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1/30 000th of the cargo of a 300,000 dead weight ton "supertanker" (as is now 

 proposed) this would mean that almost 10 tons of oil could be discharged per 

 voyage and, assuming 40% ballast, the effluent could contain 100 ppm of oil. 

 Tliese are not negligible amounts. As noted above, severe environmental damage 

 can result from very low concentrations of aromatic derivative compounds in 

 sea water Moreover^ permitting any discharge at all adds to the increasing ac- 

 cumlations of oil in the oceans. The National Oceanic and Atmospheric Admin- 

 istration recentlv reported that "oil globules ... in massive proportions infect 

 nearly 700.000 square miles of blue water from Cape Cod to the Caribbean Sea." 

 Mar Map Red Flag Report (No. 1), Fish Larvae Found in Environment Con- 

 taminated icith Oil and Plastic (January 18. 1973). If seaborne imports of oil 

 to the United States and Western Europe and oil tanker traffic increase, as both 

 government and industry project, the environmental degradation from oil pollu- 

 tion resulting from vessels and their operations will increase proportionately. "'Not 

 only will the probability of accidents increase . . . but pollution of the marine 

 environment from normal tanker operations [is] also likely to increase." S. Rep. 

 No. 92-841, 92d Cong. 2d Sess. 22 (1972). Thus, even with relatively low dis- 

 charge standards, adverse environmental effects will result, and the accumulation 

 of oil in the oceans will continue to grow. 



As noted above the objective of the Convention is the "complete elimination 

 of willful and intentional pollution of the sea by oil . . . to be achieved by 1975, 

 if possible. . . ." Thus, the Convention should adopt if possible a "no discharge 

 standard. At the very least, before any discharge standards are adopted, they 

 must he justified environmentally — a task that has not even been attempted. 

 The Convention should only establish discharge criteria which meet the fol- 

 lowing two conditions: (1) that conclusive evidence shows that it is not tech- 

 nologically feasible to reduce discharges below those levels, and (2) that con- 

 clusive evidence demonstrates that discharges at such levels are not harmful. 



(c) The Environmental Necessity for Segregated Ballast and Double Bottom 



Requirements 



As mentioned above, meaningful discharge limitations must be buttressed by 

 stringent design and construction standards. The critical design issue to be 

 discussed at the October Conference will be the proposal that all new oil tankers 

 incorporate "segregated ballast systems." By eliminating the need to mix oil 

 and water in wash cargo tanks, these systems are without doubt the most ef- 

 fective means for reducing damage to the marine environment from normal 

 tanker operations. The United States has proposed that segregated ballast be re- 

 quired and that it be achieved, in part, through incorporation of a double bot- 

 tom. Such a combination, which provides protection against accidental dis- 

 charge caused by groundings — the most common cause of tanker casualty — as 

 well as protection against operational pollution, is an environmentally sound 

 approach. The double bottom — although not the segregated ballast proposal- 

 has been rejected in entirety in the current draft of the Convention. 



This Committee need hardly be told that, in the Ports and Waterways Safety 

 Act of 1972. Congress found that, "existing standards for the design, construc- 

 tion, alteration, repair, maintenance and operation of . . . [oil carrying vessels] 

 must be improved for adequate protection of the marine environment." In reach- 

 ing this conclusion. Congress implicitly rejected the prevailing single bottom 

 design for tankers and the traditional practice of utilizing cargo tanks for 

 ballast and discharging oily water into the sea. 



The segregated ballast/double bottom feature is precisely the kind of design 

 and construction innovation which Congress intended to be developed and 

 required. It is clearly superior to load-on-top methods or shoreside disposal — 

 other alternatives proposed in the Convention. Indeed, to permit the use of 

 load-on-top as an alternative to segregated ballast/double bottoms would amount 

 to nothing more than to maintenance of the status quo. Thus, we believe that 

 such a design and construction standard should be made mandatory on all 

 vessels. 



As it now stands, the segregated ballast requirement would only apply to oil 

 tankers in excess of 1. '0,000 dead weight tons and combination carriers in excess 

 of 100.000 dead weight tons. These tonnage limitations are far too high and wholly 

 without justification. Coast Guard studies have demonstrated that a segregated 

 ballast/double bottom approach is cost effective down to ships as small as 

 20,000 dead weight tons, and, in point of fact, several tankers of both intermediate 



