Save The River has long been a proponent of stringent ballast water regulations for all ships entering or transiting the St. Lawrence River and Great Lakes as the only means of stopping the introduction and spread of aquatic invasive species. Since 1959, when the St. Lawrence Seaway opened the River and Lakes to direct ocean-going shipping, 65% of species discovered have been attributed to ballast water release. River communities know the serious impact aquatic invasive species have on the health of the St. Lawrence River and our local economy. The cost of zebra and quagga mussel control alone is estimated at $500 million per year over the next five years and the impact on indigenous species such as bass from invaders like the round goby cannot yet be calculated.

While we have applauded incremental steps to clean up ballast water in the past such as the Seaway’s requiring salt water flushes of ocean-going vessels, we have steadfastly maintained that the goal must be zero discharges of non-native species in ballast water. This past week the EPA had an opportunity to make significant progress toward that goal. Instead it finalized regulations that limit, but do not eliminate the number of organisms that can be dumped into our River.

It is disappointing that almost 40 years after the enactment of the Clean Water Act it took a lawsuit to force the EPA to act to protect the nation’s waterways at all and that when it did act, it did so in such weak manner.  Significantly the EPA regulations set out:

• a weak standard – the EPA accepted the industry endorsed ‘IMO’ standard, which from our perspective (and that of the state of California, with a standard 100x more protective) represents the bare minimum for regulation and is not protective of the River, with no requirements on ships that only transit the Lakes;

• a weak timeline – the EPA expects all ships to be compliant by 2018, but with no apparent recourse if ships do not meet that deadline; and

• no mechanism to strengthen standards or improve technology – our concerns come straight from an industry spokesman, who stated, “EPA’s final rules now end the debate over ballast water regulation.”

No one should be lulled into a sense that our River and the economy that depends on it are safe with these standards. The next destructive invasive species may be only a ballast discharge away.

The opening of the Seaway prompted a reflection on the state of the River and the River communities that depend on it. We were pleased that several newspapers (Thousand Islands Sun, Kingston Whig-Standard, Brockville Recorder & Times and the Watertown Daily Times) thought it worth publishing. The T.I.Sun version is here.

As the Seaway opens this week for its 54th shipping season, we’ve been grappling to fully understand the long-term implications of last Friday’s release by the US Coast Guard of their final rule for regulating ship ballast discharges.

(The final Coast Guard rule can be found here. And, interested readers can learn more from the Watertown Daily Times: Environmental advocates “disappointed” with final US Coast Guard ballast rules and Associated Press: Coast Guard orders ships to cleanse ballast water to protect against foreign species invasions)

River communities know the serious impact aquatic invasive species have on the health of the St. Lawrence River and our local economy. Ship ballast discharges are the single largest source of aquatic invasive species introductions to the waters of the River and Great Lakes. Save The River and River communities have long advocated for strong ballast water clean-up rules to protect from future aquatic invasive species introductions.

As is often the case with news about federal regulations, we have good news and bad news to report on the Coast Guard’s rule. Unfortunately in this case the news is more bad than good.

The Coast Guard’s regulations contain several key disappointments.

• Weak Standard – The Coast Guard has selected to enforce the ‘IMO’ standard, which from our perspective represents the bare minimum for regulation and a standard that is not protective of the River.

• Weak Timeline – Most salties navigating the Great Lakes and St. Lawrence River would have to comply with this new rule beginning in 2016, which is nearly 4 years away. (As a side note, the Coast Guard rule does not regulate ‘lakers’, ships that operate solely within the GreatLakes. Although lakers do not bring new aquatic invaders into the Lakes, they do contribute to their spread.)

• No Mechanism for Stronger Standards & Technology Development - In it’s draft, the Coast Guard had proposed a two phase approach to regulating ballast discharges, with a goal of ultimately reaching a very strong standard (commonly referred to as 1,000xIMO). This phased approach would have been critical in driving technology development for stronger ballast treatment systems. Unfortunately, the Coast Guard’s final rule eliminates the proposed second phase, removing incentive to develop even better ballast treatment systems.

