Comment Submitted by Justin Meyers

1. We appreciate the USCG evaluating the long-term benefits of ballast water treatment. However, we urge the Coast Guard to ensure that benefit calculations explicitly incorporate localized economic impacts—such as municipal water intake biofouling, state commercial fishery losses, and regional habitat degradation. National average valuations can mask severe, localized ecological damages. Economic models must reflect the regional necessity of state-specific water quality controls and local environmental protections. 2. The retrospective analysis should explicitly acknowledge the vital role of state authority in ballast water management. Federal discharge standards serve as a baseline floor, not a ceiling. States maintain primary statutory authority under the Clean Water Act and state law to protect local water quality and prevent invasive species spread. Any future regulatory updates derived from this retrospective analysis must preserve state delegation, monitoring oversight, and the ability of states to enforce regional protective measures. 3. While the retrospective model assesses BWMS retrofitting costs for the regulated fleet, it must also evaluate the risk posed by exempt or domestically operating vessels moving intra-regionally. In regional watersheds (such as the Great Lakes or coastal estuaries), secondary spread from unequipped vessels remains a major pathway for NIS dissemination. The analysis should account for the regulatory burden that falls onto states to manage secondary spread when federal standards exempt specific vessel classes. 4. To ensure the projected net benefits of the 2012 rule are actually realized, federal reporting and compliance data must be accessible to state regulators in real time. We recommend that the Coast Guard integrate state monitoring data into its ongoing evaluation framework. State environmental agencies frequently perform localized sampling and inspection; leveraging state-level monitoring strengthens compliance tracking without increasing overall federal administrative burden.