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Marine Transportation and Aquatic Invasive Species:
Comparing Hawaii and Washington Policy
by
Patricia Hildebrandt Bateman
A Thesis: Essay of Distinction
Submitted in partial fulfillment
of the requirements for the degree
Master of Environmental Studies
The Evergreen State College
March 2011
©2011 by Patricia Hildebrandt Bateman. All rights reserved.
This Thesis for the Master of Environmental Studies Degree
by
Patricia Hildebrandt Bateman
Has been approved for
The Evergreen State College
By
Martha L. Henderson, Ph.D.
Member of the Faculty
Date
ABSTRACT
Marine Transportation and Aquatic Invasive Species:
Hawaii and Washington Policy Comparison
Patricia Hildebrandt Bateman
Aquatic invasive species have detrimental economic and environmental impacts for
both the private and public sectors. Research has found that the main vector for the
transmission of aquatic invasive species is marine transportation, through ballast
and hull fouling. States have attempted to address the issue of marine
transportation and invasive species through policies and regulations, however,
inconsistencies and gaps make successfully combating aquatic invasive species
nearly impossible. This comparative policy analysis addresses the differences
between two states, Washington and Hawaii, whose economies include a high
degree of interstate transportation, yet have varying policies regarding ballast and
hull fouling. Washington and Hawaii policies have strengths and weaknesses,
however, have different compliance and success rates. This policy analysis identifies
similarities and differences between the two states, as well as current national and
international regulations. Finally, policy improvements are suggested to help reduce
the transmission of aquatic invasive species to and from both locations, placing an
emphasis on the importance of consistency when battling a national and
international issue.
Contents
1: Introduction
2: Marine Transportation Components of Concern
2.1: Ballast
2.2: Hull Fouling
3: Current Management
3.1: Ballast
3.1.1: Filtration
3.1.2: Open Ocean Exchange
3.1.3: Treatment Technologies
3.2: Hull Fouling
3.2.1: Anti‐Fouling Coatings
3.2.2: Manual Removal
4: Current Regulations
4.1: State
4.1.1: Ballast
4.1.2: Hull Fouling
4.2: National
4.2.1: Ballast
4.2.2: Hull Fouling
4.3: International
4.3.1: Ballast
4.3.2: Hull Fouling
5: Bi‐state analysis of Current Practices and Regulations
5.1: Ballast
5.2: Hull Fouling
6: Suggested Improvements
7: Conclusion
v
Figures & Images
2.1: Ballast Loading and Discharge Patterns
3.1.3: Treatment Options
4.1: Washington and Hawaii Regulations Comparison Chart
4.2.1: Exclusive Economic Zones of the United States
4.3.1: Treatment Standards Comparison Chart
vi
Acknowledgments
I would like to thank the people who have helped and inspired me while working
towards the completion of my thesis and the Master of Environmental Studies
degree.
Thank you to my reader and MES director, Martha Henderson, who guided me
through the thesis process and helped me stay on track. She provided me with
valuable insights and support. Thanks are also due to Gail Wootan, the MES
Assistant Director, who helped keep myself and other students on track when
working towards the goal of graduation.
Many thanks are also owed to my supportive family and friends. You made sure I
completed this thesis, and I appreciate the love and support. A special thanks to my
husband, Matthew, who helped me recognize when I needed to stay focused, and
who inspires me to want to make the world a better place for our future, and the
future of those we share this world with.
Thank you.
vii
1: Introduction
The transmission of aquatic invasive species due to marine transportation,
both commercial and private, has become an increasingly important question in
environmental management over the past decades. Aquatic invasive species have a
significant impact on the environment and related ecosystems and ecosystem
services; however, the transmission of aquatic invasive species is almost entirely
anthropogenic. The anthropogenic nature of this transmission leads to the need for
an anthropogenic solution, policy. Policy has been established by several
governments to address aquatic invasive species and marine transportation,
however, there is a lack of collaboration.
Increased international trade and ship transportation has contributed to
multiplied organism discharge in ports throughout the world, with approximately
eighty percent of the world’s trade volume transported via ship (National Research
Council 22), and large vessel capacities in excess of 200,000 m3 of ballast (National
Research Council 23). It is estimated that 438 million m3 of wetted surface area, also
known as the portion of the boat or vessel surface located under water, enters the
United States yearly (Smithsonian Environmental Research Center 1). Globally, it is
estimated that more than 100,000 marine species are transported each day via
ballast (Buck 1). Several preventative measures are currently being studied to help
prevent the introduction of invasive species, but the United States’ and other global
shipping leaders’ lack of a comprehensive ballast and hull fouling management plan
is problematic. This paper discusses current ballast and hull fouling management
approaches by comparing Washington and Hawaii policies and makes suggestions
1
for improving these policies to help reduce the transmission of Aquatic Invasive
Species.
Aquatic invasive species, also known as AIS, have both environmental and
economic impacts for the planet, governments, and private industry. It is clear that
aquatic invasions have created changes in food web dynamics, chemical cycling,
disease outbreaks, and species extinction rates. Invasive species are second only to
habitat loss in terms of risk to overall global biodiversity (Gramling 8). The rate of
known marine invasions in North America has increased exponentially over the past
two hundred years (Carlton et al 3). Not only is the number continuing to rise, there
is also an increase in the variety of species being transported, the types of habitats
they infest, and the global regions they are impacting. The Great Lakes have seen
over sixty new invasive species since 1960 and San Francisco Bay over seventy since
1970 (Gramling 8).
Economic impacts of invasive species include fishery losses, drop in tourism,
damage to municipal water systems, as well as the money spent for eradication of
invasive species. In 2001, it was estimated that the U.S. alone suffered over $100
billion per year in economic losses due to invasive species (National Ballast
Information Clearinghouse 1).
A prime example of environmental and economic loss due to AIS is the case
of the zebra mussel and the Great Lakes, which created an impetus for the Invasive
Species Act. The zebra mussel, an import from the Black Sea, began establishing
itself in the Great Lakes in 1988. Since then, the mussel become established north
to Quebec, south to New Orleans, and as far west as Oklahoma, with small
2
infestations as far west as Oregon and Washington. The mussels are inedible to
most of North America’s indigenous species, consequently allowing their rapid
proliferation into massive colonies and strangling native ecosystems. The muscle
clogs industrial and municipal water pipes causing closures to accommodate manual
removal. The mussels filter out phytoplankton at a high rate, changing entire
ecosystems they inhabit. It has been estimated zebra mussels cost the United States
$5 billion each year in economic losses and control efforts (Harder 234).
