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Center for Science in the Public Interest, 



Washington, D.C., July 9, 1973. 

 Hon. Warren G. Magnuson, 



Chairman, U.S. Senate Commerce Committee, 5202 New Senate Office Building, 

 Washington, D.C. 



Dear Senator Magnuson : Since the oceans, which represent 70% of the 

 earth's surface, are this planet's last frontier, we think it imperative that steps 

 be taken to protect them from further pollution, particularly from oil spills. 



Bills S. 1067 and S. 1070, which we have reviewed, are steps in the right direc- 

 tion toward alleviating the problems caused by large oil spills in the oceans. 

 We suggest that to S. 1070 be added the intention of Congress that eventual 

 enforcement of oil pollution regulations on the high seas be a United Nations or 

 other international organization function. Ocean transport and discharge of oil 

 can effect the environmental quality of the ocean even when the traflBc does not 

 enter U.S. waters. The U.S., however, should not have to become the ocean's 

 policeman. That should be the task for an international group such as the U.N. 

 The upcoming IMCO conference will focus on this issue. 



Specifically, we have the following comments on the two bills : 



S. 1067 



Restriction of international discharge is quite important. Expressing the ex- 

 ceptions to the discharge ban in quantitative language, as proposed in Section 2, 

 will ease enforcement of the provision and limit confusion as to its applicability. 



The establishment of tanker construction standards (Section 5) is a very 

 important development. The certification procedure, as proposed, is a solid initial 

 step in oil pollution control. Certification should evolve to include discharge 

 methods used by each vessel. We are pleased that S. 1067 would authorize the 

 Secretary to refuse entry to tankers from countries not subscribing to the Inter- 

 national Convention for Oil Pollution Prevention. 



Present law classifies a discharge violation as a misdemeanor. Section 7 pro- 

 poses stiffer penalties. We find these measures still inadequate. It is our conten- 

 tion that a $10,000 fine is insufficient to deter oil interests from illegal oil dis- 

 charging. These organizations are large, sophisticated operations and the pro- 

 posed penalties are relatively minimal for them. For the public, the costs of oil 

 pollution are high. We feel they should be so for the violators. 



Section 9 proposes an increase in categories to require record book entries. 

 Especially important are the inclusion of tanker loading and unloading operations. 

 We believe the improved recording procedures will encourage better discharge 

 practices. 



S. 1070 



As previously noted, spills outside U.S. waters can have- consequences equal to 

 domestic spills. As a temporary measure, the intervention authorized by this 

 act is useful, but the intent should not be to establish a unilateral policing force. 

 We support the intent of S. 1067 and S. 1070. These measures will contribute 

 to efforts aimed at alleviating oil spill damages. But regulation can not stop at 

 this level ; oil pollution is a serious threat to the ocean environment and should 

 receive serious consideration and prohibition. As long as tanker operators are 

 permitted to place personal convenience and economy over the environmental 

 quality of areas belonging to all, oil discharges will continue to create large 

 scale damage. 



Sincerely, 



James Sitllivan. 

 Albert Fritsch. 

 Mark Mazak. 



Center for Law and Social Policy. 



Washington, D.C, June 29, 1973. 

 International Convention for the Prevention of Pollution From Ships, 1973. 

 Capt-fS. M. SiiuMAN, 



Executive Secretary, U.S. National Committee for the Prevention of Marine 

 Pollution, U.S. Coast Guard. Wm^hingtov. D.C. 



Dear Captain SIIU^rAN : In accordance with the request of the United States 

 National Committee for the Prevention of Marine Pollution, we are submitting 



