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Articles & White Papers
Casualty, Pollution and Salvage

Environmental Compliance in the Cruise Industry
 
May 31, 2001
 

ABSTRACT

The deep-sea, overnight cruise industry is the fastest growing segment of the maritime industry with annual growth rates of eight to ten percent. The environmentally sound and legally compliant operation of its ships is a priority of cruise ship operators. The changing legal landscape, increasing public interest, the activities of a number of interested parties, ship operational requirements, technical innovations, and evolving environmental sensitivity are some of the specific aspects of the overall cruise ship environmental issue. A discussion on these various aspects is presented in order to inform the reader of some of the specific actions and developments to date and to provide a better understanding of the overall issues.

INTRODUCTION

Regulatory and public interest in the potential impacts of cruise ship operations on the environment continues to draw significant attention. As a result of a recent petition by a group of public environmental advocates, the U.S. Environmental Protection Agency has undertaken the task of evaluating cruise ship operations and their potential environmental impacts. This effort is being undertaken concurrently with similar evaluations by states such as Alaska, Florida, and California. The cruise industry is working closely with regulatory agencies and the public to address operational and environmental concerns.

This paper describes the complex legal regime in which the industry currently must operate and the methods the cruise industry uses to meet these stringent environmental requirements. Included is a discussion of current engineering and operational practices applied by the cruise industry to minimize the environmental impacts of their operations.

The paper concludes with an overview of technical and operational changes that are anticipated as a result of current and future regulatory efforts and related developments. A brief industry outlook is also presented.

THE CRUISE INDUSTRY

The U.S.-based, deep-sea, overnight cruise industry served over 6.9 million passengers in 2000 and operated 123 ships on numerous itineraries through the Caribbean, Alaska, and other exotic locales. The total economic impact in the United States alone was calculated to be over $15 billion. To say that the cruise industry is the fastest growing segment of the overall maritime industry is an understatement. With a growth rate of between eight and ten percent over the past several years, as of January 2001, there were fifty-three new cruise ships on order to be delivered by 2005. At a total investment of over $18.5 billion, these new ships will add over 98,000 berths to the market (Seatrade Cruise Review 2001). As a specific example of growth, one major cruise operator will increase its capacity from 18,670 available berths in 1998 to 45,006 berths in 2004 – a whopping 241% expansion (International Cruise and Ferry Review). This expansion will be even greater if options for additional ships are exercised. With this explosive growth come great opportunities as well as great challenges. One such challenge is the environmentally sound and legally compliant operation of these ships.

THE LEGAL REGIME

Cruise ships operate within a pervasively regulated industry. They are subject to control and oversight from their flag state (i.e., the nation with which they are registered), the port states (i.e., the nations at which they make port calls), and, in the United States, the individual states and localities that they visit. International standards are developed by the International Maritime Organization (IMO). Cruise ships are also inspected and surveyed by classification societies. With respect to environmental issues, the major international standard applicable to cruise ships is the International Convention for the Prevention of Pollution from Ships, commonly referred to as MARPOL. This standard addresses such things as operational discharges of oil, disposal of garbage and plastics, and air emissions. Most flag states and port states, including the United States, have adopted MARPOL requirements as their domestic standard, so that compliance with this convention constitutes compliance with national law. The International Safety Management (ISM) Code required by Chapter IX of the International Convention for the Safety of Life at Sea (SOLAS) is also important to environmental protection. This code requires an extensive Safety Management System (SMS) that addresses safety and environmental management practices and procedures.

The United States has also adopted a series of national environmental laws that are applicable to all cruise ships operating in U.S. waters. The drafters of some of these statutes, such as the Federal Water Pollution Control Act (FWPCA), consciously considered maritime issues. Other statutes, though, such as the Clean Air Act (CAA) and the Resource Conservation and Recovery Act (RCRA), were implemented with little or no consideration of maritime application, which was primarily recognized after the fact. The FWPCA prohibits the discharge of oil and hazardous substances into waters of the United States. It also addresses the operation of marine sanitation devices (MSDs). The CAA authorizes the U.S. Environmental Protection Agency (EPA) to establish air emission standards and impose civil penalties for emissions in excess of those standards. RCRA authorizes the EPA to establish regulations relating to the handling and disposal of hazardous waste. Under this statute, the EPA has developed a complex and paperwork-intensive program that tracks hazardous waste "from cradle to grave."

