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92 93 NAMEPA state (countrywhere a ship is registered) and port state (where the ship trade) administrations. Non-compli- ance can result in financial penalties and detentions, which places an enormous financial riskon offenders. Themaritime industry,through the IMO,works towards continuous improvement.Some of themost recent areas of activity include action to reduce the risk of invasive species using ballast water management systems,the reduction of harmful emissions through the lowering of fuel sulphur content in 2020 from the current 3.5% to .5%,changes to ship designs tomake themmore energyefficient,and the reporting of ener- gyusage as a bench- mark for developing a strategy for reducing Greenhouse Gases (GHGs) in 2023. BALLASTWATER MANAGEMENT Since the introduc- tion of steel-hulled vessels around 120 years ago,water has been used as ballast to stabilize vessels at sea.Ballast water is pumped in tomaintain safe operating conditions throughout a voyage.This practice reduces stress on the hull,pro- vides transverse stability,improves propulsion and maneuverability,and compensates for weight chang- es in various cargo load levels due to fuel andwater consumption.​ Thezebramussel,which is native to the Caspi- an and BlackSeas,arrived in Lake Erie in the ballast water of a transatlantic freighter in 1988.Within 10 years it had spread to all the five neighboring Great Lakes.The economic cost of this introduction has been estimated by the U.S. Fish andWildlife Ser- vice at about $5 billion. Ballast water dis- charges are believed to be the leading source of invasive species in U.S.marinewaters, thus posing public health and environ- mental risks,as well as significant economic cost to industries such as water and power utilities,commercial and recreational fisheries,agriculture,and tour- ism.Studies suggest that the economic cost just from the introduction of pest mollusks (zebramussels,theAsian clam,and others) toU.S.aquatic ecosystems ismore than $6 billion per year. IMOhas been at the front of the interna- tional effort by taking the lead in addressing the transfer of invasive aquatic species (IAS) through shipping.After more than 14 years of complexnegotiations between IMO Member States,the International Convention for the Control andManagement of Ships’ BallastWater and Sediment (BWMConven- tion) was adopted byconsensus at a Diplo- maticConference held at IMOHeadquarters in London on February13,2004. In the United States,Congress passed theNational Invasive SpeciesAct of 1996 (NISA) to control aquatic invasive species. The Coast Guard issued ballast water regula- tions,pursuant toNISA,in 2012,incorporat- ing differing guidelines for management sys- tems (dead vs.non-viable)–three systems types approved since December and one in the pipeline. It is anticipated therewill be nine byyear’s end. The Environmental ProtectionAgency (EPA) has issued discharge permits for controlling ballast water un- der CleanWaterAct authority. The Convention requires a reviewto be undertaken to determinewhether appro- priate technologies are available to achieve the standard.MEPChas conducted several such reviews and agreed that appropriate technologies are available to achieve the standard contained in regulationD-2 of the