GREAT LAKES MARITIME TASK FORCE One Maritime Plaza – 3rd Floor • Toledo, Ohio 43604 Phone: (419) 255-3940 • Fax: (419) 255-2350 Web site: www.glmtf.org <http://www.glmtf.org/> • E-Mail: info at glmtf.org Great Lakes Maritime Task Force is deeply committed to protecting the Great Lakes environment and appreciates the opportunity to work with the Environmental Protection Agency to ensure that the final implementation of this rule is fair, balanced, and reasonable. We believe that a full understanding of the commercial vessels operating on the Great Lakes, their small environmental footprint, their large environmental benefits, and tremendous economic impact can result in a balanced approach that meets the needs of all. The EPA’s proposed regulation would have eliminated 25% of the U.S.-Flag Great Lakes within a few years. Even the Government of Canada has taken the highly unusual step of asking the EPA to undertake further analysis before proceeding with the Great Lakes portion of this proposed regulation lest 50 Canadian-Flag ships be put at risk. By closely examining the impacts and unintended consequences of over-regulating air emissions from vessels, the Great Lakes region can be protected without impeding our regional and national economic recovery. The U.S.-Flag Great Lakes fleet already burns cleaner fuel than that used by many of the world’s oceangoing vessels. We appreciate the effort of the Great Lakes Congressional delegation and Administration officials who crafted a solution that extends the useful lives of the thirteen U.S.-Flag steamships to 2020, when the .5 % sulfur standard is implemented worldwide. Vessel owners now have more time to make informed business decisions regarding the future of those vessels and explore other options to meet emission requirements. In particular, we thank Congressmen Dave Obey (D-WI) and Jim Oberstar (D-MN), who worked tirelessly to ensure that this regulation can achieve its goals without decimating Great Lakes shipping. We still must determine the best way to deal with the thirteen U.S.-Flag lakers that employ Category 3 compression-ignition engines. The regulatory flexibility extended to other industries and other fuel standards is appropriate for the Lakes Heavy industry needs affordable transportation of raw materials and so does the American consumer, otherwise neither will prosper. The potential economic impact of the proposed rule, if enacted as proposed, would have been just one more blow for a region already suffering record unemployment. The environment needs Great Lakes shipping too. Ships burn less fuel and produce fewer emissions than trains and trucks. The thirteen vessels that currently are powered with Category 3 diesel engines using intermediate fuel hauled 29 million tons of cargo in 2008. It would take 1.1 million trucks or 290,000 railcars to replace their carrying capacity. We all win when we keep these cargos on vessels working the Great Lakes. ******************* Founded in 1992, Great Lakes Maritime Task Force promotes domestic and international shipping on the Great Lakes. It is the largest coalition to ever speak for the Great Lakes shipping community and draws its membership from both labor and management representing U.S.-Flag vessel operators, shipboard and longshore unions, port authorities, cargo shippers, terminal operators, shipyards and other Great Lakes interests. Its goals include restoring adequate funding for dredging of Great Lakes deep-draft ports and waterways, construction of a second Poe-sized lock at Sault Ste. Marie, Michigan; protecting the Jones Act and other U.S. maritime cabotage laws and regulations; maximizing the Lakes overseas trade; and opposing exports and increased diversions of Great Lakes water. -30- For more information contact Glen G. Nekvasil, Secretary:440-333-9996 / E-mail: info at glmtf.org GLMTF Members illinois ArcelorMittal USA – Chicago ♦ CN – Chicago ♦ Chicago Port Council – Joliet Hannah Marine Corporation – Lemont ♦ Illinois International Port District – Chicago indiana Central Marine Logistics, Inc. – Griffith ♦ Ports of Indiana – Indianapolis michigan CMS Energy – Jackson ♦ Central Dock Company – Benton Harbor ♦ Detroit Edison - Detroit Detroit/Wayne County Port Authority – Detroit ♦ Dock 63 