29-cruisingforabruising

Chris WellsWashington Public InterestResearch Group (WashPIRG)

February 2005

Cruising fora BruisingWhy Washington Needs Lawsto Protect its Waters fromCruise Ship Dumping

Acknowledgments

WashPIRG would like to gratefully acknowledge the help of Gershon Cohen (Cam-paign to Safeguard America’s Waters, C-SAW), Ross Klein, and Teri Shore (BluewaterNetwork) for providing valuable information and guidance for this report.

More information about Gershon Cohen’s work is available at www.earthisland.org.It should be noted that an earlier article by Gershon shared the head title with this report.

Ross Klein’s famous Cruise Junkie website is www.cruisejunkie.com.

The Bluewater Network’s website is www.bluewaternetwork.org.

The author alone bears responsibility for any factual errors. The recommendations inthis report are those of WashPIRG.

© 2005 WashPIRG

WashPIRG is an environmental and consumer advocacy group working on environ-mental preservation, consumer protection, and good government in Washington. Formore information, please call (206) 568-2850 or visit www.washpirg.org.

Cover: Puget Sound, photo by Stacey Jurgensen; photo insets (top to bottom): estuary, photo courtesy of WDFW; cruiseship, photo by Russell Lynch, courtesy of KAHEA; warning sign in Discovery Park, photo courtesy of Ivy Sager-Rosenthal.

Graphic design: Harriet Eckstein Graphic Design

Table of Contents

Executive Summary 5

Introduction 9

Part 1: The Environmental Record ofthe Cruise Ship Industry 11The Growth of the Cruise Industry 11The Cruise Industry’s Legal Record 12Alaska’s Cruise Experience 12

Part 2: Costs to the State of Washington 15The State of Washington Waters 15Washington’s Economy at Risk 17

Part 3: Legislation or MOU?: The Attemptsof Six States to Address Cruise Ship Pollution 19States that have passed legislation 19States that have signed Memoranda of Understanding 20Comparison of the results of legislation and MOUs 21

Conclusions and Recommendations 23

References 25

4 Cruising for a Bruising

Executive Summary 5

Executive Summary

In the thirty years since the cruise shipbusiness became a major industry, tak-ing cruises has become a vacation phe-

nomenon. People seem to love the aspectsof cruises that make them different fromother vacations—easy-going trips to ex-otic locations, constant service, seclusionand famously good and plentiful food;since 1980, the number of passengerscruising out of North America has in-creased from 1.4 million to 7 million in2000. Around the globe, 12 millionpeople took cruises in the year 2000.1

The cruise industry’s popularity hasmade it a potent source of profits for itsowners and shareholders, and a signifi-cant source of jobs for the 100,000 pluscruise industry workers.2

But below the decks of these glamor-ous floating resort hotels – floating citiesin scale – is a poor environmental recordand disdain for environmental regulation.

Cruise ship traffic poses major threatsto delicate Puget Sound ecosystems, aregion where biological health and di-versity have enormous social, environ-mental, and economic significance andare already threatened. In the UnitedStates, six states have taken one of two

approaches to protecting their waters fromcruise ship wastes: three, including Wash-ington, have signed Memoranda of Un-derstanding (MOUs) with the cruiseindustry, and three have passed legisla-tion. On the west coast, California andAlaska have both enacted laws to protecttheir waters from cruise ship wastes. Whileships from both states regularly come toSeattle, Washington has no laws bindingcruise ships to clean environmental practices.

A comparison of MOUs and laws anda review of the experiences of states thathave implemented each reveal that anMOU is insufficient for protectingWashington’s waters and that the Legis-lature needs to pass laws to protect ourmarine waters.

The Cruise Industry’sEnvironmental RecordThe cruise industry’s environmentalrecord is poor.

• Between 1993 and 1998, the cruiseindustry was cited for 87 illegal


dumping events in U.S. waters andincurred over $100 million in fines.3

• When Alaska tested wastewaterdischarged by cruise ships into theocean in 2000, concentrations offecal coliform in the wastewater wereas high as 100,000 times the federalstandard.4

• In 2003, the Norwegian Sun dis-charged 16,000 gallons of rawsewage into Puget Sound betweenWhidbey Island and the Strait ofJuan de Fuca.5

Costs of Cruise Ship WastesIn a day, a typical cruise ship of 3000 pas-sengers and crew generates as much wasteas a small city:

• 11.5 tons of garbage from the pas-sengers alone.7

• 23 gallons of toxic waste, includingsilver nitrate (from photo labs), heavymetals, and PERC (perchloroethyl-ene, from dry-cleaning facilities).8 , 9

• 30,000 gallons of sewage and addi-tional tons of sewage sludge.

• 270,000 gallons of graywater, thewastewater from sinks, showers,dishwashing, and laundry.

• 7,000 gallons of oily bilge water. 10

• Air pollution equivalent to thatproduced by more than 12,000automobiles.11

The enteric bacteria, fecal coliform,pathogens, diseases, viruses, intestinalparasites, excessive nutrients, heavy met-als, and toxic chemicals in cruise shipwastes have a number of harmful effectson marine environments they enter.Three of the most severe are:

1. The threat to human healththrough direct contact withpathogens, viruses, other diseases,and parasites while swimming orotherwise enjoying the water.According to the U.S. Commissionon Ocean Policy, in 2002, more than12,000 beach closings and swimmingadvisories were issued in the UnitedStates.12

2. The threat to human health andthe economy due to contamina-tion of shellfish such as oystersand clams.As of July 2004, 30,000 acres ofPuget Sound’s 165,000 acres ofshellfish beds were restricted fromcommercial and recreational harvestdue to bacterial contamination in theSound’s water.13

3. The eutrophication, or oxygendepletion, of marine environmentsdue to excess nutrients.The oxygen-depleted “dead zone”now expanding in Hood Canal is thebest-publicized example of this wide-spread process in the Puget Sound.

FACT:Ross Klein’s www.cruisejunkie.com

records that several of the largest

fines imposed on cruise lines for

environmental violations included

citations for falsifying ship logs and

lying to the Coast Guard. This fact

casts serious doubt on the credibility

of an industry that routinely asks to

be regulated by voluntary measures.6

Executive Summary 7

Puget Sound’s Economyin JeopardyThe impacts of cruise ship wastes directlyor indirectly affect millions of people liv-ing in the Puget Sound region, and tensof thousands who make their livings fromthe Sound’s resources:

• Each year, Washington’s oysters,mussels, clams, and geoducks gener-ate around $77 million in sales,supporting 1,200 jobs in Mason andPacific counties alone.15 The recre-ational harvest of shellfish is alsoculturally and economically verysignificant. During the season,30,000 people a day go out to digrazor clams on Washington’s coast.16

• Combined commercial landings andexpenditures for recreational fishingin Washington are worth around$1.2 billion annually, directly sup-porting 24,000 jobs.17

• The opportunities to go boating,waterskiing, swimming, fishing,clam-digging, and whale-watching;the ability to catch and eat wild

Puget Sound fish and shellfish; andcorresponding tourism and propertyvalues all contribute to the economyand social structure of the region andare adversely impacted by marinepollution.

