Availability of Retrospective Analysis of 2012 Ballast Water Discharge Standards

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.

The commenter supports the retrospective analysis of the 2012 ballast water standards but urges the Coast Guard to incorporate localized economic impacts, preserve state regulatory authority, and account for risks from exempt vessels. They also recommend integrating state monitoring data into federal reporting to improve compliance tracking.

Giles Candy critiques the report's methodology, arguing that it lacks direct evidence of compliance and relies too heavily on estimated data from vessel operators. He suggests that a more rigorous biological analysis of ballast discharges is necessary to accurately determine the cost-benefit of BWDS compliance.