29 CruisingForABruising

Chris Wells
Washington Public Interest

Research Group (WashPIRG)
February 2005
Cruising for
a Bruising
Why Washington Needs Laws
to Protect its Waters from
Cruise Ship Dumping
Acknowledgments
WashPIRG would like to gratefully acknowledge the help of Gershon Cohen (Cam-
paign to Safeguard Americas Waters, C-SAW), Ross Klein, and Teri Shore (Bluewater
Network) for providing valuable information and guidance for this report.
More information about Gershon Cohens 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 Kleins famous Cruise Junkie website is www.cruisejunkie.com.
The Bluewater Networks website is www.bluewaternetwork.org.
The author alone bears responsibility for any factual errors. The recommendations in
this 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. For
more 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; cruise
ship, 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 of
the Cruise Ship Industry 11
The Growth of the Cruise Industry 11
The Cruise Industrys Legal Record 12
Alaskas Cruise Experience 12
Part 2: Costs to the State of Washington 15
The State of Washington Waters 15
Washingtons Economy at Risk 17
Part 3: Legislation or MOU?: The Attempts
of Six States to Address Cruise Ship Pollution 19
States that have passed legislation 19
States that have signed Memoranda of Understanding 20
Comparison of the results of legislation and MOUs 21
Conclusions and Recommendations 23
References 25
4 Cruising for a Bruising
Executive Summary 5
Executive Summary
I
n the thirty years since the cruise ship
business became a major industry, tak-
ing cruises has become a vacation phe-
nomenon. People seem to love the aspects
of cruises that make them different from
other vacationseasy-going trips to ex-
otic locations, constant service, seclusion
and famously good and plentiful food;
since 1980, the number of passengers
cruising out of North America has in-
creased from 1.4 million to 7 million in
2000. Around the globe, 12 million
people took cruises in the year 2000.
1
The cruise industrys popularity has
made it a potent source of profits for its
owners and shareholders, and a signifi-
cant source of jobs for the 100,000 plus
cruise industry workers.
2
But below the decks of these glamor-
ous floating resort hotels floating cities
in scale is a poor environmental record
and disdain for environmental regulation.
Cruise ship traffic poses major threats
to delicate Puget Sound ecosystems, a
region where biological health and di-
versity have enormous social, environ-
mental, and economic significance and
are already threatened. In the United
States, six states have taken one of two
approaches to protecting their waters from
cruise ship wastes: three, including Wash-
ington, have signed Memoranda of Un-
derstanding (MOUs) with the cruise
industry, and three have passed legisla-
tion. On the west coast, California and
Alaska have both enacted laws to protect
their waters from cruise ship wastes. While
ships from both states regularly come to
Seattle, Washington has no laws binding
cruise ships to clean environmental practices.
A comparison of MOUs and laws and
a review of the experiences of states that
have implemented each reveal that an
MOU is insufficient for protecting
Washingtons waters and that the Legis-
lature needs to pass laws to protect our
marine waters.
The Cruise Industrys
Environmental Record
The cruise industrys environmental
record is poor.
Between 1993 and 1998, the cruise
industry was cited for 87 illegal
dumping events in U.S. waters and
incurred over $100 million in fines.
3
When Alaska tested wastewater
discharged by cruise ships into the
ocean in 2000, concentrations of
fecal coliform in the wastewater were
as high as 100,000 times the federal
standard.
4
In 2003, the Norwegian Sun dis-
charged 16,000 gallons of raw
sewage into Puget Sound between
Whidbey Island and the Strait of
Juan de Fuca.
5
Costs of Cruise Ship Wastes
In a day, a typical cruise ship of 3000 pas-
sengers and crew generates as much waste
as a small city:
11.5 tons of garbage from the pas-
sengers alone.
7
23 gallons of toxic waste, including
silver nitrate (from photo labs), heavy
metals, 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, the
wastewater from sinks, showers,
dishwashing, and laundry.
7,000 gallons of oily bilge water.
10
Air pollution equivalent to that
produced by more than 12,000
automobiles.
11
The enteric bacteria, fecal coliform,
pathogens, diseases, viruses, intestinal
parasites, excessive nutrients, heavy met-
als, and toxic chemicals in cruise ship
wastes have a number of harmful effects
on marine environments they enter.
Three of the most severe are:
1. The threat to human health
through direct contact with
pathogens, viruses, other diseases,
and parasites while swimming or
otherwise enjoying the water.
According to the U.S. Commission
on Ocean Policy, in 2002, more than
12,000 beach closings and swimming
advisories were issued in the United
States.
12
2. The threat to human health and
the economy due to contamina-
tion of shellfish such as oysters
and clams.
As of July 2004, 30,000 acres of
Puget Sounds 165,000 acres of
shellfish beds were restricted from
commercial and recreational harvest
due to bacterial contamination in the
Sounds water.
13
3. The eutrophication, or oxygen
depletion, of marine environments
due to excess nutrients.
The oxygen-depleted dead zone
now expanding in Hood Canal is the
best-publicized example of this wide-
spread process in the Puget Sound.
FACT:
Ross Kleins 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 Sounds Economy
in Jeopardy
The impacts of cruise ship wastes directly
or indirectly affect millions of people liv-
ing in the Puget Sound region, and tens
of thousands who make their livings from
the Sounds resources:
Each year, Washingtons oysters,
mussels, clams, and geoducks gener-
ate around $77 million in sales,
supporting 1,200 jobs in Mason and
Pacific counties alone.
15
The recre-
ational harvest of shellfish is also
culturally and economically very
significant. During the season,
30,000 people a day go out to dig
razor clams on Washingtons coast.
