Déjà Vu All Over Again: Environmentalists Petition for Unprecedented Expansion of Requirements for Vessel Sewage Discharges
Written by Barry M. Hartman (Washington, D.C.), Susan B. Geiger (Washington, D.C.), Christopher R. Tate (Washington, D.C.)
An environmental group is petitioning the U.S. Environmental Protection Agency ("EPA") to completely revamp the regulation of sewage discharges by strengthening and changing treatment requirements and imposing new, expansive recordkeeping requirements for marine sanitation devices ("MSDs") at a cost for cruise ships that is estimated to approach $10 million. MSDs used on everything from container ships to car carriers to tug boats to offshore vessels to large private yachts — anything that is over 65 feet in length — could be affected by the proposed changes.
This petition represents only the most recent effort by citizen groups to expand the regulation of vessels under federal environmental laws. This alert describes what this petition seeks, how it will be handled, and what the maritime industry might consider doing to effectively participate in this process.
