Minutes Exhibit B
Port Commision Special Meeting
of November 12. 2019
1
The Honorable Peter Steinbrueck
Commissioner, Port of Seattle
The Honorable Courtney Gregoire
Commissioner, Port of Seattle
The Honorable Fred Felleman
Commissioner, Port of Seattle
The Honorable Ryan Calkins
Commissioner, Port of Seattle
The Honorable Stephanie Bowman
Commissioner, Port of Seattle

Port of Seattle
PO Box 1209
Seattle, WA 98111

November 12, 2019

Dear Commissioners:

We, the undersigned organizations, oppose the Port of Seattle's proposed Terminal 46
cruise ship terminal due to the risk of significant climate disruption, marine pollution, and
public health impacts from cruise ship emissions.

Washington State prides itself on being at the forefront of climate leadership and,
consistent with this, the Honorable Commissioners of the Port of Seattle just last year
passed the Energy and Sustainability Motion. This motion directed the Port to develop
and implement initiatives that will reduce greenhouse gas emissions and enhance the
sustainability of the port. Expanding port infrastructure to support more cruise ships of
ever-increasing size is incompatible with the climate leadership this State is striving
toward and the spirit of the motion passed last year to reduce climate emissions.

The need to dramatically reduce global greenhouse gas emissions is both urgent and
real. In 2018, The United Nations Intergovernmental Panel on Climate Change warned
that the world had only 12 years, i.e. by 2030, to stem catastrophic levels of climate
disruption.' It called for radical and immediate action to decarbonize all sectors if
humanity is to avert this global crisis.

The maritime sector is produces more climate pollution than many major countries,
including Canada, Germany, Brazil, South Korea, and Mexico. If it were a country, it
would be the sixth largest emitter of greenhouse gases. Yet, despite the massive

' Miller, B.(Oct 8, 2018). CNN: Planet has only until 2030 to stem catastrophic climate chanqe, experts

warn

2
amount of climate pollution produced, the shipping industry was omitted from the Paris
Climate Agreement. If left unchecked, the sector is on track to be responsible for 17% of
global greenhouse gas emissions by 2050.

Cruise ships as they exist today are the antithesis of decarbonization. These massive
vessels are floating cities, and are almost wholly fueled with one of the dirtiest fossil
fuels on earth -- heavy fuel oil. Heavy fuel oil is a waste product of the world's oil
refineries, quite literally the bottom-of-the-barrel toxic sludge left over after other
petroleum products are distilled from crude. And cruise ships use a lot of fuel.

The world's largest cruise line operator Carnival Corporation & plc, which owns the
Holland America Line, Princess Cruises, and Carnival Cruise Line brands that frequent
Seattle, burned 3.3 million metric tons of fuel in 2018 alone.? In January 2020, despite
new fuel regulations coming into play, over 85% of its ships will continue to use heavy
fuel oil -- as the company has led the charge in installing 'emissions cheat' open loop
scrubber systems. In addition, nearly 54% of Royal Caribbean Cruises, Ltd., 41% of
Norwegian Cruise Line Holdings, Ltd., and 65% of MSC Cruises ships will continue
filling their tanks with the dirtiest fuel available.

Converting air pollution into ocean pollution with open-loop scrubbers is not a solution to
the enormous negative impacts of operating these behemoths, which function
essentially as glorified hazardous waste incinerators for the world's oil refineries.

Further, at a time when vessel traffic noise pollution is crippling the ability of critically
endangered Southern Resident Killer whales to hunt salmon,* and the pollutants that
have bioaccumulated up the food web are damaging their ability to survive and
reproduce, introducing more toxins and more mega-ship traffic into their habitat could
well push these iconic animals closer to the brink of extinction.

Finally, the human health risks associated with increased cruise ship traffic are real and
deeply concerning. Ship exhaust from all ship types poses serious risks to human
health globally. Seventy percent of all ship emissions occur within 250 miles of shore,
and winds carry the pollution far inland  exposing millions of unsuspecting people to
dangerous levels of particulate matter and other harmful toxins. The impacts on port
communities and coastal areas in heavily trafficked seas are even more dire. Globally,


2 Dolvan, T. & A. Harris (January 31, 2019). The Miami Herald: Cruise lines have
a solution for a new
clean fuel requlation. But is it the greenest option?
3 Crisp, W. (September 29, 2019). The Independent. Thousands of ships fitted with 'cheat devices' to

divert poisonous pollution into sea.
4 Mapes, L.V. (May 19, 2019). The Seattle Times: The Roar Below: How
our noise is hurting orcas'
search for salmon

3
an estimated 14 million cases of childhood asthma and 400,000 premature deaths are
attributed to ship exhaust exposure.'

