A Favorite Theme: They’re Killing the Non-Profits

from the Stanford Social Innovation Review <http://ssir.org/articles/entry/the_nonprofit_starvation_cycle&gt;

Philanthropy

The Nonprofit Starvation Cycle

A vicious cycle is leaving nonprofits so hungry for decent infrastructure that they can barely function as organizations—let alone serve their beneficiaries. The cycle starts with funders’ unrealistic expectations about how much running a nonprofit costs, and results in nonprofits’ misrepresenting their costs while skimping on vital systems—acts that feed funders’ skewed beliefs. To break the nonprofit starvation cycle, funders must take the lead.

Why do nonprofits and funders alike continue to shortchange overhead? To answer this question, we studied four national nonprofits that serve youth. Each organization has a mix of funding, including monies from government, foundation, and individual sources. We also interviewed the leaders and managers of a range of nonprofit organizations and funders, as well as synthesized existing research on overhead costs in the nonprofit sector.

Our research reveals that a vicious cycle fuels the persistent underfunding of overhead.1 The first step in the cycle is funders’ unrealistic expectations about how much it costs to run a nonprofit. At the second step, nonprofits feel pressure to conform to funders’ unrealistic expectations. At the third step, nonprofits respond to this pressure in two ways: They spend too little on overhead, and they underreport their expenditures on tax forms and in fundraising materials. This underspending and underreporting in turn perpetuates funders’ unrealistic expectations. Over time, funders expect grantees to do more and more with less and less—a cycle that slowly starves nonprofits.

Although several factors drive the cycle of nonprofit starvation, our research suggests that taking action at the first stage—funders’ unrealistic expectations—could be the best way to slow or even stop the cycle. Changing funders’ expectations, however, will require a coordinated, sector-wide effort. At a time when people need nonprofit services more than ever and when government is increasingly turning to nonprofits to solve social problems, this effort is necessary to keep nonprofits healthy and functioning.

Funders’ Unrealistic Expectations

The nonprofit starvation cycle is the result of deeply ingrained behaviors, with a chicken-and-egg-like quality that makes it hard to determine where the dysfunction really begins. Our sense, however, is that the most useful place to start analyzing this cycle is with funders’ unrealistic expectations. The power dynamics between funders and their grantees make it difficult, if not impossible, for nonprofits to stand up and address the cycle head-on; the downside to doing so could be catastrophic for the organization, especially if other organizations do not follow suit. Particularly in these tough economic times, an organization that decides—on its own—to buck the trend and report its true overhead costs could risk losing major funding. The organization’s reputation could also suffer. Resetting funder expectations would help pave the way for honest discussions with grantees.

Many funders know that nonprofit organizations report artificially low overhead figures, and that the donor literature often reflects grossly inaccurate program ratios (the proportion of program-related expenses to indirect expenses). Without accurate data, funders do not know what overhead rates should be. Although for-profit analogies are not perfect for nonprofits, they do provide some context for thinking about how realistic—or not—average overhead rates in the nonprofit sector are. Overhead rates across for-profit industries vary, with the average rate falling around 25 percent of total expenses. And among service industries— a closer analog to nonprofits—none report average overhead rates below 20 percent.

In the absence of clear, accurate data, funders must rely on the numbers their grantees report. But as we will later discuss, these data are riddled with errors. As a result, funders routinely require nonprofits to spend unhealthily small amounts on overhead. For instance, all four of the youth service organizations that we studied were managing government contracts from local, state, and federal sources, and none of the contracts allowed grantees to use more than 15 percent of the grant for indirect expenses (which include operations, finances, human resources, and fundraising).

Some foundations allot more money for indirect costs than do government agencies. Yet foundations are quite variable in their indirect cost allowances, with the average ranging from 10 percent to 15 percent of each grant. These rates hold true even for some of the largest, most influential U.S. foundations. And foundations can be just as rigid with their indirect cost policies as government funders.

Many times, the indirect allowances that grants do fund don’t even cover the costs of administering the grants themselves. For example, when one Bridgespan client added up the hours that staff members spent on reporting requirements for a particular government grant, the organization found that it was spending about 31 percent of the value of the grant on its administration. Yet the funder had specified that the nonprofit spend only 13 percent of the grant on indirect costs.

Most funders are aware that their indirect cost rates are indeed too low, finds a recent Grantmakers for Effective Organizations (GEO) study. In this national survey of 820 grantmaking foundations, only 20 percent of the respondents said that their grants include enough overhead allocation to cover the time that grantees spend on reporting.2

Individual donors’ expectations are also skewed. A 2001 survey conducted by the Better Business Bureau’s Wise Giving Alliance found that more than half of American adults felt that nonprofit organizations should have overhead rates of 20 percent or less, and nearly four out of five felt that overhead spending should be held at less than 30 percent. In fact, those surveyed ranked overhead ratio and financial transparency to be more important attributes in determining their willingness to give to an organization than the success of the organization’s programs.

