“Finally, I cannot overemphasize the need to protect the Belize Barrier Reef and the importance of putting on a legislative basis the assessment of damages for injury to it.”
Dr Abdulai Conteh, Chief Justice of Belize, April 2010
Belize currently has no oil spill response mechanism in place to effectively deal with a spill event at sea. The National Emergency Preparedness Plan for Oil Spills (NEPPOS) was endorsed by the Cabinet circa 1995-19961 and at the time of preparation of this paper the tangible assets necessary for the actual physical response at sea were virtually non-existent.
This paper will examine the issue of oil spill preparedness and response in the Belizean context given Belize’s pristine marine environment (including its Barrier Reef – a world heritage site) and the significant risks posed to it from ship-based sources. It will discuss Belize’s obligations under the various conventions to which it is a signatory and highlight those conventions to which it is not a party but which would provide added protection if it were to become a signatory thereto.
The existing threats to the preservation and protection of the marine environment will be examined with a view to understanding the burdens that the Government of Belize faces in preparing for such threats and, finally, the paper will examine the challenges to establishing an effective oil spill response mechanism bearing in mind national limitations.
There are many sources of oil pollution but for the purposes of this paper, the focus will be on potential spills from international shipping given the real and present danger to Belize from this ubiquitous but necessary activity.
Pursuant to articles 3 and 57 of the United Nations Convention on the Law of the Sea (UNCLOS), Belize can claim as much as 12 miles of territorial seas and 200 miles of exclusive economic zone, respectively. Though the said provisions of the convention allow Belize to significantly expand its territory “such potentially large extensions of sovereignty for a small state can not only enrich [Belize] but also burden it with the responsibility”2 to properly manage, preserve and protect it.
Article 192 of UNCLOS imposes a duty on Belize “to protect and preserve the marine environment.” This obligation is extremely wide, implicitly requiring the Government of Belize to provide protection for the marine environment from a myriad of threats – both real and perceived – within the areas of its territorial seas and exclusive economic zone as claimed by it pursuant to its rights under the said Convention.
Article 194 goes further, providing that states shall “take all measures consistent with this Convention that are necessary to prevent, reduce and control pollution of the marine environment from any source,...”
In addition to the foregoing, by virtue of her ascension to the Cartagena Convention and its related protocols, Belize has an obligation to provide an adequate spill response mechanism. Article 3.2 of the Protocol Concerning Co-operation in Combating Oil Spills in the Wider Caribbean Region, states:
The Contracting Parties shall, within their capabilities, establish and maintain, or ensure the establishment and maintenance of, the means of responding to oil spill incidents and shall endeavour to reduce the risk thereof. Such means shall include the enactment, as necessary, of relevant legislation, the preparation of contingency plans, the identification and development of the capability to respond to an oil spill incident and the designation of an authority responsible for the implementation of this Protocol.
Concomitant with Belize’s international duty to protect and preserve its marine environment is its direct obligation to its citizens. Belize, it is said, has about 44% of its territory under some form of protection, boasting an impressive 614 square miles of marine protected areas.3
Many Belizeans rely on the maritime spaces for their livelihood, recreation and sustenance. In addition, the reef provides significant levels of coastal protection. The World Resources Institute estimates that Belize’s Barrier Reef System contributes about US$395 – US$559 million in direct and indirect benefits to Belize per annum.4
It stands to reason therefore that any spill event that impacts on Belize’s marine ecosystem will have a knock-on negative effect on the economy. In the circumstances therefore, even in the absence of an international obligation to do so, it behooves the Government of Belize to put in place all necessary measures to protect and preserve its marine environment.
The threats to Belize’s marine environment are manifold but the single largest threat comes from shipping. This view is by no means universal and the World Wildlife Fund, for example, lists shipping as the third greatest threat to Belize’s Barrier Reef after climate change and fishing.5
Nonetheless, with over 90% of Belize’s trade (by volume) moving by sea, there can be no doubt that shipping is vital to Belize’s economic wellbeing. However, as critical as it may be, shipping presents direct and significant risks to the marine environment as a consequence of groundings, the discharge of ship generated wastes (garbage, sewage and hazardous waste), air pollution (SOx and NOx), oil spills, et al.