While comparing AIS policies for Washington and Hawaii may not seem
intuitive due to differing climates, comparing the two states offers an excellent
opportunity to examine how marine transport in different environments can result
in dispersal and establishment of aquatic invasive species. The two states have
economies that rely heavily on marine transportation, experiencing approximately
500 direct cargo interactions annually (Kaluza et al, 2172), resulting in high exposure
to AIS, and reinforce the need for stringent and comprehensive policies regardless of
origination and destination of travel.
Current research in the area of marine transportation, ballast, and hull
fouling and the resulting invasive species infestations has not created a cohesive or
thorough body of knowledge. It is widely accepted and supported that commercial
trade results in rising annual and cumulative rates of invasion (Meyerson & Mooney
200). Current research focuses mainly on localized infestations, usually evaluating
the situation on a local scale, rarely focusing on a nation wide or global scale.
Detailed quantitative research has been limited and focused on invasion patterns
rather than the impacts of the invasions (Meyerson & Mooney 202). However,
3
multiple efforts have been made to address increased concerns in regards to
globalization, invasive species, and biodiversity threats.
Comparative policy analysis is lacking in current literature. The most
comprehensive comparisons available have been located in presentation notes and
conference proceedings, such as Jason Savarese’s presentation at the 14th Biennial
Coastal Zone Conference, entitled “Preventing and managing hull fouling:
international, federal, and state laws and policies.” Due to the lack of
comprehensive comparisons, it is difficult to establish current comparison
methodology, resulting in an increased need to provide a comprehensive source of
current regulations impacting Washington and Hawaii prior to providing a specific
comparison. Comparative analysis of current regulations will allow Washington and
Hawaii, as well as surrounding states, to make educated decisions about
comprehensive and effective policies, and help them to identify areas in which they
can improve and collaborate. This thesis works to identify the similarities and
differences, as well as suggest possible improvements to current policies.
2: Marine Transportation Components of Concern
In order to understand the relevance of aquatic invasive species and marine
transportation, it is important to understand the different components of marine
transportation that are integral in the transmission of invasive species. The main
areas of concern are ballast and hull fouling. These two causes are defined here:
4
2.1: Ballast
Ballast is any solid or liquid placed in a ship to increase the depth of
submergence of the vessel in the water, to change the trim, to regulate stability, or
to maintain stress loads within acceptable limits. It may also be brought on board to
compensate for drinking water or fuel consumption (Carlton et al 3) and may be sea
water, fresh water, or suspended or settled sediments (National Research Council
vii). Ballast is taken on at one port when the cargo is off‐loaded by the vessel, and is
usually discharged at another port when cargo is received, as seen in image 2.1
(Center for Coastal Resources 1).
Image 2.1: Ballast loading and discharge patterns.
Image courtesy of the International Maritime Organization
5
Vessels take on ballast usually by pump or gravitation. On a vessel, intakes
are located several meters below the water line, and are protected by a grate or
strainer, equipped with openings between 1.0 and 1.5 cm in diameter (Gramling 6).
Ballast tank configuration varies greatly from vessel to vessel, and may consist of
several small tanks, or one large tank (National Research Council 25). When ballast
water is brought on board a vessel, suspended sediment will settle to the bottom of
the tank, and will likely not be discharged during the ballast water disposal or
exchange. Settled sediments are also of concern in reference to AIS transmission, as
resulting sediments from the tanks and holds of vessels are removed only on an
intermittent basis through a variety of methods, either in‐water or on shore. Prior
to removal from the vessel they can create a viable substrate for organisms brought
on board via ballast water, and result in a high level of organism survival and
reproduction.
Ballast water that is brought on board a vessel when it is not carrying cargo
contains organisms living in the surrounding waters and sediments, ranging in size
from microscopic viruses to twelve inch fish (Globallast 2002, 1). The size of
surviving organisms varies depending on the uptake method, which can be
gravitational or pump fed. Larger organisms tend to survive when gravitation is used
exclusively to take on ballast, while larger organisms will die when passing through
the pumping mechanisms (Carlton et al 5). Surviving organisms have the potential to
become AIS (also referred to as bio‐invaders, non‐native species, alien species, or
exotic species) in the port of ballast discharge. Research has shown that commercial
6
shipping may account for up to eighty percent of aquatic invasive species in coastal
habitats. Up to 300 species have been identified in the ballast water of a single
container ship (Dobroski 6). These include bacteria, microbes, small invertebrates,
and the eggs, cysts, and larvae of various species. The problem of AIS transmission in
ballast water is only compounded by the fact that virtually all marine species have
life cycles that include at least one planktonic state (Globallast 2002, 2) meaning
species which are normally thought of as anchored can still be transmitted. Varying
species and density of AIS are currently found worldwide. Widespread AIS include
the North American Comb Jelly, the North Pacific Seastar, the Zebra Mussel, Asian
Kelp, the European Green Crab, and the Mitten Crab (Globallast 2008, 1).
2.2: Hull Fouling
Hull fouling is the settlement and accumulation of microorganisms, plants,
algae, and animals on the underwater surface of a vessel or platform. Fouling
organisms are organisms that attach to submerged hard surfaces, both natural and
manmade. Fouling organisms include species such as mussels, seaweed, sea squirts,
and anenomes, as well as the associated organisms that may live on these species‐
such as bryozoans, crabs, shrimp, and sea snails. The above listed organisms can
create a fouling community that lives on the vessel and travels with it from port to
port, allowing for the introduction of new AIS (Fofonoff).
There are many factors that relate to the dispersal of AIS and hull fouling.
Factors that influence whether a vessel can successfully transfer AIS include vessel
speed, harbor residence time, voyage duration, surface area and complexity of
7
vessel, and the period of time since the vessel was last painted. Vessel areas that do
not experience wave action due to speed, such as the anchor and anchor chain, as
well as the sea chest and propeller, also tend to accumulate fouling communities at
a higher frequency than those that are exposed to higher wave action. Studies have
documented extensive fouling communities particularly on towed vessels and
recreational vessels (Takata, Falkner, and Gilmore). In Hawaii, it is believed that
fouling is responsible for more successful marine introductions than any other
vector, accounting for approximately seventy‐four percent of all AIS introductions
(Godwin). For North America, a study estimates that at least thirty‐six percent of AIS
introduced via maritime transportation was done via fouling (Fofonoff et al).
3: Current Management
Management of AIS by ballast and hull fouling can be split into two main
approaches: technical control and regulatory control. Both play important roles in
preventing AIS transmission, and it is important to understand technical control in
order to be able to craft realistic policies and regulations.
