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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
Review of 2015
Another Lakes/Seaway Navigation Season ends with the Winter closure of the Seaway System. After a brief pause in the action for our international flag partners with that closure, it seems like a good time to take a look at a few of the items which attracted the attention of USGLSA and what may be in store for 2016.
Navigation and Ice Conditions
Thankfully, the opening of the 2015 Navigation Season was not nearly as chaotic as it was in 2014. However, neither was it so easy, as early Spring weather conditions remained formidable. Credit to the US and Canadian Coast Guard for their responsiveness with improved queuing and convoy management as well as other communications improvements helping to facilitate the deployment of pilots and assets to reduce the length of delays which were experience in 2014 by the vessel operators served by USGLSA agents. The 2015 Season proved to be not quite as strong as 2014, but otherwise proved to be better than reported calls since 2007. The Season ended with unseasonably fine weather which could have an effect of helping to make the 2016 opening comparatively more favorable. However, Mother Nature can be cruelly unpredictable such that the Coast Guard Ice Conference Calls are well into operation currently and assets are deployed as ice formations especially in the Northern Lakes and along the shores are being reported. As I write these Comments in mid-January, it is about 9 degrees F outside and we have about 12 inches of snow on the ground out here in the Cleveland Area snow belt, so we need not get over confident and should remain prepared for anything as much as possible.
Rate making for pilotage services as set by the USCG, demanded a considerable amount of attention from USGLSA during 2015. Prospects for that situation to continue appear likely. As previously reported in this space, the USCG Lakes Pilotage Office has proposed significant changes in its rate making methodology resulting in proposed new rates and special surcharges which, if implemented for the 2016 Navigation Season, are estimated to increase pilotage expense to vessel operators by approximately 58 percent or more. The public Comment period on these proposals closed on December 9, 2015. A group of stakeholders led by The Shipping Federation of Canada, American Great Lakes Ports Association and USGLSA submitted strong objections to these proposals based on legal, administrative and economic principles. A total of 81 sets of comments from the public have been posted to the docket. USCG has expressed the intention of issuing a Final Rule prior to the opening of the 2016 Navigation Season. Alternative action in response to the Comments could be possible.
Great Lakes PiIotage Advisory Committee (GLPAC)
Also relating to pilotage, this past year saw some progress in efforts by USGLSA and others to reform the communication channels between pilots and the international flag vessel operators which actually receive and pay for the pilotage services. Currently, only U.S. citizens are allowed to serve on the Committee as is the case with other Federal Advisory Committees such as GLPAC. In 2015, with valuable facilitation provided from the USCG Lakes Pilotage Office, informal meetings were arranged and the pilots and international flag vessel operators met face to face and directly discussed issues of concern. To some observers, that may not appear to be a major development, as it seems to be such an obvious step. However, that irony dramatically makes the point that clearly, the currently required GLPAC membership structure which inhibits this direct interaction and adversely impacts the effectiveness of GLPAC needs to be changed.
Creation of Pilotage Office presence in the Lakes Region
As a means of obtaining a better sense of the operation and delivery of Lakes pilotage services, USGLSA and others have suggested to USCG that it might consider increasing its Lakes Pilotage Office local presence in the Lakes Region rather than operating solely from Washington, DC. A likely location suggested was the current USCG District 9 Headquarters in Cleveland. Indeed, the Pilotage function was located in Cleveland some years ago until it was moved to Washington for reasons which remain unclear. Whether this suggestion would mean moving the entire office from Washington, DC or simply posting some operating staff would have to be discussed. After some encouraging signs that this suggestion might make some sense, it is now reported that no further action is currently planned. Too bad.
Ballast Water Management and Vida Legislation
During 2015, a Federal Appeals Court decision was reported out which appears to have the potential for clearing the way for resolution of conflicts between USCG and EPA regulations affecting ballast water management aboard vessels. Heretofore, these conflicts have caused much uncertainty to vessel operators and shipbuilders seeking to design and install compliance grade equipment. Unfortunately, while finding the EPA Rules flawed, the Court did not strike them down, but instead ordered them rewritten. Estimates are that such a rewrite could take many months; pessimistically, maybe more than a year. Thus, rather than removing the uncertainty by perhaps placing ballast water management solely in the hands of USCG, things could well go into a worse state of paralysis given the unknown of what and when the EPA produces and what further judgments, if any, the Court may make once the EPA work product is delivered. Overall, not a good development for the cause of clarity.
A potential saving element previously identified could be the passage of the Vessel Incidental Discharge Act (VIDA) which would legislatively remove all of the conflict and firmly place ballast water management solely in the hands of USCG. The House and Senate versions of VIDA, while receiving strong support from many maritime organizations including USGLSA, has not received final approval to date.
Final Rule on APHIS Inspection Fee Changes
This information item updates prior reports on the subject. It involves proposed increases in U.S Department of Agriculture inspection fees charged for agricultural inspections of vessels as well as other transportation modes moving agricultural products in and out of the U.S. Despite opposition from a large group of interested parties which included USGLSA, the USDA finalized this matter and instituted those rates during 2015. Among the unfortunate changes made in addition to higher rates for vessels was the elimination of a so called “cap” limitation on the number of times the fees were charged to vessels calling at the same U.S. port.
