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Page 37, last sentence. It is believed that the last sentence is incorrect and 

 does not agree with the table of losses from ships shown on page 16. This 

 sentence indicates that the total of the discharges from vessels other than 

 tankers and from the machinery bilges tankers is only 1/lOth of the amount 

 discharged as a result of tanker ballasting and tank cleaning operations. The 

 table on page 16 indicates that the losses from ships other than tankers is 

 600,000 tons per year and from bilges from tankers is 100,000. Thus, the total 

 losses from these sources is 700,000 tons per year as compared to 967,000 tons 

 per year from tank cleaning operations. It is recommended, therefore, that the 

 last three lines (the total of these discharges is only one-tenth of the amount 

 being discharged as a result of tanker ballasting and tank cleaning operations) 

 should be deleted. 



Page 49. Paragraph 5, which is in the section concerned with the relationship 

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

 enhancement of long-term productivity, is inadequate and inaccurate. The present 

 paragraph really says little, but implies that oil is harmful to all organisms. 

 We believe that a more reasonable discussion of the inadequate knowledge of 

 the harm of oil in water should be included. An example might be found in the 

 offshore drilling environmental impact statement. 



Page .51, first sentence, top of page. The phrase, "however, it is conceivable 

 that in a dire emergency some of the ballast tanks could be converted to cargo 

 tanks," seems to be inappropriate. The paragraph is discussing irreversible 

 commitment of resources, and the possible rare emergency use of ballast tanks 

 for other purposes has little or nothing to do with commitment of long-range 

 resources. Also, it is believed that the use of ballast tanks for oil would indeed 

 be rare, if ever. 



Sincerely yours, 



W. W. Lyons, 

 Deputy Assistant Secretary of the Interior. 



o 



