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ELEMENTS OF AN IMPLEMENTATION STRATEGY 94 The Coast Guard can exert some control over fisheries. A Certificate of Adequacy (COA) must be obtained for piers serving vessels that off-load more than 500,000 pounds of commercial fishery products annually. In addition, Coast Guard regulations effective May 19, 1994, require that U.S.-flag, ocean- going commercial vessels over 12.2 meters (about 40 feet) keep records of garbage discharges.3 Commercial fisheries are among the fleets affected.4 By promoting knowledge of regulations and awareness of garbage handling practices, as well as means of verifying that responsibilities are being carried out, the use of such records is expected to "promote compliance, facilitate enforcement, and reduce the amount of plastics discharged into the marine environment" (59 Fed. Reg. 18,700 ). Fortunately, the government is not the only source of control. Experience has shown that indirect control can be exerted through employee complaints to law enforcement authorities and peer pressure (Alverson and June, 1988; Recht, 1988; Buxton, 1989; DPA Group, 1989). Attempts are being made to harness these tools to influence fisheries behavior (Center for Marine Conservation, 1989). Increasingly, regional councils focusing on the prevention of marine debris are enlisting the active support of fishermen to encourage voluntary change (Buxton, 1989; Gulf of Mexico Program, 1991; Pearce, 1992). Some form of influence clearly is needed to improve port reception facilities, which (as in most maritime sectors) are considered inadequate for handling all the garbage generated by fishing vessels. Fishing ports are owned and managed by a variety of government organizations, city docks, and commercial enterprises. As with any new standard that imposes changes in waste handling, complying with the mandate for port reception facilities can be prohibitively expensive for a small harbor, pier, or terminal. The government may be able to exert some influence in this area by offering to subsidize modification costs, guarantee loans for facility construction, or classify costs of port reception facilities as pollution-control devices for bond underwriting purposes. Analysis of Interventions Table 4-2 indicates options for intervening to improve Annex V implementa- 3 Under 33 C.F.R. Â§151, garbage logs must show when and where garbage is incinerated or discharged (overboard, to another ship, or to a port reception facility); the date, time, location, and volume of the discharge; and the specific contents of garbage discharged overboard. The final rule was published in 59 Fed. Reg. 18,700 (1994). 4 The regulations also affect the limited number of U.S.-flag cargo ships, all manned offshore platforms, some research vessels, and the few U.S.-flag cruise ships. Public vessels and foreign-flag vessels are not required to comply, although proposed amendments to the Marine Plastics Pollution Research and Control Act would allow the regulations to be extended to any ship of a size and use specified by the Secretary of Transportation.
ELEMENTS OF AN IMPLEMENTATION STRATEGY 95 tion in the fisheries sector. In general, it is important to take into account regional differences, to use whatever intelligence is available, and to capitalize on the existing government control structure established by NMFS oversight of fishing activities and Coast Guard regulation of vessels and operators. Technological interventions need to be tailored to the conditions on fisheries vessels. Trash compactors, for example, need to be the fight size. Special storage procedures may be needed depending on the size and condition of waste materials. Measures also could he taken to reduce gear losses, as encouraged by the International Maritime Organization (IMO) guidelines for Annex V implementation. A key organizational intervention, suggested by the preceding discussion of control, would be to modify criteria of restricted fishing seasons to enable retrieval of gear left in the water. Another promising approach would be for fishing cooperatives and other organizations to obtain advice and support from federal and state agencies to help establish port reception facilities tailored to local needs. In addition, fishermen could be encouraged to return to shore any debris recovered in nets or other gear. Education to encourage voluntary compliance with Annex V must continue to consolidate some of the early success in this community. Annex V information could be disseminated through existing channels, such as fishing license renewal and boat registration processes as well as the Sea Grant Marine Advisory Service. Sea Grant agents might be able to provide the necessary technical assistance as well. Another promising educational strategy would be to distribute data on lost gear and its possible effects on the marine environment, including fish stocks. In addition, fisheries management councils could be educated in how to encourage Annex V compliance in their planning. Annex V enforcement, including vigorous prosecution of violators and imposition of significant penalties, is important in this sector. Debris from fishing activitiesânet fragments, monofilament lines, broken traps, and other gearâis associated consistently with injuries to wildlife and damage to vessels. In some regions of the United States, debris originating from fishing vessels dominates the garbage washing ashore; where this occurs, securing compliance from local fishing fleets could yield significant environmental benefits. If the objectives of Annex V cannot be met through voluntary compliance (and the work of Sutinen et al.  points out how the fisheries regime struggles to achieve compliance), then federal authorities should focus their limited enforcement resources on the most effective strategies. Options include expanding the duties of NMFS on-board observers to include monitoring for Annex V violations, and requiring the reporting of gear losses (not covered by the Coast Guard record-keeping regulations). In addition, international agreements could encourage or require Annex V compliance by participating nations; this approach might be valuable, for example, in fostering compliance by the Mexican shrimp industry, which is blamed in part for debris in the Gulf of Mexico (Boudreaux, 1993).
