THE SHELL LEAKS FILES: 22 SEPTEMBER 2026

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THE SHELL LEAKS FILES: 22 SEPTEMBER 2026

SLF-2007-065

The Sakhalin Papers LV: The Scientist Who Walked Away — Rick Steiner’s Warning to Shell, the PA-B Tow-Out and the ISRP Resignation

On 14 July 2005, Independent Scientific Review Panel member Rick Steiner sent an urgent appeal directly to Royal Dutch Shell chief executive Jeroen van der Veer. The massive PA-B platform base was due to be towed to Sakhalin the following day. Steiner asked Shell to postpone it. He listed unresolved questions involving underwater noise, ship collisions, oil-spill preparedness, independent monitoring and the platform’s proximity to the feeding grounds of one of the world’s most endangered whale populations. Shell responded the next day. The tow-out went ahead. Six weeks later, Steiner resigned from the continuing scientific process.

Archive reference: SLF-2007-065
Collection: The Sakhalin Papers
Principal scientific record: IUCN Independent Scientific Review Panel report, 2005
Authenticated corporate record: The Shell Sustainability Report 2005
Contemporaneous correspondence: Rick Steiner to Jeroen van der Veer, 14 July 2005; Ian Craig, Sakhalin Energy, to Steiner, 15 July 2005; Steiner resignation email, 29 August 2005
Contemporaneous reporting: Reuters-era coverage collected in the archive; The Guardian/Observer, March–September 2005
Judicial context: Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin)
Evidence standard: Steiner’s scientific concerns and personal assessments are attributed to him. Sakhalin Energy’s responses are attributed to the company. ISRP conclusions are distinguished from Steiner’s individual position. Neither the panel nor Steiner possessed regulatory authority to stop Sakhalin II.


Introduction

The previous three instalments followed Shell’s relationship with Sakhalin into the post-2022 world of Russian decrees, missing LNG cargoes, frozen compensation and litigation.

This file goes backwards.

To understand why Sakhalin II had become such an internationally sensitive project long before Vladimir Putin dismantled its original corporate structure, it is necessary to return to 2005.

And to a scientist who eventually decided he could no longer participate.

Rick Steiner was not an outside campaigner commenting on the Independent Scientific Review Panel from a distance.

He was inside the process.

The surviving documents provide something more useful than hindsight: they record what he said before the PA-B platform was installed, how Sakhalin Energy responded, and what he said when he subsequently withdrew.

That paper trail allows the disagreement to be reconstructed without turning either side’s position into established fact.


1. Steiner’s Sakhalin concerns pre-dated the whale panel

Rick Steiner’s involvement with Sakhalin did not begin in 2005.

Years earlier, he had examined oil-spill preparedness on the island with Dan Lawn and Jonathan Wills.

Their 1999 report, Sakhalin’s Oil: Doing It Right, was explicitly intended to review environmental monitoring and oil-spill prevention and response, and to recommend improvements. The authors described themselves as independent of government, the oil industry and organised environmental groups.

The report eventually contained 78 recommendations. Its sponsors recorded that the investigators remained concerned that Sakhalin was not yet adequately prepared either to prevent or respond to a major oil spill.

Steiner brought unusual personal experience to that subject. The report identifies him as a University of Alaska professor and former commercial fisherman who had participated in the response to the Exxon Valdez spill.

His separate paper, Oil Spills: Lessons from Alaska for Sakhalin, described catastrophic tanker accidents as a serious risk and argued for much stronger prevention and emergency-response arrangements.

Those were Steiner’s assessments.

They were not judicial findings against Sakhalin Energy.

But they establish that by the time the western gray whale controversy intensified, Steiner had already been examining Sakhalin petroleum risks for years.


2. The environmental argument widened

By January 2003, environmental organisations from Russia, the United States, Japan and South Korea had issued a common set of demands concerning Sakhalin I and II.

They called for best available technology, higher pollution-control standards and application of the precautionary principle to western gray whale habitat.

Among their demands were that the proposed PA-B platform be positioned farther from the feeding habitat; offshore pipelines avoid that habitat; seabed disturbance be reduced; seismic activity be restricted while whales were present; and cumulative effects be independently studied.

Those demands were advocacy positions.

Sakhalin Energy disputed many of them.

But the same broad subjects — noise, cumulative effects, platform location, vessel risk, spill preparedness and independent scientific scrutiny — subsequently appeared in the formal independent review process.


