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E-M:/ MI permit to control dirty ballast discharges: Public comments due 7/28!
- Subject: E-M:/ MI permit to control dirty ballast discharges: Public comments due 7/28!
- From: "Molly Flanagan" <Flanaganm@nwf.org>
- Date: Mon, 24 Jul 2006 15:06:44 -0400
- Delivered-to: firstname.lastname@example.org
- Delivered-to: email@example.com
- List-name: Enviro-Mich
- Reply-to: "Molly Flanagan" <Flanaganm@nwf.org>
Enviro-Mich message from "Molly Flanagan" <Flanaganm@nwf.org>
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
and then pass this action alert along. If you have any questions,
feel free to contact me, Jen Nalbone, Great Lakes United, 716-213-0408
firstname.lastname@example.org, or Kyle Landis-Marinello, National Wildlife Federation,
734-769-3351 x45, email@example.com. We are happy to help!
Michigan Permit to Control Dirty Ballast Discharges
Public Input needed!
Please submit comments by Friday, July 28, 2006
On June 2, 2005, Michigan passed Public Act 33 to protect state waters
the Great Lakes from aquatic invasive species introduced from dirty
water discharges. Act 33 was a state-level response to the lack
government control over ocean-vessel ballast water dumping in U.S.
Ballast water is periodically taken onboard and released by vessels
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.
released into a new environment invaders can cause serious economic
environmental damage. The zebra mussel is a well known invader
an ocean-vessel into the Great Lakes. About 90% of ocean-vessels that
the Great Lakes are heavily loaded with cargo and carry little ballast
for stabilization. These vessels, called "No Ballast on Board" (NOBOB),
not subject to federal regulations, though they still carry invaders in
residuals that can be released and cause harm.
Act 33 requires the Michigan Department of Environmental Quality (MDEQ)
regulate oceangoing vessels in Michigan beginning January 1, 2007. By
date, an ocean-vessel must obtain a permit from the MDEQ if it wants
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
invasive species introductions if it intends to discharge ballast tank
The MDEQ is gathering public comments on the permitting process
well as on four proposed ballast water treatment methods that
can use to meet permit requirements. These treatments are:
treatment; Chlorine Dioxide treatment; Solids removal followed by UV
Radiation treatment; and Deoxygenation treatment.
Official copies of the MDEQ public notice, fact sheet, and draft permit
be found at: http://www.michigan.gov/deq (on the left side of the
click on Water, Surface Water, and NPDES Permits; then click on
Public Notice" which is under the Permits banner)
Please take a moment to send an email to Michigan (e-mail:
firstname.lastname@example.org ) and comment on the state draft permit.
your letter are drafted below, but please modify freely to reflect
opinions and interests. Comments from individuals or organizations
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
33 and develop a permitting program to prevent biological pollution
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
dirty ballast water discharges. I strongly support Michigan meeting
deadline set in Public Act 33 and implementing a permitting program no
than January 1, 2007.
Second, Michigan should additionally establish a performance standard
ocean-vessels that will prevent the discharge of aquatic invasive
as Act 33 requires. The benefit of articulating a performance standard
that it is non-prescriptive, and allows the shipping industry to
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.
carry invaders and present a threat to the Great Lakes. NOBOB's make up
majority of vessels entering Michigan waters, and are currently
by the federal government, or covered by the draft state permit. These
vessels should be required to perform a mid-ocean tank flushing before
allowed to operate at a Michigan port.
Finally, I would like to stress that only environmentally sound
and treatments should be used. To this end, Michigan must remove the
hypochlorite as a possible treatment that ocean-vessels could use to
with the state permit. Hypochlorite is not safe for discharge into the
environment because it creates dangerous by-products when it interacts
organic matter. I also urge you to embrace the precautionary principle
you determine whether to allow the use of any chemical biocide and
negative repercussions to the environment or public health will result
Thank you again for doing all that you can to protect state waters and
Great Lakes from invaders. In light of the failure of the federal
to regulate ocean-vessel ballast water discharges, I urge Michigan, as
as other Great Lakes states and provinces, to work in concert to
Great Lakes waters.
You have my support in this critical effort, and I trust that you will
to improve the draft permit before its finalization to best protect
natural resources and our precious Great Lakes waters.
(If you would like a summary of comments from Michigan, please include
full mailing address and email)
Campaign Director, Great Lakes United
(716) 213-0408; web: www.glu.org
Great Lakes United staff represented by UAW Local 55
GLWatch: providing top Great Lakes announcements each month. Send a
email to: <BLOCKED::mailto:email@example.com>
AIS: information on aquatic invasive species in the Great Lakes. Send
blank email to: <BLOCKED::mailto:firstname.lastname@example.org>
NAV: information on navigation in the Great Lakes. Send a blank email
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
NWF's mission is to inspire Americans to protect wildlife for our
ENVIRO-MICH: Internet List and Forum for Michigan Environmental
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