3.1: Ballast technical control
Ballast water management (BWM) is a complicated issue with several
components. Ballast water management refers to the techniques used to remove
AIS from ballast. In order to establish a better understanding of BWM, the following
sections will discuss currently used techniques for removal of AIS and techniques
currently being tested.
8
3.1.1: Intake and Discharge Filtration
Ballast water can be filtered before it enters the vessel, or filtered during
discharge. Filtering during intake is considered preferential because it allows the
organisms which have been removed to remain within their native habitat, while
organisms filtered out during discharge have to be disposed of properly so they do
not accidently contaminate the environment (Tang 412). Currently, filtration is
occurring on a basic level during most ballast intake procedures. As was stated
previously, the majority of vessels have a screen or grate on the ballast intake, in
order to prevent the intake of any large organisms. Standard intake screens filter to
the 1.0 to 1.5 cm level, which still allows for contamination by a multitude of
organisms, including viruses and bacteria (Gramling 6). According to Congelosi et al
(547), the decrease in opening size to 25 to 50 micrograms leads to effective
removal of biological matter, including macro and micro‐zooplankton.
3.1.2: Open‐ocean ballast water exchange
Open‐ocean ballast water exchange is currently the most common method
of ballast treatment occurring worldwide. It is also the recommended method for
the reduction in risk of introduction of AIS (Globallast 2008). Ballast water exchange
works in the following pattern: the vessel takes in ballast at port, travels to a certain
offshore distance (at least 200 nautical miles) and depth (at least 2,000 meters) and
exchanges the ballast in tank for open‐ocean water (Globallast 2008). Depending on
trip length, this exchange can occur only once, or many times (Gramling 6). Open‐
ocean water is then released at the arrival port.
9
Exchange is effective for two main reasons: (1) the majority of organisms
taken in by ballasting are suited to the brackish water often found in near‐shore
locations, and not to the higher salinity water of the open ocean, and vice versa.
Releasing open‐ocean organisms into the brackish near‐shore water often results in
a high death rate, as does releasing near‐shore organisms into the open‐ocean
water (Globallast 2008), (2) The density of organisms living in near‐shore waters is
significantly greater than the density of organisms in the open‐ocean. Releasing
open‐ocean water at near‐shore locations results in an overall drop in number of
organisms released (Smithsonian Environmental Research Center). Offshore
distance and depth of ballast exchange also helps to ensure the effectiveness of
ballast exchange, due to a decrease in species density with increased depth
(National Research Council 37).
There are two types of ballast water exchange: (1) Flow‐Through and (2)
Sequential. The choice of exchange method is dependent on the ballast tank
configuration of an individual vessel (Prince Williams Sound Fact Sheet 6). Flow‐
through exchange involves pumping open ocean water into a full ballast tank for a
length of time sufficient to flush the ballast water tank. Sequential is used on vessels
with multiple ballast chambers, and involves completely emptying segregated
ballast tanks, individually or in sequence, and then refilling them with open ocean
water (Prince William Sound Fact Sheet 7).
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3.1.3: Possible Ballast Treatment Technologies
Ballast water treatment can take place during different stages of the ballast
process. These treatments may be either port‐based or shipboard, and can take
place at various stages in the vessel’s journey. There are three main shipboard
treatment areas being researched and tested, and a fourth area being explored in
port‐based facilities.
Port‐based treatment involves having a facility at each port equipped with the
ability to either fill ballast tanks with previously treated water or to de‐ballast tanks into
land based treatment plant (Puget Sound Action Team 36). Shipboard treatments
include mechanical options, such as filtration, de‐oxygenation, ozonation, and cyclonic
separation. Chemical use of biocides, chlorine, hydrogen peroxide, and sodium are also
being tested at this time. Finally, the use of heat and electricity‐ such as UV radiation,
magnetic, electrolysis, and ultrasonic – are also being tested (National Research Council
53‐55).
Image 3.1.3: Treatment Options
Image courtesy of Puget Sound Action Team
11
There are varying degrees of success with these methods, but with the technologies
available at this time, it is currently considered likely that a combination of
treatment techniques will need to be utilized in order to meet desired organism
discharge standards (National Research Council 60). The lack of a universal
treatment standard, which will be discussed in the next section on regulations, has
also created an inability to successfully develop technologies, as an ultimate goal is
not known at this point (U.S. Coast Guard 2004, 3).
There are several considerations to be included when evaluating ballast
treatment techniques, beyond the ability to remove AIS. Such considerations are:
environmental impact (such as discharge of chemicals), safety, implementation cost,
and loss of transit time (National Research Council 57). The cost of implementation
is especially limiting when new treatment techniques need to be tested at the full
scale level (Globallast 2008). Currently, very few vessels have full scale shipboard
testing occurring.
3.2: Hull fouling technical control
Hull fouling is controlled through the use of two common methods: anti‐
fouling paint or manual removal. Both methods are discussed below.
3.2.1: Anti‐fouling paint
Due to the fact that fouling can be detrimental economically to the shipping
industry, preventing fouling for the purpose of vessel maintenance and efficiency
has been of high importance for many decades. Anti‐fouling compounds have
12
included arsenic, lime, mercury, and pesticides (Lewis). Currently, the most
commonly used technique to prevent hull fouling is the use of biocidal paint, which
slowly release tributyltin (TBT), an organotin based chemical. By the mid 1970’s
most oceangoing vessels had TBT based anti‐fouling paint, as the compound was
found to be highly effective at keeping the hull clean. However, studies have shown
that TBT may have significant environmental impacts. These studies indicate that
the slow release of TBT to the vessel hull also results in the slow release of the
chemical to the water column sediments, and has been linked to shell deformation
in oysters, reduced infection resistance in fish, and is a bioaccumulate in the food
chain (Nehring 343).
As a result of these findings, many countries have implemented rules and
regulations restricting the use of TBT based anti‐fouling paint. Due to these
restrictions there has been an increased use of Copper and Zinc based paints for
anti‐fouling, however, several countries and states, including Washington, have
regulations limiting the use of such products. Currently the only viable,
environmentally friendly fouling prevention option is the use of silicon‐based
coatings that result in the vessel hull being too slippery for organisms to adhere,
however, this process is not cost effective at this point in time (Takata, Falkner, and
Gilmore 4).
