APPENDIX B 

STATUS AND TRENDS OF BALLAST WATER MANAGEMENT 

IN THE UNITED STATES 

FIRST BIENNIAL REPORT 

OF THE 

NATIONAL BALLAST INFORMATION CLEARINGHOUSE 

Submitted to United States Coast Guard 

16 November 2001 

G.M. Ruiz, A.W. Miller, K. Lion, B. Steves, 

A. Arnwine, E. Collinetti, E. Wells. 

Smithsonian Environmental Research Center 

 P.O. Box 28 

Edgewater, Maryland 21037 USA 

U.S. Coast Guard Technical Advisor: R. A. Everett, United States Coast Guard (GMSO-4), 2100 2nd Street, S.W., Washington, D.C. 20593 USA 

1
APPENDIX B 

LIST OF ABBREVIATIONS 

BOB Ballast On Board 

CFR Code of Federal Regulations

COTPZ Captain of the Port Zone

EEZ Exclusive Economic Zone

IMO International Maritime Organization

MARAD Maritime Administration 

MSIS U.S. Coast Guard Marine Safety Inspection Survey 

mt metric ton 

NABS National Ballast Survey 

NIS Nonindigenous Species 

NISA The National Invasive Species Act of 1996, P.L 104-332 

NOBOB No Ballast On Board 

SERC Smithsonian Environmental Research Center 

USCG United States Coast Guard 

2
APPENDIX B 

EXECUTIVE SUMMARY 

BACKGROUND

1. Biological invasions by non-native, invasive species are having significant ecological, economic, 

and human health impacts. Importantly, the rate of new invasions appears to be increasing. 

2. For coastal marine ecosystems, the ballast water of ships is known to be an important mechanism 

for the transfer of non-native species, which are entrained unintentionally at one port and released 

at another. 

3. Under the National Invasive Species Act of 1996 (NISA), Congress requires ships entering U. S. 

waters from outside the Exclusive Economic Zone (EEZ) to report ballast water management 

practices, including the retention of ballast water on board. (This reporting requirement excludes 

ships arriving to the Great Lakes ecosystem, as these are addressed separately by existing 

regulations.) 

4. NISA also requests the masters of these ships to follow a suite of voluntary ballast water 

management guidelines to reduce the risk of introducing foreign organisms to the waters of the U. 

S. via discharged ballast water. The guidelines include the following actions: 

(a) exchanging ballast water obtained from harbors or other coastal areas outside of the U.S. EEZ 

for mid-ocean water (obtained from areas at least 200 miles from any shore and with at least 

2,000 meters of depth) prior to its release in U.S. coastal waters; 

(b) retention (i.e. no discharge) of unexchanged ballast water that is derived from overseas coastal 

areas; 

(c) use of an alternative ballast water management practice determined by the U.S. Coast Guard 

to be at least as effective as ballast water exchange in preventing invasions by nonindigenous 

species. 

5. Ships are required to submit reports on ballast water management and discharge to the National 

Ballast Information Clearinghouse (hereafter Clearinghouse), a collaborative effort of the U. S. 

Coast Guard and the Smithsonian Environmental Research Center for the collection, management, 

and analysis of nationwide data on ballast water management and coastal invasions, pursuant 33 

CFR §151.2045. 

6. To determine the rate of compliance with the reporting requirement, the Clearinghouse compares 

the submitted reports with data on ship arrivals from the database of U. S. Foreign Waterborne 

Transportation Statistics maintained by the Department of Transportation’s Maritime 

Administration (MARAD). The MARAD database is composed of data collected by the U. S. 

Customs Service and the Army Corps of Engineers. 

7. To determine the rate of compliance with the voluntary ballast water management guidelines, the 

Clearinghouse analyzes the submitted data and estimates: (a) the number of vessels reporting 

discharge of ballast water according to ballast management practices (i.e., no exchange, discharge 

with some exchange, alternative treatment, or retention of ballast water) and, (b) the volume and 

proportion of discharged ballast water that underwent the various management practices. 

8. To verify the accuracy of information reported by vessels, and to further educate the shipping 

industry about ballast water management requirements and guidelines under 33 CFR §151.2045, 

the U.S. Coast Guard implemented independent Verification Surveys aboard randomly selected 

arriving vessels. These surveys were carried out as a pilot program over the past 24 months. 

3
APPENDIX B 

9. This biennial report is prepared to inform the U.S. Coast Guard, the Secretary of Transportation, 

and the U.S. Congress of the current status and trends for nationwide ballast water reporting, 

delivery, and management. 

RESULTS

A. Compliance with Reporting 

10. Nationwide compliance with reporting was low over the first 24 months (1 July 1999 – 30 June 

2001) that mandatory reporting was in effect. Only 30.4% of the vessels that entered U. S. waters 

from outside the EEZ filed reports with the Clearinghouse, as required by the U.S. Coast Guard. 

11. Compliance with reporting varied greatly among geographic regions, during the first 24 months. 

Compliance rates by region were as follows: Alaska – 20.8%; Caribbean – 16.6%; East Coast –

29.0%; Gulf Coast – 17.1%; West Coast – 66.5%; and Pacific Islands – 50.4% (calculated for 

Hawaiian ports only, as MARAD data do not include Guam). 

12. Among individual Captain of the Port Zones (COTPZs) of the U.S. Coast Guard, compliance with 

reporting ranged from 87.9% in San Francisco, California to 10.1% in Providence, Rhode Island. 

13. For the entire U.S., compliance with reporting did not improve substantially from the first year to 

the second (28.3% and 32.4%, respectively). 

14. Among the three continental U.S. coastal regions, the Gulf Coast showed the least improvement in 

reporting compliance between years (0.5%) followed by the East Coast (5.2%). 

15. On the West Coast (of the contiguous U. S.), compliance with the reporting requirement increased 

markedly (15.3%) between years, resulting primarily from an increase in California (which 

receives most ship arrivals). This increase was coincident with implementation of California state 

law, requiring submission of copies of the federal ballast water management reports to the State 

Lands Commission and authorizing monetary and criminal penalties for noncompliance. 

B. Compliance with Voluntary Guidelines 

16. Due to the poor nationwide reporting rate (30.4%), it remains difficult to estimate reliably the 

temporal and geographic patterns for (a) ballast water delivery and (b) use of the voluntary ballast 

water management practices. 

17. Despite current low nationwide reporting, the National Ballast Survey and the Clearinghouse 

database were designed explicitly to provide fine-grained information on patterns of ballast water 

management and delivery by geographic location (port, coast, traffic pattern), time (month, year, 

and across years) and vessel type. Thus, the system is in place to evaluate and track management 

patterns across the country. 

18. Here, we report some coarse patterns of ballast water management that emerge from the limited 

reports to date. However, as reporting rates rise and concomitant uncertainty diminishes, the 

NABS database will better describe the behavior of commercial vessels arriving to the U.S. 

19. Of the 28,988 foreign arrivals that submitted reports from 1 July 1999 to 30 June 2001, 73.6% 

indicated no intention to discharge ballast water within U. S. territory, 12.9% declared no 

exchange of ballast water prior to discharge, and 13.0% of the reporting vessels declared some 

degree of ballast water exchange prior to discharge. 

4
APPENDIX B 

20. Thus, of the 7,652 vessels that reported discharge of ballast water in U.S. waters, about half 

(51.2%) indicated some degree of mid-ocean exchange and 48.8% indicated discharge with no 

prior exchange. 

21. Nationwide, approximately 29.7% (11.1 million metric tons, or mt) of the ballast water from 

foreign arrivals was reported as discharged into the U. S. without undergoing any exchange. 

22. Of the vessels that reported no intent to discharge ballast water upon arrival, most carried ballast 

water. Only 12.8% (3,712 of 21,336 vessels) was reported as No Ballast on Board, or NOBOB. 

 

23. Compliance with the voluntary guidelines varied greatly among regions. For the West Coast, 

most ships that discharged ballast reported it had undergone exchange (72.3% of ships), and most 

ballast water discharged was reported to have undergone some exchange (85.2% of the total 

volume). In contrast, on the East Coast, most ships (70.4%) that discharged ballast water reported 

they had not undertaken exchange, although most of the discharged ballast water had reportedly 

undergone some exchange (53.3% of total volume). 

24. Compliance with voluntary guidelines also varied considerably by port system, or COPTZ. For 

example: Portland, Oregon received the highest volume of ballast water, (6.60 million mt) of 

which 91.5% underwent some degree of mid-ocean exchange prior to discharge; Juneau, Alaska 

had the highest percent of reported discharged ballast water that had undergone some exchange 

(98.1% of 113,050 mt); and Portland, Maine had the lowest percent of reported discharge that had 

undergone any exchange (0% of 17,559 mt). 

25. Analysis of the locations reported for completion of ballast exchange, using a geographic 

information system, indicates a significant proportion of the reported exchange occurred in coastal 

areas (< 200 mi offshore), rather than mid-ocean as requested. 

C. Verification Surveys 

26. The U.S. Coast Guard pilot program for Verification Surveys is currently being evaluated, to 

explore the best options to verify accuracy of reporting. The pilot program tested the feasibility of 

a stratified, random survey that was implemented by U.S. Coast Guard across all 30 COPTZs in 

the country. The pending analyses will be used to examine both opportunities and constraints 

associated with ship arrival schedules, availability of personnel for verification, and specific 

methods. 

CONCLUSIONS

27. Nationwide compliance with the mandatory reporting requirement remains low (34.7% for the 

month of June 2001, and 30.4% for the cumulative two year period) and exhibits no marked 

improvement over the last 12 months. 

28. On the West Coast, compliance with reporting increased over the first 12 months to approximately 

75%, coinciding with initiation of state regulations in California that (a) impose penalties for noncompliance and (b) include an active boarding program that targets 20-30% of arrivals. 

Compliance has increased between the first and second year for California, as well as Washington 

and Oregon (which have also passed state regulations). 

29. Despite increased reporting on the West Coast, this represents only a small fraction (14%) of the 

nationwide ship arrivals from outside of the EEZ, and reporting did not increase appreciably along 

the Gulf Coast and East Coast (38% and 30% of all arrivals, respectively). 

5
APPENDIX B 

30. At the present rate of improvement for reporting, full compliance with reporting will not occur for 

decades. 

