ASOD= MSD American Samoa. GUAMS=MSO Guam (probably includes Saipan/CNMI)
HONMS= MSO Hononulu, Hawaii. SJPMS=MSO San Juan, Puerto Rico. STTD=MSD St. Thomas, USVI
(Source: U.S. Coast Guard, Office of Vessel Traffic Management)
Agencies have taken a number of steps to address threats to coral reefs from direct vessel impacts. These efforts include management plans, installation of navigational aids, educational outreach, and enforcement. Some specific activities are described below.
In 1992, with the designation of the Flower Garden Banks National Marine Sanctuary, vessels larger than 100 feet in length were prohibited from anchoring on the banks. Vessels less than 100 feet in length were required to use mooring buoys, if available. If none were available, such vessels could anchor, but could not damage sanctuary resources and were required to use ground tackle with no more than 15 feet of chain or wire rope, a practice that would limit resource destruction by the ground tackle itself. The regulations further required that the anchor line be of soft fiber such as nylon or polypropylene or some similar material.
Agencies have a number of statutory authorities to address vessel damages to coral reefs. More robust authorities are found within protected areas, such as the National Marine Sanctuaries and the National Parks. Other authorities are available if a ship grounding includes oil pollution or hazardous waste discharges or the threat of these. A brief sampling of some legislative authorities include:
Prohibits operation of tank vessels or large vessels within the "Area to be Avoided."
National Wildife Refuge Improvement Act of 1997, 16 U.S.C. 3101 et seq.
Primary Impediments to Addressing Threats from Vessel Impacts
Knowledge Gaps. In order for agencies to more effectively address vessel-related impacts, it is necessary to know where "hot spots" of vessel activities and vessel-related damages occur, which will allow agencies to examine the main causes of vessel-related damages specific areas.
Navigator Inexperience/ Error. Many of the causes of vessel-related damages to coral reefs stem from navigator error or inexperience, particularly among recreational vessel users. These errors may include, among other things, misuse of electronic navigational equipment, misreading navigational aids and charts, not having charts, and not knowing how to respond once a ship has been grounded (sometimes much more damage is caused by boats trying to power off a coral reef or seagrass bed). Education and public outreach is a critical component to addressing navigator inexperience and error. Because coral damaged by a grounding can take decades to recover, the prevention of groundings and other vessel-related damage is of utmost importance.
Need for More/ Better Navigational Aids. Better navigational aids (such as charts delineating coral reefs, marine protected areas or buoys marking restricted areas) would be useful to help vessels avoid coral reef areas. This would also include better delineation on international charts. Installing and maintaining permanent anchoring buoys in areas of high recreational use can avoid anchor damage. Another technology that could potentially improve navigating in and round coral environments is electronic charts and Global Positioning System (GPS) aided navigational software. Through this technology, vessels could be alerted when they enter high hazard areas such as shallow coral environments. Automatic Identification System (AIS) marine transponders which are currently under development, will permit cost effective monitoring of high(er) threat commercial shipping in areas such as the Florida Straits. While it is unknown what effect this emerging technology will have in improving navigation and the ability to monitor shipping around coral reefs, inroads for protection should be fully exploited.
Lack of Resources. Resources are needed across the board (to fill in knowledge gaps, to improve navigational aids and public education, and to enforce existing laws). Federal and local on-water law enforcement personnel are extremely scarce in the Pacific territories. Funds are necessary to allow trustees to do restoration activities without having to wait for years and a judicial ruling or collection. Existing resources should be better leveraged (for example, NOAA’s revolving fund used for response costs should be maintained in interest bearing accounts). Additional funding for periodic surveys of coral reef habitats would allow the Parks and Marine Sanctuaries to assess, if not repair, the damages caused by unreported groundings.
Need for Standard Response to Vessel Groundings. Quick agency responses are necessary where groundings or other damages occur to avoid future degradation of damaged reefs. A number of agencies have response protocols, but there is a need to share information among the agencies and to develop a consistent approach to response, assessment, and collection of evidence for consistent and high quality enforcement actions.
