The South Carolina Ports Authority plans to expand the Union Pier cruise ship terminal in Charleston at a cost of $35 million. Local groups are concerned this will increase environmental impacts from docked cruise ships, such as air and noise pollution. Supporters argue it will boost tourism and the economy. The document discusses regulations that cruise ships must follow regarding waste disposal and air emissions to protect the environment. It also provides alternatives to the proposed expansion such as conducting further studies, limiting ship sizes, and implementing buffer zones or fees.

1. Jennifer Balliet
From:
To: South Carolina Ports Authority
RE: Policy recommendation regarding the reconstruction of Union Pier cruise ship terminal in
Charleston, SC. Date: 20 April 2015
Summary
The South Carolina State Ports Authority plans to make a $35 million dollar expansion to the
Union Pier cruise ship port in the historic district of downtown Charleston, SC. Since 2010 a 2,000
passenger Carnival Cruise ship has been based at the Charleston, SC terminal which is now
considered old and outdated.1
Many local interest groups, such as The Preservation Society of Charleston, Historic Charleston
Foundation, Historic Ansonborough Neighborhood Association, South Carolina Coastal
Conservation League, Charlestowne Neighborhood Association, Charleston Chapter of the
Surfider Foundation, and the Charleston Communities for Cruise Control, are concerned about the
environmental impact that will increase due to the docked cruise ships.2
Potential environmental impacts include air shed emissions, traffic noise and traffic volume. In
particular, the increase of Sulfur Dioxide (SO2) emissions. SO2 is a major component of acid rain
and is also known to create many different health issues.2 Supporters of the new port, such as the
City of Charleston, and the S.C. State Ports Authority, argue that the port will increase tourism
and local business and city revenue.2
Background
Union Pier is a 63-acre property surrounded by more than 5,000 feet of chain-link fence along the
Cooper River in downtown Charleston, SC. Public access is prohibited and used for maritime
purposes only. The northern part of pier accommodates various industrial transportation units such
as over 200 cargo ships, trains and trucks.3 At the southern end of the property is where the cruise
ship terminal is located.
Currently, Concord Street and Washington Street between North Market and Hasell close on days
that a cruise is departing while passengers are present.
The cruise industry is regulated by both national and international standards. The cruise ship that
is based out of Charleston is a member of the Cruise Lines International Association (CLIA). The
International Convention for the Prevention of Pollution from Ships (MARPOL) was adopted on
1 Farnham, A. (2013,February 22). Port Cities Fret Over Taxpayer-Funded Terminals for CruiseShips.Retrieved
March 1, 2015.
2 SCELP. (2015,January 1). Retrieved February 1, 2015,from https://scelp.org/projects/view/98
3 Union Pier Concept Plan.(2010,September 1). South Carolina State Ports Authority. Retrieved January 1, 2014,
from http://www.scspa.com/UnionPierPlan/pdf/Union_Pier_Concept_Plan_Report_FINAL.pdf

2. 2 November 1972 at The International Maritime Organization (IMO) by CLIA.4 All ships that are
regulated under MARPOL are in compliance with all applicable international, federal, and state
requirements set by the EPA.5
Union Pier Concept Plan3
The Union Pier Concept Plan was approved by Charleston City Council on 15 March 2011. The
Union Pier Concept Plan in summery is as follows:
 Connects Charleston neighborhoods to the water
 Removes chain-link fence, industrial architecture, 200 cargo ships, trains and tracks.
Replaced with trees, landscape, and historic brick used throughout Charleston currenty
 Relocates passenger terminal northward on Union Pier
 Eliminates current street closings
 Restores shoreline
 Added green spaces
 Provides public and private use of the pier
 Creates jobs an economic vitality
Cruise Terminal Location & Layout: The cruise terminal is being proposed to relocate from the
southern end of the pier to the northern end where the terminal can accommodate building 322
which is currently a warehouse used to store goods in transit. Building 322 is a 240’ x 450’ or
approximately 108,000 square feet. The portion of land where the terminal is currently accessed
at the southern end will be made available for private development and public access.
Transportationsystem: Concord Street and Washington Street will have full access. Market Street
and other city streets will extend to the water. Freight delivery to the cruise ships is separated from
the Ground Transportation Area to improve safety and passenger convenience. Passenger vehicles
of loading and unloading occur within the Ground Transportation Area in front of the terminal
building.
Traffic Volumes: Many different types of vehicles access the cruise ship area to load and unload
passengers or service to ships. Different time slots are allotted to different types of vehicles for
different reasons. Semi Tractors will not be on site as passengers are arriving to the terminal to
created less congestion.
4 International Convention for the Prevention of Pollution from Ships (MARPOL). (2015, January 1). Retrieved from
http://www.imo.org/about/conventions/listofconventions/pages/international -convention-for-the-prevention-of-
pollution-from-ships-(marpol).aspx
5 Regulation and Compliance. Retrieved from http://www.cruising.org/regulatory/issues-
facts/environment/regulations-and-compliance

