392 



pollution of the oceans is attributed to ''Highway Machinery". Table 2 attributes 

 the same percentage of oil pollution to "Automobile crankcase oil disposal." The 

 paper by Porricelli, Keith and Storch explains the empirical assumptions from 

 which this figure is derived. In order that readers of the impact statement may 

 understand the basis for these somewhat broad assumptions, we suggest that by 

 footnote or otherwise there be some indication that they rest upon the authors' 

 estimate that 75 percent of unaccounted for lubricating oil "ends up in the ocean." 

 The same comment applies to the figure for industrial machinery pollution. 



There can be no disagreement with the conclusion stated under "Relationship 

 between local short-term use of man's environment and the maintenance and 

 enhancement of long-term productivity." However, we believe the case for the 

 conclusion would be sul)stantially strengthened by expansion of the terse state- 

 ment that "oil in water is harmful." A brief discussion, citing examples of major 

 harmful effects would be useful. 



Martin Convisseb. 



Department of Transportation, 



Office of the Secretary, 



November 28, 1972. 



Memorandum 



Subject : Draft Environmental Impact Statement Amendment of the Oil Pollu- 

 tion Act, 1961 

 From : Assistant Secretary for Environment and Urban Systems, OST 

 To : Chief, OflSce of Marine Environment and Systems, USCG 



We have reviewed the draft environmental impact statement on S. 3766/ 

 H. 15627, a bill which would amend the Oil Pollution Act of 1961 to reflect the 

 1969 and 1971 amendments to the International Convention for the Prevention of 

 the Pollution of the Sea by Oil. 



Although we have no specific comments, the draft statement provides a useful 

 discussion of the positive environmental effects of the proposed legislation. We 

 look forward to reviewing the final statement and the comments thereto. 



John E. Hibten. 



United States Department of the Interior, 



Office of the Secretary, 

 Washington, D.C., November 22, 1972. 



Commander D. B. Charter, Jr., USCG 

 Chief, Environmental Coordination Branch, 

 Washington, B.C. 



Dear Commander Charter: In general, we think the Draft Environmental 

 Statement prepared by the U.S. Coast Guard, Marine Environmental Protection 

 Division, dated September 1972. Amendment of the Oil Pollution Act, 1961 (75 

 Stat. 402), as amended, by implementation of the 1969 and 1971 amendments 

 to the International Convention for the Prevention of the Pollution of the Sea 

 by Oil, 1954, as amended, is comprehensive and adequate. 



The bill would implement the amendments to the convention by modifying, 

 in some instances, the oil and oil-containing discharges permissible from those 

 ships regulated by the convention. It would institute requirements as to new 

 tankers' tank arrangement and size, and create a certificate system to ensure 

 compliance with these requirements. United States flag ships engaged in either 

 domestic or foreign traflSc would be required to comply, and provisions would be 

 set out under which foreign tankers could be denied access to U.S. ports or 

 offshore terminals if they are required to, but do not. comply with the new 

 requirements. The bill would also increase fines and institute civil penalties ; 

 broaden the authorization as to personnel who may be called upon to enforce 

 the convention ; and increase the record keeping requirements to include situa- 

 tions such as loading, transferring, and discharging of oil cargo by tankers. 



Some suggested changes are as follows : 



Page 4. paragraph 1. Recommend that the word nationality be deleted at the 

 end of the first sentence if it has no legal meaning. However, we would urge 

 that similar legislation be enacted affecting U.S. companies operating vessels 

 under (foreign) flags of convenience. Such legislation might result in substantial 

 reductions of oil pollution in the world's oceans. 



