# APPENDIX B STATUS AND TRENDS OF BA LLAST WATER MANAGEMENT IN THE UNITED STATES FIRST BIENNIAL REPORT OF THE NATIONAL BALLAST INFORM ATION 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 2 nd

# Street, S.W., Washington, D.C. 20593 USA
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# 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 mtmetric 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 USCGUnited States Coast Guard

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# 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 sp ecies, 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 intro ducing 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 Clearinghou se), 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 Clearinghou se 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. 

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# 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 reportin g 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 Clearin ghouse, 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: Alas ka – 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. 

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# APPENDIX B 20. Thus, of the 7,652 vessels that reported discharg e 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 discharg e 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 reportedexchange occurred in coastal areas (< 200 mi offshore), rath er 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 verifyaccuracy of reporting. The pilo t 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, availa bility 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 approximately75%, 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 seco nd 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 ou tside of the EEZ, and reporting di d not increase appreciably along the Gulf Coast and East Coast (38% an d 30% of all arrivals, respectively). 

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# 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 prev enting 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 arri ving 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 approachis preferable, as it would yield the highest quality and quantity of data. 34. The ballast water reporting requirement shouldbe extended to include coastwise ship traffic, and ships should repo rt 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 (f oreign 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 im portant 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 organism s 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 exchan ge, 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. 

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# APPENDIX B 36. There remains a need for implementation of V erification Surveys, which are designed specifically to verify the accura cy 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. Coas t 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 s ubmission would reduce the effort required by the shipping industry.



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# APPENDIX B INTRODUCTION Biological invasions are fundamentally changingthe structure and function of the earth’s ecosystems. Invasions result from the transf er and establishment of species outside of their historical range. The extent of i nvasions has become increasingly clear over the past decade, and many communities are nowdominated by invading or nonindigenous species (NIS) in terms of number of organism s, 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 inva sions, driven in large part by observed ecological effects as well as economic im pacts, 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 invasi ons 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 veryrobust across various habitats, taxonomic groups, and global regions. This apparent increa se 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 inva sions, management strategies and policies are being advanced at state, regional, national and internatio nal levels. For example, the U.S. Congress has enacted two laws si nce 1990, and President Clinton signed an Executive Order, to limit the rate and impactof 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, resu lting 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) ha s issued voluntary guidelines, including the use of open-ocean ballast water exchange, to limit transfer of coastal organisms in ballast water. In essen ce, ships are asked to flush out their ballast tanks at sea, reducing the con centration 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. Inaddition, alternative treatment methods are at various stages of development and testing throughout the world. The U.S. Congress has passed two laws thatinclude 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 dataconcerning the transf er and invasion of nonindigenous species associated wi th the ballast water of ships. Under NISA, Congress directed the Secret ary of Transportation to promulgate regulations that (a) require ve ssel 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 manageme nt practices for use by such vessels. The voluntary guidelines include hol ding 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 mi nimize the transfer of NIS in ballast water of ships and to reduce the risk of exotic species invasions a ssociated 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 th e rate of ballast-mediated invasions. The Clearinghouse was created to provi de 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 exp licitly to create a national databaseon ballast water to be used to measure: (1) rates of compliance w ith 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 regi on and season of arrival; (4) among-year changes in ballast water management by ve ssel class and geographic region; and (5) accuracy of data through use of mu ltiple, independent data sources. The NABS relies on three primary sources of data. These include: 1. Ballast water information reported directlyto the Clearinghouse by arriving vessels; 2. Foreign waterborne Transportation statisti cs 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 in cludes 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 allvessels, arriving from outside the EEZ, that are missing in the firs t data set, providing a measure of underreporting and thus of compliance with NI SA’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 th e first data set and (2) make statistical comparisons of ballast delivery patterns by vessel class, geographi c 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 th e 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. Coas t Guard and Secretary of Transportation, and is used inform the U.S. Congress on implementation of NISA. Other Clearinghouse Components: Marine Invasions Databaseand Research Directory The NABS is only one component of the Cl earinghouse. The Cl earinghouse functions more generally as a centralized source of national information on marine invasions and on ballast water invasions issues. The fo llowing 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 Es tuarine 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 estuarie s (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 intern ational information on people, research, technology, policy, and management issues re levant to ballast water and aquatic invasions. • The Ballast Water Exchange Verification Project Testing and development of in-situ and laboratory-based technologies for im proved 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 reporti ng 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 requireme nt, and compliance with the voluntary guidelines, were assessed at three different geographic scal es: national, regional (major coasts), and local port system (U.S. Coast Guard Captain of the Port Zone, COTPZ; Figure 2). Prior to all anal yses, data received by the Cl earinghouse underwent standard protocols to detect and rem ove erroneous records, incl uding duplicate reports and numerical outliers beyond the realm of po ssibility. 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 requireme nts, as outlined in NISA. The following rules were applied to differentiate “foreign” arrivals (those included in the analyses) from “domestic” or “coastwise” arri vals (those excluded), under direction by the U.S. Coast Guard: 11

