2805 South Industrial Hwy., Suite 100

Ann Arbor, Michigan 48104-6791

Office 734-971-9135 ▪ Fax 734-971-9150 ▪ glc@glc.org

EXECUTIVE DIRECTOR

Tim A. Eder

February 8, 2013

Mr. Jeffrey Zients

Deputy Director for Management

Office of Management and Budget

725 17th Street, NW

Washington, DC 20503

Ms. Nancy Sutley, Chair

White House Council on

Environmental Quality

722 Jackson Place, NW

Washington, DC 20503

Dear Deputy Director Zients and Chairwoman Sutley:

I am writing on behalf of the Great Lakes Commission to reiterate our support for 

certain ballast water provisions of the proposed National Pollutant Discharge 

Elimination System 2013 Vessel General Permit (VGP). Specifically, we urge you to 

retain the requirement that vessels entering the Great Lakes continue ballast water 

exchange or saltwater flushing in the final VGP. This practice is an important part of 

protecting the Great Lakes from damaging aquatic invasive species introduced by 

ballast water from ocean going commercial vessels.

The Great Lakes Commission is on record supporting a national standard for ballast 

water discharge that is protective of the water resources of the Great Lakes – St. 

Lawrence River region. The Commission also strongly supports maintaining a ballast 

water exchange/saltwater flushing requirement in addition to meeting numeric ballast 

water treatment limits. Ballast water exchange and salt water flushing are proven, 

effective techniques to reduce the risk of invasive species introduction from ballast 

water and should be retained to complement technology treatments designed to meet the 

International Maritime Organization (IMO) standard. Scientific research has 

demonstrated that the combined effects of tank flushing and salinity exposure are highly 

effective at eliminating potential invaders. Further, Canada has proposed that a ballast 

water exchange and saltwater flushing requirement remain in effect as part of their 

implementation of the IMO Convention. 1

Aquatic invasive species are among the most serious threats to the environmental and 

economic health of the Great Lakes. The Great Lakes states recognize and are taking 

action to address all potential pathways through which aquatic invasive species can 

enter the Great Lakes. The states remain committed to working together to harmonize 

ballast water regulations and establish regulatory consistency within our region. We 

strongly urge you to retain the ballast water exchange/saltwater flushing requirement in 

the final VGP as a key mechanism for safeguarding the Great Lakes. 

Please contact our executive director, Tim Eder (734-971-9135, teder@glc.org), should 

you have any questions or would like more information about our position.

Sincerely,

Kenneth G. Johnson

Chair

1 Transport Canada. Discussion Paper: Canadian Implementation of the Ballast Water Convention.

Oct. 26, 2012. http://www.tc.gc.ca/media/documents/marinesafety/discussion-paper-ballast-water-eng.pdf.

BOARD OF DIRECTORS

CHAIR

Kenneth G. Johnson

Administrator

Water Division

Wisconsin Department of

Natural Resources

Madison, Wisconsin

VICE CHAIR

Kelly Burch

Regional Director

Northwest Regional Office

Pennsylvania Department of 

Environmental Protection

Meadville, Pennsylvania

IMMEDIATE PAST CHAIR

James M. Tierney

Assistant Commissioner

for Water Resources

New York State Department of

Environmental Conservation

Albany, New York

Marc Miller

Director

Illinois Department of

Natural Resources

Springfield, Illinois

Kari Bennett

Commissioner

Indiana Utility Regulatory Commission

Indianapolis, Indiana

Jon W. Allan

Director

Office of the Great Lakes

Michigan Department of 

Environmental Quality

Lansing, Michigan

Thomas E. Huntley

Minnesota State Representative

Duluth, Minnesota

Joseph Martens

Commissioner

New York State Department of 

Environmental Conservation

Albany, New York

James Zehringer

Director

Ohio Department of 

Natural Resources

Columbus, Ohio

William Carr

Manager

International Relations and Policy

Office of International

Relations and Protocol

Toronto, Ontario

Eric Marquis

Québec Government Representative

Chicago, Illinois

Ensuring environmental and 

economic prosperity for the Great 

Lakes-St. Lawrence region through 

communications, policy research and 

development, and advocacy.