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September 12, 2006 - Mr. John Jamian, Seaway Great Lakes Association, Franklin, Michigan

By way of introduction, the Seaway Great Lakes Trade Association (SGLTA) is a U.S. based advocacy organization devoted to the efficient and responsible use of the St. Lawrence Seaway and Great Lakes transportation system. The goal of the SGLTA is to ensure the continued operation of, and access to, this critical economic resource, one on which much of the region's industrial base relies to maintain both a domestic and international competitive advantage.

On behalf of our diverse membership representing businesses made up of St. Lawrence Seaway users from industry, shippers and carriers from the eight Great Lakes states, we are pleased to submit our comments to the International Joint Commission with regards to the report, "Options for Managing Lake Ontario and St. Lawrence River Water Levels and Flows".

For trade to continue unimpeded, it is an essential requirement that water levels and flows be maintained within limits allowing safe and uninterrupted shipping movements.

The commercial navigation in the Lakes and the Seaway operate on one restriction: the 26 feet 6 inches draft limitation of the Seaway. This is true for sea carriers who often begin their in-bound voyage weeks prior to reaching Montreal; for domestic carriers trading intra-lakes, for ports in the Seaway and in the Lakes who will maintain depths alongside their berths accordingly, for all Authorities responsible for dredging to ensure that the connecting channels allow these ports to remain accessible.

The permissible draft in the Seaway has become the element upon which the economics and the health of the industry of the entire Great Lakes Region is based.

It is irrelevant where a new regulation plan would create a more stringent restriction: members over the entire basin would be affected.

We would, therefore, argue that minimum levels to operate in all three sections (Seaway above and below Long Sault and Lake Ontario) as well as safe flows must always be maintained or that, at the very least, the frequency and durations of the deviations to this requirement be kept to the absolute minimum.

We understand that the "Commercial Navigation Cost Model" does not take into consideration revenue losses caused by changes in the water levels and/or flows nor loss of business resulting from potential model shifts or new import/export routes: this raises some doubts and concerns about the conclusions reached by the Commercial Navigation Model and if loss of revenue was used to assess the impacts on other interests, would also invalidate the comparison of the economic impacts between the various interests.

The economic and environmental impact of a modal shift in cargo caused by a plan that is inconsistent in managing our water levels raises great concerns. Our already over crowded surface transportation system cannot possibly absorb an increase in truck and rail traffic and air emission problems that would be caused by an inconsistent policy. Ultimately the shippers themselves would divert their freight to another region thus causing price increases on goods coming to our region while also driving away business.

Table 6 of the report titled, "Economic Results by Interest and Region" indicates for commercial navigation a concurrent positive impact for the Seaway and a negative impact for Lake Ontario for all proposed plans: in view of our argument above, this appears questionable.

Therefore, the conclusion reached by the Report that all three plans provide economic benefit for commercial navigation compared to the present regulation plan should be considered with all reserves.

Past short and medium term deviation – the latter because they allow the first – have proved helpful to offer relief to commercial navigation and other interests under abnormal or unforecasted circumstances, while having a minimal impact on other stakeholders. They provided the Board of Control with a safety margin at times when forecasting proved inaccurate. It is our recommendation that the present practice of clearly defined but discretionary deviation by the Board of Control be maintained to avoid costly traffic disruptions whenever it can be done without noticeable prejudicing other interests.

Our analysis leads us to believe that of all the plans submitted for comments, D+ is the most likely to address our concerns provided it is modified to include an adaptive management strategy under the authority of a Control Board.

However, should the IJC rule that adaptive management would distort the mechanisms of plan D+, we would recommend that plan 1958 D be retained.

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