# APPENDIX B (1) All arrivals to the Pacific coast, Atlantic co ast or Gulf of Mexico coast from countries other than the United States or Canada are designated as “f oreign” 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 departthe EEZ during transit. (3) Vessels that leave the Pacific coast of North America, traverse the Panama Canal, and arrive at the Atlantic or Gu lf of Mexico coasts (and vice versa) are deemed “foreign” arrivals. (4) Since there are no available re cords to verify whether a co ast-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 tr ansited from a forei gn country’s island to a U.S. state or protectorate wereconsidered “foreign” arrivals. (6) Arrivals to the Great Lakes are excluded from the present analysis. These vessels are required to undertake ballas t water exchange, and a separate program of the U.S. Coast Guard evaluates compliance for these vessels. The analysis of compliance w ith reporting require s knowledge of actual arrivals, allowing the detection of non-reporting ships. For this analysis, werelied 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 completene ss 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 listedas “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 samevessel sizes as targeted by the USCG, resulted in a total of 71,226 arrivals. The overall agreement betw een 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 forei gn from domestic arrivals using the USCG database. With the exception of mainland toisland and island to mainland transits, all U.S. to Canada and Canada to U.S. arrivals outside the Great Lake s 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 Mari time Exchanges of Baltimore, Boston, and San Francisco (Table 1). In general, th e agreement between th e 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 havebecome 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 vari es between individual Maritime Exchange offices. Selection of MARAD Data as the Base line for Determining Reporting Compliance The close agreement between the Maritime Exchange and MARAD data for foreign arrivals indicates that the MARAD “forei gn arrival” designation is probably a close approximation of the vessel traffic that actually arrives from outsidethe EEZ. Moreover, the minor differences in total vessel arrivals reported by MARAD and the USCG further suggest that MARAD provides a goo d 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 serviceablefor use in the National Ballast Survey. Constraints with MARAD Data and Adjustments Although MARAD data were generally very goo d 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 balla st water reporting forms wereexcluded from regional and national estimates of reporting compliance for particular months for Alaska and Hawaii 13

# APPENDIX B (so indicated in figures), and compliance withreporting simply could not be estimated for Guam during this period. For a few other ports, we were able to obt ain arrivals data that were missing from MARAD through Maritime Exchanges. Speci fically, 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 tocorrect inconsistenc ies (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 partic ular port system, and many regions of the country simply do not have thes e or other local entities thatcomprehensively track vessel arrivals.) Compliance with Voluntary Exchange Guidelines Although some gaps in the MARAD data limite d use of all data in measuring compliance with mandatory reporting, all submitted ball ast 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 co astal 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 acc ounted 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 Unite d States met this requirement, and there was relatively little improvement between y ears. When examined on a monthly basis (Figure 5), nationwide reporti ng 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, Al aska, 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 in crease (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 alsoreflected the same patterns over time, showing the greatest improvement for the West Coast (Figs. 6a,b). To better characterize changes in reporting over time, weused linear regressions to measure the rate of change in reporting fo r 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 Co ast, 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, co mpliance 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 Franci sco, Los Angeles, Seattle, Portland (OR), Honolulu, and Valdez. The re lative 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 withreporting 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 pa ssage in October 1999 of a state law with the pending threat of penalty; furthermore, comp liance increased markedly in January, when the law went into effect and penaltie s 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 ac tivity. Washington State passed a law 15

# APPENDIX B concerning ballast water that we nt into effect in 2001, and Oregon just recently passed a similar measure. In addition, relativelyhigh compliance in Valdez (50.0%) may be associated with a targeted federal law requiri ng ballast water exchangefor 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 fo r 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 specif ic information for discharged ballast water orig inating 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 ev aluated as the proporti on 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 untre ated 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 incl ude exchanging ballast water in areas at least 200 miles from any shore and at least 2,000 meters deep, or in an alternative ballast exchangezone approved by the COPTZ; retaining ballast water on board; using an alternative environmentall y sound, USCG approved method of treatment; or discharging ballast water to an approved reception f acility. 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 ex change, 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 otherw ise treated, or retained on board. 16

