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(Submitted by the Marine Engineers’ Beneficial Association)

The Maritime Trades Department, AFL-CIO has long supported reducing threats to the nation’s coastal environment and sustaining a diversity of options for the use by industry and citizens alike. We are, however, becoming increasingly apprehensive of plans being promulgated in response to the July 2010 Executive Order on Stewardship of the Ocean, Our Coasts, and the Great Lakes (http://www.whitehouse.gov/files/documents/2010stewardship-eo.pdf). This Order requires federal implementation of actions that address Ecosystem-based Management; Coastal and Marine Spatial Planning, climate change, and ocean acidification, among other objectives. Furthermore, the Executive Order creates a National Ocean Council and establishes zoning boards, empowering them with a level of authority so broad that it could result in adverse impacts on both land and marine interests, including, but not limited to, agriculture, commercial fishing, construction, consumers, energy, manufacturing, mining, ports and waterborne transportation.

Adding to our concerns, the recently released draft National Ocean Policy Implementation Plan calls for federal entities to take over 50 actions and implement nearly 300 projects, with roughly 160 to be completed by the end of next year.

If implemented as proposed, this Plan could very well saddle the maritime industry with new and burdensome regulations and restrictions that could also harm the countless jobs and communities it supports. Areas of particular concern include proposals to enhance regulation pertaining to vessel discharge, assess options to “minimize and/or mitigate” what are said to be “risks” associated with marine transportation and movement of heavy-grade fuel oil in the Arctic, reactivate the National Marine Sanctuary Site Evaluation List as part of an effort to identify marine areas “in need of protection,” and the development of a carbon sequestration protocol to incorporate into certain federal policies and laws.

In addition, Coastal and Marine Spatial Planning is considered by many to be a  zoning mechanism that will threaten a long-established process of utilizing careful analysis, significant industry stakeholder input, and collaboration with well-informed regulators to make determinations about measures such as Areas-To-Be-Avoided, Mandatory Vessel Traffic Routes, Vessel Traffic Separation Schemes, Lightering Areas, Pilot Boarding Areas, Safety Zones Around Vessels and Terminals, Anchoring and No Anchoring Grounds or Areas, and Security Zones in Ports and Waterways. Such existing collaborative processes have led to risk-avoidance and helped to create an impressive safety record. For example, even as domestic consumption and marine transportation of crude oil have steadily increased over the past two decades, instead of following suit, there has been a corresponding and unprecedented decrease in oil spill incidents and the volume of oil spilled from vessels in the coastal waters of the United States. Regrettably, efforts led by new federal zoning boards–and blessed by the National Ocean Council–that restrict the uses of ocean, coastal, and Great Lakes waters may also have a negative impact on the maritime sector’s ability to promote the environmentally advantageous marine highways initiative and offshore wind and ocean current technology.

The MTD and its affiliated unions support a National Ocean Policy that serves as a mechanism for job creation, infrastructure revitalization, practical environmental protection, and economic growth, and relies on full utilization of existing programs and well-established authorities that are already in place, rather than the establishment of new bureaucracies, procedures, and regulations that only serve to create additional uncertainty and unnecessary restrictions and delay.

Unfortunately, the potential for harmful impacts to the maritime industry has already emerged, as outside groups are already attempting to use the policy as a tool to impose new restrictions on shipping in certain areas off the West Coast and to delay offshore wind development in the Atlantic.

It is for these reasons that the MTD and its affiliates pledge our full support for vigorous congressional oversight over implementation of the National Ocean Policy and efforts to limit its adverse effects. We also stand with our union Brothers and Sisters in other industries who seek to ensure an acceptable outcome by raising awareness of the National Ocean Policy and the harmful impacts that it may create if left unchecked.