237 



Regulation 9, para, lib) (iv). — Since oils discharged from vessels otiier than 

 tankers are just as harmful as those discharged from tankers, there appears 

 no justification for the lower, i.e., 10 vs. 50 or 100, mileage limitation. 



Regulation 12. — As set forth in our Fourth Draft Comments at pp. 15-16, we 

 believe that the need for special areas depends upon whether the oCnference 

 can agree upon a single, strict regime to be applied to all ocean areas. Such 

 a regime would be preferable to a Convention containing several special areas. 

 Indeed the need to designate special areas tends to indicate (1) that ship- 

 generated oil pollution has already reached unacceptable levels in some areas 

 and (2) that the general discharge criteria established in the Convention for 

 non-special areas are not sufficient to provide full protection against such 

 pollution.' 



Regulation 13, para. 3 (ft). — The segregated ballast requirement should be 

 spelled out in accordance with the bracketed language in this subparagraph, and, 

 if segregated ballast is required for smaller vessels, as it should be. criteria 

 should be developed to define the appropriate ballast levels for such vessels. 



Regulation 15. — As set forth above at pp. 8 to 9. retention of oil on board 

 should not be considered an alternative to segregated ballast (though it may 

 supplement it as regards the problem of disposal of tank washings). However, 

 if ships are permitted to meet the requirements of the Convention through adop- 

 tion of this alternative, we have several specific suggestions. First, in Regulation 

 15, para. 2, we believe that the reference to being equipped with "adequate 

 means for cleaning cargo tanks" should be more specific, ^and that recirculating 

 systems, linked with high capacity, fixed tank cleaning equipment, which are an 

 effective means of reducing pollution resulting from tank washings, should be 

 required, coupled with adequate .safety measures, such as a gas inerting system. 

 Second, each of the specific equipment requirements set forth in subparagraph 

 3 should be required and any effort to delete them should be opposed. As noted 

 above, it is better to rely on technology than human competence to reduce oil 

 discharges. In particular, provision for an oil content monitoring arrangement 

 with automatic shutdown and recording equipment to make a permanent record 

 (paragraph 3(b) ) is necessary to ensure that effluents will not exceed specified 

 discharge levels. This paragraph should be clarified by adding language to the 

 effect that the oil content monitoring requirement must not just provide for 

 "automatic recording" but for "automatic shutdown". 



Regulation 16. — The effectiveness of the levels specified for oily water separa- 

 tors and oil discharge monitoring and control systems should be geared to the 

 best available technology. We understand that systems are currently available 

 which can separate out oil down to almost 5 ppm, rather than 100 ppm. If this 

 is the case, standards should be established at such levels and tied in with the 

 discharge levels in Regulation 9. Deletion of the bracketed material in subpara- 

 graph 5 of Regulation 16 is also necessary in order that discharge levels can be 

 monitored and enforced. 



Regulation 11. — In a segregated ballast tanker, consideration should be given 

 to requiring that there be a tank or tanks of adequate capacity to hold tank 

 washings as well as oily residues, for discharge into shoreside reception facilities. 

 Such a requirement would reduce operational discharges from segregated ballast 

 vessels to zero. 



Regulation 20. — As noted above, see page 9, supra, shoreside reception facilities 

 are only an acceptable alternative if there are adequate controls over and enforce- 

 ment of landside activities. As presently drafted, this Regulation is simply insuffi- 

 cient to ensure environmental protection. If .shoreside facilities are to be an 

 alternative, stringent standards shoul(^ be e.stablishetl, and provision made for 

 effective in.spection and enforcement by IMCO officials or other contracting 

 parties. 



Regulation 21, para. 2. — The bracketed material should be retained in order 

 that the completest po.ssible record of tanker operations can be developed. 



Regulations 22-25. — These four regulations, all of which relate to cargo tank 

 size limitations, provide virtually no improvement over existing industry practice, 

 since they are at the top of the scale of what is now incorporated on VLCC's. 

 The actual cargo tank size limitations presently provided for in Regulation 24 

 should be substantially reduced. The limitations contained in the Fifth Draft 

 would allow 141,519 barrels to be contained in any single wing tank and 314,487 



* If the special area concept Is retained, we would sujrpest that other areas than thnse 

 listed, i.e., the Caribbean and North Sea and the Great Barrier Reef, be considered for 

 treatment as snch. 



