The Great Lakes-The St. Lawrence River: Under Climate Change
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Phillip G. Levasseur Dr. Dane McKinney Transboundary Water Resources April 22, 2010
The Great Lakes-The St. Lawrence River: Under Climate Change Introduction: Over the past decade the United States and Canada have invested over $20 million in environmental, engineering, and economic studies of Lake Ontario and the St. Lawrence River. In 2000, the International Joint Commission (IJC) confirmed that new information regarding the transboundary water resource was required because prior assessments dated to the early 1950’s. The IJC commissioned a five year study and a Working Group which consists of the provinces/states of Quebec, Ontario, and New York (IJC, 2010). The working groups charge has been to review the regulations governing a network of channels, canals, and locks in the basin. Initial motivation for the IJC’s investigation was primarily driven by environmental conservation groups, industry, and governmental entities. Various stakeholder groups were aware that climate change may already be impacting lake levels and environmental flows; thereby impacting ecosystem services and the capacity of maritime commerce. Moreover, the ratification of the new Great Lakes Compact of 2008, by the U.S. Congress has been marked as way forward for U.S. states to regulate and cooperate with Canadian provincial governments (Hall, 2009). Therefore, newly acquired data, stakeholder comments, and newly promulgated regulations are hoped to conserve the future of the Great Lakes region. Facts: The Great Lakes are North America’s most substantial supply of freshwater and critical to environmental flows. The Great Lakes are: Erie, Huron, Michigan, Ontario, Superior and Huron. The coastline of the lakes totals more than 10,900 miles and the total area of the lakes totals 94,000 square miles. Further, the Great Lakes watershed is nearly three times the size of the actual lakes, encompassing more than 767,000 square miles (GLIN, 2009). The St. Lawrence River flows 530 miles from Lake Ontario to the Gulf of St. Lawrence “with a fall of 245 feet” (USACE, 2007). According to the U.S. Army Corp of Engineers (USACE) “the International Section of the river extends for a distance of 115 miles from Lake Ontario to St. Regis, New York where it passes into Canadian Territory”. Sections of the St. Lawrence River channel are as a deep as 60 feet and has a width of 1 mile (USACE, 2007). According to the IJC, Great Lakes-St. Lawrence system is a major driver for at least eight U.S. states including Minnesota, Wisconsin, Illinois, Indiana, Michigan, Ohio, Pennsylvania, and New York and two Canadian provinces, Ontario and Quebec (IJC, 2010). For over 200 years the St. Lawrence River and Lake Ontario have been transformed by engineers to promote commercial navigation of the waters. Channels, levees, dams, locks, and electric power stations have
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been installed. Riparian features such as rapids and falls have been eliminated. For instance the IJC and the USACE created Lake St. Lawrence, the Moses-Saunders Powerhouses, U.S. Eisenhower Lock, and Snell Locks (USACE, 2007). The governments of Canada and the U.S. have incrementally altered the natural flows for perpetuity; figure 1 illustrates the infrastructure in along the St. Lawrence Seaway. Improvement projects such as canal and dam improvements are continually reviewed and initiated. Support and Opposition for the projects and new management practices are continually brought forward to the IJC’s St. Lawrence River Board of Control which is mandated to follow the orders of the 1963 accord known as plan 1958-D (USACE, 2007) which is currently under regulatory review by the IJC and the Working Group. The IJC was created via the Boundary Water Treaty of 1909 and is therefore the intergovernmental liaison between Ottawa, Canada and Washington, D.C. The IJC has been vested considerable powers to resolve issues between the two nations and both governments appoint three members constituting a commission of six members (IJC, 2010). The Region & Economy: The Great Lakes contain nearly 20 percent of the world’s freshwater supply and 12 million people live within the basin (IJC 2010). Numerous nongovernmental and governmental organizations consider themselves stewards of the region’s water resources; but the St. Lawrence River and Lakes regions most vocal stewards are the industries that depend upon consistent lake and river water levels. International cargo depends upon consistent channel depths and proper regulation of the St. Lawrence River. International freighters in Canada and the United States export and import millions of metric tonnes of grains, agricultural products, petroleum, forest products, and base metals annually via lake-river-ocean transit, see table 1 (Millerd, 2007). The U.S. Department of Transportation’s St. Lawrence Seaway Development Corporation and Transport Canada are responsible for the regulation of transport via the waterway, see figure 2 