# APPENDIX B Although the Clearinghouse database was desi gned 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 wi despread 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 reportedcomplete 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 categorizedas “Discharge with No Exchange”, “Discharge with Some Exchange” and “Discharge with Unknown Exchange” (see below for further discussion of limitati ons to precise calculation and reporting of percent exchange). Caution: Ideally, with a high level of reporti ng, the ballast water management reports submitted by vessels could be used to estim ate the amount of treated and untreated (exchanged or otherwise) water discharged inthe U. S. However, compliance with the reporting requirement was so low, only 30.4%, that reporting vessels cannot be considered representative of the larger popul ation of all arriving ships entering U. S. waters. Compliance with Voluntary Guidelines by Ship 1. National Compliance Most (73.6%) of the reporting ve ssels 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 di d not discharge ballast water, it is noteworthy that of the 7,652 vessels that did report an intention todischarge, 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 thatdeclared no discharge varied from 90.6% in Hawaii (89.7% for the Pacific Islands if Gu am is included) to 21.0% in Alaska (Tables 3a,b). 17

# APPENDIX B The West Coast reported the highest proportion of discharging ve ssels that underwent some exchange (73.9%) and the Caribbeanreported 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 greate st 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 Angele s 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 di scharging vessels, 84.3% with no exchange, 15.1% with some exchange) and San Juan(433 discharging ve ssels, 79.4% with no exchange, 20.3% with some exchange) (Tab les 3a, 3b). These re sults 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 bi ological perspective an important compliance measure is the proportion of discharged water that was exch anged. 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 th e ballast water reporting forms submitted that there is widespread confusion on how percent exchange is calculated and reported, despite detailed published instructions. A dditionally, the current ballast water reporting form does not require that th e 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 “D ischarge with No Exchange”, “Discharge with Some Exchange”, or “Dis charge 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 practi ces 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 basi s, 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 proporti on of discharged volume that underwent some degree of exchange was the West Coas t. The lowest volumetric proportion of discharge that underwent some exch ange 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 disc harge 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 wa s not performed prior to disc harge, ships’ masters were asked to provide the reason(s), on the balla st 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) s uggests that an overt concern for the safety of the vessel and crew was not the over-ridi ng 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 th e 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 i tinerary precluded such an operation. In many such cases, there may have been an insu fficient period of time during the voyage to conduct a complete exchange, either becausethe 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 sp atial distribution and density of exchange operations on a global scale (Fig. 11). Bathymetric data describing oc ean 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-poi nts 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 di scharged to U. S. waters, as requested in the voluntary guidelines. However, many poi nts 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 anycoast, 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 withrespect 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 vari able 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 reporti ng 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 ball ast 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 Cleari nghouse beyond the initialport of entry and amended forms were also rare. Although this may accurately represent ballast water discharge for these vessels, it may also re sult 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 ve ssels 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 ineffect 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 balla st operations. The extent to which vessels arriving to the U.S. from overseas use NOBOB tanks in subsequent ballast operations, either during coastwise moveme nts 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, coinci ding 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, mo st (>70%) reported no discharg e of ballast water and were therefore following the voluntary guidelines . Of those that reported discharge, approximately half of the vessels indicated no ex change had occurred prior to discharge. Analysis of the geographic locations of the ballast exchange endpoints as recorded by the reporting vessels indicated thatan 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 remain s 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 achie ving its goals, including: • Ballast water reporting requirements currently exclude a large component of vessel traffic in the U.S. and (even if comp liance improves) therefore provides an incomplete picture; • No Verification Surveys are currently in e ffect 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 Shi ps 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 vesse ls 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 th e 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 relative ly 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 Reportin g for each Port of Arrival. For a variety of reasons, the current reporting requirement misses a significant amount of vessel traffic and ball ast water delivery. • Many ships enter the U.S. from outsideof 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 discharg e only for the first port of entry. • The transfer of ballast water from co astal (i.e., domestic) sources is an important issue by itself, re sulting in discharge of large volumes at many ports (e.g., Valdez, Alaska and Chesapeake Bay), and can lead to unwanted biological invasions. Relatively li ttle 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 critic al 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 ne w 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 signi ficant confusion about whic h 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 Asse ss 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 sampli ng of vessel arrivals across the country, to include different vessel classe s, 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 begiven 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 vesse l” 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 de scriptions of common errors and how to avoid them. 5. Improve U.S. Coast Guard database for Vessel Arrivals. Although vessel arrival data co llected 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. Speci fically, the arrivals databa se could not be used to distinguish foreign versus coastwise traffic. In October 2001, the U.S. Coast Guard databasebegan 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 colle ct 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 submissi on would greatly redu ce 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 e ffort in data entry and time needed to make the data accessible. The Clearinghouse provides mechanisms fo r electronic submission, including (1) transmission of MS Excel TM