Not only do funders and donors have unrealistic expectations, but the nonprofit sector itself also promotes unhealthy overhead levels. “The 20 percent norm is perpetuated by funders, individuals, and nonprofits themselves,” says the CFO of one of the organizations we studied. “When we benchmarked our reported financials, we looked at others, [and] we realized that others misreport as well. One of our peer organizations allocates 70 percent of its finance director’s time to programs. That’s preposterous!”

In this context, nonprofits are reluctant to break ranks and be honest in their fundraising literature, even if they know that they are fueling unrealistic expectations. They find it difficult to justify spending on infrastructure when nonprofits commonly tout their low overhead costs. For example, Smile Train, an organization that treats children born with cleft lip and palate conditions, has claimed that “100 percent of your donation will go toward programs … zero percent goes to overhead.” Nevertheless, the fine print goes on to say that this is not because the organization has no overhead; rather, it is because Smile Train uses contributions from “founding supporters” to cover its nonprogram costs.

This constellation of causes feeds the second stage in the nonprofit starvation cycle: pressure on nonprofits to conform to unrealistic expectations. This pressure comes from a variety of sources, finds the Nonprofit Overhead Cost Study. The survey found that 36 percent of respondents felt pressure from government agencies, 30 percent felt pressure from donors, and 24 percent felt pressure from foundations.3

Underfed Overhead 

In response to pressure from funders, nonprofits settle into a “low pay, make do, and do without” culture, as the Nonprofit Overhead Cost Study calls it. Every aspect of an organization feels the pinch of this culture. In our consulting work with nonprofits, for example, we often see clients who are unable to pay competitive salaries for qualified specialists, and so instead make do with hires who lack the necessary experience or expertise. Similarly, many organizations that limit their investment in staff training find it difficult to develop a strong pipeline of senior leaders.

These deficits can be especially damaging to youth-serving organizations, notes Ben Paul, president and CEO of After-School All-Stars, a Los Angeles-based nonprofit organization that provides after-school and summer camp programs for at-risk youth nationwide. “It is clear to anyone who has led an organization that the most important capital in a company is the human capital,” says Paul. “In after-school we have a saying: Kids come for the program, but stay for the staff. If we don’t hire the right people, we might as well not run after-school programs.”

Meanwhile, without strong tracking systems, nonprofits have a hard time diagnosing which actions truly drive their desired outcomes. “The catch-22 is that, while organizations need capacity-building funding in order to invest in solid performance tracking, many funders want to see strong program outcome data before they will provide such general operating support,” says Jamie McAuliffe, a portfolio manager at the New York-based Edna McConnell Clark Foundation.

Take the case of a well-respected network of youth development programs. To protect the identity of this organization, we will call it the Learning Goes On Network (LGON). Poised for a huge growth spurt, LGON realized that its data systems would be hopelessly inadequate to accommodate more clients. An analysis showed that program staff spent 25 percent of their time collecting data manually. One staff member spent 50 percent of her time typing results into an antiquated Microsoft Access database.

Staff members can become so accustomed to their strained circumstances that they have trouble justifying even much-needed investments in overhead, our interviews revealed. “We [had] known for a long time that a COO was vital to our growth but [hadn’t] been able to fund one,” relates the CEO of one of the four youth development organizations that we studied. But when his organization’s board finally created the COO position, the rest of the staff resisted. “They had lived so long in a starved organization that the idea of hiring a COO was shocking to them.”

Misleading Reporting

The final driver of the cycle that starves nonprofit infrastructure is nonprofits’ routine misrepresentation of how much they actually spend on overhead. The numbers that nonprofits report on their financial statements “[defy] plausibility,” finds the Nonprofit Overhead Cost Study. Upon examination of more than 220,000 nonprofit organizations, researchers found that more than a third of the organizations reported no fundraising costs whatsoever, while one in eight reported no management and general expenses. Further scrutiny found that 75 percent to 85 percent of these organizations were incorrectly reporting the costs associated with grants.

Our study of the four youth-serving nonprofits likewise reported discrepancies between what nonprofits spent on overhead and what they reported spending. Although they reported overhead rates ranging from 13 percent to 22 percent, their actual overhead rates ranged from 17 percent to 35 percent.