Abandoned ships in U.S. territorial waters can impact coral reef resources. Where a ship grounds on coral reefs and the wreckage is not removed, damage to coral reefs continue and reef recovery may be slowed. U.S. Fish and Wildlife Service in Hawaii has documented the long-term effects of one vessel grounding where parts of the vessel were not removed. (Green et al. 1997). In October 1993, a Taiwanese longliner Jin Shiang Fa ran aground at Rose Atoll National Wildlife Refuge, spilling 100,000 gallons of diesel fuel and other contaminants onto the reef. The vessel grounding gouged large grooves in the atoll and reduced parts of the reef into rubble; killed many invertebrates such as reef-boring sea urchins, giant clams and corals; killed the dominant algal species (crustose coralline algae) causing a bloom of opportunistic algal species; and changed the distribution of herbivorous fishes and sea urchins. Salvage operations removed most of the larger pieces of wreckage and debris, but the salvage crew did not move the stern and its associated debris, or the engine block.
Three years after the event, the reef show only limited recovery. Of most concern, the opportunistic algal species continue to dominate the wreck site, and the crustose coralline algae, which are primarily responsible for maintaining the structure of the atoll, show little sign of recovery. Preliminary studies show that iron corroding from the wreckage may be contributing to the maintenance of the algae bloom. (Green et al. 1997). Similarly, a longliner vessel ran aground on the Kure Atoll in Hawaii, in October 1998. While the vessel insurer was able to pay for some salvage, the boat remains grounded on the reef. It has been estimated that removing the Paradise Queen II from the Kure Atoll would cost $1.5 million.
Current Activities and Abilities to Address Abandoned Ships
If an abandoned ship is a hazard to navigation, the Army Corps of Engineers is responsible for mitigating the hazard and can seek reimbursement from the ship’s owners (sometimes the response is to mark the hazard and leave it). Unfortunately, most coral reefs and seagrass beds are in shallow areas. As a result, vessels that remain aground on coral reefs or seagrass beds are unlikely to be considered hazards to navigation, and the Corps of Engineers is therefore unlikely to conclude that it has authority to remove the vessel. If a ship poses a threat of oil pollution or hazardous waste discharge, the U.S. Coast Guard has authority to remove or address the threat. As the recent grounding of the longliner on Kure Atoll demonstrates, the Coast Guard’s response to the threatened or actual discharge of oil does not necessarily include removal of the vessel from the coral reef or seagrass bed.
Primary Impediments to Addressing Abandoned Ships
Lack of Resources. The primary impediment to removing abandoned ships that affect coral reefs is that such removal can be extremely costly. Many of the known abandoned ships are in remote areas of the Pacific where it would be difficult and expensive to salvage ships. The Rose Atoll, for instance, is situated more than 150 km from the nearest island, Ta’u in the Manu’a Islands, and 270 km east of the main island of Tutuila. To provide a sense of the costs of salvaging vessels, one private salvage company generally charges $25,000 per day for salvage.
Marine pollution stems from a variety of sources, including discharges of oil from vessels, ocean dumping of wastes, and discharge of sewage and wastes from land-based sources. Other vessel-based sources of pollution include the introduction of alien species into coral reef and seagrass habitats by vessels (i.e., through dumping of bilge contents) and fishing gear debris. Biologists at Biscayne National Park have noted that abandoned or lost lobster traps can cause substantial damage to coral reef communities as they are moved around by ocean currents. The Air and Water Working Group of the Coral Reef Task Force is addressing land-based sources of pollution as well as vessel-based pollution. The Destructive Fishing Practices Subgroup of the Coastal Uses Work Group is addressing the problem of fishing gear debris. Therefore, this section will be brief.
Current Activities and Abilities to Address Pollution Threats from Vessels
Statutory Authorities. A number of international and domestic regimes address marine pollution. The primary international agreement for prevention and control of marine pollution is the 1973 International Convention for the Prevention of Pollution from Ships, Nov. 2, 1973, S. Exec. Doc. E, 95th Cong., 1st Sees. 1 (1979), 12 I.L.M. 1319, as modified by the 1978 Protocol, Feb. 17, 1978, S. Exec. Doc. C, 96th Cong., 1st Sess. 1 (1979), 17 I.L.M. 546 (MARPOL 73/78). The United States has implemented MARPOL Annex V, which addresses shipboard solid waste discharge at sea, through the Act to Prevent Pollution from Ships, 33 U.S.C. 1901 et seq. This act requires U.S. public vessels, including warships, to comply with Annex V requirements by established deadlines. It also provides for criminal penalties for dumping different types of garbage and other discharges from vessel operations (i.e: not garbage transported from shore) within certain set distances from land. This applies to all waters as well as to all vessels over which the U.S. has jurisdiction.