3. Sakhalin Energy itself requested the independent review

In 2004, Sakhalin Energy asked the International Union for Conservation of Nature — IUCN to convene an independent scientific panel to examine the potential effects of Sakhalin II Phase 2 on western North Pacific gray whales.

The population was extraordinarily small.

IUCN’s published report described approximately 100 animals and classified the population as Critically Endangered at the time. (IUCN)

This point matters.

The ISRP was not imposed on Shell by a court.

It was not a Russian regulatory tribunal.

It was an independent scientific mechanism established under IUCN auspices at Sakhalin Energy’s request.

Rick Steiner became one of the participants.


4. The panel did not give Sakhalin II a clean bill of health

The final 2005 report was far more cautious than a conventional project endorsement.

The panel acknowledged that Sakhalin Energy had spent substantial sums on whale research and mitigation.

It also concluded that significant information gaps remained.

One particularly important issue was Sakhalin Energy’s use of the engineering-risk principle:

ALARP — “as low as reasonably practicable.”

The panel said the lack of specificity in how ALARP had been applied to decisions including the PA-B platform locationprevented it from completing a rigorous evaluation of some risks and mitigation options. (IUCN Portals)

Its population modelling was equally sobering.

The panel concluded that the loss of one additional female each year, beyond then-current mortality, could drive the population towards extinction with high probability. (IUCN Portals)

The panel therefore adopted an explicitly precautionary approach.

Its strongest option was temporary suspension and delay of development around the feeding grounds while risk assessment and independent monitoring mechanisms were improved. (IUCN Portals)

That was scientific advice.

It was not an order.


5. Shell did make one major design change

The story would be distorted if the response of Shell and Sakhalin Energy were portrayed simply as rejection of the scientific process.

In March 2005, Sakhalin Energy announced that the offshore pipelines would be rerouted approximately 20 kilometresfarther from the principal feeding ground.

Contemporaneous reporting described roughly 12 additional miles of pipeline. (The Guardian)

Shell’s own Sustainability Report 2005 subsequently said that Sakhalin Energy had taken the panel’s advice and moved the offshore pipelines farther from the feeding area.

The same corporate report said advanced acoustic modelling and independent scientific observers had been used during installation of the production-platform bases and reported that installation had been completed without signs of disturbance to the whales. That was Shell’s published assessment of the outcome. (Shell)

So there was a concrete result from the scientific intervention:

the pipeline route changed.

But the platform location did not.


6. The PA-B platform became the dividing line

Contemporary press coverage immediately recognised the distinction.

The Guardian reported on 31 March 2005 that the pipelines had been rerouted but that campaigners continued demanding relocation of the platform itself. (The Guardian)

A few weeks later, Sakhalin Energy chief executive Ian Craig said the company would continue engaging whale experts and maintained that the company had been open and transparent about the project. (The Guardian)

Thus two things were simultaneously true.

Sakhalin Energy had altered part of the engineering design because of whale concerns.

And significant disagreement remained about the PA-B platform.

For Rick Steiner, that disagreement was not academic.

The concrete base was about to move.


7. 14 July 2005: an urgent letter to Jeroen van der Veer

The archive contains a remarkable one-page document dated:

14 July 2005

It is marked:

URGENT

It is addressed directly to:

Jeroen van der Veer
Chief Executive Officer
Royal Dutch Shell

The subject is:

“postponement of PA-B platform tow-out to Sakhalin.”

Steiner identifies himself as a member of the Independent Scientific Review Panel and the subsequent review process.

He says the PA-B base is scheduled to be towed to the Piltun field the following day.

His request is unambiguous:

postpone it.


8. Steiner listed what he believed remained unresolved

The significance of the letter lies in its specificity.

Steiner did not merely say that he disliked the project.

He identified outstanding subjects that he believed still required adequate resolution:

acoustic modelling;

the adequacy of the noise-impact assessment;

noise intervention and action levels;

noise-mitigation protocols;

independent oversight and monitoring;

ship-collision assessment and mitigation;

oil-spill prevention and response preparedness;

and:

independent review of the PA-B location and alternatives farther from whale habitat.

He argued that the precautionary approach required postponing the tow-out until independent review was complete and the outstanding issues had been reasonably resolved.

That is Steiner’s position in his own contemporaneous document.

It should not be conflated with a unanimous ISRP instruction.


9. The letter closely tracked concerns in the panel’s own report

This is an important distinction.

Steiner’s demand to postpone the tow-out was his.

