6
Committee’s Conclusions and Recommended Option for the Great Lakes Region

The committee was asked to develop a range of practical and technically feasible options that would meet the following two criteria: (a) enhance the potential for global trade in the Great Lakes region and (b) eliminate further introductions of nonindigenous aquatic species by vessels transiting the St. Lawrence Seaway.

After examining a wide range of candidate actions aimed at meeting these criteria, the committee concluded that the only way to satisfy the absolute requirement to eliminate further ship-vectored introductions of aquatic invasive species (AIS) would be to close the seaway to all vessel traffic. Such action would eliminate a trade route into and out of the Great Lakes and would not, therefore, enhance the Great Lakes region’s potential for global trade. In the committee’s judgment, moreover, such closure is not a realistic solution to the AIS problem since it is far from clear that both the Canadian Parliament and the U.S. Congress would pass the legislation that would be needed to close the binational waterway to traffic. Hence, closure of the seaway to all vessels would not address the AIS issue in a timely manner. As noted in Chapter 5, such closure would also not prevent all further AIS introductions into the Great Lakes, given that 30 to 45 percent of such introductions have historically been attributed to nonshipping vectors.

In the absence of an ideal suite of actions that enables both project criteria to be met simultaneously, the committee’s task became one



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6 Committee’s Conclusions and Recommended Option for the Great Lakes Region The committee was asked to develop a range of practical and tech- nically feasible options that would meet the following two criteria: (a) enhance the potential for global trade in the Great Lakes region and (b) eliminate further introductions of nonindigenous aquatic species by vessels transiting the St. Lawrence Seaway. After examining a wide range of candidate actions aimed at meeting these criteria, the committee concluded that the only way to satisfy the absolute requirement to eliminate further ship- vectored introductions of aquatic invasive species (AIS) would be to close the seaway to all vessel traffic. Such action would elim- inate a trade route into and out of the Great Lakes and would not, therefore, enhance the Great Lakes region’s potential for global trade. In the committee’s judgment, moreover, such closure is not a realistic solution to the AIS problem since it is far from clear that both the Canadian Parliament and the U.S. Congress would pass the legislation that would be needed to close the binational water- way to traffic. Hence, closure of the seaway to all vessels would not address the AIS issue in a timely manner. As noted in Chapter 5, such closure would also not prevent all further AIS introductions into the Great Lakes, given that 30 to 45 percent of such introduc- tions have historically been attributed to nonshipping vectors. In the absence of an ideal suite of actions that enables both project criteria to be met simultaneously, the committee’s task became one 1 22

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Committee’s Conclusions and Recommended Option 123 of selecting the most promising alternatives from among possible compromise options. After some brief comments about distinguish- ing features of these compromise options, this chapter discusses the committee’s rationale for identifying practical and technically feasi- ble options for the Great Lakes region. Two alternatives—closure of the seaway to transoceanic shipping and the technology-based approach recommended by the committee—are then examined. The various components of the recommended approach are then discussed and the actions necessary to implement this approach are enumerated. After an examination of the strengths and weaknesses of the recommended approach, the chapter concludes with brief remarks about future management of the waters of the Great Lakes. COMPROMISE OPTIONS The most important difference among the alternative compromise options lies in how to meet the requirement to eliminate further ship-vectored AIS introductions. As noted in Chapter 5, examina- tion of the candidate actions listed in Box 5-2 led the committee to conclude that there are two distinct approaches to eliminating fur- ther AIS introductions by vessels transiting the seaway: 1. Eliminate the shipping vector by removing or killing AIS carried by vessels. 2. Keep vessels that may be carrying AIS out of the Great Lakes. The first approach would rely on a combination of technologies, regulation, enforcement, and monitoring. Prevention strategies would address all vessels transiting the seaway that pose a risk of in- troducing AIS into the Great Lakes. The most serious limitation of this approach is that current technologies cannot guarantee to kill or remove all potential invaders, although they offer the potential to reduce markedly the risk of further AIS introductions if they are rigorously implemented. Furthermore, improvements in the effec- tiveness of technologies are anticipated, particularly for new vessels.

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1 24 Great Lakes Shipping, Trade, and Aquatic Invasive Species As already discussed, the second approach—closing the seaway to all vessel traffic—is not a realistic solution. The question remains whether closing the seaway to transoceanic vessels, which have his- torically been the main source of AIS introductions into the Great Lakes since the waterway opened, would be an effective and imple- mentable compromise. Such closure would not eliminate further ship-vectored AIS introductions by vessels transiting the seaway but would reduce substantially the risk of such introductions. The committee’s conclusions with regard to both the above compromise options are discussed later. COMMITTEE’S RATIONALE In its efforts to identify practical and technically feasible options for meeting the two project criteria, the committee sought an approach that is the most robust among various alternatives because it • Offers the potential to make progress toward the ultimate goals in a timely manner, • Minimizes undesirable consequences, and • Keeps options open for an uncertain future. Timeliness Timeliness was identified as a critical consideration following the public meeting in Toronto in May 2007. One of the major messages that the committee took away from the meeting was the urgency of taking action to prevent further introductions of AIS into the Great Lakes. A wide range of stakeholders expressed the view that actions rather than words are needed, and they are needed now. This view derives not only from the observed impacts of AIS on the Great Lakes ecosystem and the costs incurred by public and private orga- nizations in managing a number of high-profile invaders, such as the zebra mussel, but also from the continuing reports of new AIS discoveries in the Great Lakes. Chapter 3 indicated that a consider- able time may elapse between the introduction of a new AIS and re-