The Port of Seattle already hosts two heavily used cruise ship terminals adjacent to the
densely populated downtown area. The new terminal would be situated next to the
sports stadiums and iconic Pioneer Square. There is a cynical irony of situating a
massive polluter next door to the places where elite athletes train and play their sports.

The exhaust from cruise ships is particularly problematic, and the open loop scrubbers -
or as the industry refers to them, 'Advanced Air Quality Treatment Systems" - are
intended only to reduce sulfur emissions. There may be some marginal co-benefits
regarding other types of air pollution (again, air pollutants from exhaust are then
discharged as water pollution), but these systems do not and are not designed to
address particulate matter and other health-damaging emissions.

Earlier this year, a Johns Hopkins Bloomberg School of Public Health professor
released a study he conducted of air pollution on the decks of Carmnival's subsidiary
brand ships. He found that air pollution on the decks behind the smoke stacks, while
the ships were underway, rivaled and at times far exceeded ultrafine and
nanoparticulate pollution measured in some of the world's most polluted cities, such as
Beijing, China and Santiago, Chile.

In addition, cruise ships emit on average three times the amount of climate-disrupting,
health-damaging black carbon particulate pollution as their cargo ship counterparts."

For the health of our children, our city, our oceans, our endangered orcas, and our
climate, now is not the time to add more infrastructure to bring more of these polluting
mega-ships to our shores.

We call on you to suspend the Terminal 46 cruise ship terminal selection process and
direct Port staff to develop and issue a revised Request for Qualifications (RFQ) and
Request for Proposals (RFP) that aligns with the goal of zero-emissions, zero-discharge
cruising  and that cruise ships companies like Carnival Corporation, Royal Carribbean
and Norwegian:

e  Stop the use of pollutant-intensive heavy fuel oil across their entire global fleets.




5 Roberts, K.B. (February
6, 2018). Phys.org: Study finds cleaner ship fuels will reduce childhood asthma
by 3.6 percent globally.
Kennedy, R. (January
24, 2019). An investigation of air pollution on the decks of 4 cruise ships.
7 Comer, B., Olmer,
N., et al. (2017). The International Council on Clean Transportation. Black Carbon
Emission and Fuel Use in Global Shipping 2015

4
e  Switch their current fleets to a proven hybrid technologies, and - in the
immediate short-term -- to cleaner marine gas oil with catalyzed diesel particulate
filters.

e  Commit to state-of-the-art, low-carbon, zero emissions battery or hydrogen fuel
cells propulsion systems in new ships.

e  Operate below key whale-related decibel frequencies in whale migration or
feeding habitats.

eo   Demonstrate a commitment to Free, Prior, Informed Consent of Indigenous
Peoples (FPIC), incorporating a social and racial equity lens in all decisions,
including infrastructure investments and expansions.

Sincerely,

Kendra Ulrich, Stand.earth
Stacy Oaks, 350 Seattle
Shannon Wright, Executive Director, RE Sources for Sustainable Communities
Kriss Kevorkian, Founder, Legal Rights For The Salish Sea
Thomas Meyer, Regional Organizing Manager, Food & Water Action
Kara Sweidel, Mosquito Fleet
Emily Martin, Our Climate
Harry Katz, Sunrise Movement Seattle
Benita & Darren Moore, Native Daily Network
Anne Miller, South Seattle Climate Action Network
Salish Sea Whale Sanctuary
Grace Hope, 350 Tacoma
Paul Chiyokten Wagner, Protectors of the Salish Sea
Deborah Steward, Climate Reality Project Seattle-King County Chapter
Dakota Case, Water Warrior Movement
Grace Stahre, Climate Action Families
Claudia Reidener, Redefine Tacoma
Blair Englebrecht, Puget Soundkeeper Alliance
Catherine Carey, Seattle Citizens Climate Lobby
Elizabeth Burton, People for Climate Action - Seattle
Lynn Fitz-Hugh, Faith Action Climate Team

CC:   Mike Merritt, Chief of Staff, Port of Seattle Commission
Aaron Pritchard, Policy Manager, Port of Seattle Commission

8 Gerretsen, |. (October 3, 2019). CNN Business: Shipping is one of the dirtiest industries. Now it's trying

to clean up its act

STAND
earth
The Case Against the Port of Seattle's
Proposed Terminal 46 Cruise Ship Terminal
The Urgency of the Climate Crisis and the Global Climate Impacts of Ships

We face an unprecedented climate crisis. Scientists
agree we are risking a period of
abrupt climate breakdown, a disaster that will threaten the future of our children and
grandchildren. Melting glaciers, rising sea levels, dying coral reefs, and collapsing
ecosystems are all warning signs that we are in the midst of a mass extinction of our
own making.