But many of the underlying subjects were not invented by him individually.

The ISRP report itself had identified uncertainties surrounding noise, vessel collision, cumulative effects, spill risks, monitoring, mitigation and the basis for the PA-B location decision. (IUCN Portals)

The panel’s oil-spill analysis was particularly detailed.

It said effective response in Sakhalin’s severe conditions would be difficult and expensive, and noted that the PA-B Health, Safety and Environment case had not yet been completed in documentation supplied to the panel at the time of its review. (IUCN Portals)

Thus the documentary distinction is:

Steiner personally demanded postponement.

But:

the risk categories underpinning his demand had been examined by the independent panel itself.


10. Shell’s chief executive did not ignore the letter

The following day, 15 July 2005, Sakhalin Energy chief executive Ian Craig replied.

The surviving company letter says Craig had been asked by Jeroen van der Veer to respond to Steiner’s fax because van der Veer believed Craig was the appropriate person to discuss the specific matters raised.

That is significant in itself.

The appeal reached the top of Royal Dutch Shell.

And a reply came back immediately.

Craig thanked Steiner for his role in the Independent Scientific Review Panel and described the ISRP report and subsequent exchanges with Sakhalin Energy as an important contribution to the company’s efforts to mitigate potential effects on the western gray whales.

The two sides were therefore not disputing whether the science mattered.

They were disputing what should happen while the scientific process remained unfinished.


11. Sakhalin Energy said the outstanding issues were still being worked on

Craig’s reply acknowledged continuing work.

The company said a further workshop would address subjects including:

ship strikes and collisions;

noise;

oil and gas spills and accidents;

habitat disturbance and degradation;

the PA-B location;

cumulative effects;

research and monitoring;

mitigation;

and independent mechanisms for verifying compliance with protection measures.

This is an important company-side document because it confirms that, on the eve of PA-B installation, the scientific process had not simply ended.

Outstanding matters were still under discussion.

But Sakhalin Energy did not accept Steiner’s conclusion that this required stopping the platform.


12. The company relied on the Gland workshop

Craig referred to a scientific workshop held at Gland, Switzerland, in May.

According to the IUCN summary quoted in his letter, many participants accepted the proposed platform location after explanation, although some preferred no installation at that site.

The letter also said most participants considered that moving the platform to another technically accessible location was unlikely to make a significant difference to potential impacts.

Sakhalin Energy said documentation supporting that conclusion was being finalised.

Craig added that the company was concentrating on effective mitigation during installation and had gained useful experience from installation of the Lunskoye gravity-base structure earlier that month.

The company’s position can therefore be stated fairly:

continued scientific review and mitigation were compatible with proceeding with the PA-B installation.

Steiner’s position was the opposite:

the independent review should be completed before the effectively irreversible tow-out occurred.


13. This was the real disagreement

The documentary record is more interesting than a simple argument about whether Shell “listened to scientists.”

It clearly did listen in some respects.

The pipeline was rerouted.

Scientific monitoring continued.

The permanent advisory structure was later expanded.

But the PA-B episode exposed a harder governance question:

When must scientific uncertainty actually stop construction?

For Steiner, the unresolved issues justified a pause.

For Sakhalin Energy, they justified continued analysis, monitoring and mitigation while the project proceeded.

Those are materially different applications of the precautionary principle.


14. The platform proceeded

The PA-B base was subsequently installed.

Shell’s Sustainability Report 2005 presented the installation as successfully managed from the standpoint of whale disturbance, stating that external scientific observers monitored noise levels and that the platform bases were installed without observed signs of disturbance to the whales. (Shell)

That is an authenticated Shell statement.

It is not the same thing as an independent finding that every concern raised by Steiner had been resolved.

Nor does the absence of observed immediate disturbance establish the absence of every possible longer-term, cumulative or population-level effect.

The original ISRP had specifically warned against waiting for conclusive population-level evidence before addressing risks. (IUCN Portals)


15. Six weeks later, Steiner withdrew

The archive also contains Steiner’s email dated:

29 August 2005

Its heading records:

“ISRP resignation 8/29/05.”

Steiner told fellow participants:

“I have decided to opt out of further participation”

in the continuing Sakhalin II Phase 2 review process.

He said he had made his concerns clear to the other scientists, Shell and prospective lenders.

Then the email moved beyond technical criticism into personal judgment.

Steiner wrote that he believed the process was being unfairly exploited by Shell and singled out the PA-B location decision as an example.

