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of the European river ruffe from its current habitat in western 

 Lake Superior. We and our partners in this endeavor are, in the 

 words of the U.S. Fish and Wildlife Service, quote, "the first mari- 

 time association in North America to propose a voluntary ballast 

 water management strategy." 



When we identified the problem that the ruffe presented, we re- 

 sponded as quickly and to the degree that current knowledge and 

 technology allowed as well as what economics would allow. We did 

 not cause the problem but we know that we are part of the solution 

 to mitigate it. 



I say we did not cause the problem. I think the committee is 

 aware that we are in the inland water transportation system and 

 that the water we carry as ballast is water that is already con- 

 tained within the inland waters of the United States. If there is 

 some nonindigenous species within that water, they were probably 

 brought in from a salt water ship. 



As you know, the ruffe is a very aggressive feeder and, as noted 

 earlier, in just six years it is now the most abundant fish in the 

 Duluth/ Superior Harbor and unfortunately it is spreading east at 

 25 miles a year. And I have to agree with my colleague at this 

 table that probably in time the ruffe will spread probably to all 

 waters east of the Rockies, in time. 



The voluntary water ballast water management plan instituted 

 at the beginning of the 1993 navigation season is simple in its con- 

 text and execution. It did not require any retrofitting of any of our 

 vessels or any significant distortions in loading or trading patterns. 

 It was an ideal set of circumstances since Duluth/ Superior Harbor 

 is primarily a loading port, so only in certain circumstances is it 

 necessary for a vessel to take on ballast water in Duluth/Superior. 



We believe that the U.S. Coast Guard's strategy, present regula- 

 tions based on law for the Great Lakes, is and should be the first 

 line of defense. We must do our best to keep nuisance nonindigen- 

 ous species out of our inland waters. All of these nonindigenous 

 species are certainly blind to flag. Whether they come in through 

 Canadian waters, Mexican waters, or U.S. waters, they will eventu- 

 ally get into the inland waters of the United States. And once in 

 those waters it is very difficult, if not impossible, to control the 

 spread. 



As mentioned earlier, Duluth/Superior was ideal. If those ruffe 

 get into Lake Erie or Lake Michigan, ballast water management 

 plans such as we have would not work and we would probably have 

 to stop it. I think the committee is well aware that ballasting is an 

 essential function of vessel safety. When a ship is not carrying 

 cargo, it has to have ballast on board so that the ship will ride low 

 enough in the water to maintain safe steerage, to have hull stress 

 management, and the stability of the vessel. 



And ballasting, as indicated by Dr. Carlton, takes on vast 

 amounts of waters. The largest U.S. vessel that we operate on the 

 lakes does carry 14.5 million gallons when it is light. Even on the 

 smaller ships, we carry 2.5 to 5 million gallons. This water is 

 pumped out as the ship is loaded, and if you pump it out too quick- 

 ly, the ship will hog, sag or snap in half causing severe damage to 

 the vessel. And when you do ballast exchange in open waters, you 