31. Many vessels that discharge ballast water in the U.S. are not implementing the voluntary ballast 

water management guidelines, based upon their reports. However, we cannot estimate accurately 

the full extent of non-compliance with ballast management guidelines due the very low rate of 

reporting by foreign arrivals to the U.S. 

RECOMMENDATIONS

32. There exist currently numerous impediments preventing accurate measurement of the patterns of 

ballast water delivery and management in the U.S. Each of these should be the focus of specific 

action(s) by the U.S. Coast Guard to improve the current national assessment. Only with accurate 

estimates for ballast water discharge and management patterns can the U.S. Coast Guard (a) assess 

the effectiveness of regulations in changing ballast water management and (b) identify geographic 

areas, vessel traffic, or industry sectors for enhanced efforts, including education, to prevent 

introductions via ballast water. 

33. Of paramount importance, reporting must be improved to characterize the ballast water 

management of all vessels arriving to the U.S. ports. This can be accomplished by one of two 

methods: (a) complete compliance with mandatory reporting by all vessel arrivals or (b) complete 

reporting by a representative sample of all vessels that results from a carefully designed stratified, 

random sampling program. The former approach is preferable, as it would yield the highest 

quality and quantity of data. 

34. The ballast water reporting requirement should be extended to include coastwise ship 

traffic, and ships should report ballast water management activities for all ports visited. We 

believe there remains confusion about which vessels should report, and when they should report 

on ballast water management. Comprehensive (foreign and coastwise) reporting would remove 

any uncertainty about which traffic should report, improve overall data quality, and address 

important gaps in the current program: 

• Many ships enter the U.S. from outside of the EEZ and move coastwise. Although such 

traffic is meant to report the fate of any ballast water discharged in U.S. waters after entry, 

under the current reporting requirement, we believe many ships report discharge only for the 

first port of entry. 

• The transfer of coastal water itself is an important issue, resulting in discharge of large 

volumes at many ports (e.g., Valdez, Alaska and Chesapeake Bay), and can lead to unwanted 

biological invasions. Inadequate data exist currently about management and delivery of 

ballast water that originates within the U.S. (e.g., San Francisco Bay to Chesapeake Bay, 

Chesapeake Bay to New Orleans) upon which to make management and policy decisions. 

• The use of NOBOB (i.e., relatively empty) tanks for ballast operations upon arrival to the U.S 

can result in the discharge of residual organisms from foreign sources that could result in new 

invasions. The use and management of these tanks, comprising 38.9% of all ballast tanks for 

reporting ships, is not addressed in the current program. However, reporting at each port 

(with the current form) would measure the extent, pattern, and potential importance of this 

practice. 

35. Additional information is required from each ship to better measure ballast water 

management. Specifically, the capacity of each ballast tank is needed for the Clearinghouse to 

calculate directly the percent ballast water exchange, which is erroneous (and therefore unusable) 

on many ships’ reports. In addition, instructions for the reporting form could be improved to 

illustrate how to prevent common errors associated with reporting of data for ballast water volume 

and exchange. 

6
APPENDIX B 

36. There remains a need for implementation of Verification Surveys, which are designed 

specifically to verify the accuracy of reporting by vessels. Verification Surveys should be 

implemented, using a stratified, random sampling design across the entire country or at selected 

key ports. This approach is necessary to address accuracy for different geographic regions and 

vessel types over time. 

37. Fully implement use of the revised U.S. Coast Guard vessel tracking system (MSIS), to 

create a comprehensive database of key information for all vessel arrivals to each port. The 

previous version of MSIS did not include standardized information on last port of call, restricting 

its utility for analyses by the Clearinghouse, and MARAD’s data had significant gaps in some 

regions. 

38. To the maximum extent possible, encourage electronic submission of ballast water reporting 

by vessels. This would serve to increase accuracy of data and reduce the time needed to make 

resulting data available. Further, electronic submission would reduce the effort required by the 

shipping industry. 

7
APPENDIX B 

INTRODUCTION 

Biological invasions are fundamentally changing the structure and function of the earth’s 

ecosystems. Invasions result from the transfer and establishment of species outside of 

their historical range. The extent of invasions has become increasingly clear over the 

past decade, and many communities are now dominated by invading or nonindigenous 

species (NIS) in terms of number of organisms, biomass, and ecological processes. At 

the present time, it is clear that invasions have caused dramatic shifts in food webs, 

chemical cycling, disease outbreaks, and extinction rates. 

There is now great public concern about invasions, driven in large part by observed 

ecological effects as well as economic impacts, such as crop and fishery losses, 

associated with invasions. For example, recent estimates suggest the economic impacts 

of NIS in the U.S. alone exceed $100 billion per year. Although the impacts of most 

invasions remain unexplored, there is no doubt that biological invasions have become a 

major force of ecological change, as well as economic and human health impacts, 

operating on a global scale. 

Recent studies suggest that invasion rates are continuing to increase. For example, the 

rate of known marine invasions in North America has increased exponentially over the 

past two hundred years. Furthermore, this pattern appears very robust across various 

habitats, taxonomic groups, and global regions. This apparent increase in invasion rate, 

combined with significant impacts, has further elevated public and scientific concerns 

about invasions in recent years. 

In response to the increasing number of invasions, management strategies and policies 

are being advanced at state, regional, national and international levels. For example, the 

U.S. Congress has enacted two laws since 1990, and President Clinton signed an 

Executive Order, to limit the rate and impact of invasions. The Convention on Biological 

Diversity recognizes biological invasions as a significant threat to biological diversity 

and is exploring approaches to reduce this threat. Furthermore, many state and local 

policies are being implemented within the U.S. and elsewhere. Much of this response has 

focused on steps to prevent future invasions, with some additional effort focused on 

control and management of established invasions. 

In coastal marine ecosystems, commercial shipping is considered to be the largest single 

transfer mechanism, or vector, for NIS. Historically, species have been transferred 

unintentionally on the hulls and in ballast of ships, resulting in hundreds to thousands of 

invasions worldwide. Today, ballast water of ships appears to be the leading source of 

invasions for coastal habitats in the U.S. and elsewhere. Ballast water is clean water 

taken on in one port, used for stability and trim during voyages, and discharged to various 

extents at future ports of call. In 1991, the U.S. alone received >70 million metric tons of 

ballast water from foreign ports. The use of ballast water by ships results unintentionally 

in the entrainment and dispersal of species around the globe. 

8
APPENDIX B 

To reduce the risk of invasions associated with ballast water, vessel masters are being 

asked to manage their ships’ ballast water, using practices that prevent the transport of 

organisms. The International Maritime Organization (IMO) has issued voluntary 

guidelines, including the use of open-ocean ballast water exchange, to limit transfer of 

coastal organisms in ballast water. In essence, ships are asked to flush out their ballast 

tanks at sea, reducing the concentration of coastal organisms, which have the greatest 

chance of becoming established at future ports of call. Many member countries have 

requested or required ships to comply with these guidelines. In addition, alternative 

treatment methods are at various stages of development and testing throughout the world. 

The U.S. Congress has passed two laws that include guidelines and regulations for 

management of ships’ ballast water. Here, we report on the status and trends of ballast 

water management, as directed by the most recent of these laws. 

National Ballast Information Clearinghouse 

The National Invasive Species Act of 1996 (NISA) directed the United States Coast 

Guard (USCG) in conjunction with the Smithsonian Environmental Research Center 

(SERC) to develop a National Ballast Information Clearinghouse (hereafter 

Clearinghouse). The Clearinghouse, located at SERC, plays a central role in the 

organization and analysis of national data concerning the transfer and invasion of 

nonindigenous species associated with the ballast water of ships. 

Under NISA, Congress directed the Secretary of Transportation to promulgate 

regulations that (a) require vessel masters to report their ballast management practices 

when entering U. S. waters from beyond the 200 mile Exclusive Economic Zone (EEZ), 

and (b) describe a suite of voluntary ballast water management practices for use by such 

vessels. The voluntary guidelines include holding ballast water on board and open-ocean 

exchange (flushing) of ballast tanks that will be discharged in U.S. waters. The 

management practices are intended both to minimize the transfer of NIS in ballast water 

of ships and to reduce the risk of exotic species invasions associated with the release of 

ballast water. 

A key element of NISA involves tracking the effectiveness of voluntary guidelines, as 

measured by (a) the level of compliance with voluntary guidelines, (b) changes in the rate 

and patterns of ballast water delivery, and (c) reduction in the rate of ballast-mediated 

invasions. The Clearinghouse was created to provide these analyses on a national scale. 

National Ballast Survey 

The Clearinghouse and the USCG have implemented the National Ballast Survey 

(NABS), to measure ballast water management and delivery patterns for commercial 

vessels that arrive to U.S. ports from outside the nation’s EEZ. 

9
APPENDIX B 

The NABS was designed explicitly to create a national database on ballast water to be 

used to measure: (1) rates of compliance with the ballast water reporting requirement; (2) 

rates of compliance with the voluntary management guidelines for holding or exchanging 

ballast water; (3) patterns of ballast water delivery and management (including exchange) 

according to vessel class for geographic region and season of arrival; (4) among-year 

changes in ballast water management by vessel class and geographic region; and (5) 

accuracy of data through use of multiple, independent data sources. 

The NABS relies on three primary sources of data. These include: 

1. Ballast water information reported directly to the Clearinghouse by arriving vessels; 

2. Foreign waterborne Transportation statistics collected by the U.S. Customs Service 

and the U.S. Army Corps of Engineers. The Department of Transportation’s Maritime 

Administration (MARAD) compiles these data on vessel arrivals to U.S. ports. For 

selected port systems where MARAD data were incomplete, Maritime Exchange data 

were required. 

3. Verification surveys of vessels, arriving from outside the EEZ, conducted nationwide 

by the USCG. 

Each of the data sets serves a specific and important function in the NABS. Use of these 

data can be viewed as a step-wise process: 

• The ship-generated reports (data source 1, above) were intended to create a large, 

comprehensive data set that includes ballast water history for most vessels arriving to 

each U.S. port from outside of the EEZ. 

• The MARAD data of arrivals at each port can identify all vessels, arriving from 

outside the EEZ, that are missing in the first data set, providing a measure of underreporting and thus of compliance with NISA’s mandatory reporting requirement. 

• The Verification Survey is meant to provide “ground-truthing” for a subset of all

arrivals to (1) estimate the accuracy of the first data set and (2) make statistical 

comparisons of ballast delivery patterns by vessel class, geographic region, and size. 

