January 15, 2016
Great Lakes Regional Coordinator
National Oceanic and Atmospheric Administration
Office of National Marine Sanctuaries
4840 South State Road
Ann Arbor, Michigan 48108
Re: Proposed Wisconsin – Lake Michigan National Marine Sanctuary; Docket Number: NOAA-NOS-2015-0112
Dear Ms. Brody:
Founded in 1992, Great Lakes Maritime Task Force (GLMTF) promotes domestic and international shipping on the Great Lakes. With 86 member organizations, it is the largest coalition to ever speak for the Great Lakes shipping community and draws its membership from both labor and management representing U.S.-flag vessel operators, shipboard and longshore unions, port authorities, cargo shippers, terminal operators, shipyards, and other Great Lakes interests. The men and women of the GLMTF organizations are reliant on waterborne transportation for their livelihood.
GLMTF fully supports Governor Scott Walker’s nomination of the Wisconsin-Lake Michigan National Marine Sanctuary.
To maintain the advantages that Great Lakes shipping brings (227,000 direct jobs and $3.6 billion per year savings in transportation costs, for instance), we ask that the following issues receive due consideration as the process of drafting both the Management Plan and Environmental Impact Statement begins.
Federal navigation channels in the ports and harbor approaches and at private docks must all be periodically dredged to continue current operations. The United States Army Corps of Engineers (Corps) is required to maintain the harbors of Two Rivers, Manitowoc, Sheboygan, and Port Washington. Manitowoc, as a commercial port, requires 25,000 to 40,000 cubic yards of material removal every two to three years. These ports also host recreational boaters, commercial and charter fisherman, and United States Coast Guard stations. The Corps uses the material dredged from these harbors for beneficial reuse as beach nourishment along Wisconsin’s shores. Interruption of this activity could close these ports.
Ships arriving to load or unload cargoes must ballast dockside for the safety of crew and ship. Ships will also ballast while transiting the open waters of the proposed Sanctuary to maintain trim, stability, and structural integrity. Any prohibition of ballasting could negatively impact and potentially eliminate our Lakes-based integrated and interdependent operations.
To ensure there are no deleterious impacts to our businesses related to the establishment of the National Marine Sanctuary, we ask that the boundaries be drawn such that there are not the unintended consequences of eliminating dredging and ballasting. The ports and their entrances should be excluded and the landward boundary of the Sanctuary should be below low water datum.
The historical and cultural value the Sanctuary brings large recreational, educational, and economic benefits to the area. As stated in our resolution passed November 23, 2015, GLMTF “supports the establishment of any number of marine sanctuaries on the Great Lakes, provided provision is made to allow safe and efficient waterborne commerce to continue in those waters (emphasis added).”
GLMTF is committed to moving the project forward and working with the National Oceanic and Atmospheric Administration’s Office of National Marine Sanctuaries. Please do not hesitate to reach out to us with any questions or ways we can be of further assistance.
Fraser Shipyards, Inc.
Brian D. Krus
First Vice President-Positions & Resolutions
American Maritime Officers, AFL-CIO
James H. I. Weakley
Second Vice President-Membership
Lake Carriers’ Association
John D. Baker
Third Vice President-Government Relations
Great Lakes District Council, ILA, AFL-CIO