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Ship Source Pollution: Final Comments

Ship Source and Non-Ship Source Pollution
 
Recommendations:
 
1)      Existing Annexes 4, 5, and 6 on ship source pollution should be updated and combined into one annex to provide for a more integrated approach to ship source pollution. Some of the changes that should be made to update these annexes when they are combined, include:
 
  • Add Air Emissions from ships to this annex. As we have learnt, air emissions are major contributors to water contamination in the Great Lakes-St. Lawrence River system. Therefore, all sources of air emissions to the Great Lakes should be addressed. One of the components of this annex should be the requirement that ships use the same improved standards for fuels that the truck transportation sector is now required to use. Low-grade heavy bunker fuel must be phased out of use.
  • Add a section on the need to develop methods of transferring and storing materials from ships to shore facilities that does not risk contamination of adjacent water bodies. This includes coal, road salt, etc.
  • Add section on biofouling of ship hulls, etc., to require that toxic substances now in use be phased out and replaced with tested safe alternatives. For example, tributylin is currently the most commonly used anti-fouling agent. It is a highly persistent toxic substance that in very low concentrations has major impacts on marine life, especially mollusks.
  • Add a section banning the transportation of radioactive wastes and other highly toxic substances on the Great Lakes. If a spill of radioactive wastes or other highly toxic substances were to occur from a ship into the Great Lakes or St. Lawrence River or the connecting channels, it would be impossible to recover them since they would be so quickly distributed through the system and the impacts would be devastating for the very long term.
  • The reference to Aquatic Invasive Species currently in Annex 6 of the Agreement should be replaced with a new annex dedicated solely to aquatic invasive species. Our proposals for this new annex appear elsewhere in our comments.
 
2)      The existing Annex 8 is focused on onshore and offshore oil-handling facilities. We propose that this annex be renamed and expanded to include additional non-ship sources of pollution from facilities operating on, in or under the lakes, the St. Lawrence River and the connecting channels. Annex 8 should include sections on:
 
  • On-shore and off-shore oil handling facilities, as it currently does;
     
  • Under-lake gas pipelines;
  • In-lake aquaculture;
  • In-lake wind farms;
  • Submerged transmission lines; and,
  • In-lake natural gas and oil drilling operations.
Such projects should not be considered until the Parties, in full engagement with the public and all other levels of government, have developed bi-national guidelines, including possible bans or development of exclusions zones, for each type of operation.
 
Once the Parties have developed guidelines, full environmental assessments should be required for each of the projects listed above with full public engagement from the earliest stages at which the project is being considered. At a minimum, the environmental assessment should include: 1) a needs assessment to determine whether the project is needed, including an alternatives assessment to determine whether there is a more appropriate way to address the need; 2) assessment of potential environmental impacts, including clear statements on the unknowns in terms of potential impacts because of current lack of data and studies; 3) decommissioning and restoration plans; 4) detailed specific action plans in case the facility does not act as predicted. This should include plans for immediately stopping pollution in case an accident occurs as well as remediation and restoration plans. The approval for each facility should also include financial bonds.
 
3)      Other:
 
  • Require compatible goals and targets throughout the basin;
  • At a minimum use the most stringent international marine environmental conventions, and assess whether more stringent requirements are necessary to protect the Great Lakes – St. Lawrence River system;
     
  • Similar reporting requirements to the IJC and to the public as in other annexes to the GLWQA.

 

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