In the federal system of the United States, each state has broad residual authority or "police power" over most issues, with the exception of things such as national defense and coinage, and regulation of interstate or foreign commerce. One area in which the states and local jurisdictions have and exercise extensive authority is that of environmental protection. Thus, balancing the states rights against federal interests, each state or community visited by a cruise ship may adopt standards with respect to defining permissible discharges, including graywater (from dishwashers, showers, laundry, bath, galleys, and washbasins), blackwater (sewage and medical and dental sink drainage), oil, ballast water, and air emissions. Florida, where the majority of large cruise ships are based, has adopted stringent standards for hazardous waste management, in accordance with the RCRA. California has initiated programs affecting cruise ships by addressing such things as ballast water discharges and air emissions.

PRIOR ENVIRONMENTAL VIOLATIONS

Over the past several years, the cruise industry has experienced several highly visible environmental violations. They have been cited for discharges of oily waste, hazardous substances, and plastics, as well as excessive air emissions. In an effort to improve their stature as good environmental citizens and reduce the risk of future environmental violations, cruise lines are adopting compliance programs that establish formal internal regimes for meeting or exceeding environmental standards, and for training and auditing. They are also installing new equipment to significantly reduce discharges and emissions.

THE GAO REPORT

The United States General Accounting Office (GAO) published a Report to Congressional Requesters in February 2000 (GAO 2000). This report, entitled "Marine Pollution – Progress Made to Reduce Marine Pollution by Cruise Ships, but Important Issues Remain," was developed in response to a request by Congressman John D. Dingell (D-MI) and Congressman Henry A. Waxman (D-CA) and addressed the general issue of cruise ship environmental performance and several specific related issues, for the period of 1993-1998. The report concluded that federal agencies and the cruise industry have recently taken positive steps to improve environmental performance and compliance. While the report indicated that only four percent of the pollution violations by commercial foreign-flagged ships were attributable to cruise ships, and that many of these instances were a result of accidents, such as failed hydraulic lines and spilling of "a few drops of paint," it also recognized that a number of significant environmental issues still require attention by all parties. These issues include technical and scientific aspects of environmental protection, as well as operational, legal, administrative, and policy matters.

THE BLUEWATER NETWORK PETITION

On March 17, 2000, the environmental advocacy group, Bluewater Network, and 53 other organizations sent a petition to the EPA urging various regulatory actions to further control cruise ship discharges. The petition, and an accompanying report entitled, "Cruising for Trouble: Stemming the Tide of Cruise Ship Pollution," (Schmidt 2000) expressed concern over a number of issues including, the magnitude of the discharge volumes from an increasing number of larger cruise ships. The petition and report recognized that cruise ships generate and discharge several waste streams and requested that the EPA take the following actions:

  1. Assess the volumes and characteristics of cruise ship discharges.
  2. Identify potential water quality, aquatic environment, and human health impacts.
  3. Examine existing federal regulations governing cruise ship discharges.
  4. Recommend means to control and regulate cruise ship discharges.
  5. Outline monitoring and record-keeping options for pollutants discharged by cruise ships in U.S. ports.

EPA INITIATIVES

Traditionally, the EPA has paid scant attention to ships. In addition to exempting discharges from properly operating marine engines from the FWPCA prohibitions, the agency also exempted discharges of sewage, wastes from laundries, showers, and galley sinks, and other discharges incidental to the normal operation of a vessel from requiring permits under the National Pollutant Discharge Elimination System (NPDES). Sewage treatment and discharge, however, is addressed in the law and in implementing regulations overseen by the United States Coast Guard. In response to the Bluewater Network petition and other concerns expressed, the EPA has undertaken a study of environmental issues associated with cruise ship operations. The agency has commenced a broad assessment of cruise ship discharges.

To this end, the EPA launched an interagency work group on March 31, 2000 to develop and implement a plan for responding to the Bluewater Network petition. This work group developed a draft six-month action plan outlining proposed actions in response to the petition. These actions included conducting public hearings to solicit input from interested parties, gathering cruise ship waste discharge information, drafting a report on cruise ship discharges, and reviewing existing regulatory requirements to determine which, if any, should be updated. Public hearings were announced in the Federal Register on August 11, 2000 and were held in the regional locations of Los Angeles, Juneau, and Miami in September 2000. On August 22, 2000, the EPA published a Cruise Ship White Paper (EPA 200) containing preliminary information regarding cruise ships and waste management practices and some preliminary discussion on how the EPA might respond to the Bluewater Network petition.