Many factors support this underreporting of nonprofit costs. According to a survey conducted by The Chronicle of Philanthropy in 2000, a majority of nonprofits say that their accountants advised them to report zero in the fundraising section of Form 990.4 Limited surveillance of nonprofits’ Form 990 tax reports only exacerbates the problem: The IRS rarely levies the $50,000 penalty for an incomplete or inaccurate return, and generally applies it only when an organization deliberately fails to file the form altogether. According to the Chronicle study, “Improperly reporting these expenses is likely to have few, if any, consequences.”

The IRS’ ambiguous instructions likewise lead to error, report several sources. For example, nowhere does the IRS explicitly address how to account for nonprofit marketing and communications. As a result, many organizations allocate all marketing and communications expenses to programs when, in most cases, these expenses should be reported as administrative or fundraising overhead.

Government agencies likewise have varying and ambiguous definitions of indirect costs. The White House Office of Management and Budget, for example, defines indirect costs as “those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective.” It then goes on to say that “because of the diverse characteristics and accounting practices of nonprofit organizations, it is not possible to specify the types of cost that may be classified as indirect cost in all situations.”5

There is some good news. Currently, the U.S. Government Accountability Office (GAO) is conducting a study of various federal grantors’ definitions of indirect costs. As Stan Czerwinski, the director of strategic issues for GAO, explains, “The goal is to achieve consistency, so that when nonprofits go in for funding, they have clarity (as do funders) about what they’re actually going to get reimbursed for.” The study is in the early stages, but as Czerwinski notes, the need is clear: “We don’t find anybody telling us that we’re barking up the wrong tree.”

Proper Care and Feeding

Although the vicious cycle of nonprofit starvation has many entry points and drivers, we believe that the best place to end it is where it starts: Funders’ unrealistic expectations. Foundations and government funders must take the lead because they have an enormous power advantage over their grantees. When funders change their expectations, nonprofits will feel less need to underreport their overhead. They will also feel empowered to invest in infrastructure.

The first step that funders should take is to shift their focus from costs to outcomes. In the nonprofit world, organizations are so diverse that they do not share a common indicator of program effectiveness. In the absence of this indicator, many funders try to understand an organization’s efficiency by monitoring overhead and other easily obtained yet faulty indicators. Funders need to refocus their attention on impact by asking “What are we trying to achieve?” and “What would define success?” In so doing, they will signal to their grantees that impact matters more than anything else. Even focusing on approximate or crude indicators (for example, “Are we getting an A or a C on our impact goals?”) is better than looking at cost efficiencies, as focusing on the latter may lead to narrow decisions that undermine program results.

Funders must also clearly communicate their program goals to their grantees. Having established that funder and grantee share the same goals, funders should then insist on honest answers to the question “What will it take to deliver these outcomes consistently, or to deliver these outcomes at an even higher level of quality or quantity?”

One of our study participants, for instance, worked closely with its major funder to think through this question, and ultimately determined it needed a sizable investment in technology to support its projected growth. The funder agreed that only by making such an investment would the organization be able to track outcomes uniformly and to make program improvements quickly.

When feasible, funders should help meet grantees’ identified infrastructure needs by making general operating support grants. Grantmakers and nonprofits agree that more operating support is very likely to improve an organization’s ability to achieve results, finds the 2008 Grantmakers for Effective Organizations study. And a 2006 CompassPoint Nonprofit Services study of nearly 2,000 nonprofit executives in eight metropolitan areas reveals that receiving general operating support played a major role in reducing burnout and stress among executive directors.6 Yet although 80 percent of the foundations in this study made some general operating grants, they dedicated a median of only 20 percent of their grant dollars to this kind of support.

Regardless of the type of support they provide, funders should encourage open, candid discussions with their grantees about what the latter need to be effective. Many funders’ grantmaking processes are not set up to consider the full scope of what grantees do, and why. As a result, their grants are not as flexible as they need to be. Yet when funders fully understand their grantees’ operations, they are more likely to meet their grantees’ needs.

Although changing their expectations will have the greatest impact on the nonprofit starvation cycle, funders can also intervene in other useful ways. When making use-restricted grants, funders should commit to paying a greater share of administrative and fundraising costs. Indeed, in 2004, the board of the Independent Sector encouraged funders to pay “the fair proportion of administrative and fundraising costs necessary to manage and sustain whatever is required by the organization to run that particular project.”

Likewise, rather than prescribing an indirect expense rate for all grants, government funders should allow nonprofits to define their true overhead needs in grant applications and, so long as these needs are justifiable, pay for them. For example, some federal funding contracts allow a nonprofit to justify an indirect cost rate (within guidelines), which the organization can then use for all its federal grant applications. Extending such a policy to all federal, state, and local government contracts would go a long way toward helping nonprofits deliver better programs while being able to pay for their grants’ management.