The primary international agreement dealing with marine disposal of wastes is the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter (London Convention), Dec. 29, 1972, 26 U.S.T. 2406, 1046 U.N.T.S. 120. Countries ratifying the London Convention have agreed to prohibit the dumping of certain wastes (listed Annex I), including mercury, cadmium, organohalogens, oil, persistent plastics, and high-level radioactive wastes. Special permits are required for ocean disposal of other wastes (listed in Annex II), such as arsenic, copper, lead, cyanides, pesticides, scrap metal, and low-level radioactive wastes. All other substances require a general permit for ocean disposal. The United States implements the London Convention through the Ocean Dumping Act, 33 U.S.C. 1411 et seq., which prohibits U.S. flag ships or citizens from departing from the U.S. to dump anything into ocean without a permit (or dumping in U.S. territorial sea when transported from outside U.S. (12 nautical miles)). This Act provides for civil penalties of $ 50,000 per violation ($125,000 for medical waste), 33 U.S.C. 1415(a); criminal penalties (up to 5 years imprisonment), 33 U.S.C. 1415(b); and injunctive relief, 33 U.S.C. 1415 (d).
Domestic oil pollution is addressed through the Section 311 of the Clean Water Act, 33 U.S.C. 1321, and the 1990 Oil Pollution Act, 33 U.S.C. 2701-2761. Section 311 of the Clean Water Act prohibits oil or hazardous substance discharges in navigable waters of the United States in quantities which "may be harmful to the public health and welfare or environment of the United States." 33 U.S.C. 1321(b)(3)-(4). Both civil and criminal enforcement and penalties are available to enforce Section 312, and civil enforcement is available to abate actual or threatened discharges. 33 U.S.C. 1321(e)(1). The Oil Pollution Act of 1990 provides for strict liability of responsible parties for clean up costs and natural resource damages from discharges of oil.
Enforcement Actions. The Department of Justice has brought civil and criminal enforcement actions against polluting vessels. In one criminal prosecution, the United States secured from the violator a commitment to fund coral reef projects. In U.S. v. Royal Caribbean Cruises, Ltd.. (D.P.R.) (S.D.Fla.), the Department took action against cruise ship discharges of oily bilge water that threatened water quality in U.S. waters and in the Caribbean. The United States obtained $ 9 million in penalties, $ 1 million of which was suspended to fund coral reef projects in the territorial seas of Puerto Rico and South Florida.
PROPOSED ACTIONS AND STRATEGIES TO ADDRESS KEY THREATS
Monitoring. Agencies propose to identify "hot spots," or areas of high recreational or commercial traffic and use and high risk of damage to coral reefs, and evaluate best management practices to address the risks. Solutions may include installation of permanent mooring buoys, modification of existing charts and navigational aids, education and outreach, enforcement, or other measures. Determination of the grounding "hot spots" will enable NOAA and the Coast Guard to assess whether it is appropriate to change the existing navigational aids and charts.
Mapping. NOAA’s National Ocean Service (NOS) proposes to prepare a prototype of an improved navigational chart that consists of a conventional chart, overlaid with boundaries noting important jurisdictional areas (such as marine sanctuaries or national parks), along with environmental data showing the location of coral reefs. Additional notes on the chart could warn the reader of potential fines and sanctions for violating marine sanctuary or other rules. The purpose of this chart would be to alert vessels in a user-friendly way of the existence of protected areas and help them avoid coral reefs. A potential drawback to this approach is the increased use of, and resulting stress to, the coral reef resources as recreational boaters are better equipped to find and take advantage of the resources. NOAA’s NOS also will work with the International Hydrographic Organization and the British Admiralty to explore ways to improve international navigational charts
Public Education. Agencies propose to work with NGOs to help develop an educational and outreach campaign aimed at protecting coral reefs from a range of vessel-related impacts (vessel groundings, anchor damage, vessel pollution, and diver activity).
Targeted Education. Agencies also will explore possibilities to collaborate with the boating insurance industry to have them distribute educational materials relating to vessel groundings and tips on how to avoid further damage.
Enforcement. Prosecution of civil damage claims can send a message to the maritime industry that natural resource damage claims will be pursued. Hopefully, this will encourage commercial operators to use utmost caution when navigating in the vicinity of marine resources. Agencies propose to work to develop an enforcement protocol for vessel grounding incidents to standardize responses, damage assessments, and other elements of building an enforcement case. The Department of Justice may host a 1-2 day workshop for managers of coral reef resources and other agencies with regulatory and enforcement jurisdiction to develop this protocol.