FEDERAL LEGISLATION

Congress recently enacted, as part of a consolidated appropriations act, a bill introduced by Senator Frank Murkowski (R-AK) addressing certain cruise ship operations in Alaska waters. This stand-alone legislation codifies many of the operational practices previously agreed upon by all participants in the Alaska Cruise Ship Initiative, including cruise ship operators. It reinforces and enhances prior federal measures regarding ship discharges, but limits its application to large cruise ships in Alaska. It prohibits discharge of untreated sewage into navigable waters of the United States within Alaska and certain other U.S. waters in the vicinity of Alaska. It specifies that the discharge of treated sewage and graywater is permitted only when a cruise ship is proceeding at not less than six knots, is more than one mile from land, is in compliance with all applicable discharge standards, and when the discharge is not otherwise prohibited. The legislation establishes requirements with respect to effluent quality for sewage and graywater, which the EPA is authorized to change by regulation. The U.S. Coast Guard is directed to establish a cruise ship inspection and wastewater sampling regime, examine environmental compliance records and procedures, and inspect the functionality and proper operation of equipment installed for abatement and control of discharges. Owners, operators, and masters of cruise ships are required to immediately report any discharge in violation of the legislation. Violations may result in the assessment of civil penalties. Negligent violations may result in misdemeanor prosecutions. Persons who knowingly violate the restrictions may face felony prosecutions, as may anyone who knowingly makes a false statement or tampers with any testing or monitoring device or method required by the legislation. To date, no implementing regulations have been promulgated, although the cruise industry is working closely with the Coast Guard and other regulatory agencies to ultimately comply with the requirements.

U.S. COAST GUARD ACTIONS

As part of their role in participating in interagency work groups and in fulfilling their mission, the U.S. Coast Guard conducted Operation Cruise Watch 2000 from June to September 2000 to place increased emphasis and focus on cruise ships for compliance with applicable environmental laws. The Coast Guard increased the scope of its environmental inspections and oversaw the sampling of cruise ship discharges for every major cruise ship operating in Alaskan waters. The cruise industry voluntarily agreed to cooperate in this program and funded the sample analysis efforts. Coast Guard inspectors dedicated more time during their periodic inspections reviewing environmental compliance and examining oil-water separators (OWS) and marine sanitation devices. These increased efforts in inspection and oversight of pollution prevention equipment and environmental management practices are continuing.

STATE INITIATIVES AND RELATED ACTIONS

Alaska

In December 1999, the Alaska Department of Environmental Conservation (ADEC) invited the EPA, the Southeast Alaska Conference (representing Southeast Alaska communities), and the Coast Guard to join with cruise ship industry officials in discussions to improve cruise ship discharge and pollution prevention practices. The meeting objectives included the identification of discharges and spill risks, development of pollution prevention and waste management techniques to eliminate or reduce pollution impacts, evaluation of the compliance process, and ways to educate the public on these issues. After this initial meeting, ADEC established the Alaska Cruise Ship Initiative and formed several work groups to assess cruise ship discharges, focusing on air quality, oil pollution response, wastewater and solid waste management, and environmental leadership. After receiving questions and complaints from environmental groups and Alaskans, the Coast Guard, as part of the Initiative, examined the need to change the standards for wastewater discharge. One major impact on this decision stemmed from the controversy involving cruise ships transiting through "doughnut holes," which are small, localized areas within the Inside Passage of Alaska that are more than three miles from any land and technically considered to be international waters where certain wastes can be legally discharged. These discharges into the "doughnut holes" would not be permitted if these waters were classified as territorial waters of the United States. In an effort to allay this controversy, the non-U.S. flagged cruise ships on Alaskan itineraries pledged in 1999 to consider all the waters of the Alexander Archipelago as internal to the U.S., and therefore, off limits to discharges by cruise ships.

In July 2000, the Alaska Cruise Ship Initiative developed a sampling plan and laboratory analysis procedures for both graywater and blackwater to determine the type, quantity, and constituent makeup of cruise ship discharges. The regulatory agencies, cruise ship industry, environmental groups, and interested citizens worked cooperatively to develop the sampling plan which required each cruise ship to have its wastewater discharges sampled twice during the summer. Since the cruise industry had already committed to discharging only when at least ten miles from port, the sampling occurred while underway.

Following the release of preliminary results from Alaska's cruise ship sampling efforts in September 2000, Alaska's Governor Tony Knowles called on state and federal governments to toughen cruise ship environmental regulations. Final results from the sampling effort indicate that a majority of the samples analyzed failed to fully comply with established standards. Many graywater samples exhibited fecal coliform counts in excess of 1000 per 100 milliliters (ml) and as many as nine samples of treated blackwater exhibited counts in excess of 10 million per 100 ml. A complete summary of findings is available in the Initiative’s November 2000 Wastewater Monitoring Fact Sheet (ADEC 2000).