Finally, to foster transparent and accurate reporting, funders should encourage the development of a standard definition of the term overhead. Currently, organizations have to report their overhead differently for nearly every grant that they receive. Standardization would allow funders to compare apples with apples, as well as allow grantees to understand better their own overhead investments—or lack thereof. Having a dialogue about real overhead rates could also help shift the focus to the real target: outcomes.

What Grantees Can Do

The burden of breaking the cycle of nonprofit starvation does not rest solely with funders. Nonprofit leaders also play a role. As a baseline task, they should commit to understanding their real overhead costs and their real infrastructure needs. At LGON, for instance, senior managers spent several months digging into their costs, analyzing their current systems—including the organization’s subpar tracking process—and identifying gaps in capacity. After this strategic planning process, the organization could articulate a clear plan for a new tracking system and a 150 percent increase in nonprogram staff over three years.

Nonprofits must then speak truth to power, sharing their real numbers with their boards and then engaging their boards’ support in communicating with funders. Case studies of organizations that have successfully invested in their own infrastructure have repeatedly noted the need for a shared agenda between the leadership team and the board. The executive director of LGON, for example, communicated early and often with her board members throughout the strategic planning process. She also facilitated several meetings to address infrastructure needs.

For their part, board members should ask the tough questions before funders do, namely: “What does this organization really need to succeed?” “Where are we underinvesting?” and “What are the risks we’re taking by underinvesting in these areas?” Board members should encourage nonprofit leaders to develop strategies that explicitly recognize infrastructure needs. In developing plans for infrastructure, board members can help, notes Chris Brahm, chairman of the board of directors at Larkin Street Youth Services, a San Francisco nonprofit that serves homeless and runaway youth: “The people running agencies are often consumed with programs and raising money. Board members, whether businesspeople or otherwise, can bring external perspective on overhead services.”

At LGON, for example, the executive director identified a handful of board members who were fervent supporters of the emerging strategic vision. These board members then communicated to their colleagues how much overhead this vision would require.

During these discussions, both board members and managers should focus on how investments in infrastructure will benefit the organization’s beneficiaries, rather than reduce costs. Even within the confines of a “cost conversation,” they should emphasize how infrastructure investments may actually reduce the costs of serving beneficiaries over time. One organization in our study, for instance, determined that an investment in technological infrastructure yielded $350,000 per year by freeing up staff time and consolidating “scrappy” systems.

Finally, organizations must attempt to educate their donors. “Donors don’t want to pay for an organization’s rent, or phone bill, or stamps,” notes Paul, “but those are essential components of everyday work. You can’t run a high-performing organization from your car. And there are many ways to explain these types of expenses to donors.”

Both funders and grantees are feeling the sting of the current recession. But this economic downturn is no excuse to cut overhead funding. “If a nonprofit’s leaders are feeling as if they cannot raise money to support overhead, I think they’re confusing the issue,” says Brahm. “The real issue is that they can’t raise enough money, period. Either they do not have, or they have not been able to communicate, a results story that is compelling to funders.”

Rather than being the reason to reduce overhead spending, the recession is an excellent opportunity to redress decades-long underinvestment in nonprofit infrastructure. “There is real potential for change if all of the major stakeholders—government, private funders, and the nonprofits themselves—take steps to acknowledge that capacity building is critical to the health of an organization,” says McAuliffe. And although the forces that fuel the nonprofit starvation cycle are strong, the opportunity to achieve more for beneficiaries in the long term should compel funders and grantees alike to stop the cycle.

Former Bridgespan Group manager William Bedsworth contributed to this article. 

Notes

  1. See also Kennard Wing, Tom Pollak, and Patrick Rooney, How Not to Empower the Nonprofit Sector: Under-Resourcing and Misreporting Spending on Organizational Infrastructure, Washington, D.C.: Alliance for Nonprofit Management, 2004. Wing, Pollak, and Rooney are three of the lead researchers on the Nonprofit Overhead Cost Study.
  2. William H. Woodwell Jr. and Lori Bartczak, Is Grantmaking Getting Smarter? A National Study of Philanthropic Practice, Washington, D.C.: Grantmakers for Eff ective Organizations, 2008.
  3. Kennard Wing and Mark Hager, Who Feels Pressure to Contain Overhead Costs?, Paper presented at the ARNOVA Annual Conference, 2004.
  4. Holly Hall, Harvy Lipman, and Martha Voelz, “Charities’ Zero-Sum Filing Game,” The Chronicle of Philanthropy, May 18, 2000.
  5. White House Office of Management and Budget, Circular A-122 (Revised): Cost Principles for Nonprofit Organizations. 
  6. Jeanne Bell, Richard Moyers, and Timothy Wolfred, Daring to Lead 2006: A National Study of Nonprofit Executive Leadership, San Francisco: CompassPoint Nonprofit Services, 2006.