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Committee’s Conclusions and Recommended Option 125 ports of its discovery. Nonetheless, the fact that new AIS continue to be reported argues strongly against any complacency in preven- tion efforts. Avoid Undesirable Consequences An acceptable solution to the problem of AIS introductions into the Great Lakes cannot be developed without consideration of its broad environmental and other consequences. Thus, a “solution” that shifts the AIS problem to a different geographic location, such as ma- rine ports on the east coast of North America, would be unaccept- able. An approach that substitutes one environmental problem for another would also be unsatisfactory. For example, attempts to solve the AIS problem in the Great Lakes by shifting marine cargoes to al- ternative modes of transportation would need to take account not only of introductions of invasive species but also of other environ- mental impacts of transportation, including greenhouse gas emis- sions, criteria air contaminant emissions, accidents, and noise. Moreover, the possibility of shifting seaway cargoes to alternative land-based modes may raise questions about capacity and logistical constraints and the effects of trying to move even more freight on an already overburdened system. Thus, while shifting seaway cargoes to alternative routes or modes of transportation may be viable, the var- ious trade-offs would need to be evaluated carefully before advocat- ing such an approach to solving the AIS problem in the Great Lakes. Keep Options Open for an Uncertain Future The need to keep options open and retain flexibility reflects the un- certainties underlying the selection and implementation of actions aimed at meeting the two project criteria. For example, experts are not yet in a position to make quantitative estimates of how ef- fective ballast water management technologies will be when they are applied rigorously to all vessels posing a risk of AIS introduc- tions. Similarly, reliable forecasts of the direction, composition, and magnitude of global trade affecting the Great Lakes region are not possible. In addition, the extent to which the Great Lakes

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1 26 Great Lakes Shipping, Trade, and Aquatic Invasive Species ecosystem should be modeled as biologically fragile (easily subject to perturbation) or resilient is unclear, and there is no widely ac- cepted ethical calculus for weighing the interests of the different uses and users of the Great Lakes. One approach to decision making under such conditions of deep uncertainty is to develop sophisticated models with enhanced pre- dictive capabilities. In this case, the committee did not consider such an approach to be productive. Even experts are unable to create simulations of a complex and adaptive system (the Great Lakes economy), placed within a larger environment of other world economies, that will yield reliable predictive outputs. Large and well-refined macromodels are not entirely satisfactory in predict- ing even 1 year into the future, to say nothing of a decade or more. In this case, the objective is not to forecast the future but rather to understand (a) how changes in the future might affect the choice among alternative actions taken today and (b) how these actions, if taken, would affect the chances of meeting specified goals in the fu- ture. If today’s actions are to be chosen wisely in light of long-term objectives, the key question is not, What will happen? Rather, be- cause the future cannot be forecast accurately, we want to ascertain which actions taken today will both further our goals and preserve options that may be desirable later in light of improved under- standing. The committee sought to take account of such consider- ations in assessing candidate options for the Great Lakes region. The remainder of this chapter addresses two compromise options for meeting the project criteria. It gives the committee’s assessment of whether the proposed approaches are timely, free of undesirable consequences, and flexible in light of future uncertainties. CLOSURE OF THE SEAWAY TO TRANSOCEANIC SHIPPING As the following discussion illustrates, the committee’s assessment of the effects of closing the seaway to transoceanic shipping was beset with uncertainties. The various economic, environmental, political,

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Committee’s Conclusions and Recommended Option 127 and legal unknowns indicated to the committee that any decision to close the seaway to transoceanic vessels would be a high-risk strategy—even in view of the uncertainty with regard to the future role of the seaway within the larger Great Lakes transportation sys- tem (see Chapter 2). The current limited understanding of the con- sequences of closing the seaway to transoceanic vessels is insufficient to support a robust public policy decision about such closure. The committee’s remarks about the economic impacts of closing the seaway to transoceanic shipping focus on their general direction and nature. The remarks are founded on economic principles and thus are compelling. However, no attempt was made to quantify the effects, and any attempt to do so would be subject to wide un- certainties. For example, individuals and organizations are adaptive in their responses to change, so the full nature of their responses is uncertain, as is the estimation of transportation costs for alterna- tive routes and modes (Taylor and Roach 2005). As discussed at some length in Appendix D, estimating the economic benefits of transoceanic shipping through the seaway is a challenging task. The committee’s review of the literature suggests that partial answers are available to some of the relevant questions, but the compre- hensive analysis needed to quantify with confidence the economic impacts of closing the seaway to transoceanic vessels is lacking. Permanent or Temporary Closure A few preliminary remarks about the two variants listed in Box 5-2— permanent and temporary closure of the seaway to transoceanic vessels—are appropriate in the present context. Advocates of tem- porary closure (a moratorium) are careful to note that they are not calling for permanent closure. However, a prolonged moratorium could have serious financial consequences for the seaway’s future because of the loss of Canadian toll revenues. These revenues are needed to support day-to-day operations of the seaway, as well as ongoing maintenance, which cannot be deferred without jeopar- dizing safety. Tolls, which made up more than 90 percent of the St. Lawrence Seaway Management Corporation’s (SLSMC’s) total