3.2.2: Manual Removal
In addition to biocidal paints, hull fouling is controlled by the regular manual
removal of organisms from the vessel. Vessels are cleaned during any period of dry
13
dock, but also may be cleaned while still in water. In‐water cleaning has become a
topic of concern for multiple reasons. First is that in‐water cleaning may result in an
increased sloughing of TBT based paints, increasing water pollution issues. Second is
the concern that fouling organisms which are being manually removed are still
viable in the environment they are being disposed in. Studies have shown that
upwards of seventy percent of organisms removed from hulls are still viable in the
port where they are removed, which likely is not their port of origination. Due to this
issue, in‐water cleaning may be resulting in increased AIS dispersal rates (Takata,
Falkner, and Gilmore 14). In addition, hull scraping can leave remnants of the
fouling organisms, such as shells or tissues, which in some fouling species act as a
signal for unattached organisms in the water column to settle (Railkin 256).
4: Current Regulations
There are several regulations that impact ballast and hull fouling practices.
The problem of AIS transport via ballast and hull fouling is not just a local problem,
so many state, federal, and international laws have been implemented which impact
practices. While this paper is primarily concerned with Washington and Hawaii, it is
important to understand that maritime travel is international, and international,
national, and state policies have various impacts.
4.1: State
Washington and Hawaii have greatly varying climates and oceanic
environments. Washington’s outer coast lines as well as the Puget Sound region are
14
classified as temperate cold, with an average nearshore water temperature ranging
from 44 degrees Fahrenheit in winter months to 56 degrees Fahrenheit in the
summer months (NOAA). Washington has 3,026 miles of tidal shoreline, and is
home to multiple active ports (NOAA).
Hawaiian waters are classified as tropical, with nearshore water
temperatures ranging from 71 degrees Fahrenheit during winter months to 80
degrees Fahrenheit in the summer (NOAA). Hawaii consists of eight major islands,
four of which (Hawaii, Oahu, Maui, and Kauai) are large enough to house
commercial ports, that come together to create what is known as the Hawaiian
archipelago. According to NOAA tidal shoreline calculations, Hawaii has 1,052 miles
of tidal shoreline.
The Hawaiian archipelago is about 4,000 km from the nearest continent,
making it the most isolated group of oceanic islands in the world. It also possesses
one of the most highly endemic and endangered biotas on earth, and is home to
approximately 40% of the threatened and endangered species in the United States.
Hawaii is also a major transportation hub and tourist destination. The remote
location, highly sensitive environment, and status as a transportation and tourist
destination make it exceptionally susceptible to AIS from marine transportation.
According to the Hawaii Biological Survey by the Bishop Museum, Hawaii is home to
343 total aquatic invasive species, 287 invertebrates, 24 microalgae, 12 flowering
plants, and 20 fish. Of these 343 total species 251 are a direct result of marine
transportation, either through ballast water, solid ballast, or hull fouling.
15
4.1.1: State Ballast
Currently, the legislatures in the states of California, Hawaii, Maryland,
Michigan, Oregon, Virginia, and Washington have enacted laws addressing ballast
water discharge. California, Hawaii , Michigan, and Washington have laws more
stringent than those laid out in the National Invasive Species Act (NISA), while others
do not significantly differ from NISA (American Association of Port Authorities 2).
This paper is concerned specifically with the policies of Washington and Hawaii, and
details of both follow.
Washington has enacted RCW (Revised Code of Washington) 77.120, the
Ballast Water Control Act. This RCW specifies that discharge of ballast water is only
permitted in Washington State with authorized permission, if an open ocean
exchange has occurred, any alternate treatment methods on board have been
previously approved, or that have ballast on board that originated within the waters
of Washington, the Columbia river system, or the internal waters of British Columbia
south of latitude fifty degrees north.
In order to enforce RCW 77.120, there is WAC (Washington Administrative
Code) 220‐150, which is the Ballast Water Discharge Standard and Treatment
System Approval Process. The WAC states that vessels that have not adequately
exchanged their ballast as required by RCW 77.120 must treat their ballast to meet
or exceed the state discharge standards, however, those standards have not been
set and the proposed standards are currently withheld from WAC records. WAC 220‐
150 states that vessels must report ballast water management information and
plans to discharge at least twenty‐four hours prior to entering Washington waters
16
by submitting a ballast water reporting form, either the International Maritime
Organization or United State Coast Guard version, electronically transmitted to
Washington State Fish and Wildlife.
If vessels do not meet the above standards by filing a ballast water reporting
form, retaining ballast water, exchanging ballast water, or treating water, they may
be fined up to $27,500 a day for each violation (Washington State Department of
Fish and Wildlife). Washington does allow for safety exemptions from the above
rules, however, a $500 safety exemption filing fee is assessed to cover
administrative costs to assess compliance.
In 2001, Hawaii state legislature designated the Department of Land and
Natural Resources to be the lead agency in preventing the introductions of AIS
through the regulation of ballast water discharges and hull fouling via Hawaii
Revised Statues Chapter 187A‐31. After this designation, the Department of Land
and Natural Resources created Hawaii’s Ballast Water and Hull Fouling Alien Aquatic
Organism Prevention Program. This prevention program was broken into two
phases, phase I relating to ballast water, and phase II relating to hull fouling. Phase I
sets forth proposed administrative rules, many of which were incorporated into
Department of Land and Natural Resources Chapter 13‐76, explained below. The
suggestions of this plan included: requiring a mandatory ballast management plan
on board all vessels entering state waters, required mid‐ocean ballast water
exchange with required reporting to the Department of Land and Natural Resources
48 hours prior to entering state marine waters, and required ballast water sediment
management plan on board all vessels entering state waters.
17
Hawaii’s current ballast water practices are laid forth in Hawaiian
Administrative Rules, Department of Land and Natural Resources Chapter 13‐76.
This administrative rule was put into place in August of 2007, and strengthened
Hawaii’s previously weak policy on ballast water management. Chapter 13‐76
requires that all vessels have a ballast water management plan on board, as is also
required by the United States Coast Guard. Hawaii also requires a complete ballast
water exchange outside of the Exclusive Economic Zone (200 nautical miles off
shore), and must submit a ballast water reporting form to the Department of Land
and Natural Resources and the United States Coast Guard, following Coast Guard
standards, at least 24 hours prior to arrival within Hawaiian waters. This reporting
can be done electronically or via fax, and the reporting form must be kept on board
for two years. Chapter 13‐76 clearly states that is it unlawful for the vessel master
to prevent, hinder, or interfere with the Department of Land and Natural Resources
or the United State Coast Guard’s evaluation of the vessel’s compliance to any of the
above mentioned requirements.