16
Combined commercial landings and
expenditures for recreational fishing
in 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; and
corresponding tourism and property
values all contribute to the economy
and social structure of the region and
are adversely impacted by marine
pollution.
Memoranda of
Understanding (MOUs)
Versus Regulations
Out of concern for their coastal resources,
several states have taken one of two ap-
proaches to regulating cruise ship wastes:
binding statutory laws, and voluntary
memoranda of understanding (MOUs).
Alaska, California, and Maine have passed
laws to regulate cruise ships; Washing-
ton, Florida and Hawaii have signed
MOUs with the cruise industry. During
the 2004 cruise season, Washington saw
three violations of its MOU, including
one discharge of untreated gray water that
contained high levels of fecal coliform,
biochemical oxygen demand, and total
suspended solids.
18
And the contrasting
experiences of Alaska and Hawaii clearly
illustrate the superiority of laws to MOUs
in protecting marine waters.
The first year it was in effect, Hawaiis
MOU was violated 16 times. Violations
included mostly the discharge of
graywater and blackwater in the protected
fishing ground known as Penguin Bank.
Also cited were an instance of incinerat-
ing waste while in port, the discharge of
almost 20,000 gallons of galley waste and
graywater in marine areas, and reporting
errors.
19
In Alaska, wastewater discharge
violations by cruise ships since the pas-
sage of regulations have been nearly non-
existent, and air emissions violations have
gone from 39 between 1999 and 2001 to
just 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 Recommendations
To protect its marine waters from the
threats posed by cruise ship wastes, Wash-
ington State needs measures stronger
than an MOU. Washington lawmakers
should pass legislation that will:
1. Ban the discharge of blackwater,
graywater, oily bilge water, ballast
water, and hazardous wastes in state
waters.
2. Establish clear penalties for violating
regulations. Penalties should provide
an economic deterrent to violation
and cover the damage to state eco-
systems.
3. Create a per-passenger fee system to
pay for a state monitoring program.
A graduated fee scale could provide
economic incentives for cruise lines
to be environmentally responsible.
An average fee of $1-2 per passenger
would pay the major part of the
expenses of cruise ship monitoring.
FACT:
In contrast to Hawaiis 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 from
other vacationseasy-going trips to ex-
otic locations, constant service, seclusion,
and famously good and plentiful food;
since 1980, the number of passengers
cruising out of North America has in-
creased from 1.4 million to 7 million in
2000. Around the globe, 12 million
people took cruises in the year 2000.
22
The cruise industrys popularity has
made it a potent source of profits for its
owners and shareholders, and a signifi-
cant source of jobs for the 100,000 plus
cruise industry workers.
23
But below the decks of these glamor-
ous floating resort hotels floating cities
in scale is a deplorable environmental
record and a blatant disregard for envi-
ronmental regulation. The first part of
this report catalogues some of the most
egregious and harmful violations, espe-
cially in Washington and Alaska. Before
1998, when a series of events unfolded
that ultimately forced state governments
to begin taking cruise ship environmen-
tal practices into their own hands, cruise
ships had environmental records nothing
short of disgraceful.
The watershed events of 1998 began
in June, when Royal Caribbean agreed to
pay a total of $18 million for twenty-one
total violations of environmental laws
around the country. Also in 1998, Hol-
land America Line paid a total $2 million
for dumping oily bilge water into pris-
tine Inside Passage waters in Alaska. And
in 2000, Alaska sued Royal Caribbean for
dumping toxic chemicals and oily water
and was awarded $3.5 million.
24
After testing implemented by the first
Alaska cruise ship initiative in 2000 re-
vealed that cruise ships were dumping
huge quantities of pollution into pristine
North Pacific waters, and that even ships
running Coast Guard-certified Marine
Sanitation Devices were releasing efflu-
ent with up to 100,000 times federally
legal levels of fecal coliform, Alaskan pub-
lic sentiment demanded legislation. In
response, the Alaska State Legislature
enacted in 2001 legislation with three
main components:
1. A sampling component, including
requirements for sampling and
reporting of wastewater discharges
and air emissions. Ships must sample
their effluent at least twice per year
and must share the results with the
state. Alaska may also conduct
unlimited sampling while the ship is
in Alaskan waters.
2. A standard component, establishing
standards and enforcement. For
graywater or blackwater to be dis-
charged in state waters, the effluent
must meet state standards for sus-
pended solids, fecal coliform and
other substances. Also, several no-
discharge zones were created.
3. A fee component, to ensure the
cruise industry bears the cost of
regulation. The fee established was
$.75 to $1.75 per passenger per cruise.
Cruise ship pollution has proven itself
a threat to Washington waters as well. In
2003, the Norwegian Sun discharged
16,000 gallons of raw sewage in Puget
Sound between Whidbey Island and the
Strait of Juan de Fuca.
25
And in Septem-
ber of 2003 it was revealed that despite
more than one commitment to burn low-
sulfur fuel while at dock at the Port of
Seattle, the cruise lines were not and had
never been doing so.
26
The irony of the cruise industrys tar-
nished environmental record is that the
industry spends considerable resources
not only to brand itself environmentally
responsible, but also to advertise the very
places and wildlife that are threatened by
its unethical environmental practices. All
together, the industry spends over $500
million a year in advertising.
27
For cruises
to the Northwest and Alaska, much of
that 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 should
be done to protect Washington waters,
especially Puget Sound, from cruise ship
pollution. Around the United States,
states have taken two approaches. Some
have passed tough legislation to hold
cruise ships to strict standards and punish
them for violations. Other states, includ-
ing Washington, have adopted voluntary
agreements with cruise lines. This report
will demonstrate that voluntary agreements
are significantly less effective than legis-
lation in preventing cruise ship pollution
and will recommend that Washington
adopt into law legislation comparable to
that 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 and
some of the environmental threats that
cruise ships pose to marine waters in gen-
eral and to Washington waters in particu-
lar. The history of the cruise ship industry
and its regulation is important context for
understanding the positions of states,
such as Alaska and California, which have
taken regulatory action, and states that
are pursuing voluntary agreements, in-
cluding Washington.