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1 28 Great Lakes Shipping, Trade, and Aquatic Invasive Species revenue for 2006, are generally higher for the higher-value com- modities often carried by transoceanic vessels (see Chapter 2). A recent study examined the revenue impacts of a cessation of transoceanic shipping through the seaway on the seaway corpora- tions and concluded that, for the period 2002–2006, SLSMC would have incurred a loss in toll revenues of about $18 million annually (Taylor and Roach 2007).1 It has been suggested that the economic shortfall resulting from a loss of transoceanic traffic through the seaway could be remedied either by increasing the tolls on domestic vessels or by increasing government subsidies (Taylor and Roach 2005). The committee did not explore either of these possibilities in detail. It noted, how- ever, that even small increases in freight rates for low-value bulk commodities of the type carried by many domestic laker vessels can make the difference between a carrier being profitable or un- profitable. In light of the aforementioned uncertainties about re- sponses to change, the effects of increased tolls on domestic vessels are unclear. Whether the Canadian government would increase its current subsidy to SLSMC to keep the seaway operating in the ab- sence of transoceanic traffic is unknown. However, if revenues were insufficient to ensure continuing maintenance of the water- way’s infrastructure—a plausible consequence of a permanent or prolonged temporary closure to transoceanic shipping—the sea- way could cease to be a viable transportation option and could end up closing to all vessel traffic, not just to transoceanic vessels. Potential for Global Trade The Great Lakes region’s trade with the rest of the world consists of far more than the movement of cargoes through the seaway. Much of this trade is carried to and from the region via other routes and by other modes of transportation. The actual value of 1 As noted in Chapter 2, tolls on the U.S. portion of the seaway were eliminated in 1986. The U.S. St. Lawrence Seaway Development Corporation (SLSDC) relies almost exclusively on federal ap- propriations for its revenues and thus would not be directly affected by a loss of toll revenues from transoceanic vessels (Taylor and Roach 2007).

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Committee’s Conclusions and Recommended Option 129 transoceanic shipping through the seaway has proved difficult to specify, as discussed in Appendix D, but closing the seaway to transoceanic shipping could hardly serve to enhance the potential for global trade. Economic principles indicate that, in the absence of the seaway option, the costs of moving cargoes by alternative modes and routes would almost certainly increase. As noted earlier, the responses of individuals and organizations to such changes are subject to wide uncertainties. Some bulk commodities currently re- lying on the seaway might shift to rail, albeit at a higher cost, but in other cases the higher cost of movements could result in a curtail- ment of the enterprises generating the cargoes. Shipping companies (i.e., carriers) that have invested in specialized vessels for Great Lakes international trade would lose a key market if the seaway were closed to transoceanic shipping. While there may be opportunities to use such vessels elsewhere, companies that these carriers service may not be able to relocate and could go out of business. The committee endeavored to obtain estimates of the value of international seaway trade as a percentage of the Great Lakes re- gion’s trade in its entirety, by all modes and all routes. However, a literature search did not reveal any such estimates, perhaps because compiling the necessary data represents a major challenge. Taylor and Roach (2005) note that, in 2002, Great Lakes transoceanic shipping accounted for 10.9 percent of all Canadian grain exports and 21.4 percent of all Canadian steel imports in terms of tonnage. The corresponding data for the United States are 1.9 percent of all grain exports and 6.3 percent of all iron and steel imports. Available data suggest that it would be hard to posit the continued use of the seaway as vital to the economic health of North America. However, the seaway may be critical for the continued operation of certain industries in the Great Lakes region, particularly in a time of heightened international competitiveness. For specific communities, sectors, and port operators, closure of the seaway to transoceanic shipping would have serious and disruptive effects. For example, shippers would incur not only higher freight rates but also the expense of changes in their logistics infrastructure and practices. Although the full nature of responses to such changes is unclear,

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1 30 Great Lakes Shipping, Trade, and Aquatic Invasive Species some shippers and their supporting logistics providers might go out of business. Thus, the region’s trade could be adversely affected, at least in the short term pending the development of alternative trans- portation options. Whether competitive transportation alternatives to transoceanic shipping through the seaway could be provided has not been demonstrated convincingly, although the absence of such evidence should not lead one to conclude that such alternatives do not exist or would not emerge in response to demand. The political and legal uncertainties surrounding any decision to close the seaway to transoceanic vessels (see below) would also hamper efforts to catalyze economic development in the Great Lakes region through investment in transportation options that are water based or multimodal with a water-based component. Timeliness Closing the seaway to transoceanic shipping would require leg- islative action by the Canadian Parliament and the U.S. Congress. Furthermore, recent litigation relating to the regulation of ballast water under the U.S. Clean Water Act and to Michigan’s ballast water permit requirement suggests that any action to initiate clo- sure of the seaway would bring the issue before the courts. Work- ing through the political and legal issues, particularly in a binational context, could be a protracted process, and the eventual outcome is not clear. Unforeseen circumstances, coalitions of political forces with asymmetric strength and influence, and unpredictable out- comes could result in no closure—or no resolution of the issue. In the committee’s judgment, closure of the seaway to trans- oceanic shipping would require many years, if it could be carried out at all. Years could be lost awaiting uncertain legal and political outcomes, during which time AIS introductions would continue. The prolonged period of uncertainty could also adversely affect ef- forts to develop technological solutions to eliminate AIS from bal- last water. Few factors have a more deleterious effect on investment, innovation, and the ability of market mechanisms to alter behav- ior than a climate of uncertainty. While international efforts to

