Steven A. Fisher, Executive Director of the American Great Lakes Ports Association takes issue with the findings of a Notre Dame Ballast Water Technology research paper.
To the Editor:
In recent years, a debate has raged between the maritime industry and environmental activists regarding the appropriate regulation of ships' ballast water. This public policy discussion has unfortunately been tainted by considerable misinformation. Such misinformation fuels "issue hysteria" and leads to poorly crafted regulations. We see evidence of such regulations in California and Michigan - both of which have promulgated unworkable ballast water treatment rules.
On March 30, MarineLink.com featured a press release from the University of Notre Dame entitled “BWT: the Cost of Great Lakes Invasive Species Damage.” The research paper referenced in the press release contains questionable data and adds to misinformation.
First, the study released by Notre Dame is not new. The same research was released four years ago. It appears that the study authors have been shopping it around, trying to get it published. Second, the study employs a controversial methodology called "structured expert judgment." While the name sounds impressive, structured expert judgment amounts to nothing more than organized guessing. A quote from the research paper explains; "In an SEJ exercise, experts on a topic rely on relevant scientific research and their professional opinions to generate estimates (emphasis added) for variables of interest." We regret that data from such a questionable process will now pollute the body of scientific research done by credible institutions on vessel ballasting and invasion science.
Notre Dame researchers have unfortunately affiliated themselves with fringe groups that advocate a cessation of shipping on the Great Lakes as a solution to the ballast water/invasive species problem. Their research seeks to empower this radical view with academic legitimacy. We see this as a "win-lose" approach to public policy - one that suggests it is legitimate to protect the environment at the expense of jobs.
Great Lakes shipping is a foundation of the Midwest economy supporting 227,000 jobs and generating $34 billion in business revenue. We believe there are "win-win" approaches to the ballast water problem that will protect both the environment and jobs. For example, on March 23rd the U.S. Coast Guard issued new regulations requiring ship owners to install ballast water treatment equipment to filter and clean ballast water. These new rules will do much to minimize the future introduction of invasive species, while at the same time enabling maritime commerce to continue to serve our region.
There is no doubt that aquatic invasive species have caused damage to the Great Lakes ecosystem. As we work to solve this problem, academia has an important role to play by informing science-based decision-making. We invite Notre Dame researchers to join the hundreds of Americans and Canadians partnering to solve this problem in a constructive manner.
Steven A. Fisher
American Great Lakes Ports Association
Access the report at: /http://newsinfo.nd.edu/news/29875-new-paper-assigns-dollar-figure-to-cost-from-ship-borne-invasive-species-to-the-great-lakes