Part 2 focuses on the economy of
coastal Washington and Puget Sound,
and the numerous small businesses and
large businesses that are impacted by the
degradation of marine waters and the
threats posed by cruise ship pollution.
Part 3 will show that signing Memo-
randa of Understanding (MOUs), which
are voluntary agreements, is not as effec-
tive a tool for protecting marine waters from
cruise ship pollution as enacting legisla-
tion. The experiences of states with MOUs
in place will be compared with the expe-
riences of states that have passed legisla-
tive regulations, and particular attention
will be drawn to the contrasting degrees of
success of Alaska's laws and Hawaii's MOU.
The conclusion presents additional
factors 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 Record
of the Cruise Ship Industry
The Growth of the
Cruise Industry
T
he modern cruise ship industry was
born in the 1950s, when large num-
bers of Americans began being able
to afford luxury vacations.
28
The cruise
industry grew steadily alongside the af-
fluence of American vacationers, but the
industry took off in the 1970s; between
1970 and 2002, the number of people tak-
ing cruises increased 1,000%, and con-
tinues to grow.
29
The increase in the total
number of cruise ship passengers is paired
with not only more ships plying Ameri-
can waters, but with ships of increasing
size. In the 1970s, most ships carried
around 600-700 passengers; today, the
smallest major-line cruise ships carry
more than a thousand, and modern cruise
ships top out at more than 5,000 passen-
gers and crew.
30
Today, a typical cruise ship of 3,000
passengers 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 garbage
is incinerated and the ashcontain-
ing toxics from the burning of
plastics and heavy metalsis
dumped into the sea.
23 gallons of toxic waste, including
silver nitrate (from photo labs),
which is toxic to fish and is not
permitted to be used outdoors
31
;
heavy metals; and PERC (perchloro-
ethylene, from dry-cleaning facili-
ties), which evaporates quickly in the
air and affects the nervous system,
among other human health impacts.
At the environmental scale, PERC
can add to the development of
photochemical 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 waste
contains fecal coliform bacteria,
other pathogens, diseases, viruses,
intestinal parasites, and harmful
nutrients including nitrogen and
phosphorus.
33
The major risks posed
by these substances will be discussed
later and include direct threats to
human health, threats to shellfish
beds and the people who eat them,
and a general degradation in the
waters they contaminate through
eutrophication.
270,000 gallons of graywater, the
wastewater from sinks, showers,
dishwashing, and laundry. Although
fecal coliform is usually associated
with blackwater, testing by the state
of Alaska in 2000 found significant
levels in graywater also.
34
7,000 gallons of oily bilge water.
Air pollution equivalent to that
produced by more than 12,000
automobiles. Almost all cruise ships
burn diesel fuel, which has been
linked to lung cancer, other types
of cancer, and a rising rate of
asthma.
35
Not surprisingly, more people cruis-
ing on more ships in greater concentra-
tions than ever before has had significant
consequences for the marine environ-
ments that they explore. Before 1998 and
1999, when the environmental impacts of
cruise ships began attracting attention,
36
the industrys environmental record was
what one might expect from a fast-grow-
ing, unregulated industry operating be-
low the view of public scrutiny and
mainstream media: horrific.
The Cruise Industrys
Legal Record
The U.S. General Accounting Office
records 87 illegal dumping events in U.S.
waters between 1993-1998.
37
On his
website, www.cruisejunkie.com, Dr. Ross
Klein records 117 environmental viola-
tions by various cruise ships cumulatively
resulting in $100 million in fines between
1992 and 1999. These violations include
the 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 Coast
Guard records, which calls into question
the cruise industry's credibility when it
insists that it does not harm the environ-
ment.
38
There is also one citation for
damage to a reef.
The combination of the incredible size
of modern cruise ships and the volume
of waste they produce with the number
and frequency of environmental viola-
tions by cruise ships during the last de-
cade makes cruise ship pollution a serious
threat to marine ecosystems.
Alaskas Cruise Experience
Between 1998 and 2001, several high-
profile events took place that significantly
reshaped both the Alaskan publics atti-
tudes towards the cruise industry and leg-
islators willingness to pursue regulatory
options. First, Royal Caribbean Interna-
tional agreed to an $18 million fine in
pleading guilty to twenty-one violations
that included the illegal discharges of oil
and hazardous wastes around the United
States and lying to the Coast Guard. In
1998, Holland America Line paid a $1
million fine and $1 million in restitution
for intentionally discharging oily bilge
water into Alaskas pristine Inside Passage
in 1995. Then, in 2000, the state of Alaska
won a suit against Royal Caribbean for
dumping toxic chemicals and oily water
into Alaskan waters; the company paid a
$3.5 million fine.
39
Not surprisingly, following these
widely publicized incidents, there was
strong 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 late
1999, Alaskas Department of Environ-
mental Conservation, along with the
Coast Guard, the industry, and conser-
vationists, began a cruise ship initiative
to assess environmental impacts of cruise
ships. They created a sampling plan to
measure cruise ship wastewater dis-
charges and air emissions, which went
into effect in 2000, and in the words of
then-Alaska governor Tony Knowles, the
results were disgusting and disgraceful.
40
Tests of blackwater effluent from
cruise ships operating federally
mandated, Coast Guard-certified
Marine Sanitation Devices revealed
fecal coliform levels as high as
9 to 24 million colonies per 100
millileters of treated water.