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Committee’s Conclusions and Recommended Option 131 develop ballast water treatment systems are expected to continue regardless of the status of shipping on the seaway, uncertainties about the future market could stymie the development of treat- ment systems optimized for the Great Lakes’ freshwater environ- ment. Thus, valuable time that could have been spent pursuing technical solutions to the AIS problem would have been lost. In this respect, a decision to pursue closure of the seaway to transoceanic vessels could impede quick and comprehensive action with the po- tential to achieve the same end, namely, a significant reduction in further ship-vectored AIS introductions into the Great Lakes. Environmental Consequences Closing the seaway to transoceanic vessels would be expected to eliminate further AIS introductions by such vessels and would ad- dress both the ballast water and hull fouling vectors. (As discussed in Chapter 3, the hull fouling vector is thought to play a minor role compared with the ballast water vector in introducing AIS into the freshwater ecosystem of the Great Lakes.) A variety of environmen- tal consequences would accompany the likely increase in trans- shipment of cargoes by rail (and possibly by truck2) resulting from closure of the seaway to transoceanic shipping. To estimate the en- vironmental impact of such modal shifts, the committee commis- sioned an expert paper on the environmental footprints of ship, rail, and truck modes of freight transportation (Lawson 2007). The paper led the committee to conclude that precise estimates and rig- orous quantitative comparisons of the environmental effects of freight transportation by ship and overland modes in hypothetical scenarios resulting from seaway closure are not currently possible because of data limitations. However, the paper provided general indications with regard to the effects of ship, rail, and truck modes on 13 environmental factors. The ship mode was found to have the 2 For relatively low-value bulk commodities moving on the seaway, many of which can be stock- piled if necessary, rail would be the most likely alternative mode. Truck is generally a more at- tractive option for medium- or high-value semifinished or finished products for which inventories are low and short transit times are critical (see Table 2-1).

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1 32 Great Lakes Shipping, Trade, and Aquatic Invasive Species smallest and least undesirable footprint in 11 of the 13 environ- mental categories, and rail is preferable to truck in virtually every category. The two areas where the ship mode ranks unfavorably are AIS introduction and particulate matter emission.3 The com- mittee concluded, therefore, that shifts of cargoes to land-based modes (notably rail) that would result from closing the seaway to transoceanic shipping could result in increased environmental im- pacts in terms of fuel use, greenhouse gas emissions, accidents, noise, congestion, and several other factors.4 Closure of the seaway to transoceanic vessels could also result in an increased number of such vessels discharging and loading car- goes at marine (i.e., saltwater) ports in Canada or the United States for transshipment by water- or land-based modes to and from lo- cations within the Great Lakes region. These marine ports could become more vulnerable to AIS introductions vectored by hull fouling. Thus, while closing the seaway to transoceanic vessels would reduce the risk of ship-vectored AIS introductions into the Great Lakes, it could increase the risk of such introductions elsewhere by diverting vessel traffic to alternative destinations. Future Options A decision should not be made on the basis of sunk costs—costs that have already been incurred. In the case of an infrastructure asset, such as the seaway, any decision about its future should not be prejudiced by considerations of the money that went into its creation and cannot now be unspent. The key question, from a purely economic perspective, is whether the asset has a future value (option value) that more than offsets the direct and indirect costs associated with maintaining it. 3 Lawson (2007) notes that anticipated reductions in the sulfur content of fuels are expected to reduce emission rates of sulfur oxides and particulate matter for all modes. 4 A recent study examines the likely air quality impacts of shifting seaway cargoes from transoceanic vessels to alternative modes, notably rail (Taylor and Roach 2007). In common with Lawson (2007), these authors comment on the difficulties of obtaining relevant emissions data. Their analysis, which is based on the single comprehensive data source they were able to find, indicates that “the cessation of ocean shipping into the Great Lakes would have no significant impact on air quality” (p. 44).