Memoranda ofUnderstanding (MOUs)Versus RegulationsOut of concern for their coastal resources,several states have taken one of two ap-proaches to regulating cruise ship wastes:binding statutory laws, and voluntarymemoranda of understanding (MOUs).Alaska, California, and Maine have passedlaws to regulate cruise ships; Washing-ton, Florida and Hawaii have signedMOUs with the cruise industry. Duringthe 2004 cruise season, Washington sawthree violations of its MOU, includingone discharge of untreated gray water thatcontained high levels of fecal coliform,biochemical oxygen demand, and totalsuspended solids. 18 And the contrastingexperiences of Alaska and Hawaii clearlyillustrate the superiority of laws to MOUsin protecting marine waters.

The first year it was in effect, Hawaii’sMOU was violated 16 times. Violationsincluded mostly the discharge ofgraywater and blackwater in the protectedfishing ground known as Penguin Bank.Also cited were an instance of incinerat-ing waste while in port, the discharge ofalmost 20,000 gallons of galley waste andgraywater in marine areas, and reportingerrors.19 In Alaska, wastewater dischargeviolations by cruise ships since the pas-sage of regulations have been nearly non-existent, and air emissions violations havegone from 39 between 1999 and 2001 tojust one in 2002 and 2003.20

FACT:The U.S. Commission on Ocean Policy

found that harmful algal blooms,

caused by excess nutrients, cost the

United States an average of $49

million per year in fisheries closures,

tourism and recreation losses, and

health care and monitoring

expenses.14


Policy RecommendationsTo protect its marine waters from thethreats posed by cruise ship wastes, Wash-ington State needs measures strongerthan an MOU. Washington lawmakersshould pass legislation that will:

1. Ban the discharge of blackwater,graywater, oily bilge water, ballastwater, and hazardous wastes in statewaters.

2. Establish clear penalties for violatingregulations. Penalties should providean economic deterrent to violationand cover the damage to state eco-systems.

3. Create a per-passenger fee system topay for a state monitoring program.A graduated fee scale could provideeconomic incentives for cruise linesto be environmentally responsible.An average fee of $1-2 per passengerwould pay the major part of theexpenses of cruise ship monitoring.

FACT:In contrast to Hawaii’s MOU, which

was violated 16 times the first year it

was in effect, Alaska has seen almost

no wastewater discharge violations

and just one air emission violation in

2002-03. A recent exception was a

Holland America Line dumping of

20,000 gallons of sewage into Juneau

harbor, for which the company paid

$2 million in fines and mandatory

preventive measures.21

Introduction 9

Introduction

S ince the 1970s, taking cruises has be-come a vacation phenomenon.People seem to love the aspects of

cruises that make them different fromother vacations—easy-going trips to ex-otic locations, constant service, seclusion,and famously good and plentiful food;since 1980, the number of passengerscruising out of North America has in-creased from 1.4 million to 7 million in2000. Around the globe, 12 millionpeople took cruises in the year 2000.22

The cruise industry’s popularity hasmade it a potent source of profits for itsowners and shareholders, and a signifi-cant source of jobs for the 100,000 pluscruise industry workers.23

But below the decks of these glamor-ous floating resort hotels – floating citiesin scale – is a deplorable environmentalrecord and a blatant disregard for envi-ronmental regulation. The first part ofthis report catalogues some of the mostegregious and harmful violations, espe-cially in Washington and Alaska. Before1998, when a series of events unfoldedthat ultimately forced state governmentsto begin taking cruise ship environmen-tal practices into their own hands, cruise

ships had environmental records nothingshort of disgraceful.

The watershed events of 1998 beganin June, when Royal Caribbean agreed topay a total of $18 million for twenty-onetotal violations of environmental lawsaround the country. Also in 1998, Hol-land America Line paid a total $2 millionfor dumping oily bilge water into pris-tine Inside Passage waters in Alaska. Andin 2000, Alaska sued Royal Caribbean fordumping toxic chemicals and oily waterand was awarded $3.5 million. 24

After testing implemented by the firstAlaska cruise ship initiative in 2000 re-vealed that cruise ships were dumpinghuge quantities of pollution into pristineNorth Pacific waters, and that even shipsrunning Coast Guard-certified MarineSanitation Devices were releasing efflu-ent with up to 100,000 times federallylegal levels of fecal coliform, Alaskan pub-lic sentiment demanded legislation. Inresponse, the Alaska State Legislatureenacted in 2001 legislation with threemain components:

1. A sampling component, includingrequirements for sampling and


reporting of wastewater dischargesand air emissions. Ships must sampletheir effluent at least twice per yearand must share the results with thestate. Alaska may also conductunlimited sampling while the ship isin Alaskan waters.

2. A standard component, establishingstandards and enforcement. Forgraywater or blackwater to be dis-charged in state waters, the effluentmust meet state standards for sus-pended solids, fecal coliform andother substances. Also, several no-discharge zones were created.

3. A fee component, to ensure thecruise industry bears the cost ofregulation. The fee established was$.75 to $1.75 per passenger per cruise.

Cruise ship pollution has proven itselfa threat to Washington waters as well. In2003, the Norwegian Sun discharged16,000 gallons of raw sewage in PugetSound between Whidbey Island and theStrait of Juan de Fuca. 25 And in Septem-ber of 2003 it was revealed that despitemore than one commitment to burn low-sulfur fuel while at dock at the Port ofSeattle, the cruise lines were not and hadnever been doing so. 26

The irony of the cruise industry’s tar-nished environmental record is that theindustry spends considerable resourcesnot only to brand itself environmentallyresponsible, but also to advertise the veryplaces and wildlife that are threatened byits unethical environmental practices. Alltogether, the industry spends over $500million a year in advertising.27 For cruisesto the Northwest and Alaska, much ofthat money goes towards attracting po-tential passengers to wild images – sce-nic shots of Alaskan glaciers, mountains,grizzly bears and seals.