for a photo of seaway infrastructure. Transportation and navigation of the waterway are critical to the regional economies. Nearly 180 million metric tonnes of goods transit the Great Lakes. The St. Lawrence Seaway alone has transited over “2.5 million metric tons of cargo in 50 years, with an estimated value of more than $375 billion” (SLSDC, 2010). Nearly 25 percent of all cargo is between Europe, the Middle East, supplying commodities such as grain to the international market. The St. Lawrence Seaway can handle vessels up to 740 feet long, 78 feet wide, and a draft of 116.5 feet. With over 300 years of shipping history just within the Great Lakes, economic and social dependence upon this natural resource cannot be underrepresented. One may even state that the international economy relies upon raw commodities and manufactured goods that are produced in this region. Further, there has been a movement to value ecosystem services of the region. Since the 1970’s there has been a movement to look beyond the raw economic power of the Great Lakes and evaluate the value of marshlands, sediment transport, indigenous species, and pollution. An economic and environmental balance
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must be found among the numerous riparian and coastal stakeholders. For instance, for over 80 years heavy industries associated with the manufacturing of technology and goods have depended maritime services provided by the Great Lakes; cities such as Detroit boomed as result of affordable transport cost and due to the proximity of industrial commodities such as iron ore and coal. Yet, economic development has brought along unintended externalities such as water pollution and the introduction of invasive species (GLIN, 2009). Approaching Environmental Concerns & Climate Change: Environmental Canada, the U.S. Environmental Protection Agency (EPA) and numerous state and local agencies have been actively improving the water quality in the Great Lakes via the identification of point source polluters and nonpoint source pollution. The Transport Canada, U.S. DOT, the U.S. Coast Guard, and the Seaway Authorities have actively pursuing a process of eliminating the entry of invasive species into the Great Lakes. Voluntary and mandatory guideless have been in place on international cargo vessels since the early 1990’s. Invasive species are essentially drowned in saline ballast water before the vessels move past Montreal, Canada; ballast water must be not have be a salinity less than 30 parts per million (SLDC, 2010). Invasive species such as the sea lamprey were believed to have been introduced as long as the early 20th century via the Erie Canal System. Today, cargo vessels are believed to be responsible for the introduction of the zebra mussel and numerous other species. Since 1997 regulations concerning invasive species have become more stringent and the IJC has a board that monitors these particular environmental issues (IJC, 2010). Research indicates that more may have to be done to limit the environmental impact of invasive species, such as the introduction of predators to limit the populations. Further, other researchers are concerned that invasive or non-native species may dominate the Great Lakes aquatic ecosystem due to forecasted increases in water temperature (Millerd, 2007). Therefore, climate change may provide for the increased diminishment of coldwater species. Freshwater species at all trophic levels may be impacted by temperature change and apex dynamics. However, researchers note “that suggesting possible effects of climate change on both indigenous and nonindigenous species requires an examination of the multiple effects of climate change on habitat, not just a consideration of the effects of higher water temperatures” (Millerd, 2007). Invasive species is just one area of concern for the Great Lakes-St. Lawrence River. Undoubtedly, Frank Millerd’s brief investigation of the issues in Transportation Board Special Report 291 “Global Climate Change and Great Lakes International Shipping” helps facilitate a conversation of decadal lake temperature rise and its impact on the region and transportation. Millerd’s summary of climate change impacts highlighted that the shipping industry, an integral component of the economy, may actually be at risk as large cargo vessels will have less draft due to lower lake levels. Lower lakes levels will be created by the increased melting of ice, increased lake temperatures, increased
Levasseur 4
