National marine sanctuaries have been and should continue to be developed in a way that does not undermine other lawful beneficial uses of the Great Lakes.
It is the policy of the United States¹ to, among other objectives:
- Support sustainable, safe, secure, and productive access to, and uses of the ocean, our coasts, and the Great Lakes
- Respect and preserve our Nation's maritime heritage, including our social, cultural, recreational, and historical values.
Great Lakes national marine sanctuaries, as cultural assets, celebrate the historic maritime heritage of the Great Lakes and respect the many lives lost and the sailors still plying these waters. Sanctuaries are a key component of the responsible use of our waters as is commercial maritime transportation. Lake Carriers’ Association (LCA) welcomes the recreational and educational opportunities of sanctuaries. However, it is imperative that they should not encumber critical commercial activity related to maritime transportation on the Lakes, connecting channels, and in ports.
Three lawful commercial activities are of paramount concern to LCA members:
- Dredging of federal navigation channels in ports, rivers, and their approaches is essential for our vessels’ access to dockside customers, an Army Corps’ of Engineers mandate since it was established under the General Survey Act of 1824.
- Washdown of de minimis amounts of dry cargo residue critical for the safety of crew members working on deck in accordance with the geographic limits set in 33 CFR Table 151.66(b)(3).
- Ballasting that is crucial to maintain propulsion, maneuverability, and trim, all key components necessary for the safe operation of a vessel. Section 602, Safe Vessel Operation in the Great Lakes, of the Coast Guard Authorization Act of 2015 specifically permits ballasting in culturally-based sanctuaries of the Great Lakes.
These activities are critical to commercial waterborne transportation, the many businesses served by our members, and the unencumbered sharing of the collective Great Lakes resources. These normal, lawful operations constitute no negative impacts on sanctuaries and must continue to be allowed once any sanctuary is established.
Lastly, when setting boundaries of sanctuaries in the Great Lakes, ports should not be included and the landward boundary should be located 10 feet below low water datum so that common practices, such as beach nourishment, can continue to enhance public and private shorefront properties.
LCA represents 14 American companies that operate 56 U.S.-flag vessels on the Great Lakes and carry the raw materials that drive the nation’s economy: iron ore and fluxstone for the steel industry, aggregate and cement for the construction industry, coal for power generation, as well as salt, sand and grain. Collectively, these vessels can transport more than 100 million tons of cargo per year. Our members help drive 227,000 jobs, $3.6 billion in transportation savings, and 3.2 percent of the Nation’s gross domestic product.
¹ Executive Order 13547, Stewardship of the Ocean, Our Coasts, and the Great Lakes (July 19, 2010)