This report will analyze what shouldbe done to protect Washington waters,

especially Puget Sound, from cruise shippollution. Around the United States,states have taken two approaches. Somehave passed tough legislation to holdcruise ships to strict standards and punishthem for violations. Other states, includ-ing Washington, have adopted voluntaryagreements with cruise lines. This reportwill demonstrate that voluntary agreementsare significantly less effective than legis-lation in preventing cruise ship pollutionand will recommend that Washingtonadopt into law legislation comparable tothat in Alaska and California.

The report is divided into three parts:In Part 1, the report will overview the

history of the cruise ship industry andsome of the environmental threats thatcruise ships pose to marine waters in gen-eral and to Washington waters in particu-lar. The history of the cruise ship industryand its regulation is important context forunderstanding the positions of states,such as Alaska and California, which havetaken regulatory action, and states thatare pursuing voluntary agreements, in-cluding Washington.

Part 2 focuses on the economy ofcoastal Washington and Puget Sound,and the numerous small businesses andlarge businesses that are impacted by thedegradation of marine waters and thethreats posed by cruise ship pollution.

Part 3 will show that signing Memo-randa of Understanding (MOUs), whichare voluntary agreements, is not as effec-tive a tool for protecting marine waters fromcruise ship pollution as enacting legisla-tion. The experiences of states with MOUsin place will be compared with the expe-riences of states that have passed legisla-tive regulations, and particular attentionwill be drawn to the contrasting degrees ofsuccess of Alaska's laws and Hawaii's MOU.

The conclusion presents additionalfactors supporting legislation and recom-mendations for legislation to protect Wash-ington waters from cruise ship pollution.

Part 1: The Environmental Record 11

Part 1:The Environmental Recordof the Cruise Ship Industry

The Growth of theCruise Industry

The modern cruise ship industry wasborn in the 1950s, when large num-bers of Americans began being able

to afford luxury vacations.28 The cruiseindustry grew steadily alongside the af-fluence of American vacationers, but theindustry took off in the 1970s; between1970 and 2002, the number of people tak-ing cruises increased 1,000%, and con-tinues to grow.29 The increase in the totalnumber of cruise ship passengers is pairedwith not only more ships plying Ameri-can waters, but with ships of increasingsize. In the 1970s, most ships carriedaround 600-700 passengers; today, thesmallest major-line cruise ships carrymore than a thousand, and modern cruiseships top out at more than 5,000 passen-gers and crew. 30

Today, a typical cruise ship of 3,000passengers and crew, in a single day,generates:

• 11.5 tons of garbage from the passen-gers alone. In many places without

strict regulations, 75-80% of garbageis incinerated and the ash—contain-ing toxics from the burning ofplastics and heavy metals—isdumped into the sea.

• 23 gallons of toxic waste, includingsilver nitrate (from photo labs),which is toxic to fish and is notpermitted to be used outdoors31 ;heavy metals; and PERC (perchloro-ethylene, from dry-cleaning facili-ties), which evaporates quickly in theair and affects the nervous system,among other human health impacts.At the environmental scale, PERCcan add to the development ofphotochemical smog.32

• 30,000 gallons of sewage and addi-tional tons of sewage sludge. Sewage,or blackwater, is highly contami-nated with human waste. Such wastecontains fecal coliform bacteria,other pathogens, diseases, viruses,intestinal parasites, and harmfulnutrients including nitrogen andphosphorus.33 The major risks posedby these substances will be discussed


later and include direct threats tohuman health, threats to shellfishbeds and the people who eat them,and a general degradation in thewaters they contaminate througheutrophication.

• 270,000 gallons of graywater, thewastewater from sinks, showers,dishwashing, and laundry. Althoughfecal coliform is usually associatedwith blackwater, testing by the stateof Alaska in 2000 found significantlevels in graywater also.34

• 7,000 gallons of oily bilge water.

• Air pollution equivalent to thatproduced by more than 12,000automobiles. Almost all cruise shipsburn diesel fuel, which has beenlinked to lung cancer, other typesof cancer, and a rising rate ofasthma.35

Not surprisingly, more people cruis-ing on more ships in greater concentra-tions than ever before has had significantconsequences for the marine environ-ments that they explore. Before 1998 and1999, when the environmental impacts ofcruise ships began attracting attention,36

the industry’s environmental record waswhat one might expect from a fast-grow-ing, unregulated industry operating be-low the view of public scrutiny andmainstream media: horrific.

The Cruise Industry’sLegal RecordThe U.S. General Accounting Officerecords 87 illegal dumping events in U.S.waters between 1993-1998.37 On hiswebsite, www.cruisejunkie.com, Dr. RossKlein records 117 environmental viola-tions by various cruise ships cumulatively

resulting in $100 million in fines between1992 and 1999. These violations includethe dumping of oil or oily water; dis-charges of sewage (blackwater), graywater,garbage, plastic waste, fuel, paint, and bal-last water. A distressing number of viola-tions also include falsification of CoastGuard records, which calls into questionthe cruise industry's credibility when itinsists that it does not harm the environ-ment.38 There is also one citation fordamage to a reef.

The combination of the incredible sizeof modern cruise ships and the volumeof waste they produce with the numberand frequency of environmental viola-tions by cruise ships during the last de-cade makes cruise ship pollution a seriousthreat to marine ecosystems.

Alaska’s Cruise ExperienceBetween 1998 and 2001, several high-profile events took place that significantlyreshaped both the Alaskan public’s atti-tudes towards the cruise industry and leg-islators’ willingness to pursue regulatoryoptions. First, Royal Caribbean Interna-tional agreed to an $18 million fine inpleading guilty to twenty-one violationsthat included the illegal discharges of oiland hazardous wastes around the UnitedStates and lying to the Coast Guard. In1998, Holland America Line paid a $1million fine and $1 million in restitutionfor intentionally discharging oily bilgewater into Alaska’s pristine Inside Passagein 1995. Then, in 2000, the state of Alaskawon a suit against Royal Caribbean fordumping toxic chemicals and oily waterinto Alaskan waters; the company paid a$3.5 million fine.39

Not surprisingly, following thesewidely publicized incidents, there wasstrong support in Alaska for investigat-ing and stopping further abuses of its

Part 1: The Environmental Record 13

waters by the cruise ship industry. In late1999, Alaska’s Department of Environ-mental Conservation, along with theCoast Guard, the industry, and conser-vationists, began a cruise ship initiativeto assess environmental impacts of cruiseships. They created a sampling plan tomeasure cruise ship wastewater dis-charges and air emissions, which wentinto effect in 2000, and in the words ofthen-Alaska governor Tony Knowles, theresults were “disgusting and disgraceful.”40

• Tests of blackwater effluent fromcruise ships operating federallymandated, Coast Guard-certifiedMarine Sanitation Devices revealedfecal coliform levels as high as9 to 24 million colonies per 100millileters of treated water.