While the Coast Guard does indicate in the final rule that they will consider stronger standards in the future, we are left to wonder how long it will take for them to do so and whether our River can wait.

What’s Next?

A press release from our coalition partners Great Lakes United, National Wildlife Federation, Alliance for the Great Lakes and National Resources Defense Council details of actions for moving forward in efforts to clean up ship ballast tanks. (Coast Guard Issues Ballast Water Discharge Standards: Misses Mark to Protect Nation from Invasive Species; Conservation groups look to states and Environmental Protection Agency to strengthen standards, shortening timeline, and address loopholes )

In short, two opportunities are available in the coming year:

• US EPA Regulations – The US Environmental Protection Agency has yet to issue their final ballast regulations. We will be looking to the USEPA to step up to the plate on this issue and anticipate seeing their final regulation in the coming months.

• State Action – We will be continuing to ask states, such as New York that have considered their own ballast regulations, to continue to be leaders in protecting our waterways from the threat of future aquatic invasive species introductions.

A bill being considered by Congress this week will derail progress on cleaning up ship ballast tanks and stopping aquatic invasive species introductions. Call your Member of Congress today and tell them that the St. Lawrence River needs stronger – not weaker – ballast clean up programs!

Background

Aquatic invasive species, such as zebra mussels and round gobies, are one of the most significant environmental threats to the health of the St. Lawrence River and Great Lakes. Invasive species foul beaches, wreak havoc on the fishery, clog water intake valves of cities and utilities, and harm fish and wildlife. A few invasive species facts:

• More than 60% of aquatic invasive species found today in the River and Lakes were brought in by ship ballast tanks.

• Research shows that the annual cost to Great Lakes states from invasive species introduced by oceangoing vessels may be upwards of $200 million annually.

• Recognizing this problem, in 2005 the Great Lakes Regional Collaboration warned of an impending “invasional meltdown” in the Great Lakes.

Unfortunately Congress is moving in the opposite direction. The House of Representatives is set to vote this week on the Commercial Vessel Discharges Reform Act of 2011 (Title VII of  HR2838). This bad bill would:

• Set ballast clean up standards – called the ‘IMO standard’ – that are inadequate to fully protect the St. Lawrence River and our nation’s waters from invasive species;

• Delays even those weak standards by up to 10 years;

• Prevent states like New York from implementing their own strong ballast clean up programs;

• Makes it difficult, if not impossible, to add new protections even if the US EPA or other agencies determine that the IMO standard is not doing the job; and

• Stops citizens from being able to enforce the law through the Clean Water Act.

Bottom line: This bill does not protect the St. Lawrence River or our nation’s waters; it protects the shipping industry. It will derail progress on cleaning up ship ballast tanks and stopping more aquatic invasive species introductions.

Take Action!

Contact your Representative in Congress today to ask them to defeat this bad bill so that our River is protected from aquatic invasive species introductions. (Not sure how to contact your Congressional Representative? Find your Representative.)

Talking Points for Calling or Writing Your Legislator

• I am calling/writing to urge [insert Member's Name] to oppose the Commercial Vessel Discharges Reform Act of 2011 (Title VII of  HR2838).

• Aquatic invasive species are one of the most serious threats to the St. Lawrence River. [Insert why the St. Lawrence River is important to you.] We need stronger ballast clean up programs that protect the St. Lawrence River and our nation’s waterways to prevent more damaging aquatic invasive species introductions.

• I urge [insert Member's Name] to delete the bad ballast water amendments – Title VII from HR 2838 – and to vote against the Coast Guard and Martitime Transportation Act of 2011 if those provisions remain.

• Thank you for protecting the St. Lawrence River.

Let us know what you hear! E-mail or call us to let us know how your Member of Congress responds!

