January 18, 2006
Izaak Walton League of America
Position Paper on Ballast Water Management in the Great Lakes
The Izaak Walton League of America (IWLA) recognizes that commercial
navigation on the Great Lakes is an important form of commerce for the
Great Lakes states, the U.S., Canada and many foreign countries.
Unfortunately, ballast water discharged from oceangoing vessels passing
through the Great Lakes contain invasive species and sometimes human
pathogens that create significant changes to the Great Lakes ecosystem
and are a potential health threat to residents. It is well
documented in the Great Lakes and other places that once a
nonindigenous species is introduced into an aquatic system, they are
difficult to control and likely impossible to eliminate.
The IWLA has established policy on invasive species and the treatment of ballast water.
Conservation Policies 2005. Izaak Walton League of
America. 04 Jan. 2006.
www.iwla.org/policies/conservationpolicies.pdf. See pages 57-58.
The IWLA has determined that further reforms are necessary to
require the shipping industry to comply with best available technology
and management practices for the removal or destruction of non-native
organisms in ballast water. Without swift and full compliance,
additional non-native invasive species will continue to be introduced
and the danger to the ecosystem will outweigh the benefits to the Great
Lakes’ states economies. Economists from Grand Valley State
University estimate the cost of existing invasive species ranges from
$200 million to $5 billion per year, and that the economic benefit of
oceangoing commerce in the Great Lakes is approximately $55 million
annually.
Taylor, John C., and James L. Roach.
“Ocean Shipping In the Great Lakes: Transportation Cost Increases That
Would Result From A Cessation of Ocean Vessel Shipping.” December
2005.
From 1994-2003 an average of 535 oceangoing foreign ships entered the Great Lakes per year.
From the affidavit of Raymond Vaughan in support
of the petition of the states of New York, Wisconsin, Minnesota, Ohio,
Illinois, the Commonwealth of Pennsylvania, the Michigan Department of
Environmental Quality, and Great Lakes United to the United States
Coast Guard. Contact committee members for more
information. See also
http://www.oag.state.ny.us/press/2004/jul/jul15b_04.html.
It is estimated that about six million metric tones (1.584
billion gallons) of foreign ballast water mixed with lake water is
discharged in the Great Lakes each year.
Reeves, Eric. Analysis of Laws and Policies
Concerning Exotic Invasions of the Great Lakes: A Report Commissioned
by the Office of the Great Lakes, Michigan Department of Environmental
Quality. 15 March 1999.
http://www.deq.state.mi.us/documents/deq-water-great-lakes-aquatics-exotic2.pdf.
Note: 1 metric tonne is approximately 264 gallons, therefore six
million metric tones equals 1.584 billion gallons of foreign ballast.
Ballast water is thought to be the source for zebra mussels, Eurasian
ruffe, the round and tubenose gobies, spiny water fleas, and quagga
mussels. Some 160 other species of fish and invertebrates have invaded
the Great Lakes, most since the St. Lawrence Seaway opened in
1959. It is estimated by assistant Professor Anthony Ricciardi of
McGill University in Montreal that a new invader is identified in the
Great Lakes about every 7 months.
Meersman, Tom. “Invaded Waters.” Star Tribune, 13 June 2004.
This is unacceptable. These nonindigenous species disrupt the
natural Great Lakes ecosystems, impact the natural reproduction of
native fish and invertebrates, exacerbate botulinus toxin outbreaks
which kill birds and animals, and have other adverse impacts on native
flora and fauna. Further, many of these species quickly spread to
inland waters throughout the U.S. The economic impact to the
sport and commercial fisheries of the Great Lakes is estimated by the
U.S. Fish and Wildlife Service to be $4 billion annually.
At present, treatment of ballast water before discharge from the ships
is the most effective way to address the introduction of non-native
invasive species to the Great Lakes ecosystem. To ensure this
protection, the IWLA recommends the immediate use of chlorine for the
treatment of all ballast water in ships entering the Great Lakes
through the St. Lawrence Seaway (“salties,” or sea-going) and in
intra-lake vessels (“lakers”) that carry goods among the different
Great Lakes basins. The purpose of the chlorine treatment is 1)
to kill as many invasive plants, animals, invertebrates, and human
pathogens as possible from “salties” entering the Great Lakes and 2) to
control the movement of invasive species and pathogens between
different Great Lakes by treating ballast water in “lakers” or
“salties” moving between basins.