evaporation, and diminished ice season (2007). From time to time one may hear that climate change is opening new shipping routes and extending route travel times. However, lower water levels in the Great Lakes may actually increase operating costs because cargo companies will have to carry less tonnage to increase ship draft. Long distance carriers depend upon the economies of scale and often are working within very thin margins. With a modest lowering of the Great Lakes, shipping costs are projected to increase between 5 and 22 percent by the year 2030; table 2 indicates possible lake level decreases the as a result of temperature increases as modeled by the Canadian Centre for Climate Modeling and Analysis; table 3 indicates that percentage cargo transit cost increase over various models climate models. Millerd summarizes that if climate change models do appear to be correct, then commodities such as grain will become more expensive to ship per tonne because grains are usually exported over long distances. Freight companies will have to make more trips to make up for the fact that their cargo vessels will not be able to take advantage of their capacity due to a lack of channel depth (Millerd, 2007). The impacts of climate change on the Great Lakes will be considerable and the communities throughout the region will have to adapt to different environmental management and business practices if warming trends continue and the lake temperatures increase. Shorter freeze periods were once thought of as a positive component of climate change, but researchers such as Frank Millerd raise a validate point, that longer shipping times will not translate to more economic productivity. Further, ecosystems throughout the region are projected to be impacted by the change in environmental flows. Legal research analysts such as Noah D. Hall notes that policy advances made by the U.S. Congress have enabled the states to work together and address inter-state and binational water resource issues. From 2000 to 2008 considerable policy tools have been provided to governors and state agencies; however, “final decision” making will most likely be reserved to the IJC and the federal governments (Hall, 2009) Discussion: 1. In regards to policy development should the Great Lakes states act unilaterally to address environmental and economic concerns? 2. Should the Canadian and U.S. governments require that the International Joint Commission continue to take a centrist approach to regulating the economic and environmental needs of the state? 3. Is there a possible technical solution to the invasive species harbored in ballast tanks? 4. Is there truly a means to valuate the ecosystem services provided by a freshwater body the size of New England? 5. Would the International Joint Commission be a more efficient arbiter if the members were not appointed by the leaders of Canada and the U.S.? 6. Do you believe that the Great Lakes under climate change have a ripple effect to North American Security and trade relations? 7. Should government and nongovernmental organizations aim for “restoration” or partial adaptation and restoration of the Great Lakes?
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Further Policy Issues:
Deepening of the Great Lakes Channels Dredge Contamination Agricultural Run-Off Aging Infrastructure-Budgetary Constraints Water Rights Hydropower Municipal Water Use Politicization of Issues
Required: Millerd, F.(2007).Transportation Research Board Special Report 291: Global Climate Change and Great Lakes International Shipping. Transportation Research Board. Suggested: Hall, N.D.(2009).INTERSTATE WATER MANAGEMENT AND THE GREAT LAKES-ST. LAWRENCE RIVER BASIN WATER RESOURCES COMPACT-TESTIMONY BEFORE THE UNITED STATES SENATE COMMITTEE ON THE JUDICIARY. Wayne State University Law School of Legal Studies: research paper series # 09-05. Available online at < http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1229243>. Other References: GLIN.(2009). “The Great Lakes”. The Great Lakes Information Network. Available online at http://www.great-lakes.net/.html IJC. (2010). “Great Lakes”. International Joint Commission. Available online at . Scott, M. (2009). “Environmental groups say 50th anniversary of Seaway opening no cause for cheering”. Clevland. Available online at http://blog.cleveland.com/metro/2009/03/environmental_groups_say_50th_1.html SLSDC. (2010).“Great Lakes St. Lawrence Seaway System”. Saint Lawrence Seaway Development Corporation. Available online at http://www.greatlakesseaway.com/en/seaway/environment/index.html#Sustainability USACE. (2007) “St. Lawrence River-Great Lakes”. U.S. Army Corp of Engineers. Available online at . Definitions: Basis of Comparison (BOC), is used as a reference or base point for assessing the impacts of any change in water levels. Taking into account normal seasonal and annual hydrologic and climate variation, the BOC is assumed to provide an indication of the water levels that would occur naturally without climate change. The BOC is the set of water levels that would have occurred each month of the 90-year period from1900 to 1989 if all current regulation plans, structures, channels, and diversions had been in effect over that period. The hydrologic conditions or actual water supplies that occurred over these 90 years are applied to current water management procedures and structures to derive a set of monthly water levels for various locations on the Great Lakes and the St. Lawrence River. (Millerd, 2007)
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Tables & Figures:
Figure 1. Great Lakes & St. Lawrence Seaway (USACE, 2007)
Figure 2. St. Lawerence Seaway-Lock (Scott, 2009).