The threat of ship-source pollution comes primarily from two main streams: the ship’s bunkers and the ship’s cargo.6 This is important to note because international conventions dealing with civil liability for ship-source oil spills treat them as such.
In 2009 Belize saw a total of 655 ship calls by 208 individual ships.7 A single ship, depending on its size and type, can pose grave risks to Belize’s marine environment. To put this into perspective, let us examine in a very cursory fashion two ships that visit Belize on a frequent basis, the M/V Caribe Mariner and M/S Carnival Valor.
In 2009 the M/V Caribe Mariner (a small container ship) made a total of 38 visits to Belize carrying on average 74 metric tons of IFO 180.8 This translates into approximately 20,796 gallons of fuel per visit or a total of more than 790,000 gallons that year. Substantial quantities in its own right, but contrast that with the M/S Carnival Valor (a large cruise ship) which made 49 visits to Belize in 2009, carrying on average 2047 metric tons of IFO 380;9 this translates into a total of 557,486 gallons of fuel per visit or over 23. 7 million gallons during 2009.10
Noteworthy is the fact that, in addition to fuel for firing their engines, ships also have on board other hydrocarbons that are carried in significant quantities, such as marine diesel oil and lube oil, for use in generators and other machinery. By way of example, on October 26, 2009 when M/V Caribe Navigator11 called on Belize she had on board 9,277 gallons of marine diesel oil and 8,311 gallons of lube oil, quantities that if spilt would be near the upper limits of the Tier One threshold as defined by the Department of the Environment.
At this juncture one should be mindful that, even though ships often carry large quantities of oil as bunkers, it is unlikely that they will spill all that fuel as a result of an accident since bunkers are stored in several tanks – depending on the size and type of ship it could be in as many as eight to ten different tanks. The most likely scenario is that the ship might rupture one or two tanks thus losing the contents therein but it is very rare that ships lose all the bunkers carried on board. Even when a ship sinks, bunkers in properly sealed tanks can remain contained for a long time.
Given the profile of ships currently calling on Belizean ports it is safe to say that in the event of a spill resulting from the rupture of a single tank, Belize could immediately be faced with a Tier Two oil spill. The national oil spill response mechanism must therefore take this into consideration.
Currently, the NEPPOS defines three levels of oil spills, consistent with the tiered approached employed globally:12
|Tier One||1,000 – 10,000 gallons||polluter’s responsibility|
|Tier Two||10,000 – 100,000 gallons||Government assistance needed|
|Tier Three||>100,000 gallons||Government/external assistance needed|
In as much as there is a serious risk of marine pollution from ships’ bunkers, Belize has not yet signed on to the International Convention on Civil Liability for Bunker Oil Pollution Damage, 2001 (The Bunkers Convention).
Belize cannot therefore claim to be building a credible spill response mechanism without becoming a signatory to the Bunkers Convention given the kind of exposure it faces from ships’ bunkers. The Government of Belize would be well advised to sign on to this convention with dispatch since it provides an international framework “to ensure the payment of adequate, prompt and effective compensation for damage caused by pollution resulting from the escape or discharge of bunker oil from ships”.13
The other stream of ship-source pollution comes from oil being carried as cargo. According to the Statistical Institute of Belize, Belize Natural Energy exported 53.58 million gallons of crude in 2009, an 11.5% increase over 2008.14 During the same period, according to the Ministry of Finance (quoted in the Amandala newspaper), ESSO imported 32,200,658. 7 million gallons15 of fuel, predominantly refined products.
These cargoes were transported, without incident, by a total of 29 tankers making a total of 60 port calls over the course of the year. Global statistics will inform that tanker ships are by far the greatest cause of ship-source pollution and according to the International Tanker Owners Pollution Fund (ITOPF), during the 1990s total spills from tankers alone was 1,136,000 tons (314,672,000 gallons).16 Though that figure decreased significantly during the period 2000-2009 it still remains a significant source of pollution at 206,000 tons (57,062,000 gallons).