Florida

The Florida Department of Environmental Protection (FDEP) signed a memorandum of understanding (MOU) on March 14, 2000 with the fifteen cruise-line members of the Florida-Caribbean Cruise Ship Association (FCCA). The MOU effectively documented the FDEP's acceptance of a set of waste management practices and procedures and formalized an agreement between the FDEP, the FCCA and its members, and the Coast Guard to work together on discharge management proposals, meeting on an annual basis. The cruise industry waste management practices and procedures, as appended to the MOU, outlines environmentally responsible and legally compliant practices and procedures for the minimization, reuse, and recycling of wastes and specific procedures for improved management and disposal of solid wastes, hazardous wastes, and wastewaters, including graywater, blackwater, and bilgewater. Additional principles under the agreement included compliance with applicable environmental laws and regulations, development of educational training for discharge management, and environmentally-friendly cruise ship designs. The U.S. Coast Guard is also recognized as the onboard inspection agency and a comprehensive inspection checklist for onboard environmental compliance oversight has been developed jointly by the cruise industry, the Coast Guard, and FDEP personnel. This group is working on a number of tasks, including, for example, a resolution to the issue of numerous waste tracking numbers being used to follow hazardous wastes transferred ashore in different ports around the United States. Ultimately, the use of a single waste tracking account number for all waste generated by a given ship will provide more efficient management, tracking, and accountability.

California

In September 2000, the California Legislature passed, and Governor Gray Davis signed, Assembly Bill AB 2746 (AB 2746). The objective of AB 2746 is to evaluate the environmental practices and waste streams of large passenger vessels and regulations pertaining thereto. AB 2746 called for the creation of the California Environmental Protection Agency Cruise Ship Environmental Task Force, composed of representatives from the State Water Resources Control Board, Department of Fish and Game, Department of Toxic Substances Control, Integrated Waste Management Board, State Lands Commission, and Air Resources Board. The U.S. Coast Guard will also participate in the Task Force. The purpose of the Task Force is to gather information necessary for the preparation of a report to the Legislature due June 1, 2003. As stated in the bill, and as requested by the task force, cruise vessel operators will provide records or information relating to waste released or offloaded after January 1, 2001, from vessels in California. Such information may be in the form of copied excerpts of records and manifests, including oil record books, garbage record books and other ships logs. The report of the Task Force is expected to: identify areas that may not be adequately addressed by existing reporting requirements; identify opportunities to improve coordination of regulatory efforts; and make recommendations to the U.S. Coast Guard and State agencies to address any areas where additional regulations or reporting may be appropriate.

CRUISE INDUSTRY INITIATIVES AND RELATED ACTIONS

The International Council of Cruise Lines (ICCL) is an industry trade association representing sixteen major cruise operators. In August 2000, ICCL and the U.S. Coast Guard jointly conducted an environmental management forum during which the Coast Guard, the EPA, the National Oceanic and Atmospheric Administration (NOAA), the U.S. Department of Justice (DOJ), various state agencies, and public environmental advocacy groups were invited to discuss industry waste management practices, environmental concerns, and existing oversight mechanisms. This forum led to an industry initiative to develop a guideline intended to propose more uniform environmental management practices. This guideline, developed with the input of the EPA, the Coast Guard, and other interested parties, is expected to provide guidance to all cruise ship operators to ensure that management systems are uniform in the scope of the elements addressed and to assure oversight agencies and the public that shipboard waste management practices and procedures are being properly conducted.

Additionally, in an effort to better understand some of the technical issues behind cruise ship discharges, the ICCL commissioned a dispersion analysis and report. This study estimated the expected concentrations of wastewater constituents following release from a "typical" cruise ship underway at various speeds. The results of this analysis indicated that wastewater constituents would disperse into the receiving waters with a dilution factor as large as 111,000 (Kim 2000). The Northwest Cruise Ship Association (NWCA), another industry trade association, conducted rudimentary water sampling studies in the waters off Ketchikan Alaska, which indicated that constituent concentrations likely drop off so quickly in the receiving waters that they become essentially undetectable. Currently, the industry and the EPA plan to cooperatively conduct a wastewater dispersion analysis in the spring of 2001 utilizing the R/V Anderson, a scientific research vessel. It is envisioned that the R/V Anderson could trail behind a transiting cruise ship taking concentration measurements. While there has been much preliminary discussion, the detailed water sampling plan and testing protocols for determining constituent or indicator dye concentrations in the actual receiving waters are still under development.