Ann Goggins Gregory is the director of knowledge management at the Bridgespan Group and a former consultant in Bridgespan’s strategy area. In her consulting work, Ann’s clients included education and youth development organizations, as well as foundations.

Don Howard is a partner at the Bridgespan Group, where he leads the San Francisco office. His clients have included foundations and nonprofits working to alleviate poverty, end homelessness, revitalize neighborhoods, end inequities in education, and improve the environment.

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Scary Account of Unknown Plague Affecting East Flower Garden Bank, offshore Texas.

Passed along by Wendy Ann Lee, based on this account in the NOAA Sanctuaries web site. . .

<http://sanctuaries.noaa.gov/news/jul16/noaa-scientists-report-mass-die-off-of-invertebrates-at-east-flower-garden-bank.html>

NOAA scientists report mass die-off of invertebrates at East Flower Garden Bank in Gulf of Mexico

Sanctuary recommends public avoid diving, fishing, boating activities in affected area

By Dr. Steve Gittings, steve.gittings
Chief Scientist, Office of National Marine Sanctuaries

July 2016

A white mat of unknown material coats a dying sponge at the East Flower Garden Bank during a large-scale mortality event. Image: FGBNMS/G.P. Schmahl

On Monday, sport divers on the M/V Fling, diving in the Gulf of Mexico 100 miles offshore of Texas and Louisiana, were stunned to find green, hazy water, huge patches of ugly white mats coating corals and sponges, and dead animals littering the bottom on the East Flower Garden Bank, a reef normally filled with color and marine life. The reef, which is part of Flower Garden Banks National Marine Sanctuary, is considered one of the healthiest anywhere in the region.

The charter captain alerted scientists from the National Oceanic and Atmospheric Administration(NOAA) and Bureau of Ocean Energy Management (BOEM), who were doing annual monitoring work a few hundred yards away on the same reef. The scientists are now reporting that a large-scale mortality event of unknown cause is underway on this bank.

Coats of white mats covering dying star corals during a large-scale mortality event at the East Flower Garden Bank. Image credit: FGBNMS/G.P. SchmahlThe divers and researchers found unprecedented numbers of dying corals, sponges, sea urchins, brittle stars, clams and other invertebrates on large but separate patches of the reef. Sanctuary Research Coordinator Emma Hickerson reported extensive white mats covering corals and sponges, and estimates the mortality of corals to be nearly 50 percent in some of the affected areas. The spatial extent of the event is still being determined, but Hickerson says the die-off has so far been seen at three dive sites that charter boats typically use when they visit the bank.

Oddly, there was no evidence of the mass die-off at the site used for long-term monitoring of the bank since the late 1980s, where the scientists had been working when they first heard the news. Annual monitoring at the sanctuary is co-funded by NOAA, BOEM and the National Marine Sanctuary Foundation. Twelve miles away, the reefs of the West Flower Garden Bank remain vibrant, bathed in clear, blue water and free of the problem for now.

A massive star coral impacted by a large-scale mortality event at the East Flower Garden Bank. These corals are hundreds and hundreds of years old, and can be lost in a matter of days. Image credit: FGBNMS/G.P. SchmahlUntil the problem is sorted out, NOAA is recommending the public avoid diving, fishing, and boating activities on the East Flower Garden Bank. This is primarily to prevent the transmission of whatever is causing the mass mortality to unaffected locations, but also could protect divers from ingesting what could be harmful pathogens or toxins.

“At present, we are not aware of any specific risks to humans, but we are recommending this action as a precaution until more is known about the cause,” said G.P. Schmahl, Sanctuary Superintendent.

The remains of a sea urchin recently dead from a large-scale mortality event at the East Flower Garden Banks laying atop dying star coral colonies – these are coated with a white mat of unknown material. Image credit: FGBNMS/G.P. Schmahl Several potential causes of the outbreak will be investigated, including poor water quality, disease pathogens and chemical spills. Each alone could cause mortality in coral reef organisms, but more likely, a combination of stressors is at work.