Those fecal coliform levels exceeded
federal standards by 10,000 to
100,000 times.
The tests found that not one of 22
tested ships was in compliance with
all blackwater standards; the reason
for the unanimous failure of the
Marine Sanitation Devices, the
Coast Guard found, was that they
were either not being operated
properly by the cruise company,
or they had not been properly
maintained.
41
After the cruise ship testing, the cruise
industry found itself facing even more
Alaskan public support for meaningful
rules to bring cruise ship companies to
bay and punish them when they fouled
state waters. Because of the public out-
cry, the U.S. Congress passed legislation
to protect certain federal waters off Alaska
and give Alaska the right to regulate
blackwater in state waters.
42
Also, bipar-
tisan leadership from Democrats Gover-
nor Knowles and Representative Beth
Kerttula, and Republican Senator Rick
Halford helped to craft the Alaska Cruise
Ship Initiative,
43
which created a three-
part cruise ship regulation. Alaskas cruise
ship regulations will be discussed in Part
3 of this report.
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Estuarine habitats are critically important to hundreds of species of marine life. Delicate and
close 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 of
Washington Waters
S
tates like Alaska and Washington
have good reason to worry about the
risk of cruise ship pollution on our
beaches and in our water. As the recent
reports of the Pew Oceans Commission
and U.S. Commission on Ocean Policy
found, the deadly combination of pollu-
tion (including the substances cruise ships
discharge), overfishing, and coastal
overdevelopment has pushed ocean
ecosystems around Americas coasts to
the brink of collapse. And estuarine habi-
tats like the Puget Sound have been hard-
est hit because they receive most of the
non-point source (land source) pollution,
toxins are often not swiftly washed away
by ocean currents, and they are habitat
and breeding ground for thousands of
species.
44 , 45
Any kind of marine water pollution has
the potential to impact marine life, the
economy, and human health through
short term impacts, which are usually the
most 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 been
spared any major cruise ship discharge
resulting in immediate and highly visible
damage of estuarine habitat or human
health, two recent oil spills in the Sound,
in December 2003 and October 2004,
clearly illustrate the incredible financial
cost of even relatively small spoils of toxic
substances.
The smaller of these spills was a 1,000
gallons oil spill between Tacoma and
Maury Island in the middle of the night
on October 14, 2004. Even with the early
alert of authorities and oil spill contain-
ment crews, which were hampered by
morning fog, the toxic oil spread across
southern Puget Sound and soiled beaches
from the Tacoma Narrows to Bainbridge
Island. As of November 8, 2004 the esti-
mated cleanup cost of the spill was nearly
$2 million.
46
All this from 1,000 gallons
of fuel oil, which is minuscule compared
to the fuel holds of cruise ships. (The
Cunard companys Queen Elizabeth 2, a
ship with beds for fewer than 2,000 pas-
sengers, has a capacity of more than 4,300
tons 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 waste
like blackwater and graywater.
The most egregious case of cruise ship
dumping in Washington waters was the
dumping of 16,000 gallons (40 tons) of
raw sewage into the Strait of Juan de Fuca
on May 3
rd
, 2003.
48
Like the vast major-
ity of ship discharges, the great damage
caused by the discharge was not any sea
life that turned up dead at the scene. In-
stead, these discharges contribute to the
pollution increasing in the waters sur-
rounding our coasts. The types of pol-
lutants contained in cruise ship blackwater
and graywater waste include enteric bac-
teria, fecal coliform, pathogens, diseases,
viruses, intestinal parasites, and harm-
ful nutrients including nitrogen and
phosphorus.
49
There are multiple environmental con-
sequences for releasing these substances
into the water. The most serious are:
The threat to human health
through direct contact with
pathogens, viruses, other diseases,
and parasites while swimming or
otherwise enjoying the water.
According to the U.S. Commission
on Ocean Policy, in 2002, more than
12,000 beach closings and swimming
advisories were issued in the United
States. Most of those are due to the
presence of bacteria associated with
fecal contamination; the number of
beach closings is rising each year;
and they are costing the nation
millions of dollars in lost income
from tourism.
50
The threat to human health and
the economy through consump-
tion of shellfish such as oysters
and clams. The U.S. Commission
found that harmful algal blooms are
on the rise; that toxins associated
with such blooms cause 62% of
worldwide seafood-caused illness;
and that they cause 15% of the
deaths from food poisoning out-
breaks with a known cause.
51
As of
July 2004, 30,000 acres of Puget
Sounds 165,000 acres of shellfish
beds were restricted from commer-
cial and recreational harvest due to
bacterial contamination in the
Sounds water.
52
In Washington, the
Department of Health in April 2003
mapped 19 Threatened Shellfish
Growing Areas, which included
major growing areas on the coast and
in Puget Sound threatened by
marine biotoxins tied to excess levels
of nutrients. Shellfish beds at Grays
Harbor, on the west side of the
Olympic Peninsula, at Henderson
Bay in the south Sound, at Hood
Canal and at Port Townsend and
Skagit Bay further north were all
listed.
53
The steady eutrophication, or
build up of excess nutrients,
which the Pew Oceans Commis-
sion found to have moderately or
severely degraded two-thirds of
the estuaries and bays in the
United States.
54
Perhaps the most
tragic threat pollution poses to ocean
A pollution warning at Discovery Park, Seattle.
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Part 2: Costs and Benefits 17
ecosystems, the process of eutrophi-
cation is the literal destruction of
ocean areas; excess nutrients feed
giant algae blooms, which die off,
feeding the aerobic activity of bacte-
ria, which plunge the dissolved
oxygen levels of the area below
concentrations that fish and other
organisms need to breathe. In the
Puget Sound the dead zone now
expanding in Hood Canal is the best-
publicized example of this process.