The urgent need for transformative climate action is real. The United Nations warned in
2018 that the world had only 12 years to avoid catastrophic levels of global warming.!
We have a decade or less to turn it around, reduce our greenhouse gas emissions, and
stop the expansion of the fossil fuel industry.

Bringing more cruise ships into the Port of Seattle is totally incompatible with a climate-
stable future and the Port's claims to prioritize sustainability.

Why Do We Object to Terminal 46?

1.  The Shipping Industry: A Major Polluter

If the shipping industry were a country, it would be the world's sixth largest polluter. By
2050just 30 years from nowthe International Maritime Organization (IMO) projects
that emissions will grow by between 50% and 250% if vessels continue to burn fossil
fuels unchecked.? Shipping is projected to produce as much
as 17% of global
greenhouse gas emissions.3

According to an April 2019 study by the Environmental Defense Fund, absent bold
leadership, the rising carbon dioxide emissions of international shipping and aviation

* CNN: "Planet has
only until 2030 to stem catastrophic climate change, experts warn"
2 IMO: Third IMO Greenhouse
Gas Study 2014
3 European Environment
Agency: Aviation and shipping emissions in focus

could consume nearly one-third (15 to 30 percent) of our remaining "allowable warming"
world's average
the amount of additional warming that can occur before the
of the
temperature surpasses 2 degrees Celsius above pre-industrial levels  by the end
century.#

Across the shipping industry - from cargo to cruises -- operators must rapidly
decarbonize, with complete carbon neutrality no later than 2050. Cruise operators are
the antithesis of climate action, as these companies are building bigger and bigger
vessels whose vast energy needs are filled with climate-disrupting fossil fuels. The
overwhelming majority of cruise ships burn one of the dirtiest fossil fuels on earth -
heavy fuel oil.

2.  Increasing Greenhouse Gas Emissions

The climate impacts of the cruise sector are enormous. As noted in a recent
publication:

Research has also found that cruise travel makes an outsized contribution to
climate changeand it begins before the ship leaves port. A single passenger
flying from New York to Vancouver or Seattle (the two busiest departure ports for
Alaska cruises) produces about a tonne of carbon dioxide. Double that if you're
flying round trip. Once on board the cruise ship, the climate cost soars. The
International Council on Clean Transportation (ICCT), a nonprofit research group
with offices around the globe, found even the most efficient cruise ships emit
three to four times more carbon dioxide per passenger kilometers than a jet

of
Building a third cruise ship terminal in the Port of Seattle will encourage the growth
the global cruise ship fleet and result in a net increase in global greenhouse gas
emissions. It will increase the amount of carbon in the atmosphere, support the
expansion of the fossil fuel industry, and move us further from decarbonizing the
shipping industry and addressing the climate crisis.

We're
Other cities are limiting the number of cruise ships, and Seattle must join them.
calling on the Port and the City to demand that cruise lines like Carnival Corporation

4 EDF: "What role do emissions from international shipping and aviation play in the global
international
climate?" and "Climate benefits of proposed carbon dioxide mitigation strategies for
shipping and aviation"
5 Hakai Magazine: Coastal Sciences and Societies. Leviathans in the Harbor.

& Bloomberg: "Cruise Ship Companies Are Finding it Hard to Quit Carbon" and Insider: "7 places
being ruined by cruise ships"

commit to sustainable zero-emission cruising if they want to continue doing business
here.

Seattle should not allow more cruise ships until they:

e  Stop the use of pollutant-intensive heavy fuel oil across the entire global fleet.


e  Switch current fleets to proven hybrid technologies, and -- in the immediate short-
term -- to cleaner marine gas oil with catalyzed diesel particulate filters.

oe   Commit to state-of-the-art, low-carbon, zero emissions battery or hydrogen fuel
cells propulsion systems in new ships."

e  Operate below key whale-related decibel frequencies in whale migration or
feeding habitats.

e  Demonstrate a commitment to Free, Prior, Informed Consent of Indigenous
Peoples (FPIC), incorporating a social and racial equity lens in all decisions,
including infrastructure investments and expansions.