“We know of no spills that have recently occurred near the Flower Garden Banks,” said Schmahl, “but water temperature over the banks is quite high, at 86 degrees.” In addition, large plumes of low-salinity coastal water have moved offshore following months of extreme rainfall in the region. That water is rich with plankton, nutrients and chemicals that arrive to the Gulf through runoff and river discharges. As the plumes decay, oxygen levels in the water can decrease.

Tissue sloughing off a recently dead brain coral succumbing to a large-scale mortality event at the East Flower Garden Bank. Image credit: FGBNMS/G.P. SchmahlCombined, these stressors could make coral reefs animals and plants more prone to disease outbreaks, or simply fuel the growth of bacterial or algae mats that smother the reefs. Scientists from around the world are offering advice and assistance in trying to help discover the cause.

Isolated bleaching events and unconfirmed cases of diseases have been reported at the Flower Garden Banks in the past. Overall, however, the health and stability of the sanctuary’s invertebrate and fish populations have been in stark contrast to coral reefs around the world that have degraded over the last four decades.

A deadly white mat coats a sponge between star and brain coral at the East Flower Garden Banks. Image credit: FGBNMS/G.P. Schmahl.Concern now is that the isolation of the banks, which many believe has been shielding them from human impacts, may not be enough to fully protect them anymore. But from what? The sanctuary and the science community are desperately trying to figure that out.

To learn more:
Flower Garden Banks National Marine Sanctuary
http://flowergarden.noaa.gov/

BOEM Science Notes – Flower Garden Banks National Marine Sanctuary
http://www.boem.gov/2014-03-Science-Notes/

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Carib Journal Op Ed: Marine Pollution in the Caribbean

from the Carib Journal <http://www.caribjournal.com/2016/07/21/op-ed-marine-pollution-caribbean/?utm_source=Caribbean+Journal&utm_campaign=59065adaf4-Caribbean+Journal&utm_medium=email&utm_term=0_ea4e1e4090-59065adaf4-188909129>

[Ship-borne waste may be a contributor to marine pollution in the Caribbean, but I question whether it’s a major source, and whether addressing ship-borne waste issues (with their high capital costs as outlined in this discussion) are the most cost-effective tactics for reducing marine and coastal ecosystem impairments. My own bet would be that on-island investments in a variety of strategies to reduce forms of land-based run-off would do more to increase the productivity of the coastal and marine environment on a dollar-for-dollar basis than any ship-borne waste program. Furthermore, the capital-intensive nature of ship-borne waste management activities described here require a much higher proportion of imported products and technologies than increasing the competence and changing the land management activities of local farmers, developers and residents. bp]

Op-Ed: Marine Pollution in the Caribbean

July 21st, 2016 | 9:35 pm

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Exploring Marine Pollution and the Caribbean Maritime Transport Industry

By George Nicholson and Rachael Robinson
Op-Ed Contributors

Pollution of the world’s oceans is globally recognized as one of our highest environmental concerns. The oceans are regarded as the transportation highways for shipping, tourism and commerce, and with this abundance of ships, there is a significant amount of ship-generated waste that needs disposal. International conventions guide both states and masters of vessels on handling ship generated wastes and, depending on the nature of the waste, these regulations determine whether it may be discharged into the ocean or disposed of on land once the ships come into port. Given the scope and intensity of shipping in the Greater Caribbean, as well as the sensitive nature the Caribbean Sea itself, ship-generated waste presents a significant threat to regions’ marine ecosystems.

In light of this sensitivity and given that the region serves as a major hub for the global shipping industry, the capacity of ports or states to handle and dispose of ship-generated waste itself is a complex issue.

It is well recognised that marine pollution, including oil, chemicals, garbage, sewage, and food waste, which are all being dumped into the ocean, negatively affects industries related to the ocean such as fishing and tourism. In light of this recognition the international community developed the International Convention for the Prevention of Pollution from Ships, otherwise known as the MARPOL Convention, as the principal international treaty governing ship-generated waste.

The Convention, written in 1973 and modified in 1978 focuses on the regulation of ship-generated waste.

Under the provisions of MARPOL, waste is categorized into six annexes, allowing restrictions to be placed on groups of materials rather than on specific substances, and further defines separate requirements for the disposal of each. Annex I and II which cover the prevention of pollution by oil, and noxious liquids carried in bulk respectively, are subject to compulsory ratification by all parties while Annexes III to VI, which introduces requirements to control pollution of the sea by noxious substances and sewage from ships, are optional and must be ratified separately. Of all the annexes, oil (Annex I) and garbage (Annex V) are the most common and make up the majority of waste tonnage. Annex V which focuses on Prevention of Pollution by Garbage from Ships sets restrictions on the handling of garbage, including all food, domestic, and operational waste and completely prohibits the dumping of plastics at sea.

