- Mr. Michael BootsThe White House Council on Environmental Quality
- Mr. David RedfordU.S. EPA
Tell EPA to Protect Our Seas from the Navy’s Ocean Dumping Program
Join our call. Tell the U.S. EPA to bring the Navy’s ship ocean dumping program in-line with current laws, laws that all citizens of the United States must abide by. Your support will make the difference!
A report by the Basel Action Network, Dishonorable Disposal: The Case Against Dumping U.S. Naval Vessels at Sea, and subsequent investigation by The Associated Press, uncovered the wasteful legacy of the U.S. Navy's ship sinking program. This comprehensive analysis of ship ocean disposal by way of target practice exercise cites toxicological data demonstrating polluted waterways, and an economic analysis revealing lost recycling jobs, wasted taxpayer dollars and squandered resources at the center of the government's ship disposal program.
The Pentagon quietly pulled back plans to sink the USS Forrestal and three other aircraft carriers in 2011, deciding instead to recycle these vessels domestically. However, the Navy ignored the rationale that led them to that decision and sunk four ships in 2012, and is moving ahead with plans to sink two more ships by sinking exercise (SINKEX) in the pristine waters of the Hawaiian islands in July 2014.
The EPA and Navy admit that toxic chemicals are deposited into the marine environment as a result of ship sinking operations, including asbestos, lead paint, antifouling paint containing tributyltin (TBT), polybrominated diphenyl esters (PBDEs) and notably polychlorinated biphenyls (PCBs), a suspected carcinogen that has been targeted for global phase-out and destruction under the Stockholm Convention. However, the EPA and the Navy have not yet assessed the impacts of this toxic dumping to any degree of certainty, nor do they have plans to assess the ramifications of such dumping. Yet the sinking program continues unobstructed.
In 1998-99, EPA revised the general SINKEX permit to allow the Navy to continue the SINKEX program with exemptions to the U.S. Toxic Substances Control Act (TSCA), essentially giving the Navy a pass to leave intact solid PCB contaminated materials on SINKEX vessels for deep sinking. Following this exemption, the Navy quickly escalated the program. From 1970-1999 SINKEX accounted for approximately 8% of all vessel disposals, but from 2000-2010 (following the TSCA exemption), sinkings accounted for approximately 65% of all disposals, with over 100 ships being dumped in that decade alone. These ships contained an estimated 600,000 tons of recyclable steel, copper and aluminum, worth an estimated half a billion dollars in scrap had the vessels been recycled.
The Navy has taken great advantage of the exemptions EPA granted them and escalated the ocean dumping program, presumably to save on costs related to PCB compliance under TSCA, which is applicable to all other ship disposal methods. But EPA has done nothing to restrict the program or improve the remediation requirements by limiting exemptions that were granted over 13 years ago. In fact, in January 2014, the EPA explicitly stated that the Navy can sink up to 100 lbs. of pure molecular PCBs with each SINKEX target vessel.
Join our call. Tell the U.S. EPA to bring the Navy’s ocean dumping program in-line with current laws, laws that all citizens of the United States must abide by.
Thank you for your support.
Basel Action Network
- The White House Council on Environmental Quality
Mr. Michael Boots
- U.S. EPA
Mr. David Redford
RE: Navy SINKEX
To Whom It May Concern:
I am writing to submit public comment asking EPA to intervene and bring the Navy's SINKEX program in line with U.S. and international law. I believe the EPA's support for this wasteful ocean dumping program, and the exemptions granted to the Navy under past administrations, present a troubling situation. Ocean dumping of toxic pollutants is simply irresponsible when waste can be responsibly managed and contained in land-based facilities. Adding insult to injury, the dumping squanders tons of critical metal resources that could otherwise be recycled in the domestic marketplace, lessening the demand on primary metal resources and related environmental impacts.
I urge EPA to consider the big picture here - the dumping of Navy wastes into nature for any purpose sends a very dangerous cultural message that the natural world, and in particular our marine environment, can be exploited as the solution to our growing waste problem. The Obama Administration’s Lead by Example mandates and the widely accepted waste management hierarchy should guide practical and principled policy decisions here.
The Navy should at the very least be required to follow the law, as everyone else is required. Why should the Navy be granted exemptions to PCB remediation requirements that industry and all citizens of the United States must strictly follow? It is our Government that not only enforces the law on its citizens, but it is our Government that should be expected to comply with the law in the same manner as its citizens.
The environmental benefits of recycling are important to consider, especially as the Obama Administration has gone out of its way to promote recycling through Executive Order, as well as promoting initiatives for healthy seas.
The ships currently being readied for SINKEX – the Ogden, Fresno, and Tuscaloosa – are all likely to contain a host of hazardous materials within their construction given their 1960’s vintage, yet the Navy can prepare them and sink them without direct oversight by EPA or any other agency. In fact, EPA has granted them general authority by way of permit, to leave intact regulated concentrations of PCBs for ocean dumping. This is not sufficient to ensure pollution is minimized to protect the environment and in particular the vulnerable ocean ecosystem.
I ask the EPA to take the lead and correct the errors in judgment made by past administrations, errors that allow ocean dumping of hazardous materials into our seas on the Obama Administration’s watch. As a proud citizen of the United States of America, I urge you to “Lead by Example”, just as our President has directed you, and clean up this run-away program.
Thank you for your consideration.
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