The threat to fish, humans, and
the environment from toxic
chemicals such as silver nitrate,
which kills fish
55
; mercury, a
potent neurotoxin linked to birth
defects and learning disabilities in
human children; other heavy
metals; and perchloroethylene, which
contributes to smog and is toxic to
humans at moderate to high concen-
trations
56
.
Washingtons Economy
at Risk
Three sectors of the marine economy
should be considered when understand-
ing the potential impacts of the contri-
butions cruise ships make to marine
pollution: shellfish, both recreationally
and commercially harvested; fishing, in-
cluding commercial fishing, recreational
fishing, charter boat fishing, and the sup-
ported processing and sale sectors; and
impacts on Puget Sound quality of life,
property value and tourism.
Shellfish
Shellfish growing is one of Washingtons
trademark cultural and economic activi-
ties. In fact, Washington leads the nation
in producing farmed bivalve shellfish.
This is a major driver of Western Wash-
ington economies, especially in the most
rural areas where waters tend to be the
purestwhich is what shellfish need most
to be grown safely. Each year, Washingtons
oysters, mussels, clams, and geoducks
generate around $77 million in sales, sup-
porting 1,200 jobs in Mason and Pacific
counties 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 razor
clams on Washingtons coast.
58
As described above, human wastes
from cruise ships and other sources, be-
cause of the high levels of dangerous bac-
teria they contain and their potential for
overfeeding harmful algae, pose a serious
threat to shellfish farms around the state.
Fishing
Washingtons fishing economy is one of
the biggest in the country, with major
fishing and processing companies based
in Seattle and operating in the waters off
Alaska. There are also major commercial
fishing operations in Washington State
waters, and combined with expenditures
for recreational fishing, fishing in Wash-
ington State is worth around $1.2 billion
annually, directly supporting 24,000
jobs.
59
Cruise ship wastes pose a two-pronged
threat to fish in Puget Sound. First, as Digging for clams on a Washington beach.
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described above, toxic substances such as
silver nitrate are simply toxic for fish to
ingest; it kills them. Also, Puget Sound is
already experiencing severe eutrophica-
tion from mostly human wastes washing
into 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 same
elements and compounds into the water,
and without strong monitoring they can
do it directly, without valuable biological
buffers.
Other Impacts
There are countless reasons people
choose to live in the Puget Sound region
and spend their money here buying
homes, boats, and property. And there is
no question that as the waters are the
Puget Sound are degraded, Washington
citizens lose some of the value of their
recreational activities, such as boating,
waterskiing, wildlife watching, swim-
ming, fishing, and clam-digging. The
strictly economic value of property on
Puget Sound is affected, the special abil-
ity to safely produce and feed themselves
with Puget Sound products is reduced,
and numerous other elements of the high
quality of life here are threatened.
A block seiner in Puget Sound.
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Part 3: Legislation or MOU 19
States That Have
Passed Legislation
T
o date, six states have taken formal
actions to attempt to control the pol-
lution left by cruise ships in their
waters. ThreeAlaska, California, and
Mainehave passed legislation.
Alaska:
The momentum for passing legislation
to control cruise ship dumping was gener-
ated after several egregious dumping epi-
sodes outside of Alaska in the late
nineties, and the horrific results of test-
ing in 2000 (see Part 1, Alaskas Experi-
ence). The Alaska Cruise Ship Initiative
of 2001:
1. Banned the dumping of untreated
sewage by cruise ships; set effluent
standards for cruise ships blackwater
and graywater that are as strong as
those for municipal facilities and
required that cruise ships meet one
of three standards to be allowed to
dump anywhere, one mile from
shore, or outside state waters (3 miles
from shore);
2. Established comprehensive sampling
requirements for cruise ships and
sampling rights for the state Depart-
ment of Environmental Protection;
and
3. Enacted a per-passenger fee system
of between $.75 and $1.75 to pay the
Department of Environmental
Protections costs for their program.
60 , 61
The bill also outlined damages to be
levied. 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 for
determining the amount of the penalty
were identified as compensation for the
cost of damages to the environment; the
cost to the state to detect and investigate
the violation; the savings benefiting the
violator for not complying with the law;
and any additional cost necessary to en-
courage compliance.
62
Also in 2000, Alaskas Senator Frank
Murkowski sponsored legislation at the
federal level to regulate the dumping of
Part 3:
Legislation or MOU?:
The Attempts of Six States
to Address Cruise Ship Pollution
raw sewage in specific parts of Alaskas
Inside Passage, close donut holes be-
tween islands in the Inside Passage, and
give 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 Alaskas exercise of author-
ity over sewage dumping in its waters
would not be challenged in court.
Californias approach to what the cruise
industry has claimed to be an ambiguity
in the CWA is different, as we will see.
The battle to clean up cruise ships in
Alaska is not over. In negotiating the pro-
visions of the 2001 legislation, standards
for waste streams other than blackwater
and graywater were removed. A new Alas-
kan cruise ship initiative to protect against
other discharges, including hydrocar-
bons, plastics, and metals, is backed by
the Campaign to Safeguard Americas
Waters (C-SAW) and has qualified for the
Alaska ballot in 2006.
64
California:
California has passed a number of pieces
of legislation to regulate the wastes
dumped by cruise ships. In 2001, the State
Assembly passed legislation to mitigate
the impact of ballast water on state waters.
It gave cruise ships a number of options
for treating ballast water or exchanging
their ballast water before they came
within 200 miles of the coast. In 2003,
the Assembly banned the dumping of
sewage sludge, oily bilge water and haz-
ardous wastes in state waters.
65
And in
2004, the Assembly made Californias
standards the most comprehensive in the
country by banning the dumping of
graywater and blackwatertreated or
untreatedin state waters, and banning
the use of onboard waste incinerators
while within 2 miles of shore.