During 2015, USGLSA participated jointly with a number of maritime organizations though meetings and event attendance as well as advocacy and support concerning initiatives and issues affecting our industry and the customers our agent members serve. These organizations included
- The National Association of Maritime Organizations (NAMO) – Representing nationwide maritime shipping and port interests. I currently serve on behalf of USGLSA as NAMO’s Vice President for Great Lakes.
- Green Marine - Founded in 2007 by a small handful of U.S and Canadian Lakes/ Seaway operators and interested parties including USGLSA. This organization, through a rigorous certification process is able to demonstrate to the public the environmental advantages of maritime and the good environmental citizenship practiced by the vessel operators, ports and other participants in the trade. Green Marine membership and participation ow extends to the East and West coasts of the U.S. and Canada including the Lakes/Seaway Region. USGLSA remains a part of this effort thorough membership and participation of the Great Lake Advisory Committee.
- U.S. Coast Guard Federal Advisory Committees - GLPAC (previously identified) and the National Maritime Security Advisory Committee – NMSAC. During 2015, my membership on both of these Committees expired after 6 years of service, which is required by the law. However, USGLSA continue its interest in both of these subject areas with USCG and will participate as appropriate on the issues of pilotage and maritime security.
- Highway H20 – An initiative of the Canadian St. Lawrence Seaway Management Corporation and U.S. St. Lawrence Seaway Development Corporation promoting international trade into the Seaway System and throughout the U.S. and Canadian Lakes/Seaway Region.
- The formation of the Great Lakes Seaway Partnership sponsored by the American Great Lakes Ports Association, the Lake Carriers’ Association, Fednav, Limited and the St. Lawrence Seaway Development Corporation. In its release announcing the formation, the Partnership said, “The organization will manage an education- focused communications program, sponsor research and work closely with media policy makers, community groups, allied industries environmental stakeholders, and the general public to highlight the positive attributes of marine transportation.” On behalf of USGLSA, we wish this effort great success and will look forward to working with the Partnership as issues and projects unfold in the future.
- Recently, the well-respected Conference of Great Lakes and St. Lawrence Governors and Premiers released a draft of a comprehensive Strategy for the Great –Lakes St Lawrence River Maritime Transportation System. The Conference invites public comments by February 3, 2016, the latest. Although only in draft, I wanted to provide this to readers who may not be aware of it. The document really appears to be an excellent overview and collection of recommendations on a wide range of challenges and opportunities affecting the Lakes/Seaway Region. In final form, I am confident it will provide an excellent platform for advocacy for the Lakes/Seaway maritime industry and the economies of the 8 U.S. Great Lakes States and the Canadian Provinces of Ontario and Quebec. A copy of this draft is posted on the USGLSA website under the category of “Items of Interest.” Even as the February 3 comment deadline passes, the document is worth the read and in final form will surely be a valuable contribution to the message we wish to share about our maritime transportation system.
- In June of 2015, the Lakes welcomed Rear Admiral June E. Ryan as the new District 9 Commander. USGLSA looks forward to working productively with Admiral Ryan and her staff.
- Dredging on Lakes and associated rivers and harbors and the ongoing efforts to assure that the U.S. Army Corps of Engineers is funded adequately continues. Application of the terms of Water Resources Reform and Redevelopment Act (WRRDA) and utilization of Harbor Maintenance Tax (HMT) revenues have improved prospects under this legislation. USACE Lakes budget allocations are reported to be more responsive and improved, but as Federal budgets and cyclical water levels can change and competition for these monies can be fierce, this funding matter will still require careful attention.
- Last, but surely not least, I have a new boss in the person of Mr. Larry Del Regno who was elected earlier in 2015 to succeed Mr. Tom Gierszal as President of USGLSA. Sincere personal thanks to Tom for all his support, effort and counsel as President. It has been my honor to work with Tom. I have already experienced those same qualities in Larry’s leadership as we have worked together during 2015. It bodes well for the future of USGLSA.
USGLSA will continue to work hard to provide value and support to its agent members and the vessel operating Principals they serve. Going forward, we hope that we might hear from readers with any suggestions or comments on how we may improve our strength and effectiveness to achieve those goals. Best wishes to all for a safe and rewarding Navigation Season on the Lakes and in the Seaway during 2016.
Stuart H. Theis
Mr. Theis, who has served as Executive Director since April 2007, is an attorney and businessman with prior associations at Cleveland, Ohio based M. A. Hanna Company and Oglebay Norton Company. At Hanna, he held a variety of legal/operational positions including Corporate Vice President with responsibilities for Hanna's Great Lakes/St Lawrence Seaway and Ocean Marine vessel and dock operations in the U. S. and Canada. While at Oglebay Norton, Mr. Theis served as President of the Company's Great Lakes fleet and dock operations. Mr. Theis is a member of the American Bureau of Shipping and has recently served as a member on two U. S. Coast Guard Advisory Committees, the Great Lakes Pilotage Advisory Committee and the National Maritime Security Advisory Committee.