U.S. law requires all foreign trade ships to employ United States and Canadian registered pilots throughout the Great Lakes and St. Lawrence Seaway. In U.S. portions of the Great Lakes, pilotage services are provided under a regulated system overseen by the U.S. Coast Guard. Pilotage is a component of safe navigation on the Great Lakes, but it is also one of several structural and cost-related factors that influence the competitiveness of the Great Lakes–St. Lawrence Seaway navigation system.
AGLPA believes that a broader, fact-based examination of these factors—including pilotage, Canadian Seaway tolling, and other regulatory and operational costs—is necessary to better understand how cumulative costs affect the ability of the Great Lakes region to attract and grow international shipping.
AGLPA Position
AGLPA supports safe, reliable, and efficient navigation on the Great Lakes and St. Lawrence Seaway and recognizes the role pilotage plays in maintaining safety. AGLPA supports continued oversight of Great Lakes pilotage by Congress and through structured industry engagement and believes that pilotage policy should manage safety, transparency, and cost-effectiveness.
AGLPA encourages Congress and federal agencies to pursue a comprehensive Great Lakes shipping barriers-to-entry study, conducted in coordination with the Great Lakes St. Lawrence Seaway Development Corporation (GLS) and regional stakeholders, led by AGLPA. Such a study would examine pilotage and reliability alongside other costs and policy drivers that influence shipping decisions, with the goal of developing a clearer, data-driven understanding of the cumulative costs affecting the system as a whole.
Additional Background
Marine pilots are expert navigators familiar with local geography, weather, currents, sailing conditions, and customs. In U.S. portions of the Great Lakes, pilotage services are provided by three private companies, each serving a defined geographic area.
The Great Lakes Pilotage Act of 1960, together with its associated regulations, establishes the framework for pilotage in waters under U.S. jurisdiction. Under this structure, ship operators are required by law to use pilotage services, and only one authorized provider operates in each designated area. As a result, pilotage functions as a federally regulated monopoly rather than a competitive market, with rates and operating requirements set through federal regulation by the U.S. Coast Guard.
The U.S. Coast Guard exercises regulatory oversight of Great Lakes pilotage, including responsibility for setting pilotage rates. Rates are determined through a multi-step annual process set forth in federal regulations (46 CFR Part 404) and are adjusted through a federal rulemaking process each year.
An important element of pilotage oversight is the Great Lakes Pilotage Advisory Committee (GLPAC). Established by statute, GLPAC is composed of representatives from pilot associations, vessel operators, ports, and a financial expert, and provides advice and recommendations to the Coast Guard on pilotage policy, rates, staffing, and regulatory issues.
Over time, pilotage costs have increased. Between 2014 and 2025, the total cost of U.S. pilotage on the Great Lakes increased from approximately $12.8 million to $43.2 million in order to remedy maritime safety issues associated with recruitment and retention, training, and decades of neglect regarding infrastructure. Pilot compensation levels are established by the Coast Guard as part of the rate-setting process and reflect the regulated nature of the system.
In its most recent Notice of Proposed Rulemaking on Great Lakes pilotage rates, the Coast Guard proposed eliminating the working capital fund component of the rate-setting methodology — a change that AGLPA and other stakeholders have long supported.
Pilotage costs are one component of a broader set of expenses associated with international shipping on the Great Lakes–St. Lawrence Seaway system. Other factors—including Canadian Seaway tolls, regulatory requirements, and operational constraints—also influence vessel routing decisions and overall system competitiveness.
Great Lakes ports, terminals, dock workers, warehouse operators, truck drivers, and other stakeholders all depend on a viable and competitive navigation system. Understanding how the combined effect of pilotage and other system costs influences shipping behavior is essential to support trade, economic growth, and job creation throughout the region.