From the desk of Rear Admiral John Nadeau, assistant command for prevention policy
In December of 2015, my predecessor, Rear Admiral Paul Thomas, published a six-part blog series to provide an update about the Coast Guard’s ballast water regulations. The focus at that time was primarily on implementing the 2012 regulations. The ballast water blog series was one of the most popular series to be published on Maritime Commons, prompting outstanding feedback to the Coast Guard and numerous discussions nationally and internationally.
In 2016, the Coast Guard received more than 122,000 ballast water reports, and reporting compliance is over 90 percent. There are now six U.S. type approved Ballast Water Management Systems (BWMS), and the Coast Guard expects more applications for type approval in the near future. The Coast Guard focus has shifted from implementing the 2012 regulations to ensuring that vessels comply with requirements. Things have changed internationally as well. The International Maritime Organization (IMO) Ballast Water Management Convention entered into force on Sept. 8, 2017, requiring most ships around the world to comply with the Convention. Although the U.S. is not a party to the Convention, the Coast Guard recognizes this milestone as it represents many years of hard work by nations around the globe to prevent the spread of invasive species in ballast water.
Considering the challenges associated with managing ballast water, I am not surprised to be questioned about ballast water during nearly every discussion I have with the maritime industry. Based on these discussions and my most recent engagements, both domestically and internationally, I am now offering a new five-part series to provide an update on the U.S. ballast water program.
As an introduction, I will provide an overall perspective on ballast water management. The second blog will discuss the Coast Guard’s shift in focus from regulatory implementation to regulatory compliance. The third blog will provide an update on the U.S. type approval program. In the fourth blog, I will provide insight on a recommended approach to selecting a BWMS, and the fifth blog will discuss contingency planning for inoperable equipment or unavailable management methods.
Coast Guard Perspective on Ballast Water Management
The Coast Guard’s approach to managing invasive species in ballast water is analogous to how we have approached other environmental threats. For example, many years ago, the approach to managing oily bilge water and untreated sewage was not like it is today. When these discharges began being regulated, there was initial confusion, followed by uncertainty, and an overall hesitancy to purchase newly required equipment. As we transitioned from implementation to compliance, owners, operators, and crew members adopted new shipboard management practices, procured new shipboard equipment, and changed the way they operate. We are taking the same approach with ballast water management.
Combating invasive species in ballast water is a complex challenge. At the core of this issue is a real threat to our environment and economy. According to the National Ballast Information Clearinghouse, so far in 2017, almost half of ballast water discharged into the U.S. has been from overseas sources. That’s more than 122 million cubic meters of foreign ballast water. The U.S. Fish and Wildlife Service estimates that invasive species cause more than $120 billion in damages each year in the United States alone. The treatment technologies used in BWMSs are also complex and evolving. In facing these challenges, we must keep in mind these invasive species can enact significant long lasting damage to both the environment and our economy.
Over the past 30 years the Coast Guard has transitioned from voluntary ballast water exchange, to mandatory exchange, to the new ballast water management options and discharge standard presented in our 2012 regulations. Over the past 5 years, the Coast Guard established the Alternate Management System (AMS) program, which allows the relatively “short term” use of about 70 foreign type approved BWMSs in U.S. waters. The AMS program was established as a bridging strategy, allowing time for those systems to be type approved by the Coast Guard, upgraded to the U.S. type approved configuration and design, or replaced with a U.S. type approved system. To date, the Coast Guard has type approved six BWMSs, with others at or nearing completion of testing.
Now that there are multiple compliance options available for the industry, the Coast Guard is focused on compliance enforcement. Just as the Coast Guard enforces the Oil Pollution Act of 1990, the Coast Guard enforces compliance with the National Invasive Species Act of 1996.
The Coast Guard will continue to work with stakeholders to ensure our compliance approach is as consistent and practical as possible. I look forward to continued dialogue between the Coast Guard and industry as we work together to reduce the threats of invasive species.
The second blog in this series will provide more detail on the Coast Guard’s focus on ballast water management compliance.
Read the other posts in our new blog series:
12/1/2017: Ballast Water Series Part 5 – Contingency planning for ballast water management
11/30/2017: Ballast Water Series Part 4 – The “plug and play” ballast water management system
11/29/2017: Ballast Water Series Part 3 – Coast Guard BWMS type approval program update
11/28/2017: Ballast Water Series Part 2 – The Coast Guard’s focus on compliance
11/27/2017: New ballast water series from Coast Guard’s assistant commandant for prevention policy
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.
Categories: Commercial Vessel Compliance