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RECOMMENDATIONS

RECOMMENDATIONS

Enforce the London Convention

Government vessels sunk through SINKEX and through the artificial reefing program can contain polychlorinated biphenyls (PCBs), an organohalogen listed in Annex I that is prohibited from ocean dumping under the original London Convention. Calling artificial reefing placement and not dumping is an inappropriate designation, as placement can only be deemed an exception to ocean dumping restrictions if it is not contrary to the aims of the Convention: “… to prevent the pollution of the sea by the dumping of waste and other matter that is liable to create hazards to human health, to harm living resources and

marine life….” The EPA’s allowing of an Annex I substance to be dumped in excess of trace amounts for ocean disposal is clearly liable to create hazards to human health and marine life and is contrary to the aims of the Convention.

As demonstrated, both SINKEX and the artificial reefing programs are liable to create such hazards and harm.

Proper implementation and enforcement of U.S. obligations under the London Convention would make it illegal to dump PCBs in excess of trace amounts in the marine environment without exception.

Amend the Marine Protection, Research and Sanctuaries Act

The MPRSA is meant to implement the objectives of the London Convention in national law. It therefore must regulate artificial reefing , Any does the London Convention. as

exemptions for placement must be predicated therefore on ensuring that such placement is not liable to harm the marine environment. Rather, the MPRSA simply claims that placement such as artificial reefing is regulated

under other laws. Yet the other laws fail to regulate it properly and to the same extent as the London Convention. The MPRSA must be reformed to specifically exclude placement of any hazardous waste or London Annex I material above trace amounts, as this is clearly a violation of the aims of the London Convention.

End SINKEX: Revoke General Permit

SINKEX is an old practice designed to simulate war conditions and provide our military with practice exercises for destroying enemy Navy vessels. It was conceived at a time prior to knowledge about contamination on board vessels and their impacts on the marine environment. It was designed at a time when our concerns for conserving metals, resources and preventing greenhouse gases were not as acute. And moreover, it is a program designed

at

a

time

before

computer

and

video

simulations were developed as a science.

Today, SINKEX is a relic we no longer need and can no longer afford. The days of using the sea as a dumping ground must end.

BAN has interviewed military experts who claim that today such target practice is not essential for military readiness. If on-sea targets are

needed

they

advised

that

clean,

uncontaminated barges could be substituted. In fact, during the Rim of the Pacific (RIMPAC) war games of 2010, the navy used inflatable and biodegradable balloons called killer tomatoes, as targets for gunnery exercises in an effort to

BASEL ACTION NETWORK

57

2011

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