As high as the risks might be from ships calling directly at Belizean ports, there are an even greater number of ships that sail through or near to Belize’s territorial waters en route to nearby ports in Guatemala and Honduras.
In 2007 an estimated 3,958 ships sailed to the ports in the Gulf of Honduras region, including 307 tankers.17 This is significant maritime traffic by any measure and it has led the World Wildlife Fund to declare that the “steady traffic of oil tankers – transporting more than 1 million tons of crude oil a year from the port of Santo Tomas del Castillo in Guatemala – puts the reef at constant risk of a catastrophic oil spill.”18
Though Belize has been fortunate thus far it cannot con tinue to pretend that the risks do not exist, equally there is also no need for alarm. Belize must take a sober, proactive and sensible approach to these risks and use this time to prepare, to build its defences and to develop a mutually beneficial relationship between Government and industry.
Mistakenly, many people are of the view that a couple thousand feet of booms, a flotilla of boats and a few dozen skimmers are the sole basis for a sound oil spill response mechanism. They could not be further from the truth. A robust, well thought-out response mechanism has to be built on four key pillars: legal, financial, diplomatic and scientific. It must be pointed out here that these areas are not mutually exclusive and often times the lines between two or more of them will become blurred, particularly during a crisis situation.
The creation of a legal framework to effectively deal with oil spills must be the starting point for building a credible response mechanism. In this regard Belize is lacking. Though Belize has an Environmental Protection Act (EPA), it is by and large terrestrially focused. There have been some amendments that address marine environmental pollution but as well meaning as that exercise was, it did not go far enough. Very little consideration was given to the relevant international maritime instruments to which Belize is a party, indicating a need for greater appreciation of the various protocols, practices and dynamics of the world of shipping.
A sound legal framework must proscribe the introduction of oil into the marine environment (whether accidental, deliberate or by negligence). It must be proactive, laying out measures to prevent pollution from ships in the first place. This approach suggests that the legal framework must transcend the EPA and embrace some of the functions of the Belize Port Authority and the Belize National Coast Guard as they relate to maritime safety issues such as vessel traffic management, an improved port state control inspection regime, and the establishment of sea lanes, amongst others.
The legal framework must further provide for a single person to lead the response mechanism and that person must have full statutory authority to make decisions designed to mitigate or avoid a catastrophe. Clear legal roles must be assigned to both the public and private sectors and the necessary technical skills must be available for deployment.
Provisions must also be made for mandatory contingency planning for ships, ports, offshore drilling facilities, shore-side storage facilities, etc. Cleanup and remediation processes must be provided for and a transparent cost recovery methodology is a must.
Importantly, the legal framework must provide a reasoned, tested and sensible methodology for assessing environmental and consequential damages caused by oil pollution. This cannot be overstated since in the absence of statutory guidance to the Courts, the aggrieved parties might not be able to fully recover their losses.
In his written judgment handed down in the Westerhaven trial,19 the learned Chief Justice, Dr Abdulai Conteh (as he was then) lamented the poor statutory footing upon which the Court must stand in relation to assessing environmental damage, he stated: “Regrettably, there is no comparable legislation in Belize to that of the USA on which the HEA is based or the Australian legislation regarding its Great Barrier Reef.”20
The US legislation to which the CJ referred to above is the Oil Pollution Act of 1990 (OPA 90), a revolutionary piece of legislation (emanating from the Exxon Valdez disaster) that is both preventive and remedial in its approach. OPA 90 apart from prescribing preventative measures also provides an excellent cost recovery methodology providing for inter alia the recovery of:
The time is now, and as a matter of urgency, for Belize to pen a marine environmental protection act that address contemporary maritime environmental protection issues having due regard to Belize’s convention duties and global best practices. To serve Belize’s long term needs the Act must be both preventive and remedial in its approach, thus a similar legislative foundation as OPA 90 would be a good starting point.
There is no universal measurement with respect to the cost of oil spills but the recent BP experience has clearly demonstrated that it can be very expensive. Though the historic cost for a single ship-source oil spill has not been anywhere near the magnitude of the cost of the BP spill, a ship-source spill can still cost a tidy sum.
