The vessels go 12 miles to dump the waste because of an international agreement that extends the U.S. protections against sewage sludge dumping by nine miles.

Locally, much has been made of a North West CruiseShip Association accord with the port and Ecology to prohibit its members from discharging untreated sewage into Puget Sound. In response to environmental concerns in ports of call such as Seattle, the cruise lines have begun deploying more advanced sewage-treatment systems onto their vessels.

"All the ships that operate in this region -- 27 ships out of Vancouver, Seattle and San Francisco -- all have advanced wastewater-treatment systems onboard that purify the water to near drinking-water standards," said North West CruiseShip Association John Hansen.

Under the Port of Seattle agreement, cruise vessels can use those systems to strain the solid material from the raw sewage. Once the solids are separated, the rest is treated and can be discharged into the water within one nautical mile of the port berth while the ship is traveling at 6 knots.

That deal has been trumpeted by the cruise lines and the port.

But what cruise spokesmen don't like to talk about is how -- after treating the raw sewage before discharging it into the sound -- most vessels store the concentrated waste that is left until they are 12 miles offshore and dump it into the ocean.

Some operators, such as Royal Caribbean, have committed to drying and burning all sewage sludge. Others that pass through Seattle still use outdated systems for treating and are not allowed to dump any of their wastewater in Puget Sound.

In December, Ecology invited members of King County's wastewater division to a meeting between the port and the cruise lines to discuss pumping the waste ashore into King County storage tanks that would be built to handle sewer overflows during rainy winter months.

"I believe that if a sludge intake pipe is feasible, it may be a very worthwhile project to pursue," Creighton wrote some of his supporters. "It could be a signature project of our green-port efforts."

During summer weekends, nine cruise ships leave and arrive in clusters.Filing in and out of the Port of Seattle like ducklings, many travel the same path through the Strait of Juan de Fuca and through the open ocean close to the west side of Vancouver Island before going eastward to catch the upper half of the Inner Passage.

"Three leave at a time through the strait, so one could be discharging on top of the discharge of another," Felleman said.

After the sewage sludge hits the propellers and fans out into the water, nutrient-deprived algae begins using the sludge to grow. That algae begins to grow quickly, forming blooms that, like the sludge, are decomposed by bacteria that consumes oxygen in the process. If too many cruise ships dump their sewage sludge in the same spot, it can create areas of oxygen-deprived water devoid of marine life.

Pumping the waste ashore would eliminate that scenario.

If cruise ships were to pump waste ashore, it could be treated and used for fertilizer spread either on farms or recovering forestland, such as the Mountains to Sound Greenway.

Greg Bush, the manager of planning and compliance for King County's wastewater division, said the upcoming Interbay expansion project also could be suited for sludge storage and transportation in the summer.

Once the waste is on shore, it could be trucked to the South Treatment Plant in Renton or piped to the West Point Treatment Plant in Magnolia. At both facilities, the waste would be turned into fertilizer.

The cruise lines are hesitant to say it's a good idea, even if the port puts up the money for the infrastructure, because it would mean paying for the disposal of waste they can dump or burn at their own discretion.

An Interbay pumping station is already in place close to the docks that would be used by the cruise ships, and it is hooked up to the West Point Treatment Plant by a large pipe.

That station, West Point, and the pipe that connects them all have capacity in the summer to handle output from the cruise lines, according to Bush and West Point Manager Jim Pitts.

But in materials prepared for a presentation to the commission, port staffers wrote that West Point and the connecting pipe didn't have the capacity, which Creighton said isn't true.

What is not clear at this point, Bush said, is whether another pipe that runs by the docks and the short distance to the pumping station could handle additional waste. Running pure sewage sludge through pipes meant for both raw sewage and storm water could also cause the pipes to corrode, King County engineer Eric Davison said.

The port needs to reconcile all the concerns, Creighton said.

Commissioner Bob Edwards believes the port needs to take time to study the matter, saying the sludge project is an add-on that should be put off.

"Is this as high a priority as cleaning up Puget Sound?" Edwards asked.

A LETTER

Environmental activist group Bluewater Network wrote the following to the Department of Ecology regarding the disposal of sewage from cruise ships in December 2006:

Amy Jankowiak
Washington State Department of Ecology
NW Regional Office
Water Quality Program
3190 160th Ave SE
Bellevue, WA 98008

Dear Amy:

The growing number of cruise ships homeporting in Elliott Bay pose a unique pollution threat to Puget Sound with air and marine emissions equal to that of small towns. We acknowledge the State of Washington has attempted to manage this waste stream in response to a couple of recent cruise ship dumping incidents by entering into a voluntary Memorandum of Understanding (MOU) with the Port of Seattle and the NW Cruise Ship Association. While we believe that it is in the best interests of the State to develop enforceable regulations, we would like to provide comment as Ecology reviews and revises the existing MOU.

We appreciated the opportunity to participate in the annual Cruise Ship Memorandum of Understanding meeting at the Port of Seattle on December 8th. The purpose of this letter is to follow up on some of the issues raised at that meeting in hopes that the MOU could be modified accordingly before the next cruise season.

We were pleased to hear the discussion on biosolids disposal. There appears to be a variety of options available to the cruise lines and we hope that the Port of Seattle chooses to provide infrastructure for cruise ships to make appropriate disposal easy and cost effective. However, we are adamant that under no circumstances should the MOU continue to condone the disposal of biosolids in the Olympic Coast National Marine Sanctuary.

We were surprised to learn that you had not received a copy of the Sanctuary's letter expressing the managers' concern about this practice and have attached it for your reference. The waters encompassed by the sanctuary comprise a small portion of a cruise and therefore poses little burden on the operator to refrain from dumping within its borders. We believe this practice is in violation of the Sanctuary Act and sends the wrong message to cruise passengers that they are despoiling the very habitats they are paying to visit. It should not be problematic if this requires expanding the waters to which the MOU pertains, especially since one of the purported benefits of the MOU was to be able to expand one's jurisdictional reach and the ATBA already includes waters beyond state jurisdiction. It is also worth noting that three West Coast Sanctuaries are now considering new regulations that will prohibit all discharges from cruise ships except engine cooling water. Please keep us apprised of any changes in biosolid disposal practices by the cruise lines visiting the Port of Seattle.

It was interesting to learn that the Summit, Mercury and Vision of the Seas did not seek permission to discharge in State waters in 2006. We hope that you will inspect their logs in the future to verify that they did not. The fact that they can hold their effluent provides the opportunity for cruise lines to minimize their impact on the poorly flushed Puget Sound by waiting until they clear Admiralty Inlet before beginning their discharge. Given the elevation of pollution concerns raised by the Puget Sound Partnership, it seems appropriate that the cruise lines would like to distinguish themselves by such practices. Please let us know if any of the cruise lines make such a commitment. We would also be happy to provide you with a copy of our comments to the Partnership on cruise ship and port pollution.

We were disappointed to learn that only four WET tests were conducted in 2006 and two in 2005. We are also concerned to learn that Ecology has found high levels of toxicity in the few samples collected. If Ecology initiates a WET Test Task Force as discussed, we ask that Gershon Cohen from Haines, Alaska, be included in its membership.

We would feel far more comfortable with the MOU if the aforementioned issues could be addressed before the next cruise season. However, as we have expressed in our 11/09/06 letter to the Port of Seattle in response to the DEIS for the new cruise ship and container terminals, we still have a problem with the lack of enforceability of the agreement.

Rather than waiting for state or federal legislation we are hoping that the modified MOU could be attached to the lease or docking agreement the Port has with Cruise Terminals NW or the cruise lines directly, or utilize other available mechanisms, to make it legally binding and enforceable. The fact that you have navigated a path by which the state can invoice the port, which is in turn reimbursed by the cruise lines, to fund the administration of the MOU demonstrates your ability to work through the various parities to formalize this agreement. This is particularly important in light of the fact that the Port is referencing the MOU as mitigation in the DEIS for the new cruise terminal. We believe using a voluntary agreement as mitigation comprises one of the most serious flaws in the DEIS, and if not corrected may serve to slow progress on the project.

Finally, we understand that Celebrity Cruises has until December 17 to appeal the notice of violation that Ecology sent them in response to the Mercury's 10 illegal discharges in Juan de Fuca Strait and at the Port. Please inform us at your earliest convenience if the cruise line files an appeal.

Thank you once again for opening the MOU meeting to the public. Feel free to contact me or our consultant in Seattle, Fred Felleman (206.783.6676), if you have any questions about issues raised in this letter or in the testimony presented on the 8th.

Sincerely,

Teri Shore
Bluewater Network
Friends of the Earth