Incident Investigation Unit reports, various years.

12 Submission No 49 Queensland Government

13 Submission No. 24, Environment Australia.

14 Submission No 59 Torres Pilots,

15 Submission 49 Queensland Government

16 Submission No 13 Australian Reef Pilots and No 33 Hydro Pilots

17 Including the Bunga Teratai Satu which did run aground.

18 Submission No 6 Australian Chamber of Shipping, No 49 Queensland Government

19 Submission No 49, Queensland Government

20 Oil Spill Risk Assessment for Coastal Waters of Queensland and the Great Barrier Reef Marine Park, 2000, prepared for Queensland Transport and GBRMPA Great Barrier Reef Review of Safety Initiatives Study, (the Holden Report), 2000

21 Courier Mail, 20 July 2001, Pilots for Whitsundays

22 Lloyds List DCN, 8 December 2000, Compulsory Reef pilotage would hit shipper costs.

23 Submission No 6 Australian Chamber of Shipping

24 Typical daily charter rates for bulk carriers are in the range 180,000 DWT US$15,000-19,000; 70,000 DWT US$10,500-13,500 and 50,000 DWT US$9,000-10,500.  For Tankers daily charter rates are in the range: VLCCs (100,000 DWT US$20,000-25,000; 40,000 DWT US$15,000-16,000

25 Submission No 13, Australian Reef Pilots

26 Great Barrier Reef Review of safety Initiatives Study, (the Holden Report), 2000, p19

27 Ibid, p19

28 Submission No 6 Australian Chamber of Shipping, No 13 Australian Reef Pilots

29 Communications from GBRMPS, 26 July 2001

30 Submission No 6 Australian Chamber of Shipping, No 12 Australian Marine Pilots Association, No 13 Australian Reef Pilots, No 19 Coral Sea Shipping Lines, No 20 Mr Corrie, No 22 Capt Duelberg, No 24 Environment Australia, No 25 Capt Every, No 30 GBRMPA, No 36 Low Isles Preservation Society, No 52 Capt Richardson

31 Submission No 24, Environment Australia

32 DNV, 1999, GBR Pilot Fatigue Risk Assessment, p13-14

33 Holden Report, 2000, p24.

34 DNV, 1999, GBR Pilot Fatigue Risk Assessment p27; House of Representatives Standing Committee on Communications, Transport and the Arts, 2000, Beyond the Midnight Oil - Managing Fatigue in Transport (the Neville Report); and Department of Transport and Regional Services and AMSA, 2000, Review of the Navigation Act 1912 - Final Report

35 Holden Report, 2000, p22

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last updated: 4 September 2001