ENVIRONMENTAL COMPLIANCE Compliance is Cheaper!! Assistant Commandant for Prevention Policy U.S. COAST GUARD

View of starboard ballast tank of a foreign vessel in U.S. waters with visible oil discharge A Coast Guard Sector received an anonymous report of a foreign- flagged vessel allegedly discharging oil illegally. Further investigation by the Port State Control Team revealed oil being discharged through the starboard side ballast water overboard discharge piping.

Improper use of installed spool piece The spool piece is depicted in the vessel operations manual and drawings. However, it is intended to be used ONLY for emergency dewatering. BALLAST WATER PIPE SPOOL PIECE BILGE WATER PIPE

Emerging Trend of Illegal Oil Discharge: Pumping Through Ballast Water Tank Vent

USCG Use of Satellite and AIS Technology

Improved Monitoring Equipment: Resolution MEPC 107 (49) The purpose of these guidelines and specifications is to assist Administrations in determining appropriate design, construction, and operational parameters for pollution prevention equipment utilizing a more refined and technological sound methodology. This resolution and its equipment provide a means to track vessel discharges and compare them with Oil Record Books. The Oil Content Meter fitted with this resolution is more sensitive in design and provides enhanced filtering capabilities not found in the MEPC 60 (33).

A new field guide has been created by the USCG to assist personnel conducting expanded MARPOL Investigations to determine compliance with U.S. regulations. It has been tested during field training sessions with CGIS special agents and will be finalized by the end of CY14. Improving Investigator Training & Guidance

Falsified Log Entries Remain Primary Criminal Enforcement Tool

How the U.S. Uses Surety Bonds Surety Bonds are financial guarantees furnished as evidence of financial responsibility under The Oil Pollution Act of 1990 and The Comprehensive Environmental Response, Compensation, And Liability Act. Average time for processing may take between four to five days during which time the vessel is not allowed to leave the port. The surety bond is dependant upon the maximum of violations under the Act to Prevent Pollution From Ships (APPS). On average, the USCG secures Surety Bonds between $350K to $500K (US) per APPS violation.

Environmental Compliance Referrals

Results of USCG Criminal Enforcement Criminal Fines More than 140 companies and individuals prosecuted Over $300 million (US) in criminal fines /38 years of jail time Environmental Compliance Plans (ECP) Over 1400 vessels have court imposed ECP’s overseen by the Coast Guard ECPs consists of third-party audits and added tech requirements. Debarment from US trade Option only reserved for egregious repeat offenders Extremely Rare - A company may select debarment in lieu of implementing ECP Coast Guard Goal: To change corporate culture through creation and implementation of an effective Environmental Management System

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