3. EPA Regulation
Cruise ships operate in every ocean worldwide, often with sensitive ecosystems. Cruise ships
provide passengers luxuries similar of hotels and resorts. As a result, cruise ships are highly
regulated by the EPA because of the great volume of wastes produced into the water and air. The
following are EPA regulations that cruise ships must be in compliance of.
The Cruise Ship Discharge Assessment Report
Assesses and regulates five primary cruise ship waste streams: sewage, graywater, oily bilge water,
solid waste, and hazardous waste.6 The Cruise Ship Discharge Assessment Report sets standards
for cruise ships waste.
SECTION 2 of The Cruise Ship Discharge Assessment Report
Sewage known as Black Water is known as human waste and regulated under The Clean
Water Act Section 312. Section 312 requires that vessels with installed toilet facilities be
equipped with operable marine sanitation device (MSD), certified by the Coast Guard.
Section 312 of the Clean Water Act also established procedures for the designation of no-
discharge zone for vessel sewage.6
MARPOL Annex IV requires ships to be equipped with either a sewage treatment plant, a
sewage comminuting and disinfecting system, or a sewage holding tank. The discharge of
sewage into the sea is prohibited except when the ship has an approved sewage treatment
plant or is discharging comminuted and disinfected sewage using an approved system at a
distance of more than three nautical miles from nearest land; or is discharging sewage
which is not comminuted or disinfected at a distance of more than 12 nautical miles from
the nearest land.7
SECTION 3 of The Cruise Ship Discharge Assessment Report
Sewage known as Graywater is wastewater from sinks, baths, showers, and laundry.
Graywater does not include drainage from toilets, urinals, hospitals, and cargo spaces.
Section 312 under the Clean Water Act applies here as stated before in regulating Black
Water.6
SECTION 4 of The Cruise Ship Discharge Assessment Report
Oily bilge water is a mixture of water, oily fluids, lubricants, cleaning fluids and other
similar wastes that accumulate in different sources such as engines, piping, and other
mechanical and operational sources found throughout the vessel.6 Oily bilge can be
managed by retaining onboard holding take and discharge later to a facility on shore or
6 United States Environmental Protection Agency. (200). Cruise Ship Discharge Assessment. Retrieved from
http://water.epa.gov/polwaste/vwd/upload/2009_01_28_oceans_cruise_ships_0812cruiseshipdischargeassess.pd
f
7 MARPOL Annex VI. (2015, January 1). Retrieved January 1, 2015,from
http://www2.epa.gov/enforcement/marpol-annex-vi