Figure 1 summarizes the functional aspects of the National Ballast Survey. Data are 

submitted to the Clearinghouse from the multiple sources and entered into a relational 

database. The database is then queried, and the results are used to describe ship arrival 

and ballast water management patterns. Every two years, a biennial report of these 

patterns is to be submitted to the U.S. Coast Guard and Secretary of Transportation, and 

is used inform the U.S. Congress on implementation of NISA. 

Other Clearinghouse Components: Marine Invasions Database and Research Directory

The NABS is only one component of the Clearinghouse. The Clearinghouse functions 

more generally as a centralized source of national information on marine invasions and 

on ballast water invasions issues. The following areas are being actively pursued. 

• The National Ballast Survey (NABS) - Measurement of spatial and temporal patterns 

of ballast delivery / management for the U.S.; 

10
APPENDIX B 

• The National Marine and Estuarine Invasions Database - Measurement of patterns 

and rates of coastal marine invasions for the U.S.; 

• Regional databases on invasion ecology – Characterization of patterns and rates of 

invasion for selected bays and estuaries (e.g., Chesapeake Bay, San Francisco Bay, 

Puget Sound, Tampa Bay, Prince William Sound, Coos Bay, etc.). 

• The Aquatic Invasions Research Directory - Creation of an internet-based, searchable 

database containing regularly updated international information on people, research, 

technology, policy, and management issues relevant to ballast water and aquatic 

invasions. 

• The Ballast Water Exchange Verification Project Testing and development of in-situ

and laboratory-based technologies for improved verification of ballast water 

exchange. 

Purpose of Biennial Report 

The overall goal of this report is to assess (a) compliance with the ballast water reporting 

requirement and (b) implementation of voluntary guidelines for ballast water 

management for the first two-year reporting period of NABS (1 July 1999 – 30 June 

2001). The biennial report is meant to inform the U.S. Coast Guard, the Secretary of 

Transportation, and the U.S. Congress of the current status and trends for nationwide 

ballast water management and delivery. In addition, the report also provides conclusions 

about the overall implementation of the national program and recommendations to 

address critical gaps that currently exist. 

APPROACH: ASSESSING COMPLIANCE 

Compliance with Ballast Water Reporting 

Compliance with the reporting requirement, and compliance with the voluntary 

guidelines, were assessed at three different geographic scales: national, regional (major 

coasts), and local port system (U.S. Coast Guard Captain of the Port Zone, COTPZ; 

Figure 2). Prior to all analyses, data received by the Clearinghouse underwent standard 

protocols to detect and remove erroneous records, including duplicate reports and 

numerical outliers beyond the realm of possibility. Further information on these 

procedures is available upon request. 

Figure 3 defines which traffic patterns were included in the present analyses by NABS, 

illustrating (a) the variety of different shipping routes a vessel might follow before 

arriving at a U.S. or Canadian port and (b) which ones were included when estimating 

compliance with mandatory reporting requirements, as outlined in NISA. The following 

rules were applied to differentiate “foreign” arrivals (those included in the analyses) from 

“domestic” or “coastwise” arrivals (those excluded), under direction by the U.S. Coast 

Guard: 

11
APPENDIX B 

(1) All arrivals to the Pacific coast, Atlantic coast or Gulf of Mexico coast from countries 

other than the United States or Canada are designated as “foreign” arrivals. 

(2) Arrivals to or from U.S. island states or protectorates (e.g., Hawaii, Guam, and 

Puerto Rico) to or from any of the three mainland coasts are considered “foreign” 

arrivals since they depart the EEZ during transit. 

(3) Vessels that leave the Pacific coast of North America, traverse the Panama Canal, and 

arrive at the Atlantic or Gulf of Mexico coasts (and vice versa) are deemed “foreign” 

arrivals. 

(4) Since there are no available records to verify whether a coast-wise transit leaves the 

EEZ, all within coast transits, as well as those between the Atlantic and Gulf coasts 

were categorized as “domestic” arrivals. 

(5) For inter-island passage, only vessels that transited from a foreign country’s island to 

a U.S. state or protectorate were considered “foreign” arrivals. 

(6) Arrivals to the Great Lakes are excluded from the present analysis. These vessels are 

required to undertake ballast water exchange, and a separate program of the U.S. 

Coast Guard evaluates compliance for these vessels. 

The analysis of compliance with reporting requires knowledge of actual arrivals, allowing 

the detection of non-reporting ships. For this analysis, we relied upon arrivals data from 

the Maritime Administration. To validate use of these data, we compared their quality to 

that of other sources of arrival information. Below, we present briefly the results of this 

comparison, providing a strong rationale for use of the Maritime Administration data. 

Sources of Data on Vessel Arrivals

The Department of Transportation’s Maritime Administration (MARAD) compiles vessel 

arrival data that are collected by the U. S. Customs Service and the U. S. Army Corps of 

Engineers. To evaluate the completeness and utility of MARAD’s vessel arrival 

information, comparisons were made with two other databases 1) USCG Port State 

Control data from Advance Notice of Arrivals submitted to the COTPZs (creating the 

USCG or MSIS database) and 2) Maritime Exchange data from selected port systems 

(Baltimore, Boston, and San Francisco). 

Comparison Between USCG and MARAD Databases

For 1998, the total number of vessel arrival reports recorded by the USCG was 85,319. 

Removal of all records listed as “Not Arrived-No Action Scheduled” reduced the number 

to 64,129 arrivals for the entire United States. For the same year, MARAD reported 

92,379 total vessel arrivals. Removal from the MARAD data of vessels smaller than 300 

gross tons, to reflect the same vessel sizes as targeted by the USCG, resulted in a total of 

71,226 arrivals. The overall agreement between the two data sets (64,129 vs. 71,226) is 

good, with a difference of just 10%. 

12
APPENDIX B 

The MARAD data set includes standardized identification of “Last Port of Call” and 

“Arrival Port”, data that are essential for tracking shipping patterns for the purposes of 

the NABS, but which are not consistently entered in the USCG database. The MARAD 

database thus divides vessel traffic into “Foreign” and “Domestic” arrivals, while there is 

no easy and reliable way to distinguish foreign from domestic arrivals using the USCG 

database. With the exception of mainland to island and island to mainland transits, all 

U.S. to Canada and Canada to U.S. arrivals outside the Great Lakes were designated as 

“domestic” arrivals in accordance with rules applied to ballast water reports as described 

in Introduction. 

Comparison of MARAD and Maritime Exchange Data

To further test the completeness of the MARAD database, MARAD data were compared 

with data compiled by the independent Maritime Exchanges of Baltimore, Boston, and 

San Francisco (Table 1). In general, the agreement between the MARAD and Maritime 

Exchange estimates of the number of vessels arriving from foreign ports was quite good. 

For the Port of Baltimore, the data for 1997 and 1998 show nearly identical results. In 

the comparison with Maritime Exchange data for Boston and San Francisco between 

1995 and 1997, MARAD reported somewhat higher numbers of foreign arrivals. 

According to MARAD, vessel arrival data have become increasingly more accurate since 

1997 (e.g., many fewer “unknown” entries for the ship type data field). The average 

number of MARAD reports deviated from Maritime Exchange data across all three ports 

by less than 9.6%. It is not clear how the quality of reporting varies between individual 

Maritime Exchange offices. 

Selection of MARAD Data as the Baseline for Determining Reporting Compliance 

The close agreement between the Maritime Exchange and MARAD data for foreign 

arrivals indicates that the MARAD “foreign arrival” designation is probably a close 

approximation of the vessel traffic that actually arrives from outside the EEZ. Moreover, 

the minor differences in total vessel arrivals reported by MARAD and the USCG further 

suggest that MARAD provides a good overall estimate of total ship arrivals to the U. S. 

When the extent of reporting, information content, and ease of accessibility were 

compared for MARAD, USCG, and Maritime Exchange databases, the MARAD 

database was deemed the most serviceable for use in the National Ballast Survey. 

Constraints with MARAD Data and Adjustments

Although MARAD data were generally very good throughout the country, they were not 

available for a limited number of ports or limited time periods. This was especially 

problematic for Alaska, Hawaii, and Guam. To preclude over-estimation of reporting 

rates, the corresponding ballast water reporting forms were excluded from regional and 

national estimates of reporting compliance for particular months for Alaska and Hawaii 

13
APPENDIX B 

(so indicated in figures), and compliance with reporting simply could not be estimated for 

Guam during this period. 

For a few other ports, we were able to obtain arrivals data that were missing from 

MARAD through Maritime Exchanges. Specifically, we obtained arrivals for two 

months each in Los Angeles and New York from the local sources. In addition, we 

obtained and used data from local sources to correct inconsistencies (i.e., missing data) 

within the MARAD data for San Francisco Bay. (Note: While the Maritime Exchanges 

can provide very useful and high quality data, it is important to recognize that their 

geographic scope is often limited to a particular port system, and many regions of the 

country simply do not have these or other local entities that comprehensively track vessel 

arrivals.) 

Compliance with Voluntary Exchange Guidelines 

Although some gaps in the MARAD data limited use of all data in measuring compliance 

with mandatory reporting, all submitted ballast water reporting forms were used to 

determine the extent to which voluntary ballast water management guidelines were 

followed. 

RESULTS 

Compliance with Ballast Water Reporting Requirement 

1. Nationwide Vessel Traffic. 

The extent of vessel traffic to the U.S. as measured by the cumulative number of foreign 

MARAD arrivals, varied considerably among coastal regions (Fig. 4). The East Coast 

and Gulf Coast led the nation in foreign arrivals, accounting for 38% and 30% 

(respectively) of the 95,471 arrivals from 1 July 1999 to 30 June 2001. The West Coast 

represented only 14% of total arrivals, the Caribbean accounted for 16% of arrivals, 

whereas Alaska and Hawaii combined received only 2% of the traffic. 

2. Nationwide Compliance. 

The nationwide compliance with required ballast water reporting was 30.4% for the 

period 1 July 1999 to 30 June 2001 (Table 2). The Clearinghouse received 13,266 reports 

during year 1 and 15,722 during year 2, representing 28.3% and 32.4% compliance 

(respectively). Thus, less than 1/3 of all vessels required to report ballast water 

management information upon entry to the United States met this requirement, and there 

was relatively little improvement between years. When examined on a monthly basis 

(Figure 5), nationwide reporting rates also show a very slow increase in reporting 

compliance over the 24 months, occurring mostly in January 2000 (as discussed below). 

