In March 2013, the U.S. EPA issued its updated Vessel General Permit that will come into effect on December 19, 2013. Similar to the Coast Guard’s Final Rule, the EPA generally requires BMPs on lakers. However, the EPA’s Vessel General Permit also allows individual states to add their own requirements and that could mean requiring ballast water treatment systems. For example, two Great Lakes states have at times considered mandating systems that exceed the current norm by 1,000 times, this despite the fact there isn’t even a way to measure performance to such a level.

LCA supports the continued use of Best Management Practices on lakers, and not just because no treatment system is currently available that can accommodate lakers’ volumes and flowrates. Lakers never leave the system, so they have never introduced a non-indigenous species. Lakers’ ballast could possibly spread a species introduced by an oceangoing vessel, but one must remember there are at least 64 identified vectors for introduction and spread. Further, no new non-indigenous species have been identified ever since 2006 when the St. Lawrence Seaway started requiring mid-ocean ballast water exchange on vessels that loaded overseas.

Add to that the fact the Lakes are interconnected, so species can and do migrate independent of commercial navigation. The ruffe, for example, is expanding its range by migrating along the southern shore of Lake Superior.

Technology may well reach the point where a system can handle lakers’ volumes and flowrates (which can top 16.4 million gallons and approach 80,000 gallons per minute), but for all the reasons stated here, there is no need for lakers to treat their ballast.

LCA has helped to find solutions to this world-wide problem. Our first voluntary ballast water management plan dates from 1993. Within a few years we were collaborating on testing a filtration system that could be installed on oceangoing vessels trading to the Lakes. Best Management Practices and steps to respond to an outbreak of viral hemorrhagic septicemia followed. Individual members have undertaken efforts of their own. We too want to see an end to ballast water introductions of non-indigenous species and that goal now is in sight with the coming requirement that oceangoing vessels treat their ballast.

Nationwide, the fleet engaged in domestic waterborne commerce numbers more than 40,000 vessels of all kinds. While the Lakes Jones Act fleet numbers only 65 or so large vessels, they are real workhorses, moving as much as 115 million tons of cargo per year when the economy is strong.

The ownership requirement ensures the U. S. maintains control over its domestic fleet. The build requirement supports the shipyards that are needed to build and maintain our Navy and Coast Guard. The crewing requirement means the U. S. has skilled and loyal seafarers to call on in times of war to ferry supplies to our troops throughout the globe.  During the first Persian Gulf war, some foreign-flag vessels chartered to move supplies to U.S. troops refused to enter the war zone.

The level playing field promotes competition (contracts are won or lost for cents per ton), and on the Great Lakes, has produced the world's largest fleet of self-unloading vessels. The Lakes Jones Act fleet is so efficient a vessel can move a ton of cargo more than 800 miles for about roughly the cost of a lunch at a moderately priced restaurant.

Every Administration since 1920 has supported the Jones Act. The Navy considers the law indispensible. It's very simple, without the Jones Act, America would be less secure.

The environment benefits too.  Jones Act vessels are held to the world's highest environmental, safety, and operational standards.

Twinning the Poe Lock is a perfect vehicle for energizing the region's economy. The $590 million project is shovel ready, and would, over a decade, generate 1.5 million man hours for construction workers. One economist likens the project to opening an auto manufacturing plant in one of the most distressed areas of the country.

The benefits will continue long after construction is complete. Because nearly 70 percent of U. S.-flag carrying capacity on the Lakes is restricted to the Poe Lock, a second chamber will ensure a failure of the Poe Lock does not bring Great Lakes shipping to a virtual standstill. This means steel mills and power plants no longer need fear crippling disruptions in their supply chain should the Poe Lock fail and the U. S. military no longer needs fear a slowdown or cessation of steel production.

The coffer dams at either end of what will be the new chamber are in place, so if Congress will appropriate $100 million or so this year, full-scale construction could be underway almost immediately. If the project is funded in small increments, the 10-year construction schedule will be extended and the overall cost will increase due to the inefficiencies inherent with incremental funding.

The reason the project has stalled is a flawed benefit/cost (b/c) study that incorrectly assumes the railroads can fill the void if the Poe Lock goes down for a lengthy period of time.  That conclusion is wrong in two regards: 1) the railroads do not have enough rolling stock to move the cargo that vessels currently haul; and 2) many end users, steel mills in particular, lack rail access.  At the behest of Senator Debbie Stabenow (D-MI), the Corps is re-examining the lock’s benefits and seeking more input from Great Lakes stakeholders.  A proper analysis of the lock’s role will produce a positive b/c ratio.

