The seventh meeting of the Great Lakes Ballast Water Collaborative took place March 3-4 in Washington, D.C., despite a severe winter storm that closed all federal government offices.
The storm made it impossible to hold the meeting at the NOAA Science Center on March 3. However, organizers quickly arranged for an alternate location and held the meeting as scheduled. More than 40 key stakeholders met in person and many more joined via teleconference to discuss the status of current science, research and development, the current regulatory environment, industry perspectives, and the challenges of successfully implementing ballast water management regulations.
A ship on the St. Lawrence Seaway. Credit: K. Mukherjee.
Ballast water is taken aboard ships to maintain stability, safe structural loads, trim, and the ability to steer as the load carried by the ship changes from off-loading cargo or burning fuel. Unfortunately, the water taken aboard also may contain harmful invasive species that may be transported to new regions where they could thrive and damage the environment. Zebra mussels are the most notorious example of a species that arrived in the Great Lakes via ballast water discharges.
The Saint Lawrence Seaway Development Corp. and IJC have partnered in sponsoring the Great Lakes Ballast Water Collaborative since 2009. The purpose of the Collaborative is to bring together representatives from the marine industry along with state and federal regulators and respected scientists to find workable and effective solutions to the challenges of aquatic invasive species as they relate to the Great Lakes-St. Lawrence Seaway System. A key goal of the Collaborative is to share relevant, useful, and accurate information and foster improved communication and collaboration among the key stakeholders engaged in the effort to reduce the risk of introduction and spread of aquatic nuisance species from ballast water discharges.
A prop covered with zebra mussels. Credit: TownePost Network.
Efforts to prevent new introductions of aquatic invasive species (AIS) via ballast water discharges have made progress. Due to the vigorous enforcement of requirements to conduct ballast water exchange and saltwater flushing of ballast tanks on ships arriving in the Great Lakes, no new AIS introductions attributed to ship ballast water have been reported since 2006. The 2013 Summary of Great Lakes Seaway Ballast Water Working Group, published in February, provides all the details of this effort, the most stringent ballast water discharge enforcement regime in the world.
Despite the success of the current regulations, the requirement for ships to exchange their ballast water in the open ocean has some limitations, including the potential safety exemptions and the inconsistent effectiveness of saltwater flushing on some ship designs. Therefore, the International Maritime Organization (IMO) adopted the International Convention for the Control and Management of Ships’ Ballast Water and Sediments in 2004 that requires ships to limit the number of potentially invasive organisms discharged. Canada ratified the Convention in 2010 and is preparing to implement the measures in Canada. Most vessels on international voyages (including Great Lakes “Lakers” operating bi-nationally on the Great Lakes and St. Lawrence Seaway) would be subject to the proposed regulations. These ships would be required to:
- Develop an approved ballast water management plan
- Undergo surveys and carry certificates to demonstrate that the plan is being followed
- Keep records of ballasting activities
- Manage ballast water discharges: initially by performing ballast water exchange in the open ocean when voyage patterns and safety considerations allow, and eventually by adhering to performance standards limiting the number of organisms discharged in ballast water.
Canada also is proposing some requirements that are more stringent than those of the IMO Convention; requiring vessels to perform saltwater flushing of residual sediment in empty ballast tanks before entering Canadian fresh water ports, as well as to continue ballast water exchange and flushing in addition to treatment to the IMO performance standard, and to fit a system suitable for freshwater if planning to load or move ballast water on the Great Lakes.
In the United States, the regulation of ballast water discharges in the Great Lakes falls under the jurisdiction of two federal agencies, the U.S. Coast Guard (USCG) and U.S. Environmental Protection Agency (EPA), and eight states. This, together with Canada, created the potential for a patchwork of inconsistent regulatory approaches across the region. During the past five years, thanks in part to the efforts of the Collaborative, the discharge limits set by IMO Convention have been recognized as a practicable requirement by seven states, the USCG, EPA and Canada. Like Canada, states have adopted the additional requirement to conduct both ballast water exchange/flushing and treatment to further reduce the risk on introducing AIS to the Great Lakes.
On March 23, 2012, the Coast Guard established a ballast water discharge standard for U.S. waters and a type-approval process for ballast water management systems. The Final Rule also includes a provision for approval of alternate management systems, to allow foreign IMO type-approved systems to be installed as an interim step while USCG type-approved systems were developed. To date, approximately 33 ballast water treatment systems have been certified by foreign governments as meeting the IMO treatment standard; however, no systems have yet been type-approved by the USCG.
In 2013, the EPA issued a final vessel general permit to regulate ballast water discharges from commercial vessels. It includes the IMO numeric discharge standard limiting the release of non-indigenous invasive species in ballast water and also contains additional requirements for exchange/flushing plus treatment for the Great Lakes, like Canada and many Great Lakes states.
Those participating in the March 3-4 Ballast Water Collaborative meeting recognized the progress made to date and focused on the particularly vexing issues of implementation and enforcement. A key problem identified is that no systems have been type-approved by the USCG and most systems approved by foreign governments have not been tested and proven effective in freshwater conditions equivalent to the Great Lakes. Non-compliant Lakers subject to IMO discharge requirements could potentially be blocked from binational trade.
Additionally, provisions to grant extensions for meeting compliance deadlines and for addressing vessels that are found non-compliant with U.S. regulations are not consistent between the USCG and EPA. This creates a dilemma for shipping companies that need to select treatment systems costing millions of dollars, where they face a high risk in that installed systems may later be found unsuitable and be required to be replaced. The relatively small market for freshwater systems approved for the Great Lakes creates little incentive for vendors of treatment systems to invest large sums in an effort to gain USCG type-approval.
Participants discussed options for overcoming these challenges, providing incentives for installing treatment systems and identifying a practicable way forward. Although no specific solutions were identified at the workshop, the discussions prompted many to schedule additional discussions aimed at overcoming the challenges of implementation. The proceedings of the Ballast Water Collaborative meeting will be posted on the Saint Lawrence Seaway Develop Corp. website.