What is ballast water?
Ballast is defined as any solid or liquid that is brought on board a vessel to increase the draught, change the trim, regulate the stability or maintain stress loads within acceptable limits.
With the introduction of steel-hulled vessels and pumping technology, water became the ballast of choice. Water can easily be pumped in and out of ballast tanks, requires little manpower and, as long as tanks are kept full, poses little to no stability problems.
A history of binational co-operation
Ballast water uptake is known to pick up plants and animals. The unloading of unmanaged ballast water in Great Lakes ports is one way that potentially invasive species can be introduced into the waters Canada shares with the United States of America (U.S.). For this reason, our two countries have co-operated closely in establishing regulations to manage ballast water discharges and reduce the risk of invasions. All vessels arriving from overseas are required to exchange ballast water in mid-ocean before arrival. This practice involves replacing ballast water picked up in port with saltwater from the open ocean. Ballast water exchange reduces the number of potential invaders in ballast tanks and also reduces their survival after they are discharged into the freshwaters of the Great Lakes. Even if ships are not carrying ballast, they are still required to flush residual tank contents with open ocean water to reduce the number of seeds, spores and eggs. These binationally compatible regulations have provided safety for ships, crews and the environment while ensuring consistency with international treaties.
Today, all vessels entering the St. Lawrence Seaway from outside Canada’s exclusive economic zone are inspected under a binational program before they enter the Great Lakes. This enforcement action ensures full compliance with exchange and flushing requirements, as ships must either already meet the regulatory requirements or take corrective action to meet them. Scientific research has shown that this program is effective, and recommended it for other freshwater ecosystems around the world. Since this binational inspection system was implemented in 2006, no new non-native species attributed to ships’ ballast water has been reported in the Great Lakes.
Overview
The Government of Canada wants to reduce the risk of aquatic species invasions from ships’ ballast water. This is of particular concern in the Great Lakes and St. Lawrence Seaway System. This binational trade route supports tens of thousands of jobs on both sides of the border. It serves as a critical transportation corridor for commodities such as iron ore, coal, minerals and grain. Canada’s strong and effective ballast water regulations recognize both the environmental and economic importance of the Seaway.
The State of New York’s upcoming unachievable requirements are delaying installation of protective treatment systems and threatening to stop traffic on the St. Lawrence Seaway. Canada continues to strengthen its ballast water regulations, having ratified an international ballast water convention.i Canada invites New York to join international efforts that are increasing environmental protection through rules that are compatible across jurisdictions and can be implemented now.
Canada’s concerns with New York’s requirements
In 2008, in response to a court action in the United States, the Environmental Protection Agency (EPA) began regulating ballast water discharges under the Clean Water Act. The Act requires U.S. states to approve the EPA’s ballast water requirements and allows states to add conditions that apply to vessels while in their waters. This has resulted in a patchwork of inconsistent requirements for the Great Lakes.
New York’s upcoming requirements, which take effect in 2013, are at least 100 times more stringent than those of the International Maritime Organization. Canada has three main concerns with these unachievable requirements.
- Approved ballast water treatment systems are not available to meet the required standard. The EPA Science Advisory Board recently concluded that no current treatment system types will be able to meet New York’s standard.ii The requirements are therefore creating uncertainty for shipowners and delaying installation of available ballast water treatment systems. This in turn delays environmental protection.
- It is not possible to test systems to the level required. There is no approval protocol to test the operation of ballast water treatment systems beyond the International Maritime Organization’s standard. Testing these systems is a complex and difficult process, requiring significant laboratory work and large volumes of water. The EPA Science Advisory Board recently concluded that current available methods prevent testing of New York’s standard.iii
- The requirements apply to all vessels operating in New York waters, regardless of whether they plan to discharge ballast water. As two Seaway locks near the entrance to the Great Lakes lie within New York waters, enforcement of the requirements on transiting ships would stop commercial traffic on the Seaway, including domestic ships travelling between Canadian ports. Additionally, Canadian shipments to and from the Port of New York and New Jersey would be curtailed.
