Ludington car ferry seeking EPA individual permit

Lake Michigan Carferry, owner of the steamer SS Badger, the last coal-fired commercial ferry in operation in the United States, has filed an application to the Environmental Protection Agency to continue operating on Lake Michigan, citing test data it says demonstrates the vessel’s coal ash discharges are well within the allowable limits set by Wisconsin, Michigan and the EPA.

“Multiple tests by EPA-approved laboratories show that the Badger’s discharges are a small fraction of the amount that has been routinely approved for similar permits on the Great Lakes,” said Bob Manglitz of Holland, president/CEO of LMC. “The materials discharged by the Badger that are tracked by the EPA are literally hundreds of times less than what others are permitted to discharge into Lake Michigan.”

According to Manglitz, the total mercury content in the ash discharged by the Badger while crossing Lake Michigan over the course of a year is two one-hundredths of an ounce, which Manglitz said is far less than what has been considered acceptable in other permits.

LMC asserts that 146 approved Great Lakes Clean Water Act individual permits for discharges into Lake Michigan contain 36 times more mercury, on average, than the Badger discharge, according to the Argonne National Laboratory.

The EPA issued a Vessel General Permit to the Badger in 2008, allowing it to discharge coal-ash slurry into Lake Michigan until Dec. 19 this year. In February, the EPA decided to require LMC to apply for an individual permit under the National Pollutant Discharge Elimination System because EPA anticipates that LMC will want to continue the coal ash discharge next year.

LMC has been studying the conversion of the Badger boilers to liquefied natural gas.

According to Don Clingan, one of the owners of LMC along with Manglitz and Jim Anderson, the Badger burns 50 tons of coal every 24 hours. It discharges about four tons of coal ash on every crossing of the lake.

Clingan said LMC has “done a fair amount of research” into the potential conversion to LNG and “we’re learning more and more about that.” He said liquefied natural gas has been used in European steam ferries for almost 10 years.

“(The) real truth is that the ash has almost immeasurable impact on water quality in Lake Michigan. … With that minimal impact, it makes really good sense to give the Badger the time it needs to thoroughly investigate and plan for this liquid natural gas conversion,” Clingan said.

The 6,650-ton, 410-foot SS Badger entered service in 1953, carrying railroad freight cars across Lake Michigan. It ceased operations as a rail car ferry in 1990, and then sat idle until 1992 when it changed hands and began carrying passengers and motor vehicles. It has a capacity of 600 passengers and 180 vehicles, and now makes two cross-lake round trips each day from Ludington to Manitowoc, Wis., from mid-May through mid-October. Clingan would not reveal exactly how many passengers the Badger carries in a year, for competitive reasons, but said it is more than 100,000.

According to Clingan, the Badger is a viable competitor with the Lake Express high-speed car ferry operating between Muskegon and Milwaukee.

Clingan said the Badger is an important part of Ludington’s history and tourism industry.

“There was about an 18-month period of time (in 1990-1992) where the vessel was out of service, and a lot of local businesses could really feel the difference,” he said.

According to LMC, the Badger steam propulsion system was designated a mechanical engineering landmark by the American Society of Mechanical Engineers in 1996. Other accolades include:

**Registered Michigan historic site by the Michigan Historical Commission, 1997.

**Registered Wisconsin historic site by the Wisconsin Historical Commission, 1997.

**Michigan Centennial Business by the Historical Society of Michigan, 1997.

Manglitz said many solutions to the dumping of Badger coal ash in Lake Michigan have been thoroughly studied, “but none of them are both technologically and economically feasible at this time. The permit application includes our continuing commitment to vessel discharge improvements, ongoing testing, and a promise to pursue other cleaner fuels.

“The infrastructure to supply natural gas and the technology to use the fuel on the Badger will take some time to develop, but we are committed to it,” added Manglitz.

LMC hired the law firm of K&L Gates in Washington, D.C., to prepare its 1,000-page permit application. LimnoTech in Ann Arbor and Merit Laboratories Inc. in East Lansing were also retained to do environmental impact testing for the application.

According to LMC, the Badger is currently operating in “strict accordance” with requirements and standards in its current EPA permit. In 2008, according to LMC, EPA said the discharges were appropriate under the Clean Water Act given the lack of harm and the lack of feasible or affordable alternatives. At that time, EPA told the Badger’s owners to apply for an individual permit if no feasible alternative was found by 2012.

“Our company has done all that has been asked of us by the EPA in the permit application process. Tests show that our discharges are well within the limits set by Michigan, Wisconsin and the EPA, and less than 146 other permitees on the Great Lakes. All we ask is that we be treated fairly and in a timely manner,” said Manglitz.

Both U.S. Sen. Debbie Stabenow and U.S. Rep. Bill Huizenga have come out expressing support for a solution that would keep the Badger in operation.