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REGULATORY REVIEW boundaries.” Regarding process, GLC thinks that solving lent cooperation and communication” between the two agen- ballast water issues will require a “more nuanced dialogue” cies. As an example, she cited the recent EPA/Coast Guard than exists within standard public comment processes, e.g., VIDA listening session at the US Merchant Marine Academy.

the 60-day window that will follow the draft policy letter. Carpenter said that VIDA implementation offers the

Nichols writes, “Ballast water is a policy that has in many Coast Guard and EPA a chance to prioritize management ways eluded the Basin for decades and one that is worth practices that can provide better payoffs for environmental getting right. The Commission strongly urges the US and protection and vessel operators’ time and resources. She

Canada to ? nd a way to work together with the Great Lakes noted, for example, that with barges, the VGP requires a

Basin community to develop smart, durable and consen- weekly vessel inspection that must be documented every sus-based policy solutions for vessel discharges.” week and reported to EPA annually. If a company owns 100 barges, that generates over 5000 reports per year, a ? ling deluge not likely helpful to anyone. She hopes that

A Good Start?

On the industry side, the American Waterways Operators VIDA implementation results in a program focused on (AWO) has long been involved in ballast water policy. AWO pollution prevention, establishing big-picture indicators of led the industry coalition supporting VIDA’s passage, citing progress and success, based on streamlined and ef? cient compliance requirements from marine businesses.

the bene? ts of a uniform, national program. Jennifer Car-

That’s a great set of goals. The clock is ticking.

penter is AWO’s Executive Vice President & Chief Operating

Of? cer. It’s her assessment that EPA and the Coast Guard are

Tom Ewing is a freelance writer specializing in off to a good start with VIDA implementation. “We’re very energy and environmental issues.

encouraged by what we’ve seen,” Carpenter said, citing “excel- 39 www.marinelink.com MN

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