The economic impact of New York’s requirements would be substantial. A recent economic study concluded that closure of the St. Lawrence Seaway at New York’s locks could affect almost $11 billion in business revenue and over 72,000 jobs in Canada and the U.S. Of these jobs, over 31,000 are directly at risk in marine services and in industries that depend directly on ports.iv A closure of the Seaway and the Port of New York and New Jersey would disrupt the shipment of approximately 44 million metric tonnes of cargo (annual average), representing the inputs and outputs of key industries such as agriculture and steel.v
Canada’s approach
As invasive species do not recognize international boundaries, scientists advise that an ecosystem approach, rather than a patchwork of requirements, is the best way to protect the Great Lakes. Canada has recognized that strong new international rules are needed to ensure timely adoption of treatment systems by the global fleet that carries North America’s trade. Thus Canada is working closely with other nations to strengthen its rules and require vessel operators to adopt internationally accepted measures and use approved ballast water treatment systems. For that reason, Canada recently ratified an international ballast water convention that requires vessels to be equipped with treatment systems that "effectively, reliably, and dramatically remove live organisms from ballast water under the challenging conditions found on active vessels." vi
Canada would like to see approved ballast water treatment systems installed on ships as soon as possible so that they can begin to increase environmental protection in the Great Lakes and around the world. This would also improve safety for ships and crews. An estimated 68,000 ships are expected to install treatment systems before 2016 in order to comply with the convention.vii Acting now will create the certainty that will make it possible for shipowners to finance capital investment — estimated at $1 million per ship on averageviii — in systems that are designed to last decades. In light of this, Canada has asked New York to adopt an internationally compatible approach, especially for transiting ships.
Canada values the long-standing co-operation we have enjoyed with the U.S. in managing our navigable boundary waters. Now we must work together to find a compatible approach to ballast water regulation that is practical and protective, and that satisfies all regulators.
November 2011
i The International Maritime Organization’s International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004.
ii EPA Science Advisory Board (2011). "Efficacy of Ballast Water Treatment Systems," p. 37.
http://yosemite.epa.gov/sab/sabproduct.nsf/6FFF1BFB6F4E09FD852578CB006E0149/$File/EPA-SAB-11-009-unsigned.pdf
"No current BWMS types can meet a 100x or 1000x discharge standard."
iii EPA Science Advisory Board (2011). "Efficacy of Ballast Water Treatment Systems," p. 3.
http://yosemite.epa.gov/sab/sabproduct.nsf/6FFF1BFB6F4E09FD852578CB006E0149/$File/EPA-SAB-11-009-unsigned.pdf
iv "Current methods (and associated detection limits) prevent testing of BWMS to any standard more stringent than D-2/Phase 1 and make it impracticable for verifying a standard 100 or 1000 times more stringent."
v Martin Associates (2011). "The economic impacts of the Great Lakes-St. Lawrence Seaway system."
http://www.marinedelivers.com/sites/default/files/documents/Econ%20Study%20-%20Full%20Report%20Final.pdf
vi Transport Canada analysis from St. Lawrence Seaway Management Corporation data.
vii EPA Science Advisory Board (2011). "Efficacy of Ballast Water Treatment Systems," p. 36.
http://yosemite.epa.gov/sab/sabproduct.nsf/6FFF1BFB6F4E09FD852578CB006E0149/$File/EPA-SAB-11-009-unsigned.pdf
viii King, Riggio and Hagan (2010). "Preliminary overview of global ballast water treatment markets.".
http://www.maritime-enviro.org/Downloads/Reports/Other_Publications/MERC_Preliminary/files/assets/seo/page1.html
See also King, Riggio and Hagan (2009). "Preliminary cost analysis of ballast water treatment systems."
http://www.maritime-enviro.org/Downloads/Reports/Other_Publications/MERC_Preliminary_Cost/files/assets/seo/page1.html
