Resource Management Issues: Cruise Ships

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Large cruise ships recently began visiting Monterey, with three visits in 2002, 14 visits in 2003, and 21 visits in 2004 and 9 scheduled visits for 2005. These ships can provide local businesses with economic benefits, particularly if they introduce the region to tourists who may return for later visits. However, both the public and businesses have raised concerns about environmental issues associated with these ships. Cruise ships are of enormous size, capable of generating massive volumes of waste. Currently the largest vessel in the global cruise line fleet, Royal Caribbean’s Voyager of the Seas, is larger than an aircraft carrier at 1,017 feet in length and holds more than 5,000 passengers and crew¹.

Worldwide, cruise ships constitute a large and rapidly growing industry. The industry consistently grew at a rate of eight percent per year between 1992 and 2002². By the end of 2001, the worldwide fleet of cruise ships totaled 167 vessels; the industry will increase the fleet by 38 vessels by 2005, an increase of forty-five percent for this five-year period³. Passenger numbers in North America are expected to increase from 6.8 million in 2001 to 11.9 million in 2010⁴. Currently 643,000 cruise ship passengers embark annually from California ports in San Francisco Bay, Los Angeles, and San Diego⁵. Although partly constrained by the lack of local docking facilities, cruise ship visits to Monterey are likely to continue to grow as the fleet is shifting from international to more domestic cruises, and due to a new cruise ship docking facility planned for San Francisco Bay.

Due to the recent increase in cruise ship visitation to the Monterey Bay, and concern over potential impacts to marine resources from these vessels, this issue has drawn significant attention from the public during the past year. MBNMS staff have received numerous comments requesting that the MBNMS address this issue. At their February 7, 2003 meeting, the MBNMS Advisory Council passed a resolution recommending that MBNMS staff pursue a regulatory prohibition on harmful discharges from cruise ships. In response to this resolution, a regulatory prohibition is being investigated as part of the Joint Management Plan Review Process.

Environmental Impacts of Cruise Ships and Current Regulation
Due to their sheer size and capacity for passengers, cruise ships can cause serious impacts to the marine environment. The main pollutants generated by a cruise ship are: sewage, also referred to as black water; gray water; oily bilge water; hazardous wastes, and; solid wastes.

While large cruise vessels are the equivalent of small cities in regard to waste production, they are not subject to the strict environmental regulations and monitoring requirements that land based facilities are required to comply with, such as obtaining discharge permits, meeting numerous permit conditions and conducting monitoring of discharges. However, there are a number of existing laws that address some aspect of cruise ship discharge. The various pollutants contained on cruise ships, their environmental impacts, and their current regulatory controls are outlined below.

Sewage
Sewage includes vessel sewage and wastewater from medical facilities. Sewage from ships is generally more concentrated than that from land based sources, as it is diluted with less water when flushed (three quarts versus three to five gallons). Sewage discharge can contain bacteria or viruses that cause disease in humans and other wildlife. It can present a public health concern, if discharged in the vicinity of marine life harvested for human consumption, or in or near waters used for recreational activities such as swimming, diving, or boating. Nutrients in the sewage can cause eutrophication, whereby excessive growth of algae depletes oxygen and can lead to the death of fish and other organisms. Additionally, chemicals and deodorants including chlorine, ammonia, or formaldehyde are often used in Marine Sanitation Devices (MSD), and can present a threat to marine organisms. Volumes of sewage for a typical cruise ship have been estimated at between five to ten gallons per person per day, or up to 210,000 gallons per week⁶.

Sewage is classified as a pollutant under the Clean Water Act (CWA). However, cruise ships are not subject to the National Pollutant Discharge Elimination System (NPDES) Permitting Program, which requires land-based facilities to obtain a permit for discharges under the CWA . Black water from cruise ships is however regulated under Section 312 of the CWA, which requires vessels to possess a US Coast Guard certified MSD. A MSD is a piece of equipment designed to treat or store sewage prior to discharge. A type II MSD must meet a water quality standard of 200 fecal coliform per 100 ml of water, for sewage treatment. A type III MSD, also referred to as a holding tank, is designed to contain sewage until it can be disposed of. Section 312 of the CWA is jointly implemented by the USCG and U.S. Environmental Protection Agency, and states may also enforce Federal standards. Section 312 requires the use of MSDs for all vessels within 3 miles of shore, and vessels over sixty-five feet to have a type II or type III MSD⁷. In certain cases the Act can also be applied to any discharge that occurs beyond the three-mile limit but may affect waters within the limit⁸.

Under the Clean Water Act, raw sewage can be legally discharged beyond three nautical miles. However, MBNMS regulations prohibit the discharge of raw sewage and require that discharges from vessels throughout the Sanctuary occur through a properly functioning Type I or Type II MSD that meets the standards of Section 312 of the Clean Water Act.