That was Steiner’s opinion.

It was not an ISRP finding.


16. “Sub-optimization”

Steiner used a revealing concept in explaining his departure:

“sub-optimization”

He described it as doing something in the best possible way when, in his view, it should not be done at all.

He then said there was much Shell could do to make the project safer, but that he no longer believed the particular scientific process would achieve that objective.

He concluded that he could no longer participate and told potential lenders that his own recommendation was to opt out of the project.

Again, these were strong personal conclusions.

They should neither be diluted nor presented as collective findings of the other scientists.


17. The resignation became public

The dispute did not remain within scientific correspondence.

On 11 September 2005, The Observer reported Steiner’s resignation and reproduced part of his explanation.

The newspaper described the resignation as a setback for the Sakhalin project and placed it in the context of the continuing environmental controversy and the project’s sharply increasing cost. (The Guardian)

One qualification is necessary.

Some contemporary press reports simplified complicated corporate and legal developments, and not every statement in them should be accepted uncritically.

For this archive, their value is narrower:

they independently confirm that Steiner’s withdrawal and criticism were public events at the time.

The resignation was not reconstructed twenty years later.


18. Steiner did not speak for the entire panel

This point is essential.

Rick Steiner was a member of the independent scientific process.

But his resignation did not mean the entire panel had resigned.

Nor does his criticism establish that all panel members shared his assessment of Shell’s conduct.

Indeed, Ian Craig’s July reply specifically relied on the Gland discussion as evidence that many participants were prepared to accept the PA-B location after considering the alternatives.

The proper documentary formulation is therefore:

There was significant scientific concern.

There was disagreement about how the precautionary principle should affect the construction schedule.

Steiner reached a point at which he personally could no longer participate.

Others continued.


19. Nor did the scientific process disappear

In October 2006, IUCN announced the creation of the longer-term:

Western Gray Whale Advisory Panel — WGWAP

Ten scientists were initially appointed to provide continuing independent advice on Sakhalin II and wider industrial risks to the whale population. (IUCN)

This is an important counterpoint to Steiner’s resignation.

The institutional experiment did not collapse.

It became more permanent.

Indeed, the WGWAP ultimately operated for many years, generating the extensive scientific record examined in earlier Shell Leaks Files.

But later disputes show that the underlying tension did not vanish.

In 2007, IUCN reported disagreement between the scientific panel and Sakhalin Energy over underwater-noise criteria. (IUCN)

In 2009, IUCN publicly criticised Sakhalin Energy for providing important information too late for effective panel review. (IUCN)

Those later events do not retrospectively prove Steiner right about every 2005 issue.

They do establish that questions about information, timing, independent review and the relationship between scientific advice and operational decisions remained part of the Sakhalin system years after he left.


20. Shell’s own later record acknowledged the long-term value of the process

There is another side to the historical record.

Shell did not subsequently repudiate the whale-review process.

Its 2006 Sustainability Report highlighted the pipeline reroute, continuing scientific monitoring and creation of the long-term advisory panel. It said the whale population had grown and described the project’s approach as one involving independent scientific advice and operational mitigation. (Shell)

A decade later, Shell’s 2015 Sustainability Report was still citing its partnership with IUCN and the 2005 pipeline reroute as examples of efforts to reduce effects on whale habitat. (Shell)

Thus the archive should avoid an overly simple conclusion.

The scientific process both:

changed Shell’s project, and

failed to persuade Shell to accept every recommendation or every scientist’s interpretation of precaution.

Both propositions are supported by the record.


21. The controversy eventually entered an English courtroom — but on a different issue

Sakhalin II later appeared in the English High Court in:

Export Credits Guarantee Department v Friends of the Earth
[2008] EWHC 638 (Admin).

The case concerned access to environmental information relating to proposed UK export-credit support.

Mr Justice Mitting recorded that approximately US$650 million in project support had been sought and that Sakhalin II posed potentially serious consequences for western gray whale habitat. (vLex)

But the limits of that judgment are critical.

The court did not decide whether Steiner was correct.

It did not decide that PA-B should have been postponed.

It did not find that the platform harmed the whale population.

It did not rule that Shell had unlawfully ignored the ISRP.

The case concerned governmental disclosure.

Its relevance here is simply that the environmental controversy surrounding Sakhalin II and the western gray whale became sufficiently important to form part of an English public-law dispute over contemplated British financial support.


22. What later history can — and cannot — tell us

It is tempting to judge the 2005 dispute by looking at what subsequently happened to the whale population.