• Those fecal coliform levels exceededfederal standards by 10,000 to100,000 times.

• The tests found that not one of 22tested ships was in compliance withall blackwater standards; the reason

for the unanimous failure of theMarine Sanitation Devices, theCoast Guard found, was that theywere either not being operatedproperly by the cruise company,or they had not been properlymaintained.41

After the cruise ship testing, the cruiseindustry found itself facing even moreAlaskan public support for meaningfulrules to bring cruise ship companies tobay and punish them when they fouledstate waters. Because of the public out-cry, the U.S. Congress passed legislationto protect certain federal waters off Alaskaand give Alaska the right to regulateblackwater in state waters.42 Also, bipar-tisan leadership from Democrats Gover-nor Knowles and Representative BethKerttula, and Republican Senator RickHalford helped to craft the Alaska CruiseShip Initiative,43 which created a three-part cruise ship regulation. Alaska’s cruiseship regulations will be discussed in Part3 of this report.


Photo courtesy of WD

FW

Estuarine habitats are critically important to hundreds of species of marine life. Delicate andclose to shore, they are also highly sensitive to marine water pollution.

Part 2: Costs and Benefits 15

Part 2:Costs to the

State of Washington

The State ofWashington Waters

S tates like Alaska and Washingtonhave good reason to worry about therisk of cruise ship pollution on our

beaches and in our water. As the recentreports of the Pew Oceans Commissionand U.S. Commission on Ocean Policyfound, the deadly combination of pollu-tion (including the substances cruise shipsdischarge), overfishing, and coastaloverdevelopment has pushed oceanecosystems around America’s coasts tothe brink of collapse. And estuarine habi-tats like the Puget Sound have been hard-est hit because they receive most of thenon-point source (land source) pollution,toxins are often not swiftly washed awayby ocean currents, and they are habitatand breeding ground for thousands ofspecies.44 , 45

Any kind of marine water pollution hasthe potential to impact marine life, theeconomy, and human health throughshort term impacts, which are usually themost visible and get the most news cov-erage, and long term impacts, which build

over time and may be more destructive,though they receive less recognition.While the Puget Sound has so far beenspared any major cruise ship dischargeresulting in immediate and highly visibledamage of estuarine habitat or humanhealth, two recent oil spills in the Sound,in December 2003 and October 2004,clearly illustrate the incredible financialcost of even relatively small spoils of toxicsubstances.

The smaller of these spills was a 1,000gallons oil spill between Tacoma andMaury Island in the middle of the nighton October 14, 2004. Even with the earlyalert of authorities and oil spill contain-ment crews, which were hampered bymorning fog, the toxic oil spread acrosssouthern Puget Sound and soiled beachesfrom the Tacoma Narrows to BainbridgeIsland. As of November 8, 2004 the esti-mated cleanup cost of the spill was nearly$2 million.46 All this from 1,000 gallonsof fuel oil, which is minuscule comparedto the fuel holds of cruise ships. (TheCunard company’s Queen Elizabeth 2, aship with beds for fewer than 2,000 pas-sengers, has a capacity of more than 4,300tons of fuel oil.47 ) Of course, on a cruise


ship, fuel oil is only one of many hazard-ous materials, and it is not even a wastelike blackwater and graywater.

The most egregious case of cruise shipdumping in Washington waters was thedumping of 16,000 gallons (40 tons) ofraw sewage into the Strait of Juan de Fucaon May 3rd, 2003.48 Like the vast major-ity of ship discharges, the great damagecaused by the discharge was not any sealife that turned up dead at the scene. In-stead, these discharges contribute to thepollution increasing in the waters sur-rounding our coasts. The types of pol-lutants contained in cruise ship blackwaterand graywater waste include enteric bac-teria, fecal coliform, pathogens, diseases,viruses, intestinal parasites, and harm-ful nutrients including nitrogen andphosphorus.49

There are multiple environmental con-sequences for releasing these substancesinto the water. The most serious are:

• The threat to human healththrough direct contact withpathogens, viruses, other diseases,and parasites while swimming orotherwise enjoying the water.According to the U.S. Commissionon Ocean Policy, in 2002, more than

12,000 beach closings and swimmingadvisories were issued in the UnitedStates. Most of those are “due to thepresence of bacteria associated withfecal contamination”; the number ofbeach closings is rising each year;and they are costing the nationmillions of dollars in lost incomefrom tourism.50

• The threat to human health andthe economy through consump-tion of shellfish such as oystersand clams. The U.S. Commissionfound that harmful algal blooms areon the rise; that toxins associatedwith such blooms cause 62% ofworldwide seafood-caused illness;and that they cause 15% of thedeaths from “food poisoning out-breaks with a known cause.”51 As ofJuly 2004, 30,000 acres of PugetSound’s 165,000 acres of shellfishbeds were restricted from commer-cial and recreational harvest due tobacterial contamination in theSound’s water.52 In Washington, theDepartment of Health in April 2003mapped 19 “Threatened ShellfishGrowing Areas,” which includedmajor growing areas on the coast andin Puget Sound threatened bymarine biotoxins tied to excess levelsof nutrients. Shellfish beds at GraysHarbor, on the west side of theOlympic Peninsula, at HendersonBay in the south Sound, at HoodCanal and at Port Townsend andSkagit Bay further north were alllisted.53

• The steady eutrophication, orbuild up of excess nutrients,which the Pew Oceans Commis-sion found to have “moderately orseverely degraded” two-thirds ofthe estuaries and bays in theUnited States.54 Perhaps the mosttragic threat pollution poses to ocean

A pollution warning at Discovery Park, Seattle.

Photo courtesy of Ivy Sager-Rosenthal

Part 2: Costs and Benefits 17

ecosystems, the process of eutrophi-cation is the literal destruction ofocean areas; excess nutrients feedgiant algae blooms, which die off,feeding the aerobic activity of bacte-ria, which plunge the dissolvedoxygen levels of the area belowconcentrations that fish and otherorganisms need to breathe. In thePuget Sound the dead zone nowexpanding in Hood Canal is the best-publicized example of this process.

• The threat to fish, humans, andthe environment from toxicchemicals such as silver nitrate,which kills fish55 ; mercury, apotent neurotoxin linked to birthdefects and learning disabilities inhuman children; other heavymetals; and perchloroethylene, whichcontributes to smog and is toxic tohumans at moderate to high concen-trations56 .