Graywater
Graywater consists of wastewater from sinks, showers, laundry, and galleys. It can contain a number of pollutants including: suspended solids, oil, grease, ammonia, nitrogen, phosphates, copper, lead, mercury, nickel, silver and zinc, detergents, cleaners, oil and grease, metals, pesticides, and medical and dental wastes. A typical cruise ship produces an estimated 1,000,000 gallons of graywater per week⁹.

Currently, Federal regulations do not prohibit the discharge of graywater in state or U.S. waters, with the exception of the Great Lakes and the state waters of Alaska. MBNMS regulations generally prohibit discharges to the Sanctuary, but provide an exception for discharges from routine vessel operations such as graywater.

Bilge Water
Bilge water consists of fuel, oil, and wastewater from engines and machinery that collects, along with fresh water and seawater in the area at the bottom of the ship’s hull, as a result of spills, leaks, and routine operations. It may also contain other materials such as rags, cleaning agents, paint, and metal shavings. A typical cruise ship generates an estimated 25,000 gallons of bilge water per week¹⁰.

Discharge of fuel or oil, including oily bilge water, is subject to stringent requirements of the Oil Pollution Act and section 311 of the CWA¹¹. Under this law, which is enforced by the USCG, vessels are prohibited from releasing any discharge with an oil content of greater than fifteen parts of oil per one million parts water (ppm). Beyond twelve miles, discharges with oil content greater than 100 ppm is prohibited. Several cruise line companies require their vessels to have additional equipment that treats the oily bilge water to 5ppm. Discharge of oily wastes is also addressed under the International Convention for the Prevention of Pollution from Ships (MARPOL), and under the Act to Prevent Pollution from Ships (APPS), which incorporates MARPOL provisions into federal law. They set requirements for the release of oil and noxious substances, set standards for reporting discharges, and establish monitoring and record keeping protocols¹².

MBNMS regulations prohibit the discharge of oily wastes from bilge pumping at any concentration.

Ballast Water
Cruise ships take in millions of gallons of ballast water, in order to stabilize the vessel for safe and efficient operation. During the process they take in thousands of species of marine organisms, including various types of larvae, fish eggs, and microorganisms. The water is often drawn in from coastal waters in one area, and discharged at another location. This process has led to the introduction of invasive species, which disrupt marine ecosystems, and cost the U.S. billions of dollars per year¹³.

Ballast water operations are currently regulated by the state of California by the Ballast Water Management for Control of Nonindigenous Species Act. The Act requires vessels to exchange ballast water, in waters beyond 200 nautical miles from land and at least 2000 meters deep, or to retain all ballast water. However, no similar regulations yet address vessels involved only in coastal transits.

Hazardous Materials
Hazardous wastes produced on cruise ships include by-products of dry cleaning and photo processing operations, paints and solvents, batteries, fluorescent light bulbs containing mercury, and wastes from print shops. A typical ship produces an estimated 110 gallons of photo processing chemicals, five gallons of dry cleaning wastes, and ten gallons of used paints per week. These substances can be toxic or carcinogenic to marine life.

The U.S. Resource Conservation and Recovery Act (RCRA) imposes management requirements on cruise ships and other vessels that generate or transport hazardous waste and requires that hazardous materials be offloaded to land based treatment or disposal facilities.

Solid wastes
Solid wastes generated by cruise ships include large volumes of food waste, cans, glass, wood, cardboard, paper, and plastic. Plastic debris can be ingested or cause entanglement to marine life including marine mammals, seabirds, and sea turtle. In some cases the wastes are incinerated on the vessel and the ash is discharged at sea; other wastes are disposed of on shore or recycled. A typical cruise ship generates eight tons of solid waste per week¹⁴.

The discharge of solid wastes is regulated under APPS and CWA. The Marine Plastic Pollution and Control Act regulates the disposal of plastics and garbage pursuant to ANNEX V of MARPOL. Under these regulations the disposal of plastics is prohibited in any waters, and floating dunnage and packing materials are prohibited in navigable water within twenty-five nautical miles from land. Other garbage including paper, glass, rags, metal, and similar materials is prohibited within twelve nautical miles from shore (unless macerated, in which case it can be disposed of beyond land).

Cruise Line Industry violations
The cruise line industry historically has had a relatively poor record regarding environmental violations. The vast majority of cruise ships are foreign flagged. According to a report published by the Government Accounting Office, there were eighty-seven confirmed illegal discharge cases from cruise ships between 1992 and 1998 in U.S. waters. Eighty-one of these cases involved oil, and six involved plastic or garbage. Seventy-five percent of these violations were accidental (human or mechanical error)¹⁵.