1- Birkeland, C. 1997. Life and death of coral reefs. New York. Chapman and Hall. 536 pp.
2- Jameson, S.C., J.W. McManus, and M.D. Spalding. 1995. State of the reefs: Regional and global perspectives: International coral reef initiative, executive secretariat background paper. Washington, DC.
3- Adams, C. 1992. Economic activities associated with the commercial fishing industry in Monroe County, Florida. Staff paper SP92-27. Gainesville, FL: University of Florida, Food and Resource Economics Department, Institute of Food and Agricultural Sciences. 20 pp
4- Grigg, R.W. 1997. Hawaii's coral reefs: Status and health in 1997, the International Year of the Reef. pp. 61-72. In: Grigg, R.W. and C. Birkeland (eds.), Status of coral reefs in the Pacific. University of Hawaii Sea Grant NA36RG0507. Washington, DC: NOAA, Office of Sea Grant. 144 pp.
5- Bryant, D., L. Burke, J. McManus, and M. Spaulding 1998, Reefs at Risk: A Map-Based Indicator of Threats to the World’s Coral Reefs. World Resources Institute Report. 56 pp.
6- Hughes, T.P. 1994. Catastrophes, phase shifts, and large-scale degradation of a Caribbean coral reef. Science 265:1547-1551.
7- Reef Check ‘ 97. Summary of Results.
8- Van Der Knaap, M. 1993. Physical damage to corals by trap-fishing on reefs in Bonaire, Netherlands Antilles. Env. Conservation 20:265-267.
9- Maragos 1992.
Coastal Development and Shoreline Modification
Blair, Stephen M., Brian S. Flynn, Susan Markley, 1990. Characteristics and Assessment of Dredge Related Mechanical Impact to Hard-Bottom Reef Areas Off Northern Dade County, Florida. Published in Proceedings of the American Academy of Underwater Sciences Tenth Annual Scientific Diving Symposium, October 4-7, 1990. Edited by Walter C. Japp. St. Petersburg, FL: University of South Florida.
Florida Center for Public Management, 1997. Florida Assessment of Coastal Trends. Tallahassee, FL: Florida Coastal Management Program.
Maragos, James E., 1993. Impact of Coastal Construction on Coral Reefs in the U.S.-Affiliated Pacific Islands. Coastal Management, Volume 21. pp. 235-269.
U.S. Department of Transportation, 1998. A Report to Congress on the Status of the Public Ports in the United States. Washington, DC: DOT.
Biscayne National Park. 1996. Vessel Grounding Response: Policies & Procedures. Biscayne National Park Report. 28 pp.
Green, A., J. Burgett, M. Molina, D. Palawski, and P. Gabrielson. 1997. The Impact of a Ship Grounding and Associated Fuel Spill at Rose Atoll National Wildlife Refuge, American Samoa. Honolulu, Hawaii: U.S. Fish and Wildlife Service Report. 60 pp.
UNEP/ICUN. 1988. Coral Reefs of the World. Volume I: Atlantic and Eastern Pacific. UNEP Regional Seas Directories and Bibliographies. IUCN, Gland, Switzerland and Cambridge, U.K./UNEP, Nairobi, Kenya, 373 pp.
National Oceanic and Atmospheric Administration. 1996. Florida Keys National Marine Sanctuary: Final Management Plan/ Environmental Impact Statement. Washington D.C. (3 volumes).
Sargent, F.J., T.J. Leary, D.W. Crewz and C.R. Kurer. 1995. Scarring of Florida’s Seagrasses: Assessment and Management Options. Florida Marine Research Institute Technical Reports. 21 pp. Florida Department of Environmental Protection.
Zieman, J.C. 1982. The Ecology of the Seagrasses of South Florida: A Community Profile. Prepared for National Coastal Ecosystems Team, Office of Biological Services, U.S. Department of the InteriorFWS/OBS
ADDITIONAL COMMENTS FROM WORKING GROUP
There were several issues which cross cut the charges of the various working groups. These issues are listed below.
Coastal Non-point Source Pollution
Air and Water Quality lead with support from Coastal Uses
Oil Spill/HazMat Response
Ecosystem Science and Conservation and Coastal Uses shared responsibility
LIST OF WORKING GROUP MEMBERS OR CONTRIBUTORS TO THIS REPORT
DOJ/CIV/Av. & Admiralty||
|Lindy S. Johns||
|Capt. Bob Ross||
The following comments were received by non-governmental organizations in response to this summary.