The people of Seattle, of the State of Washington, and of the communities living along
the West Coast of North America deserve strong environmental and public health
leadership.  It is the Port of Seattle's responsibility to uphold these standards to
stabilize our climate and protect the millions of people living in this region.

3. An End to 'False Solutions'

The cruise industry has invented technical 'solutions' that pay lip service to sustainability
while allowing these companies to continue business as usual. We do not accept these
diversions as solutions.

e  Scrubbers So-called Exhaust Gas Cleaning Systems - otherwise known as
'scrubbers' and 'emissions cheat devices' - are flawed systems that have proven
unreliable. They fail to deliver the air pollution control for which they are
designed, and have repeatedly failed to meet water quality standards.
'Scrubbers' convert air pollution to water pollution, and divert poisonous pollution
from the air into the sea. These systems are only designed to reduce sulfur
emissions to the air. In other words, this technology is not designed to reduce the

7 Gerretsen, I. (October 3, 2019). CNN Business: Shipping is one of the dirtiest industries. Now it's trying
to clean up its act

output of the many other harmful pollutants in ship exhaust, including particulate
matter, heavy metals, and endocrine-disrupting chemicals.

Ships with 'scrubbers' still emit some sulfur oxides to the air, plus carbon dioxide,
nitrous dioxide, and particulate matter. A study published in June 2019 of cruise
ship emissions found that Carnival Corporation brands emitted 10 times more
SOX off the coasts of Europe than all of the 260 million European cars did in
2017 -- despite fuel sulfur restrictions and the use of scrubbers equivalent to
those used in the U.S. and Canada.? Converting air pollution into water pollution
and dumping toxic scrubber effluent into the world's oceans is unacceptable.
Cruise ship operators like Carnival Corporation that continue using heavy fuel oil,
the cheapest and dirtiest fuel available, and skate around stricter air pollution
control measures by installing "emissions cheat" scrubber systems, should not be
welcome in the Port of Seattle. We certainly should not be building yet another
terminal to accept more and larger cruise ships for the benefit of these polluting
corporate criminals!

The Panama Canal Authority recently joined other critically important countries
and ports, including China, Singapore, and the Port of Fujairah, in banning the
discharge of polluting scrubber effluent within its waters. We applaud the
individual ports, canals, and countries taking leadership by banning the use of
scrubbers. Scrubber effluent poses a threat to marine ecosystems the world
over, and as such, scrubbers should be banned by the Port of Seattle.

e  Liquified Natural Gas (LNG) LNG is a dirty fossil fuel thatwhen extraction and
transportation is factored inis as bad, if not worse, for the environment and
climate than the petroleum fuels currently in use due to persistent, unintentional
releases of climate-super-pollutant methane throughout the fuel cycle -- from well
to wake.?

4.  The Equity Case Against the Port of Seattle's Proposed Third Cruise Ship
Terminal

8 Transport & Environment: Luxury cruise giant emits 10 times
more air pollution (SOx) than all
of Europe's cars  study
TradeWinds: Panama Canal scrubber effluent ban draws opposing views

1% "On-road tests show
gas trucks up to 5 times worse for air pollution"
Trucks powered by liquified natural gas (LNG) pollute the air up to five times more than diesel
trucks, according to on-road tests commissioned by the Netherlands government. Surprising
how bad the NOx is in LNG-powered trucks: https://mailchi.mp/eeb/news-releaseon-road-tests-
show-gas-trucks-up-to-5-times-worse-for-air-pollution?e=dab1def1 1b

Benefiting financially while externalizing the environmental, public health and climate
costs of a new cruise ship terminal is immoral and unethical. It is an equity issue.

Cruise ships are purportedly a financial boon for the Port and City of Seattle -- though
residents of cities around the world that are already struggling with cruise passenger
overtourism may well argue that the negatives (such as significantly increased marine
and air pollution, soaring rents, strained public services and infrastructure, traffic
congestion, and local businesses shutting down to be replaced with international chains
and tacky souvenier shops) outweigh the supposed good." The actual economic
benefit of cruise ship passengers to the ports of call may be much lower than the Port of
Seattle believes, according to independent researchers.2

The Port argues that it will use the cash from building a new  and third - cruise terminal
with shore power and "green" buildings to upgrade Terminal 5 to be a state-of-the-art
cargo terminal.. If the current cruise traffic are contributing the millions of dollars to the
Seattle economy that the port states, then it should be applying the vast profits it
already has to upgrading existing terminals -- for both cargo and cruise ships.