That would be too simplistic.

Later conservation work recorded encouraging population growth.

But the whales continued to face industrial, shipping, fishing and other risks.

The eventual recovery trajectory cannot tell us what would have happened under a different 2005 construction plan.

Nor can it retrospectively demonstrate that every precaution urged by Steiner was necessary.

The stronger historical comparison is procedural.

Steiner warned about:

noise;

ship collision;

spill preparedness;

cumulative effects;

independent oversight;

monitoring;

and:

making irreversible project decisions before the scientific review was complete.

Many of those same categories remained central to the WGWAP programme for years afterwards. (IUCN)

That continuity is established.

Causation is not.


Documentary Findings

Established

Rick Steiner had been examining Sakhalin environmental and oil-spill risks years before the 2005 Independent Scientific Review Panel.

Sakhalin Energy asked IUCN to establish an independent scientific review of Sakhalin II Phase 2 and its potential effects on the western gray whale. (IUCN)

The ISRP identified substantial uncertainty concerning risks, mitigation and aspects of Sakhalin Energy’s decision-making, including the PA-B platform location. (IUCN Portals)

The panel’s most precautionary option was suspension and delay of development near the feeding grounds while risk assessment and independent oversight were strengthened. (IUCN Portals)

Sakhalin Energy subsequently rerouted the offshore pipelines approximately 20 kilometres farther from the principal feeding area. Shell later expressly attributed that change to the scientific review. (Energy Intelligence)

The PA-B platform itself was not relocated.

On 14 July 2005, Rick Steiner sent an urgent letter to Jeroen van der Veer requesting postponement of the PA-B tow-out and identifying multiple unresolved scientific and operational issues.

On 15 July 2005, Sakhalin Energy chief executive Ian Craig replied at van der Veer’s request. The company acknowledged continuing scientific work but defended proceeding with the platform location and mitigation process.

The PA-B installation proceeded.

On 29 August 2005, Steiner withdrew from further participation in the continuing review process.

His resignation and criticism were reported publicly in September 2005. (The Guardian)

IUCN established a permanent Western Gray Whale Advisory Panel in 2006. (IUCN)


Rick Steiner’s stated position

Steiner believed the PA-B tow-out should be postponed until independent review had been completed and the outstanding scientific issues reasonably resolved.

He later concluded that the continuing process was being used in a manner with which he could no longer associate himself.

He advised prospective lenders not to support the project.

Those are Steiner’s conclusions.

They are not presented here as findings by IUCN, the full ISRP, a court or a regulator.


Sakhalin Energy’s stated position

Sakhalin Energy regarded the ISRP as a valuable contribution to whale protection.

It said the PA-B location had been extensively discussed; that many participants at the Gland workshop accepted the proposed location after explanation; that relocation within technically viable areas was not expected to produce a significant reduction in potential impact; and that mitigation and continuing scientific review could manage the remaining issues.

Shell’s subsequent Sustainability Report stated that monitoring during platform-base installation showed no signs of disturbance to the whales. (Shell)

Those are company positions and observations.


Not established

It is not established that Steiner’s July 2005 demand to postpone the PA-B tow-out represented the unanimous view of the ISRP.

It is not established that Royal Dutch Shell or Sakhalin Energy violated a legal obligation by declining to postpone the tow-out.

It is not established that installation of PA-B caused a population-level decline in western gray whales.

It is not established that the absence of observed immediate disturbance during installation proves the absence of every longer-term or cumulative effect.

It is not established that later growth in the whale population proves the 2005 scientific concerns were unnecessary.

It is not established that Steiner’s resignation invalidated the continuing IUCN scientific process.

And it is not established that the ISRP as a whole approved Sakhalin II merely because most of its members continued working with Sakhalin Energy.


Commentary

The most revealing document in this file may be the one-day exchange between Steiner and Sakhalin Energy.

On 14 July, the scientist said:

wait.

On 15 July, the company effectively said:

the scientific work will continue, but the project will continue too.

That is the point at which the abstract language of precaution met the concrete reality of a multibillion-dollar construction schedule.

The disagreement was not simply science versus ignorance.

It was more difficult than that.

Shell had commissioned independent science.

The science had already altered the project.

Shell accepted some recommendations.

It rejected — or did not accept — the operational consequence Steiner drew from others.

And the scientist then had to decide whether remaining inside the process made him more useful than leaving it.

He chose to leave.


