The Alaska Department of Environmental Conservation is accepting public comment on the 2010 Large Commercial Passenger Vessel Wastewater Discharge General Permit until today. At a recent public hearing, I advocated for "common sense regulation" in consideration of this permit. In my opinion, common sense regulation should:
1. Define the specific issues of environmental concern. There are currently no known observable or measurable environmental impairments resulting from cruise ship discharge in Alaska waters in the past several years.
2. Qualify the technology necessary to meet proposed regulations. DEC is not currently aware of treatment systems that are readily available that would allow effluent to meet 2010 proposed standards.
3. Consider the implications of standards that are not achievable. If proposed 2010 regulations are adopted, companies may not apply for a permit that they cannot technologically adhere to. Ships may alter schedules and port times to allow for discharge beyond the three mile limit, which could result in less port time, and consequently fewer economic opportunities for local businesses.
4. Encourage compliance with Alaska's high environmental standards. Any vessel discharging beyond Alaska's three-mile limit is subject to less regulation than exists at this time.
5. Allow for technology development to catch-up with regulation. Existing DEC regulations allow a wastewater discharge permittee to apply for a mixing zone component in their wastewater discharge permit. All cruise ships could meet the standards of this permit, as they are similar to those of 2009. To receive this discharge permit, effluent must first be treated to remove, reduce, and disperse of pollutants using the most effective, technologically and economically feasible methods.
6. Account for the time constraints regarding the proposed 2010 permit. The Alaska cruise season will begin in approximately 60 days. If this permit is adopted unchanged, it will be impossible for many cruise ships to comply.
In conclusion, I believe that DEC should amend the 2010 Large Commercial Passenger Vessel Wastewater Discharge General Permit to allow continued science-based mixing zone dilution.
Alaska has led the world in advancement of cruise ship clean water regulation, and we should continue to work with industry to identify even more technologically advanced and economically feasible treatment alternatives.
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