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Statement of G. Tracy
Mehan, III
Assistant Administrator for Water
U.S. Environmental Protection Agency
Before the Subcommittee
on Fisheries, Wildlife and Water
Senate Committee on Environment and Public Works
June 17, 2003
Good morning, Mr. Chairman and Members of the Committee. I am Tracy Mehan, Assistant Administrator for
Water at the U.S. Environmental Protection Agency (EPA).
I appreciate and welcome this opportunity to discuss the provisions of S.
525, and to consider the continuing challenges ahead to protect water quality, human
health and the environment against invasive species.
INTRODUCTION
The Environmental Protection Agency shares the Subcommittee’s
concerns about protecting the Nation’s waters against invasive species. We commend the Subcommittee and others for
bringing attention to the problems and threats created by invasive species. As you may know, I came to EPA from Michigan, the
Great Lakes State, where interactions among over 160 known aquatic invaders have severely
affected the local ecosystem structure. Introductions
can create new competition, change trophic levels, alter habitat and impact species
interaction. Invasive species have become one
of the greatest threats to U.S. waters and ecosystems.
In fact, invasive species are regarded by biologists worldwide as the second
greatest threat to biodiversity, behind habitat loss.
Invasive species are also a costly economic problem, causing the United
States billions of dollars worth of damage each year.
The complexity of the freshwater, estuarine and marine ecosystems,
combined with the increased rate of unwanted introductions and more susceptible
environments, contributes to making invasive species a major challenge in U.S. waters. Invasive species can successfully invade aquatic
ecosystems through a wide variety of pathways, including but not limited to vessel
activities, aquaculture, aquarium trade, fish stocking, live bait, and research
activities.
Most recently, vessels have been the major focus for invasive species
issues. As ballast water is drawn into a
ship, living organisms are removed from their native water environment and brought on
board the vessel. Then these organisms may
be discharged into a new environment. Survival
in a new environment is based on a number of physical, chemical and biological factors,
such as temperature, salinity, and the presence of other organisms that might prey upon
the invaders. Advanced ship technology is
also playing a role in invasive species survival by allowing ships, and any hitch-hiking
organisms, to travel faster and farther. It
is estimated that more than 10,000 marine species (e.g., zebra mussel, Asian clam, green
crab) are transported each day in ballast water, allowing new invasions to occur regularly
in coastal waters.
Other vessel vectors that are of great importance are hull fouling,
i.e., organisms attached to the hull, and No Ballast on Board or (NOBOB) vessels. NOBOB vessels contain sediments and water slurry
that is unpumpable and may get resuspended and discharged. Studies indicate that NOBOB
vessels can carry viable organisms in the sediment and residual ballast water, creating
additional opportunities for the establishment of invasive species. Over the past 9 years, approximately 85 % of all
ships entering the Great Lakes via the St. Lawrence Seaway have been NOBOB vessels. The remaining 15% of the vessels entering the
Great lakes were required to perform ballast water management. However, the Great Lakes are still being invaded
by non-indigenous species, at an average of one invader every eight months. Approximately fifteen new species have invaded the
Great Lakes since mid oceanic exchange of ballast water was mandated in 1993. This is the same number of invasions that occurred
during the 1970s and 1980s, indicating that current ballast water management efforts are
not completely effective. Overall, the
current rate of invasions in the Great Lakes is 66 percent higher than one hundred years
ago.
The impacts of invasive species are immediate and often irreversible. If left unchecked, the number, density, and rates
of species transfers are expected to increase, and along with them, impacts on our
ecosystem, socio-economic well-being, and human health.
Prevention, reduction, and eradication are all integral parts of dealing
with invasive species. Prevention is critical
to success, as once invasive species have become established, eradication is often not
an available or successful tool. In
order to be most effective, we need an integrated national response. We need management programs, including regulatory
and non-regulatory approaches, rapid response efforts, early-warning systems, development
of control technologies, research, monitoring and education. Aggressive efforts are vital, otherwise
introductions will continue to destroy our native environments and our coastal resources.
EPA ACTIVITIES
Faced with the scope and magnitude of this threat, our collective
efforts to develop policies, conduct research and make programmatic decisions, informed by
rigorous scientific and technical studies, are crucial.
The control of invasive species is important to EPA, and we look to our
partners in the U.S. Coast Guard, other Federal agencies, States and Tribes, and the port
and shipping industries to move expeditiously to help us meet this major challenge to the
health of our nation’s coastal and ocean resources.
We look forward to expanding our partnerships as we make progress against
these invaders.
EPA continues to work with the Aquatic Nuisance Species Task Force,
chaired by U.S. National Ocean and Atmospheric Agency (NOAA) and U.S. Fish and Wildlife
Service (FWS), and the National Invasive Species Council on issues ranging from the
national and international control of ballast water discharges to the regional management
and control of individual invasive species. As a member of the U.S. delegation on
the Marine Environment Protection Committee to the International Maritime Organization,
EPA is helping to negotiate an international ballast water treaty and standard to address
ballast water discharges from ocean-going vessels.