4. treated onboard with an Oily Water Separator (OWS) which can then be discharged
overboard as long as it is in regulation of MARPOL Annex IV.6
SECTION 5 of The Cruise Ship Discharge Assessment Report
Solid waste is garbage, refuse, sludge, trash and other discarded materials resulting from
industrial, commercial, individuals, businesses, and communities. Under MARPOL Annex
V requires governments to ensure the facilities at ports and terminals for the reception of
solid waste.6
Act to Prevent Pollution from Ships regulates discharge of all garbage within three miles
of shore and plastic cannot be discharged from the ship anywhere. Vessels are required to
record each discharge.6
Clean Water Act prohibits any person from discharging any pollutant from any point into
waters of the United States, which includes the territorial seas.6
SECTION 6 of The Cruise Ship Discharge Assessment Report
The regulations under the Resource Conservation Recovery Act establish criteria for
defining hazardous waste. Types of hazardous waste generated on cruise ships include:
photo processing waste, dry cleaning wastes, photocopying and laser printer cartridges;
used cleaners and paints; pharmaceuticals, fluorescent/mercury bulbs and batteries.6
As stated in the Clean Water Act section 311 prohibits the discharge of oil or hazardous
substances into or upon waters of the United States, adjoining shorelines, or into waters of
the contiguous zone.6 Section 311 also requires the person in charge of the vessel to
immediately notify the National Response Center if any hazardous discharge of oil or
hazardous substance is in violation.6
Hazardous waste generators are regulated based on the amount of hazardous waste is
produced each month.
Clean Air Act
Ocean vessels and large ships are regulated for their air emission.8 IMO creates global
requirements on air emissions; MARPOL Annex VI was adopted in October 2008 that set
new standards.2 All ships that are regulated under Annex VI are issued an International Air
Pollution Prevention Certificate. Annex VI establishes limits on NO emissions from cruise
ships with a power output of more than 130 kW.8
Demographics
The southeast region of the United States has decreased its SO2 air emission by 72% from 2000-
2014.9 In North Charleston SO2 emission meet the national standard for SO2 emission.6 In North
Charleston SO2 emissions are below the national standard.
The cruise lines that embark from Charleston meet the EPA requirements for cruise ships through
the Cruise Ship Discharge Assessment Report.10 Charleston County is not on the current
8 The Clean Air Act. (1990).
9 Regional Trends in Sulfur DioxideLevels. Retrieved from http://www.epa.gov/airtrends/sulfur.html
10 CruiseIndustry Meet and Exceeds Standards.Retrieved from http://www.port-of-
charleston.com/UnionPierPlan/pdf/CruiseIndustryMeetsExceedsStandards.pdf

5. nonattainment counties for all criteria pollutants.11 The standards are what the waste stream is and
how much is generated; what laws apply to the waste steam; how the waste stream is managed;
potential environmental impacts of the waste stream; and on-going actions that must be taken by
the federal government to address the waste stream.5
Alternatives
Charleston cruise terminal holds about 200,000 passengers which is considered small. The Union
Pier Terminal is not completely established and neither is the cruise market, therefore Charleston
still has the ability to shape its future with several alternatives.
1. Section 106 review. A section review 106 requires the evaluation of a proposed project
if it uses federal funding and affects historic resources on or eligible for the National
Register of Historic Places. This review will investigate and prevent any new
development from harming the historic district in question.12
2. There is no hard evidence on the exact environmental impact that the cruise line has on
the environment in Historic Charleston. Charleston should conduct and investigate
studies specifically on the impacts on the overall environment, economy, and
community of Charleston before making a court decision.
3. Charleston should implement appropriate taxes, fees and funds. A percentage of these
fees should be set aside to be applied directly to historic preservation and environmental
conservation.
4. Charleston should limit the amount of ships allowed to dock and depart. Limiting the
amount of ships will help benefit Charleston from being overrun by tourists and keep
environmental impact to a minimum
5. A buffer zone concept should be pursued by the port and city if problems with noise,
pollution and other emission threats are identified. This barrier could set up a no
discharge zone, or ships must remain from identified resources. Imposing a clear
standard will eliminate environmental and social problems.13
6. Charleston should collaborate with other ports in the region to strengthen ship
regulations, bargaining power and eliminate port competition to reduce cruise traffic
congestion.
11 Current Nonattainment Counties for All Criteria Pollutants.(2015). EPA Green Book. Retrieved from
http://www.epa.gov/airquality/greenbook/ancl.html
12 Protecting Historic Properties.(n.d.). Retrieved March 1, 2015,from
http://www.achp.gov/docs/CitizenGuide.pdf
13 Smith, S. (2003, September 1). Buffer Zones. Retrieved April 1, 2015,from
http://www.beyondintractability.org/essay/buffer-zones