Environmental Engineering Reference
In-Depth Information
Even with all these advantages, the Great Lakes shipment of coal, iron ore,
and limestone can sometimes be messy, as the material ends up on the deck
or as residue in the holds of the ship. This residue and spillage, termed dry
cargo residue (DCR), created safety and maintenance issues and had to be
addressed to maintain an efficient and safe shipping operation. Since the
late 1800s the issue had been addressed by washing or sweeping the DCR
overboard, either in port or more recently away from shore once the ship was
underway. Around 2000, this practice started to generate interest and concern
because of potential environmental impacts and inconsistencies with provi-
sions of the Clean Water Act and Great Lake treaties with Canada. In recog-
nition of the issue, the U.S. Congress mandated that the U.S. Coast Guard
(USCG) develop regulations addressing the environmental and treaty/Clean
Water Act concerns. Congress considered the USCG the appropriate entity
to address the issue because they had a strong and longstanding presence
on the Great Lakes; they had maritime safety, shipping, and environmental
protection responsibilities on the Great Lakes; and they had the confidence
and respect of most stakeholders who generally considered them unbiased.
The USCG (2008) promulgation of rules governing management of DCR
constituted a federal action with potentially significant environmental
impacts. Thus they were required to comply with NEPA and chose to pre-
pare an EIS. The Coast Guard's DCR EIS provides another example of wisely
and narrowly stating the purpose and need in order to facilitate alternative
development and solicit appropriate and meaningful stakeholder input (see
ChapterĀ 10 for summary of the USCG DCR program and EIS). Having dealt
with DCR for decades, the USCG was very familiar with the issues and
current management practices, so they were well informed as they devel-
oped the purpose and need statement. They knew from their experience
and interaction with environmental groups for over a decade that there was
concern that the current practice had significantly degraded the Great Lakes
ecosystem, and also the impression of various stakeholders was that the
Great Lake carriers could easily contain the sweepings for discharge at port.
They also knew that retaining the large volume of water associated with
DCR sweeping would be impracticable at best and at worst a safety hazard
to the stability of the ship because of the shifting weight when the carriers
were underway.
3.4.2 USCG Rulemaking for DCR Discharge in
the Great Lakes: Purpose and Need
The task of developing a purpose and need statement was simplified not
only due to the USCG's extensive background and familiarity with the issues
but also by their mandate. They had a very specific directive from Congress
to develop the DCR management regulations summarized as balancing
economic viability of the Great Lakes shipping industry and environmental
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