Via E-Mail: Paul.Luebke@wisconsin.gov
Mr. Paul Leubke
Wisconsin Department of Natural Resources
101 S. Webster St.
Madison, WI 53707-7921
Dear Mr. Luebke:
Wisconsin Pollutant Discharge Elimination System (WPDES)
General No. WI-0063835-01-0
For Ballast Water Discharges and Environmental Assessment of the Proposed Action
Great Lakes Maritime Task Force is the largest coalition ever to represent the Great Lakes maritime industry. Our members are engaged in every element of Great Lakes shipping and represent both labor and management. Eight of our members are based in Wisconsin.
One of our members, Lake Carriers’ Association, has submitted extensive comments on the referenced subject. We endorse those comments and wish to re-emphasize their key points:
- Wisconsin DNR ("WDNR") has correctly exempted vessels that operate exclusively on the Great Lakes, an Enclosed Aquatic Ecosystem, from the requirement to treat ballast. These vessels ("lakers”) never leave the system and so have never introduced a non-indigenous species.
- Given the vast differences between lakers and ocean-going vessels, the cost to install a ballast treatment system on a laker could be as much as $23.4 million. This is an expenditure no bank would finance. It would not increase the vessel's efficiency or reduce its operating costs.
- Lakers treating their ballast would not end the introduction of exotics nor guarantee that non-indigenous species would not spread. There are, at least, 12 vectors for spread, including natural migration. Once an exotic has established itself in the Lakes, it is here to stay. The focus must remain solely on stopping future introductions.
- WDNR needs to reconsider its treatment of the sediment in lakers' ballast tanks. The prohibition on discharge is appropriate for ocean-going vessels, but unnecessary and counterproductive on lakers. The sediment that collects in lakers’ ballast tanks is drawn from the Great Lakes. It contains only what is already present in the system. Also, flushing sediment actually lessens the potential for exotics to survive in lakers' ballast tanks. To manually remove sediment only when a vessel is in drydock is costly, reduces the vessel's carrying capacity, and increases the chance the tank could harbor exotics. Lakers should be allowed to flush their ballast tanks 13 miles off shore (i.e., waters too deep for an exotic to find a habitat).
- Additionally, WDNR needs to adopt the IMO ballast water discharge standards for ocean-going vessels and the timelines adopted by five of the other eight Great Lakes States for implementing them. The standard you have set will drive ocean-going vessels from your ports.
The movement of dry-bulk cargos such as coal, iron ore, limestone, cement, grain and general cargos such as steel in lakers and salties is crucial to Wisconsin's economic vitality. We appreciate that WDNR has made the important distinction between lakers and ocean-going vessels. However, recognizing that ocean-going vessels are also vitally important to the future of Wisconsin ports and labor, we urge WDNR to adopt a world-wide ballast water standard (i.e., IMO) that keeps Wisconsin’s door open to the world. Please make the above changes to ensure the State's ports remain open to business but closed to exotics.
Donald Cree President
James H.I. Weakley 1st Vice President-Positions & Resolutions
John D. Baker 2nd Vice President-Membership
Patrick J. O'Hern 3rd Vice President-Government Relations