Thank you for speaking out for the health of the St. Lawrence River!

We’ve all been hearing the dire news about Asian carp. These invasive fish are at the Great Lakes’ back door, just miles from Lake Michigan. Not only are they threatening the delicate ecological balance of the Great Lakes and St. Lawrence River, they are a major threat to our regional boating and tourism industry. But, to those of us hundreds of miles downstream, action to keep the Asian carp out of the Great Lakes, and ultimately the St. Lawrence River, seems to be proceeding at a glacial pace.

Save The River has been in touch with regional environmental partners, government agencies, and elected officials to figure out what’s going on with this critical River issue. Here’s what we’ve learned….

Few Quick Solutions Available

Frustratingly, few complete solutions are available to stop the carp quickly. The U.S. Army Corps of Engineers continues to operate an electric barrier fence in waterways near Chicago separating the Mississippi River from Lake Michigan. However, questions about the effectiveness of the barrier have been raised and the Corps refuses to release data that would provide more information on the barrier’s ability to keep out the carp. [Update: Thanks to great work by our friends at NRDC, the Corps has just been forced to release this data.]

Immediate closure of the navigation locks in Chicago has also been proposed as an immediate solution. However, lock closure would only block three of five connecting waterways and, as a result, would not be fully effective in keeping the carp out of Lake Michigan.

The only permanent solution to keeping the Asian carp out of the Great Lakes and St. Lawrence River is restoring hydrologic separation of the Great Lakes and Mississippi basins. Over the past two centuries, canals have been constructed to connect the two basins that were never naturally connected. This connection has not only sped up the transfer of invasive species between the two basins but has also increased water loss from the Great Lakes.

Unfortunately, the City of Chicago’s aging sewer and water infrastructure was engineered to utilize these man-made connections, as a part of a centuries old effort to keep sewage away from the city’s drinking water intakes in Lake Michigan. Add to the equation a barge industry that is vociferously opposed to closing the connection between the Mississippi and the Great Lakes and the full picture of what is needed to reach the goal of complete hydrologic separation becomes clear.

What You Can Do

Tell the Corps to Speed Up Study

The U.S. Army Corps of Engineers is currently studying hydrologic separation solutions through the Great Lakes and Mississippi River Basin Interbasin Feasibility Study (GLMRIS). Despite its bureaucratic name, this study is critical because it will determine if implement permanent solutions to stop the Asian carp are implemented.

Unfortunately, the study is moving at a snails pace and the study goals have been diluted. The Corps is collecting public comments through March 31. Comments can be submitted via the study website: glmris.anl.gov. Comments are needed from citizens to help carry two critical points. Learn more about the study and find talking points for comments in our action alert.

Contact Your Representatives in Washington

Legislation has been submitted in Congress that will force the Corps to speed up their study and improve the focus. Contact your elected officials in Washington and urge them to support this important bill. (Not sure how to contact your Members of Congress? Check out this handy website.)

Keep Up to Date

To stay up to date with further developments on this critical issue,  sign up for our e-news or connect with Save The River on Facebook and Twitter .

It’s not too late! You still have time to write the U.S. Army Corps of Engineers to call on them to stop the Asian carp. The deadline to comment is this Thursday, March 31.

The U.S. Army Corps of Engineers are collecting public comments through March 31st on their Great Lakes and Mississippi River Basin Interbasin Feasibility Study (GLMRIS). Despite its bureaucratic name, this study is critical because its focus will determine if we implement permanent solutions to stop the Asian carp!

Many thanks to those of you who have already submitted comments on this important issue! If you haven’t had a chance to write the Corps yet, read on for more information on how to comment and talking points for your letter.

Background

Asian carp, an invasive fish species that could devastate the St. Lawrence River and Great Lakes, are at our back door just miles from Lake Michigan.

