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E-M:/ MI ballast water discharges: Public comments due 7/28!

Enviro-Mich message from "Molly Flanagan" <Flanaganm@nwf.org>

This is a friendly reminder that if you have not yet submitted comments
on the draft MI ballast water discharge permit, to please do so by
tomorrow (Friday, July 28th).  Below is an action alert circulated by
Great Lakes United.  Thank you for your time and consideration of this
critically important issue.


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


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

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.

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 

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