CLC attorneys and Clinic interns advised long-standing client, Great Lakes United, and four other conservation groups in preparing comments on the U.S. Coast Guard's ballast water rulemaking (docket number USCG-2001-10486). The dangers that ballast water poses for the introduction of aquatic invasive species have been recognized for well over a century. With the opening of the St. Lawrence Seaway in 1959, ocean vessels have become the main way that invasive species, such as the zebra mussel and round goby, have been introduced into the Great Lakes, costing millions of dollars in damage and taking a tremendous toll on the environment.
The detailed comments recognized the rule's strides to ensure ballast water discharges to U.S. waters, including the Great Lakes, no longer introduce aquatic invasive species. However, the comments also note significant weaknesses in the proposed rule. The comments call on the Coast Guard to: strengthen the phase one (first level) standards; shorten the timelines for implementation; tighten the technology practicability review process; verify treatment and technologies will work in a truly freshwater system; address the whole ship, including invasive species carried on anchors, anchor chains, and hulls; and establish a rigorous monitoring and enforcement program for compliance with the new regulations.