66
The approach taken by California is
theoretically now the strongest in the
country, but it does have some problems.
One disadvantage is that because the law
contains no funding mechanism, enforce-
ment agencies have no additional funds
to pay for field monitoring or water qual-
ity testing in the event of a possible inci-
dent. On the other hand, because no
discharge is allowed in state waters, fund-
ing to pay for more expensive boarding
and sampling of ships effluent is not nec-
essary. Also, civil penalties of up to
$25,000 per violation provide a strong
deterrent.
67
Maine:
Maine passed legislation in 2004 in an
attempt to replicate Alaskas success at
protecting its water. Maines legislation
allows dumping of graywater and black-
water only if ships have Alaska-certified
Advanced Wastewater Treatment Sys-
tems. After 2006, ships discharging must
have state discharge permits. Also, the
Board of Environmental Protections and
the Legislature are directed to approve
regulations in January 2005.
68
States That have Signed
Memoranda of
Understanding
Three states have attempted to control
cruise ship pollution by signing non-en-
forceable, voluntary, Memoranda of
Understanding (MOUs). These states
are Hawaii, Florida, and Washington.
Hawaii and Florida:
Hawaii and Florida signed MOUs with
their local cruise line associations in 2002
and 2001 respectively. Both agreements
basically accept the protections developed
by the International Council of Cruise
Lines (ICCL) in December 2001, which
Part 3: Legislation or MOU 21
include promises to minimize or elimi-
nate the discharge of several types of
waste, including silver and other photo-
processing chemicals, dry cleaning
wastes, printing and cleaning chemicals,
pharmaceuticals, mercury and fluorescent
light bulbs, and batteries; meet or ex-
ceed international standards for remov-
ing oil from wastewater; follow the
International Convention for the Preven-
tion of Pollution from Ships (MARPOL)
with respect to general garbage wastes
including glass, cardboard, and cans; dis-
charge graywater only when moving at 6
knots or more and more than 4 nautical
miles from shore; and to discharge black-
water only after processing by a certified
Marine Sanitation Device and when mov-
ing at 6 knots or more, and more than 4
nautical miles from shore.
The only substantive difference be-
tween the two MOUs is that the reach of
Floridas MOU is the states territorial
waters (out to 3 miles from shore), while
Hawaiis MOU allows ships with ad-
vanced wastewater treatment systems to
discharge a mile or further from shore,
and prevents ships without advanced
wastewater treatment systems from dis-
charging within four miles of shore.
69
Washington:
Washingtons MOU, signed in April
2004, attempts to emulate the strength
of Alaskas regulation, but without the
teeth of state law. Cruise ships discharg-
ing in Washington waters must be using
Alaska-certified Advanced Wastewater
Treatment Systems; they must be mov-
ing at least 6 knots at the time of dis-
charge, but if they use a more rigorous
treatment program including ultraviolet
light, they may be allowed to discharge
in port; sewage sludge may not be dis-
charged within 12 miles of any Washington
coast; sampling and reporting require-
ments require cruise lines to submit
monthly reports on self-administered
tests, and the Department of Ecology is al-
lowed to audit testing at any time.
70
Because the MOU does not include a
funding mechanism, the Department of
Ecology estimates that implementing the
agreement will cost taxpayers $44,767
from June 2004 to June 2005. The cruise
industry has agreed to take on the costs
of MOU implementation, but as of
the end of January 2005 this had not
happened.
71
Comparison of the Results
of Legislation and MOUs
The contrast between the effectiveness
of legislation and MOUs could not be
more clear than the different experiences
of Hawaii and Alaska. The first year it
was in effect, Hawaiis MOU was violated
16 times. Violations included mostly the
discharge of graywater and blackwater in
the protected fishing ground known as
Penguin Bank. Also cited were one in-
stance of incinerating waste while in port,
the discharge of almost 20,000 gallons of
galley waste and graywater in marine ar-
eas, and reporting errors.
72
Because the
cruise lines were subject to only a volun-
tary agreement, no fines or charges were
imposed.
Alaska, a state which saw 39 confirmed
air emissions violations in the period from
1999 to 2001, has seen only one viola-
tion between 2002 and 2003, and waste-
water discharge violations since 2001
have been nearly nonexistent.
73
Clearly
the Alaska Cruise Ship Initiative, passed
in 2001 and setting clear standards and
penalties for violation, was the key rea-
son for this dramatic improvement.
Though its MOU was only signed in
April 2004, Washington has already seen
cruise ships violate it three times. In one
instance, Holland America Lines
Zaandam discharged black and gray water
from an advanced wastewater treatment
system while at port in Port Angeles. It
violated the MOU because the Zaandam
had not submitted paperwork necessary
to be approved for discharge in port.
The Princess Lines M.S. Sapphire was
guilty of two violations by first discharg-
ing treated effluent throughout the 2004
season when it was not certified to do so;
and secondthe worst violation of the
yearby discharging untreated gray wa-
ter during its first voyage from Seattle to
Victoria. The untreated gray water con-
tained high fecal coliform, biochemical
oxygen demand, total suspended solids,
and low pH, all of which are damaging
to 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 need
for cruise lines to have a greater incentive
to meet clean environmental standards.
In addition to Washingtons little ex-
perience with its MOU, its experience
with two prior voluntary agreements
should be considered for how effective
the MOUas another voluntary agree-
mentwill be in the future.
One was the discharge of 16,000 gal-
lons of raw sewage into the Strait of Juan
de Fuca near Whidbey Island in 2003 by
the Norwegian Sun, after the cruise indus-
try had agreed to follow Alaskas standards
while in Washington waters.