Even if it is assumed that these cruise ships would follow the rules and regulations while
moored at the Port's imagined "green" cruise ship terminal or operating in the already
highly-regulated and restricted Salish Sea, the environmental and social impacts of
cruise ships are still externalized. Those paying these health and public service costs
are the residents of Seattle and the many small communities these ships will visit on the
way to Alaska after they leave this port. The vast majority of these communities do not
have the financial or regulatory resources of this wealthy city to cope with the increased
pollution and infrastructure issues that more mega-ship cruise traffic will cause.

Cruise ships are still permitted to use scrubbers in the Salish Sea, which means that
those with these cheat systems installed are burning this highly-polluting fuel here. The
combustion of heavy fuel oil results in significant releases of health-harming pollution --
including approximately three times the amount of soot (also called black carbon) and
shocking levels of ultrafine and nano particulate matter. A recent study from a Johns
Hopkins Bloomberg School of Public Health professor found levels of the latter
particulate matter on the decks of Carnival brand ships (Holland America, Princess, and
Carnival Cruise Lines) rivaled that -- and at times far exceeded -- measurements taken
in some of the world's most polluted cities, such as Beijing, China and Santiago, Chili.
Every ship in this study had scrubbers installed, which clearly shows that these systems
are wholly inadequate to protect the public from health-damaging pollution from cruise
ships. When traveling in Alaska, the soot settles on the ice and snow, darkening the

1 Ship Technology: A cruise
too far: how overtourism impacts the world's top destinations
See also, Juneau Empire: Cruise ship tourism is damaging our way of life
See also, The Guardian: A rising tide: 'overtourism' and the curse of the cruise ships
See also, Insider: 7 places being ruined by cruise ships
12 Kayahan, B., Vanblarcom,
B. & Klein, R.A. Overstating Cruise Passenger Spending: Sources of Error
in Cruise Industry Studies of Economic Impact. Tourism in Marine Environments, Vol. 13, No. 4, pp. 193
203. DOI: https://doi.org/10.3727/154427318X15417941357251

surface and increasing the absorption of solar radiation. This accelerates the melting of
glaciers and sea ice.

After cruise ships leave the Salish Sea, these ships dump vast amounts of scrubber
effluent, graywater, and treated sewage along the coast of Canada and Alaska."
Carnival Corporation was even illegally dumped untreated graywater in the beloved
Glacier Bay National Park while it was on probation for its seven felony convictions for
intentionally illegally dumping oily waste for nearly a decade.

In addition to health-harming air pollution and vast volumes of marine ecosystem-
damaging effluent dumping, these ships also emit significant levels of climate-disrupting
greenhouse gases. Carnival Corporation alone produces over 10 million tonnes of
C028 annually.

The Port of Seattle will be complicit in supporting the continued growth and expansion
of the fossil fuel industry and supporting the market for the oil industry's waste product -
heavy fuel oil - if it continues with its plan to build yet another cruise ship terminal to
accommodate even bigger cruise ships. The Port of Seattle would reap the financial
benefits, while knowingly and willfully passing the environmental and social costs on to
residents in Seattle and well as other port communities, marine life, and future
generations.'
While the Port of Seattle and the Commissioners' intentions are good and valid, this
proposed expansion reveals a myopic view of their responsibilities to Seattle and the
world. Building a new cruise ship terminal would make the Port of Seattle complicit in
exporting air pollution, water pollution, and climate pollution. This is an issue of equity
and justice.