Washington’s Economyat RiskThree sectors of the marine economyshould be considered when understand-ing the potential impacts of the contri-butions cruise ships make to marinepollution: shellfish, both recreationally

and commercially harvested; fishing, in-cluding commercial fishing, recreationalfishing, charter boat fishing, and the sup-ported processing and sale sectors; andimpacts on Puget Sound quality of life,property value and tourism.

ShellfishShellfish growing is one of Washington’strademark cultural and economic activi-ties. In fact, Washington leads the nationin producing farmed bivalve shellfish.This is a major driver of Western Wash-ington economies, especially in the mostrural areas where waters tend to be thepurest—which is what shellfish need mostto be grown safely. Each year, Washington’soysters, mussels, clams, and geoducksgenerate around $77 million in sales, sup-porting 1,200 jobs in Mason and Pacificcounties alone.57 The recreational har-vest of shellfish is also culturally and eco-nomically significant. During the season,30,000 people a day go out to dig razorclams on Washington’s coast.58

As described above, human wastesfrom cruise ships and other sources, be-cause of the high levels of dangerous bac-teria they contain and their potential foroverfeeding harmful algae, pose a seriousthreat to shellfish farms around the state.

FishingWashington’s fishing economy is one ofthe biggest in the country, with majorfishing and processing companies basedin Seattle and operating in the waters offAlaska. There are also major commercialfishing operations in Washington Statewaters, and combined with expendituresfor recreational fishing, fishing in Wash-ington State is worth around $1.2 billionannually, directly supporting 24,000jobs.59

Cruise ship wastes pose a two-prongedthreat to fish in Puget Sound. First, asDigging for clams on a Washington beach.


FW


described above, toxic substances such assilver nitrate are simply toxic for fish toingest; it kills them. Also, Puget Sound isalready experiencing severe eutrophica-tion from mostly human wastes washinginto the Sound and feeding algal blooms.The leading sources of these wastes are

septic systems and agricultural fertilizer;nonetheless, in blackwater and graywater,cruise ships are releasing exactly the sameelements and compounds into the water,and without strong monitoring they cando it directly, without valuable biologicalbuffers.

Other ImpactsThere are countless reasons peoplechoose to live in the Puget Sound regionand spend their money here buyinghomes, boats, and property. And there isno question that as the waters are thePuget Sound are degraded, Washingtoncitizens lose some of the value of theirrecreational activities, such as boating,waterskiing, wildlife watching, swim-ming, fishing, and clam-digging. Thestrictly economic value of property onPuget Sound is affected, the special abil-ity to safely produce and feed themselveswith Puget Sound products is reduced,and numerous other elements of the highquality of life here are threatened.

A block seiner in Puget Sound.


FW

Part 3: Legislation or MOU 19

States That HavePassed Legislation

To date, six states have taken formalactions to attempt to control the pol-lution left by cruise ships in their

waters. Three—Alaska, California, andMaine—have passed legislation.

Alaska:The momentum for passing legislationto control cruise ship dumping was gener-ated after several egregious dumping epi-sodes outside of Alaska in the latenineties, and the horrific results of test-ing in 2000 (see Part 1, “Alaska’s Experi-ence”). The Alaska Cruise Ship Initiativeof 2001:

1. Banned the dumping of untreatedsewage by cruise ships; set effluentstandards for cruise ships’ blackwaterand graywater that are as strong asthose for municipal facilities andrequired that cruise ships meet oneof three standards to be allowed todump anywhere, one mile from

shore, or outside state waters (3 milesfrom shore);

2. Established comprehensive samplingrequirements for cruise ships andsampling rights for the state Depart-ment of Environmental Protection;and

3. Enacted a per-passenger fee systemof between $.75 and $1.75 to pay theDepartment of EnvironmentalProtection’s costs for their program.60 , 61

The bill also outlined damages to belevied. The scale was set at $500-$100,000 for a violation, and up to$10,000 per day for violations that con-tinued past an initial event. The bases fordetermining the amount of the penaltywere identified as compensation for thecost of damages to the environment; thecost to the state to detect and investigatethe violation; the savings benefiting theviolator for not complying with the law;and any additional cost necessary to en-courage compliance.62

Also in 2000, Alaska’s Senator FrankMurkowski sponsored legislation at thefederal level to regulate the dumping of

Part 3:Legislation or MOU?:

The Attempts of Six Statesto Address Cruise Ship Pollution


raw sewage in specific parts of Alaska’sInside Passage, close “donut holes” be-tween islands in the Inside Passage, andgive the state of Alaska the power to regu-late sewage dumping in state waters.63

This last clause was provided as a clarifi-cation to the Clean Water Act (CWA),ensuring that Alaska’s exercise of author-ity over sewage dumping in its waterswould not be challenged in court.California’s approach to what the cruiseindustry has claimed to be an ambiguityin the CWA is different, as we will see.

The battle to clean up cruise ships inAlaska is not over. In negotiating the pro-visions of the 2001 legislation, standardsfor waste streams other than blackwaterand graywater were removed. A new Alas-kan cruise ship initiative to protect againstother discharges, including hydrocar-bons, plastics, and metals, is backed bythe Campaign to Safeguard America’sWaters (C-SAW) and has qualified for theAlaska ballot in 2006.64

California:California has passed a number of piecesof legislation to regulate the wastesdumped by cruise ships. In 2001, the StateAssembly passed legislation to mitigatethe impact of ballast water on state waters.It gave cruise ships a number of optionsfor treating ballast water or exchangingtheir ballast water before they camewithin 200 miles of the coast. In 2003,the Assembly banned the dumping ofsewage sludge, oily bilge water and haz-ardous wastes in state waters.65 And in2004, the Assembly made California’sstandards the most comprehensive in thecountry by banning the dumping ofgraywater and blackwater—treated oruntreated—in state waters, and banningthe use of onboard waste incineratorswhile within 2 miles of shore.66

The approach taken by California istheoretically now the strongest in the

country, but it does have some problems.One disadvantage is that because the lawcontains no funding mechanism, enforce-ment agencies have no additional fundsto pay for field monitoring or water qual-ity testing in the event of a possible inci-dent. On the other hand, because nodischarge is allowed in state waters, fund-ing to pay for more expensive boardingand sampling of ships’ effluent is not nec-essary. Also, civil penalties of up to$25,000 per violation provide a strongdeterrent.67

Maine:Maine passed legislation in 2004 in anattempt to replicate Alaska’s success atprotecting its water. Maine’s legislationallows dumping of graywater and black-water only if ships have Alaska-certifiedAdvanced Wastewater Treatment Sys-tems. After 2006, ships discharging musthave state discharge permits. Also, theBoard of Environmental Protections andthe Legislature are directed to approveregulations in January 2005.68

States That have SignedMemoranda ofUnderstandingThree states have attempted to controlcruise ship pollution by signing non-en-forceable, voluntary, “Memoranda ofUnderstanding” (MOUs). These statesare Hawaii, Florida, and Washington.