Vessels are exempt from the ballast water exchange requirements in Hawaii
if there is a safety risk associated with completing an exchange, if they have a United
States Coast Guard approved water treatment system on board, if it is a vessel of
the United States Coast Guard or the Department of Defense, or if the vessel is
discharging water in the port of origin of the ballast.
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4.1.2: State Hull
Washington State does not have any laws or regulations related to preventing AIS
via hull fouling. However, Washington does have regulations relating to anti‐fouling
paints and boat cleaning processes related to removing fouling organisms.
Washington regulations, explained below, are water quality based and aim to
prevent the release of toxic chemicals into the environment, but have an impact on
AIS transmittal as well.
RCW 90.48.080 states that it is illegal for “any person to throw, drain, run, or
otherwise discharge into any of the waters of this state, or to cause, permit or suffer
to be thrown, run drained, allowed to seep or otherwise discharged into such waters
any organic or inorganic matter that shall cause or tend to cause pollution of such
waters”. Washington State has interpreted this to mean it is illegal to perform
underwater cleaning of hulls that have ablative (soft and toxic) paints, and the
related fine can be up to $10,000. Washington also asks vessels to rinse visible
organisms from anchors and anchor chains prior to entering Washington State
waters; however, this is not an enforced activity.
Hawaii does not have any current laws or regulations related to hull fouling,
either for AIS or water quality reasons. The previously mentioned Ballast Water and
Hull Fouling Alien Aquatic Organism Prevention Program, phase II, was designed
with hopes of making policy suggestions aimed at hull fouling. Phase II of the
prevention program was not completed, and the Department of Land and Natural
Resources of Hawaii has stated that budget restrictions are the main obstacle
preventing further development and enforcement of hull fouling regulations
19
(Showalter 10). Hawaii does house some of the most advanced and up‐to‐date
research on hull fouling, funded by the Bernice Pauahi Bishop Museum in
conjunction with the University of Hawaii. The advanced knowledge Hawaii has
about their hull fouling situation and resulting AIS infestations lends itself well to
making thorough policy decisions.
Both ballast and hull fouling regulations for Washington and Hawaii are
summarized in Figure 4.1, allowing for quick comparison of the two states.
Figure 4.1: Washington and Hawaii Regulation Comparison Chart
Area
Reporting Requirements
(Ballast)
Exchange Requirements
(Ballast)
Discharge Standards
(Ballast)
Exemptions (Ballast)
Paint (Hull)
Cleaning (Hull)
Washington
Hawaii
24 hours prior to entering 24 hours prior to entering
Washingtonian waters.
Hawaiian waters.
Open Ocean exchange
Open‐ocean exchange
required, outside of EEZ, required, outside of EEZ,
except when coming from except for vessels
Washington, the Columbia conducting interisland
river system, or the
travel only.
internal waters of British
Columbia.
Previously proposed
No state discharge
Washington goals:
standards, no proposed
Technology to inactivate or discharge standards.
remove 95% of
zooplankton & 99% of
bacteria and
phytoplankton
Safety, military, treatment Safety, military, treatment
system on board
system on board
Copper discharge limits
No regulations
from dry‐docks‐
established in permitting
process
No in‐water cleaning,
No regulations
Vessels asked to rinse
visible organisms from
anchors and anchor chains
20
4.2: National Regulations
National regulations impact state regulations for many reasons. In the case
of ballast water and hull fouling, it is written that state regulations must meet or
exceed national regulations. Below are the minimum requirements for Washington
and Hawaii and laid forth by national policy.
4.2.1: National Ballast
The first attempt to control AIS in the United States was the Nonindigenous
Aquatic Nuisance Prevention and Control Act of 1990, referred to as NANPCA, which
established a federal program to prevent the introduction and control the spread of
unintentionally introduced AIS. The creation of NANPCA was brought on by the
destruction seen in the Great Lakes by the Zebra Mussel. The responsibilities of
implementing NANPCA were spread among the U.S. Coast Guard, the EPA, U.S. Fish
and Wildlife Services, Army Corps of Engineers, and NOAA, who worked together to
form the Aquatic Nuisance Species Task Force (Buck 4). The task force is responsible
for conducting studies and reporting to Congress in order to (1) identify areas where
ballast water exchange can take place without causing environmental damage, and
(2) determining the need for controls on vessels entering U.S. waters other than the
Great Lakes (NANPCA). Under this act, the Coast Guard is also responsible for
developing and implementing a ballast water management program to prevent the
unintentional introduction and dispersal of AIS. NANPCA also encouraged the
Secretary of Transportation (later changed to the Secretary of Homeland Security) to
21
negotiate with foreign countries, through the International Maritime Organization,
in order to establish similar international prevention and control goals (Buck 4).
The National Invasive Species Act of 1996, referred to as NISA, reauthorized and
amended the NANPCA (Buck 4). NISA created a national ballast water management
program modeled after the Great Lakes program, wherein all ships entering U.S.
waters (only after operating outside of the U.S Exclusive Economic Zone, see image
4.2.1), are directed to undertake mid‐ocean ballast exchange or alternative
measures pre‐approved by the U.S Coast Guard.
Image 4.2.1: Exclusive Economic Zones of the United States
Image courtesy of NOAA
The Coast Guard is not required to enforce exchange or treatment on a ship‐to‐
ship basis based on NISA, but was instead asked to study the compliance rates on a
voluntary basis (Buck 5). Compliance rates are currently measured by the National
22
Ballast Information Clearinghouse, which was developed jointly by the Coast Guard
and the Smithsonian Environmental Research Center. Following the first three years
of compliance studies, if non‐compliance rates were significant, the exchange or
treatment program was to become mandatory (NISA).
NISA created a Ballast Water Demonstration Program, established to
promote research and development of ballast water treatment technologies to be
used as an alternative to exchange. NISA also required the Coast Guard to study and
report to Congress on the effectiveness of currently used port‐based treatment
facilities found in Alaska, in addition to completing studies on the impacts of AIS in
Lake Champlain, Chesapeake Bay, San Francisco, Honolulu Harbor, and the Columbia
River System. Like NANPCA, NISA also encouraged negotiations with international
governments in order to establish similar goals and regulations (NISA).
As was previously noted, NISA required the establishment of a Ballast Water
Demonstration Program, which came to fruition as the Coast Guard STEP Program,
which is a Shipboard Technology Evaluation Program that aims to promote research
and development of new technologies. STEP facilitates the installation of
experimental technologies on both foreign and domestic vessels. Regulatory
incentives would grant conditional equivalencies for participatory vessels that might
not meet discharge standards if they were to become mandated by future
regulations (U.S. Coast Guard 2001, 7).
