Guidelines for Marine Artificial Reef Materials, Second Edition

the plan should provide a clear estimate of any anticipated funding shortfalls that would have
to be absorbed by states and/or their stakeholders. The federal government should also
prepare an Environmental Impact Statement (EIS) developed in accordance with the
National Environmental Policy Act (NEPA). The alternative that the federal government
provide grant funding to states to deal with MARAD and navy combatants when such
vessels released “as is where is” without any accompanying technical expertise and
assistance is not a preferred alternative.
• Recommend that as part of a coordinated national ship sinking plan, that the EPA, in
conjunction with the USCG and other agencies, develop a consistent and detailed artificial
reef vessel cleaning, preparation and inspection protocol. The Commissions should continue
to press for a comprehensive set of vessel cleaning and preparation standards that would
apply uniformly to both federally donated military vessels and civilian vessels procured from
the private sector.
• Recommend that the EPA provide a unified agency policy that addresses the issue of a
vessel sunk as an artificial reef as a “disposal” project versus a “continued use” project.
• Recommend that the EPA clarify issues related to environmental liability and damage, under
the Resource Conservation Recovery Act (RCRA) and Comprehensive Environmental
Response, Conservation, and Liability Act (CERCLA). For instance, is the MARAD or the
Navy, as originators of a material (ship) and any associated hazardous waste, responsible for
that material or is environmental liability and responsibility transferred by title to the
artificial reef permit holder
• If a federal large ship artificial reef program is developed, recommend that serious
consideration be given to placing some of these vessels as enhanced habitat in established
Marine Protected Areas (MPAs) in both the Gulf of Mexico and Atlantic Ocean, with
particular emphasis on supporting potential reef fish spawning aggregations and providing
deep-water outer shelf habitat enhancement at depth of 200-500 feet to such species as
snowy grouper, Warsaw grouper, speckled hind, gag, red snapper, amberjack, and other fully
or over exploited reef fish species. The artificial reef subcommittees of the interstate
fisheries commissions could coordinate with the NMFS and the Gulf and South Atlantic
Fisheries Management Councils to identify either existing MPAs or create new artificial reef
zones for these ships with Special Management Zone (SMZ) designations that would
accommodate complete or partial restriction of fishing gear. The authority to create new
SMZs or other MPAs rests with the Regional Fishery Management Councils and NMFS.
Any new SMZs or MPAs for such a project should be in an area that has very limited or
absent hard bottom habitat resources and is otherwise not utilized. This will prevent any
possible user conflict and should be supported by all.
• Recommend that if a national large military ship reefing program were established that
involved coordination through the interstate fisheries commissions, then any new
independent ship-by-ship individual applications to MARAD by state agencies terminate.
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