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Verifying Compliance with Ballast Water Discharge Regulations
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0
20
40
60
80
100
Expected % of BWViolations Detected**
Cost (Millions of Dollars)*
1a: Report that certified system is in operating condition
1b: 1a, plus report system is used properly
1c: 1b, plus report system was effective
2a: Monitoring (sensors) showing system in operating condition and used
2b: 2a, plus USCG system inspection
2c: Monitoring of BW to show conditions that will meet standards
3a: Low BW sample frequency, small BW sample size
3b: Medium BW sample frequency, medium BW sample size
3c: High BW sample frequency, large BW sample size
Wasteful
Unattainable
*Includes public cost of detecting and verifying violations (does not include cost to shippers for penalties or sanctions resulting from detected violations).
**Percent of illegal ballast water discharge detected is a measure of confidence in the verification system.
***Refer to Table 1 for more detail on these alternatives.
1a
1b
1c
2a
2b
2c
3c
3a
3b
Verification Alternatives***
Figure 2.
A cost-effectiveness curve comparing alternatives for verifying compliance with ballast
water regulations.
appear to be clearly inferior, for example, because they seem likely to fall far above the cost-
effectiveness curve (wasteful) or are not located far enough out on the cost-effectiveness
curve (are not effective enough) to be acceptable. Based on planning-level estimates of cost
and effectiveness, for example, the rebuttable presumption might be established that, until
more data become available, certain alternatives for verifying that ballast water discharge
standards are met appear more promising and deserving of attention than others.
Figure 2 provides a preliminary cost-effectiveness comparison of the verification al-
ternatives listed in Table 1. In general, verification methods based only on
reporting
are
shown to be the least costly, but to generate the least confidence because of a high likeli-
hood of undetected misreporting. Methods based on
inspecting
BWTS are more costly and
generate more confidence than reporting systems alone, but are not highly reliable because
a BWTS may not achieve certified performance standards without fail (particularly if not
properly installed, operated, and maintained). The most interesting comparison, however,
is between
monitoring
systems based on sensors that involve indirect indicators of whether
ballast water meets discharge standards and
direct measurement
systems that involve actual
sampling and analyzing ballast water as it is discharged.
Interpretation of Figure 2
At one extreme on the cost-effectiveness curve is a low cost and low confidence verification
system that involves merely accepting a report from the “master, owner, operator, agent or
person-in-charge” of a ship arriving at a U.S. port that it has a certified BWTS on board
(Option 1a in Table 1 and Figure 2).
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This could easily be incorporated into current USCG
ship reporting and inspection practices at a relatively low cost.
At the other extreme is a verification system that involves extensive and intensive
sampling and biological analyses to determine concentrations of live organisms in ballast
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