Individual cruise lines operating in Alaska, the Caribbean, and elsewhere have undertaken numerous initiatives to mitigate environmental effects, to ensure legal compliance, and to exhibit their willingness and desire to be good neighbors. Some of these initiatives include developmental efforts with equipment vendors in wastewater treatment systems, partnerships with NOAA and other research institutes, installation of onboard oceanic science labs, and the purchase and installation of state-of-the-art shipboard machinery with improved environmental performance. An indisputable sign of commitment to environmental protection and good stewardship is the standby deployment of oil recovery barges and equipment throughout the waters of Alaska.

CRUISE SHIP DISCHARGES

Graywater

Graywater is defined in 33 CFR 151.05 as drainage from dishwashers, showers, laundry, bath, galleys, and washbasin drains and does not include drainage from toilets, urinals, hospitals, and cargo spaces. It traditionally contains suspended solids, classical pollutants, nutrients, and fecal coliform bacteria. It might also contain organic compounds, petroleum hydrocarbons, oils and greases, and metals. This constituent makeup presents some biological and chemical oxygen demand on receiving waters. Cruise ship generation rates for graywater have been estimated at about fifty gallons per person per day (Alaska Cruise Ship Initiative 2000). For the typical ship undertaking a seven-day voyage with a combined passenger and crew count of 3000 persons, this equates to a total graywater generation volume of approximately 1.1 million gallons. Given the physical and logistical impossibility of holding such total volumes for any length of time, graywater is discharged in a controlled manner during the course of the voyage. One possible discharge scenario can include collection of as much as 300,000 gallons of graywater, then discharging it at pump rates as high as several hundred gallons per minute. Discharging of collected graywater can occur over several hours and as often as operationally necessary during the ship’s voyage. Samples of graywater collected from Alaskan cruise operations have shown relatively high levels of fecal coliform. The possible causes of such higher-than-expected constituent concentrations and the potential impacts of graywater constituents on the environment continue to be investigated.

GRAYWATER CONTROL

Graywater generated by cruise ships can be handled in several different ways to ensure environmental protection. Generally, as technology is developed and proven, graywater will be treated for reuse, treated for release to the receiving waters, or converted to solid or gaseous form for ultimate destruction or removal. Currently, graywater is collected and held for controlled discharge in accordance with current requirements and industry practices.

One of the most promising treatment technologies involves the filtering of contaminants from graywater, thereby reducing or eliminating the adverse environmental impact potential of the discharge. Filtration equipment can be configured into various shipboard systems from a number of commercial vendors, both foreign and domestic. Each embodiment of the filtration technology employs different filter media, preconditioning schemes, filter maintenance techniques, and equipment packaging concepts. The levels to which contaminants are removed can also vary. This variability is largely dependent on the particular filter element design and rating, the nature of the influent graywater, and on the effluent purity needs at the treated end. Water suitable for reuse in ship’s laundries, machinery plants, for deck washing, and for other technical uses can be produced with proper filtration from graywater. The theory of filtration treatment allows for treatment to water quality suitable for human use, including contact recreational use, bathing, and ingestion as drinking water. Filtration systems are augmented with chemical, thermal, or radiant disinfection processes to achieve discharge quality suitable for drinking.

Given the range of treated effluent quality available through filtration treatment, effluent quality suitable for discharge to various receiving waters can be achieved. Successful application of a commercially available and viable filtration system can lead to environmentally protective, legally compliant, and socially acceptable disposal of graywater from cruise ships.

To date, the industry’s experience with filtration systems, while limited, has been basically successful in initial shipboard field tests. Some of the technical difficulties anticipated from the deployment of filtration systems have included installation delays, system throughput limits, and filter element maintenance and ultimate life. Related to these issues are feasibility concerns including space allocation, impacts to ship operations, reliability and availability estimates, and cost. Some of the first treatment systems that have been installed are continuing to undergo evaluation and data collection while analyses of problems and issues continue in order to optimize system installation and operation.

Beyond the various embodiments of filtration technologies, other graywater treatment techniques include an activated oxidation process in which water soluble organics in the graywater are destroyed by exposure to hydrogen peroxide and ozone, as well as an electro-chemical flocculation process. Shipboard treatment systems based on these techniques are also under evaluation for throughput, effluent quality, reliability, maintenance requirements, and other feasibility issues.