14
APPENDIX B 

3. Regional Compliance. 

Among the major mainland coasts, the West Coast (made up of California, Oregon, and 

Washington) had the highest regional compliance with the reporting requirement for the 

two-year period: 66.5% of arrivals submitted reports (Figure 6a, Table 2). In contrast, 

compliance with reporting was only 29.0% for the East Coast and 17.1% for the Gulf 

Coast during the same period. Hawaii, Alaska, and the Caribbean had 50.4%, 20.8%, 

16.6% compliance respectively (Fig. 6b, Table 2). 

The rate of compliance for each coast increased from year 1 to year 2 (Fig.6a,b; Table 2), 

except for the Caribbean, which experienced decreased compliance (-3.7%). The West 

Coast had the greatest net increase (15.3%). The net increases for the remaining coastal 

regions were: Alaska (14.9%), Hawaii (7.9%), East Coast (5.2%), and the Gulf Coast 

(0.5%). 

Monthly reporting rates for each coast also reflected the same patterns over time, 

showing the greatest improvement for the West Coast (Figs. 6a,b). To better 

characterize changes in reporting over time, we used linear regressions to measure the 

rate of change in reporting for the three major coasts, allowing us to estimate the number 

of years required for each coast to reach 100% compliance. The projected time periods 

necessary for complete compliance by mainland coasts were: 3.3 years on the West Coast 

(y=1.27x+50.7, r2

=0.56), 14.8 years on the East Coast (y=0.43x+23.6, r2=0.79), and 58.3 

years on the Gulf Coast (y=0.12x+15.6, r2=0.18). 

Although the overall performance for the West Coast, and the projected time to complete 

reporting is encouraging, this represents only a small amount (14%) of the total 

nationwide traffic. Most arrivals occur on the East and Gulf Coasts, for which reporting 

compliance lagged behind the West Coast and show only slight improvement over the 

past 24 months. 

4. COTPZ Compliance 

As with the nation and most regions, compliance with the reporting requirement was 

highly variable among COTPZs (Table 2). Reporting for COTPZs ranged from 10.1% to 

87.9%, equaling or exceeding 50% in only 6 cases: San Francisco, Los Angeles, Seattle, 

Portland (OR), Honolulu, and Valdez. The relative high reporting and compliance rates 

for San Francisco and Los Angeles COTPZs may result from state law requiring ballast 

water reporting and authorizing penalties for noncompliance, effective as of 1 January 

2000. It is noteworthy that compliance with reporting was relatively high (38-46%) in 

California at the start of NABS, compared to the other western states. This may have 

resulted from increased attention and the passage in October 1999 of a state law with the 

pending threat of penalty; furthermore, compliance increased markedly in January, when 

the law went into effect and penalties were possible for failure to report. 

The high compliance of the Seattle COTPZ zone (64.5%) and Portland COTPZ (50.3%) 

may also result from state legislative activity. Washington State passed a law 

15
APPENDIX B 

concerning ballast water that went into effect in 2001, and Oregon just recently passed a 

similar measure. In addition, relatively high compliance in Valdez (50.0%) may be 

associated with a targeted federal law requiring ballast water exchange for oil tankers in 

that port, as the number of arrivals recorded by MARAD was low and tankers comprised 

a relatively large fraction of the total for this period. However, MARAD reporting in 

Alaska was incomplete in the first three months of 2001, possibly influencing the 

compliance rates measured there. 

Interestingly, compliance remains low in Maryland (34.8% in year 2), which passed a 

similar state law, but has not yet begun to impose penalties for failure to report. It will be 

instructive to examine compliance over time for states that implement state ballast water 

laws, particularly during the time periods surrounding the initiation of penalties for 

failure to report. 

Compliance with Voluntary Exchange Guidelines 

Under 33 CFR §151.2045, vessel masters were required to report specific information for 

discharged ballast water originating outside of the EEZ, including (a) whether or not 

ballast water was exchanged or otherwise treated, and (b) specific details of ballast water 

management on a per-tank basis, providing the volume, exchange method, and calculated 

percent of water exchanged. There are thus two possible measures for the rate of 

implementation of the voluntary guidelines for ballast water management operations. 

First, implementation of guidelines can be evaluated as the proportion of arriving vessels 

reporting exchange of all water discharged, or compliance on a per capita (ship) basis. 

Since the guidelines include retention of unexchanged or untreated ballast water, vessels 

that hold ballast water on board are considered to be in compliance with the voluntary 

guidelines. Second, implementation can be evaluated as the proportion of discharged 

ballast water by volume (across all ships) reported to have been exchanged, or the overall 

effect on the discharge of treated versus untreated ballast water (across the aggregate of 

reporting vessels). 

The voluntary guidelines (33 CFR §151.2035(b)) request that vessel masters carrying 

ballast water into the waters of the U. S. after operating beyond the EEZ employ at least 

one of a suite of ballast water management practices. These include exchanging ballast 

water in areas at least 200 miles from any shore and at least 2,000 meters deep, or in an 

alternative ballast exchange zone approved by the COPTZ; retaining ballast water on 

board; using an alternative environmentally sound, USCG approved method of treatment; 

or discharging ballast water to an approved reception facility. Exchange, under 33 CFR 

§151.2025, includes flow-through exchange, in which three full volumes of open-ocean 

water are pumped through a ballast tank, and empty-refill exchange, in which a ballast 

tank is emptied completely and then refilled with mid-ocean water. Thus, for exchanged 

ballast water, full compliance with these voluntary guidelines includes water that has 

been exchanged 100% (one full tank volume) by empty-refill or 300% (three full tank 

volumes) by flow-through methods, or otherwise treated, or retained on board. 

16
APPENDIX B 

Although the Clearinghouse database was designed explicitly to measure percent 

exchange and exchange method for each tank (per vessel), examination of the ballast 

water management reports submitted by vessels revealed many errors in the ships’ 

reports. It appears that widespread confusion existed among ships crews regarding how 

to determine and report the percent of water exchanged. Furthermore, many reports did 

not indicate (as requested) whether the performed exchange was empty-refill or flowthrough. Consequently, it was often not possible to determine whether a reported 

complete exchange was accomplished by pumping one or three full volumes of openocean water through a tank, or the method of exchange employed. Therefore, for 

discharging vessels, the extent of exchange was categorized as “Discharge with No 

Exchange”, “Discharge with Some Exchange” and “Discharge with Unknown Exchange” 

(see below for further discussion of limitations to precise calculation and reporting of 

percent exchange). 

Caution: Ideally, with a high level of reporting, the ballast water management reports 

submitted by vessels could be used to estimate the amount of treated and untreated 

(exchanged or otherwise) water discharged in the U. S. However, compliance with the 

reporting requirement was so low, only 30.4%, that reporting vessels cannot be 

considered representative of the larger population of all arriving ships entering U. S. 

waters. 

Compliance with Voluntary Guidelines by Ship

1. National Compliance 

Most (73.6%) of the reporting vessels indicated no intention to discharge ballast water 

(Tables 3a,b). Of the 28,988 vessels filing reports, only 7,652, or 26.4%, declared 

discharge of foreign ballast water within U. S. territory: 12.9% declared that no exchange 

had been conducted, while 13.0% of the reporting vessels declared some exchange (and 

the residual did not specify). Therefore, of the vessels that reported, 86.6% indicated 

they had followed the voluntary guidelines, either through retaining ballast water on 

board or by exchanging ballast water prior to discharge. 

Although most reporting vessels did not discharge ballast water, it is noteworthy that of 

the 7,652 vessels that did report an intention to discharge, only about one half of these 

vessels reported some mid-ocean exchange prior to ballast water discharge. This pattern 

remained relatively constant throughout the 2 year of reporting (Fig. 7). 

2. Regional Compliance 

By region, the percent of reporting vessels that declared no discharge varied from 90.6% 

in Hawaii (89.7% for the Pacific Islands if Guam is included) to 21.0% in Alaska (Tables 

3a,b). 

17
APPENDIX B 

The West Coast reported the highest proportion of discharging vessels that underwent 

some exchange (73.9%) and the Caribbean reported the lowest proportion (20.3%), 

whereas the East and Gulf Coasts were intermediate (26.5% and 49.9% respectively; Fig. 

8). 

3. COTPZ Compliance 

At the Captain of the Port Zone level, Los Angeles received the greatest percentage of the 

nation’s ballast water reporting forms (6,099 forms, 21.0% of total) between 1 July 1999 

and 30 June 2001. Miami received 3,878 forms (13.4%), and San Juan, Puerto Rico 

received 1,896 forms (6.5%). In Los Angeles 1,454 vessels reported discharge, of which 

36.6% had no mid-ocean exchange and 61.6% had some exchange prior to discharge. 

This pattern was reversed in Miami (1,533 discharging vessels, 84.3% with no exchange, 

15.1% with some exchange) and San Juan (433 discharging vessels, 79.4% with no 

exchange, 20.3% with some exchange) (Tables 3a, 3b). These results indicate very 

different ballast management practices and discharge patterns among the COTPZs that 

receive the greatest number of foreign arrivals. 

Compliance Based on Percent Exchange by Volume

While the preceding approach provides an assessment of compliance on the basis of 

individual ships, from a biological perspective an important compliance measure is the 

proportion of discharged water that was exchanged. The ballast water reports submitted 

by vessels identify, on a per tank basis, the percent exchange accomplished for each tank 

discharged. However, it is clear from the ballast water reporting forms submitted that 

there is widespread confusion on how percent exchange is calculated and reported, 

despite detailed published instructions. Additionally, the current ballast water reporting 

form does not require that the capacity of all discharged ballast tanks be specified, 

precluding a crosscheck of reported percent exchange values. These constraints limited 

the resolution at which ballast water exchange could be analyzed and necessitated that 

ballast water exchange be categorized as “Discharge with No Exchange”, “Discharge 

with Some Exchange”, or “Discharge with Unknown Exchange”. 

