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Floating Cities Navigating Environmental Compliance in the Cruise Industry

Smith, Daniel E, IIIJones, Denita L.  ; Chicago Vol. 35, Iss. 4,  (Spring 2021): 28-31,34.

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The challenges of environmental compliance can be complex for any facility at any specific location on the globe. For example, consider the ACME manufacturing facility located in Anytown, USA. ACME must identify local, state, and federal environmental compliance requirements and may also need to mitigate potential common law tort liability risks associated with its facility. These multijurisdictional requirements and risks can sometimes overlap, and it is not uncommon for them to be vague or even conflict with one another. But what if the ACME facility were not stationary? What if Anytown, USA, was floating around the world on the "Seven Seas"? The compliance requirements would then be ever changing. The requirements might be in different languages or difficult to find and understand. The boundaries between various jurisdictions might not be clear. Companies in the cruise industry actually are faced with such dynamic multijurisdictional challenges as they operate multiple "floating cities" spread all over the world at any given time. Just like the residents of a city, the passengers of a cruise ship need electricity for illumination, entertainment, heating, cooling, and dining. However, it is not only the passengers who need electricity; the general operation of the ship also requires electricity. Most of the electric power in the United States is produced by combusting fossil fuels, and the same is true on cruise ships. Whether electric power is generated on land or at sea, the resulting air emissions are subject to a wide range of regulations and control systems.

City residents and cruise ship passengers also generate significant volumes of sewage (referred to as "black water") from toilets and grey water from sinks, showers, and laundries. A 2010 Congressional Research Service (CRS) report found that during a typical one-week voyage, a large cruise ship (with 3,000 passengers and crew) is estimated to...