Guidelines for Marine Artificial Reef Materials, Second Edition

experts undertaking the demolition is recommended along with USCG coordination.
Potential impacts to marine mammals, turtles, and fishes should be considered.
• Develop and implement cleaning standards for pollutants known to occur on ships. Require
testing for PCBs on boats and ships constructed prior to 1975 (when PCB manufacture
ended). Require an asbestos inspection. Identified asbestos that is secured or encased may
be left undisturbed, and in place prior to sinking (EPA does not consider asbestos a hazard
in the marine environment but it can be a health hazard when airborne. Since sinking of a
vessel is considered structural modification of a facility, ships to be sunk as artificial reefs
fall under requirements for asbestos inspection).
• Develop and coordinate inspection standards with EPA, USCG, and affected state regulatory
agencies.
• Liability issues must be recognized and addressed by permittees who are required to provide
long-term responsibility for materials on their permitted artificial reef sites, including ships.
Demonstration of this responsibility could include liability insurance, posting a bond or other
indemnifying instrument to ensure resolution of liability issues associated with the towing,
cleaning and sinking of ships on state submerged lands. This liability includes damages
caused by movement of the materials during storm events.
• Use the consistency process under the Coastal Zone Management Act to ensure vessels
constructed as reefs in permitted sites in the Exclusive Economic Zone (EEZ) are held to the
same standards as vessels placed in adjacent state waters.
• Reassess all constraints that may be placed on sinking a ship (i.e. minimum depth, distance
from shore, complexity of vessel that may require additional technical assistance, stability
requirements, vessel orientation, cost, time involved in project, etc.), and decide early on
whether one or more of these constraints will result in a final outcome that will not be
successful in achieving the project’s objectives.
Federal Vessel Reefing Program Development Recommendations
• Gulf and Atlantic Marine Fisheries Commissions and Councils should investigate possible
federal programmatic alternatives to the multi-year drawn out process of securing piecemeal
individual MARAD vessels under current circumstances, that result in very high
expenditures per vessel.
• Recommend if a federally sponsored large-scale military ship-sinking program becomes a
reality, then efforts to coordinate such a program should occur at the national level through
the ASMFC and GSMFC. This would avoid interstate competition for vessels and
preferences given to those states that have more substantial reef funding resources than
others.
-39-