1. Nationwide Compliance 

Approximately 37.3 million metric tons (mt) of discharged ballast water was reported 

nationally (Table 4). Of this total, 25.6 million mt (68.7%) was reported to have 

undergone exchange, and 11.1 million mt (29.7 %) was reported as unexchanged (Table 

4). Reported ballast water management practices and discharge patterns were relatively 

constant during the first 24 months of the mandatory reporting period (Fig. 9). 

2. Regional Compliance 

As with exchange practices on a per ship basis, the percent of the discharged volume that 

had undergone some exchange varied across the major regions (Fig. 10, Table 4). By 

18
APPENDIX B 

volume, the region with the highest proportion of discharged volume that underwent 

some degree of exchange was the West Coast. The lowest volumetric proportion of 

discharge that underwent some exchange was in Alaska (Fig. 10). 

3. COTPZ Compliance 

There were four COTPZs that reported discharging greater than 1 million mt tons of nonexchanged water: Anchorage (1.89 million mt), Los Angeles (1.33 million mt), Houston 

(1.19 million mt), and Miami (1.05 million mt). This non-exchanged ballast water 

discharge made up the majority of all discharge in Miami (88.4%), Anchorage (79.3%), 

and Houston (50.6%) (Table 4). Conversely, seven COTPZs discharged more than 1 

million mt of ballast water that had undergone some degree of exchange. These COTPZs 

were: Portland, Oregon (5.62 million mt, 91.5% of discharge), Los Angeles (4.71 million 

mt, 76.9% of discharge), New Orleans (3.15 million mt, 77.7% of discharge), Seattle 

(2.59 million mt, 89.1% of discharge), San Francisco (1.81 million mt, 85.8% of 

discharge), Hampton Roads, Virginia (1.34 million mt, 76.7% of discharge), and Houston 

(1.10 million mt, 46.9% of discharge). Juneau, Alaska, and Wilmington, North Carolina 

had the highest percentages of discharged ballast water reported to have undergone some 

exchange (110,873 mt, 98.1% of discharge and 294,633 mt, 92.2% of the discharge, 

respectively). Conversely, over 90% of the ballast water discharged into Portland, Maine 

and Jacksonville had not undergone any exchange at all. 

Reasons for Not Conducting a Mid-Ocean Exchange

If a ballast water exchange was not performed prior to discharge, ships’ masters were 

asked to provide the reason(s), on the ballast water reporting form. The open-ended 

nature of the question resulted in a large number of unique responses, complicating an 

analysis of the reasons for not exchanging ballast water. However, pooling the responses 

by loose categories (Table 5) suggests that an overt concern for the safety of the vessel 

and crew was not the over-riding reason for the low rate of ballast water exchange. Of 

the 1,208 vessels that reported discharging ballast water without exchanging, only 56 

vessels or 4.6% of the vessels cited “safety”, or some variant of the term or phrase as a 

reason for not conducting an exchange. A frequent reason cited for not conducting 

ballast water exchange was that the ship’s itinerary precluded such an operation. In many 

such cases, there may have been an insufficient period of time during the voyage to 

conduct a complete exchange, either because the voyage was too short to permit an 

exchange, or the ship’s route did not include areas 200 miles from shore and 2,000 meters 

deep. 

Geographic distribution of ballast water exchange 

Vessel masters are required to report the latitude and longitude for the end points of 

ballast exchange operations. These data were used with geographic information system 

software to construct a map showing the spatial distribution and density of exchange 

operations on a global scale (Fig. 11). Bathymetric data describing ocean depths of less 

19
APPENDIX B 

than 2,000 meters were overlaid with ocean areas that were equal to or less than 200 

nautical miles from land, creating a map of locations restricted by the mid-ocean 

exchange guidelines in NISA. The end-points of reported tank exchanges were then 

plotted on the map. The central regions of the Pacific and Atlantic oceans are clearly the 

sites of much of the exchanged ballast water discharged to U. S. waters, as requested in 

the voluntary guidelines. However, many points lie within the shaded, or restricted, 

areas, indicating that a portion of the ostensibly “exchanged” water that is discharged into 

the U. S. comes from locations in proximity to coasts. Perhaps the clearest examples of 

this can be seen in the Gulf of Mexico and along the Pacific coast of Mexico and Central 

America. Some of the incidences of exchanging ballast close to foreign coastlines may 

stem from a misunderstanding among ship’s masters that the guidelines request that water 

be exchanged 200 miles or more from any coast, not just from the U. S. coast. The 

shipping routes to the Gulf of Mexico from Mexico, Central America, the Caribbean, and 

portions of South America are likely highly constrained with respect to where mid-ocean 

exchange can take place, as few locations may meet the specified distance and depth 

criteria for exchange. 

Verification Surveys 

The U.S. Coast Guard implemented a pilot program for Verification Surveys. The survey 

was designed to randomly target vessel arrivals for boarding, based upon COPTZ, 

covering the entire coastal U.S. For each of 30 COTPZ, the target was set at 24 

boardings per year for each of five ship types (Bulk Carrier, Container, General Cargo, 

Tanker, and Other). Thus, if all boardings were conducted, this would provide a groundtruthing for 3,600 arrivals each year. 

The results of the pilot program are currently being evaluated to consider the best 

strategies available to verify accuracy of reporting. Although the Verification Surveys 

likely provided an important outreach and training activity by U.S. Coast Guard, the 

actual number of boardings by USCG was variable in space and time, and sometimes fell 

short of the anticipated goal. The shortfall resulted from both an uneven distribution of 

vessel arrivals (spatially and temporally) and, in some cases, conflicting demands upon 

USCG personnel. 

Non-discharged Ballast Tanks: Fate and Potential Importance? 

Approximately 70% of vessels that reported on ballast water management indicated no 

intent to discharge ballast water (Tables 3a, 3b). However, most of these vessels carried 

ballast water upon arrival: 87.2% of all reporting arrivals carried ballast water, and only 

12.8% indicated “No Ballast on Board” (NOBOB; Table 6). The fate of this ballast water 

remains unknown. 

Ships are required to report the fate of all ballast water to be discharged in the U.S. that 

originates from outside the EEZ (i.e., foreign ballast water). Nearly all reporting ships 

submit their report at the port of first entry. At this time, ships are to indicate the 

20
APPENDIX B 

discharge of all foreign ballast water at the first port of entry, as well as all future ports, in 

the U.S. Should the actual pattern of discharge change from the projected plan, ships are 

required to submit an amended report to the Clearinghouse. 

Many ships visit multiple U.S. ports after arrival from outside the EEZ, becoming 

coastwise traffic. In fact, nearly half (45.7%) of the 28,992 arrivals that reported ballast 

water management visited multiple U.S. ports upon arrival. However, ships rarely 

reported ballast water discharge to the Clearinghouse beyond the initial port of entry and 

amended forms were also rare. Although this may accurately represent ballast water 

discharge for these vessels, it may also result from confusion about the reporting 

requirement and underestimate actual ballast water discharge. 

A related issue arises when considering empty ballast tanks that are used for ballast 

operations, including discharge, within the U.S. Although 12.8% of vessels are reported 

as NOBOB, 38.9% of all ballast tanks for reporting vessels were in NOBOB condition 

(Table 6). For vessels that reported at least one NOBOB tank, the average number of 

tanks/ship with and without ballast water were no different: 8.5 and 8.6, respectively 

(Table 7). 

Although there are currently no guidelines in effect for ballast water management 

associated with NOBOB tanks, recent concerns have surfaced in the Great Lakes that use 

of NOBOB tanks after entry into U.S. waters may pose significant risks of introducing 

NIS. Specifically, although NOBOB tanks are relatively empty, they may still contain 

residual organisms that can be re-suspended and discharged by ballast operations. The 

extent to which vessels arriving to the U.S. from overseas use NOBOB tanks in 

subsequent ballast operations, either during coastwise movements or within the port of 

arrival, remains unknown. 

CONCLUSIONS 

Ballast Water Reporting 

Nationwide compliance in reporting ballast water management by commercial ships was 

low and showed little improvement over the first 2-year period of mandatory reporting. 

For June 2001, the last month of the two-year period, the nationwide compliance with 

reporting was low, only 34.7% of arrivals subject to the reporting requirement. 

Although compliance did improve markedly along the West Coast (composed of 

California, Oregon, and Washington) over the past 24 months, coinciding with initiation 

of state regulations, this represents only a small proportion (14%) of the nationwide 

vessel arrivals subject to reporting. In contrast, compliance in reporting for the East 

Coast and Gulf Coast, which together account for 68% of vessel arrivals required to 

report, showed little change during the same time period. Thus, at the present rate of 

improvement in reporting, full compliance will not occur for many decades. 

21
APPENDIX B 

There remain some significant gaps in the MARAD data for Hawaii, Alaska, and Guam, 

making it difficult to accurately assess compliance with reporting for these locations. 

Although this has little impact on the overall pattern for the country, as these coasts 

account for only a small fraction (2%) of the cumulative vessel arrivals, it does limit 

assessment of compliance for these regions at the present time. 

Ballast Water Management 

Despite our summary of existing reports, it is currently not possible to assess ballast 

water delivery and management patterns for the U.S., because the rate of under-reporting 

is so severe: Most (69.6%) of vessel arrivals required to report simply failed to do so. 

Thus, the ballast management of most ships remains unknown, and it cannot be assumed 

the 30.4% of arrivals that do report are in any way representative of the entire population. 

Of ships that did report, most (>70%) reported no discharge of ballast water and were 

therefore following the voluntary guidelines. Of those that reported discharge, 

approximately half of the vessels indicated no exchange had occurred prior to discharge. 

Analysis of the geographic locations of the ballast exchange endpoints as recorded by the 

reporting vessels indicated that an appreciable proportion of the exchanges had occurred 

within 200 miles of coastlines. This may be due to misunderstanding on the part of 

vessel masters that exchange is requested to occur at least 200 miles away from any 

coast, not just the U. S. coast. 

General 

Overall, the low level of reporting remains a significant problem for (a) interpreting 

compliance with voluntary guidelines and (b) tracking the ballast water delivery and 

management patterns for the country. Reporting by ships must increase dramatically to 

meet these objectives. However, there exist some additional factors, which prevent the 

current program from achieving its goals, including: 

• Ballast water reporting requirements currently exclude a large component of vessel 

traffic in the U.S. and (even if compliance improves) therefore provides an 

incomplete picture; 

• No Verification Surveys are currently in effect to verify the accuracy of reporting; 

• Ballast water reports submitted by the ships often contained errors in the estimation 

of ballast water exchange; 

• Tracking of vessel arrivals by MARAD and the U.S. Coast Guard still has some 

significant gaps; 

• Use of electronic data submission by ships remains low. 