5.  Size Matters: No Super-sized Cruise Ships!

The Terminal 46 cruise ship terminal is intended for the newest mega cruise ships,
which have capacities between 4,000 - nearly 7,000 passengers, over 220,000GT, and

13 Vard Marine, Inc. GREYWATER GENERATION ESTIMATES FOR THE BC COAST.
http://d2akrl9rvxI3z3.cloudfront.net/downloads/greywater_generation_estimates_for_the_bc_coast_report
pdf
See also UNDERSTANDING THE IMPACTS OF CRUISE SHIP DUMPING IN SOUTHEAST ALASKA
https://www.seacc.org/cruise_ship_impacts
4 Miami Herald: Federal judge threatens to temporarily block Carnival ships from docking at U.S. ports.
https://www.miamiherald.com/news/business/tourism-cruises/article229069589.html
15 According to Carnival Corporation disclosure, in 2017, the
company produced: Direct (Scope 1) GHG
Emissions= 10,642,209 Tonnes CO2e. Energy Indirect (Scope 2) GHG Emissions - Location-based =
45,437 Tonnes CO2e. Energy Indirect (Scope 2) GHG Emissions - Market-based = 43,589 Tonnes
CO2e. According to Carnival Corporation disclosure, in 2018, the company produced: Direct (Scope 1)
GHG Emissions= 10,647,189 Tonnes CO2e. Energy Indirect (Scope 2) GHG Emissions - Location-based
= 50,413 Tonnes CO2e. Energy Indirect (Scope 2) GHG Emissions - Market-based = 48,153 Tonnes
CO2e.
18 Forbes: As Arctic Cruise Tourism Booms, Are The Risks Worth It?

are up to 1,188 ft long and 238 ft high.. Inviting more and bigger cruise into Puget
Sound and Elliot Bay is the last thing our orcas, our oceans, and our climate needs."

6.  Seattle Already has Two Cruise Ship Terminals

Seattle does not need a third cruise ship terminal in Seattle. Cruise ships already have
two terminals in the port: Terminal 66 and Terminal 91. Piers 66 and 91 hosted
approximately 213 cruise ships between April and October 2019. Seattle had over one
million cruise ship passengers in 2017, and 2018 and 2019 were projected to see 1.1
million passengers and 1.2 million passengers respectively.

7.  Carnival Corporation: Criminal Polluters.

We oppose doing business with egregious polluters like Camival Corporation. As the
largest cruise ship company in the world, with a fleet of more than 100 cruise ships,
Carnival's nine brands control over forty percent of the global market'. Carnival ships
collectively burn over 2 million tons of heavy fuel oil (HFO) every year. Heavy fuel oil
(HFO) is a waste product of the oil industry. HFO is the thick, bottom-of-the-barrel
sludge left over after crude oil is refined. It is one of the dirtiest fuels in the world, and is
considered toxic waste on land.

If we consider HFO a toxic waste on land, why do we tolerate Carnival burning HFO at
sea? Carnival cruise ships are polluting our air, our water, our climate, and our
communities.

Friends of the Earth awarded Carnival Corporation brands an overall grade of F, based
on the company's performance on sewage treatment, reducing air pollution, water
quality compliance, transparency, and criminal violations.'





7 The Guardian:
The world's largest cruise ship and its supersized pollution problem
18 https://cruisemarketwatch.com/market-share/ Statista:
Cruise Industry Market Share Worldwide
'9 Friends of the Earth Cruise Report Card

Sewage         Air Pollution         Water Quality                      Criminal      2019 Final
Cruise Line
Treatment         Reduction           Compliance       Transparency    Violations       Grade

Disney Cruise Line           A               D+                  A                A                          A-

Norwegian Cruise           A              D-                  A                F                  '        C-
Lines

Celebrity Cruises    |       A               D-                 N/A               F                          D+

Silversea Cruises            D                F        |         A                F                           D

Royal Caribbean Int'l         A                F                 N/A        |      F                           0
|
Regent Seven Seas          C                F                  A                F                           D
Cruises

Oceania Cruises            Cc                F                  C+                F                          D-
|                                  |
MSC Cruises               C-               F                 N/A               F      |                    F

Seabourn Cruise Line         A                F                  B+                F             v      |      F

P&O Cruises               D-               F                 N/A               F             v            F

Costa Cruises              F                F                 N/A               F             v            F

Princess Cruises            8               Lo                  A-         |      F             v            F

Holland America Line        B+               D                  A                F             v            F

Cunard Cruise Line          A                F                 N/A               F             v      |      F

Crystal Cruises             F                F                 N/A               F                           F

Carnival Cruise Lines         F                D                  A                F             v            F
https://foe.org/cruise-report-card/

Even more concerning, Carnival Corporation is currently on criminal probation in the US
for illegally dumping oily waste into the ocean and covering it up for nearly a decade.
The criminal activity was only revealed after a whistleblower came forward to report it to
the UK authorities. Carnival has since also pleaded guilty to violating that probation by
dumping more wastewater and the intentionally dumping plastic waste into the ocean.
The Port of Seattle should not do business with convicted felons like Carnival
Corporation.