Each spill is unique and the true cost of a spill would depend on a number of factors such as, cause of the spill, type of oil spilled, quantity of oil spilled,21 (including rate of discharge), location of the spill, prevailing weather and the management of the response mechanism.22
The immediate cost of the spill would be associated with the removal cost. How much will it cost to respond to a spill, contain the oil, recover it, dispose of it and remediate the physical environment to the extent possible?
No matter the actual dollar figure someone is going to have to meet that upfront cost, but whom? Where will the money come from to clean-up the spill and settle damages? Though various international instruments to which Belize is a party do provide for financial compensation they do nothing to address the immediate financial needs of responding to a spill.
Belize currently has nothing in place to meet the immediate costs of oil spills. The NEPPOS does require the polluter to address Tier One spills but there is no legislative framework spelling out what financial safety net must be in place by those transporting or storing petroleum products. Tier Two and Three spills are to be addressed with Government’s and if necessary external support, but again, the question needs to be asked, where is the Government going to get the money to pay for the initial response?
Invariably, ships coming to Belize are likely to have the requisite certificate of financial responsibility pursuant to the CLC 92, the Fund 92/03 and the Bunkers Convention, but it will take some time for the “paper work” to be completed before funds become available; legal manoeuvrings aside.
As can be expected, any vessel causing a spill will reserve all its rights and the subsequent legal manoeuvring can tie up civil claims for months if not years. But while the legal battles take place somebody has to attend the spill. Therein lies the rub!
In 2009, in an attempt to correct this obvious short fall, the DOE advised the Government of Belize to amend the EPA in order to inter alia make provisions for an Environmental Management Fund (EMF). The amendment sets out the nine objectives of the EMF, the first of which is “to cover all cost associated with the response and clean-up of oil spills and other chemical spills”.23 To date the EMF has not been constituted.
In the event of a spill and the response mechanism is stalled because of the lack of financial resources on the part of the Government, the polluter may very well attempt to claim contributory negligence; arguing that the Government’s own negligence contributed to the harm it suffered and for which it is attempting to seeking redress.
The importance of having in place a sound financial plan to deal with a spill event cannot therefore be ignored. As part of its preparation for potential spills the Government of Belize must, on the basis of a sound risk assessment, calculate the financial dimensions of the various spill scenarios likely to occur within its maritime areas. It is these financial projections that must inform the composition and size of the EMF.
This is perhaps the most neglected of the four pillars of a spill response mechanism. Because of the nature of the marine environment, oil spills in the territory of one state can have impacts on the maritime areas of neighbouring states. This can be a source of great friction if pre-emptive diplomatic actions are not taken beforehand.
Spills can quickly overwhelm the resources and systems of small developing states. This is all the more reason to put in place a response mechanism built upon regional cooperation.
The primary international instrument that promotes spill response cooperation is the International Convention on Oil Pollution Preparedness, Response and Cooperation, 1990 (OPRC). Parties to this convention are obliged to establish mechanisms for addressing pollution incidents, either nationally or regionally and are required to provide assistance to each other, within their means, in the event of a pollution emergency. Provisions are also made to ensure that all costs associated with said assistance are duly reimbursed.
Belize has not yet signed on to this convention but it should and having done so, it should seek a regional agreement with Mexico, Honduras and Guatemala relating to the practical aspects of combating an oil spill. Critical assets should be identified in these countries and the necessary protocols established to ensure their timely deployment to Belize in the event of a pollution incident. This is of great importance given the volume of crude oil moving to and from ports in the Gulf of Honduras region.
Diplomatic efforts with respect to marine pollution prevention must be of the proactive kind. Recently when Cuba awarded a contract for offshore exploration 55 miles south of Florida's Marquesas Key, to be commenced Q1 next year, the US immediately recognized their vulnerability as a result of both the inherent risk of offshore drilling and the lack of a bi-lateral agreement with Cuba to combat potential spills.24
A US Coast Guard official was quoted as saying "We have long-standing agreements with Mexico about how we would manage incidents and the . . . plan is routinely monitored," [but] "There is not a bilateral US-Cuba agreement on oil spills right now."25
Diplomatic efforts are now under-way to ensure that the necessary measures are put in place to address any possible spills from the Cuban offshore activity. This is the proactive nature to which earlier reference was made. With a clear understanding of the current threats from shipping/port activities in our neighbouring countries, Belize should move with urgency to conclude a regional agreement that would guarantee adequate assistance in the event of an oil spill.