Each of these elements should be the focus of specific action by the U.S. Coast Guard to 

improve the current program, allowing it to meet the objectives outlined in NISA. 

Below, we provide recommendations for action in each area. 

22
APPENDIX B 

RECOMMENDATIONS 

1. Improve Ballast Water Reporting by Ships to Provide Representative Data. 

A significant problem remains in acquiring the data necessary to measure ballast water 

delivery and management patterns for the country. In the present program, this exists as 

a severe lack of reporting by most vessels expected to submit information. 

To address this problem, the U.S. Coast Guard has two possible avenues. First, the U.S. 

Coast Guard could take steps to maximize compliance with mandatory reporting by all 

vessels subject to the requirement. Alternatively, the U.S. Coast Guard could require or 

obtain complete reporting on a representative subset of vessels. 

The former approach is most preferable, as it would result in the highest quality and 

quantity of data. In contrast, the latter involves a representative sampling of vessels and 

would require a stratified, random subsample of all vessels by vessel class, geographic 

location, and time (season and year). Although this second approach is theoretically 

feasible, it may require a large sample size, given the relatively large amount of variation 

in ballast water management that we expect among vessels, locations, and seasons. 

2. Extend the Ballast Water Reporting Requirement to include (a) Coastwise 

Traffic and (b) Better Reporting for each Port of Arrival. 

For a variety of reasons, the current reporting requirement misses a significant amount of 

vessel traffic and ballast water delivery. 

• Many ships enter the U.S. from outside of the EEZ and move coastwise. 

Although such traffic is meant to report the fate of any ballast water 

discharged in U.S. waters after entry, under the current reporting requirement, 

we believe many ships report discharge only for the first port of entry. 

• The transfer of ballast water from coastal (i.e., domestic) sources is an 

important issue by itself, resulting in discharge of large volumes at many ports 

(e.g., Valdez, Alaska and Chesapeake Bay), and can lead to unwanted 

biological invasions. Relatively little is known about management and 

delivery of ballast water that originates within the U.S. (e.g., San Francisco 

Bay to Chesapeake Bay, Chesapeake Bay to New Orleans). This information 

gap precludes the formation of critical management and policy decisions. 

• The use of NOBOB (i.e., relatively empty) tanks for ballast operations upon 

arrival to the U.S can result in the discharge of residual organisms from 

foreign sources (that can result in new invasions). The use and management 

of these tanks, comprising 38.9% of all ballast tanks for reporting ships, is not 

23
APPENDIX B 

addressed in the current program. However, comprehensive reporting for 

each port (with the current form) would measure the extent, pattern, and 

potential importance of this practice. 

We believe there remains significant confusion about which vessels should report and 

when they should report. Comprehensive (foreign and coastwise) reporting would 

remove any uncertainty about which traffic should report, improve overall data quality, 

and address important gaps in the current program. 

3. Implement Verification Surveys to Assess Accuracy of Reporting by Vessels. 

There remains a need for Verification Surveys, designed specifically to assess the 

accuracy of reporting by vessels. As a minimum, this requires design and 

implementation of a random, stratified sampling of vessel arrivals across the country, to 

include different vessel classes, geographic locations (ports), and seasons. This is the 

basic design of the pilot program for a Verification Survey, implemented by the U.S. 

Coast Guard. Particular attention should be given to resources (i.e., dedicated staff) 

necessary to complete this survey, including (a) targeted use of Clearinghouse staff for 

surveys during selected time periods and (b) use of selected key ports to represent 

broader geographic regions. 

 

4. Obtain Data on Ballast Tank Capacities.

Additional information is required from each ship to estimate ballast water 

management. Many errors exist on the ships’ reports of “percent ballast water 

exchanged”. As a result, we often cannot reliably estimate the percent of ballast water 

exchange performed on a “by tank” or “by vessel” basis. To correct this problem, we 

recommend two changes. First, the current reporting form should be modified, or some 

other mechanism implemented by U.S. Coast Guard, to obtain capacity for each ballast 

tank aboard reporting ships. Tank capacity is needed to calculate directly the percent 

ballast water exchange. Second, instructions on how to estimate percent ballast water 

exchange for the reporting form should be modified to include descriptions of common 

errors and how to avoid them. 

5. Improve U.S. Coast Guard database for Vessel Arrivals. 

Although vessel arrival data collected by MARAD provide good quality data for most 

ports, significant gaps existed for Hawaii, Alaska, and Guam. The U.S. Coast Guard 

routinely collects such data on arrivals via the Advanced Notice of Arrival, in which 

ships are required to report key information prior to arrival. Furthermore, the U.S. Coast 

Guard maintains these data in their own database. However, up until now, the U.S. Coast 

Guard data for each vessel arrival did not consistently include standardized 

identifications of the last port of call, making these data of limited utility for 

24
APPENDIX B 

Clearinghouse analyses. Specifically, the arrivals database could not be used to 

distinguish foreign versus coastwise traffic. 

In October 2001, the U.S. Coast Guard database began to include standardized input to 

the critical field of “last port of call”. Should this new system be implemented fully, it 

will create a valuable resource of data on all arrivals. We recommend that the U.S. Coast 

Guard encourage full implementation (i.e., entry of standardized last port of call data for 

all arrivals). Maritime exchanges often collect excellent arrivals data, offering an 

alternate source of information, but there exist only a limited number of exchanges and 

these cannot currently provide nationwide coverage for all arrivals. Thus, in our view, 

full implementation of the U.S. Coast Guard database offers the best opportunity to 

remove the existing gaps in the data on vessel arrivals. 

6. Promote use of Electronic Reporting. 

At the present time, most ships send reports to the Clearinghouse by FAX or mail. 

However, the use of electronic submission would greatly reduce the time required by 

ships to submit forms, since many fields of information remain unchanged at each 

submission. Electronic submission also would increase accuracy (removing problems 

associated with legibility), and reduce the effort in data entry and time needed to make 

the data accessible. 

The Clearinghouse provides mechanisms for electronic submission, including (1) 

transmission of MS ExcelTM or MS WordTM files via email and (2) use of an on-line form. 

Multiple modes for electronic submission have been in place on the Clearinghouse 

website (http://invasions.si.edu/ballast.htm) for the past 18 months. 

We recommend that the U.S. Coast Guard promote and encourage, to the maximum 

extent possible, the electronic submission of data. 

25
APPENDIX B 

Data

Figure 1. Flowchart describing the functional aspects of the National Ballast Survey 

(NABS). 

Query 

Results 

BWM 

Survey

Verify. 

Survey

MARAD

Arrivals 

Statistical 

Analyses

Biennial 

Congressional 

Reports 

NABS Database 

• Ship ID/Specs. 

• Ship Voyage 

Information 

• Ballast Water History 

Ballasting Patterns 

26
APPENDIX B 

Figure 2. Captain of the Port Zone (COTPZ) designations for all coastal marine ports of 

the United States. 

27
APPENDIX B 

Figure 3. Foreign (F) and domestic (D) arrival designations for ships calling on ports of 

the United States and U.S. protectorates. Note: although not depicted on this map, 

transits between individual U.S. Caribbean islands were considered domestic while all 

other traffic to and from the Caribbean was deemed foreign. 

28
APPENDIX B 

Alaska

1%

Caribbean

16%

East Coast

38%

Gulf Coast

30%

Hawaii

1%

West Coast

14%

Figure 4. Percent foreign arrivals traffic by coast over two-year period from July 1999 to 

June 2001 (n= 95,471 arrivals). Data are from MARAD arrival reports from 1 July 1999 

to 30 June 2001. 

29
APPENDIX B 

Jul-99

Aug-99Sep-99

Oct-99

Nov-99

Dec-99

Jan-00

Feb-00Mar-00

Apr-00

May-00

Jun-00

Jul-00

Aug-00Sep-00

Oct-00

Nov-00

Dec-00

Jan-01

Feb-01Mar-01

Apr-01

May-01

Jun-01

Arrivals Reported

500

1000

1500

2000

2500

3000

3500

4000

4500

Percent Reporting

0

25

50

75

100

Clearinghouse BW Forms

MARAD Arrivals

Percent Reporting

1999 2000 2001

Figure 5. Monthly reporting rates for the nation by foreign arrivals from July 1999 to 

June 2001. Data are from National Ballast Survey (Clearinghouse) and Maritime 

Administration (MARAD) databases.

30
APPENDIX B 

East Coast

0

25

50

75

100

0

200

400

600

800

1000

1200

1400

1600

1800

Percent Reporting

Clearinghouse BW Forms

MARAD Arrivals

0

200

400

600

800

1000

1200

1400

1600

0

25

50

75

Gulf of Mexico 100

Arrivals Reported

Percent Reporting

Jul-99

Aug-99Sep-99

Oct-99

Nov-99

Dec-99

Jan-00

Feb-00Mar-00

Apr-00

May-00

Jun-00

Jul-00

Aug-00Sep-00

Oct-00

Nov-00

Dec-00

Jan-01

Feb-01Mar-01

Apr-01

May-01

Jun-01

0

200

400

600

800

0

25

50

75

West Coast 100

Figure 6a. Monthly reporting rates for East, Gulf of Mexico, and West coasts by foreign 

arrivals from July 1999 to June 2001. Data are from National Ballast Survey 

(Clearinghouse) and Maritime Administration (MARAD) databases.

31
APPENDIX B 

Alaska

Jul-99

Aug-99Sep-99

Oct-99

Nov-99

Dec-99

Jan-00

Feb-00Mar-00

Apr-00

May-00

Jun-00

Jul-00

Aug-00Sep-00

Oct-00

Nov-00

Dec-00

Jan-01

Feb-01Mar-01

Apr-01

May-01

Jun-01

0

50

100

150

200

0

25

50

75

100

0

20

40

60

80

100

120

0

25

50

75

100

Clearinghouse BW Forms

MARAD Arrivals

Percent Reporting

Hawaii

Arrivals Reported

Percent Reporting

0

100

200

300

400

500

600

700

0

25

50

75

100 Caribbean

MARAD Data Not Available

Figure 6b. Monthly reporting rates for the Caribbean, Hawaii, and Alaska coasts by 

foreign arrivals from July 1999 to June 2001. Data are from National Ballast Survey 

(Clearinghouse) and Maritime Administration (MARAD) databases.

