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E-M:/ MI permit to control dirty ballast discharges: Public comments due 7/28!



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Enviro-Mich message from "Molly Flanagan" <Flanaganm@nwf.org>
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Important action alert circulated by Great Lakes United.  I apologize
for any cross postings.  Please send in your comments by the due date,
this Friday, July 28, 2006.

Please take a minute to send a letter supporting and recommending
improvements to the Michigan effort to regulate ballast water
discharges,
and then pass this action alert along. If you have any questions,
please
feel free to contact me, Jen Nalbone, Great Lakes United, 716-213-0408
jen@glu.org, or Kyle Landis-Marinello, National Wildlife Federation,
734-769-3351 x45, marinellok@nwf.org. We are happy to help!
 

Michigan Permit to Control Dirty Ballast Discharges
Public Input needed!
Please submit comments by Friday, July 28, 2006


Background:

On June 2, 2005, Michigan passed Public Act 33 to protect state waters
and
the Great Lakes from aquatic invasive species introduced from dirty
ballast
water discharges. Act 33 was a state-level response to the lack
federal
government control over ocean-vessel ballast water dumping in U.S.
waters.

Ballast water is periodically taken onboard and released by vessels
for
stabilization purposes as a vessel moves from port to port loading and
unloading cargo. Ballasting is an essential part of safe shipping
operations. However, ballast tanks also can harbor invasive species.
When
released into a new environment invaders can cause serious economic
and
environmental damage. The zebra mussel is a well known invader
introduced by
an ocean-vessel into the Great Lakes. About 90% of ocean-vessels that
enter
the Great Lakes are heavily loaded with cargo and carry little ballast
water
for stabilization. These vessels, called "No Ballast on Board" (NOBOB),
are
not subject to federal regulations, though they still carry invaders in
tank
residuals that can be released and cause harm.

 

Act 33 requires the Michigan Department of Environmental Quality (MDEQ)
to
regulate oceangoing vessels in Michigan beginning January 1, 2007.  By
this
date, an ocean-vessel must obtain a permit from the MDEQ if it wants
to
operate in a Michigan port. A permit will be issued only if the vessel
demonstrates 1) it will not discharge aquatic invasive species, or 2)
environmentally sound technology and methods are used to prevent
aquatic
invasive species introductions if it intends to discharge ballast tank
contents.

 

The MDEQ is gathering public comments on the permitting process
overall, as
well as on four proposed ballast water treatment methods that
ocean-vessels
can use to meet permit requirements. These treatments are:
Hypochlorite
treatment; Chlorine Dioxide treatment; Solids removal followed by UV
Light
Radiation treatment; and Deoxygenation treatment. 

 

Official copies of the MDEQ public notice, fact sheet, and draft permit
can
be found at: http://www.michigan.gov/deq  (on the left side of the
screen
click on Water, Surface Water, and NPDES Permits; then click on
"Permits on
Public Notice" which is under the Permits banner)

 

Sample Letter:

Please take a moment to send an email to Michigan (e-mail:
burnsb@michigan.gov ) and comment on the state draft permit.
Suggestions for
your letter are drafted below, but please modify freely to reflect
your
opinions and interests. Comments from individuals or organizations
outside
of Michigan State are welcome.

 

---

 

Barry Burns, Permits Section

Water Bureau, Department of Environmental Quality

P.O. Box 30273

Lansing, Michigan 48909

Re: Draft permit # MIG140000

 

Dear Mr. Burns,

 

I am writing to comment on Michigan's draft permit to implement Public
Act
33 and develop a permitting program to prevent biological pollution
from
ocean-vessel ballast water discharges.

 

First, I would like to thank Michigan for demonstrating leadership and
acting upon its responsibility to protect state and Great Lakes waters
from
dirty ballast water discharges. I strongly support Michigan meeting
the
deadline set in Public Act 33 and implementing a permitting program no
later
than January 1, 2007.

 

Second, Michigan should additionally establish a performance standard
for
ocean-vessels that will prevent the discharge of aquatic invasive
species,
as Act 33 requires. The benefit of articulating a performance standard
is
that it is non-prescriptive, and allows the shipping industry to
choose
alternative technologies or treatments that may be more efficient and
effective in removing or killing invaders. 

 

Third, to prevent the discharge of aquatic invasive species, as Act 33
requires, the permit needs to regulate "No Ballast on Board" vessels.
NOBOBs
carry invaders and present a threat to the Great Lakes. NOBOB's make up
the
majority of vessels entering Michigan waters, and are currently
unregulated
by the federal government, or covered by the draft state permit. These
vessels should be required to perform a mid-ocean tank flushing before
being
allowed to operate at a Michigan port.

 

Finally, I would like to stress that only environmentally sound
technologies
and treatments should be used. To this end, Michigan must remove the
use of
hypochlorite as a possible treatment that ocean-vessels could use to
comply
with the state permit. Hypochlorite is not safe for discharge into the
environment because it creates dangerous by-products when it interacts
with
organic matter. I also urge you to embrace the precautionary principle
as
you determine whether to allow the use of any chemical biocide and
ensure no
negative repercussions to the environment or public health will result
from
biocide use. 

 

Thank you again for doing all that you can to protect state waters and
the
Great Lakes from invaders. In light of the failure of the federal
government
to regulate ocean-vessel ballast water discharges, I urge Michigan, as
well
as other Great Lakes states and provinces, to work in concert to
protect
Great Lakes waters. 

 

You have my support in this critical effort, and I trust that you will
work
to improve the draft permit before its finalization to best protect
Michigan
natural resources and our precious Great Lakes waters.

 

Sincerely,

Your Name 

(If you would like a summary of comments from Michigan, please include
your
full mailing address and email)

 

 

Jennifer Nalbone

Campaign Director, Great Lakes United

(716) 213-0408; web: www.glu.org 

 

Great Lakes United staff represented by UAW Local 55

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Molly M. Flanagan
National Wildlife Federation 
Great Lakes Natural Resource Center
213 West Liberty Street, Suite 200
Ann Arbor, Michigan 48104
Phone: 734-769-3351  |  Fax: 734-769-1449 
flanaganm@nwf.org
http://www.nwf.org

NWF's mission is to inspire Americans to protect wildlife for our
children's future. 


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