Collection and holding of graywater and treated blackwater until the requisite discharge conditions are met, as provided for in the recent Congressional enactment of the "Murkowski Bill," is a significant step toward further precluding the possibility of adverse effects on receiving waters. Such efforts at managing the handling of wastes is an effective, albeit not technical, method of mitigating environmental risks.

Blackwater

Blackwater is defined as waste from toilets and urinals. Blackwater also includes sink drainage from medical and dental facilities. The key measurable characteristics of blackwater include fecal coliform count, suspended solids concentration, nitrogen concentration, pH, and resultant biological and chemical oxygen demand. Cruise ship generation rates for blackwater have been estimated at about five gallons per person per day (Alaska Cruise Ship Initiative). For the typical ship undertaking a seven-day voyage with a combined passenger and crew count of 3000 persons, this equates to a total blackwater generation volume of approximately 105,000 gallons, prior to any form of treatment. Blackwater can be buffered in holding tanks, biologically or chemically treated by MSDs, and discharged where allowed. Typically, some combination of these practices is employed. Examination of installed MSDs aboard ships operating in and around Alaska waters have shown some instances of improperly functioning MSDs whose effluents did not meet design specifications for a properly installed and functioning MSD. Specifically, fecal coliform counts were in excess of 200 per 100 ml. Studies and investigations have been launched to ascertain the cause of improperly functioning MSDs. While complete and conclusive findings are pending, one possible explanation could lie in the sampling methodology. It has been suggested that treated blackwater samples taken from holding tanks downstream of the treatment device might have much higher fecal coliform concentrations due to an incubation phenomenon within the holding tank itself. Treated blackwater effluent, if taken directly from an MSD, might exhibit markedly lower contaminant counts. Again, the investigations are continuing.

BLACKWATER CONTROL

The treatment of blackwater aboard cruise ships is relegated to Type II MSDs approved in accordance with IMO requirements or certified by the U.S. Coast Guard. The certification testing protocol requires that treated effluent from these MSDs contain not more than 150 milligrams per liter (mg/L) of total suspended solids (TSS) and not more than 200 fecal coliform per 100 ml, according to 33 CFR 159.126. Many of the treatment systems being examined for graywater treatment are also capable of further processing the treated blackwater effluent from Type II MSDs to achieve improved constituent characteristics. Treatment of commingled graywater and treated blackwater, along with related collection, storage, and handling issues, are being studied as part of the overall cruise ship wastewater treatment effort.

Hazardous Wastes and Substances

Examples of waste materials onboard cruise ships that are considered hazardous and that must be handled in accordance with the requirements of RCRA include photo and x-ray processing chemicals, chlorinated dry cleaning solvents, spent fluorescent and mercury vapor lamps and some batteries, some pharmaceuticals, and some miscellaneous shop process byproducts such as from print, paint, and repair shops. Contained within these liquid and solid wastes are heavy metals, volatile organic compounds, and other compounds that, if not properly handled, can pose a danger to the environment and directly to humans through both short and long-term exposure. Within the legal regime that cruise ships operate under, the handling and ultimate disposal of such hazardous materials are strictly prescribed. The industry has established practices for the safe, environmentally sound, and legally compliant handling of these wastes. These practices include a combined regimen of sorting and segregation, containerization, safe storage, and transfer to approved shore disposal facilities. In many cases, recycling programs and pollution prevention efforts, by which the type and amount of potentially polluting substances and materials are reduced, are relied upon as an integral part of the overall environmental protection and compliance effort.

Oily Wastes

Oily waste discharges from cruise ships are primarily a product of the propulsion plant and auxiliary machinery. Hundreds of thousands of gallons of fuel oil and lube oil are carried by a cruise ship at the onset of a typical voyage. A mechanical mishap or structural damage could lead to the unintended release of some of this oil. However, such events are rare and only occur as a result of other events, such as a collision or grounding. Oily waste discharges most commonly take the form of bilge accumulations or equipment drainage that is collected for proper treatment and disposal. Oily wastes are collected in large buffer tanks then processed through oil-water separators. These devices typically employ gravity separation or centrifugal force processes, aided by the natural tendency of oil to separate from water. Other means of treating oily wastes include electro-chemical flocculation, biological digestion, membrane polishing, oil absorption, and incineration. Investigations into the feasibility and effectiveness of these and other techniques and actual shipboard evaluations are currently ongoing. It is worth noting that, together with these technical developments, the IMO is in the process of reevaluating certain key aspects of MARPOL related to oil pollution. As a result, changes intended to provide added environmental protection are expected.

