Welcome the the USGLSA Website

Welcome to the web site of the United States Great Lakes Shipping Association. I hope you will find this to be a source of information about our organization as well as have it serve as a useful informational tool for our membership and other interested parties.

Comments from the Executive Director, Second Quarter, 2013

Some current updates from subject areas mentioned in the initial set of comments on this page in the first Quarterly Report, 2013, and possibly a new environmental issue on the horizon.

EPA Ballast Water Vessel General Permit Issued

On Thursday, March 28, 2013, the U.S. Environmental Protection Agency issued its definition of its new Vessel General Permit (VGP) which will now cover ballast water management and several other vessel discharges for the period 2013 through 2018. In general, EPA follows standards already in set place by the International Maritime Organization (IMO) which are generally accepted world-wide and which contain reasonable achievable levels for compliance. As such, that is generally good news considering the alternatives which had been on the table. Following IMO places the EPA VGP more in harmony with the previously issued U. S. Coast Guard Rules covering ballast water management. The new Permit goes into effect December 19, 2013. There are many features and explanations published by the EPA; details of which can be accessed by going to: www.epa.gov/npdes/vessels Some key features of the new EPA VGP are that

• While applying to all international flag vessels entering the Seaway/Lakes System, vessels trading only west of Anticosti Island will be exempt for now. That definition means that the U. S. Laker fleet and portions of the Canadian flag fleet will be exempt from the Permit requirements.
• EPA will still require at-sea ballast water exchange and support of the joint U.S. Canadian ballast water tank inspection regime which is conducted as vessels enter the Seaway/Lakes System.
• The requirement for vessels to have ballast water treatment equipment installed is by January 1, 2016, for currently existing vessels. For new vessels (those constructed after December 1, 2013), the equipment must be installed upon delivery.

The dates by which the equipment must be installed may still be in question as Coast Guard, which is developing the specific designs which will meet the IMO/EPA/Coast Guard standards, has stated it may not have such designs identified until sometime in 2015…pretty tight. Also, several Great Lakes States have not withdrawn from seeking to impose requirements on ballast water despite the emerging universal standards which have been sought for such a long time. And, as previously reported, Canadian authorities may have further views on the matter. Thus, while greatly improved, the regulatory landscape has some remaining uncertainties.

Pilotage Rate Making Review

The U.S. Coast Guard's Great Lakes Pilotage Office continues in co-operation with an independent consulting firm to review the rate making process for pilotage on the Lakes through what is called the Bridge Hour Study. Stakeholders, including USGLSA, have been participating in a review of a first draft of the Study which contained numerous suggested alternatives for Coast Guard to consider. Pilots, industry and other stakeholders have been given full opportunity to comment and make suggestions in writing and through group in-person feedback sessions. A second draft is now in circulation with comments requested by May 9, 2013. While the Study addresses and seeks simplification/clarification of many features of what appears currently to be a complex set of steps, formulas and practices to reach the annual rate determination, at least in my view, much work remains to be done. More to come.

Dredging on the Lakes - Current Budget Proposals

On April 10, the U.S. White House released its recommended Fiscal Year 2014 Budget which included the U.S Army Corps of Engineers budgeted amounts for Lakes maintenance dredging. Regrettably, the budgeted amount for the ports in the entire Great Lakes Region amounts to $40.9 million, about half of the $83.9 million estimated to be required. This is not to mention the amounts necessary to even make a dent in continuing deficits resulting from prior years' inattention to the navigational needs for Lakes and port city commerce. With water levels continuing to be low, this kind of inattention must be reversed. In that connection, Steve Fisher, the very competent Executive Director of the American Great Lakes Ports Association has compiled a set of charts, State by State, which include data on each of the State's harbors and how this disturbing shortfall in budgeted dredging may affect those operations. Should you like a set of those charts, please contact me at the e-mail address below, and I will be pleased to send them to you for use in conversations on the matter as you may see fit.

New Environmental Issue on the Horizon?

Appearing in the April 14, 2013, issue of the Detroit Free Press, "Oil proposals for Great Lakes concern Environmentalists." The article refers to two proposed projects; one of which will expand capacity of a Canadian pipeline known as the "Alberta Clipper" which will transport a form of tar sands crude to Superior WI. The second proposal is a refinery on Lake Superior; all of which could mean as much as 13 million barrels of product per year potentially going on to the Lakes. Not surprisingly, environmental groups are taking note, especially as the proposing company is Enbridge, a major Canadian oil transport group which has been involved in a major spill in 2010 on the Kalamazoo River in MI which continues to plague the area to this day. Certainly, all of this could be part of the politics of pipelines and in particular a spin off on the Keystone XL Pipeline issue between the US and Canada. Also, a plausible observation here is that the proposed expansion would have the effect of substituting water transport for rail which can certainly can be a strategy to get rail companies to lower their rates. Good negotiating?

Questions and comments are always welcome.

Stuart H. Theis, Executive Director
United States Great Lakes Shipping Association
Cleveland, Ohio
440/357-9104 (Phone)
440/357-9105 (Fax)
Exec.Director@usglsa.org (e-mail)
www.usglsa.org (web)