196 



The size limitations, wliich admittedly are tentative, are in our opinion too high 

 at 150,000 tons deadweight. We would think that a lower limit sliould be attained 

 at the Convention. 



National and international shipping interests while supporting segregated 

 ballast as presently contained in the draft will not support mandatory double 

 bottoms. 



Nonetheless, the Coast Guard after participating in and reviewing an ex- 

 liaustive study concerning segregated ballast had previously concluded that 

 lankers incorporating the segregated ballast double bottom feature prevailed 

 from a cost/pollution abatement point of view. 



We subsequently drafted a note to IMCO in December of 1972 setting forth 

 A proposal with respect to facilitating the treatment of the vessel source pol- 

 lution problem through the segregated ballast double bottom concept. This note 

 was discus.sed with the U.S. SOLAS Working Group. The Maritime Administra- 

 tion, the Environmental Protection Agency, the Council on Environmental 

 •Quality, the Office of ^Management and Budget and the Department of State 

 were also briefed on this note before presenting it to IMCO. Concurrently, an 

 advance notice of projtosed rule making was published in the Federal Register 

 of 26 January 1973 (Vol. 38, No. 17) with two paramount pun^oses in mind: 



(1) Compliance with Section 201(7) of Public Law 92-340 with regard to early 

 publication ; and 



(2) The solicitation of comments from all sectors of the public. 



Over 60 comments were received on the proposal. As might be expected the 

 comments to such a far-reaching proposal involved much more than simple ex- 

 pressions of support or nonsupport. Three primary areas of concern appeared with 

 a fair degree of commonality in the comments. These were : (1) High initial cost 

 associated with double bottoms; (2) the need for international agreement and 

 the danger of unilateral action; and (3) the treatment to be accoi-ded foreign 

 and domestic shipping not covered by the proposal. 



In regard to the high initial cost associated with double bottoms, we feel that 

 the differential cost of incorporating a double bottom as a means of achieving 

 segregated ballast is an important issue. However, this cost must be weighed 

 against the protection to the environment which it affords. These costs must also 

 be weighed in terms of whether the concept is internationally applied or not. 

 The economic implications or the conclusions reached w^ll l)e quite different de- 

 pending on whether the requirement is based on multilateral or unilateral action. 



We concur that there is a great need for international agreement in the areas 

 under discussion. We are striving with many other agencies and individuals, 

 both within and without the United States Government, to seek a strong and 

 enforceable international ccmvention to further our environmental aims and to 

 alleviate the necessity for any unilateral action on the part of the United States. 

 To this end the Commandant of the Coast Guard, Admiral Bender, acting in his 

 capacity as Chairman of the National Committee on the Prevention of Marine 

 Pollution, has formed a task group under that Committee to prepare the necessary 

 positions and documents for the United States at the October Conference. The 

 Department of State has concurred with this task group's concept. This task 

 group, of which I have been designated as Chairman, has three members of the 

 Coast Guard staff working full time along with other members of the Coast 

 Guard staff on a part time basis as well as participants from the Department of 

 Defense, the Department of State, the Environmental Protection Agency, the 

 Council on Environmental Quality, elsewhere in the Department of Transporta- 

 tion, and the Maritime Administration. Preliminary discussions have already 

 been conducted with industry, environmental, and other interested groups solicit- 

 ing their comments and inputs to the final United States positions at IMCO in 

 October. 



The matter of treatment of existing foreign and domestic vessels is one that 

 must be considered but as of this time is an unresolved issue, both in our na- 

 tional proposal and in the latest draft of the forthcoming convention. The draft 

 convention has a "grandfather" provision for existing vessels. It is our hope that 

 the coming Conference will realistically address this issue. 



Apart from the question of the competitive disadvantages which could arise 

 with the "grandfather" arrangements within the fifth draft of the convention, 

 existing vessels will be required by that draft to: (1) Operate with improved 

 "load-on-top" techniques; (2) have minimum "slop tank" capacity; and, (3) be 

 equipped with certain oil monitoring and control equipment. 



Our task group is especially examining the area of existing vessels with a view 

 toward assessing the availability and feasibility of the oil monitoring equip- 