E-mail response from Rick Schwabacher dated 2/23/99
Recommendations for the Administration and Congress
Approve comprehensive coral reef legislation building on proposals introduced in the 105th Congress (H.R. 2233, H. Con. Res. 8, and House Res. 87) to address the root causes of coral reef decline as determined from scientific, sociological, and economic information.
Strengthen existing federal programs directed at coral reef conservation and support the implementation of the Presidential Executive Order on coral reef protection.
Establish a permanent interagency working group, including scientific and policy experts, to identify adverse environmental impacts effecting U.S. coral reefs. Such a group should recognize that "rivers are the roots of the ocean" and work to address land, water and atmospheric based sources of pollution by developing comprehensive watershed management programs and effective conservation measures.
Establish an independent scientific panel to review on-going activities and advise federal agencies on coral reef conservation and related efforts, including the National Marine Sanctuary Program, activities in U.S. territories, and international initiatives.
Provide additional conservation incentives for States, territories, or countries with coral reefs or watersheds that affect coral reefs. Focus attentions on protecting the land-sea margin and the watersheds of coastlines and rivers by addressing issues concerning forestry, agriculture, coastal development and urbanization.
Identify and establish water quality goals compatible with the maintenance of healthy reef systems. Focus attention on preserving the ecological integrity of the reef system, not simply the physical reef structure. Develop water quality standards for sediment and nutrient loading, and biological oxygen demand. Direct efforts at reducing the inputs of excessive nutrients, untreated or partially-treated sewage, sedimentation and other pollutants from forestry, industry, agricultural practices and urban development. Recognize that airborne materials (components of dust and precipitation) may impact the ecological integrity of reefs as they can contribute increased nutrient and sediment loading from distant sources.
Increase efforts for coral reef restoration with emphasis on whole ecosystem restoration that includes attention to ecologically-connected watershed and airshed components. Address issues at the appropriate geographic scale, including local, regional, and global levels. Focus on the design and implementation of best practices at the regional and local levels and support appropriate demonstration projects
Establish a program within NASA’s Mission to Planet Earth to map and monitor the global distribution and health of coral reef communities and identify potential hazards to their future. The information should be made widely available and distributed on the Internet. Remote sensing data should be combined with standardized field sampling and Geographical Information Systems analyses. NASA should also investigate the possibility of using Space Station Freedom to monitor reefs in equatorial areas.
Promote the establishment and expansion of marine protected areas in the U.S. and strengthen support for applied scientific study and monitoring, especially in core nursery and recruitment zones, so that coral reefs can be sustained for future generations. Establish the Dry Tortugas as an ecological reserve, and expand Flower Garden Banks and Gray's Reef Sanctuaries to assure appropriate protection.
Ensure that the knowledge and means for coral reef management is transferred to tropical developing nations where most of the world’s coral reefs are located. Expand efforts by the Agency for International Development and the Peace Corps to address coral reef conservation concerns in developing countries, focusing on integrated coastal area management, fisheries conservation measures, education, and community involvement.
Assure that economic demands and trade do not result in further harm to reefs. Support the establishment of certification programs to eliminate the use of cyanide in fish capture, and restrict the trade in coral or coral products that threaten reef communities.
Continue and strengthen U.S. support and resources for the International Coral Reef Initiative. Support full implementation of the Biodiversity Convention and the Jakarta Mandate on Marine and Coastal Biodiversity, along with other international agreements on marine protection and conservation.
Sierra Club, Hawaii Chapter
E-mail response from Dave Raney dated 2/22/99
A. The most imminent threat to Maui's coral reefs at present appears to be large object with a lot of momentum behind it. It is called the United States Army Corps of Engineers and it appears determined to blast anddredge almost five acres of living coral at Ma`alaea. Where is the Corps participation in any of the Working Groups? Do they have a rep the Sierra Club could contact?
While being a major threat to coral reefs, the Corps has the potential to also play a major role in the restoration of wetlands, de-channelization of streams, and other "green" initiatives which would help restore coral reefs and estuaries to former levels of health. Seems they should be a key player on the Task Force.