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Table 1. Exports from and Imports to Canada and the United States (Millerd, 2007)
Table 2. Average Change in Water Levels, Climate Change Scenario (Millerd, 2007)
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Table 3. Climate Change Scenario Average Annual Cost Comparison (Millerd, 2007)
Phillip G. Levasseur Dr. Dane McKinney Transboundary Water Resources April 22, 2010
The Great Lakes-The St. Lawrence River: Under Climate Change Introduction: Over the past decade the United States and Canada have invested over $20 million in environmental, engineering, and economic studies of Lake Ontario and the St. Lawrence River. In 2000, the International Joint Commission (IJC) confirmed that new information regarding the transboundary water resource was required because prior assessments dated to the early 1950’s. The IJC commissioned a five year study and a Working Group which consists of the provinces/states of Quebec, Ontario, and New York (IJC, 2010). The working groups charge has been to review the regulations governing a network of channels, canals, and locks in the basin. Initial motivation for the IJC’s investigation was primarily driven by environmental conservation groups, industry, and governmental entities. Various stakeholder groups were aware that climate change may already be impacting lake levels and environmental flows; thereby impacting ecosystem services and the capacity of maritime commerce. Moreover, the ratification of the new Great Lakes Compact of 2008, by the U.S. Congress has been marked as way forward for U.S. states to regulate and cooperate with Canadian provincial governments (Hall, 2009). Therefore, newly acquired data, stakeholder comments, and newly promulgated regulations are hoped to conserve the future of the Great Lakes region. Facts: The Great Lakes are North America’s most substantial supply of freshwater and critical to environmental flows. The Great Lakes are: Erie, Huron, Michigan, Ontario, Superior and Huron. The coastline of the lakes totals more than 10,900 miles and the total area of the lakes totals 94,000 square miles. Further, the Great Lakes watershed is nearly three times the size of the actual lakes, encompassing more than 767,000 square miles (GLIN, 2009). The St. Lawrence River flows 530 miles from Lake Ontario to the Gulf of St. Lawrence “with a fall of 245 feet” (USACE, 2007). According to the U.S. Army Corp of Engineers (USACE) “the International Section of the river extends for a distance of 115 miles from Lake Ontario to St. Regis, New York where it passes into Canadian Territory”. Sections of the St. Lawrence River channel are as a deep as 60 feet and has a width of 1 mile (USACE, 2007). According to the IJC, Great Lakes-St. Lawrence system is a major driver for at least eight U.S. states including Minnesota, Wisconsin, Illinois, Indiana, Michigan, Ohio, Pennsylvania, and New York and two Canadian provinces, Ontario and Quebec (IJC, 2010). For over 200 years the St. Lawrence River and Lake Ontario have been transformed by engineers to promote commercial navigation of the waters. Channels, levees, dams, locks, and electric power stations have
Levasseur 2
been installed. Riparian features such as rapids and falls have been eliminated. For instance the IJC and the USACE created Lake St. Lawrence, the Moses-Saunders Powerhouses, U.S. Eisenhower Lock, and Snell Locks (USACE, 2007). The governments of Canada and the U.S. have incrementally altered the natural flows for perpetuity; figure 1 illustrates the infrastructure in along the St. Lawrence Seaway. Improvement projects such as canal and dam improvements are continually reviewed and initiated. Support and Opposition for the projects and new management practices are continually brought forward to the IJC’s St. Lawrence River Board of Control which is mandated to follow the orders of the 1963 accord known as plan 1958-D (USACE, 2007) which is currently under regulatory review by the IJC and the Working Group. The IJC was created via the Boundary Water Treaty of 1909 and is therefore the intergovernmental liaison between Ottawa, Canada and Washington, D.C. The IJC has been vested considerable powers to resolve issues between the two nations and both governments appoint three members constituting a commission of six members (IJC, 2010). The Region & Economy: The Great Lakes contain nearly 20 percent of the world’s freshwater supply and 12 million people live within the basin (IJC 2010). Numerous nongovernmental and governmental organizations consider themselves stewards of the region’s water resources; but the St. Lawrence River and Lakes regions most vocal stewards are the industries that depend upon consistent lake and river water levels. International cargo depends upon consistent channel depths and proper regulation of the St. Lawrence River. International freighters in Canada and the United States export and import millions of metric tonnes of grains, agricultural products, petroleum, forest products, and base metals annually via lake-river-ocean transit, see table 1 (Millerd, 2007). The U.S. Department of Transportation’s St. Lawrence Seaway Development Corporation and Transport Canada are responsible for the regulation of