・Friction with Congress, which can have significant monetary (Navy budget) implications
・Poorer relations with regulatory agencies, environmental groups, and others who can affect deckplate and pierside environmental issues
・Lack of credibility in lawsuits (judges and juries may be less sympathetic to the Navy if it cannot demonstrate verifiable good-faith efforts or due diligence)
・Reduced vessel safety and survivability
・Adverse impacts on crew safety, health, and quality of life
・Denial of port entry or operation in certain intematioual or foreign waters
・Disparities in pollution control capabilities and practices with allied navies, especially when engaged in joint operations and exercises or visiting foreign ports.
The Navy must try to take all monetary and non-monetary costs into consideration when deciding how to optimize vessel design and modernization, Fleet operations, personnel issues, aud environmental performance to minimize TOC.
ENVIRONMENTALLY SOUND SHIP FOR THE 21st CENTURY
Unlike the prospective developer of a shoreside facility, the Navy connot choose where to locate its vessels on the basis of the most advantageous environmental regulatory scenario and cannot avail itself of various administrative strategies (e.g., pollutant trading) intended to offset pollution problems in one geographic area with better environmental performance in another. Ships and submarines must be ready to go anywhere they are needed, without hasty or temporary retrofitting of pollution control equipment and without concern for environmental-related operational restrictions along the way or upon arrival. The only realistic way to accomplish this is to meticulously define the environmental requirements that will apply to a vessel or group of vessels throughout their relatively long service lives (now typically 30-40 years). Gazing into the environmental legislative and regulatory "crystal ball" may seem ike a distraction from the Navy's traditional focus on designing ships and submarines, weapons, and Fleet support systems for fighting wars. Nevertheless, as the Navy' s role has expanded to enconmpass obligations that would not necessatily qualify for wartime exemptions for waste discharge (forward presence, deterrence/reassurance, peacekeeping evacuation exercises with other navies, etc.), the ability to operate and visit ports without creating environmental problems is becoming imperative. In particular, the renowed Navy and Marine Corps emphasis on the littoral mission places surface combatants, submarims, and amphibious ships close enough to shore that the overboard discharge of solid and liquid wastes can interfere with green-water operations and result in floating and beached waste that are visible to local populations.
Because the Fleet prefers to "train the way it fights," altering the way a ship manages its wastes in response to changing environmental requirements as the ship moves from blue water, to littoral areas, to ports, to the IM0-desigted "special areas" introduces an element of uncertainty and can lead to changing manpower requirements to collect, handle, process, and store wastes. In addition, it is no longer a good assumption that wastes will be immediately diverted overboard at the first sign of a military threat. Ideally, every ship and submarine would have shipboard waste management practices and systems that could be used irrespective of geographic location, so that there would be no risk of discharging something overboard where it is not allowed vessels would not have to consider moving from restricted to unrestricted waters to discharge, and crews would not bave to contend with accumulating wastes on board. The best way to address these uncertainties is to have highly-automated waste processing systems that run "continuously," irrespcctive of the ship's location or operations.
Recognizing that Navy ships and submarines must be able to travel in any body of water and visit any port worldwide, the CNO's office formulated in 1989 a vision for the environmentally sound ship ofthe 21st century (ESS-21).