EPA is also assisting the Coast Guard in the development of mandatory
ballast water management regulations and in the development of standards for ballast water
discharge. These regulations are vital to our
ongoing efforts to prevent invasions from ballast water discharges. EPA has helped to prepare the environmental
analysis for the management rule, and we will be assisting in the development of the EIS
for the standards rule. This spirit of
cooperation is not only mutually beneficial to our agencies, it enhances our ability to
address this difficult problem.
EPA's Office of Research and Development (ORD), in partnership with
other agencies and organizations, is involved with numerous invasive species research
activities, including developing models which could help to identify which ecosystems are
more susceptible to invasions. These models
are being developed to identify the multiple stressors on a particular ecosystem that
could increase its vulnerability.
The Environmental Technology Verification (ETV) Program is another
example of our cooperative efforts with Coast Guard and the private sector. The Coast Guard is interested in developing
testing protocols to support its efforts to establish treatment standards and the
certification of ballast water treatment systems. Such
treatment systems may allow for safer alternatives to the current practice of open ballast
exchange. The ETV Program will test new
ballast water treatment and management technologies as they become available in the
market. This EPA program was created as a
means to accelerate the acceptance of new environmental technologies in the marketplace
through the independent verification of vendor performance claims of any treatment system
for any discharge of concern.
EPA also has developed partnerships for continued research and action
regarding invasive species. The partnerships
involve State and local resource management agencies, non-profits, the National Estuary
Program (NEP), and universities. The NEPs, in
particular, have numerous activities that play a key role in targeting many of the
challenges from invasive species. NEPs have
established partnerships in education and outreach, and have contributed to the
development of rapid assessments and baseline inventories for invasive species. NEPs also have played an integral role in
developing model monitoring and rapid response programs for invasive species. EPA has used Clean Water Act Funding for these and
other activities that address invasive species. We
believe this is consistent with Section 101 (a) of that Act, which states, “The
objective of this chapter is to restore and maintain the chemical, physical, and
biological integrity of the Nation’s waters.”
Partnerships and collaborative efforts are key to combating invasive
species. I am encouraged by the multi-faceted
opportunities for partnerships that we have within EPA, among Federal agencies, with the
States and Tribes, and with multiple industry and community representatives.
S. 525
The bill under consideration by this Subcommittee introduces many
actions intended to help address the issue of invasive species. For example, the bill addresses the risk of
invasion through vectors other than ballast water. The
bill also acknowledges EPA’s expertise and involvement in responding to the
challenge.
The goals and concepts behind the actions set forth in S. 525 are
beneficial to combating invasive species. However,
the time lines and authorizations provided are of significant concern. An average rule can take 4 to 7 years to complete
and that does not take into account the complexity of the invasive species issue. The bill introduces many actions in addition to
the new regulations. If possible, the actions
should be prioritized to appropriately use the authorized funding in the bill. As the bill stands now, it will be difficult to
complete all of the actions, without at least full appropriation of the authorized
funding.
The bill appears to identify many of the same actions for a number of
different agencies. Although agencies need to
work together to combat the issues of invasive species, different agencies should have
different responsibilities so as not to duplicate work efforts. In addition to the duplicative work efforts,
it is difficult to determine which agency has the primary role in some of the actions.
The bill provides for sediment management in transoceanic vessels to
be included as a best management practice. The
bill also recognizes the importance of addressing potential introductions of invasive
species from no-ballast-on-board (NOBOB) vessels, particularly in light of the volume of
such vessels in the Great Lakes.
The bill also addresses the issues of ballast water standards. Specifically, it sets an interim standard of 95
percent removal, which we believe raises a number of technical issues. Removal relies on laboratory testing which raises
technology maintenance and durability issues. Percent
removal also does not adequately address large volume discharges, because discharging 5
percent of a tanker ship’s volume could still release millions of organisms per
liter. We believe that the standards should
be based on concentration and size of organism, similar to discussions with the
international community. Having an interim
and a final standard could have the unintended effects of stalling development of a final
standard or misdirecting technology development away from more environmentally protective
approaches. EPA is also concerned that the
Bill identifies and designates both EPA and the Coast Guard as regulating authorities, one
for each standard. EPA and the Coast Guard
would like the opportunity to work further with the Subcommittee in order to clarify
specific agency roles, and define a more
appropriate schedule, and discuss the need for an interim standard. We would also be happy to provide further
technical assistance on this bill. We also
note that new spending authorized by this bill that is not currently included in the
President’s Budget, and as such, these actions must be considered within existing
priorities.
CONCLUSION
Tremendous progress has
been made by EPA and our many Federal, State, Tribal, local, and private partners in
cleaning up our waters over the last decade. EPA’s
experience in addressing difficult issues regarding the health of our environment can help
us protect them from these harmful invaders. We
at EPA appreciate your support and commitment to these vital goals, and look forward to
continuing a collaborative effort to protect and restore our Nation’s waters.
This concludes my prepared remarks. I would be happy to address any
questions you may have at this time.
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