Position Papers

Uniform Regulation of Ballast Water


Ballast water regulations that are protective of the environment, maintain efficient waterborne
commerce on the Great Lakes and St. Lawrence Seaway, and are binationally compatible and equitable.


Ballast water discharges are critical to the safe operation of vessels.  The maritime industry has established best management practices and technical innovations to ensure the Great Lakes ecosystem is protected.  Great Lakes stakeholders pushed for a better way to regulate ship discharges other than the Vessel General Permit (VGP) and individual State regulations.  The Vessel Incidental Discharge Act (VIDA) empowered the U.S. Environmental Protection Agency (USEPA) and the U.S. Coast Guard (USCG) to establish uniform federal vessel discharge requirements.

On October 26, 2020, the USEPA published the proposed Vessel Incidental Discharge National Standards of Performance to begin implementing VIDA. The proposal included general standards and vessel-specific standards for 20 discharges incidental to the normal operation of a vessel.  The USEPA proposal did not require vessels operating exclusively on the Great Lakes (“Lakers”) to meet the numeric ballast water discharge standard or install a ballast water management system (BWMS).  On October 18, 2023, the USEPA published a supplemental notice to the 2020 proposal. The 2023 supplemental notice continued the stance that BWMS were not required for existing Lakers but proposed the definition of a “New Laker” based on a vessel’s construction date after the effective date of future USCG VIDA implementation regulations. Due to the lack of technologies that can reliably operate in the Great Lakes, USEPA is considering an “equipment standard” for “New Lakers”. In short, this would require “New Lakers” to install BWMS but not achieve the discharge standards.

GLMTF supports specific aspects of the USEPA proposed regulations, but GLMTF does not agree with establishing a requirement for “New Lakers” based on an “equipment standard” for a technology that does not exist.  USEPA also published the draft consent decree with environmental groups that agrees to finalize the USEPA “VIDA” regulations by September 23, 2024. 

GLMTF also supports a petition submitted by the Lake Carriers’ Association to the Federal Maritime Commission on March 6, 2020, citing unfair practices by the Government of Canada in requiring U.S.‑flagged lakers to install a BWMS on any vessel operating in Canada, even if that is a U.S.-flagged vessel bringing U.S. cargoes and not discharging any ballast water in Canadian waters. 

No change has occurred on the Transport Canada ballast water regulations impacting some US-flagged vessels by September 2024. The Canadian regulation places an undue burden on U.S.-flagged Lakers by requiring equipment that significantly impacts the operation of vessels.  The estimated compliance cost for the U.S.-flagged Great Lakes fleet is $778M (2022$).  The Canadian regulation would decimate U.S.-flagged Lakers.  Forcing this equipment on vessels not discharging in Canadian waters and without any evidence of operability and effectiveness is absurd.


Continue working with the USEPA, USCG, the eight Great Lakes States, and other stakeholders to develop federal vessel discharge regulations for the Great Lakes that are protective and will align with the operational requirements of the U.S.-flagged Great Lakes fleet.  Work with our federal partners to revise the Canadian regulations and make them fair and compatible with vessel operation.