32
APPENDIX B 

Jul 1999

Aug 1999Sep 1999

Oct 1999

Nov 1999

Dec 1999

Jan 2000

Feb 2000Mar 2000

Apr 2000

May 2000

Jun 2000

Jul 2000

Aug 2000Sep 2000

Oct 2000

Nov 2000

Dec 2000

Jan 2001

Feb 2001Mar 2001

Apr 2001

May 2001

Jun 2001

Reporting Forms

0

50

100

150

200

No Exchange 

Some Exchange 

Undetermined Exch 

Figure 7. Nationwide monthly reported ballast water discharge by management strategy. 

Data from the National Ballast Survey (Clearinghouse) database (July 1999 to June 

2001). 

33
APPENDIX B 

Alaska

Discharge with No Exchange

Discharge with Some Exchange

Discharge with Unknown Exchange

Caribbean East Coast

Gulf Coast Hawaii West Coast

N = 139 BW Forms N = 433 BW Forms N = 2652 BW Forms

N = 1512 BW Forms N = 72 BW Forms N = 2816 BW Forms

Figure 8. Proportion of ships discharging ballast water by coastal region and 

management strategy. Data from the National Ballast Survey database (Clearinghouse) 

(July 1999 to June 2001). 

34
APPENDIX B 

Jul 1999

Aug 1999Sep 1999

Oct 1999

Nov 1999

Dec 1999

Jan 2000

Feb 2000Mar 2000

Apr 2000

May 2000

Jun 2000

Jul 2000

Aug 2000Sep 2000

Oct 2000

Nov 2000

Dec 2000

Jan 2001

Feb 2001Mar 2001

Apr 2001

May 2001

Jun 2001

Volume Discharged (mt)

0.0

5.0e+5

1.0e+6

1.5e+6

2.0e+6

2.5e+6

Discharge with No Exchange 

Discharge with Some Exchange

Discharge with Unknown Exchange

Figure 9. Nationwide monthly ballast water discharge volumes by management strategy. 

Data are from National Ballast Survey database (Clearinghouse) (July 1999 to June 

2001).

35
APPENDIX B 

Total Dicharged

Volume = 

3,079,377 mt

Alaska Caribbean

Discharge with No Exchange

Discharge with Some Exchange

Discharge with Unknown Exchange

East Coast

Gulf Coast Hawaii West Coast

Total Discharged

Volume =

3,079,377 mt

Total Discharged

Volume =

1,783,026 mt

Total Discharged

Volume =

5,579,085 mt

Total Discharged

Volume =

9,102,834 mt

Total Discharged

Volume =

292,697 mt

Total Discharged

Volume =

18,217,364 mt

Figure 10. Proportion of ballast water discharged by coastal region and management 

strategy. Data from the National Ballast Survey database (Clearinghouse) (July 1999 to 

June 2001). 

36
APPENDIX B 

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Depth < 2000 m or within 200 nm coastal boundary

z# Reported ballast water exchange locations

Figure 11. Reported ballast water exchange locations (end-points of exchange) for 

individual ballast tanks on vessels arriving to the United States between July 1999 and 

June 2001. Gray shading indicates zones within 200 nautical miles of coastlines and 

depths of less than 2,000 meters. 

37
APPENDIX B 

 Table 1. Comparisons of foreign arrivals as quantified by MARAD and Maritime 

Exchange. 

No. Foreign Arrivals

Port Year Maritime 

Exchange 

MARAD 

Baltimore 1998 (first quarter) 150 151 (+0.01%) 

Baltimore 1997 644 649 (+0.07%) 

Boston 1997 495 554 (+12%) 

San Francisco 1996 642 757 (+17%) 

San Francisco 1995 715 816 (+14%) 

 

38
APPENDIX B 

Table 2. Compliance with mandatory ballast reporting requirements, by coast and 

Captain of the Port Zone. Data from National Ballast Survey and MARAD databases 

(July 1999 to June 2001). Shaded rows show subtotals for broad coastal regions. U. S. Coast COTPZ # BWR Forms Year 1 # MARAD Arrivals Year 1 % Reporting Rate Year 1 # BWR Forms Year 2 # MARAD Arrivals Year 2 % Reporting Rate Year 2 Total BWR Forms Total MARAD Forms % Reporting Rate 

Cumulative 

Alaska ANCMS 72 515 14.0% 66 213 31.0% 138 728 19.0% 

Alaska JUNMS 11 50 22.0% 13 41 31.7% 24 91 26.4% 

Alaska VALMS 13 25 52.0% 1 3 33.3% 14 28 50.0% 

Alaska Subtotal 96 590 16.3% 80 257 31.1% 176 847 20.8% 

Carib SJPMS 999 5,379 18.6% 897 6,031 14.9% 1,896 11,410 16.6% 

East BALMS 155 602 25.7% 219 629 34.8% 374 1,231 30.4% 

East BOSMS 112 439 25.5% 96 486 19.8% 208 925 22.5% 

East CHAMS 275 884 31.1% 360 923 39.0% 635 1,807 35.1% 

East HMRMS 125 488 25.6% 98 495 19.8% 223 983 22.7% 

East JACMS 518 2,144 24.2% 682 1,957 34.8% 1,200 4,101 29.3% 

East LISCP 30 75 40.0% 38 241 15.8% 68 316 21.5% 

East MIAMS 1,585 7,656 20.7% 2,293 7,545 30.4% 3,878 15,201 25.5% 

East NYCCP 823 2,380 34.6% 892 2,917 30.6% 1,715 5,297 32.4% 

East PHIMS 820 2,154 38.1% 731 2,086 35.0% 1,551 4,240 36.6% 

East POMMS 191 497 38.4% 178 381 46.7% 369 878 42.0% 

East PROMS 13 184 7.1% 17 112 15.2% 30 296 10.1% 

East SAVMS 175 654 26.8% 266 761 35.0% 441 1,415 31.2% 

East WNCMS 38 267 14.2% 56 240 23.3% 94 507 18.5% 

East Subtotal 4,860 18,424 26.4% 5,926 18,773 31.6% 10,786 37,197 29.0% 

G of M CORMS 213 1,147 18.6% 201 1,088 18.5% 414 2,235 18.5% 

G of M HOUCP 765 4,887 15.7% 870 4,963 17.5% 1,635 9,850 16.6% 

G of M MOBMS 184 1,496 12.3% 263 1,606 16.4% 447 3,102 14.4% 

G of M NEWMS 744 4,619 16.1% 752 5,030 15.0% 1,496 9,649 15.5% 

G of M PATMS 138 1,072 12.9% 169 1,213 13.9% 307 2,285 13.4% 

G of M TAMMS 348 992 35.1% 336 1,046 32.1% 684 2,038 33.6% 

G of M Subtotal 2,392 14,213 16.8% 2,591 14,946 17.3% 4,983 29,159 17.1% 

Hawaii HONMS 298 651 45.8% 481 896 53.7% 779 1,547 50.4% 

Other GUAD 93 N/A N/A 100 N/A N/A 193 N/A N/A 

West LOSMS 2,792 4,301 64.9% 3,307 4,271 77.4% 6,099 8,572 71.2% 

West PORMS 442 942 46.9% 621 947 65.6% 1,063 1,889 56.3% 

West SDCMS 150 653 23.0% 228 674 33.8% 378 1,327 28.5% 

West SEAMS 556 1,050 53.0% 716 922 77.7% 1,272 1,972 64.5% 

West SFCMS 588 747 78.7% 775 804 96.4% 1,363 1,551 87.9% 

West Subtotal 4,528 7,693 58.9% 5,647 7,618 74.1% 10,175 15,311 66.5% 

 Total 13,266 46,950 28.3% 15,722 48,521 32.4% 28,988 95,471 30.4% 

39
APPENDIX B 

Table 3a. Year 1 compliance with voluntary ballast water management guidelines, by 

coast and Captain of the Port Zone. Data from National Ballast Survey database (July 

1999 to June 2000). Shaded rows show subtotals for broad coastal regions. U. S. Coast COTPZ # BWR Forms Year 1 # Zero Discharge % Zero Discharge # Zero Exchange % Zero Exchange # Some Exchange % Some Exchange # Unknown Exchange % Unknown Exchange 

Alaska ANCMS 72 14 19.4% 35 48.6% 23 31.9% 0 0.0% 

Alaska JUNMS 11 2 18.2% 0 0.0% 9 81.8% 0 0.0% 

Alaska VALMS 13 3 23.1% 2 15.4% 8 61.5% 0 0.0% 

Alaska Subtotal 96 19 19.8% 37 38.5% 40 41.7% 0 0.0% 

Carib SJPMS 999 737 73.8% 214 21.4% 48 4.8% 0 0.0% 

East BALMS 155 139 89.7% 2 1.3% 13 8.4% 1 0.6% 

East BOSMS 112 87 77.7% 20 17.9% 5 4.5% 0 0.0% 

East CHAMS 275 210 76.4% 29 10.5% 31 11.3% 5 1.8% 

East HMRMS 125 79 63.2% 14 11.2% 30 24.0% 2 1.6% 

East JACMS 518 350 67.6% 151 29.2% 13 2.5% 4 0.8% 

East LISCP 30 27 90.0% 2 6.7% 1 3.3% 0 0.0% 

East MIAMS 1,585 943 59.5% 552 34.8% 85 5.4% 5 0.3% 

East NYCCP 823 670 81.4% 73 8.9% 62 7.5% 18 2.2% 

East PHIMS 820 760 92.7% 12 1.5% 46 5.6% 2 0.2% 

East POMMS 191 178 93.2% 6 3.1% 6 3.1% 1 0.5% 

East PROMS 13 12 92.3% 1 7.7% 0 0.0% 0 0.0% 

East SAVMS 175 139 79.4% 6 3.4% 26 14.9% 4 2.3% 

East WNCMS 38 28 73.7% 3 7.9% 7 18.4% 0 0.0% 

East Subtotal 4,860 3,622 74.5% 871 17.9% 325 6.7% 42 0.9% 

G of M CORMS 213 164 77.0% 21 9.9% 25 11.7% 3 1.4% 

G of M HOUCP 765 521 68.1% 118 15.4% 116 15.2% 10 1.3% 

G of M MOBMS 184 142 77.2% 12 6.5% 29 15.8% 1 0.5% 

G of M NEWMS 744 462 62.1% 135 18.1% 141 19.0% 6 0.8% 

G of M PATMS 138 108 78.3% 9 6.5% 21 15.2% 0 0.0% 

G of M TAMMS 348 233 67.0% 77 22.1% 33 9.5% 5 1.4% 

G of M Subtotal 2,392 1,630 68.1% 372 15.6% 365 15.3% 25 1.0% 

Hawaii HONMS 298 258 86.6% 17 5.7% 23 7.7% 0 0.0% 

Other GUAD 93 82 88.2% 3 3.2% 8 8.6% 0 0.0% 

West LOSMS 2,792 2,033 72.8% 277 9.9% 465 16.7% 17 0.6% 

West PORMS 442 174 39.4% 19 4.3% 247 55.9% 2 0.5% 

West SDCMS 150 118 78.7% 8 5.3% 22 14.7% 2 1.3% 

West SEAMS 556 372 66.9% 17 3.1% 165 29.7% 2 0.4% 

West SFCMS 588 440 74.8% 40 6.8% 106 18.0% 2 0.3% 

West Subtotal 4,528 3,137 69.3% 361 8.0% 1,005 22.2% 25 0.6% 

Total Year 1 13,266 9,485 71.5% 1,875 14.1% 1,814 13.7% 92 0.7% 

40
APPENDIX B 

Table 3b. Year 2 compliance with voluntary ballast water management guidelines, by 

