251 



environmental statement indicate that tlie adjoining ports of Los Angeles and 

 Long Beach, using a combination of "traditional" trafHc control practices and 

 modern surveillance and communications procedures, have handled some 91,000 

 vessel movements since 1941) without loss of life, i>erson,al injury, pollution of 

 harbor waters or collision between merchant ships. Similarly, the installation of 

 a traffic control system in the Port of Rotterdam had dramatic results. Installa- 

 tion of the system resulted in a 75 percent decrease in the accident rate even 

 though there was a 75 percent increase in traffic volume during the period 

 studied. 



THE NEED TO SEEK INTERNATIONAL AGREEMENT ON STANDARDS 



In its report on the Ports and Waterways Safety Act of 1972, the Senate 

 Commerce Committee concluded tliat : 



The Committee fully concurs that multilateral action witli respect to 

 comprehensive st^mdards for the design, construction, maintenance and 

 operation of tankers for the protection of the marine environment would 

 be far preferable to the unilateral imposition of standards. 

 We are in full agreement with the Committee's conclusion. 



Marine pollution is clearly a problem of international concern and every effort 

 should be made to find a solution to that problem by means of international agree- 

 ment. There are a number of reasons why it is in the long run interest of the 

 United States to lend maximum support to international initiatives to c<mimon 

 environmental problems. The Chairman of the President's Council on Environ- 

 mental Quality, Russell Train, listed four of these reasons earlier this year 

 in testimony before the Senate Foreign Relations Committee. 



(1) Such agreements can help to prevent pollution of areas outside our 

 jurisdiction which would have long-run adverse effects on our national en- 

 vironment ; 



(2) Failure to support international agreements concerning pollution 

 problems can bring the United States into conflicts — political and economic — 

 with other nations, including our immediate neighbors, which it is in our 

 interest to avoid ; 



(3) The international competitive standing of United States industry is, 

 as the Congress recognized last year in section 7 of the Federal Water Pol- 

 lution Control Act, enhanced by international acceptance of pollution safe- 

 guards . . . ; and 



(4) By supporting international agreements on the environment we will 

 create an international climate in which we are better able to obtain sup- 

 port from other nations in areas of international concern which are related 

 to environmental protection. 



For these reasons we believe that it is essential that the interested govern- 

 mental regulatory agencies — the Coast Guard and the Maritime Administration- 

 defer any standard setting action until after the conclusion of the 1973 Interna- 

 tional Conference on Marine Pollution. The Coast Guard has already announced 

 that it will suspend further rule making procedures until after the Confei"ence 

 and we are hoi)eful that the Maritime Administration will reach the same 

 conclusion. 



While on the subject of the 1973 International Conference, a few comments on 

 the draft text of the convention which has been prepared for discussion at the 

 conference may be helpful. One of the significant provisions in the draft text is 

 the propo.sed requirement for segregated ballast tanks of sufficient capacity to 

 permit vessels to operate safely on ballast voyages under weather and sea con- 

 ditions they might normally be expected to encounter. It is our understanding 

 that the United States favored a more stringent double bottom/45 percent segre- 

 gated ballast requirement which was essentially identical to the requirement 

 contained in the Coast Guard's advance notice of proposed rule making'. 



In our view, the requirement contained in the draft text of the convention is 

 a reasonable one which would yield significant environmental benefits if it were 

 adopted. It would, in our judgment, effectively deal with pollution resulting from 

 normal tanker operations, including the ballasting and cleaning of cargo tanks. 

 Operational discharges of this type account for approximately 70 percent of the 

 pollution attributable to tankers and tank barges. In our judgment the addi- 

 tional lienefits which a doul)le bottom requirement might be expected to yield are 

 speculative at best and clearly not worth the additional cost. 



With regard to cost, we have estimated that a 265.000 DWT vessel equipped 

 with a double bottom and with segregated liallast capacity equal to 45 percent 

 of full lond displacement would cost 11.2 jiercent more tlian a similar vessel with 

 the .same segregated ballast capacity but without a double bottom. 



