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Feedback Letter from Great Lakes Research Consortium

Toward a Sustainable Development Plan for Great Lakes Commercial Navigation: Comments on the Reconnaissance Report for the Great Lakes Navigation System Review

Dear Mr. Schloop:

    I am writing as the Executive Director of the Great Lakes Research Consortium with 16 member colleges and universities in New York State and 9 affiliated schools in the province of Ontario. These are not official comments from our Consortium, but are instead my own opinions based on my knowledge and experience with the Great Lakes -St. Lawrence River System and my interest in sustainability. As the Director of an organization dedicated to improving understanding of the Great Lakes in all their aspects - chemical, physical, biological, social, economic and political - I certainly support further study and consideration of improving water transportation on the Great Lakes Navigation System. I believe, however, that the current Information Paper or draft reconnaissance study published in June 2002 rests on a very limited concept of "improvement" and "federal interest," and shows virtually no understanding of the economic and ecological possibilities of moving toward a sustainable water navigation system in the Great Lakes. It is understandable that the Corps chose to limit its reconnaissance to a narrow definition of "improvement" and "federal interest" since these have specific meanings in federal law and Corps experience, but it is long past time for these concepts to be revisited. The GL Maritime system could and should be improved along sustainable development lines in ways that make it considerably more benign, even environmentally beneficial. The interest in this is clearly federal, transcending as it does any local or even state jurisdictional interests. This is what a feasibility study should address, not the obviously destructive and overly simplistic path of building a 35-foot deep navigation system.  If we were to go ahead with a major expansion, we couldn't expect results in less than a decade or more. By then the need for an energy and resource conservation-based economy in North America will be even greater. It is possible now, and certainly desirable to plan for a Great Lakes Navigation System as an important element of an energy efficient transportation system in the future economy. 

   What would a feasibility study based on concepts of sustainable development include? First, it would consider the federal interest in a Great Lakes restoration plan which, like the Everglades plan, would move toward restoring as closely as possible the natural flows and fluctuations of water levels in the system. It would defer to the current Lake Ontario-St. Lawrence River study (another study the Corps personnel is leading) that promises to consider and hopefully remediate the negative environmental impacts of water level controls. Any deepening and widening of navigation channels would have significant impacts on water levels and would require compensating works to further control fluctuations.

      A sustainable development plan for Great Lakes navigation would ask many questions about present material and energy flows. The objective of such a plan would be to capture the economic and environmental benefits of water transport's energy savings while minimizing or eliminating the environmental disruption. In other words, the first feasibility study should be one that broadly looks at alternatives to physical expansion. One approach is a revitalized US and Canadian steel industry. Iron ore is now and is likely to remain the largest commodity flow in the system. It's decline by nearly 50% since the 1970s is also the leading cause of the shipping stagnation the reconnaissance report is interested in stemming. Following the logic of environmental sustainability, the industries of the future are those that can produce better with much less energy. Real progress in improving the energy efficiency of US and Canadian steel plants will lead to a resurgence of the industry, especially in a Greenhouse Gas limited world, and especially once the U.S. and Canada adopt international trade policies based on environmental criteria, as we eventually must.

The Lake Carriers Association responding to proposals to deepen and widen Great Lakes navigation channels predicts 15% increased hauling power per ore-hauling trip. These are really small gains, especially considering how lower water levels in a drier world might just undermine these projected increased loads. Clearly we do not suffer from a capacity problem under current conditions, and a revived steel industry could quickly address the profitability problem with increased volume. Most shippers would accept lighter trip loads for greater volume.

What about opening new bulk commodities such as paper, metal and plastics for recycling?  Once gas prices begin to reflect the true social and environmental costs of fossil fuels, the energy efficiency gains from the combination of water transport and recycling should make these commodities flourish.

These are just two ideas about how to spur economic growth in the Great Lakes Navigation System while helping rather than harming the environment. If we put our minds together we can think of many more.

Whenever the Great Lakes Navigation System Review publishes traffic figures and volume figures you should compare them with the volume at major US and Canadian East and West Coast ports. This will make it clear that Great Lakes shipping has never and will never compete with these larger and ever expanding ports. Studies have indicated that while international maritime traffic has increased 600% over the past 30 years, the Seaway traffic has declined by 20%. The Seaway has always carried a minute proportion of all US port traffic, and this should be made clear in the report and decision-making process. Baltimore shipping channel is now 50 feet deep. Once the Great Lakes ports go to 35 will we need to start the feasibility study for 50? Continual expansion of the system is not a viable option.
The section of your report that discusses environmental considerations makes the point that opportunities for incorporating environmentally beneficial features into the Navigation system would arise with the proposed "improvements." But this opportunity already exists, especially if we move forward with a study of navigation in the context of a Great Lakes Restoration Plan. This section also refers to the energy savings of using water transport rather than truck or rail. While these savings are important they only exist upriver from Montreal and can be gained by the current system.  Also under the section on environmental considerations, the report's authors state that, "The most dramatic impacts to the ecosystem have likely already occurred.' Although we all hope this is true, there is really no scientific or common sense basis for this optimism; we really have no idea about what drama yet awaits us. Deepening the connecting channels could have extremely dramatic effects on St. Clair river wetlands, where nearly half of all GL fish productivity may occur.

        Here are a few additional comments:

The report describes a stakeholder survey but it does not include information about who was surveyed nor why these people were chosen nor who is considered a stakeholder. A thorough stakeholder analysis should be done before any additional study occurs. 

The report should be much clearer about what has changed since previous Seaway studies concluded that there was no economic justification for Seaway expansion.

Is the potential for $1.4 billion a year in benefits based on year-round shipping? If so, the report should be clear that this means a renewed attempt to open the channels for winter navigation, something that has been clearly rejected in the past. 

 I would enthusiastically support a feasibility study on the Sustainable Development of the Great Lakes Navigation System that would take account of the issues I've raised here as well as many others.  This should be completely integrated with the development of a basin-wide Great Lakes restoration plan. The WRDA authorization language quoted in the report is clearly broad enough to make such a study possible. It would be a great challenge and fun besides.


Jack Manno, Executive Director
Great Lakes Research Consortium

Jack Manno
Great Lakes Research Consortium
24 Bray Hall
Syracuse, NY  13210
315-470-6816 (work)
315-422-9633 (home)
315-470-6970 (fax)
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