250 



a consulting lirm with consiUerable experience in matters relating to marine 

 transportation, to review that report. After a comprehensive analysis of Study 

 I and related materials, Boox-AUen found that Study I was based to a very large 

 extent on assumptions and calculations which were unsupported and unreason- 

 able. The Booz-Allen analysis concluded : 



(i) That insufficient data exists to permit a reasonably accurate projec- 

 tion of the outflow reduction which might result from the incoii)oration of 

 double bottoms in VLCC's, and 



(ii) The assumptions and calculations utilized in Study I tend to unrea- 

 sonably inflate the magnitude of the outflow reduction which might be 

 expected to be derived fx-om the incorporation of double bottoms in VLCC's. 

 A copy of Booz-AUen's comprehensive report is attached to this statement as 

 Attachment A.^ 



The data base inadequacies which are detailed by Booz-Allen in its report, 

 suggest to us that data collection efforts should be regarded as a matter of high 

 priority by concerned government agencies. The collection of such data is, in our 

 judgment, a necessary prerequisite to a national exercise of discretion in the 

 standard setting area. Until such data are collected and analyzed it is virtually 

 impossible to determine with any reasonable degree of accuracy the I'elative 

 merits of various alternatives which might contribute to the reduction of 

 marine pollution. 



THE XEED TO ESTABLISH STANDARDS WHICH WILL MITS^IMIZE ACCIDENTS 



To the extent that resource limitations necessitate choices between standards 

 directed to accident avoidance and standards directed to minimizing oil outflow- 

 in the event of an accident, we believe that emphasis should be placed on efforts 

 to reduce the number of accidents involving oil carrying vessels. Several consid- 

 erations point to this conclusion. 



First, to the extent that an accident can be avoided there is assurance that 

 accidental outflows will not result. A particular design feature may or may not 

 prevent oil outflow in the event of an accident. As Bethlehem recently observed 

 in commenting on the Coast Guard's proposed double bottom requirement before 

 the Coast Guard Subcommittee of the House Committee on Merchant Marine and 

 Fisheries, a double bottom may, in certain circumstances, actually increase rather 

 than decrease the risk of marine pollution resulting from a grounding. In a 

 particularly serious grounding, for example, the flooding of the empty ballast 

 tanks of a vessel with a double bottom will increase the vessel's draft which, in 

 turn, may make refloating difficult or impossible without the major removal of 

 cargo. In deteriorating weather conditions the result could be the total loss of 

 the vessel and a massive oil spill. 



The possibility that a double bottom requirement might actually increase the 

 risk of pollution in particular cases w^as only one of the reasons why Bethlehem 

 submitted adverse comments on the proposed rule to the Coast Guard and felt 

 compelled to testify against the proposed rule at the hearings which were recently 

 held by the Coast Guard Subcommittee. Rather than reiterating all of the points 

 which influenced Bethlehem's position on the propose<i rule, we are including 

 as Attachment B - a copy of the wa-itten comments which Bethlehem submitted 

 to the Coast Guard on March 15, 1973. We are also including as Attachment C ' 

 a copy of the testimony w-hich was presented on Bethlehem's behalf before the 

 'Coast Guard Subcommittee on .Tune 7, 1973. 



Second, because the costs involved in retrofitting existing vessels with double 

 bottoms or other major design features would be prohibitive in many instances, 

 it might not be possible to apply such standards to hundreds of older foreign- 

 flag vessels. On the other hand, improved traffic control systems in harbor areas 

 and other congested waters would yield immediate benefits irrespective of the 

 age or nationality of the vessels entering such waters. While equipment addi- 

 tions may be necessary to enable some older vessels to obtain the full benefits 

 of improved traffic control systems, such additions would be much less expensive 

 and could be effected much more rapidly than modifications in the vessel's basic 

 ■design. 



Third, experience has confirmed that the installation of traffic control systems 

 will significantly reduce the number of accidents which might otherwise be 

 expected to occur. Statistics contained in the Maritime Administration's final 



' The attachment Is in tho committee files. 

 2 3 The attachments are in the committee files. 



