Proposed ballast water regulations fall short, says WWEMA
Water and Wastewater Equipment Manufacturers Association (WWEMA) is gravely concerned with the approach being taken by EPA to regulate ballast water discharges in its Draft National Pollution Discharge Elimination System (NPDES) General Permits for Discharges Incidental to the Normal Operation of a Vessel...
• Regulation will do little, if anything, to prevent further release of invasive species into U.S. waters
WASHINGTON, DC, July 31, 2008 -- Water and Wastewater Equipment Manufacturers Association (WWEMA) is gravely concerned with the approach being taken by Environmental Protection agency (EPA) to regulate ballast water discharges in its Draft National Pollution Discharge Elimination System (NPDES) General Permits for Discharges Incidental to the Normal Operation of a Vessel and contended in their July 31, 2008 response to Docket ID No. EPA-HQ-OW-2008-0055 that such an approach will do little, if anything, to prevent further release of invasive species into the waters of the United States (U.S.). This proposed rule could potentially stifle the development of urgently needed ballast water treatment technologies that can effectively kill or remove aquatic nuisance species (ANS) that have wreaked havoc on the U.S.'s ecology and economy.
In summary, WWEMA urged the need for uniform, national standards for ballast water and a treatment system approval process.
For the better part of eight years, ballast water standards have been under development while some 4,000 invasive species are being carried in ballast tanks by ships entering U.S. waters every day, according to the World Wildlife Fund. In WWEMA's view, EPA is missing a critical opportunity by not issuing national numeric treatment standards for ballast water discharges, instead opting to only propose use of management practices by vessels for controlling the release of ANS from ballast water discharges (e.g., ballast water exchange and saltwater flushing). At a minimum, the U.S. should ratify the International Maritime Organization (IMO) convention and EPA should adopt the IMO ballast water management discharge performance standards as recently called for by our nation's own National Academy of Sciences.
Failure to ratify the IMO convention and adopt the IMO standard is also placing U.S. industry in an extremely uncompetitive situation with U.S. manufacturers of ballast water treatment technology having to petition other nations to represent them when applying for Type Approval. U.S. industry will suffer as foreign competition moves forward with their final approvals.
"Commercially available ballast water treatment technology exists and has been proven effective by many credible, independent organizations," said WWEMA Chairman Tom Mills of Severn Trent Services. "Lloyd's Register published a report in 2007 describing more than 20 technologies that are in various stages of development, three of which have already received Type Approval. EPA's contention that it cannot issue numeric treatment standards because technology is not yet commercially available is baseless. The reason these technologies are not in 'commercial' application is because there is no uniform, U.S. national standard requiring their use," Mills emphasized.
In closing, WWEMA urged the U.S. EPA to accept its court-enforced responsibility to move forward with a rule that will make a difference; because as proposed, the rule only protects the invasive species, not the U.S. waterways.
The Water and Wastewater Equipment Manufacturers Association (WWEMA) is a 100-year old national trade organization whose members represent the leading producers of products and technologies used in water supply and wastewater treatment applications by municipal and industrial clients worldwide. Since its formation in 1908, WWEMA and its members have advocated the importance of having sound, scientific-based national standards to ensure the adequate provision of a safe water supply and effective treatment of wastewater discharges as a means of protecting our Nation's most precious liquid asset -- Water.