23
4.2.2: National Hull
On the federal level, the U.S. Coast Guard is the agency responsible for
addressing hull fouling. The Coast Guard has always addressed hull fouling via
yearly vessel inspections, but the federal mandatory ballast water program
mentioned above directs vessel owners to remove fouling organisms. The program
states that “Masters, owners, operators, or persons‐in‐charge of all vessels
equipped with ballast water tanks that operate in the waters of the U.S. must do the
following: Rinse anchors and anchor chains when you retrieve the anchor to remove
organisms and sediments at their place of origin, and remove fouling organisms
from hull, piping, and tanks on a regular basis and dispose of any removed
substances in accordance with local, state, and federal regulations (Showalter 3).
4.3: International Regulations
International shipping regulations are designed and enforced by the
International Maritime Organization. The International Maritime Organization,
commonly known as the IMO, is a specialized agency of the United Nations with 167
member states, and is based in the United Kingdom. The IMO’s main task is to
develop and maintain a comprehensive regulatory framework for shipping, and
includes safety, environmental concerns, legal matters, technical co‐operation,
maritime security, and the efficiency of shipping (IMO 2008).
The IMO conventions discussed below are not ratified by the United States,
and therefore do not regulate activities within Washington and Hawaii. However,
24
states often refer to these conventions as the ultimate goal when drafting their own
policies.
4.3.1: International Ballast
After fourteen years of negotiations, the International Maritime
Organization adopted the International Convention for the Control and
Management of Ship’s Ballast Water and Sediments on February 13th 2004.
The International Convention for the Control and Management of Ship’s
Ballast Water (hereafter the BWM Convention), includes 22 articles which provide
the following information:
Member states have the right to take more stringent measures for
protection then laid out in the BWM Convention, but should ensure more
stringent standards do not cause greater harm than they prevent to their
environment, human health, property or resources, or those of other states.
Member states are to ensure that ports and terminals where cleaning or
repair of ballast tanks occurs have adequate reception facilities for
sediments.
States should work to promote and facilitate scientific and technical
research on ballast water treatment technologies.
Vessels are required to have on board and implement a Ballast Water
Management Plan approved by the regulating administration, which must
include a detailed description of actions to be taken to implement the
management plan requirements.
25
Vessels must have on board a Ballast Water Record Book, which records
when ballast water is taken on board, circulated or treated for BWW
purposes, and when it is released to sea. This record book must remain on
board for two years after final date recorded.
Vessels are required to be surveyed and certified, and may be inspected at
anytime to verify that the ship has a valid certificate, to sample ballast
water, or to inspect the vessel’s ballast water record book.
States should provide technical assistance to train personnel; ensure the
availability of relevant technology, equipment and facilities; and other
actions aimed at the effective implementation of the Convention.
The BWM Convention also lays out specific discharge and treatment standards,
known as the Ballast Water Performance Standards. These standards are laid in
image 4.3.1, in comparison with United States Coast Guard Standards.
Image 4.3.1: Treatment Standard Comparison Chart
Standard
1) Organisms greater than
50 microns in dimension
IMO Regulations
Discharge Standards
<10 viable organisms per
cubic meter
2) Organisms 10‐50
microns in minimum
dimension
3) Organisms less than 10
microns in dimension
4) E. Coli
5) Intestinal Enterococci
6)Toxigenic Vibrio
cholerae
<10 viable organisms per
ml
NISA Regulations
Exchange Standards
USCG will propose
numeric discharge and
treatment standards at a
future time
No Standards
No Standards
No Standards
<250 cfu/100 ml
<100 cfu/100 ml
<1 cfu/100 ml
No Standards
No Standards
No Standards
26
According to the BWM Convention, the above requirements and standards
will enter into force 12 months after ratification by 30 States, representing 35% of
world merchant shipping tonnage. As of January 28, 2011 28 countries (Albania,
Antigua and Barbuda, Barbados, Brazil, Canada, Cook Islands, Cote d’Ivoire, Croatia,
Egypt, France, Kenya, Kiribati, Liberia, Malaysia, Maldives, Marshall Islands, Mexico,
Netherlands, Nigeria, Norway, Republic of Korea, Saint Kitts and Nevis, Sierra Leone,
South Africa, Spain, Sweden, Syrian Arab Republic, and Tuvalu) have ratified the
Convention, representing only 25.32% of world merchant shipping tonnage (IMO
2011). While the U.S. played a large part in setting the BWM Convention standards,
they have yet to ratify the Convention.
4.3.2: International Hull
Similar to Washington, there are currently no international regulations
related to controlling the spread of AIS via hull fouling, but there are regulations
related to anti‐fouling paints. The International Maritime Organization International
Convention on the Control of Harmful Anti‐fouling Systems on Ships was adopted
October 5, 2001 and entered into force on September 17th, 2008. The Convention
states that parties to the convention are required to prohibit and/or restrict the use
of harmful anti‐fouling systems on ships flying their flag, as well as ships not entitled
to fly their flag but operate under their authority and all ships that enter a port,
shipyard or offshore terminal of the signed party. The Convention also states that
all ships shall not apply or reapply organotin compounds which act as biocides, and
27
by the effective date of the Convention ships either shall not bear such compounds
on their hulls or shall bear a coating that forms a barrier preventing compound
leaching.
As of January 28, 2011 47 countries (Antiqua and Barbuda, Bahamas,
Belgium, Bulgaria, Canada, Cook Islands, Cote d’Ivoire, Cyprus, Denmark, Estonia,
Ethiopia, Finland, France, Germany, Greece, Hungary, Iceland, Japan, Jordan,
Kiribati, Latvia, Lebanon, Liberia, Lithuania, Luxembourg, Malaysia, Malta, Marshall
Islands, Mexico, Morocco, Netherlands, Nigeria, Panama, Poland, Republic of Korea,
Republic of Moldova, Saint Kitts and Nevis, Serbia, Sierra Leone, Singapore, Slovenia,
Spain, Sweden, Syrian Arab Republic, Tuvalu, United Kingdom, and Vanuatu) have
signed the IMO Convention on the Control of Harmful Anti‐Fouling Systems on
Ships, representing 75.29% of the world’s shipping tonnage. (IMO 2011). The United
States has not ratified this convention and does not abide by the requirements.