Next to get underway was the tug/barge unit DOROTHY ANN/PATHFINDER. The vessel, one of 10 operated by The Interlake Steamship Company, loaded about 13,000 tons of iron ore at Cleveland Bulk Terminal in Cleveland, Ohio, on March 4 for delivery to the steel mill at the end of the deep-draft section of the Cuyahoga River.

Over the next several weeks, 52 more U.S.-flag lakers will return to service and spend 10-plus months hauling the raw materials that are the foundation of the industrial heartland, primarily iron ore, limestone and coal. During the course of the season more than 1,600 American mariners will crew these vessels.

The U.S.-flag Great Lakes fleet is unique in the world in that virtually every vessel is a self-unloader, which means the ship or barge can discharge cargo without any assistance from shoreside personnel or equipment. The largest vessels can unload 70,000 tons of cargo in 12 hours or less. Prior to self-unloading, it would have taken days to empty a vessel of a cargo that size.

The self-unloading vessel was invented and perfected on the Great Lakes and is one reason waterborne commerce on the Inland Seas is so efficient. A recent study by the U.S. Maritime Administration states that “on average, transportation cost savings from $10 to more than $20 per ton are associated with the use of lakers compared to the next most competitive transportation mode.” The U.S. Army Corps of Engineers estimates that Great Lakes shipping annually saves its customers $3.6 billion compared to the next least costly mode of transportation.

By law - the Jones Act - U.S.-flag lakers are built in the United States, crewed by American citizens and owned by American corporations. This holds the vessels to the world’s highest safety and operational standards and mandates that crews pass demanding U.S. Coast Guard exams.

The environment benefits when the Lakes fleet returns to service. Vessels use less fuel to move a ton of cargo than trains or trucks and produce significantly fewer emissions in the process. A number of lakers have been repowered in recent years with state-of-the-art engines and generators that have further reduced the industry’s carbon footprint.

Iron ore for steel production is the primary cargo moved by U.S.-flag lakers. In 2012, the fleet moved more than 45 million tons of taconite pellets. Limestone for the construction industry and steelmaking approached 22 million tons. Coal for power generation totaled more than 17 million tons. Other cargos included cement, salt, sand and grain and collectively totaled 5 million tons.

Those totals were impacted by the dredging crisis on the Great Lakes. At the end of 2012, the largest vessels were leaving more than 10,000 tons of cargo behind because of inadequate dredging and falling water levels. If the full length of the Federal navigation channel in the Cuyahoga River was dredged to its project depth, 23 feet, the PATHFINDER would have been able to carry 3,200 more tons. The vessel is scheduled to shuttle ore within Cleveland Harbor for four weeks, so will forfeit approximately 77,000 tons.

There is no reason the Great Lakes Navigation System cannot be maintained to project depth. The cargos that move on the Lakes (and East, Gulf and West Coasts) are taxed and the receipts are deposited in the Harbor Maintenance Trust Fund (“HMTF”). Nationwide the tax generates about $1.6 billion per year, but the HMTF typically only spends about $750 million. The surplus, about $7 billion, is used to mask the size of the Federal deficit. As a result, more than 18 million cubic yards of sediment now clog Great Lakes ports and waterways.

Legislation that would require the HMTF to spend what it takes in for dredging on dredging has been introduced in both the House and Senate. H.R. 335 was introduced on January 22 and already has 94 co-sponsors, 17 from Great Lakes districts. S. 218 was introduced on February 4, and has 31 co-sponsors, including 12 of the 16 Great Lakes Senators. The U.S. Army Corps of Engineers estimates it would cost about $200 million to restore the Great Lakes Navigation System, just a fraction of the surplus amassed in the HMTF.

The next vessels to enter service will be two cement carriers on March 7. The iron ore trade out of Escanaba, Michigan, is expected to resume on March 14.

Lake Carriers’ Association represents 17 American companies that operate 57 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, limestone and cement for the construction industry, coal for power generation, as well as salt, sand and grain. Collectively, these vessels can transport more than 115 million tons of cargo per year. Those cargos generate and sustain more than 103,000 jobs in the United States and have an economic impact of more than $20 billion. More information is available at www.lcaships.com. Contact Glen Nekvasil, Vice President. Phone: (440) 333-9996.