Cruise Line Industry Initiatives
A number of cruise lines have made significant improvements to address environmental concerns in recent years. The International Council of Cruise Lines (ICCL) is the main trade association that represents 16 of the world’s largest cruise lines (95% N American Market, 85% worldwide), and serves as a consultative organization to the International Maritime Organization. ICCL lines reported a reduction in waste by more than 50% between 1992 and 2002. In 2001, the Cruise Industry Waste Management Practices and Procedures document was adopted by ICCL members, and is now a mandatory condition for membership in the organization. Among the principles in this document are: full compliance with international laws and regulations; maintenance of cooperative relationships with U.S. and international regulatory agencies; design, construction, and operation of more environmentally sensitive vessels; utilization of new technologies; adoption of strategies for conserving resources through purchasing and product management; minimization of waste and increasing reuse and recycling; optimization of energy use/efficiency; management of discharges, and; education of guests and staff. These standards are then placed into the Safety Management System for each vessel¹⁶. Several cruise lines have adopted even more stringent voluntary measures, including Celebrity cruises, whose vessels are required by corporate policy to discharge of black water no closer than 12 miles from shore.

Within the Sanctuary, three cruise lines which visited in 2002 voluntarily adopted a no discharge policy within the Sanctuary, following numerous conversations and meetings with Sanctuary staff, State and local government officials and environmental organizations. While the Sanctuary welcomed these voluntary agreements, one of the cruise lines subsequently broke the agreement by discharging within Sanctuary boundaries upon its departure from Monterey. Critics argue that these voluntary industry initiatives are self regulated, not taken seriously by cruise ship operators, and unenforceable.

MBNMS Management Plan Initiatives
As noted above, a wide array of pollutants may be discharged in large volumes from cruise ships. Although there are a number of existing laws and regulations that partly address this issue, there is a need for a more comprehensive prohibition on cruise ship discharges within the MBNMS. These will be developed further as the main components of the JMPR Cruise Ship Action Plan. This plan outlines specific strategies and actions for addressing the threats posed by harmful cruise ship discharges. They include developing a regulation which prohibits these discharges, outreach to the cruise industry regarding Sanctuary policies, developing enforcement and monitoring programs and creating a cruise ship passenger education program.

OTHER RESOURCES:

• City of Monterey Harbor Office schedule of visits for 2004 - 2006 visits: http://www.monterey.org/harbor/cruiseships.html
• State of Alaska's Commercial Passenger Vessel Environmental Compliance (CPVEC) Program: http://www.dec.state.ak.us/water/cruise_ships/pdfs/cpvec_program_overview.pdf
• U.S. EPA Cruise Ship Water Discharge Website: http://www.epa.gov/owow/oceans/cruise_ships/
• Memorandum of Agreement Between State of Florida and ICCL: http://www.iccl.org/resources/fdep_mou.cfm

DOWNLOADABLE DOCUMENTS (PDF):

• EPA Cruise Ship White Paper (60 KB)
• US GAO Report on Cruise Ship Pollution (548 KB)
• State of California Cruise Ship White Paper (352 KB)
• Assessment of Cruise Ship and Ferry Wastewater Impacts in the State of Alaska (816 KB)
• Cruise Industry Waste Management Practices and Procedures (40KB)
• Ocean Conservancy's Cruise Control Report (584 KB)

CITATIONS:

1. State of California Legislature. Assembly Bill 906
2. United States Environmental Protection Agency. 2000. Cruise Ship White Paper. Washington D.C.
3. Bluewater Network. September, 2003. Petition to Promulgate Regulations to Prohibit Cruise Ship Discharges in Marine Sanctuaries.
4. United States Environmental Protection Agency, 2000.
5. Bluewater Network. September, 2003.
6. State of California Legislature. Assembly Bill 906
7. Business Research and Economic Advisors. Aug, 2002. The Contribution of the North American Cruise Industry to the U.S. Economy in 2001. Exton, PA.
8. The Ocean Conservancy. May 2002. Cruise Control: A Report on How Cruise Ships Affect the Marine Environment
9. Bluewater Network. September, 2003.
10. Bluewater Network. September, 2003.
11. The Ocean Conservancy. May 2002.
12. The Ocean Conservancy. May 2002.
13. State of California Legislature. Assembly Bill 906
14. Bluewater Network. September, 2003.
15. Federal Water Pollution Control Act (Clean Water Act)
16. General Accounting Office (GAO) of the United States. 2002. Marine Pollution:Progress Made to Reduce Marine Pollution by Cruise Ships, but Important Issues Remain.

PHOTOS:

All photos on this page are courtesy of Brad Damitz (MBNMS)