These fish are voracious filter feeders. The bighead carp can consume 40 per cent of its body weight each day, while the silver carp’s tendency to jump out of the water when startled makes them a hazard to boaters. They would cause irreversible harm to the Great Lakes by consuming large quantities of algae and zooplankton, outcompeting native fish populations. The estimated impact to the recreational and commercial Great Lakes fisheries would reach to over $4.5 billion. (For more information about the Asian carp issue, read our blog post.)

Top Two Reasons Why You Should Comment!

1 – The Corps was mandated to study ways to prevent invasive species movement between the Great Lakes and Mississippi River. Unfortunately, the Corps has decided to spend precious time and resources to also study ways to “reduce the risk,” not just prevent. This was not authorized by Congress nor is it a credible strategy that will protect our Great Lakes. We need you to tell them this is unacceptable and only options that will prevent invasive species movement and stop the Asian carp should be studied.

2 – The Corps study takes too long. The Chicago portion of the study is not predicted to be complete until mid-2015, or nearly five years from now. The Corps must acknowledge the urgency of finding a permanent solution, condense the timeline and produce final results for the Chicago portion of GLMRIS within 18 months rather than mid-2015 and we need you to send that message.

Concerned citizens may submit comments via the study website here: http://glmris.anl.gov/involve/comments/index.cfm no later than March 31, 2011.

For More Information

More information on the study may be found on the official GLMRIS website.

Helpful talking points for preparing to speak at hearings or to submit comments can be downloadeded from this helpful fact sheet prepared by Fresh Water Future.

More information on the Asian Carp issue can be found on the Great Lakes United Asian Carp page.

Thank you for speaking out on this critical River issue!

Below is a commentary, written by Save The River’s Executive Director, reflecting on the opening of the 52nd Seaway season.

March 22, 2011

Today marks the beginning of another season of shipping on the St. Lawrence Seaway. We’re relieved that there is little ice on the main channel, removing the need for icebreaking to open the River for ship passage. Unfortunately, the navigation buoys sit on the River’s shore and many of the boat launches, which are critical staging areas in the event of a shipping accident or spill, remain closed with plenty of ice.

This year’s Seaway opening coincides with World Water Day, which serves as an annual global celebration of water and a day of action focused protecting our precious water resources. Ironically at the same time, the Seaway agencies and shipping industry are promoting a new ‘green’ public image. The U.S. Seaway agency’s annual report just arrived in our office last week and in it, the Seaway calls itself one of the most “environmentally responsible marine transportation systems in the world.” That’s a pretty big statement and we feel it deserves some scrutiny.

The Seaway agencies and shipping industry have systematically put themselves on the wrong side of environmental policy debates. For nearly 20 years, since the introduction of the zebra mussel, they resisted any rules to clean up ship ballast tanks to prevent further invasive species introductions. Three years ago, the Seaway finally established its own rules but they are the minimum protections available. And today, as state governments and citizens call for better protections against invasive species introductions, representatives from the shipping industry and the Seaway are walking the halls of Washington, Ottawa, Albany, and the courts arguing vigorously against stronger ballast clean up rules.

And, it doesn’t end with ballast. Shippers and the Seaway are on record opposing the environmentally beneficial water levels plan (Plan B+) that our communities have been supporting for years. They’ve fought for (and unfortunately won) exemptions from federal rules to clean up ship smokestack emissions, making some of the Great Lakes ships among the dirtiest air polluters in the industry. And, the Seaway has unilaterally extended the shipping season on the St. Lawrence River, with no input from River communities, state or federal environmental and safety agencies, or elected officials. These are not the actions of an “environmentally responsible” agency.

If the Seaway wants to be “environmentally responsible” and be seen as a good neighbor by those of us who rely on the River for our livelihood and our way of life, they must begin a good faith effort to work proactively to protect the St. Lawrence River and Great Lakes. For a few ideas, we suggest they start with the recommendations outlined by more than 50 environmental and conservation groups in the report “A Better Seaway”, which lays out a specific action plan to reach a truly sustainable and responsible marine transportation system. (Visit www.abetterseaway.org to learn more.)

