Comment Submitted by Francisco Franco

I support the Coast Guard’s effort to update and refine the valuation of avoided oil spills in the maritime environment, as described in the report “Monetizing the Benefits of Avoided Oil Spills in the Maritime Environment.” This initiative represents an important and necessary advancement in regulatory analysis, ensuring that decision-making reflects current data, modern economic methods, and the true environmental and societal costs of oil spill prevention. The previous valuation framework, based on outdated spill cost data from the early 2000s, no longer adequately captures today’s maritime risks, response costs, ecological damages, or restoration expenses. Updating these values using more recent datasets and improved methodologies will significantly strengthen the Coast Guard’s ability to conduct accurate cost-benefit analyses. This, in turn, supports more effective safety regulations, spill prevention measures, and resource allocation decisions. I strongly support the report’s emphasis on reviewing current literature and applying best practices in environmental economics. A transparent, evidence-based approach to monetizing avoided spills ensures that regulatory decisions fully account for the long-term benefits of prevention, including protection of marine ecosystems, coastal economies, fisheries, and public health. These benefits are often underrepresented when outdated or overly simplified valuation methods are used. It is also important that the Coast Guard continues to incorporate uncertainty analysis, sensitivity testing, and periodic updates to ensure the values remain relevant over time. Oil spill impacts can vary widely depending on location, spill size, and environmental conditions, and valuation methods should reflect that complexity rather than rely on static averages. I encourage the Coast Guard to adopt a robust, flexible framework that can evolve with new scientific findings and economic data. Doing so will improve regulatory precision, enhance environmental protection outcomes, and strengthen public trust in maritime safety policy. Finally, I appreciate the opportunity for public comment and encourage continued transparency and stakeholder engagement as this valuation framework is finalized. This effort represents a meaningful step forward in ensuring that the full benefits of spill prevention are properly recognized in federal regulatory analysis.