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Committee’s Conclusions and Recommended Option 161 Despite the challenges of preventing further AIS introductions, the invasion vector and route that are the focus of this study—vessels transiting the St. Lawrence Seaway—are, in the committee’s view, easier to control than some other vectors, routes, and pathways. For example, angling and bait fishing, home aquaria, and water gardens are widely distributed geographically, involve large num- bers of individual citizens, and are not highly regulated. In addi- tion, controlling these vectors and pathways requires changing human behavior, which many would argue is more difficult to achieve than implementing technological solutions. In contrast, the geographic chokepoint at the entrance to the seaway provides an opportunity for Canada and the United States to enforce mea- sures aimed at preventing vessels from transporting AIS into the Great Lakes. Furthermore, the number of vessels using the seaway annually (approximately 30014) is small in absolute terms, and the shipping industry is already highly regulated. If vessels transiting the seaway were the only vector and route for introducing AIS into the Great Lakes, the committee could well have recommended a different suite of actions from among the possibilities identified in Chapter 5. However, its examination of the shipping vector through the seaway in the broad context of all AIS introductions into the Great Lakes led it to conclude that a combination of technology, enforcement, and monitoring for com- pliance constitutes the most robust, practical, technically feasible, and effective approach, and the one that offers the most rapid response to the issue. The committee is optimistic that its recom- mended suite of actions, if fully implemented, would result in sub- stantial progress toward elimination of further introductions of AIS by vessels transiting the seaway and would reduce this vector/ route to a minor contributor to the overall problem of AIS intro- ductions into the Great Lakes. 14 As noted in Chapter 4, the number of transoceanic vessels using the seaway each year is approx- imately 230, and the Canadian domestic fleet of coastal and inland vessels using the seaway com- prises about 70 ships.

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1 62 Great Lakes Shipping, Trade, and Aquatic Invasive Species Enhancing the Potential for Global Trade A recent report from the Brookings Institution observes that the Great Lakes and its waterways “offer a tremendous opportunity for reinvigorating the economy of the region” (Austin et al. 2007, 10). Consistent with this observation, the committee’s recommended suite of actions, and in particular the harmonization of Canadian and U.S. BWM standards for vessels entering the Great Lakes, could help create an environment conducive to enhancing the re- gion’s global trade by removing current regulatory uncertainties about the availability of waterborne freight transportation. In ad- dition, opposition to Great Lakes shipping from those concerned about the negative impacts of ship-vectored AIS introductions could be greatly reduced in the event of substantial progress toward eliminating such introductions. As a result, states and provinces would feel less constrained in promoting economy-enhancing ini- tiatives dependent on waterborne transportation. Possible seaway- dependent, economy-enhancing initiatives include container feeder services between Great Lakes ports and container ports in Nova Scotia, increased short-sea shipping to avoid the growing conges- tion on certain land-based transportation corridors, and cruise ship operations associated with ecotourism. While it is not clear which, if any, of these ventures will succeed, all have a common thread: the need for unhindered shipping via the St. Lawrence Seaway. In the current climate of uncertainty about future BWM regu- lations, shipping companies and their business partners have dif- ficulty in developing sound business plans for future initiatives and in generating the investment capital needed to modernize and ex- pand their capabilities. Specifically, shipowners are reluctant to in- vest in ballast water treatment systems for existing or new vessels when the goals of the treatment are unclear. Widespread frustration at the delays in updating the U.S. Na- tional Invasive Species Act of 1996 appears to have led some groups to take action themselves to address the AIS problem. For exam- ple, the state of Michigan has established its own ballast water leg- islation, and other Great Lakes states are considering following

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Committee’s Conclusions and Recommended Option 163 suit. In addition, environmental groups are taking action through the courts to have ballast water discharges regulated under the U.S. Clean Water Act. The adoption by the United States of BWM standards equiva- lent to those of IMO, as recommended by the committee, would not necessarily halt other legislative initiatives, including those by individual states. However, it would remove much of the cur- rent uncertainty and result in greater consistency in BWM re- quirements for vessels using the binational GLSLS system. Many observers have noted that a complex patchwork of BWM require- ments would complicate compliance, and the committee concurs with this view. The committee envisages that the shipping industry would bear the costs of installing and operating ballast water treatment and re- mote monitoring systems on its vessels. It recognizes that these ad- ditional costs could result in some transoceanic vessels ceasing operations into the Great Lakes—probably “tramp” vessels that visit the lakes infrequently. However, its discussions with repre- sentatives of the St. Lawrence and Great Lakes maritime industry, the creation of marine industry environmental initiatives such as the binational Green Marine program,15 and efforts by individual shipping companies to investigate and implement ballast water treatment systems led the committee to conclude that transoceanic shipping through the seaway would not cease as a result of the ad- ditional costs associated with the proposed AIS control program. Forecasting future seaway traffic and associated trade is fraught with difficulties, as discussed in Chapter 2. Moreover, as discussed in Chapter 5, economic development and ensuing trade are influ- enced by myriad forces, of which policies aimed at preventing further AIS introductions are only one. Thus, the impact of the committee’s proposed suite of measures on seaway traffic and on the Great Lakes region’s global trade in general is impossible to an- ticipate with certainty. By keeping the seaway open to vessels that 15 Information on the marine industry environmental partnership, Green Marine, is available at www.cmc-ccm.com/cmc/english/greenmarine.asp.