transport via the waterway, see figure 2 for a photo of seaway infrastructure. Transportation and navigation of the waterway are critical to the regional economies. Nearly 180 million metric tonnes of goods transit the Great Lakes. The St. Lawrence Seaway alone has transited over “2.5 million metric tons of cargo in 50 years, with an estimated value of more than $375 billion” (SLSDC, 2010). Nearly 25 percent of all cargo is between Europe, the Middle East, supplying commodities such as grain to the international market. The St. Lawrence Seaway can handle vessels up to 740 feet long, 78 feet wide, and a draft of 116.5 feet. With over 300 years of shipping history just within the Great Lakes, economic and social dependence upon this natural resource cannot be underrepresented. One may even state that the international economy relies upon raw commodities and manufactured goods that are produced in this region. Further, there has been a movement to value ecosystem services of the region. Since the 1970’s there has been a movement to look beyond the raw economic power of the Great Lakes and evaluate the value of marshlands, sediment transport, indigenous species, and pollution. An economic and environmental balance
Levasseur 3
must be found among the numerous riparian and coastal stakeholders. For instance, for over 80 years heavy industries associated with the manufacturing of technology and goods have depended maritime services provided by the Great Lakes; cities such as Detroit boomed as result of affordable transport cost and due to the proximity of industrial commodities such as iron ore and coal. Yet, economic development has brought along unintended externalities such as water pollution and the introduction of invasive species (GLIN, 2009). Approaching Environmental Concerns & Climate Change: Environmental Canada, the U.S. Environmental Protection Agency (EPA) and numerous state and local agencies have been actively improving the water quality in the Great Lakes via the identification of point source polluters and nonpoint source pollution. The Transport Canada, U.S. DOT, the U.S. Coast Guard, and the Seaway Authorities have actively pursuing a process of eliminating the entry of invasive species into the Great Lakes. Voluntary and mandatory guideless have been in place on international cargo vessels since the early 1990’s. Invasive species are essentially drowned in saline ballast water before the vessels move past Montreal, Canada; ballast water must be not have be a salinity less than 30 parts per million (SLDC, 2010). Invasive species such as the sea lamprey were believed to have been introduced as long as the early 20th century via the Erie Canal System. Today, cargo vessels are believed to be responsible for the introduction of the zebra mussel and numerous other species. Since 1997 regulations concerning invasive species have become more stringent and the IJC has a board that monitors these particular environmental issues (IJC, 2010). Research indicates that more may have to be done to limit the environmental impact of invasive species, such as the introduction of predators to limit the populations. Further, other researchers are concerned that invasive or non-native species may dominate the Great Lakes aquatic ecosystem due to forecasted increases in water temperature (Millerd, 2007). Therefore, climate change may provide for the increased diminishment of coldwater species. Freshwater species at all trophic levels may be impacted by temperature change and apex dynamics. However, researchers note “that suggesting possible effects of climate change on both indigenous and nonindigenous species requires an examination of the multiple effects of climate change on habitat, not just a consideration of the effects of higher water temperatures” (Millerd, 2007). Invasive species is just one area of concern for the Great Lakes-St. Lawrence River. Undoubtedly, Frank Millerd’s brief investigation of the issues in Transportation Board Special Report 291 “Global Climate Change and Great Lakes International Shipping” helps facilitate a conversation of decadal lake temperature rise and its impact on the region and transportation. Millerd’s summary of climate change impacts highlighted that the shipping industry, an integral component of the economy, may actually be at risk as large cargo vessels will have less draft due to lower lake levels. Lower lakes levels will be created by the increased melting of ice, increased lake temperatures, increased
Levasseur 4