coast and Captain of the Port Zone. Data from National Ballast Survey database (July 

2000 to June 2001). Shaded rows show subtotals for broad coastal regions. U. S. Coast COTPZ # BWR Forms Year 1 # Zero Discharge % Zero Discharge # Zero Exchange % Zero Exchange # Some Exchange % Some Exchange # Unknown Exchange 

% Unknown Exchange 

Alaska ANCMS 66 15 22.7% 34 51.5% 17 25.8% 0 0.0% 

Alaska JUNMS 13 3 23.1% 0 0.0% 10 76.9% 0 0.0% 

Alaska VALMS 1 0 0.0% 0 0.0% 1 100.0% 0 0.0% 

Alaska Subtotal 80 18 22.5% 34 42.5% 28 35.0% 0 0.0% 

Carib SJPMS 897 726 80.9% 130 14.5% 40 4.5% 1 0.1% 

East BALMS 219 201 91.8% 3 1.4% 15 6.8% 0 0.0% 

East BOSMS 96 94 97.9% 1 1.0% 1 1.0% 0 0.0% 

East CHAMS 360 315 87.5% 15 4.2% 30 8.3% 0 0.0% 

East HMRMS 98 63 64.3% 11 11.2% 23 23.5% 1 1.0% 

East JACMS 682 535 78.4% 128 18.8% 15 2.2% 4 0.6% 

East LISCP 38 35 92.1% 2 5.3% 1 2.6% 0 0.0% 

East MIAMS 2,293 1,402 61.1% 741 32.3% 147 6.4% 3 0.1% 

East NYCCP 892 764 85.7% 84 9.4% 37 4.1% 7 0.8% 

East PHIMS 731 671 91.8% 19 2.6% 39 5.3% 2 0.3% 

East POMMS 178 168 94.4% 4 2.2% 6 3.4% 0 0.0% 

East PROMS 17 17 100.0% 0 0.0% 0 0.0% 0 0.0% 

East SAVMS 266 212 79.7% 5 1.9% 46 17.3% 3 1.1% 

East WNCMS 56 35 62.5% 3 5.4% 17 30.4% 1 1.8% 

East Subtotal 5,926 4,512 76.1% 1,016 17.1% 377 6.4% 21 0.4% 

G of M CORMS 201 161 80.1% 28 13.9% 12 6.0% 0 0.0% 

G of M HOUCP 870 614 70.6% 90 10.3% 144 16.6% 22 2.5% 

G of M MOBMS 263 213 81.0% 10 3.8% 40 15.2% 0 0.0% 

G of M NEWMS 752 470 62.5% 120 16.0% 157 20.9% 5 0.7% 

G of M PATMS 169 141 83.4% 12 7.1% 13 7.7% 3 1.8% 

G of M TAMMS 336 242 72.0% 71 21.1% 23 6.8% 0 0.0% 

G of M Subtotal 2,591 1,841 71.1% 331 12.8% 389 15.0% 30 1.2% 

Hawaii HONMS 481 448 93.1% 15 3.1% 17 3.5% 1 0.2% 

Other GUAD 100 84 84.0% 2 2.0% 14 14.0% 0 0.0% 

West LOSMS 3,307 2,612 79.0% 252 7.6% 430 13.0% 13 0.4% 

West PORMS 621 264 42.5% 13 2.1% 340 54.8% 4 0.6% 

West SDCMS 228 199 87.3% 15 6.6% 13 5.7% 1 0.4% 

West SEAMS 716 503 70.3% 26 3.6% 187 26.1% 0 0.0% 

West SFCMS 775 644 83.1% 25 3.2% 105 13.5% 1 0.1% 

West Subtotal 5,647 4,222 74.8% 331 5.9% 1,075 19.0% 19 0.3% 

Total Year 2 15,722 11,851 75.4% 1,859 11.8% 1,940 12.3% 72 0.5% 

Grand Total 28,988 21,336 73.6% 3,734 12.9% 3,754 13.0% 164 0.6% 

41
APPENDIX B 

Table 4. Compliance with voluntary guidelines by volume for management of ballast 

water during period from July 1999 to June 2001. Shaded rows show subtotals for broad 

coastal regions. 

 US Coast COTPZ 

No Exchange [mt] 

No Exchange [%] 

Some Exchange [mt] 

Some Exchange [%] 

Unknown Exchange [mt] 

Unknown Exchange [%] 

Alaska ANCMS 1,894,957 79.3% 493,655 20.7% 1,800 0.1%

Alaska JUNMS 2,177 1.9% 110,873 98.1% 0 0.0%

Alaska VALMS 222,062 38.6% 353,853 61.4% 0 0.0%

Alaska Subtotal 2,119,196 68.8% 958,381 31.1% 1,800 0.1%

Carib SJPMS 928,930 52.1% 837,495 47.0% 16,600 0.9%

East BALMS 86,389 14.0% 508,524 82.5% 21,780 3.5%

East BOSMS 48,207 85.7% 8,013 14.3% 0 0.0%

East CHAMS 58,204 41.4% 74,315 52.9% 7,987 5.7%

East HMRMS 370,686 21.3% 1,335,139 76.7% 35,190 2.0%

East JACMS 274,989 90.0% 28,364 9.3% 2,184 0.7%

East LISCP 4,276 88.6% 548 11.4% 0 0.0%

East MIAMS 1,046,990 88.4% 133,511 11.3% 3,330 0.3%

East NYCCP 150,048 53.8% 113,851 40.8% 15,243 5.5%

East PHIMS 281,871 60.8% 163,756 35.3% 18,298 3.9%

East POMMS 72,051 46.6% 71,651 46.4% 10,810 7.0%

East PROMS 17,559 100.0% 0 0.0% 0 0.0%

East SAVMS 40,938 13.8% 239,466 80.9% 15,457 5.2%

East WNCMS 23,514 7.4% 294,633 92.2% 1,314 0.4%

East Subtotal 2,475,722 44.4% 2,971,771 53.3% 131,593 2.4%

G of M CORMS 453,238 60.1% 267,287 35.4% 34,064 4.5%

G of M HOUCP 1,193,966 50.6% 1,105,637 46.9% 57,697 2.4%

G of M MOBMS 106,493 19.1% 449,355 80.5% 2,289 0.4%

G of M NEWMS 837,110 20.6% 3,154,942 77.7% 67,042 1.7%

G of M PATMS 274,360 43.1% 336,925 53.0% 24,759 3.9%

G of M TAMMS 196,920 26.7% 518,357 70.3% 22,393 3.0%

G of M Subtotal 3,062,087 33.6% 5,832,503 64.1% 208,244 2.3%

Hawaii HONMS 122,014 41.7% 161,256 55.1% 9,427 3.2%

Other GUAD 11,733 31.1% 25,960 68.9% 0 0.0%

West LOSMS 1,326,599 21.7% 4,705,304 76.9% 87,624 1.4%

West PORMS 438,022 7.1% 5,621,938 91.5% 86,321 1.4%

West SDCMS 18,001 12.7% 111,681 78.6% 12,354 8.7%

West SEAMS 277,842 9.6% 2,588,297 89.1% 37,381 1.3%

West SFCMS 296,831 14.1% 1,809,326 85.8% 3,160 0.1%

West Subtotal 2,357,295 13.5% 14,836,546 85.2% 226,840 1.3%

 Total 11,076,977 29.7% 25,623,912 68.7% 594,504 1.6%

42
APPENDIX B 

Table 5. Reasons provided by vessel masters for not exchanging ballast water to be 

discharged in U. S. waters. The categories were constructed by the Clearinghouse, and 

individual reports were assigned as best as possible. Reporting period was July 1999 to 

June 2001. 

Reason Provided Total BWR Forms [#] % of Total 

Clean Ballast 184 15.2% 

Itinerary 159 13.2% 

N/A 127 10.5% 

Other/Undecipherable 650 53.8% 

Safety 56 4.6% 

Ship's Design 32 2.6% 

TOTAL 1,208 100% 

43
APPENDIX B 

Table 6. Comparison of no ballast on board (NOBOB) and ballast on board (BOB) 

vessels and tanks based on total number of foreign arrivals and total tanks that arrived to 

U.S. ports between July1999 and June 2001. 

Vessel Condition Vessel No. % Vessel No. % 

NOBOB 3,712 12.8% 3,712 12.8% 

BOB 25,280 87.2% 25,280 87.2% 

Total 28,992 100% 28,992 100% 

44
APPENDIX B 

45

Table 7. Average number of NOBOB tanks and BOB tanks aboard 24,607 foreign 

arrivals that carried at least one NOBOB tank. Reporting period was from July 1999 to 

June 2001. 

Tank Condition Mean No. of Tanks Standard Error 

NOBOB tanks 8.6 0.05 

BOB tanks 8.5 0.04 

All Tanks 17.2 0.05