75
In re-
sponse to the state of Washingtons cita-
tion, the cruise line claimed both that the
discharge was a mistake and that the state
didnt have jurisdiction over cruise ships
anyway. The second was the cruise
industrys disregard of 2002 and 2003
commitments to burn only low sulfur
fuels while in port at Seattle. In Septem-
ber 2003 the environmental groups Blue-
water Network and Ocean Advocates
discovered and revealed that ships at the
Port of Seattle were not and had never
used low sulfur fuels there.
76
Again, be-
cause the agreement was a voluntary one
between the Port of Seattle and the cruise
lines, no penalty was imposed on the
cruise lines.
In the first case, though they had
clearly broken a stated promise, Norwe-
gian Cruise Lines argued that the state
did not have the power to regulate cruise
ships. And in the second, the broken
promise to burn low sulfur fuels at the
Port of Seattle was only discovered when
cruise industry lobbyists claimed they did
not have the technology to burn low sul-
fur fuels, though they had already com-
mitted to burning low sulfur fuels in
Seattle. The cruise industrys broken
promises and ambivalence toward envi-
ronmental protection will continue as
long as Washington relies on voluntary
agreements to safeguard its marine waters
health.
A cruise ship at dock in Hawaii.
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Conclusions and Recommendations 23
Factors demonstrating the
importance of legislation
I
n addition to the quantifiably differ-
ent experiences of states that have en-
acted laws and states that have signed
MOUs, there are several factors that
show Washington should pass legislation.
First, Washington is in a geographic po-
sition where strict laws make sense. Both
Alaska and California have passed legis-
lation to protect state waters and punish
polluters. Ships traveling from Alaska and
California are already equipped to meet
high environmental standards. There is
no reason for Washingtons waters to be
the dumping ground for west coast cruise
ships.
Second, as described in Part 2, Wash-
ingtons marine resources deserve the
highest standard of protection because of
their high aesthetic and economic value,
and because they are already seriously
threatened by pollution. Legislation pro-
vides both a powerful incentive for envi-
ronmental responsibility as well as the
opportunity for the state to recover the
costs 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 costs
of monitoring and recovery to taxpayers.
The Department of Ecology estimated
it will cost Washington State $44,767 to
implement the MOU from June 2004 to
June 2005. While the cruise lines have
agreed to take on the cost of implemen-
tation, that arrangement has not been
completed.
77
Thus citizens of Washington
have so far paid for both the regulation
and the violationsof an industry that takes
home tens of millions of dollars in profits.
Fourth, there is the question of trust.
As Ross Klein has pointed out, MOUs are
an expression of trust. Given the cruise
industrys record of breaking verbal and
written agreements, betting Washingtons
marine resources on the trustworthiness
of cruise lines is a very risky proposition.
The most concerning violation of trust
in Washington to date was the Norwe-
gian Cruise Lines response to the state,
after dumping 16,000 gallons of sewage
in the Strait of Juan de Fuca, that only a
promise, not a law, had been broken.
78
Taking up voluntary protections with an
industry with this attitude is unwise.
Conclusions and
Recommendations
Last, cruise lines regularly insist that
their ships meet the standards of proposed
law, even while resisting regulation. If
their ships meet proposed standards al-
ready, then cruise lines should accept leg-
islation. In fact, lines whose ships meet
standards of proposed law should support
that legislation because they stand to gain
a competitive advantage over lines that
need to upgrade their ships.
Recommendations
To protect Washingtons marine environ-
ment, legislation regulating cruise ship
discharges should include:
1. A ban on the discharges of blackwater,
graywater, oily bilge water, ballast
water, and hazardous wastes in state
waters.
2. Clear penalties for violating regula-
tions. Penalties should provide an
economic deterrent to violation
and cover the damage to state
ecosystems.
3. A per-passenger fee system to pay
for a state monitoring program. A
graduated fee scale could provide
economic incentives for cruise lines
to be environmentally responsible.
An average fee of $1-2 per passenger
would pay the major part of the
expenses of cruise ship monitoring.
Conclusion
Perhaps the futility of pursuing voluntary
action as a means of protecting public
resources is summed up best by Larry
Lau, Hawaiis state deputy director for
environmental health. In response to the
many violations of Hawaiis MOU by the
cruise industry, Lau told the Honolulu
Advertiser that the MOU beats noth-
ing Im trying to do the best with what
we have.
79
In Washington, an MOU is
the best we have only because we have
not demanded better protection for our
coasts. The protection of Washingtons
incredible marine waters are in the hands
of our state Representatives, Senators,
and Governor, and they need to make
sure that Washingtons resources are bet-
ter protected.
Washingtons marine waters are too
precious to the state, its citizens, and its
economyand already far too endan-
geredto accept anything less than
strong, specific, and enforceable stan-
dards for what cruise ships may leave here.
References 25
1. Klein, Ross. Cruise Ship Blues: The Underside of
the Cruise Industry. New Society Publishers:
Gabriola Island, Canada, 2002. p. 2.
2. Ibid. p.121.
3. U.S. General Accounting Office. Marine
Pollution: Progress Made to Reduce Marine
Pollution by Cruise Ships, but Important Issues
Remain. 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 on
How Cruise Ships Affect the Marine Environ-
ment. The Ocean Conservancy, May 2002. p. 14.
5. Bluewater Network. Trust Us is not an
effective environmental policy. Factsheet, 2004.
6. Klein, Ross. Cruisejunkie.com http://
www.cruisejunkie.com Viewed November 11,
2004.
7. Herz, Michael. Cruise Control: A Report on
How 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 viewed
Dec. 3, 2004.
9. EnviroTools.org factsheet (adapted from U.S.
EPA) http://www.envirotools.org/factsheets/
contaminants/Perchloroethylene.shtml#effect
viewed Dec. 3, 2004.
