Enough information exists to justify a Basin Plan prohibition for ballast water and hull fouling discharges, and to develop the mechanism for allowing exceptions to this prohibition. The specific exceptions will allow the development of appropriate management practices and technology and their rapid implementation. Table 4-1 of the Basin Plan should be amended to include this prohibition, and Chapter 4 amended with a description of exception mechanism(s) to this prohibition.
Although researchers have sampled and studied the organisms in ballast water at numerous ports around the world, the ballast water arriving in the San Francisco Estuary has never been sampled, and only rough estimates are available on the total annual volume of this discharge. Annually, as much as 4 billion gallons of ballast water are discharged to this estuary (11 million gallons per day or mgd), including approximately one billion gallons of foreign ballast water (3 mgd)19. Given that this estuary has been characterized as the “most invaded estuary” in the nation by agencies and scientists, the lack of information specific to these ongoing discharges is problematic. Information on the organisms discharged with ballast water is needed to assess the urgency of implementing ballast water management, to characterize the nature of this stressor on the estuary’s ecosystem, and to provide baseline data against which to measure the effectiveness of future control efforts.
While there is general consensus that introduction of exotic species to the estuary is a problem, there is an outstanding issue regarding the best available technology economically achievable (BAT) to address the problem. The issue should be resolved before a permitting system is implemented. Finalizing the technology guidance will require federal agency leadership, extensive stakeholder involvement, and engineering feasibility studies, estimated to take a minimum of two years.
TMDL product: Basin Plan Amendment prohibiting ballast water and potentially hull fouling discharges. Basin Plan Amendment allowing exceptions to this prohibition, which encourage development and implementation of appropriate management practices and technology.