The science of oil spills is very complex. It differs significantly from the science of marine degradation from land-based sources which is by and large an incremental deterioration of the marine environment by the introduction of small quantities of pollutants over a period of time. Oil spills are different in that they have the potential to introduce huge quantities of persistent toxic substances into the marine environment in a very short period of time – almost instantaneously.
Throughout Belize’s maritime spaces there are a number of sub-systems that make up the ecosystem, each of which has their own scientific profile. In order to be able to protect these sub-systems they must be understood in the context of their ability to survive in an oil tainted environment. An objective marine ecological baseline must therefore be established against which any oil pollution damage can be measured. The baseline would obviously have to be updated on a regular basis if it is to remain relevant and of any practical use.
This exercise should lead to an oil spill sensitivity matrix that should guide the DOE and spill responders as to what are the national priorities for protection in the event of an oil spill.
The science of hydrocarbon behaviour in a marine setting and the resulting degradation that can occur as a result must also be understood. This understanding is important in assessing spill behaviour and patterns and should inform the practical spill response apparatus.
Ambient oceanography can have a tremendous impact on how a spill behaves. This is especially important where spills occur near extremely sensitive marine ecosystems or near to maritime borders. What are the prevailing winds? How deep is the receiving water? What is the wave action like in various sectors of the maritime areas and how will wave action impact on the various types of oils? What kind of current prevails and how is that likely to influence how the spill is dispersed? What is the average temperature of the receiving water and how will that influence the behaviour of different types of oils? All questions to be answered by science alone.
Perhaps the greatest scientific input with respect to spills involves the calculation of marine environmental damage consequential to an oil spill. This will often be the single most contentious point between the polluter on the one hand and the claimants on the other. The Government, either by itself or in partnership with the private sector must catalogue Belize’s marine ecology with a view to being able to prove environmental damage.
The methodology devised to demonstrate and calculate oil spill damage must be scientific and transparent. Above all else it must be codified in order to provide statutory guidance to the Courts. In his written judgment in the Westerhaven trial, in which the Court was trying to determine the extent of injury to the Barrier Reef, the learned Chief Justice Abdulai Conteh (as he was then) stated that “However helpful and instructive as the HEA26 may be for the assessment of damage to the Belize barrier Reef, I am constrained from accepting it for the simple reason that it is premised on legislation that has no parallel in Belize.”
The obvious existing challenge to the creation of a spill response mechanism is the absence of a robust legal framework but there are other challenges that can act a s stumbling blocks if not addressed urgently.
Firstly, Belize lacks the technical expertise at this time to effectively respond to a marine spill. This is not to say that isolated pockets of knowledge do not reside in-country, it is the absence of a coordination mechanism undergirded by constant training and continued professional development that is being referred to.
The fostering of habitual relationships between the various governmental departments as well as the private sector is crucial. These relationships can only be created and nurtured through the conduct of regular drills and exercises: the foremost barrier to this of course is the lack of funds. Exercises of this nature are expensive particularly as it relates to live exercises – the actual deployment of personnel and assets – and there are no budgetary considerations for such undertakings on the part of the Government.
Securing the commitment of the private sector is critical but is often difficult to do especially in an environment where, whether by accident or design, a schism exist between the public and private sectors. The effectiveness of Belize’s spill response mechanism will be impacted negatively without sufficient stakeholder buy-in. It is important therefore that from the outset Government seek the cooperation and commitment of the maritime sector.
One of the great deficiencies that can rear its head during a crisis is the lack of relevant data. Currently no data are being systematically collected from ships regarding the quantity and type of bunkers on board, important information needed to ensure readiness. On the other hand, though Government agencies do collect massive amounts of data very little relevant analysis is conducted, in essence the availability of the data does not contribute to meaningful and forward-looking public policy.
