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Testimony at the International Joint Commission’s 11th Biennial Public Forum

Presented by Jennifer Nalbone, Great Lakes United
October 20, 2001 Montreal Quebec

Good afternoon and thank you for this opportunity to speak. My name is Jennifer Nalbone and I am the Habitat and Biodiversity Coordinator for Great Lakes United. I am here to make recommendations to the International Joint Commission on behalf of Great Lakes United on issues seriously impacting the biodiversity and integrity of the Great Lakes – St. Lawrence River. Specifically, I would like to address the constant influx of aquatic nuisance species – or exotic species—from the ballast water of foreign ships.

The direction and approach that the Great Lakes regulatory agencies have taken to address exotics has not been the immediate, 100% effective solution—which is to prohibit foreign ships from deballasting at any time within the basin. As you know, the Great Lakes regulatory agencies have been working for almost 10 years on policy, treatments and technologies that could be used to remove or kill exotic species in ballast water before discharge. Great Lakes United has been working within this context, as the only environmental representative on the federally mandated Great Lakes Aquatic Nuisance Species Panel, to ensure that policy and technology proves effective, environmentally benign and progresses rapidly.

I would like to state to the International Joint Commission that we have that proven, effective, environmentally benign technology, and we desperately need technology onboard ships.

Currently, we have technology (the combination of UV radiation and filtration) that has proven to be effective removing the vast majority of organisms from water in large scale barge tests, and is being validated onboard cruise ships.

This technology does not compromise the chemical integrity of a receiving water body due to biocide treatment residual or byproduct. This technology must be tested and placed onboard ships if we are going to make critical progress towards the goal of prevention of new introductions into the basin.

But what we are seriously lacking—and what is holding up the investment of large amounts of money from the private technology industry and the commitment of the shipping industry—is a lack of a standard.

We were lacking a standard 2 years ago in Minneapolis at the last IJC biennial—where the need for a standard was a primary recommendation from the IJC sponsored workshop on exotic species policy. Today, there is still no standard.

The recommendation on behalf of Great Lakes United to the International Joint Commission is that a ballast water treatment/discharge standard be set that is at least effective as the proven UV/filtration technology and no less environmentally benign (and chemical free).

We have the benchmark, we must move forward. Set the standard to this benchmark. Different technology will come that exceeds the effectiveness of this UV/filtration system, and we must work to improve our standard and improve our ability to protect the integrity of the Great Lakes – St. Lawrence River. But today we can and must more forward. Set the standard to this benchmark: at least as effective as the proven UV/filtration technology and no less environmentally benign and chemical free.

I would also like to make a comment on the status of fish populations. Native Great Lakes – St. Lawrence River fish populations are in flux—being negatively impacted by exotics, the purposeful stocking on non-native fish, poor water quality, widespread land use, resource extraction on land and in the water, intensive fishing, dredging, pipeline trenching, and will be significantly impacted in the next few decades by climate change.

Fish managers have a daunting task in light of all these threats. But managers must improve efforts to protect, maintain and rehabilitate native fish populations in the Great Lakes – St. Lawrence River—the species best suited to adapt to a dramatically changing aquatic ecosystem. I would like to provide to the International Joint Commission a scientific proceedings (called Taking Stock of our Future) on the impacts of non-native fish stocking on the biological and genetic integrity of the Lakes and recommend that fish managers aggressively protect and rehabilitate native fish populations, and strive to phase out the extensive stocking on non-native fish in the basin.

Please let me conclude by saying that more and more scientific, economic, community and spiritual leaders are alerting us that we are causing massive environmental change due to our societies inability to harmoniously exist within the environment. We must take aggressive action now. Our society only has two choices, we can choose to fight this environmental change—we can try to force the Lakes to produce a certain quantity and species of fish or we can try to force accessibility to the lakes through extensive dredging and channel modification. We can try to force the environment to meet our unsustainable expectations, which will only further accelerate environmental decline. Or, we can choose to take a new approach and develop and manage sustainably, responding to and living within a changing environment. It is gravely necessary that we do the latter. And it is never a better time to begin than now.