B. Under Information Gaps, in Hawaii at present NGOs have very little to guide them as to the present condition of specific reefs, with the possible exception of Kaneohe Bay. We don't know whether the reefs are healthy, degrading, or recovering. We suspect many are gradually degrading due to sub-lethal stressors. I don't know whether this aspect of Information Gaps falls within the purview of your Working Group, but it should be acknowledged by at least one of the Working Groups. The responsibility for making such assessments may lie with state agencies, but federal assistance would be welcome. In Hawaii the state agency, DLNR, has only recently hired a coral reef expert.
As I have mentioned earlier, NGOs are eager to work on specific projects for coral reef protection and restoration within the context of integrated watershed management ( the Ahupua`a model in Hawai`i). We seek information from state and federal agencies, and coral reef ecosystem scientists, to help us focus our efforts effectively. We will be supplementing agency and scientific information with the viewpoints of traditional users of the resources.
My assessment of the value of the Task Force efforts will be based largely on its usefulness to NGOs interested in taking specific actions to protect or restore specific coral reef ecosystems.
E-mail response from Alexander Stone Dated 2/25/99
After reviewing the Working Group's draft list of target issues, ReefKeeper offers for consideration the following list of "Top Priority/Concern" issues in order of their importance perceived by us.
#1- Coastal Development & Shoreline Modification
(In the long run, the worst & broadest impact)
- Particularly for ship/boat channels & marinas
- Particularly worried about USVI and CNMI
1b) Beach Renourishment
- Particularly in SE Florida (Palm Beach through Dade Counties)
- Direct Impacts:Nearshore Coral Hardbottom burial (intentional!) and accidental offshore dredge gouging of reefs
- Indirect impacts: massive sedimentation from dredge salt plumes;
chronic long-term siltation from leaching of beach "fines"
1c) Mangrove and seagrass removal (not on your original list)
- threatens sustainability of reef biota since mangrove and seagrass are reef nurseries
- particularly worried about USVI
1d) Changes to natural sediment transport
- causes/amplifies beach erosion, triggering beach renourishment projects
- particularly concerned about effects of port inlet jetties (documented)
- particularly worried about Florida
1e) effluent outfall pipe siting (not on your original list)
- eutrophication impacts
- particularly worried about Puerto Rico
#2- Fishing Impacts
- greatest magnitude of impacted bottom, but may actually occur mostly away from hardbottoms
2b) destructive fishing techniques
- Lobster & fish trap deployment and retrieval
- grapnels dragged across reef bottom
- particularly worried about USVI, Florida, Puerto Rico and Gulf of Mexico dome banks
- Shallow reef nets
- coral abrasion (chronic)
- particularly worried about Hawaii
- Note: Bleach and dynamite outlawed everywhere in USA
2c) Overfishing of Herbivorous fish
- aggravates algal shifts/ overgrowth
- real danger in USVI and Puerto Rico (Herbivorous fish now primary catch
- Note: Magnuson-Stevens Act/Essential Fish Habitat (EFH) regulations offer cure But fishery management councils so far are minimally responsive
#3- Vessel Traffic
3a) Vessel anchoring zones (Not on your original list)
- particularly concerned about reef areas immediately adjacent to commercial and/or cruise ship ports/docks
- particularly worried about USVI, CNMI, Guam, SE Florida (Pt. Everglades, Pt. of Palm Beach, etc.)
- SOP for vessels to anchor to wait for port pilot or for next available berth
- In absence of designated anchoring zones, it's Russian Roulette for the reefs
3b) Vessel shallow water turbidity (not on your original list)
- particularly worried about CNMI, USVI, Guam
- massive sediment suspension and displacement from large ship propellers
- Reef habitat chronically stressed, eventually buried
3c) Vessel Groundings
- Need more "area to be avoided" actions by Coast Guard (Via UN's IMO)
- Need general compensation statute for all reefs
- Need authority to require compensation from US-sited ships for foreign groundings (right now, RKI involved in efforts to get 2 cruise lines to compensate marine parks in Cancun & St. Maarten for reef groundings)
Other general comments we think are pertinent include: (1) Working Group should focus intent to "build a national mitigation policy" to a precaution- based "National Damage-Prevention Policy"... (2) coastal development may be "highly regulated" in theory, but in practice the regulations are highly circumvented or compromised... (3) CZMA needs refocusing to become responsive to submerged habitat needs.. (4) there's legal precedent to place at least a $263 per sq. ft. value on reefs (consult B.Causey/ FKNMS)... (5) Vessel monitoring Systems (VMS) for commercial vessels would give a better handle on groundings prevention and compensation (Coast Guard familiar with VMS in context of fisheries regulations).
D R A F T