・A "Sense of Congress" in the National Defense Authorization Act for Fiscal Year 1997 that specifically states that the Navy should fully comply with Annex V of MARPOL 73/78 (which prohibits solid waste discharges in internationally designated "special areas")
・Proposed Annex IV of MARPOL 73/78 that will significantly expand blackwater discharge restrictions
・Proposed Annex VI of MARPOL 73/78 that will implement air emission requirements for shipboard engines and incinerators
・An anticipated new MARPOL 73/78 annex on the control of non-indigenous species
・Unform National Discharge Standards (UNDS) that are being jointly established by EPA and DoD (pursuant to the National Defense Authorization Act for Fiscal Year 1996) for the shipboard control of 25 specific liquid effluents
・Continuing government-wide emphasis on pollution prevention and hazardous materials reduction.
Experiencc over the last twenty years has shown that environmental restrictions will continue to tighten, even if the exact nature of the new requirements cannot be accurately predicted. It has also been amply demonstrated that the Navy will increasingly become part of the regulated community except for increasingly-narrow national security exemptions that entail their own "public relations" risks.
COSTS OF ENVIRONMENTAL REQUIREMENTS
The Navy can incur several types of monetary costs related to Fleet environmental rerquirements: compliance, non-compliance, and good stewardship. Compliance costs derive primarily from: the shoreside disposal of wastes offloaded from ships and submarines (e.g., landfilling barging services, wastewater treatment); the development procurement installation (especially backfitting), and operation of shipboard pollution control systems (e.g., Oil/Water Separators and Oil Content Monitors); and the design of environmental systems into new naval platforms, especially where ship designs must be modified (e.g., ECPs). An ongoing NAVSEA-sponsored study of the return-on-investment(ROI) for new shipboard environmental capabilities estimated that the Fleet-wide cost of ship waste offload and disposal alone in FY95 was over $67 million worldwide. Costs of non-compliance consist of: fines for violations (e.g, exceeding air emission limits); legal judgments that impose operational changes (e.g., vessel speed reductions and area restrictions to avoid whales); and new environmental monitoring and reporting obligaions (sampling and analysis of harbor waters where Navy vessels are homeported). The costs of good stewardship, i.e., going beyond legal requirements, can be any or all of the above costs that the Navy chooses to assumne to protect especially environmentally-sensitive areas, foster better relationships with regulators, or enhance its public image (e.g., holding medical waste beyond 50 nm even when it can be processed and discharged in accordance with law and Navy policy).
There are also numerous other environmental "costs" to the Navy that cannot be conveniently expressed in dollars. The Navy is the most visible of the military services. Its ships and submarines are always dispatched to troublespots around the world under the scrutiny of the news media and Navy vessels are very large weapons that can be easily seen moving around in coastal waters or tied up to piers in some of the most geographically-interesting areas of the world. This elevates the Navy's public image to the point where environmental problems (oil spills, wash-up of medical waste on beaches, offload of large volumes of trash, ship collisions with whales, etc.) are newsworthy events, sometimes creating negative publicity, rallyirg opposition, and precipitating litigation. Such non-monetary costs include:
