Proposed amendments to the
Cruise Ship Memorandum of Understanding
Public comment period: Feb. 17 to March 19, 2021
The Department of Ecology, Port of Seattle, and Northwest Cruise Ship Association negotiated a MOU in
2004 to establish voluntary actions ...↓
ships operating in Washington waters. The waters subject to the MOU include the Puget Sound and the
Strait of Juan de Fuca south of the international boundary with Canada; and along Washington's Pacific
Coast extending for three miles seaward. The original Memorandum was signed on April 20, 2004.
The current MOU as written has an amendment process every three years; at which time proposed
amendments from MOU parties as well as from the public are requested and reviewed. The most
recent call for proposed amendments ended on December 18th
. After the close of the proposed
amendment request, the MOU parties have 45 days to review the proposed amendments to verify they
meet the requirements for further review and then put the proposed amendments out for a 30-day
public comment period.
In the most recent review of the proposed amendments, the MOU parties have agreed that two
amendment proposals meet the MOU's requirements for consideration. Ecology is opening a 30 day
public comment period beginning February 17th to review the proposed amendments. The proposed
amendments have not yet been adopted by the MOU parties. Adoption of the proposed amendments
and final language of any amendments to the MOU will be determined by the MOU parties after the
public comment period has ended.
The two proposed MOU amendments are listed below. Please use the ecomments form to comment on
the proposed amendment.
Proposed MOU amendments:
1) Institute a ban on the discharge of exhaust gas scrubber washwater from all scrubber types,
including bleed off or sludges, in MOU waters.
This proposed MOU amendment met the criteria as it was specific to the MOU waters and was
accompanied by scientific data to support the amendment. However, if adopted, some of the
wording of this amendment is likely to change to conform with regulations under the MARPOL
treaty regarding exhaust gas scrubber washwater.
2) Ecology proposes to incorporate the Vessel Sewage No Discharge Zone (NDZ) for Puget Sound
into the MOU to reflect the Washington state NDZ regulation. Chapter 173-228 Washington
Administrative Code (WAC), adopted on April 9, 2018, and effective May 10, 2018. Additional
information is available online at https://ecology.wa.gov/Water-Shorelines/Puget-Sound/Nodischarge-zone. As written, the MOU allows for treated sewage (blackwater) discharges after
advanced wastewater treatment that are now not allowed by the NDZ regulation. To be
consistent with the regulation and to prevent vessel sewage discharges in MOU waters, all
allowances of the sewage discharges in MOU waters should be prohibited. This would not affect
graywater discharge in the MOU.
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