April 6, 2015
City of Charleston Planning Commission
68 Calhoun Street
Charleston, SC 29403

Re: 2015 Update to the Tourism Management Plan, Cruise Recommendations

Dear City of Charleston Planning Commissioners:
Thank you for the opportunity to comment on the draft City of Charleston Tourism Management Plan—2015 Plan Update. Charleston Communities for Cruise Control (C4) includes residents of the greater Charleston area, downtown business owners, and others concerned that the delicate balance of our historic residential port city be restored while continuing to provide an unforgettable tourist experience. The Coastal Conservation League represents 5,000 members and works to protect the natural landscapes, abundant wildlife, clean water, and quality of life here in South Carolina.

Updating our city’s tourism management plan is an opportunity to achieve a delicate balance between tourism and residential quality of life. Several recommendations related to cruise tourism are included in the document, for which we commend the committee. However, it is imperative that the City take a proactive stance with cruise tourism, as it has done with all other facets of tourism here, particularly since the cruise industry is one of the fastest-growing in the world.

No other cruise port in the world has hosted cruises without detrimental effects, and many have implemented guidelines in order to protect their communities. Implementation of our suggested changes will help our city once again be a leading force for tourism management in the nation as well a vibrant living historic city.

Therefore, here are four changes that will strengthen the document before you tonight:

Shorepower for Ships
Rather than the ongoing milestone “continuing the dialogue on the installation of shore power,” the City of Charleston should expect that the State Ports Authority (SPA) is contracting only homeported ships that are shore power-capable.
If that expectation is not met, the SPA will not renew contracts and only work with homeported ships that are shore power-capable.
Our suggestion complements both the South Carolina State Legislature’s budget proviso, which states that any cruise terminal built or designed in Charleston County during the 2014-2015 fiscal year must be capable of providing electrical shore power to the ships it serves, as well as Charleston City Council’s 2014 resolution, which supports shore power at the cruise terminal if needed. It is needed now. Because it has been demonstrated by the foremost expert on shipping emissions that shorepower is needed, and several other ports around the world have implemented the use of shore power without any regulatory mandate, a recommendation in the updated Tourism Management Plan requiring shorepower capability both landside and shipside for the cruise industry is sensible and overdue.

We recommend the deadline for achieving this milestone be set for the port and city to pass a joint resolution agreeing to these retrofits by December 2015.

Pollution Logs
Charleston takes its water quality and aesthetics seriously, and with good reason: the South Carolina Department of Parks, Recreation, and Tourism has valued coastal tourism, boat manufacturing, and commercial fisheries as totaling more than $11.5 billion in direct, indirect, and induced resources annually. Federal law allows the cruise industry to discharge raw sewage, garbage, and untreated graywater when at least three miles from shore.
Carnival claims it has a voluntary corporate policy not to discharge anything within twelve miles of shore, but does not provide proof. Therefore, we recommend adding that the port and City of Charleston publish quarterly records supplied by Carnival Corporation on discharges made within   twelve miles of Charleston’s shores, and agree to start doing so within three months.

Legalize limits
The addition of the Carnival Sunshine as a second homeported ship in Charleston shows the need to strengthen the limits of a maximum of 104 cruise visits per year that carry no more than 3,500 passengers per ship.

The current ordinance details a one-year notification process for the SPA to alert the city to increases beyond their currently-stated limits. It is not an ordinance designed to maintain a balance. This should be revised to officially set the limits at 104 ship visits per year, with no ship larger than 3,500 passenger capacity. The city must have the power to do with cruise ships exactly what it does with every other type of tourism.

Location, location, location
We are pleased to support the evaluation of remote passenger parking within a year to reduce congestion.
It is important to note that the City of Charleston and community groups have spent considerable amounts of money and time (Charleston Mobility Report by Gabe Klein; City of Charleston Downtown Plan; City of Charleston Century V Plan) to assess how to reduce traffic congestion on the peninsula, and are examining outer area parking at garages in the Neck area, and increasing shuttles, bike share, and other solutions. To allow cruise passengers to continue to drive into the heart of the peninsula is not consistent with other traffic studies.
In addition, within three months, the port must make public its assessment of alternative sites for the cruise terminal and how it reached the conclusion that the southeast’s most valuable waterfront property is most appropriate as a cruise terminal, particularly when cruise only constitutes approximately five percent of the port’s overall business. The location of a cruise terminal in the heart of historic downtown is in direct contrast with what other cruise ports across the country have designed. The SPA must also show how this particular cruise location fits within the vision the city is moving towards with development and quality of life on the peninsula.
The port should also present the development plan for the entirety of the Union Pier property in order to clarify which entities will have what responsibility—for example, many citizens wrongly believe that if the new cruise terminal is located at the northern end of Union Pier, the city will then own the remainder of the property.
Thank you for your consideration of our suggestions. We seek to make this update to the Tourism Management Plan the best possible, and believe that implementation of our suggestions will do so.

Sincerely,
Carrie Agnew
Executive Director
Charleston Communities for Cruise Control (C4)
cruisestandards@gmail.com
Katie Zimmerman
Program Director
Air, Water & Public Health
Coastal Conservation League
katiez@scccl.org