Fw: VGP - Vessel General Permit 

Ronna Beckmarin to: Cynthia Gaines 

Cc: Denise Gawlinski

2011 N01117 PM I: 14 11/16/2011 02:25 PM 

Ronna Beckmann 

Office of the Regional Administrator 

U.S. Environmental Protection Agency, Region 5 

312-886-0689 

Forwarded by Ronna Beckmann/R5/USEPAJUS on 11/16/2011 09:35 AM 

From:	"Lamers, Holly J - DNR <Holly.Lamers©Wisconsin.gov> 

To:	 Denise Gawlinski/R5/USEPA/US@EPA, Ronna Beckmann/R5/USEPAIUS@EPA 

Cc:	 Kluesner, Elizabeth M - DNR' <Elizabeth.Kluesner©wisconsin.gov > 

Date:	11/16/2011 08:12 AM 

Subject:	VGP - Vessel General Permit 

Good morning, Dawn and Ronna, 

Will you please route this letter to Administrator Jackson? I will be sending 

the hard copy via postal mail today as well. 

Thank you kindly, 

Holly Lamers 

Assistant to Secretary Cathy Stepp and Deputy Secretary Matt Noroney 

Wisconsin Department of Natural Resources 

(*) phone:	608-267-7556 

(*) e-mail:	Holly. Lamers@wisconsin.gov

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20111116075058671.pdf
State of Wisconsin 

DEPARTMENT OF NATURAL RESOURCES 

101 S. Webster Street 

Box 7921 

Madison WI 53707-7921

Scott Walker, Governor 

Cathy Stepp, Secretary 

Telephone 608•266-2621 

Toll Free 1-888-936-7463 

TTY Access via relay - 711 

Y1SCOHSIN 

DEPT. OF 4TURAL RESOURCES 

DArLY READIN FILE

November 15, 2011 

Honorable Lisa Jackson 

i\dmi ni strator 

U.S. Environmental Protect ion Agency 

1200 Pennsylvania Ave., NW 

Washington, DC 20460 

Dear Administrator Jackson: 

It is my understanding that later this month EPA will be re-issuing its \'essel General Permit (VGP), in which 

ballast water management on the Great Lakes will be addressed. 1 am writing to share Wisconsin's input on this 

i iiportant issue. 

For years, Wisconsin has been a leader on ballast water management on the Great Lakes. We have worked hard 

to develop conditions in our Wisconsin Pollutant Discharge Elimination System (WPDES) Ballast Water 

Discharge General Permit that are l)rotecti\'e of the Gieat Lakes resources while also practical for the shipping 

industry, and we'd like our success to continue. 

It is critical that the proposed EPA \'GP not preempt any of the important work and permit conditions that 

Wisconsin has already established, so I kind))' ask that you please consider the following recommendations and 

points. 

First, the mid-ocean Ballast Water Exchange (B WE) Best Management Practice (Bi'IP,I slw,ld be sustained in 

the VGP wit/i added treatment requirements, as a dual treatment approach would better protect the Great 

Lakes from the threat of aquatic noi:-tndigenous species. Currently, the most effective way to remove nonindigenous species from ballast water is the liMP of BWE, or saltwater flushing. This practice reduces the 

number of coastal organisms (potent al invasive threats to our waters), and continues to be effective. Research of 

Dr. Sarah Bailey, Fisheries and Oceans Canada (publication pending, Development of Guidelines and Other 

Documenis for Uniform Implementation of the 2004 BWM Convention), indicates that combining BWE with a 

ballast water treatment system is an even better way to protect the Great Lakes from the harmful aquatic 

organisms and pathogens ballast water can introduce. 

Second, BMP requirements for all Great Lakes vessels (Lakc,$) should be established in the VGP. Our 

WPDES Ballast Water Discharge General Permit has established BMP requirements for Lakers, a target group we 

know to be a primary vector in spreading aquatic non-indigenous species throughout the Great Lakes. These 

requirements have proven effective for our state and would be beneficial across the board. 

Finally, numeric standards equal to the Internah anal Maritime Organization (Ji'IiO) standard should be 

included in the VGP and imiade effecili'e immediately. lii 2010, Wisconsin reviewed documentation and expert 

opinions on ballast water treatment technologies to determine whether the WPDES Ballast Water Discharge 

General Permit treatment standards were achievable. Wisconsin requested the Gieat Lakes Ballast Water 

Collaborative to act as a technical advisory committee to make recommendations based on the combined effort of 

I PPA1TD 

c,v	yu.tO 

PAPER 

dnr.wi.gov

wsconsin,gov	 Naturally WISCONSIN
experts in the field of ballast water treatment technology. The recommendation that came from this committee 

was to set treatment standards at the IMO level because higher standards for treatment were not yet achievable. 

Previously, EPA tasked its Science Advisory Board (SAB) to address the question of whether ballast water 

treatment technology already existed, or would exist in the foreseeable future, to meet a standard greater than the 

1MO standard. In the SA_B's recently issued final report, it emphatically stated that no such technology currently 

exists. States should not be permitted to have standards more stringent than the IMO standard, as higher 

standards are technologically impossible to meet, and would possibly force closures and threaten thousands of 

maritimere1ated jobs in the Great Lakes states. 

Thank you for your consideration of these points. I look forward to working with you on this important issue. 

C:aıhy Sıepp

Sccrelil^Y

cc. Governor Scott Walker 

Members, Wisconsi ii Congressional Delegation