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1 64 Great Lakes Shipping, Trade, and Aquatic Invasive Species take appropriate measures to protect against further AIS intro- ductions, the proposed approach provides opportunities to develop a variety of seaway-dependent, economy-enhancing initiatives. Furthermore, it helps ensure the availability of a variety of trans- portation options (routes and modes) within the region, thereby resulting in competitive pricing, which may in turn facilitate trade. Robust Approach The committee’s recommended approach has the advantage that many of the proposed actions, notably the changes in BWM regu- lations, could be implemented within the next 2 to 3 years. The committee anticipates that the surveillance program, the control and eradication program, and the adaptive process could also be established in at least a preliminary form in a similar time frame, with enhancements being implemented in later years. The recommended approach has the further advantage of help- ing to solve the AIS problem in the Great Lakes without transfer- ring it to other locations, such as marine ports on the east coast of Canada and the United States. It also avoids the replacement of one environmental problem with another. While eliminating fur- ther introductions of AIS is desirable, it is questionable whether achievement of this goal should be at the expense of increases in other adverse environmental impacts associated with transporta- tion, including greenhouse gas emissions, criteria air contaminant emissions, accidents, and noise. Although data limitations pre- clude detailed quantitative comparisons of the environmental im- pacts of different modes of freight transportation, the marine mode is in many respects more environmentally friendly than the rail alternative that could be used to move the relatively low-value bulk commodities shipped on the seaway (Lawson 2007). The committee’s recommended approach does not preclude fu- ture options that may further enhance opportunities for global trade in the Great Lakes region, as discussed earlier. In particular, it rec- ognizes that the seaway has a future value as a component of the region’s transportation network, even though that value cannot

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Committee’s Conclusions and Recommended Option 165 currently be quantified. In addition, it does not preclude the pos- sibility of strengthening measures to protect against further AIS in- troductions, if experience and improved knowledge indicate that such action is necessary. The recommended adaptive process aims to facilitate such revisions by establishing a formal mechanism whereby necessary changes to prevention policies would be iden- tified and brought to the attention of the governments of Canada and the United States. Resource Requirements Experience has shown that solving environmental problems requires resources, and the present case is no exception. The committee anticipates that full implementation of its suite of recommended actions will require resources over and above those already de- voted to the prevention of further AIS introductions into the Great Lakes. In particular, the recommended surveillance, control and eradication, and adaptive management initiatives will require new dedicated and continuing funding to ensure that their objectives are met. Although limited opportunities exist to leverage ongoing monitoring efforts as part of the surveillance program, these efforts alone are insufficient to ensure that the overall scope of the pro- posed program is sufficiently comprehensive to detect new AIS in a timely fashion. The committee anticipates that the recommended actions to be taken by Transport Canada and the U.S. Coast Guard would be sup- ported by federal funding, given that they are closely related to the two agencies’ current regulatory activities. The question remains, however, as to what extent federal funding (i.e., taxpayer revenues) could (or should) cover some of the other recommended actions, no- tably the surveillance, control, and adaptive management initiatives. Application of the “user pays” principle is one approach to generating funds for AIS prevention measures. As noted earlier, the committee envisages that the shipping industry will bear the costs of installing and operating shipboard systems on its vessels. A further option could be to levy user fees on vessels transiting

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1 66 Great Lakes Shipping, Trade, and Aquatic Invasive Species the seaway to help cover the costs of the recommended surveil- lance, control, and adaptive management efforts. However, be- cause these proposed efforts address the whole gamut of vectors and pathways by which AIS enter the Great Lakes, and not just shipping through the seaway, additional sources of funding would be needed. Furthermore, the imposition of such user fees would raise a number of potentially divisive issues, including the effects of assessing environmental fees against one mode of trans- portation (shipping) and not others (rail, truck), and against marine carriers in the Great Lakes region but not in other geo- graphic regions. As noted in Chapter 5, the debate about the extent to which users of transportation services should pay for externalities, such as the environmental costs of transportation, is complicated (see, for example, TRB 1996) and well beyond the scope of this report. In view of these complexities and those inherent in other fund- ing approaches (see, for example, Stewart 2007), the committee notes that further investigation of funding sources will be needed to ensure full implementation of its recommended AIS control program. MANAGING THE WATERS OF THE GREAT LAKES— A VISION FOR THE FUTURE In the committee’s view, changes driven by nature and by human activities on the Great Lakes themselves and on the immense drainage basin call for collective management. The present system of Great Lakes’ governance is fragmented among agencies and of- fices of two federal governments; eight states; two provinces; and myriad municipalities, local governments, and aboriginal peoples. All manner of treaties, agreements, institutions, and organizations have been created to address activities relating to the quantity and quality of waters from the lakes, such as commerce, planning, and pollution control. While many of these endeavors are cooperative efforts between Canada and the United States, there is no compre-