Why the July 2005 correspondence matters

The letters also illuminate a recurrent problem in corporate scientific advisory systems.

An independent panel can investigate.

It can advise.

It can warn.

It can monitor.

But unless its mandate gives it decision-making authority, management retains the final decision.

That was true at Sakhalin.

The ISRP could identify the most precautionary option.

Steiner could appeal to Shell’s chief executive.

The scientists could continue reviewing noise, collision risks, spills and habitat.

But the scientists could not themselves order the PA-B base to remain in port.

That structural limitation does not mean the advisory process was worthless.

The pipeline reroute demonstrates the opposite.

But it explains why Steiner’s resignation deserves to be retained in the documentary history alongside Shell’s later celebration of the same scientific partnership.

Both are part of the record.


Source Record

The principal scientific source is the 2005 IUCN Independent Scientific Review Panel report, Impacts of Sakhalin II Phase 2 on Western North Pacific Gray Whales and Related Biodiversity. It records the exceptionally small whale population, the project risks, weaknesses and information gaps in some risk assessments, the panel’s concerns regarding the PA-B decision and its precautionary recommendations. (IUCN)

IUCN — Independent Scientific Review Panel report, 2005

The authenticated corporate account is The Shell Sustainability Report 2005. Shell records the establishment of the independent panel, the approximately 20-kilometre pipeline reroute, acoustic modelling, monitoring during platform-base installation and its plans for a permanent whale advisory panel. (Shell)

Shell Sustainability Report 2005

The archive holds Steiner’s 14 July 2005 urgent letter to Jeroen van der Veer, requesting postponement of the PA-B tow-out and enumerating unresolved scientific and safety issues.

It also holds Sakhalin Energy chief executive Ian Craig’s 15 July 2005 response, sent after van der Veer asked him to address Steiner’s concerns.

The archive additionally contains Steiner’s 29 August 2005 resignation email, in which he explained why he was withdrawing from further participation and set out his personal assessment of the process.

Contemporaneous reporting documents the March 2005 pipeline reroute and the continuing disagreement over the platform location. (The Guardian)

The Guardian — Shell reroutes Sakhalin pipeline, 31 March 2005

The Observer subsequently reported Steiner’s resignation on 11 September 2005. (The Guardian)

The Observer — Rick Steiner resignation, 11 September 2005

IUCN’s 2 October 2006 announcement documents the creation of the permanent Western Gray Whale Advisory Panel following the original review. (IUCN)

IUCN — New Western Gray Whale Advisory Panel, 2 October 2006

The judicial background is Export Credits Guarantee Department v Friends of the Earth [2008] EWHC 638 (Admin). Mr Justice Mitting recorded the environmental significance of Sakhalin II, the western gray whale issue and the approximately US$650 million of contemplated UK-backed project finance. The case concerned environmental-information disclosure, not the merits of Steiner’s PA-B objections. (vLex)

Archive disclaimer: The direct Steiner correspondence records the views of one participant in the scientific process. His allegations and characterisations are attributed to him and are not adopted as findings of fact. Sakhalin Energy’s contemporaneous reply and Shell’s sustainability reporting record the company’s position. The ISRP’s conclusions are independent scientific assessments, not regulatory orders or judicial findings. No causal claim is made that PA-B installation produced a particular population-level outcome for western gray whales.

Site-wide disclaimer applies.


Next instalment

The Sakhalin Papers LVI: Before the Whale Panel — Rick Steiner, Exxon Valdez and the 78 Warnings Shell Faced Before Sakhalin II Phase 2

The 2005 resignation was not the beginning of Rick Steiner’s Sakhalin story.

Six years earlier, he had already travelled to the island with two other oil-pollution specialists.

Their report was called:

Sakhalin’s Oil: Doing It Right

It contained:

78 recommendations.

The investigators examined tanker routes, double hulls, tug escorts, vessel monitoring, spill-response equipment, independent oversight, liability, emergency exercises and the implications of trying to clean oil from some of the harshest waters on earth.

Steiner then carried the lessons of the Exxon Valdez disaster into a separate warning about Sakhalin.

One sentence captured his central concern:

a major accident off Sakhalin would not merely be an environmental disaster — it could become an economic and social catastrophe as well.

The next file returns to 1999 and asks:

What did Steiner and his colleagues tell Shell and the Sakhalin authorities six years before he walked away from the whale-review process — and how many of those warnings were still unresolved when Sakhalin II Phase 2 moved ahead?

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