Hawaii and Florida:Hawaii and Florida signed MOU’s withtheir local cruise line associations in 2002and 2001 respectively. Both agreementsbasically accept the protections developedby the International Council of CruiseLines (ICCL) in December 2001, which

Part 3: Legislation or MOU 21

include promises to minimize or elimi-nate the discharge of several types ofwaste, including silver and other photo-processing chemicals, dry cleaningwastes, printing and cleaning chemicals,pharmaceuticals, mercury and fluorescentlight bulbs, and batteries; “meet or ex-ceed” international standards for remov-ing oil from wastewater; follow theInternational Convention for the Preven-tion of Pollution from Ships (MARPOL)with respect to general garbage wastesincluding glass, cardboard, and cans; dis-charge graywater only when moving at 6knots or more and more than 4 nauticalmiles from shore; and to discharge black-water only after processing by a certifiedMarine Sanitation Device and when mov-ing at 6 knots or more, and more than 4nautical miles from shore.

The only substantive difference be-tween the two MOUs is that the reach ofFlorida’s MOU is the state’s territorialwaters (out to 3 miles from shore), whileHawaii’s MOU allows ships with ad-vanced wastewater treatment systems todischarge a mile or further from shore,and prevents ships without advancedwastewater treatment systems from dis-charging within four miles of shore.69

Washington:Washington’s MOU, signed in April2004, attempts to emulate the strengthof Alaska’s regulation, but without theteeth of state law. Cruise ships discharg-ing in Washington waters must be usingAlaska-certified Advanced WastewaterTreatment Systems; they must be mov-ing at least 6 knots at the time of dis-charge, but if they use a more rigoroustreatment program including ultravioletlight, they may be allowed to dischargein port; sewage sludge may not be dis-charged within 12 miles of any Washingtoncoast; sampling and reporting require-ments require cruise lines to submit

monthly reports on self-administeredtests, and the Department of Ecology is al-lowed to audit testing at any time.70

Because the MOU does not include afunding mechanism, the Department ofEcology estimates that implementing theagreement will cost taxpayers $44,767from June 2004 to June 2005. The cruiseindustry has agreed to take on the costsof MOU implementation, but as ofthe end of January 2005 this had nothappened.71

Comparison of the Resultsof Legislation and MOUsThe contrast between the effectivenessof legislation and MOUs could not bemore clear than the different experiencesof Hawaii and Alaska. The first year itwas in effect, Hawaii’s MOU was violated16 times. Violations included mostly thedischarge of graywater and blackwater inthe protected fishing ground known asPenguin Bank. Also cited were one in-stance of incinerating waste while in port,the discharge of almost 20,000 gallons ofgalley waste and graywater in marine ar-eas, and reporting errors.72 Because thecruise lines were subject to only a volun-tary agreement, no fines or charges wereimposed.

Alaska, a state which saw 39 confirmedair emissions violations in the period from1999 to 2001, has seen only one viola-tion between 2002 and 2003, and waste-water discharge violations since 2001have been nearly nonexistent.73 Clearlythe Alaska Cruise Ship Initiative, passedin 2001 and setting clear standards andpenalties for violation, was the key rea-son for this dramatic improvement.

Though its MOU was only signed inApril 2004, Washington has already seencruise ships violate it three times. In oneinstance, Holland America Lines’


Zaandam discharged black and gray waterfrom an advanced wastewater treatmentsystem while at port in Port Angeles. Itviolated the MOU because the Zaandamhad not submitted paperwork necessaryto be approved for discharge in port.

The Princess Line’s M.S. Sapphire wasguilty of two violations by first discharg-ing treated effluent throughout the 2004season when it was not certified to do so;and second—the worst violation of theyear—by discharging untreated gray wa-ter during its first voyage from Seattle toVictoria. The untreated gray water con-tained high fecal coliform, biochemicaloxygen demand, total suspended solids,and low pH, all of which are damagingto the health of Puget Sound.74

While all three violations can be ex-plained to some degree by the ships’crews being unfamiliar with the new pro-cedures, they also underscore the needfor cruise lines to have a greater incentiveto meet clean environmental standards.

In addition to Washington’s little ex-perience with its MOU, its experience

with two prior voluntary agreementsshould be considered for how effectivethe MOU—as another voluntary agree-ment—will be in the future.

One was the discharge of 16,000 gal-lons of raw sewage into the Strait of Juande Fuca near Whidbey Island in 2003 bythe Norwegian Sun, after the cruise indus-try had agreed to follow Alaska’s standardswhile in Washington waters.75 In re-sponse to the state of Washington’s cita-tion, the cruise line claimed both that thedischarge was a mistake and that the statedidn’t have jurisdiction over cruise shipsanyway. The second was the cruiseindustry’s disregard of 2002 and 2003commitments to burn only low sulfurfuels while in port at Seattle. In Septem-ber 2003 the environmental groups Blue-water Network and Ocean Advocatesdiscovered and revealed that ships at thePort of Seattle were not and had neverused low sulfur fuels there.76 Again, be-cause the agreement was a voluntary onebetween the Port of Seattle and the cruiselines, no penalty was imposed on thecruise lines.

In the first case, though they hadclearly broken a stated promise, Norwe-gian Cruise Lines argued that the statedid not have the power to regulate cruiseships. And in the second, the brokenpromise to burn low sulfur fuels at thePort of Seattle was only discovered whencruise industry lobbyists claimed they didnot have the technology to burn low sul-fur fuels, though they had already com-mitted to burning low sulfur fuels inSeattle. The cruise industry’s brokenpromises and ambivalence toward envi-ronmental protection will continue aslong as Washington relies on voluntaryagreements to safeguard its marine waters’health.A cruise ship at dock in Hawaii.

Photo by Russell Lynch, courtesy of KAH

EA

Conclusions and Recommendations 23

Factors demonstrating theimportance of legislation

In addition to the quantifiably differ-ent experiences of states that have en-acted laws and states that have signed

MOUs, there are several factors thatshow Washington should pass legislation.First, Washington is in a geographic po-sition where strict laws make sense. BothAlaska and California have passed legis-lation to protect state waters and punishpolluters. Ships traveling from Alaska andCalifornia are already equipped to meethigh environmental standards. There isno reason for Washington’s waters to bethe dumping ground for west coast cruiseships.