Promoting a greener image is one thing, but without actions to back it up we have nothing but words from the Seaway, and no one to protect our River but ourselves.

- Jennifer J. Caddick, Save The River Executive Director & Upper St. Lawrence Riverkeeper

Great Lakes United * National Wildlife Federation * Save The River

As Seaway Opens, Groups Call for Strong Coordinated Action to Stop Invasive Species

Buffalo, N.Y. (MARCH 21) —In what is turning out to be a pivotal year in the battle to protect the Great Lakes and other waters from the onslaught of invasive species, conservation organizations are calling for strong, coordinated action by the U.S. and Canadian governments to stop ships from dumping ballast water filled with harmful biological pollution.

The call for action comes as the St. Lawrence Seaway prepares to open tomorrow for its 52nd season amidst the myriad of pending state and federal ballast water regulations aimed at protecting U.S. and Canadian waters from species like the zebra mussel and round goby—unwanted invaders that cost Great Lakes citizens, businesses and cities more than $200 million per year in damages and control costs.

“For years, the Seaway opening has been a huge sign advertising the Great Lakes are open for the next invasion,” said Jennifer Nalbone, director of navigation and invasive species for Great Lakes United. “The Great Lakes are home to a multi-billion dollar fishery and source of drinking water for tens of millions of people. They require the highest protections possible, not the most convenient.”

This year could be a turning point in the fight against invasive species. After over 20 years of virtual inaction, the U.S. and Canadian governments are setting the stage to finally confront the ongoing problem of invasive species so that shared waters can be protected from biological pollution. However challenges remain regarding harmonizing regulations on shared waterways.

The groups are urging the U.S. and Canada and the region’s states to move quickly to coordinate and implement the highest protective standards proposed in the region, across the region, to mandate that ships do not dump harmful invaders into bi-national waters.

After years of inadequate action by the two federal governments, momentum is building to shut the door on aquatic invasive species—due largely to the efforts of state public officials who have passed ballast requirements and established numeric ballast water discharge standards, as well as advocacy groups, which have filed lawsuits to protect water quality. A recent court settlement requires the U.S. Environmental Protection Agency to define a numeric ballast water discharge standard by 2012. In addition, the federal government of Canada has ratified the International Maritime Organization’s Ballast Water Management Convention—considered minimally protective of water quality—and is planning to incorporate the IMO’s numeric standard in the Canada Shipping Act. The U.S. Coast Guard will be finalizing a rule to establish a ballast water discharge standard this spring, proposed in 2009 to be the IMO standard, and strengthened as treatment technology advances.

”The stage is now set for the U. S. and Canada to stand and deliver,” said Marc Smith, senior policy manager with National Wildlife Federation’s Great Lakes office. “The question is, ‘Will they?’ We encourage public officials to take strong action to protect the Great Lakes and other waters from aquatic invasive species.”

The shipping industry has unsuccessfully challenged in court state regulations to stop invasive species from entering the Great Lakes. The industry has also lobbied Congress and the Administration for weaker standards for foreign vessels and loopholes that could delay implementation by lakers of the pending Coast Guard rule. The federal government of Canada is also lobbying Congress, the Administration, and state of New York to weaken proposed standards in New York.

The No. 1 way non-native species enter the Great Lakes is through ballast water discharge of foreign vessels. Lakers, vessels that never leave the Great Lakes, do not introduce new invasive species from overseas but can spread species from lake to lake. Currently the most stringent regulations being implemented by foreign vessels coming to the Great Lakes are two management practices: ballast water exchange, which has been required on approximately 10% of vessels entering the Great Lakes region since 1996, and flushing of empty tanks (for 90% of vessels entering the region termed “no ballast on board” or NOBOB), which was imposed by Canada in 2006 and the St. Lawrence Seaway in 2008. Ballast water exchange and NOBOB flushing are beneficial and have reduced the risk of new invasive species establishment by purging organisms in the open ocean or shocking freshwater organisms with high salinity water. But a 2007 study by the National Oceanic and Atmospheric Association states that both salinity shock and volumetric ballast exchange are “imperfect and subject to widely variable efficacy depending on taxa” and that the risk of new establishment of invasive species remains.