We want Carnival Corporation to put the planet before their bottom line. As a critical first
step to rehabilitating the company's dismal reputation, we call on Carnival to switch from
heavy fuel oil (HFO) to relatively cleaner-burning marine grade oil (MGO).

Further, the Port should prohibit or disqualify any of the three Cruise Ship Consortiums
that include companies with criminal records, and should require all qualifiers to
disclose any and all violations of criminal federal, state, and local laws and regulations
occurring within the last ten years, as well as any and all civil liabilities and lawsuits of

the parties involved. Any consortium involving Carnival Corporation should be
disqualified.
https://content.qovdelivery.com/accounts/WASEATTLEPORT/bulletins/242ca14

8.  Impact on Whales

In the Salish Sea, the population of Southern Resident Orcas is in serious decline. Just
seventy-three orcas remain in Puget Sound, a 35-year low.2! Though ferries and other
vessel traffic may play a bigger role, it cannot be denied that the tremendously loud
noise from cruise ships are certainly a contributing factor to the Orcas' decline. Among
other factors, engine noise from massive cruise ships inhibits their ability to
communicate and echolocate. They're cut off from each other, and effectively blinded by
the sound.??

Further, upon passing through the Strait of Juan de Fuca, cruise ships begin
discharging thousands of gallons of treated sewage, greywater, scrubber effluent, oily
bilge water, solid waste, and hazardous waste into the ocean, all of which have a
negative effect on the Orcas' habitat.

9.  The Port needs better outside overview and accountability.

The objective of any public process should be to empower the public to participate in
government integrity, accountability, and transparency in our political system. No public
agency should be policing itself. For the sake of transparency and accountability, the
SEPA (State Environmental Policy Act) process should be transferred to WA
Department of Ecology.

10. Regional Tribes are entitled Free, Prior, and Informed Consent

The principles of Free, Prior and Informed Consent (FPIC) require engaging in
government-to-government consultation with regional tribes, including obtaining Free,
Prior and Informed consent from the Duwamish, as the port is within this nation's
ancestral lands.

20 "Felons of the Seas: Smoke, Mirrors and Obfuscation,"
Yellow Tourism: Crime and Corruption in the
Holiday Sector (ed. A. Papathanassis, S. Katsios, R.N. Dinu). Pp. 3-17. Cham, Switzerland: Springer
Nature. https://www.springer.com/gp/book/9783319946634
21 Seattle Times: Two More Puget Sound Orcas Predicted
To Die In Critically Endangered Population
https://www.whaleresearch.com/july2019population
22 The Guardian: Ships Noise Is Serious Problem for
Killer Whales and Dolphins Report Finds
https://www.ncbi.nlm.nih.qov/pmc/articles/PMC4800784/
https://www.ncbi.nlm.nih.qov/pubmed/19173379/

The Port of Seattle staff have ignored the Port Commissioners' March 12, 2019
guidance to acknowledge historical and cultural roots of the region in any terminal
development. The department has chosen not to engage in government-to-government
consultation with regional tribes in a way that accounts for the impacts of the proposed
cruise terminal expansion, and has failed to honor tribes' waterfront heritage.

11.Public health impacts

The long-term health impacts of increasing the number of large cruise ships visiting
Seattle has not been sufficiently investigated. Thousands of people live and work within
a mile of Terminal 46, including a half dozen schools. Diesel fumes are rated as a level

one carcinogen by the World Health Organization (WHO), in the same category as
smoking tobacco. Cruise ships pump out toxic fumes from their engines that can cause
permanent damage to children's lungs. Even if shore power is provided, Seattle
residents are still exposed to cruise ship emissions as the vessels enter and leave port.
The amount of air pollution from one of these new mega-ships has not yet been
calculated, but even these ships' smaller counterparts release a staggering amount of
pollution. To put this into context, a mid-sized cruise ship emits as much pollution as a
million cars.

Air pollution in the US alone has been linked to over 30,000 deaths and impacted
lifespans.?* It causes permanent lung damage in children, issues with dementia and
cognition, untold suffering for people with asthma, birth defects, heart attacks and
strokes, chronic and acute bronchitis, and cancer.