Second, as described in Part 2, Wash-ington’s marine resources deserve thehighest standard of protection because oftheir high aesthetic and economic value,and because they are already seriouslythreatened by pollution. Legislation pro-vides both a powerful incentive for envi-ronmental responsibility as well as theopportunity for the state to recover thecosts of damages and repair harm.

Third, MOUs not only fail to penal-ize polluters, but they include no man-datory fee system, often leaving the costsof monitoring and recovery to taxpayers.The Department of Ecology estimatedit will cost Washington State $44,767 toimplement the MOU from June 2004 toJune 2005. While the cruise lines haveagreed to take on the cost of implemen-tation, that arrangement has not beencompleted. 77 Thus citizens of Washingtonhave so far paid for both the regulationand the violationsof an industry that takeshome tens of millions of dollars in profits.

Fourth, there is the question of trust.As Ross Klein has pointed out, MOUs arean expression of trust. Given the cruiseindustry’s record of breaking verbal andwritten agreements, betting Washington’smarine resources on the trustworthinessof cruise lines is a very risky proposition.The most concerning violation of trustin Washington to date was the Norwe-gian Cruise Lines’ response to the state,after dumping 16,000 gallons of sewagein the Strait of Juan de Fuca, that only apromise, not a law, had been broken.78

Taking up voluntary protections with anindustry with this attitude is unwise.

Conclusions andRecommendations


Last, cruise lines regularly insist thattheir ships meet the standards of proposedlaw, even while resisting regulation. Iftheir ships meet proposed standards al-ready, then cruise lines should accept leg-islation. In fact, lines whose ships meetstandards of proposed law should supportthat legislation because they stand to gaina competitive advantage over lines thatneed to upgrade their ships.

RecommendationsTo protect Washington’s marine environ-ment, legislation regulating cruise shipdischarges should include:

1. A ban on the discharges of blackwater,graywater, oily bilge water, ballastwater, and hazardous wastes in statewaters.

2. Clear penalties for violating regula-tions. Penalties should provide aneconomic deterrent to violationand cover the damage to stateecosystems.

3. A per-passenger fee system to payfor a state monitoring program. Agraduated fee scale could provideeconomic incentives for cruise lines

to be environmentally responsible.An average fee of $1-2 per passengerwould pay the major part of theexpenses of cruise ship monitoring.

ConclusionPerhaps the futility of pursuing voluntaryaction as a means of protecting publicresources is summed up best by LarryLau, Hawaii’s state deputy director forenvironmental health. In response to themany violations of Hawaii’s MOU by thecruise industry, Lau told the HonoluluAdvertiser that the MOU “beats noth-ing… I’m trying to do the best with whatwe have.”79 In Washington, an MOU isthe best we have only because we havenot demanded better protection for ourcoasts. The protection of Washington’sincredible marine waters are in the handsof our state Representatives, Senators,and Governor, and they need to makesure that Washington’s resources are bet-ter protected.

Washington’s marine waters are tooprecious to the state, its citizens, and itseconomy—and already far too endan-gered—to accept anything less thanstrong, specific, and enforceable stan-dards for what cruise ships may leave here.

References 25

1. Klein, Ross. Cruise Ship Blues: The Underside ofthe Cruise Industry. New Society Publishers:Gabriola Island, Canada, 2002. p. 2.2. Ibid. p.121.3. U.S. General Accounting Office. “MarinePollution: Progress Made to Reduce MarinePollution by Cruise Ships, but Important IssuesRemain.” Report to Congressional Requesters,February 2000. http://www.gao.gov/new.items/rc00048.pdf Viewed Dec. 17, 2004.4. Herz, Michael. “Cruise Control: A Report onHow Cruise Ships Affect the Marine Environ-ment.” The Ocean Conservancy, May 2002. p. 14.5. Bluewater Network. “’Trust Us’ is not aneffective environmental policy.” Factsheet, 2004.6. Klein, Ross. Cruisejunkie.com http://www.cruisejunkie.com Viewed November 11,2004.7. Herz, Michael. “Cruise Control: A Report onHow Cruise Ships Affect the Marine Environ-ment.” The Ocean Conservancy, May 2002. pp.13-15.8. EPA Silver Nitrate Factsheet http://www.epa.gov/pesticides/biopesticides/ingredi-ents/factsheets/factsheet_072503.htm viewedDec. 3, 2004.9. EnviroTools.org factsheet (adapted from U.S.EPA) http://www.envirotools.org/factsheets/contaminants/Perchloroethylene.shtml#effectviewed Dec. 3, 2004.

10. Herz, Michael. “Cruise Control: A Reporton How Cruise Ships Affect the MarineEnvironment.” The Ocean Conservancy, May2002. pp. 13-15.11. Seattle Post-Intelligencer Staff. “Cruiseships to plug in to reduce pollution.” Oct. 1,2004.12. U.S. Commission on Ocean Policy. “Pre-liminary Report of the U.S. Commission onOcean Policy.” April 2004. p. 10.13. Puget Sound Action Team. 2005-2007 PugetSound Conservation and Recovery Plan. 2004. p. 17.14. U.S. Commission on Ocean Policy. “Pre-liminary Report of the U.S. Commission onOcean Policy.” April 2004. p. 11.15. Puget Sound Action Team. Treasure of theTidelands (Factsheet). July 2003. http://www.psat.wa.gov/Programs/shellfish/fact_sheets/economy_web1.pdf viewed Dec. 3,2004.16. Puget Sound Action Team. A Heritage ofHarvest (Factsheet). July 2003. http://www.psat.wa.gov/Programs/shellfish/fact_sheets/heritage_web1.pdf viewed Dec. 3,2004.17. Koenings, Jeff, Ph.D., Director of Washing-ton Dept. of Fish and Wildlife. Presentation tothe Northwest Sportfishing Association,October 25, 2003. http://wdfw.wa.gov/depinfo/director/oct2503.htm viewed Dec. 3, 2004.

References


18. Washington State Department of Ecology.

2004 Assessment of Cruise Ship Environmen-

tal Effects In Washington. Prepared by Amy

Jankowiak. January 24, 2005, p. 20.