“It’s frustrating to see the start of another shipping season on the St. Lawrence Seaway knowing that still more needs to be done to clean up ship ballast tanks,” said Jennifer Caddick, Executive Director for Save The River. “The Seaway agencies and shipping industry have been painting themselves green. Unfortunately, the reality is that they have fought regulations that are protective of our Great Lakes and St. Lawrence River waters, such as New York’s strong rules to clean up ship ballast tanks, at every step of the way. Rather than fighting regulations, I wonder how far we could be today if that energy was instead spent advancing ballast treatment technology.”

For more information:

NOAA’s “Assessment of Transoceanic NOBOB Vessels and Low-Salinity Ballast Water as Vectors for Non-indigenous Species Introductions to the Great Lakes” can be found here: http://www.glerl.noaa.gov/res/projects/nobob/products/

Contacts:

Jennifer Nalbone, Great Lakes United: 716-983-3831; jen@glu.org

Marc Smith, National Wildlife Federation: 734-887-7116; msmith@nwf.org

Jennifer Caddick, Save The River: 315-686-2010; jennifer@savetheriver.org

Asian carp, an invasive fish species that could devastate the St. Lawrence River and Great Lakes, are at our back door just miles from Lake Michigan.

These fish are voracious filter feeders. The bighead carp can consume 40 per cent of its body weight each day, while the silver carp’s tendency to jump out of the water when startled makes them a hazard to boaters. They would cause irreversible harm to the Great Lakes by consuming large quantities of algae and zooplankton, muscling out native fish populations. The estimated impact to the recreational and commercial Great Lakes fisheries would reach to over $4.5 billion. (For more information about the Asian Carp, visit the Great Lakes United Asian Carp FAQ.)

Help Stop the Asian Carp!

The U.S. Army Corps of Engineers are collecting public comments through March 31st on their Great Lakes and Mississippi River Basin Interbasin Feasibility Study (GLMRIS). Despite its bureaucratic name, this study is critical because its focus will determine if we implement permanent solutions to stop the Asian carp!

Top Two Reasons Why You Should Attend a Meeting in Your Area!

1 – The Corps was mandated to study ways to “prevent” invasive species movement between the Great Lakes and Mississippi River. Deplorably, the Corps has decided to spend precious time and resources to also study ways to “reduce the risk,” not just prevent. This was not authorized by Congress nor is it a credible strategy that will protect our Great Lakes. We need you to tell them this is unacceptable and only options that will “prevent” invasive species movement and stop the Asian carp should be studied.

2 – The Corps study takes too long. The Chicago portion of the study is not predicted to be complete until mid-2015, or nearly five years from now. The Corps must acknowledge the urgency of finding a permanent solution, condense the timeline and produce final results for the Chicago portion of GLMRIS within 18 months rather than mid-2015 and we need you to send that message.

Is there a public meeting in your community?

The U.S. Army Corps of Engineers is hosting public meetings in communities throughout the Great Lakes basin. The list of cities and dates is below. Full details on each meeting, including location, times and how to register to speak are available at: http://glmris.anl.gov/involve/pubschedule/index.cfm

January 11 – Buffalo, NY

January 13 – Cleveland, OH

January 20 – St. Paul, MN

January 25 – Green Bay, WI

January 27 – Traverse City, MI

February 1 – Cincinnati, OH

February 3 – Ann Arbor, MI

February 8 – St. Louis, MO

February 10 – Vicksburg, MS

If you can’t attend a public meeting, you may submit comments via the study website here: http://glmris.anl.gov/involve/comments/index.cfm no later than March 31, 2011.