Solid Wastes

Solid wastes generated aboard cruise ships during the course of a typical voyage include paper, plastic, glass, metal, and other trash produced by passengers and crew. It does not include materials otherwise designated as hazardous. It also does not include food wastes from galleys and passenger meal consumption. Not unlike the techniques for handling hazardous materials and substances, solid waste is sorted and segregated. The waste is then stored for proper disposal ashore, recycled, or incinerated aboard ship. All of these practices ensure minimal adverse impacts to the environment.

Air Emissions

Cruise ship operations, like other segments of the marine industry, generate air emissions from operating propulsion engines, auxiliary engines, and incinerators. The stack emissions contain the byproducts of combustion including oxides of nitrogen, sulfur, and carbon, unburned hydrocarbons, and particulate matter. The opacity of stack emissions from cruise ships has drawn recent attention in Alaska and California, for example, and has resulted in notable actions by ship owners and operators, including changes in operational procedures, controlling fuel selection, equipment changes, and system modifications. The design and selection of the engines, the manner in which they are used when approaching, maneuvering in, and departing ports, and the condition in which they are maintained all impact stack emissions. In an unprecedented effort to help improve the air quality in Alaska, Princess Cruises, a major operator, is planning to secure its shipboard service generators in favor of taking shore power from the pier when in the Alaskan port of Juneau. Of course, advances in engine design and shipbuilding will also have beneficial trickle down effects. The installation of gas turbine power or newer "greener" diesel engines on some new construction ships are examples. All these efforts are indicative of the industry’s awareness and sensitivity and their good-faith efforts to minimize air emissions.

THE INDUSTRY’S OUTLOOK

There is no doubt that the cruise industry, the vast majority of whose ships are non-U.S. flagged, will continue to be heavily scrutinized. Cruise ships engaged in international trade must comply with a regulatory scheme that includes international, federal, and state requirements. However, all of these ships call at numerous ports around the world. In fact, cruise ships call at over 300 ports in over 100 different countries. This being the case, the cruise industry will continue to call for standardized regulations so that equipment designed to comply with the laws in Alaska, for example, will be suitable for compliance with the laws in California, Florida, Melbourne Australia, Istanbul Turkey, or Southampton England. As an international trade, the cruise industry seeks international solutions. Many of the solutions to environmental concerns, which will be implemented by the industry in locations around the world, are being developed as a result of the many legal requirements the industry is facing in the United States.

In a proactive effort to address concerns expressed mainly in the United States but certainly applicable in any operating location, the cruise industry has taken to voluntarily adopting mandatory industry standards for environmental protection issues, as well as for safety, security, and health. As the industry develops and implements this self-regulating posture, especially for issues where there currently are no regulations and in which the regulatory process may take years, these industry standards will set the bar higher for all cruise ships and these standards may become applicable to other segments of the maritime industry as a whole. Solutions to environmental problems, or what may be perceived as environmental problems, may also impact shipboard operations and not just their design and equipment. The agreement to preclude discharge of graywater or treated blackwater while a ship is in port is one example. This practice was formally codified in the enactment of the "Murkowski Bill" for the waters of Alaska, although cruise ship operators apply such industry policy globally to the extent possible. As environmental protection issues continue to unfold, there may indeed be additional operational impacts that could go so far as to affect the selection of ship itineraries and ports of call.

Undoubtedly, self-policing will be important for an industry that has been publicly embarrassed by several environmental violations over the past decade. In this era of instantaneous communications, it will continue to be imperative that the cruise lines be proactive in assuring that facts are forthcoming regarding their self-imposed standards as well as continuing to inform the regulators and the public of their current onboard waste management practices and procedures. The cruise industry must be diligent in ensuring the accuracy of the facts it reports, and also stay vigilant to ensure the same of others. Certainly, as new technologies are refined and applied onboard ships and even as old technologies are adapted for use onboard cruise ships, the cruise industry will want to make these developments known. Use of environmental technologies such as gas turbine/diesel combinations (CODAG) and water injection techniques to reduce air emissions, improved graywater treatment and blackwater treatment systems, dry cleaning and photography systems that do not result in hazardous wastes, and "clean" ballast water systems will be important steps forward that the cruise industry will want to publicize to the regulators and to the public.

