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REGULATORY REVIEW “Ballast water is a policy that has in many ways eluded the Basin for decades and one that is worth getting right. The Commission strongly urges the US and Canada to ? nd a way to work together with the Great Lakes

Basin community to develop smart, durable and consensus-based policy solutions for vessel discharges.” – Darren Nichols, Executive Director -

Great Lakes Commission will include tracking invasive species, evaluating speci? c GLC, established in 1955, includes the eight Great Lakes risks and establishing emergency best management prac- states; Ontario and Quebec are associate members.

tices for rapid deployment in a speci? c locality or region. VIDA does provide a mechanism for Great Lakes gover-

This is to be coordinated through the federal Aquatic nors to propose and implement “enhanced standards and

Nuisance Species Task Force (ANSTF) which includes requirements.” But it’s not a quick and direct process and representatives from numerous federal agencies, as well as the costs associated with a new standard have to be consid- ex-of? cio members, from the American Water Works As- ered. For higher compliance costs, each Great Lakes gov- sociation, for example, and the Great Lakes Commission. ernor has to endorse the proposed standard. If compliance

Six regional panels advise the larger Task Force. costs do not increase, just ? ve of the eight governors need

Brady said a focus on this Framework is starting now but to endorse. Depending on point of view this can seem too he added that these next steps depend somewhat on the pro- slow and clumsy. On the other hand, it prevents governors, posals within the forthcoming draft policy letter. Importantly, perhaps facing internal state pressures, from casually tak- this response Framework is linked to new ballast water report- ing on a process with very complex science.

ing requirements to be ? led with the National Ballast Infor- Darren Nichols is Executive Director of the Great Lakes mation Clearing House. The reports will serve as the basis for Commission. As VIDA moves forward, Nichols said that an annual report evaluating “nationwide status and trends” GLC is evaluating how it can best in? uence upcoming bal- relating to ballast water delivery and management and “inva- last water policy decisions. A top priority is a “constructive sions of aquatic nuisance species resulting from ballast water.” binational dialogue.” Canada’s ballast water regulations

That ? rst annual report, authored by the coast Guard in align with the IMO, not the U.S. Coast Guard. Nichols conjunction with the Task Force and the Smithsonian En- wrote in an email reply to questions that it’s unclear to the vironmental Research Center (SERC), is due July 1, 2019. Commission “whether and how the two federal govern-

It’s not clear whether that ? rst report will be ready on time. ments are working together toward a harmonized outcome

SERC of? cials did not reply to questions about their work. in the Great Lakes.” One idea GLC is considering is a con- ference with EPA and the Coast Guard to “explore where there may be areas of consensus among key stakeholders”

The Great Lakes

As one might expect, the Great Lakes Commission (GLC), before “proposing a formal national standard.”

It is GLC’s contention that dual federal rulemaking is based in Ann Arbor, MI, is one major regional group keep- unlikely to provide a comprehensive solution to ballast ing a close watch on initial VIDA/ballast water implementa- tion. With invasive species, particularly for the Great Lakes, water within the Great Lakes basin. The GLC Board of

Directors seeks a “harmonized, binational approach since there’s usually no second chance – clean up and remedia- tion are poor substitutes compared to preventative diligence. the waters of the Great Lakes are not limited by political

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