Comment Submitted by Control Union Vessel Performance Centre B.V.

Control Union Vessel Performance Centre B.V.SupportBusiness
Summary: Control Union Vessel Performance Centre B.V., an independent maritime environmental compliance test organization, supports the maintenance of the 2012 ballast water discharge standards. They argue that the retrospective analysis understates the risks of invasive species and recommend incorporating more direct in-service performance data and a clearer crosswalk between taxonomic data and size-class standards.
Please find the response of Control Union Vessel Performance Centre in the attached file. We are available for feedback. Best regards, Cees van Slooten, PhD

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