Inc. – St. Joseph ♦ Durocher Marine – Cheboygan Edw. C. Levy Co. – Detroit ♦ International Association of Machinists & Aerospace Workers – Washington Twsp. International Union of Operating Engineers Local 324 – Livonia ♦ The King Co., Inc. – Holland Lake Michigan Carferry Service, Inc. – Ludington ♦ Lakes Pilots Association – Port Huron Luedtke Engineering Company – Frankfort ♦ MCM Marine, Inc. – Sault Ste. Marie Michigan Maritime Trades Port Council, MTD, AFL-CIO – Algonac Pere Marquette Shipping Company – Ludington ♦ Ryba Marine Construction Co. – Cheboygan Sargent Companies – Zilwaukee ♦ Seafarers International Union – Algonac Soo Marine Supply, Inc. – Sault Ste. Marie ♦ Wirt Stone Docks – Bay City minnesota AGP Grain, Ltd. - Duluth ♦ Duluth Seaway Port Authority – Duluth ♦ Great Lakes Fleet / Key Lakes, Inc. – Duluth Hallett Dock Company – Duluth ♦ Marine Tech, LLC – Duluth montana Montana Coal Council – Helena new york American Steamship Company – Williamsville ♦ Gateway Trade Center, Inc. – Buffalo Maritime Port Council of Greater New York & Vicinity – New York ♦ Port of Oswego Authority – Oswego St. Lawrence Seaway Pilots’ Association – Cape Vincent ohio AK Steel – Middletown ♦ Cleveland-Cuyahoga County Port Authority – Cleveland Cliffs Natural Resources, Inc. – Cleveland ♦ Corus – Warren CSX Transportation, Toledo Docks – Toledo Flats Oxbow Association – Cleveland Faulkner, Muskovitz & Phillips, LLP – Cleveland Grand River Navigation Company, Inc. – Avon Lake ♦ Great Lakes District Council, ILA, AFL-CIO – Cleveland The Interlake Steamship Company – Richfield ♦ ILA - Lake Erie Coal & Ore Dock Council – Toledo ILA - Local 1317 – Cleveland ♦ ILA - Local 1768 – Toledo ♦ Int’l Organization of Masters, Mates & Pilots – Cleveland Int’l Ship Masters’ Association – Brooklyn ♦ Ironhead Marine, Inc., – Toledo Lafarge North America – Streetsboro ♦ Lake Carriers’ Association – Rocky River ♦ Lorain Port Authority – Lorain MEBA, AFL-CIO – Cleveland ♦ Midwest Terminals of Toledo, International, Inc. – Toledo Osborne Concrete & Stone Co. – Grand River ♦ Pickands Mather Lake Services Company, Inc. – Kirtland Toledo-Lucas County Port Authority – Toledo ♦ Toledo Port Council, MTD, AFL-CIO – Toledo United Steelworkers, District 1, AFL-CIO-CLC – Warrensville Hts. United Steelworkers, Local 5000 – Middleburg Hts. ♦ Wheeling & Lake Erie Railway Co. – Brewster pennsylvania Carmeuse Lime, Inc. – Pittsburgh ♦ Erie Shipbuilding, LLC – Erie ♦ US Steel Corp. – Pittsburgh virginia B+B Dredging Company – Portsmouth Norfolk Southern Corporation (coal shipping docks in Sandusky, Ohio, and Ashtabula, Ohio) – Norfolk wisconsin Bay Shipbuilding Company – Sturgeon Bay ♦ Brown County Port & Solid Waste Dept. – Green Bay City of Superior Planning Department – Superior ♦ Fox River Dock Co., Inc. – Green Bay Fraser Shipyards, Inc. – Superior ♦ Midwest Energy Resources Company – Superior The Port of Milwaukee – Milwaukee ♦ Western Great Lakes Pilots’ Association – Superior greater washington, dc American Great Lakes Ports Assn. – Washington, DC ♦ American Maritime Officers, AFL-CIO – Washington, DC American Maritime Officers Service – Washington, DC ♦ American Shipbuilding Association – Washington, DC Int’l Brotherhood of Boilermakers – Fairfax, VA ♦ K&L | Gates – Washington, DC Transportation Institute – Camp Springs, MD This email and any attached files are confidential and intended solely for the intended recipient(s). If you are not the named recipient you should not read, distribute, copy or alter this email. Any views or opinions expressed in this email are those of the author and do not represent those of the company. Warning: Although precautions have been taken to make sure no viruses are present in this email, the company cannot accept responsibility for any loss or damage that arise from the use of this email or attachments. -------------- next part -------------- An HTML attachment was scrubbed... URL: http://www.great-lakes.net/lists/glin-announce/attachments/20091028/e539514e/attachment.html -------------- next part -------------- A non-text attachment was scrubbed... Name: not available Type: image/jpeg Size: 1070 bytes Desc: image002.jpg Url : http://www.great-lakes.net/lists/glin-announce/attachments/20091028/e539514e/attachment.jpe