5. Bi‐State Analysis of Current Practices and Regulations
Climate differences, as described in the section on state regulations, often
indicate that aquatic invasive species would not be able to thrive in both
Washington and Hawaii. However, a lack of consistent policies and regulations in
Washington and Hawaii has directly resulted in overlapping AIS concerns.
One direct example of the AIS connection between Washington and Hawaii
is the recorded introduction of the blue mussel, also known as the Mediterranean
mussel (Mytilus galloprovincialis). Blue mussels were observed on the hull of the
U.S.S. Missouri, which was towed to Pearl Harbor, Oahu, Hawaii from Puget Sound
28
Naval Shipyard in Bremerton, Washington. Blue mussels, considered AIS in Hawaii
and Washington, were observed spawning on their arrival in Honolulu, and juveniles
were observed and identified three months later (Godwin, Eldredge, & Gaut 5).
Other examples of AIS that have been established in both Washington and
Hawaii through either ballast or hull fouling are Sargassum muticum, Schizoporella
errata, and Schizoporella unicornis. Sargassum muticum, commonly referred to as
Sargassum, is a large brown seaweed. It grows attached to rocks, with a maximum
of 5 cm holdfast, and an additional 5 cm of height. These are the maximum growth
specs for Washington State, however, in warmer waters off the coast of Hawaii it
has been known to grow to up to 12 meters in length. Sargassum has negative
impacts both economically and environmentally, and can clog waterways,
preventing marine transit and recreational activities. It can also clog intake pipes, as
well as choke out local species. Schizoporella errata and Schizoporella unicornuis are
fouling bryozoans, and are of concern in both Washington and Hawaii as they out‐
compete natives for space and food (Global Invasive Species Database).
Washington and Hawaii have also identified their environment as
susceptible to the establishment of Carcinus maenas, commonly known as the
European green crab. Neither states have established populations, but individuals of
the species have been found in both states. Hawaii and Washington have voiced
concern over the likely arrival and establishment of the species (Global Invasive
Species Database).
Co‐establishment of the above AIS, as well as the establishment of hundreds
of others within both Washington and Hawaii clearly illustrates the need for
29
improved policies, regulations, and practices within both states. Hawaii and
Washington policies regarding ballast and hull fouling have several similarities, yet
also have key differences.
Ballast water regulation similarities include the stringent reporting
requirements, mandatory ballast water management plans on board all vessels
which enter state waters, the requirement for open‐ocean ballast water exchange
outside of the exclusive economic zone of the state, and the resulting fines
associated with violating any of the above requirements. Although reporting
requirements are nearly identical, Washington and Hawaii compliance rates vary
greatly. According to Third Biennial Report of the National Ballast Information
Clearinghouse, compiled by the Smithsonian Environmental Research Center, the
most recent compliance data (2004‐2005) indicates an 88.6% compliance rate on
the West Coast (Washington, Oregon, and California), versus 76.1% compliance rate
in Hawaii. Compliance on the West Coast increased 19.0% during 2004‐2005, while
there was a 15.4% decrease in compliance in Hawaii. Hawaii was the only area of the
United States showing a decrease in ballast water reporting compliance
(Smithsonian 5). Key differences between Washington and Hawaii relate to a lack of
details within Hawaiian policy. This lack of detail may have a connection to the lack
of compliance as recorded by the Smithsonian.
5.1: Ballast
Current ballast water practices, ranging from treatment to regulations, have
several key problems. First, utilizing ballast water exchange as the currently
30
suggested method for reducing AIS has several drawbacks. The ability of a vessel to
effectively remove and exchange all of its ballast is variable depending on the
specific vessel (National Research Council 25). In the most efficient vessels it is still
near impossible to remove all sediments and water from the bottom of the ballast
tank, which results in remaining organisms. A vessel considered free of ballast
typically contains 150 tons of residual water and mud, due to the fact that the
nozzle which pumps water from each tank hangs several feet above the tank floor
(Harder 235). Exchange also does not remove organisms stuck to the sides or
supports within the tank (Baskin 734).
According to McCollin, Shanks, and Dunn, even though ballast water
exchange creates an overall reduction in number and abundance of taxa found on
board, this reduction was not consistent between tanks and voyages. This same
research also showed that even with a reduction in number of species found in
water, there were also several incidences of an increase in potentially harmful
species (536). Also, safety concerns arise when the vessel has to flush its ballast
water mid‐transit. Ballast's purpose is to help stabilize the ship during transit, and
the removal of this stability creates a window of increased danger due to capsize
(Gramling 22). At this point, most regulations allow for ballast water exchange to be
bypassed if the vessel captain feels conducting the exchange would be dangerous
for the vessel or any crew on board. No secondary opinions on safety are required,
and no explanation other than reporting that exchange was bypassed for safety is
necessary (Endresen 615). The issue of shipping patterns also raises concern. A
31
large proportion of vessel trips do not cross the necessary depth and off shore
distance for effective exchange (Endresen 618).
The current mechanisms of regulation also have several problems. Current
regulations create a confusing, overlapping, and possibly conflicting reporting
situation, which is problematic for the shipping industry (U.S Coast Guard 2006, 5).
Having state regulations that differ from federal regulations and proposed
international regulations makes compliance exceptionally difficult. The current
voluntary status of ballast water management has resulted in low compliance rates.
According to the National Ballast Information Clearinghouse, compliance to
voluntary reporting was only 30.4% during the first 24 months that reporting
requirements were in effect. About one half (51.2%) of the reporting ships that
discharged ballast water performed some degree of ballast water exchange (U.S.
Coast Guard 2001). According to existing U.S. regulations, exchange is not
suggested, even on a voluntary basis, if a vessel does not travel outside of the U.S.
EEZs, or Exclusive Economic Zones (NISA). This is problematic due to the fact that
travel from port to port within the U.S. has the potential of spreading AIS. Travel
between San Francisco Bay, which is heavily impacted by AIS, to the Puget Sound,
which is only moderately impacted by AIS, has the potential of environmental and
economic harm for the Puget Sound area.
Also, a lack of discharge standards has created a situation of standstill in the
development and implementation of new ballast water treatment technologies. In
order to obtain greater environmental benefits, state of the art ballast water
treatment technology needs to be widely available and affordable, however,
32
manufacturers are unwilling to take the business risks necessary to begin
commercially producing treatment systems unless they know the discharge
standards those systems need to meet (U.S Coast Guard 2006, 6).
All vessels of the United States’ Armed Forces are exempt from ballast
regulations in Washington and Hawaii. This does not mean military vessels are not
conducting ballast water exchanges or following the suggested guidelines, it just
means they are exempt from reporting, resulting in a lack of knowledge in this area.
