Comment from Whitney Stohr

Section 1441(b)(3) of the National Marine Sanctuaries Act charges the agency with the responsibility to “maintain the natural biological communities in the national marine sanctuaries.” Agency studies and publicly-disclosed information suggests that the discharge of sewage and graywater from cruise ships has the potential to cause serious and irreparable injury to the ecosystem of the Olympic Coast Sanctuary. To permit such discharge frustrates the purpose of the Act, thus making it necessary to prohibit this activity. The benefits of prohibiting the discharge of wastewater clearly outweigh any burden imposed on the regulated public. In addition to enhancing water quality, the proposed regulation will result in greater protection of the Sanctuary’s unique ecosystem. It will provide further protection for the native tribes with fishing rights in the Olympic Coast area, and ensure the continued growth of their traditional way of life. Furthermore, as the information available in the Docket suggests, the proposed regulation will follow in the path of prior regulatory changes prohibiting wastewater discharge in other West Coast sanctuaries. In further support of this regulation, the owners and operators of cruise ships will not suffer substantial injury by this promulgation. Many cruise ships are already equipped with storage tanks large enough to hold their sewage and graywater during the time in which they pass through the Sanctuary. Additionally, the cost imposed upon the unequipped regulated parties will be minimal compared to the potential environmental damages caused by their continued unregulated discharge. In this context, any cost suffered by those regulated cannot outweigh the benefits of the proposed regulation. The rule prohibiting cruise ships from discharging their wastewater into the Olympic Coast Sanctuary should thus be promulgated.