# 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/ball ast.htm) for the past 18 months. We recommend that the U.S. Coast Guard promote and encourage, to the maximum extent possible, the elec tronic 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 coas tal 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 arri vals 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 BJul-99Aug-99Sep-99Oct-99Nov-99Dec-99Jan-00Feb-00Mar-00Apr-00May-00Jun-00Jul-00Aug-00Sep-00Oct-00Nov-00Dec-00Jan-01Feb-01Mar-01Apr-01May-01Jun-01Arrivals Reported


# 500 1000 1500 2000 2500 3000 3500 4000 4500Percent Reporting


# 0 25 50 75 100

Clearinghouse BW Forms MARAD Arrivals Percent Reporting 2000 2001 1999



# Figure 5. Monthly reporting rates for the nati on by foreign arrivals from July 1999 to June 2001. Data are from National Ballast Survey (Clearing house) 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 75 100 

# Gulf of MexicoArrivals ReportedPercent ReportingJul-99Aug-99Sep-99Oct-99Nov-99Dec-99Jan-00Feb-00Mar-00Apr-00May-00Jun-00Jul-00Aug-00Sep-00Oct-00Nov-00Dec-00Jan-01Feb-01Mar-01Apr-01May-01Jun-01 

# 0 200 400 600 800 0 25 50 75 100 

# West Coast


# Figure 6a. Monthly reporting rates for East, Gulf of Mexic o, 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

AlaskaJul-99Aug-99Sep-99Oct-99Nov-99Dec-99Jan-00Feb-00Mar-00Apr-00May-00Jun-00Jul-00Aug-00Sep-00Oct-00Nov-00Dec-00Jan-01Feb-01Mar-01Apr-01May-01Jun-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 

# HawaiiArrivals ReportedPercent 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 BJul 1999Aug 1999Sep 1999Oct 1999Nov 1999Dec 1999Jan 2000Feb 2000Mar 2000Apr 2000May 2000Jun 2000Jul 2000Aug 2000Sep 2000Oct 2000Nov 2000Dec 2000Jan 2001Feb 2001Mar 2001Apr 2001May 2001Jun 2001Reporting Forms 

# 0 50 100 150 200

No Exchange Some Exchange Undetermined Exch 

# Figure 7. Nationwide monthly reported ballas t water discharge by management strategy. Data from the National Ballast Survey (Cl earinghouse) 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 = 2652 BW Forms N = 433 BW Forms N = 139 BW Forms

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


# Figure 8. Proportion of ships dischargi ng ballast water by coastal region and management strategy. Data from the National Ballast Survey database (Clearinghouse) (July 1999 to June 2001). 34

# APPENDIX BJul 1999Aug 1999Sep 1999Oct 1999Nov 1999Dec 1999Jan 2000Feb 2000Mar 2000Apr 2000May 2000Jun 2000Jul 2000Aug 2000Sep 2000Oct 2000Nov 2000Dec 2000Jan 2001Feb 2001Mar 2001Apr 2001May 2001Jun 2001Volume 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 ballastwater discharged by coastal region and management strategy. Data from the National Ballast Survey database (Clearinghouse) (July 1999 to June 2001). 36

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# Depth < 2000 m or within 200 nm coastal boundary # 

# Reported ballast water exchange locations 

# z 

# Figure 11. Reported ballast water exchangelocations (end-points of exchange) for individual ballast tanks on ve ssels 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 arri vals 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 balla st 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 s how subtotals for broad coastal regions.U. S. CoastCOTPZ# BWR Forms Year 1# MARAD ArrivalsYear 1% Reporting RateYear 1# BWR Forms Year2# MARAD ArrivalsYear 2% Reporting RateYear 2Total BWR FormsTotal MARAD Forms% Reporting RateCumulative 

# 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 volunt ary 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. CoastCOTPZ# 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. CoastCOTPZ# 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% 

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# APPENDIX B Table 4. Compliance with voluntary guideline s by volume for management of ballast water during period from July 1999 to June 2001. Shaded rows show subtotals for broad coastal regions.US CoastCOTPZNo 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% 

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# 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 assigne d 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%



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# APPENDIX B Table 6. Comparison of no ballast on board (NOBOB) and ballast on board (BOB) vessels and tanks based on total number of fore ign 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%



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# 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. Reporti ng 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