Background on Case Studies - Environmental Impact Analysis: Process and Methods - page 363

10.2 U.S. Coast Guard Dry Cargo Residue Management EIS

The natural resources and shipping lanes in the Great Lakes basin create a
“perfect storm” for manufacturing and other commercial/industrial activi-
ties, thus creating one of the major economic engines of the United States.
The abundance of easily extractable iron ore at the western end of the Great
Lakes, the coal resources in both the eastern and western ends and the
limestone present in the center of the basin provide the necessary materi-
als and an optimum opportunity for steel manufacturing. In the nineteenth
century this opportunity was recognized and it has been realized through
the efficient, inexpensive, and timely transport of the material via Great
Lakes carriers (large lake-going cargo vessels up to 300 m long) between the
sources of materials and manufacturing centers. These Great Lakes carriers
are also heavily involved with the transport of other dry cargo originating
in the Great Lakes Basin including grains, stone for construction aggregate,
and even salt (there is a large salt deposit under Lake Erie offshore from
Cleveland, Ohio).
The Great Lakes carriers load, transport, and unload an annual average of
over 100 million tons of iron ore (which is preprocessed to marble size pel-
lets called taconite), coal, limestone, and other materials (U.S. Coast Guard
(USCG) 2008). During the process some of the material inadvertently spills
on the deck and within the bowels of the ship. Historically this spilled dry
cargo residue (DCR) has been swept overboard in order to maintain a clean
and safe working area for the ship's crew. This has resulted in an estimated
500 tons per year of DCR discharged to the Great Lakes since the late 1900s
(USCG 2008). This common and historic practice of DCR sweeping and dis-
charge did not change with the passage of the Clean Water Act in 1972 or the
negotiation of treaties between the US and Canada addressing Great Lakes
environmental protection even though the practice was arguably a violation
of both.
Recognizing this potential conflict with regulations and treaties, in the
1990s, the USCG developed and issued interim regulations governing the
discharge of DCR and the U.S. Congress authorized them to develop per-
manent regulations that balanced environmental protection and the con-
tinued viability of the Great Lakes shipping industry. Since promulgation
of the regulations was a major federal action potentially affecting the envi-
ronment, the USCG prepared an EIS under NEPA. The process was tiered
because following the completion of the original EIS (USCG 2008), the USCG
felt there was inadequate information regarding the economic impact on the
shipping industry and the effectiveness of various DCR discharge manage-
ment options was not well documented. Thus they issued an interim rule
and commitment to continued study of the issues, preparation of a tiered EIS
(currently under review), and promulgation of a final rule.