19. Klein, Ross. Cruisejunkie.com http://www.cruisejunkie.com Viewed November 11, 2004.20. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003.pp. 7.21. Pemberton, Mary. “Cruise ship companyadmits dumping sewage.” Seattle P-I, Dec. 8, 2004.22. Klein, Ross. Cruise Ship Blues: The Undersideof the Cruise Industry. New Society Publishers:Gabriola Island, Canada, 2002. p. 2.23. Ibid. p. 121.24. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003.pp. 3-4.25. Bluewater Network. “’Trust Us’ is not aneffective environmental policy.” Factsheet, 2004.26. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003. p. 13.27. Klein, Ross. Cruise Ship Blues: The Undersideof the Cruise Industry. New Society Publishers:Gabriola Island, Canada, 2002. p. 6.28. Dragon, Debbie. “History of Cruise Ships.”http://www.traveljobz.com/cruise-ship-jobs/cruise-overview.asp Viewed November 11, 2004.29. Klein, Ross. Cruise Ship Blues: The Undersideof the Cruise Industry. New Society Publishers:Gabriola Island, Canada, 2002. p. 2.30. Ibid. p. 5.31. EPA Silver Nitrate Factsheet <http://www.epa.gov/pesticides/biopesticides/ingredi-ents/factsheets/factsheet_072503.htm > viewedDec. 3, 2004.32. EnviroTools.org factsheet (adapted fromU.S. EPA) <http://www.envirotools.org/factsheets/contaminants/Perchloroethylene.shtml#effect> viewed Dec. 3,2004.33. Herz, Michael. “Cruise Control: A Reporton How Cruise Ships Affect the MarineEnvironment.” The Ocean Conservancy, May2002. pp. 13-15.34. Ibid. p. 14.

35. Seattle Post-Intelligencer Staff. “Cruise shipsto plug in to reduce pollution.” Oct. 1, 2004.36. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003. p. 4.37. U.S. General Accounting Office. “MarinePollution: Progress Made to Reduce MarinePollution by Cruise Ships, but Important IssuesRemain.” Report to Congressional Requesters,February 2000. http://www.gao.gov/new.items/rc00048.pdf Viewed Dec. 17, 2004.38. Klein, Ross. Cruisejunkie.com http://www.cruisejunkie.com Viewed November 11, 2004.39. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003.pp. 3-4.40. Ibid, p. 5.41. Herz, Michael. “Cruise Control: A Reporton How Cruise Ships Affect the MarineEnvironment.” The Ocean Conservancy, May2002. p. 14.42. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003. p. 5.43. Shore, Teri, Bluewater Network. Conversa-tion with, September 24, 2004.44. Pew Oceans Commission. “America’s LivingOceans: Charting a Course for Sea Change.”April 2003.45. U.S. Commission on Ocean Policy. “Pre-liminary Report of the U.S. Commission onOcean Policy.” April 2004.46. Mapes, Lynda M. “Vashon Island returns tonormal following oil spill.” Seattle Times.November 8, 2004.47. Cunard website http://www.cunard.com/OnBoard/default.asp?OB=QE2&sub=sp viewedDec. 3, 2004.48. Cohen, Gershon. Factsheet titled “CruiseShip Facts.” Campaign to Safeguard America’sWaters (C-SAW).49. Herz, Michael. “Cruise Control: A Reporton How Cruise Ships Affect the MarineEnvironment.” The Ocean Conservancy, May2002. pp. 13-15.50. U.S. Commission on Ocean Policy. “Pre-liminary Report of the U.S. Commission onOcean Policy.” April 2004. p. 10.

References 27

51. Ibid.52. Puget Sound Action Team. 2005-2007 PugetSound Conservation and Recovery Plan. 2004. p. 17.53. Washington Department of Health.Threatened Shellfish Growing Areas, map.http://www.doh.wa.gov/ehp/sf/Pubs/Threatareas02.pdf viewed Dec. 3, 2004.54. Pew Oceans Commission. “America’s LivingOceans: Charting a Course for Sea Change.”April 2003. p. 59.55. EPA Silver Nitrate Factsheet http://www.epa.gov/pesticides/biopesticides/ingredi-ents/factsheets/factsheet_072503.htm viewedDec. 3, 2004.56. EnviroTools.org factsheet (adapted fromU.S. EPA) http://www.envirotools.org/factsheets/contaminantsPerchloroethylene.shtml#effect viewed Dec. 3,2004.57. Puget Sound Action Team. Treasure of theTidelands (Factsheet). July 2003. http://www.psat.wa.gov/Programs/shellfish/fact_sheets/economy_web1.pdf viewed Dec. 3, 2004.58. Puget Sound Action Team. A Heritage ofHarvest (Factsheet). July 2003. http://www.psat.wa.gov/Programs/shellfish/fact_sheets/heritage_web1.pdf viewed Dec. 3, 2004.59. Koenings, Jeff, Ph.D., Director of Washing-ton Dept. of Fish and Wildlife. Presentation tothe Northwest Sportfishing Association,October 25, 2003. http://wdfw.wa.gov/depinfo/director/oct2503.htm viewed Dec. 3, 2004.60. Shore, Teri, Bluewater Network. “CruiseShip Memorandum of Understanding asCompared to the state law of Alaska.” Informa-tional memo, 2003.61. Shore, Teri, Bluewater Network. Personalcorrespondence, December 7, 2004.62. Alaska House of Representatives Bill No.260 in the 22nd Legislature (2001), signed intolaw July 20, 2001.63. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003. p. 5.64. Cohen, Gershon. “Campaign to SafeguardAmerica’s Waters” Earth Island Journal,Summer 2003. http://www.earthisland.org/eijournal/new_articles.cfm?articleID=696&journalID=68Viewed Dec. 17, 2004.65. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective for

Protecting the Environment?” October, 2003. p. 11.66. Bluewater Network Press Release. “CruiseShip Dumping and Trash Burning Banned InCalifornia.” Sept. 24, 2004. http://bluewater-network.org/press_releases pr2004sep24_cv_dumpingbills.pdfViewed on Nov. 14, 2004.67. California State Law, Chapter 764, Section72430. Passed as bill AB 2672, filed Sept. 24, 2004.68. Shore, Teri, Bluewater Network. “Summaryof Current and Pending Cruise Ship Laws andLegislation in the U.S.” November 2004.69. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003. p. 9.70. Shore, Teri, Bluewater Network. “Summaryof Current and Pending Cruise Ship Laws andLegislation in the U.S.” November 2004.



tal Effects In Washington; Appendix C:

Annual Cruise Meeting Notes. Prepared by

Amy Jankowiak. January 24, 2005.

72. Klein, Ross. Cruisejunkie.com http://www.cruisejunkie.com/Hawaii_mou.htmlViewed November 11, 2004.73. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003. p. 7.





75. Bluewater Network. “’Trust Us’ is not aneffective environmental policy.” Factsheet, 2004.76. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003. p. 13.





78. Klein, Ross. “The Cruise Industry andEnvironmental History and Practice: Is aMemorandum of Understanding Effective forProtecting the Environment?” October, 2003. p.11-12.79. Yamanouchi, Kelly. “Cruise Lines AdmitPollution Violations.” Honolulu Advertiser,December 12, 2003.

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