EPA's Vessel General Permit and Small Vessel General

damage to mortality.
Baleen whales are exposed to these neurotoxins by preying on highly contaminated zooplankton
(Durbin et al. 2002). For example, the summertime habitat of the North Atlantic right whale
overlaps with seasonal blooms of the toxic dinoflagellate Alexandrium fundyense. Foraging right
whales would ingest large concentrations of contaminated copepods, which affect respiratory
capabilities, feeding behavior, and ultimately the reproductive condition of the populations
(Durbin et al. 2002).
Sea Turtles
Vessel mediated ANS can include the organisms that cause harmful algal blooms. As described
above, harmful algal blooms can produce toxic compounds, including brevetoxin, saxitoxin and
microcystins. Toxins can bioaccumulate in high trophic level marine animals (Bushaw-Newton
and Sellner 1999), with adverse effects ranging from cell and tissue damage to mortality.
Immune system responses have been affected by brevetoxin exposure in the endangered
Loggerhead sea turtle (BE).
Mollusks
Invasive species are likely to adversely affect endangered abalone species via predation,
competition, and by transmitting parasites. The invasive green crab, described earlier, preys on a
variety of mollusks and is likely to prey upon black and white abalone. The invasive snail
Batillaria attramentaria outcompetes a native mollusk species, Cerithidea californica, along
northern California via a more efficient ability to convert food into body tissue and possibly
greater dispersal potential (Savino and Kolar 1996, Carlton 1999, Pothaven et al. 2001). It, or
other introduced sea snails, are likely to compete with reduced black and white abalaone
populations for prey and habitat. In addition, mollusks are particularly sensitive to pathogens.
Withering syndrome threatens the survival and recovery of the black abalone; it is caused by a
Rickettsia-like bacterium, XenoHaliotis californiensis, that was likely introduced to southern
California via ballast water discharge (Friedman et al. 2000, Smith et al. 2003, Bower 2009,
Cohen 2010). Various species of the genus Vibrio have been identified in ballast water
(Anguiano-Beltrán et al. 1998, Ben-Haim and Rosenberg 2002, Aguirremacedo et al. 2008) and
are known to cause high rates of mortality in abalone (Chew 1990, Ciguarria and Elston
1997)Simon et al. 2006) (Nell 2002, Lleonart et al. 2003, Nehring 2006, Haupt et al. 2010). A
parasitic worm, Terebrasabella heterouncinata, was introduced to red abalone via aquaculture
but likely to be spread to endangered abalone species via ballast water (Kuris and Culver 1999,
Cohen and Webb 2002, Culver and Kuris 2002, Bower 2006). Thus, the introduction of ANS is
likely to reduce the survival of endangered mollusks through predation, competition, and disease
transmission.
Corals
Vessel-mediated introductions of ANS adversely affect coral species through the mechanisms of
competition and disease transmission. Invasive corals and algae overgrow native corals (Lesser
et al. 2007). For example, introduced red algae competes with native Hawaiian coral species for
space on the reef (Lafferty and Kuris 1996). The snowflake coral, Carajoa riisei, has overgrown
up to 90% of surveyed black coral colonies in Hawai’i, where it was introduced via shipping
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