Exposure to shipping exhaust has been attributed with an excess 60,000 annual excess
deaths globally. In the U.S., Seattle is already the most heavily impacted city. A recent
study by the International Council for Clean Transportation found that:  " . .within the
United States, the areas of Seattle and San Francisco lead in terms of early deaths per
100,000 residents (1.8 and 1.6), or more than double the global average, due to air
pollution from the ports of Seattle, Tacoma, Oakland, and San Francisco."?

Dispersion modeling should be commissioned by the Port and conducted by a technical
expert to understand the potential exposure of local residents to cruise ship pollution,
prior to any decision regarding an additional cruise terminal being made.

12. Cultural impact

23 CBC A cruise ship's emissions
are the same as 1 million cars: report
24 Science Daily Air pollution in US associated with
over 30,000 deaths and reduced life expectancy
25 The International Council for Clean Transportation Silent but deadly: The
case of shipping emissions

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Once these cruise ships leave the port of Seattle, these mega-vessels will travel to
locations around the world, but the majority of them travel north -- up the British
Columbia coast to Alaska. Many of the ports of call are small communities, where the
ships will unleash a flood of tourists, swamping local infrastructure and create a host of
social and cultural issues -- in addition to pollution and whale strikes.?.

For example, in the small villages on the Cinque Terre coast of Italy, public bathrooms
are scarce, so touriststhe bulk of whom arrive on cruise shipshave been caught
"urinatingor worsein... gardens and in doorways." The Italian government has since
decided to drastically reduce the number of tourists allowed to visit the islands on cruise
ships.2" When major cities like Seattle tacitly endorse the building of ever-larger cruise
ships, they should consider the downstream effects on the smaller, less well-funded
communities those ships will eventually visit.

13.Labor standards

An investigation by the ITF (International Transport Workers Federation) has found
serious abuses of workers' rights on board many major cruise ships including Carnival
Corporation, Royal Caribbean, P&O Princess Cruises (a part of Carnival Corporation &
plc) and Malaysia's Star Cruises.? Wages can be as low as US$45 per month for
waiters and waitresses and contracts are short and insecure. An ITF survey of 400
cruise ship employees showed that 95 percent are working seven days a week with
time off restricted to turnaround in port. Over a third surveyed worked up to 12 hours a
day, while just under a third worked up to 14 hours. Holidays are not included during the
contract period. Instead, workers return home and wait for two or three months for the
next contract. Moreover, the medical care of employees on cruise ships is often
substandard; Michael Guilford, who has practiced maritime law for more than 30 years,
says that cruise lines penalize doctors who arrange for too much shoreside care. Injured
employees are routinely given painkillers and instructed to keep working.?



%6 Hakai Magazine: Coastal Sciences
and Societies. Leviathans in the Harbor.
2" The Guardian: Italy To Impose Limits On Visitors To Cinque Terre With Tourist Ticket System

28 Sweatships: What it's really like
to work on board a cruise ship.
https://waronwant.org/sites/default/files/sweatships.pdf
29 https://story.californiasunday.com/below-deck

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In Conclusion

We urge the Port of Seattle to:

Immediately suspend the Terminal 46 cruise ship terminal selection process.

Immediately suspend the Terminal 46 cruise ship terminal SEPA review.

Immediately disqualify any consortiums that include environmental felon Carnival
Corporation and any others consortiums that include any companies with a
history of environmental crimes. The Port of Seattle should avoid doing business
with convicted environmental criminals.

Issue a revised Request for Qualifications that aligns with the points and
principles made above, including:

Consultation with the Duwamish tribe and a requirement for free, prior and
informed consent prior to any Consortium or the Port moving forward with
the cruise terminal expansion.
The responsibility of the Port of Seattle to not only address the global
climate by reducing its own Scope 1 GHG emissions, but also the Scope 3
GHG emissions that will result from increased cruise passenger flights into
Seattle and from the mega cruise ships once these vessels depart from
the Port. It is an inescapable reality that increasing port capacity for super-
sized cruise ships will increase both upstream and downstream GHG
emissions.
Cruise ships' air, water, and climate pollution along the coast of British
Columbia and Alaska once they leave the Salish Sea.
Additional health impacts and costs for Seattle residents and those that
will be impacted in the ports of call these ships will visit.
The equity, moral, and ethical implications of more cruise ships.
Measures to address the dismal labor conditions on board cruise ships.

For more information, please contact:

Jim Ace
Stand.earth
JimAce@Stand.earth



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