191 



Present day statistics for intentional discharges from tank cleaning for bal- 

 lasting varies between 530,000 tons and 1,240,000 tons depending on which figures 

 are used. The average is approximately 800,000 tons. These figures do not include 

 tank cleaning for the removal of sludge build-up or tank cleanings done prior 

 to entering a shipyard for repairs. The United Kingdom in a study, "The En- 

 vironmental and Financial Consequences of Oil Pollution from Ships," presents 

 in Table XX of Appendix I, a summary of oil discharged from ballasting and 

 deballasting operations. These figures are projected to year 2000. The table 

 is based on crude oil transportation only and the figures are calculated using 

 an effectiveness of LOT of 90%. (Table XX is attached). 



The amount of pollution from LOT and non-LOT discharges is lower in Table 

 XX than the average calculated from several sources. So we could say the 

 estimates are conservative. We see that in 1990 if the 1/15,000 criteria is strictly 

 followed only 240,000-250,000 tons of oil would be intentionally discharged, a 

 threefold reduction from the 800,000 tons today. However, we also see that if 

 present trends continue by 1990 approximately 2,250,000 tons could be dis- 

 charged into the oceans — threefold increase. 



We can conclude that if all the tankers in year 1990 could operate a LOT 

 procedure with suflScient effectiveness to meet the 1969 Amendments, then the 

 total amount of oil discharged would be reduced to approximately one-third of 

 that discharged today. The key is gaining the required degree of effectiveness 

 of LOT and effectively dealing with those vessels unable to practice LOT for 

 a variety of reasons. 



TABLE XX.-OIL DISCHARGED IN DEBALLASTING AND TANK-WASHING OPERATIONS: FUTURE TRENDS (TONS P.A). 



1971 Amendments 



/. Wliiit is the estiinutcd cost of these requirements i)i terms of: (a) construc- 

 tion costs; (&) increase in the required freight rate; and (c) additional cost of 

 a gallon of gas at the pump? 



The 1971 Amendments to the 1954 Convention on the Pollution of the Sea by 

 Oil relate to the arrangements of vessel tanks and limitations of tank size for 

 new tankers. The objectives of these amendments are to place a theoretical limit 

 on tlie quantity of oil which can escape into the sea as a result of a collision or 

 other casualty. 



The attempt to assign cost data to the implications of the amendment is tenuous 

 at best for the reason that this is a criterion to which a ship must be designed 

 and not a material requirement. At the time of development of this amendment 

 at IMCO. however, the Italian delegation and the International Chamber of 

 Shipping (ICS) representative did attempt to quantify the cost on a "typical 

 ship" basis. The Italian report concluded that the amendment "did not affect 

 the transi>ortation cost of the cargo for tankers up to 300,000^00,(X)0 tons dead- 

 weight. In larger sizes, they affect this cost in a percentage (approximately 1.5 

 percent) apparently insignificant if compared with the benefit one (may) hope 

 to expect from the limited oil outflow". The ICS indicated that these amend- 

 ments for the ships they investigated amounted to approximately a $100 capital 

 investment per cubic meter of oil saved. Relative to clean-up costs this is rather 

 attractive. 



Quantitatively, the capital costs and increases in required freight rates cannot 

 be estimated. Qualitatively, both of these figures can be said to vary between 

 a negligible amount to at most 2% for the very largest takners envisioned up 

 to 1.000.000 tons deadweight. 



As far as cost of gasoline at the pump, this answer requires deep insight to 

 oil company economics and corporate decision making. That is, how much of 