evaporation, and diminished ice season (2007). From time to time one may hear that climate change is opening new shipping routes and extending route travel times. However, lower water levels in the Great Lakes may actually increase operating costs because cargo companies will have to carry less tonnage to increase ship draft. Long distance carriers depend upon the economies of scale and often are working within very thin margins. With a modest lowering of the Great Lakes, shipping costs are projected to increase between 5 and 22 percent by the year 2030; table 2 indicates possible lake level decreases the as a result of temperature increases as modeled by the Canadian Centre for Climate Modeling and Analysis; table 3 indicates that percentage cargo transit cost increase over various models climate models. Millerd summarizes that if climate change models do appear to be correct, then commodities such as grain will become more expensive to ship per tonne because grains are usually exported over long distances. Freight companies will have to make more trips to make up for the fact that their cargo vessels will not be able to take advantage of their capacity due to a lack of channel depth (Millerd, 2007). The impacts of climate change on the Great Lakes will be considerable and the communities throughout the region will have to adapt to different environmental management and business practices if warming trends continue and the lake temperatures increase. Shorter freeze periods were once thought of as a positive component of climate change, but researchers such as Frank Millerd raise a validate point, that longer shipping times will not translate to more economic productivity. Further, ecosystems throughout the region are projected to be impacted by the change in environmental flows. Legal research analysts such as Noah D. Hall notes that policy advances made by the U.S. Congress have enabled the states to work together and address inter-state and binational water resource issues. From 2000 to 2008 considerable policy tools have been provided to governors and state agencies; however, “final decision” making will most likely be reserved to the IJC and the federal governments (Hall, 2009) Discussion: 1. In regards to policy development should the Great Lakes states act unilaterally to address environmental and economic concerns? 2. Should the Canadian and U.S. governments require that the International Joint Commission continue to take a centrist approach to regulating the economic and environmental needs of the state? 3. Is there a possible technical solution to the invasive species harbored in ballast tanks? 4. Is there truly a means to valuate the ecosystem services provided by a freshwater body the size of New England? 5. Would the International Joint Commission be a more efficient arbiter if the members were not appointed by the leaders of Canada and the U.S.? 6. Do you believe that the Great Lakes under climate change have a ripple effect to North American Security and trade relations? 7. Should government and nongovernmental organizations aim for “restoration” or partial adaptation and restoration of the Great Lakes?
Levasseur 5
Further Policy Issues:
Deepening of the Great Lakes Channels Dredge Contamination Agricultural Run-Off Aging Infrastructure-Budgetary Constraints Water Rights Hydropower Municipal Water Use Politicization of Issues
Required: Millerd, F.(2007).Transportation Research Board Special Report 291: Global Climate Change and Great Lakes International Shipping. Transportation Research Board. Suggested: Hall, N.D.(2009).INTERSTATE WATER MANAGEMENT AND THE GREAT LAKES-ST. LAWRENCE RIVER BASIN WATER RESOURCES COMPACT-TESTIMONY BEFORE THE UNITED STATES SENATE COMMITTEE ON THE JUDICIARY. Wayne State University Law School of Legal Studies: research paper series # 09-05. Available online at < http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1229243>. Other References: GLIN.(2009). “The Great Lakes”. The Great Lakes Information Network. Available online at http://www.great-lakes.net/.html IJC. (2010). “Great Lakes”. International Joint Commission. Available online at . Scott, M. (2009). “Environmental groups say 50th anniversary of Seaway opening no cause for cheering”. Clevland. Available online at http://blog.cleveland.com/metro/2009/03/environmental_groups_say_50th_1.html SLSDC. (2010).“Great Lakes St. Lawrence Seaway System”. Saint Lawrence Seaway Development Corporation. Available online at http://www.greatlakesseaway.com/en/seaway/environment/index.html#Sustainability USACE. (2007) “St. Lawrence River-Great Lakes”. U.S. Army Corp of Engineers. Available online at . Definitions: Basis of Comparison (BOC), is used as a reference or base point for assessing the impacts of any change in water levels. Taking into account normal seasonal and annual hydrologic and climate variation, the BOC is assumed to provide an indication of the water levels that would occur naturally without climate change. The BOC is the set of water levels that would have occurred each month of the 90-year period from1900 to 1989 if all current regulation plans, structures, channels, and diversions had been in effect over that period. The hydrologic conditions or actual water supplies that occurred over these 90 years are applied to current water management procedures and structures to derive a set of monthly water levels for various locations on the Great Lakes and the St. Lawrence River. (Millerd, 2007)
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Tables & Figures:
Figure 1. Great Lakes & St. Lawrence Seaway (USACE, 2007)
Figure 2. St. Lawerence Seaway-Lock (Scott, 2009).
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Table 1. Exports from and Imports to Canada and the United States (Millerd, 2007)
Table 2. Average Change in Water Levels, Climate Change Scenario (Millerd, 2007)
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Table 3. Climate Change Scenario Average Annual Cost Comparison (Millerd, 2007)