CONCLUSION

The cruise industry operating U.S. itineraries is continually under increasing scrutiny and pressure to adhere to environmental regulations and to actively participate in the development of related technical, operational, policy, and legal initiatives. As good corporate citizens who care about the environment and as responsible businessmen, the leaders in the industry have made marked strides in recent years toward developing an integrated solution to the environmental protection issue. Engaging all interested and responsible parties in open communications, better defining issues and points of concern, initiating technical studies and data collection efforts, testing technological innovations in a shipboard setting, and evaluating any necessary regulatory reform are all examples of progress made. As the issues continue to develop and evolve, the industry will meet many challenges and continue to face new ones. Following the significant accomplishments of 2000, the Alaska Cruise Ship Initiative, and its many component organizations, plan to continue its record of unprecedented actions and achievements in 2001. The results of planned sampling events, findings from Coast Guard inspections, and feedback from the industry on its own environmental management guidelines will further define the status of environmental compliance in the cruise industry. Technical research, development, testing, and evaluation will undoubtedly continue as one of the many key aspects of the total solution. A periodic reexamination of these issues, related developments, and ultimate impacts are all important aspects of a comprehensive approach to sound environmental practices.

REFERENCES

Alaska Cruise Ship Initiative, "Part I Final Report - Activities and Work Products up to June 1, 2000."

Alaska Department of Environmental Conservation. Alaska Cruise Ship Initiative, Wastewater Monitoring Fact Sheet, November 2000. www.state.ak.us/dec/press/cruise/cruise.htm

International Cruise and Ferry Review, a CCL Magazine, a subsidiary of Euromoney Publications PLC, London. "Capitalizing on the Spoils of a Bull Run," Simon Jones interview with Tim Harris, Chairman, P&O Cruises. Page 14.

Kim, Don K., P.E., "Cruise Ship Wastewater Dispersion Analysis – Report on the Analysis of Graywater Discharge," prepared for the International Council of Cruise Lines, September 14, 2000.

Schmidt, Kira, "Cruising for Trouble: Stemming the Tide of Cruise Ship Pollution," Report prepared by the Director of Bluewater Network’s Cruise Ship Campaign, March 2000.

Seatrade Cruise Review Published by The Seatrade Organisation, Ltd. March 2001, Vol. 5 No. 1. Page 41. "’Market News’ Cruiseship Orderbook at End January 2001."

United States Environmental Protection Agency, "Cruise Ship White Paper," August 22, 2000.

United States General Accounting Office, Report to Congressional Requesters, "Marine Pollution – Progress Made to Reduce Marine Pollution by Cruise Ships, but Important Issues Remain," GAO/RCED-00-48, February 2000.

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Don K. Kim, P.E., is an Environmental Program Manager in the M. Rosenblatt & Son Group of AMSEC, LLC in Arlington, Virginia. Mr. Kim earned his Bachelor of Science and Master of Engineering degrees in Mechanical Engineering from the University of Virginia. He is a registered Professional Engineer in the Commonwealth of Virginia. He is a member of the American Society of Naval Engineers and the American Society of Mechanical Engineers.

Dennis L. Bryant, Esq., is Senior Counsel in the Washington Office of Haight Gardner Holland & Knight, a law office of Holland & Knight LLP. He specializes in the government regulation of ships and shipping. He served twenty-seven years of active duty in the U.S. Coast Guard, retiring as a Captain, after supervising the agency's implementation of the Oil Pollution Act of 1990. He is a graduate of the U.S. Coast Guard Academy and Vanderbilt Law School. He serves as chair of the Committee on Navigation, Coast Guard, and Government Regulation of the Maritime Law Association of the United States.

Jennifer M. Salerno is a Senior Environmental Consultant with Booz Allen & Hamilton in Arlington, Virginia. Ms. Salerno earned her Bachelor of Science degree in Marine Biology from the University of Maryland at College Park and her Master of Science degree in Environmental Studies from American University in Washington, D.C. Her work focuses toward coastal zone management concepts, endangered species consultations, and development of water regulations.

Thomas E. "Ted" Thompson is Executive Vice President of the International Council of Cruise Lines. He retired in 1995 from the U.S. Coast Guard as a Captain after twenty-seven years of service, twenty-three of which were in the field of marine safety and environmental protection. Mr. Thompson graduated from the United States Coast Guard Academy in 1968 and received his Master of Engineering degrees in Naval Architecture and Marine Engineering and in Nuclear Engineering from the University of Michigan in 1975. He has been a member of the Society of Naval Architects and Marine Engineers since 1990.

DISCLAIMER: This paper expresses solely the findings and opinions of the individual authors and does not necessarily reflect the positions of any company, organization, or industry.

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