The ability of the private sector to access such data is also severely curtailed as public officers tend to be very protective of their “turf”. The data are viewed as the property of the collecting agency rather than public information that should inspire study and research.
Funding the spill response mechanism is perhaps the single greatest challenge. Spill readiness and response is expensive and somebody has got to pay for it, but whom? Ideally both the shipping and petroleum industry should pay for it after all it is they who pose the risks and who in turn will benefit from an effective and well coordinated response in the event of a spill.
Given the dependence of Belize’s economy on cruise tourism, the cruise lines wield excessive power and thus may object to paying for the spill response mechanism. If they do, they can influence government policy as in the case of Grenada where in 1999, Carnival Cruise Lines withdrew its ships because it did not want to pay a $1.50 head tax to fund a new landfill.27 If the cruise lines object and are able to have their own way, the cargo vessels are sure to follow as will the petroleum industry.
The construction of a sound spill response mechanism to effectively address a pollution incident at sea has to be a pressing task for Belize. Particularly given the significant threats to the marine environment posed by shipping activities. It is imperative therefore that a credible protection regime be implemented with great urgency.
As it stands, the primary threat of oil spills comes from international shipping in the form of bunkers and hydrocarbon cargoes. Substantial quantities of oil and related products transit through or near to Belize’s territorial waters posing a very high risk of a pollution incident. Thus, even as the debate rages about the emerging threat of offshore drilling, the existing threats from bunkers and crude oil are real and require immediate attention.
Belize has an obligation under various international conventions to which it is a party, to provide the necessary systems to combat oil spills in order to ensure that it does not encroach into maritime areas that are outside of its control. To meet those obligations Belize must create a national spill response mechanism that is predicated upon the four pillars: legal, financial, diplomatic and scientific.
Challenges abound: the lack of a sound legal framework that addresses contemporary maritime issues is primary amongst these even as the challenge of building the necessary habitual relationships between the Government and the private sector continues to haunt. Pre-spill data that is relevant and useful must be systematically collected, analyzed and shared; this is critical if the response is to be effective, timely and focused. All this of course has to be underpinned by sound fiscal planning if Belize is to be able to meet the immediate needs of a pollution incident.
With all said and done, Belize must do all in its power to develop and implement a sound oil spill response mechanism post-haste. It simply has too much to lose to do otherwise.
1 Personal communications, Chief Environmental Officer, Department of the Environment, October 21, 2010.
2 David Neale, A Note on Marine Administration in Small Island Developing States (SIDS), found at http://www.fig.net/pub/figpub/pub36/chapters/chapter _11.pdf on October 5, 2010.
4 Cooper E., Burke L., Bood N., Coastal Capital: Belize, the Economic Contribution of Belize’s Coral Reefs and Mangroves , World Resources Institute, WRI Working Paper, Washington D.C., 2009.
6 Ship’s fuel, usually residual fuels such as IFO 180, 380 or HFO 180 and 380, persistent polluters once introduced into the marine environment.
7 Statistics provided by the Belize Port Authority.
8 A blend of gas oil and heavy fuel oil, with less gas oil than marine diesel oil (found at http://en.wikipedia.org/wiki/Fuel_oil).
9 Figure taken from Mariner’s and Valor’s Notice of Arrival filed with the Belize Port Authority in October 2009. The figure was then multiplied by the number of visits. It is important to note that they may have arrived on previous or subsequent visits with more or less fuel since their total capacity is about 251 MT and 3900 MT respectively. The example is merely to give an idea as to the total quantity of fuel that may be on board a ship, it is not meant to be a true record of the actual fuel carr ied during the reference period.
10 Almost one half of yearly crude oil exports by Belize Natural Energy and about two thirds of imports by ESSO.
11 The sister ship of M/V Caribe Mariner.
12 However the thresholds are set by individual States as there is no universal definition for the each tier.
13 The International Convention on Civil Liability for Bunker Oil Pollution Damage, 2001.
15 The Amandala newspaper, Oil Spill Threats Require “An Absolute Quick Response”: Senator Hulse, found at http://www.amandala.com.bz/index.php?id=10054, accessed 03 Oct 2010. The quantity was changed from barrels to gallons as we believe that the inclusion of the word “barrels” had to have been a typo.