5.2: Hullfouling
Hull fouling regulation issues are hard to identify due to the fact that there is
currently little to no regulation relating to hull fouling and the transmission of
aquatic invasive species. Inconsistent regulations and rules regarding ablative paints,
anti‐fouling systems, and boat cleaning, as mentioned previously, create a confusing
atmosphere for both private and commercial vessel operators. Lack of reliable
scientific data regarding AIS and hull fouling is also an issue.
The above mentioned military exemption is particularly pertinent to
Washington and Hawaiian policies due to the heavy military presence in both states.
It is reasonable to expect that this exemption will remain in place for hull fouling
regulations as well as the already written ballast water regulations. The only
documented direct transmission of invasive species from Washington to Hawaii was
the previously mentioned blue mussel, transferred via hull fouling from Puget Sound
Naval Shipyard in Bremerton, WA to Pearl Harbor in Honolulu, HI.
33
6. Suggested Improvements
The key to reducing and preventing AIS transmission through the vectors of
ballast and hull fouling is creating a consistent set of policies, therefore creating a
maritime shipping environment that is easy to comply with. Moving towards
consistency will be key to success. To move towards this goal, the following
recommendations are suggested.
Hawaii and Washington could improve in both the ballast and hull fouling
segments of maritime transportation, however, the hull fouling component is a
more prominent issue at this point in time. The complete lack of regulations
regarding AIS transportation via hull fouling is detrimental to both states’ economic
and environmental situations.
In order to improve the ability to regulate hull fouling issues, it strongly
suggested that the legislatures from both Hawaii and Washington pressure the
United States to sign on to the IMO International Convention on the Control of
Harmful Anti‐fouling Systems on Ships. Creating a national standard for the use of
ablative paints and regulating the anti‐fouling technologies available will create a
base that will allow for long term AIS management policies and goals. Without
consistent standards relating to ablative paints and anti‐fouling mechanisms, it is
difficult to set realistic policies.
In addition to the issues with ablative paints, it is also important to focus
regulations on activities that can reduce initial AIS transmission. Emphasis should be
placed on preventative techniques. The first suggested preventative technique is to
restrict time in port to essential operations only, such as cargo operations, fueling,
34
and loading supplies. For vessels that intend longer terms stays, such as cargo
barges, crane barges, drilling platforms, floating drydocks, and decommissioned
military and personal vessels, it is suggested for states to develop quarantine
procedures for vessels prior to docking, or to require a mandatory out of water
cleaning prior to permanent or long term docking.
Hawaii and Washington could improve ballast policies by passing legislation
that is consistent with International Maritime standards. The IMO Ballast Water
Convention represents 10 years of consensus building and provides a detailed and
realistic plan of action to battle AIS. The United States has been involved in setting
the regulations proposed by the IMO, but has not ratified the convention. Hawaii
and Washington choosing to pass state standards consistent with the IMO would be
an indicator to national level government that ratifying the convention is desired.
The BWM Convention will not go into effect until it has 30 signatories, representing
35% of world shipping tonnage. World shipping tonnage is a measure of total
volume of ships operating worldwide, irrespective of actual cargo carried. If the U.S.
were to ratify the convention, this would represent approximately 15% of world
shipping tonnage (IMO 2011), and would be enough to put the IMO Convention into
action. Ratification of the BWM convention is supported by several key
organizations involved in shipping, including the Coast Guard, American Association
of Port Authorities, the Shipping Industry Ballast Water Coalition (which includes
representative from several major shipping corporations), and several other industry
related groups (American Association of Port Authorities, Coast Guard 2002, Coast
Guard 2004, Coast Guard 2005, Shipping Industry Ballast Water Coalition).
35
Adopting a ballast water treatment standard at a state level, preferably by
adopting a treatment standard consistent with the IMO, would help encourage
design and implementation of new ballast water treatments. Allowing for
adjustments to the standard based upon available technologies is also important.
The battle over which should come first, the treatment standard or the preferred
treatment technique needs to be resolved. Waiting for treatment techniques to be
developed has been slow, for reasons discussed earlier, and may be expedited with
the phased implementation of treatment standards. It is also important that any
standards set be required for any travel, even if within the EEZs of each individual
state or climate zone. Preventing transmission of AIS from port to port will be key in
slowing down the spread of species.
Also important for both Washington and Hawaii is to require preventative
measures in ballast water management plans. Both states currently require all
vessels to have a ballast water management plan on board, but do not have any
requirements for what is found in the plan. Emphasizing the need to reduce initial
AIS intake in ballast will allow for less burden to be placed up treatment
technologies or exchange. Such preventative measures include: minimizing
ballasting in ports and coastal areas, avoiding ballast intake at night, and avoiding
ballast uptake in ‘hot spots’, or areas near sewage outfalls or have known AIS
infestations (Globallast 2008).
In order for these recommendations to become policy both states need to have
increased funding dedicated to AIS. Both Hawaii and Washington have the
information and potential for great improvements in policy and enforcement,
36
however, neither can do so without increased funding. This funding could be used
for education and outreach, creating a more communicative environment between
marine vessel operators and managers and those working to reduce AIS
introductions. Funding could also be used to increase vessel inspections, helping to
close an information gap that forms from a self‐reporting system.
7. Conclusion:
Aquatic invasive species and the related dispersal by marine transportation
is a global and ongoing problem. The lack of comprehensive and collaborative policy
has resulted in a regulatory situation that is confusing and difficult to navigate for
both private and commercial vessel owners and operators. Improvements to the
policy and regulatory environment could result in increased effectiveness when
battling aquatic invasive species. The comparison of Hawaii and Washington
identifies a number of policy constraints and possibilities to ensure ecological and
economic viability.
Hawaii and Washington could both make individual or joint policy
improvements, as listed above, that would result in an increased line of defense
against the transmission of aquatic invasive species. However, without efforts on a
larger scale, individual and even joint state changes are not going to result in a
drastic reduction in invasive species transmissions and establishments. Creating
consistent and thorough policies at a national and international level is going to be
the necessary change in order to reduce AIS transmissions and the resulting
economic and environmental impacts. Modeling state ballast policies to match
37
those of the International Maritime Organization works towards a consistent
international policy framework, and also places pressure on the United States to
move towards those standards at a national level. As there are no current best
practices available for the prevention of AIS through hull fouling, it is suggested that
Washington and Hawaii focus on creating consistent port based prevention efforts,
allowing for initial protection while more research is completed and best practices
can be established.
38
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