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Committee’s Conclusions and Recommended Option 167 hensive, coordinated, and coherent binational governance or man- agement structure that can identify shared societal goals and ensure that the Great Lakes are managed in such a way that desired values and uses are nurtured and sustained. During its work, the committee observed that discrepancies be- tween Canadian and U.S. approaches can complicate efforts to pre- vent further AIS introductions into the Great Lakes. For example, inconsistencies between Canadian and U.S. BWM regulations com- plicate compliance for vessels but do not provide a greater degree of protection against AIS introductions for the nation with more stringent requirements. In contrast, efforts by the two nations to work together in preventing further AIS introductions can opti- mize the use of available resources to ensure maximum effective- ness, as illustrated by the example of the binational Ballast Water Working Group, which was formed in 2006 to address inspection and enforcement procedures for vessels entering the GLSLS system (see Chapter 4). To avoid unacceptable delays, the committee proposes that its recommended actions be undertaken by existing organizations with the appropriate expertise. In the case of the surveillance, con- trol, and adaptive management initiatives, this approach will likely require an expansion of the existing mandates of relevant organizations. The committee recognizes that the issues of Great Lakes governance and environmental protection are far broader in scope than the subject of the present report. Nonetheless, it en- visions that, in the longer term, the recommended AIS control program might be implemented most effectively within the con- text of a revised governance structure, such as a new binational in- stitution charged with managing the waters of the Great Lakes. The new institution’s mission would be to ensure that the Great Lakes support the values and uses important to society in a sustain- able manner, consistent with a vision proposed by Conservation Ontario (2006, 1): The Great Lakes Basin is a global treasure and the Great Lakes and St. Lawrence region is one where people, the environment, and the econ- omy are healthy and thrive for generations to come.

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1 68 Great Lakes Shipping, Trade, and Aquatic Invasive Species KEY POINTS • The only way to eliminate further AIS introductions into the Great Lakes by vessels transiting the seaway would be to close the waterway to all vessel traffic. Such action, which appears un- likely from a political perspective, would eliminate a trade route into and out of the Great Lakes and would not, therefore, enhance the region’s potential for global trade. • Closing the seaway to transoceanic shipping would reduce sub- stantially the risk of AIS introductions by vessels using the wa- terway. However, this action would not address the AIS problem in the Great Lakes in a timely fashion and would increase the cost of moving goods. It could also result in adverse environmental impacts associated with alternative transportation modes and routes, copycat actions or other reprisals by trading partners of the United States and Canada, and the elimination of future transportation options for the Great Lakes region. • A comprehensive technology-based AIS program targeting all vessels transiting the seaway would constitute a practical and technically feasible approach that would go a long way toward eliminating further ship-vectored introductions into the Great Lakes and could help enhance the region’s potential for global trade. • A requirement for all transoceanic and coastal vessels transiting the seaway to conduct BWE or saltwater flushing, if combined with effective enforcement, would be an important step in en- suring that policies aimed at preventing further AIS introduc- tions into the Great Lakes reflect the best current understanding of aquatic invasion biology and proven BWM practices. • The adoption of a single set of ballast water standards for the Great Lakes equivalent to the proposed IMO BWM standards would provide a robust basis for evaluating the effectiveness of shipboard ballast water treatment systems and for informing fu- ture decisions about AIS prevention policies. This approach could also encourage investment by equipment manufacturers and shipowners in the development and demonstration of bal- last water treatment systems for vessels entering the Great Lakes.

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Committee’s Conclusions and Recommended Option 169 • A binational science-based surveillance program to monitor for the presence of new AIS in the Great Lakes would provide infor- mation that could be used to (a) investigate possible deficiencies in prevention strategies and (b) develop capabilities for con- tainment, control, and possible subsequent eradication follow- ing the discovery of any new AIS. • An adaptive process that takes account of new knowledge and lessons learned in preventing AIS introductions would ensure that the proposed technology-based AIS control program responds to the ever-changing challenges posed by AIS in the Great Lakes. REFERENCES Abbreviations IMO International Maritime Organization NRC National Research Council SLSDC St. Lawrence Seaway Development Corporation TRB Transportation Research Board Austin, J. C., S. Anderson, P. N. Courant, and R. E. Litan. 2007. Healthy Waters, Strong Economy: The Benefits of Restoring the Great Lakes Ecosystem. Brookings In- stitution, Washington, D.C. www.healthylakes.org/site_upload/upload/GrtLakesCost Benefit.pdf. Conservation Ontario. 2006. Position on Great Lakes Sustainability. Dec. conservation- ontario.on.ca/policy-issues/CO_GL_position.pdf. Corbett, J. J., and J. J. Winebrake. 2007. Sustainable Goods Movement: Environmental Implications of Trucks, Trains, Ships, and Planes. Environmental Management, Nov., pp. 8–12. coast.cms.udel.edu/Papers/EMCorbettWinebrake2007.pdf. Costello, C., J. M. Drake, and D. M. Lodge. 2007. Evaluating an Invasive Species Policy: Ballast Water Exchange in the Great Lakes. Ecological Applications, Vol. 17, pp. 655–662. Gollasch, G., M. David, M. Voigt, E. Dragsund, C. Hewitt, and Y. Fukuyo. 2007. Critical Review of the IMO International Convention on the Management of Ships’ Ballast Water and Sediments. Harmful Algae, Vol. 6, pp. 585–600. Gray, D. K., T. H. Johengen, D. F. Reid, and H. J. MacIsaac. 2007. Efficacy of Open-Ocean Ballast Water Exchange as a Means of Preventing Invertebrate Invasions Between Freshwater Ports. Limnology and Oceanography, Vol. 52, pp. 2386–2397.