10. Herz, Michael. Cruise Control: A Report
on How Cruise Ships Affect the Marine
Environment. The Ocean Conservancy, May
2002. pp. 13-15.
11. Seattle Post-Intelligencer Staff. Cruise
ships to plug in to reduce pollution. Oct. 1,
2004.
12. U.S. Commission on Ocean Policy. Pre-
liminary Report of the U.S. Commission on
Ocean Policy. April 2004. p. 10.
13. Puget Sound Action Team. 2005-2007 Puget
Sound Conservation and Recovery Plan. 2004. p. 17.
15. Puget Sound Action Team. Treasure of the
Tidelands (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 of
Harvest (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 to
the 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.
www.cruisejunkie.com Viewed November 11, 2004.
20. Klein, Ross. The Cruise Industry and
Environmental History and Practice: Is a
Memorandum of Understanding Effective for
Protecting the Environment? October, 2003.
pp. 7.
21. Pemberton, Mary. Cruise ship company
admits dumping sewage. Seattle P-I, Dec. 8, 2004.
22. Klein, Ross. Cruise Ship Blues: The Underside
of the Cruise Industry. New Society Publishers:
23. Ibid. p. 121.
pp. 3-4.
Protecting the Environment? October, 2003. p. 13.
28. Dragon, Debbie. History of Cruise Ships.
http://www.traveljobz.com/cruise-ship-jobs/
cruise-overview.asp Viewed November 11, 2004.
30. Ibid. p. 5.
31. EPA Silver Nitrate Factsheet <http://
ents/factsheets/factsheet_072503.htm > viewed
Dec. 3, 2004.
32. EnviroTools.org factsheet (adapted from
U.S. EPA) <http://www.envirotools.org/
factsheets/contaminants/
Perchloroethylene.shtml#effect> viewed Dec. 3,
2004.
2002. pp. 13-15.
34. Ibid. p. 14.
35. Seattle Post-Intelligencer Staff. Cruise ships
to plug in to reduce pollution. Oct. 1, 2004.
37. U.S. General Accounting Office. Marine
Pollution: Progress Made to Reduce Marine
Pollution by Cruise Ships, but Important Issues
Remain. Report to Congressional Requesters,
February 2000. http://www.gao.gov/new.items/
rc00048.pdf Viewed Dec. 17, 2004.
www.cruisejunkie.com Viewed November 11, 2004.
pp. 3-4.
40. Ibid, p. 5.
2002. p. 14.
43. Shore, Teri, Bluewater Network. Conversa-
tion with, September 24, 2004.
44. Pew Oceans Commission. Americas Living
Oceans: Charting a Course for Sea Change.
April 2003.
Ocean Policy. April 2004.
46. Mapes, Lynda M. Vashon Island returns to
normal following oil spill. Seattle Times.
November 8, 2004.
47. Cunard website http://www.cunard.com/
OnBoard/default.asp?OB=QE2&sub=sp viewed
Dec. 3, 2004.
48. Cohen, Gershon. Factsheet titled Cruise
Ship Facts. Campaign to Safeguard Americas
Waters (C-SAW).
2002. pp. 13-15.
References 27
51. Ibid.
52. Puget Sound Action Team. 2005-2007 Puget
Sound 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. Americas Living
Oceans: Charting a Course for Sea Change.
April 2003. p. 59.
55. EPA Silver Nitrate Factsheet http://
ents/factsheets/factsheet_072503.htm viewed
Dec. 3, 2004.
56. EnviroTools.org factsheet (adapted from
U.S. EPA) http://www.envirotools.org/
factsheets/contaminants
Perchloroethylene.shtml#effect viewed Dec. 3,
2004.
57. Puget Sound Action Team. Treasure of the
Tidelands (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 of
Harvest (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 to
the Northwest Sportfishing Association,
October 25, 2003. http://wdfw.wa.gov/depinfo/
director/oct2503.htm viewed Dec. 3, 2004.
60. Shore, Teri, Bluewater Network. Cruise
Ship Memorandum of Understanding as
Compared to the state law of Alaska. Informa-
tional memo, 2003.
61. Shore, Teri, Bluewater Network. Personal
correspondence, December 7, 2004.
62. Alaska House of Representatives Bill No.
260 in the 22nd Legislature (2001), signed into
law July 20, 2001.
64. Cohen, Gershon. Campaign to Safeguard
Americas Waters Earth Island Journal,
Summer 2003. http://www.earthisland.org/
eijournal/new_articles.cfm?articleID=696&journalID=68
Viewed Dec. 17, 2004.
66. Bluewater Network Press Release. Cruise
Ship Dumping and Trash Burning Banned In
California. Sept. 24, 2004. http://bluewater-
network.org/press_releases pr2004sep24_cv_dumpingbills.pdf
Viewed on Nov. 14, 2004.
67. California State Law, Chapter 764, Section
72430. Passed as bill AB 2672, filed Sept. 24, 2004.
68. Shore, Teri, Bluewater Network. Summary
of Current and Pending Cruise Ship Laws and
Legislation in the U.S. November 2004.
70. Shore, Teri, Bluewater Network. Summary
of Current and Pending Cruise Ship Laws and
Legislation in the U.S. November 2004.
tal Effects In Washington; Appendix C:
Annual Cruise Meeting Notes. Prepared by
Amy Jankowiak. January 24, 2005.
www.cruisejunkie.com/Hawaii_mou.html
Viewed November 11, 2004.
Protecting the Environment? October, 2003. p.
11-12.
79. Yamanouchi, Kelly. Cruise Lines Admit
Pollution Violations. Honolulu Advertiser,
December 12, 2003.
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