Chlorine and/or other ballast water treatment have been used in
treating ballast water in other countries, including Chile, Argentina,
and New Zealand.
Aquatic Nuisance Species in Ballast Water
Discharges: Issues and Options. U.S. Environmental
Protection Agency. 10 Sept. 2001.
http://www.epa.gov/npdes/pubs/ballast_report_attch5.pdf.
Studies show that using chlorine can remove more than 90% of
aquatic invasive species when treated to a residual of 10 ppm (parts
per million) of sodium hypochlorite. 7
Professional engineer and IWLA member Frederick Eyer, who has spent his
career in management of water treatment facilities, estimates the cost
to treat ballast at 10 ppm of sodium hypochlorite and dechlorination of
the residual with sodium bisulfite to be $1.57 per/thousand gallons, or
$157 per million gallons. He further suggests the costs of two
metered pumps for application of the sodium hypochlorite and sodium
bisulfite to be less than $1000 each.
The IWLA is aware of the toxic nature of chlorine and therefore
believes that any sources used in its manufacture should be free of
mercury emissions. Further, ballast water needs to be thoroughly
dechlorinated before discharge. Also, tests for residual chlorine
levels and neutralizing additives should be required to eliminate
negative impacts on the Great Lakes.
Chlorine treatment is only part of the solution. Environmentally
protective ballast water standards must be set with an aggressive
timeline for implementation. The IWLA encourages the shipping industry
to invest in research and development of technologies that may be more
effective than chlorine treatment of ballast water. In addition
to on-board solutions such as chlorine treatment, shore treatment
facilities should be developed by the industry or the Army Corps of
Engineers at several locations along the Seaway. These facilities
should be capable of treating ballast water on ships for invasive
species and removing bottom sediments. The cost of operation of
these facilities should be borne by the shipping industry on a “user
pay” basis.
The IWLA further encourages the shipping industry to implement sediment
removal on a routine basis as a Best Management Practice. Doing
so increases the effectiveness of any ballast water treatment and, in
the case of biocides, significantly reduces the amounts of chemicals
needed as well as the cost per treatment.
Finally, the IWLA suggests that “empty” ballast water tanks be treated
with chlorine or another acceptable biocide. The average residual
sediment and water remaining in a ship after it has off-loaded its
ballast water is 42,000 gallons.
Reeves, Eric. Analysis of Laws and Policies
Concerning Exotic Invasions of the Great Lakes: A Report Commissioned
by the Office of the Great Lakes, Michigan Department of Environmental
Quality. 15 March 1999.
http://www.deq.state.mi.us/documents/deq-water-great-lakes-aquatics-exotic2.pdf.
This secondary treatment would further reduce hard-to-treat
aquatic invasive species or those that burrow into the sediment on the
bottom. The amount of chemical remaining when the ship took on
new ballast would be a part of that treatment although it is quite
probable little would remain after 24 hours if the ship was under
movement.
To assure that rapid progress is made on the best management practices
described above, the IWLA supports the enactment of compatible laws by
the Great Lakes states requiring Clean Water Act discharge permits for
the discharge of ballast water. States could suspend these laws upon
demonstration of adequately protective federal regulations.
Since the League was formed in Chicago in 1922, the Great Lakes
ecosystem has been considered by our members to be a valuable natural
resource. The Great Lakes are a significant economic resource to
the Great Lakes states and Canadian provinces. The IWLA urges
decision-makers and the shipping industry to seriously address the
problem of invasive non-native species and take the necessary steps to
protect this national treasure.
Prepared by the Great Lakes Committee of the Izaak Walton League of America
January 2006
Members of the committee are:
Illinois: Wendy Reid tpreid@mindspring.com
Indiana: Char Read reads@skyenet.net
Jim Sweeney jpbiod@comcast.net
Michigan: John Trimberger jtrimber@earthlink.net
Minnesota: Jill Crafton - bccheyenne@msn.com
Dave Dempsey davemec@voyager.net
Dave Zentner dzentner@charter.net
New York: Les Monostory fishbugm5@twcny.rr.com
Ohio: Rick Graham rick.graham@ohiostatebuckeyes.com
Wisconsin: Jeanne Agneessens lgb@titletown.org
Sarah Mix sarahmix@gmail.com
IWLA National Staff Liaison: Leah Miller - leah@iwla.org
(301) 548-0150 or (800) IKE-LINE