For More Information

More information on the study may be found on the official GLMRIS website.

Helpful talking points for preparing to speak at hearings or to submit comments can be downloadeded from this helpful fact sheet prepared by Fresh Water Future.

More information on the Asian Carp issue can be found on the Great Lakes United Asian Carp page.

Thank you for speaking out on this critical River issue!

Aquatic invasive species, such as zebra mussels and round gobies, are one of the most significant environmental threats to the health of the St. Lawrence River and Great Lakes. Invasive species foul beaches, wreak havoc on the fishery, clog water intake valves of cities and utilities, and harm fish and wildlife. Research suggests that the annual cost to the just the 8 Great Lakes states from invasive species introduced by shipping are upwards of $200 million annually. (To learn more about the impact of aquatic invasive species on the St. Lawrence River and Great Lakes, visit our Clean Up the Ballast page.)

The U.S. Environmental Protection Agency (EPA) is collecting input as they update their Vessel General Permit which regulates ballast discharges to stop invasive species introductions under the Clean Water Act. Your input it critical to ensure that the EPA’s effort significantly improves protections on the St. Lawrence River and Great Lakes! The deadline for comments is December 31st.

Background

The EPA issued their first Vessel General Permit (VGP) in February 2008. The VGP requires ballast water exchange for all oceangoing vessels (”salties”) and flushing for salties that declare No Ballast on Board. Both practices represent the status quo, as salties were already required to perform them under existing Coast Guard and St. Lawrence Seaway regulations. The VGP is set to expire in 2013, and it’s time to let the EPA know that the Vessel General Permit needs to be significantly strengthened to stop introduction and spread of aquatic invasive species in the Great Lakes and nationwide.

Take Action!

Take a few minutes today to urge the US EPA to strengthen the Vessel General Permit to stop the introduction and spread of aquatic invasive species in the St. Lawrence River, Great Lakes and nationwide.

Sample letter language:

Dear Administrator Jackson:

The St. Lawrence River is very important to me [explain why…]

As you know, ship ballast is the primary pathway for aquatic invasive species introductions into the Great Lakes-St. Lawrence River system, and aquatic invasive species, such as zebra mussels and round gobies, are one of the most significant environmental threats to the health of the River and Lakes. Invasive species foul beaches, wreak havoc on the fishery, clog water intake valves of cities and utilities, and harm fish and wildlife.

I am writing today to urge the US EPA to significantly strengthen the Vessel General Permit to stop the introduction and spread of aquatic invasive species in the St. Lawrence River, Great Lakes, and nationwide. The US EPA should include the following provisions in the permit:

• The VGP must include effluent limitations for discharges of invasive species in ballast water and should have a standard of zero discharge unless proven otherwise.

• The VGP must require vessels to use the Best Available Technology to treat their ballast water before discharging.

• The VGP must apply to domestic “laker” vessels that travel only within the Great Lakes, as well as international “salties”.

• The VGP should establish a clear and transparent process for approving technology for use, monitoring, reporting, and enforcement.

• Any federal program to control ballast water from ships must engage both the EPA and the Coast Guard and should fully comply with both the Clean Water Act and the National Invasive Species Act.

Aquatic invasive species introductions via the commercial shipping industry have been allowed to pose a direct threat to the economic and environmental health of our communities for too long. I urge you to strengthen the Vessel General Permit to protect our waterways for current and future generations.

Sincerely

[Insert Your Name and Address]

How to Submit Comments

Deadline: December 31, 2010

The easiest way to let your voice be heard is via:

Email: ow-docket@epa.gov; Attention: Docket ID No. EPA–HQ–OW–2010–0828

Mail:

Water Docket Environmental

Protection Agency, Mailcode: 28221T

1200 Pennsylvania Ave., NW.

Washington, DC 20460

Attention: Docket ID No. EPA–HQ–OW–2010–0828.

Thank you for speaking out to protect the health of the St. Lawrence River!