May 9, 2005 testimony by Samuel W. Speck, Director, Ohio Department of Natural Resources on behalf of Governor Taft
Thank you for the opportunity to provide comments regarding ballast water management for vessels entering the Great Lakes declaring no ballast on board (NOBOBs). I am Sam Speck, Director of the Ohio Department of Natural Resources, representing Governor Taft today on a priority issue for Ohio and the Great Lakes region stopping new introductions and the spread of aquatic invasive species (AIS) in the Great Lakes. Eliminating introductions of AIS from ballast tanks of incoming vessels to the Great Lakes, addresses one of the most important natural resource management issues facing the United States. We must take action to combat this significant and urgent risk to the environmental and economic health of our region and the United States. I urge you to be responsive to the comments expressed today by Governor Taft, as well as comments from several other Great Lakes organizations and states. The Council of Great Lakes Governors, which Governor Taft co-chairs with Governor Doyle of Wisconsin, the Great Lakes Commission, where I represent the Ohio Delegation as a Board Member, and several other Great Lakes states have made it a priority to attend this meeting today to also express the urgency and importance of regulating NOBOBs. I have four key points to make during the short time each speaker has been allotted.
First - Enacting mandatory ballast water management practices for NOBOBs is a critical and necessary step.
Ballast water introductions are the single most important conduit for AIS introductions to the United States. Other AIS control strategies will continue to be hampered until this primary source is eliminated. Because the majority (>90%) of vessels entering the Great Lakes declare no ballast on board and these vessels can also contain living organisms, failure to enact mandatory management practices for NOBOBs would represent an enormous shortfall in the overall effort to prevent introductions of AIS.
Second - Prevention of AIS must be the primary focus of management strategies.
Because AIS are difficult to control, and almost impossible to eradicate once established, preventing their introduction must be the primary focus of management strategies. Continued introductions of AIS have enormous economic consequences. Estimated costs related to the negative consequences of AIS are well into billions of dollars annually. Among other impacts, additional AIS introductions further threaten the Great Lakes sport and commercial fishing industry, which alone is valued at $4.5 billion annually. The biological damage caused by AIS is immeasurable. Aquatic ecosystems throughout the United States have been fundamentally, and in many cases, irrevocably, altered by AIS. This has resulted in significant losses of native species and reduced productivity of these systems. In Ohio, for example, zebra and quagga mussels have extirpated native freshwater mussels from Lake Erie and many of its fisheries have been directly impacted by AIS. The current efforts do not effectively preclude new introductions of AIS.
Third - A federal approach is needed to effectively stop the introduction and spread of AIS.
Managing AIS is a complex endeavor and success will ultimately require cooperation between public and private entities, both in the United States and internationally. We encourage the USCG to exercise its full authority toward aggressive and decisive action to stop the introduction and spread of AIS from all vessels including NOBOBs. The states will be less effective implementing prevention strategies individually than the federal government implementing prevention strategies which are consistent nationwide. Failure to adequately address this national concern, will lead to more state legislatures passing laws targeting sources of AIS in their states and regions.
Fourth - The goal must be zero discharge of living organisms from vessels entering the Great Lakes.
Progress in the prevention and management of AIS in the Great Lakes will only occur through sustained, multi-faceted efforts, including development of a policy of zero discharge. We encourage the USCG to continue working with shipping and research interests to develop effective technology and practices for ballast water management in all vessels including NOBOBs. Many emerging technologies show promise of being effective for killing living organisms in residual ballast water and practical for implementation in existing vessels. Ohio EPA recently provided information on Ohio water quality standards and allowable discharge limits of biocides proposed by the USCG for use in controlling AIS in the residual ballast water in NOBOB declared ships. The USCG must enact needed regulations as soon as possible and encourage development of technologies to serve those ends rather than allowing current shortcomings in technologies to limit the scope of regulatory action.
In conclusion, eliminating introductions of AIS from ballast tanks of vessels entering the Great Lakes, addresses one of the most important natural resource management issues facing the United States. A federal, mandatory approach to prevent further introductions of AIS must be undertaken as soon as possible to begin to realize the goal of zero discharge of living organisms from all vessels including NOBOBs. We look forward to future collaboration on AIS issues in our shared responsibility to protect and conserve our aquatic resources.