ELEMENTS OF AN IMPLEMENTATION STRATEGY 96 TABLE 4-2 Applying the Hazard Evolution and Intervention Model to Commercial Fisheries and Their Fleet Ports Hazard Evolution Model Behavior that On-board Generation Encourages Generating of Garbage Garbage Intervention Model Modify Behavior that Reduce Garbage Encourages Generating Generation during Garbage Voyage Technological Reduce use of discardable material. Organizational and Repair nets ashore. Examine materials Operational Modify criteria of now in use to identify restricted fishing season where use of substitute to enable retrieval of gear materials can reduce left in water. waste generation. Sort garbage at site of generation. Use only vendors committed to packaging and storage techniques that minimize waste. Educational (Target Educate vessel operators Examine methods now Population/Content) about alternate in use to identify processing methods that where alternative generate less waste than methods would conventional approaches. generate less waste. Communicate that cleaner water may increase value of fish and minimize damage to vessel and gear.
ELEMENTS OF AN IMPLEMENTATION STRATEGY 97 Hazard Evolution Breakdown in Discharge of Exposure to Model Compliance Garbage into Sea Discharged Garbage Intervention Model Prevent Block Discharge Block Exposure Breakdown in of Garbage into to Discharged Compliance Sea Garbage Technological Build garbage Develop and Use products storage space install appropriate made of and processing garbage handling biodegradable equipment into equipment. Try to materials (except new vessels prevent storms plastic). Tag gear and retrofit and vessels from with pingers or where feasible. dislocating set other devices to Keep shipboard fishing gear. help relocate it. systems well maintained. Organizational Provide Establish port Encourage crews and Operational reminders via reception and captains to posters and facilities tailored bring to shore placards on to local needs. any debris vessels. Audit Establish an recovered in gear. practices incentive for regularly. Keep manufacturers to records on gear buy back nets. losses and disposal. Educational Circulate data Train crews to (Target on lost or hold garbage Population/ discarded gear (including items Content) and effects on often discharged) wildlife. for shoreside Distribute recycling. Annex V Educate fisheries information via management Sea Grant councils to agents and incorporate fishing license Annex V and boat compliance into registration fisheries processes. management planning.
ELEMENTS OF AN IMPLEMENTATION STRATEGY 98 Hazard Evolution Behavior that Encourages On-board Generation Model Generating Garbage of Garbage Intervention Model Modify Behavior that Reduce Garbage Encourages Generating Generation during Garbage Voyage Government or Private Prohibit use of certain Regulation and plastic materials in the Enforcement manufacture of gear. Prohibit fishing methods that promote setting of excess gear or wasteful discards. Economic (Market Develop equivalent Determine overall costs Forces) products using alternative (throughout product materials. Establish an life cycle) of using incentive for manufacturers discardable materials. to buy back nets. Improve Create market demand remanufacturing of old nets. for recycled nets (intact and fragments) and materials. Financial incentives may be particularly useful. Canadian interviews5 reported by Buxton (1989) suggest that economic incentives will drive compliance in some circumstances. Buxton reports that''... it makes business sense to change present disposal practices. This may relate to quality issues, real or perceived, or avoiding losing fish.'' Interviewees expressed concerns about the cost of garbage handling equipment and even greater anxiety about the high fines for illegal discharges (Buxton, 1989). Interventions to encourage the return of used 5 Canada is not a signatory to Annex V but has strict domestic regulations that parallel the mandates of Annex V.