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1 70 Great Lakes Shipping, Trade, and Aquatic Invasive Species Grigorovich, I. A., A. V. Korniushin, D. K. Gray, I. C. Duggan, R. I. Colautti, and H. J. MacIsaac. 2003. Lake Superior: An Invasion Coldspot? Hydrobiologia, Vol. 499, pp. 191–210. Hart, R. C. 1988. Zooplankton Feeding Rates in Relation to Suspended Sediment Con- tent: Potential Influences on Community Structure in a Turbid Reservoir. Freshwater Biology, Vol. 19, pp. 123–139. Hodgson, J. R. 2007. Carrots and Sticks: Opportunities to Accelerate the Development and Adoption of Ballast Water Treatment Technologies for Vessels Operating into the Great Lakes. Hodgson and Associates, Halifax, Nova Scotia, April. IMO. 2004. International Convention for the Control and Management of Ships’ Ballast Water and Sediments. London, United Kingdom. Jenkins, P. T. 2007. Brine as a Treatment Solution for the Control of Aquatic Nuisance Species Introductions into the Great Lakes by NOBOB Vessels. Prepared for Transport Canada Marine Safety by Philip T. Jenkins and Associates, Ltd., Fonthill, Ontario. Kazumi, J. 2007. Ballast Water Treatment Technologies and Their Application for Vessels Entering the Great Lakes via the St. Lawrence Seaway. University of Miami, Fla., May. Kelly, D. W. 2007. Vectors and Pathways for Nonindigenous Aquatic Species in the Great Lakes. Landcare Research, Dunedin, New Zealand, June. Kelly, D. W., and J. Kazumi. 2007. Retroactive Evaluation of International Maritime Orga- nization Ballast Water Standards. Landcare Research, Dunedin, New Zealand, and University of Miami, Fla., Sept. Kirk, K. L. 1991. Inorganic Particles Alter Competition in Grazing Plankton: The Role of Selective Feeding. Ecology, Vol. 72, pp. 915–923. Lake Carriers’ Association and Canadian Shipowners Association. 2001. Voluntary Man- agement Practices to Reduce the Transfer of Aquatic Nuisance Species Within the Great Lakes by U.S. and Canadian Domestic Shipping. Jan. 26. Lawson, J. 2007. The Environmental Footprint of Surface Freight Transportation. Lawson Economics Research, Inc., Ottawa, Ontario, Canada, June. Lloyd’s Register. 2007. Ballast Water Treatment Technology: Current Status. June. Millerd, F. 2007. Global Climate Change and Great Lakes International Shipping. Wilfrid Laurier University, Waterloo, Ontario, Canada, May. NRC. 1996. Stemming the Tide: Controlling Introductions of Nonindigenous Species by Ships’ Ballast Water. National Academy Press, Washington, D.C. Raaymakers, S. 2001. 1st International Ballast Water Treatment Standards Workshop. Global- last Monograph Series No. 4, Workshop Report, IMO, London, March 28–30. global- last.imo.org/monograph%204%20standards%20workshop.pdf. Reid, D. F., T. H. Joehengen, H. MacIsaac, F. Dobbs, M. Doblin, L. Drake, G. Ruiz, and P. Jenkins. 2007. Identifying, Verifying, and Establishing Options for Best Management

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Committee’s Conclusions and Recommended Option 171 Practices for NOBOB Vessels. Final report to the Great Lakes Protection Fund. www.glerl.noaa.gov/res/Task_rpts/2004/aisreid04-1.html. Ruiz, G. M., and J. T. Carlton. 2003. Invasion Vectors: A Conceptual Framework for Man- agement. In Invasive Species: Vectors and Management Strategies (G. M. Ruiz and J. T. Carlton, eds.), Island Press, pp. 459–504. SLSDC. 2007. Seaway Regulations and Rules: Periodic Update, Various Categories. Notice of Proposed Rulemaking. Federal Register, Vol. 72, No. 249, Dec. 31, pp. 74247–74250. Standing Committee on Fisheries and Oceans. 2003. Aquatic Invasive Species: Uninvited Guests. House of Commons, Canada, May. Stewart, R. D. 2007. Do Institutional Mechanisms Exist to Set and Enforce Standards for the Great Lakes That Exceed the Ballast Water Performance and Exchange Standards Estab- lished by the International Maritime Organization? University of Wisconsin, Superior, June 11. Taylor, J. C., and J. L. Roach. 2005. Ocean Shipping in the Great Lakes: Transportation Cost Increases That Would Result from a Cessation of Ocean Vessel Shipping. Grand Valley State University, Grand Rapids, Mich., Aug. www.gvsu.edu/cms3/assets/C6D78A67- 0AEF-0264-A38619EC6FB0793A/OceanShippingReport091105.pdf. Taylor, J. C., and J. L. Roach. 2007. Ocean Shipping in the Great Lakes: An Analysis of Issues, Phase 2. Grand Valley State University, Grand Rapids, Mich., Oct. www.gvsu.edu/ business/index.cfm?id=11971F16-DBAF-2179-96B0680A95CC6F83. TRB. 1996. Special Report 246: Paying Our Way: Estimating Marginal Social Costs of Freight Transportation. National Research Council, Washington, D.C. U.S. Coast Guard. 2007. 2006 Summary of Great Lakes Ballast Water Management Exams. Ninth District. Vander Zanden, M. J. 2007. Surveillance and Control of Aquatic Invasive Species in the Great Lakes. University of Wisconsin, Madison, June 15.