Comments from the Executive Director

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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.

 

                        MESSAGE FROM THE EXECUTIVE DIRECTOR

 

September, 21, 2011

 

A primary role that USGLSA plays for its Member organizations is to participate in advocacy for the benefit of those Members’ principals/customers which consist primarily of international flag vessels calling at U.S. Ports.  Ballast water issues continue to remain in the forefront. 

 

While it is anticipated that the U.S. Coast Guard will be publishing comprehensive regulations providing for a single ballast water management program before the end of the year, there have been developments on the international front as well. 

 

In 2010, the U.S. and Canada announced intentions to update what is known as the Great Lakes Water Quality Agreement which dates back almost 38 years and has been modified from time to time; the last time in 1987. US and Canadian representatives, including input from the International Joint Conference (IJC), have been negotiating changes and in connection with their process, have invited comments from the public. Last week, I participated in a public Webinar offered by the negotiating parties.  While there were laudable topics on the table (negotiations continue) there  appeared to be a distinct lack of attention being given to the importance of the commercial vessel operations.

 

What follows is a copy of remarks submitted to the Agreement negotiating team by USGLSA.

 

On September 13, 2011, I  represented the United States Great Lakes Shipping Association (USGLSA) during the Public Webinar regarding the current negotiations to revise the US/Canada Great Lakes Water Quality Agreement.

By way of background, USGLSA is a trade association consisting of members who serve as vessel agents serving vessels calling at Great Lakes ports.  The vessels these agents serve are primarily Canadian flag and other international flag vessels coming from around the world through the St. Lawrence Seaway System and entering the Lakes.  While USGLSA does not represent the international fleet owners directly, issues affecting them are of great interest to the USGLSA member agents and are therefore often the focus of USGLSA advocacy. USGLSA is a member of the National Association of Maritime Organizations (NAMO) and participates in many other Seaway/Lakes initiatives.

The Webinar was very informative and conducted very professionally.  We thank you for the opportunity to participate and would now respectfully provide the following comments and suggestions for consideration:

1) We applaud the general statement of objectives of the negotiation be to achieve water that is "drinkable, swimmable and fishable." However, while recognizing that this Agreement is focused on water quality, that should not necessarily mean that the negotiators should ignore the propriety of making note of the need to harmonize those objectives with the commercial transportation importance represented by the Lakes to both countries. It is well known that the Great Lakes/St. Lawrence Seaway System provides a vital transportation link to U.S. and Canadian commerce affecting the well being of citizens in many States and Provinces. The jobs at the Ports and the commercial enterprises served by vessel traffic is significant to both countries as trading partners.

2) We suggest that the Agreement might include notations of support for the strengthening of commercial activities on the Lakes which can be in harmony with the objectives of clean water.  We suggest the efforts and progress currently being made by government and the industry in this regard which, while not yet perfect, represent much progress  being made which should be recognized and encouraged through the overall recommendations contained in the Agreement.  For example,

  • Currently and for several years now, US/Canadian authorities have required any ocean vessel entering the Lakes/Seaway system to exchange ballast water at sea. Once into the St. Lawrence River, each vessel is  then detained near Montreal and every ballast tank checked prior to entering the System to assure a saline content in the ballast  tanks which will eradicate all invasive species.  This regime has resulted in no new aquatic invasive species having been detected in the Lakes for over 4 years.
  • Vessel operators, voluntarily and at their expense, individually and in concert with public and private groups, are currently and actively testing new technologies and ballast water management procedures, seeking to improve this necessary process.
  • By the end of the year, U.S. Coast Guard is expected to issue a comprehensive set of ballast water regulations which will hopefully help move the Lakes operations toward compliance with a universally accepted standard instead of the current individual state regimes which have proven chaotic and unproductive. 
  • Further, some of the State involvement  in this area of Lakes water quality regulation can present international impacts of which the negotiators may already be aware, but should consider addressing by supporting reasonable and rational approaches.  In New York, for example, the State Department of Environmental Conservation has proposed that water quality in ballast tanks of vessels passing through New York waters (not even necessarily discharging) must have to be of a quality 100 times higher than IMO (International Maritime Organization) standards (drinking water equivalent) by August 1, 2013 and 1000 times higher than IMO standards by January 1, 2013.  Since these standards are clearly impossible to achieve, a complete stoppage of all traffic from the Seaway into the Lakes and return wood result which some commentators suggest will violate certain trade agreements and treaties between the U.S. and Canada . As improbable as this may seem, New York appears adamant and people are beginning to take this prospect more seriously.

The point of all of this is that we believe the role commercial vessel traffic plays in the Lakes is an important factor in the Lakes which should be recognized by the negotiators in the Agreement.  We suggest that the Agreement provide a sign post for both countries to work together in a balanced and rational manner, while seeking the clean water goal.  We recommend that the U.S. and Canada commit to promoting a vital commercial Lakes/Seaway vessel industry which will comply with universally applicable standards. We seek  the cooperation of all players toward the achievement of clean water through reasonable, realistic and balanced steps so that the healthy and important trade between our countries continues as we seek water that is "drinkable, swimmable and fishable"

Thank you for the opportunity to provide these thoughts.

Respectfully submitted,

Stuart H. Theis, Executive Director

United States Great Lakes Shipping Association

Cleveland, Ohio

440/357-9104 (Phone)

440/357-9105 (Fax)

theismarine@roadrunner.com (e-mail)

www.usglsa.org (web)

 

 

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. Most recently, he served as an independent consultant to the Cleveland-Cuyahoga County Port Authority with oversight responsibility for a feasibility study examining the possibility of a Trans Lake Erie ferry service between Cleveland and Port Stanley, Ontario.