Alan Mearns

The proposed new definition of marine debris still is unclear to me. I am particularly concerned about tar balls and other "organic" material that may be introduced to the ocean via man's activity whether or not a reponsible party can be identified. I am also concerned that during the process of surveying or monitoring marine debris some items may be ignored and yet they have relevance. Two cases come to mind. 1) Thousands of tons of soy beans were spilled onto Aleutian Alaska shorelines following the Selendang incident. The volume of the soy bean spill was much greater than the fuel oil itself. Yet there was no regulation that required clean up and removal of the soy beans or even any understanding of the extent to which they impacted marine and wildlife. The windrows of rotting beans were left alone while the oil ws being surveyed and cleaned. If it wassoy bean OIL it would have been responded to. If nothing else, studies should have been done to document the presence and fate of the soy beans piles and their effects on marine life. We should have some requirement that we learn something from events that do not fall neatly into an agency mandate. In terms of "definition" I submit that this cargo was indeed "persistent solid material that is (was) manufactured or processed and directly or indirectly, intentionally or unintentionally, disposed of or abandoned into the marine environment or the Great Lakes". Unless we need to further define "persistent". 2) Tar balls. Nearly the same argument as above. Yes, there are natural tarballs on beaches and "background" is not zero. But that is not known a priori. They could have reuslted from heavy fuel spills with no known RP. They can be the result of a manufaactured or processed activity. But more importantly, we need good data onbackground concentrations regardless of the source. Tarballs should be counted during debris surveys and reported as a class of material and its densities. That information would give us a better idea of what background is in various areas of the US and provide guidance on how clean is clean during a known oil spill response. Clearly both types of "organic" items also challenge another definition: solid. If the NOAA MD Program or other spill legislation or mandates cannot address these types of pollutants, who can?