16 Almost twice as much as BP’s gulf spill (4.4 million barrels/184,800,000 gallons).
17 International MarConsul & Asociados, Navigational Risks and Regulations Harmonization Assessment Concerning Safety of Navigation (final draft), May 2009.
19 Admiralty Claim No. 49 of 2009 between the Attorney General of Belize and MS Westerhaven Schiffahrts (1st defendant) and Reider Shipping BV (2nd defendants).
20 Conteh, A. O., The Westerhaven (2010).
21 The largest tanker that called on the Belize City Port during 2009 had a capacity of about 13.2 million gallons, whilst the largest carrier used by BNE to transport crude out of the Port of Big Creek in 2009 had a capacity of about 3 million gallons.
22 White I.C. and Molloy F.C., Factors that Determine the Cost of Spills, ITOPF, 2003.
23 Act No. 5 of 2009, Environmental Protection (Amendment) Act, 2009, Chap 328 of the Laws of Belize.
24 http://www.caribbeannewsnow.com/headline-US-Coast-Guard-preparing-for-possible-Cuba-oil-spills-242282.html, accessed October 8, 2010.
26 Habitat Equivalency Analysis
25 Mike Melia, Caribbean cruise ships dump garbage at sea, Associated Press, March 01, 2009. Found at http://articles.sfgate.com/2009-03-01/news/17212998_1_cruise-ships-dumping-cayman-islands, October 11, 2010.
Belize National Disaster Plan, National Oil Spill Contingency Plan, Vol. 3dii, Draft One dated 2/5/2009.
Cooper E., Burke L., Bood N., Coastal Capital: Belize, the Economic Contribution of Belize’s Coral Reefs and Mangroves, World Resources Institute, WRI Working Paper, Washington D.C., 2009.
Melia M., Caribbean cruise ships dump garbage at sea, Associated Press, March 01, 2009. Found at http://articles.sfgate. com/2009-03-01/news/17212998_1_cruise-ships-dumping-cayman-islands on October 11, 2010.
Neale D., A Note on Marine Administration in Small Island Developing States (SIDS), found at http://www. fig.net/pub/figpub/pub36/chapters/chapter_11.pdf on October 5, 2010.
Notice of Arrival, M/S Carnival Valor, dated October 29, 2009.
Notice of Arrival, M/V Caribe Mariner, dated October 30, 2009.
Office of Legal Affairs, United Nations Convention on the Law of the Sea, United Nations, 2001
The Amandala News Paper, Oil Spill Threats Require “An Absolute Quick Response”: Senator Hulse, found at http://www.amandala.com.bz/index.php?id=10054 accessed 03 Oct 2010.
The Convention for the Protection and Development of the Marine Environment of the Wider Caribbean Region (The Cartagena Convention, 1983).
The International Convention on Civil Liability for Oil Pollution Damage, 1992.
The International Convention on the Establishment of an International Fund for Compensation for Oil Pollution Damage, 1992.
The International Convention on Civil Liability for Bunker Oil Pollution Damage, 2001
International MarConsul & Asociados, Navigational Risks and Regulations Harmonization Assessment Concerning Safety of Navigation (final draft), May 2009.
White I.C. and Molloy F.C., Factors that Determine the Cost of Spills, ITOPF, 2003.
http://www.biodiversity.bz/belize/protected_areas/, accessed 05 October 2010.
http://www.worldwildlife.org/what/wherewework/mesoamericanreef/threats.html, accessed October 5, 2010.
http://en.wikipedia.org/wiki/Fuel_oil, accessed October 7, 2010.
http://www.caribbeannewsnow.com/headline-US-Coast-Guard-preparing-for-possible-Cuba-oil-spills-2282.html, accessed October 8, 2010.
My deepest thanks for reviews by Captain Johnnie Borland, Commandant Belize National Coast Guard Service, Mr. Martin Alegria, Chief Environmental Officer, Department of the Environment, and Ms Elissa Gibson, Head Legal Department, Belize Port Authority.
© Major Lloyd Jones
HTML last revised 11th November, 2011.
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