Maritime Environmental Regulations & the Challenges of Compliance

Regulation Hierarchy International United Nations- IMO UNCLOS, MARPOL, SOLAS Area/Regional Specific HELCOM EU Directives National /Port State Clean Water Act US NPDES Vessel General Permit State/Provincial VGP – 401 Certifications Other State Requirements Provincial Requirements Port Specific Destination Stewardship is at the core of our work. For us it means….

MARPOL and SOLAS Overseen by the International Maritime Organization (IMO) -Specialized agency of the United Nations with 169 Member States and three Associate Members. - Primary purpose is to develop and maintain a comprehensive regulatory framework for shipping and today that includes: safety, environmental concerns, legal matters, technical co-operation, maritime security and the efficiency of shipping. MARPOL - is the International Convention for the Prevention of Pollution From Ships established in Feb. 1973. Contains 6 annexes, concerned with preventing different forms of marine pollution from ships: Annex I - Oil Annex II - Noxious Liquid Substances carried in Bulk Annex III - Harmful Substances carried in Packaged Form Annex IV - Sewage Annex V - Garbage Annex VI - Air Pollution 2009 - Hosted a Destination Stewardship think tank on-board Oasis of the Seas inaugural cruise 2009 - Sponsor establishment of the Global Sustainable Tourism Council’s Destination Stewardship Working Group 2010 - Launch the Sustainable Shore Excursions Program 2011 - Bahamas and Haiti Private Destinations achieve bronze-level Sustainable Tourism Education Program (STEP) eco-certification for attractions and tour operations 2012 - Private island destination in the Bahamas is awarded Gold-level STEP sustainability certification 2012 - Sponsor the creation of the GSTC Global Sustainable Tourism Criteria for Destinations 2013 - Support sustainable destination management diagnostic and action agenda in Cozumel, Mexico 2013 - Private island destination in Haiti is awarded Gold-level STEP sustainability certification 2013 - Support sustainable destination management diagnostic and action agenda in Roatan, Honduras 2013 - Support creation of a destination monitoring tool designed help destinations to track trends and changes occurring over time Generally does not pertain to cruise vessels

MARPOL / Regional Agreements - Emission Control Areas – The North America (NA) ECA which generally covers within 200nm of the NA coast (Canada and USA) requires the use of 0.1% sulfur fuel. As of January 1, 2016 all new vessels will also be required to meet Tier 3 NOx levels.

World Emission Control Areas

US Requirements - Vessel General Permit & Clean Water Act Vessel General Permit – covers 27 operational discharges examples are Deck washing – must use specific NPDES soaps and cleaners Gray Water - Prohibited to discharge GW within 3nm Sewage and GW mix – to discharge <3nm must meet the requirements of section 5.1 of the VGP: Using end of pipe monitoring must be treated using an AWP prior to discharge. Sewage – to discharge <3nm and within US waters (12nm) must meet 40 CFR 140 or 33 CFR 159 requirements. Ballast water – must install and operate a USCG Approved BWMS, differs from the IMO Type Approved systems. Ballast Water – National Invasive Species Act 1996 Requires the installation and operation of a USCG Approved BWMS, differs from the IMO Type Approved systems. Allows for extension of the installation requirement until an approved system is identified.

Provincial / State Specific Oil Spill Response – Must identify and contract with an Oil Spill Response Organization (OSRO) for all ships sailing in Canadian or US waters: Canada – Eastern Canada Response Corporation US – NRC or MSRC State specific discharge requirements – Example of some requirements are: Connecticut - prohibits the discharge of GW, Bilge water or Exhaust Gas Cleaning water regardless of treatment. Maine & New York - requires exchange and treatment of ballast water. New York – prohibits the discharge of Bilge water regardless of treatment.

ABOVE AND BEYOND COMPLIANCE MARPOL Regulations vs RCL Policy Waste MARPOL RCL Policy Treated Sewage 3nm 12 nm, & >6kts Gray water No min. 12 nm, & >6kts Bilge Water 15 PPM 5 PPM, & >12nm Food Waste 3 nm 12 nm, & >6kts

Regulatory Impacts Overview of a single ships regulatory requirements: Sailing from Boston calling on Portland, ME; Bar Harbor, ME; St. John, New Brunswick and Halifax Nova Scotia a ship must abide with the following regulations: Emissions NA ECA – 0.1% fuel within approximately 200nm Shorepower – available in Halifax beginning in 2015 Discharges – VGP – Deck cleaning, Sewage, Gray water, Ballast water, Bilge water, Scrubber wash water, etc. Canadian - Sewage, Ballast water, Bilge water, scrubber wash water, etc. Port Specific – prohibitions (ie. Bilge, scrubber wash water, GW) Oil Spill Response – Canadian and US requirements for OSRO’s Garbage – Waste classification requirements (Hazardous vs Nonhazardous) Example of this is incinerator ash is defined in Canada as regulated waste, in the US is deemed non-regulated waste.

How RCL manages this monumental task By using an integrated living database call ESIMS (Environmental Stewardship Information Management System). It allows our vessels to input their itinerary and receive all the relevant Env. Regulations for that itinerary.

How RCL manages this monumental task

Environmental Binders Australia & New Zealand Baltic & Northern Europe Eastern - North America Mediterranean Western - North America South America & Caribbean Hawaii & Polynesia (Micronesia & Melanesia) Antarctica China and Southeastern Asia