Due to its heavy maritime traffic, sensitive and fragile marine ecosystem, and the nature of the currents through the region, the Caribbean Sea was designated a Special Area with restrictions under MARPOL Annex V in 2011. This is of key importance to the region as special areas are provided with a higher level of protection than other areas, and strict rules apply for the disposal of garbage from ships. Within the Wider Caribbean Region, vessels operating are prohibited from discharging any garbage, with the exception of food waste which may be discharged subject to certain conditions, if the vessel is at least 12 nautical miles from the nearest land. Implementation of this special area status however is not without its own challenges.

The designation recognizes the ecological sensitivity of the region, but puts additional strain on the region’s port waste collection infrastructure. This is especially problematic in the context of the region’s Small Island Developing States (SIDS), which rely heavily on ships coming into their ports, but may lack the means to dispose of the additional waste they bring. Cruise ships, for instance, are critical to the economies of many SIDS, but they also produce significantly more waste than container ships. Although vessel traffic in the region is one of the primary contributors to the tourist-driven economy, limited financial resources curtail the ability of small states to construct appropriate facilities.

Given that ships must now offload all of their waste in ports, since the volume that was once dumped into the sea must now be processed at ports, there is the risk that region’s ports may become overburdened as they lack the infrastructure or reception facilities necessary to handle this increase. Whilst the majority of ports in the region have reported to have adequate port reception facilities, high costs of disposal, and other factors may lead some mariners to illegally discharge of their ship’s waste in the Caribbean’s waters.

With an average of five million barrels of crude oil being transported daily throughout the Wider Caribbean Region, together with an annual total of 70 million tons passing through the Panama Canal, it is estimated that approximately 250 major and minor oil spills will occur each year in the Caribbean Sea and the Gulf of Mexico.

However, studies show that of the sixty-plus Caribbean ports that handle oil and oil derivatives, oil/slop or ballast reception facilities are lacking. The International Maritime Organization (IMO) Global Integrated Shipping Information System further reveals a great need for the availability of data regarding port reception facilities (discharge restrictions, charges, availability of facilities, etc.), particularly in the Small Island Developing States (IMO, 2016). Port State Control inspectors in the territories are responsible for determining if vessels are adhering to international agreements, and have committed to inspecting a minimum of 15% of international ships calling at their ports, but given the vastness of the Caribbean Sea, and the lack of capacity of some member states, there is a significant probability that illegal dumping may go undetected.

Pollution already affects the marine environment and will continue to do so in the Special Area unless territories are able to provide ports with inexpensive and efficient waste disposal systems, either on the port itself or through offsite facilities. Unless disposal is desirable from the mariners’ point of view, pollution will continue in the face of such challenges; consequently compliance with the provisions of MARPOL may not be universal.

In spite of these challenges, through effective enforcement, Caribbean countries have a significant opportunity to improve the region’s marine ecological footprint. Ideally, there must be either an improvement to port infrastructure or other means of improving waste management in the Caribbean on a regional basis and given the difficulties in enforcement, any solution proposed must be both convenient and cost-effective to incentivise compliance.

While there have been improvements, the enactment of the relevant instruments into national legislation to further support the international regulatory framework would also assist the region in meeting its obligations. A successful solution will allow shipping and commerce to continue with minimal hindrance but also result in a significant reduction in the area’s marine pollution.

George Nicholson is the Director of Transport and Disaster Risk Reduction and Rachael Robinson is the Transport and Disaster Risk Reduction Research Assistant of the Association of Caribbean States. Any comments or feedback should be submitted to feedback

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Home Town Heroes

It made me proud to learn that a hometown company, the Delaware North Companies, with offices above the new Westin Hotel in BUFFALO, NEW YORK, is listed by Forbes Magazine as one of the richest US privately held companies.

And my friend Joe tells me:

Well, it turns out that just about every name in Yosemite has been changed due to a trademarks dispute. Yosemite, like most national parks, uses private management companies to operate the hotels and campgrounds and provide food service. When the Park Service was not paying attention, the former private management company, Delaware North, proceeded to trademark under their name virtually every historic place in the park; and when they were replaced by Aramark, they offered to return the trademarks to the Park Service for a mere $52 million. (Does this sound like something Trump would do?) In fact, there is no such thing as Yosemite National Park anymore because Delaware North trademarked that name as well; so it is now just “Yosemite.”

And these guys aren’t even Big Pharma!

So the next time you happen to see them slithering around the lounge of the new Westin in Buffalo, give my regards to these scions of the Jacobs family of Buffalo — Chairman Jeremy actually lives in East Aurora, according to Wikipedia.

