The City of Norfolk, the Virginia Pilots Association, the Virginia Tourism Authority, the Virginia Maritime Association, and the Cruise Lines International Association (CLIA) oppose any new regulations on the cruise ship industry which of course is their right. But a fair question to ask is – Is a primary driver for their opposition related to their economic self-interest?

I will admit that I too was initially motivated by self-interest when Princess Cruise Lines decided it wanted to come to Yorktown. Me and others saw this as character-altering and enjoyed living in a small village with a reasonable approach to tourism. But since learning about this industry, my motivation has changed. We worked hard on this petition with the help of others to affect positive change for port communities today and our environment for my children and future generations. In my opinion a thriving, healthy, stable long-term approach should be preferred to short term gains. Furthermore, moving to the sustainable long-term solution, need not be done disruptively. Phased approaches are effective and reasonable. For example, the Port of Seattle has used a phased approach to require shore power which can reduce emissions by as much as 80%.

Economic benefit is cited for not supporting regulations in this petition. I would like to point out that 120 ports around the world regulate this industry through scrubber bans and they still reap an economic benefit from the industry. Sensible regulation can co-exist with a stable sustainable economy – that indeed seems to be a role of the DEQ and its Air and Water Control Boards. Several economic arguments are presented. One discusses the over 700,000 jobs and the over $87B gross state product from ports in Virginia. I have not researched these numbers but find it hard to fathom that ocean-class cruise ship regulation will impact this economy negatively in any significant way. Today’s cruise ship industry is a relatively small player in the greater Port of Virginia, but it wants to expand. Therefore, now is the time to act to ensure managed growth that protects Virginians and our fragile ecosystems that our seafood industry is built upon.

A second economic argument is based on port fees and tourist dollars fueling a local economy. As stated in the petition, some will benefit from this industry, but these benefits are frequently exaggerated. Multiple economic studies are called out in the petition to refute this claim. One economist that studies the cruise industry stated in terms of dollars spent by tourists, cruise ship passengers spend less than any other class of tourist. The cruise line model is, to the extent possible, to keep the passengers well-fed on the ship and up-sell them. And being foreign-flagged ships, they pay little to no U.S. tax on their profits.  The claims of economic benefit forget to mention the cost of infrastructure and maintenance, and the cost of increased security and emergency services. They do not account for the health cost to residents in port communities related to respiratory ailments; they do not account for the damage to our waters and the impact on the seafood industry; and they do not account for their contribution to or the cost of climate change and the destruction it brings.

A recurring theme in the opposing comments is that the cruise industry is already regulated and that this petition is duplicative.  After examining a great deal of evidence, I do not feel that his perspective is accurate. The regulatory requests in this petition have not been fully addressed by MARPOL or the EPA. Furthermore, the petition cites papers, articles, documentaries, and examples of laws in other states that support the need for additional state regulatory action. A claim of redundancy is simply not justified.

CLIA’s certainly has self-interest at heart. They are a powerful lobby for the cruise industry. The petition regulation discusses the funding spent on lobbying to ensure maximizing profits. I am sure they know the law better than anyone, but what they are saying in essence is that Virginia has no authority over its waters. Currently, Virginia has no discharge zones which I believe fall under federal authority when petitioned by the state. If I am right Virginia at least has that mechanism. I suspect Virginia also has control of its ports, the security, and a future influx of passengers that can lead to over-tourism like in Sitka, AL, Bar Harbor, ME, Juneau AL, Venice, Rome and many other places in the U.S. and around the world that have instituted restrictions. They are saying we cannot require ships to plug into shore power even though they are using our ports and lands. What they are telling the Commonwealth is that they are a large multi-billion dollar foreign-operated enterprise, and Virginians and our elected representatives can have no say what-so-ever in what they do in Virginia. Again, they know the law better than us – but if what they are saying is true, something is seriously broken. This is exactly why they need to be managed before they expand in Virginia. The industry will spare no expense to put up a fight but ask then to purchase cleaner fuel and they will work tirelessly regardless of the cost. Here is a link to the GoFundMe page to fight cruise industry legal challenges in Bar Harbor: https://www.gofundme.com/f/8aeb5n-protect-acadia-from-cruise-ships . The town voted to limit this industry and they have face repeated legal challenges (which have held up to date). Do we really want to create a situation in Virginia where we have no control of this industry?

I am sure the organizations opposed to this petition are much more politically savvy than I am and have powerful lobbies or connections working at the state-level. Furthermore, the cruise industry has hired multiple lobbyists and a high-powered firm to support their efforts in Virginia. They are well-funded, and I am sure well-connected. The Protect Virginia coalition is  not but we have learned that when average citizens are made aware of the impacts of this industry, they want regulation. As of today, over 8300 people have signed Change.org petitions to stop the current practices of these large cruise ships in Virginia and over time this number is sure to grow. We are not a well-oiled firm with polished lobbyists, but I believe we have valid concerns supported by evidence. We may not have everything just right, but it is certainly not all wrong.  This is why I am asking the DEQ and its Control Boards to take this request seriously and not to dismiss it out of hand as powerful entities will certainly recommend. My hope, although possibly naïve, is the Virginia will lead the nation with a sustainable tourism approach for the benefit of all.

Thank you for your service to the Commonwealth.

Respectfully

Robert Hodson

Yorktown, Virginia