Current Delaware North Chairman Jeremy Jacobs, the son of founder Louis Jacobs, represents the second generation of the Jacobs family to own and lead the company. His three sons – Jerry, Lou and Charlie – are chief executive officers of Delaware North and are leading the company’s long-term business strategy.

We invite you to learn more about the Jacobs family.

  • JEREMY M. JACOBSChairman, Delaware North
    Owner/Governor, Boston Bruins

  • JERRY JACOBS JR.Co-Chief Executive Officer, Delaware North
    Alternate Governor, Boston Bruins

  • LOU JACOBSCo-Chief Executive Officer, Delaware North
    Alternate Governor, Boston Bruins

– See more at: https://www.delawarenorth.com/about/family-leadership#sthash.wN5l1yQW.dpuf

Would it surprise you to know that these fine fellows run a lot of gambling casinos and racetracks all over the world? … along with Ralph Wilson Stadium in Orchard Park!

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Success: Why Strong Stormwater Regs, Rigorously Applied are Important.

… after three inches of rain, the silt fence and hay bales held.

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New Edition of the Ramsar Handbooks

The Secretariat of Ramsar Convention has just announced the launch of the first Handbook in the 5th Edition Ramsar Handbook Series. It is entitled “An Introduction to the Convention on Wetlands” and replaces “The Ramsar Convention Manual”.

http://www.ramsar.org/sites/default/files/documents/library/handbook1_5ed_introductiontoconvention_e.pdf

“An Introduction to the Convention on Wetlands” is aimed at a diverse and extensive audience and explains the role of the Convention and how it works. The Handbook is currently being translated into French and Spanish.

The 5th Edition Handbooks will be organized under three sub-series, covering International Cooperation on Wetlands; Wise Use of Wetlands; and Wetlands Conservation and Management.

Handbook 2, “The Ramsar Strategic Plan 2016-2024”, is scheduled to be released in July.

The 5th Edition Series includes:

SUB-SERIES I: INTERNATIONAL COOPERATION ON WETLANDS

Handbook 1: An Introduction to the Convention on Wetlands

Handbook 2: The Ramsar Strategic Plan 2016-2024

Handbook 3: International cooperation

Handbook 4: Ramsar Regional Initiatives

Handbook 5: Partnerships

SUB-SERIES II: WISE USE OF WETLANDS

Handbook 6: Wise use of wetlands, sustainable development and poverty eradication

Handbook 7: Freshwater-related guidance

Handbook 8: Wise use of wetlands in the coastal zone and small islands

Handbook 9: Wetland cities

Handbook 10: Wetlands and health

Handbook 11: Wetlands, including peatlands, climate change and disaster risk reduction

Handbook 12: Implementing CEPA with participatory skills

Handbook 13: Strategic environmental assessment

Handbook 14: Wetlands and culture

SUB-SERIES III: WETLAND CONSERVATION AND MANAGEMENT

Handbook 15: National wetland policies, laws and institutions

Handbook 16: Designating Ramsar Sites

Handbook 17: Addressing change in wetland ecological character

Handbook 18: Managing wetlands

Handbook 19: Avian influenza and wetlands

Handbook 20: Inventory, assessment and monitoring

Handbook 21: Wetland education centres

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IRF Scholarships to Two Caribbean Scholars Who Attended ISISA XIV

Thank you!

Gen

Sent from Yahoo Mail on Android

On Thu, 23 Jun, 2016 at 6:15 pm, Bruce G. Potter
<bpotter@irf.org> wrote:
In reviewing the documentation from the International Society of Island Studies Association (ISISA), Islands of the World XIV Conference in Lesvos last month, I learned that two Caribbean Scholars received 500 Euro awards sponsored by Island Resources Foundation and funded by the Kincey and Bruce Potter Environmental Fund.

Congratulations to all the winners. . . . .

Winner Country Award Email
Rosie Alexander Scotland ISISA Rosie.Alexander@uhi.ac.uk
Guillermo Brink Chile Baldacchino gpbrinck@gmail.com
Angelica Erazo-Oliveras Puerto Rico Island Resources Foundation erazo.angelica@hotmail.com
Genève Phillip Trinidad Island Resources Foundation geneve.phillip@yahoo.com
Gitanjali Pyndiah France/England ISISA g_pyndiah@yahoo.fr
Maria Reyes-Perez Netherlands ISISA m.reyesperez@unesco-ihe.org
Giang Tran Vietnam ISISA trangiangus@yahoo.com
Tabitha Espina Velasco Guam ISISA tvelasco@triton.uog.edu
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