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John E. SununuSenator
STATEMENT OF SENATOR GEORGE ALLEN
Thank you Mr. Chairman.
I want to thank you for your leadership in scheduling this hearing regarding the impact of Ballast Water Invasive Species Management and Threats to Coral Reefs. This is an important environmental issue and one that can be remedied through innovative technology as we will be learning about today. Our role in this process, as members of this Committee, is to craft a regulatory environment that effectively deals with problems without hampering the innovation of the private sector. One of my constituents from Virginia, Mr. Joel Mandelman, will be speaking before this Committee later today. I want to take this opportunity to thank him for his appearance and for the innovative work that his company Nutech is doing in its efforts to treat ballast water so the impact of invasive species on the environment can be controlled. Invasive species cause significant economic impact and are a major threat to public health and the environment. It is estimated that damage from these organisms causes over $6 billion in damages to the United States annually. The industries most affected include power plants, municipal water treatment systems, ships and fishing. In particular, the vitality of the shellfish industry is greatly impacted.
It is my understanding that Nutech has developed a treatment system for ballast water that both reduces the spread of invasive species and reduces operating costs for ship owners. This process involves treating ballast water with ozone gas to decontaminate the water. Ozone gas has been shown to be very effective in disinfecting drinking water, swimming pools and aquariums. Testing of ozone gas treatment aboard ships in Alaska in 2000 showed that this form of water treatment greatly reduced the number of unwanted organisms found in ballast water. I am told that this innovative technology works in both fresh and salt water because ozone gas quickly degrades and reverts back to oxygen. Therefore, ozone has the potential to fulfill the requirements that the National Aquatic Invasive Species Act (S. 363) places on the discharge of ballast water in the Great Lakes. This technology also speeds up the timeline for when ships can comply with the requirements set forth in the International Maritime Organization (IMO) Treaty.
However, to encourage new technology that will improve our environment, any legislative approaches must be mindful of the needs of companies like Nutech to ensure they have the tools they need to successfully test and implement their technology. In September of this year, another test will be conducted where Nutech will install an advanced version of its technology on an oil tanker. Because of improvements in the technology, this version will cost 65 percent less than the equipment for the first test and will be able to be installed without taking the ship out-of-service.
According to the shipping industry, deep ocean ballast water exchanges cost a ship owner between $16,000 and $80,000 per exchange (which must occur every month). For this technology to be implemented, several changes must be made to induce ship owners to participate. Therefore, Nutech suggests that the implementation period in S. 363 be shortened so ships currently in service will have to treat their ballast water once the Coast Guard approves a treatment technology. Nutech believes this change ensures that ballast water treatment continues to evolve along with technology. Second, to speed up the implementation date of the legislation the Committee should expand the scope of the Coast Guard’s Shipboard Evaluation and Testing Program (STEP) to allow more ships of the same owner to participate in experimental technology program. In addition, we should consider grandfathering in owners who install approved technology prior to the mandatory implementation date to current standards. Third, in terms of complying with Coast Guard regulations, ship captains must be able to prove that they have been treating their ballast water. For more effective testing, it is suggested that conducting microbe counts at every port is not an effect way to measure the quality of the ballast water. Total Residual Oxidant testing should be the main test of ballast water with microbe testing done on a periodic basis. Finally, any Congressional action should be the exclusive legislative authority for mandating methods of treatment and discharge of ballast water. This provision will prevent conflicting regulation of discharges under the Clean Water Act.
It is vital that we on this Committee work with companies such as Nutech to create an efficient regulatory environment that fosters innovation. By developing incentives that allow ship owners to invest in new technology, we will be able to better protect the environment with a lower cost to business owners. I hope that during this hearing we will consider the best way to remedy this significant problem impacting our oceans and lakes. I again would like to thank the Chairman for his leadership on this issue and look forward to working with the Committee as we figure out the best legislative approach for dealing with this problem. Thank you.
Daniel K. InouyeSenator
I would like to join our Chairman in welcoming our distinguished panel of witnesses today, and to thank him for holding this important hearing. I would like to particularly welcome Ms. Kim Hum, of The Nature Conservancy of Hawaii, to the hearing and to thank her for her work on coral reef conservation in the Pacific.
Unfortunately, I am all too familiar with the problems of invasive species and threats to coral reefs. In my home state of Hawaii, the two often go together. The impacts of such alien species on our native species have been among the most significant in the country.
The United States Ocean Commission recognized the problem of invasive species as one of the greatest threats to coastal environments. Invasive aquatic species have been found in all regions of the United States, including most of the states represented on this Committee. Invasive species are thought to have been involved in most of the extinctions of native aquatic species.
The Commission also called for expanded national and international action to address increasing threats to coral reefs, including those posed by invasive species.
Ballast water from ships is one of the largest pathways for the introduction and spread of aquatic invasive species. It has been estimated that some 10,000 non-indigenous aquatic organisms travel around the globe each day in the ballast water of cargo ships, and billions of gallons of ballast water are discharged in U.S. waters each year. The problem is not only from ballast water, but also invasive species that travel on the hulls and other parts of ships.
The direct and indirect costs of aquatic invasive species to the economy of the United States are also staggering, and have been estimated to amount to billions of dollars per year. We need to find a solution to this problem, while at the same time ensuring that our maritime industry can continue to operate in a cost-effective manner.
Existing law does not provide the legal authority needed to effectively address this problem. That is why I introduced the Ballast Water Management Act of 2005. The bill establishes standards for ballast water treatment that will be effective but on a schedule that our maritime fleet can realistically achieve. It recognizes safety as a paramount concern, and allows flexibility in ballast exchange practices to safeguard vessels and their passengers and crew.
Looking to the future, the bill will also encourage the development and adoption of new ballast water treatment technologies, as well as innovative technologies to address other vessel sources of invasive species such as hull fouling, through a grant program.
Coral reef resources are, of course, central to life in Hawaii, where we rely on them to sustain our fisheries, attract and retain tourism, and protect our coastal communities during extreme weather events. Reef-related tourism and fishing activities directly generate $360 million each year for Hawaii’s economy, and coral reefs are the lynchpin for Hawaii's entire tourism industry, valued at over $10 billion. Hawaii and other areas of the Pacific boast some of the most beautiful and exotic reefs on the planet, but they are threatened by a variety of impacts, from global warming and vessel groundings, to invasives, pollution, and overharvesting. These impacts are even more apparent in the Western Pacific, where communities may rely almost exclusively on coral reefs and associated resources for economic survival.
We are particularly fortunate to have the Northwestern Hawaiian Islands as a laboratory for the study and protection of coral reefs. This remote and uninhabited area, 1200 nautical miles long by 100 nautical miles wide, contains unparalleled resources for scientists and others concerned with coral ecosystem protection.
Congressional support for designation of this area as the largest National Marine Sanctuary in the world has given us the opportunity to map, monitor, assess, and explore these vast regions and habitats. The Sanctuary will help us build our base of knowledge to improve restoration and conservation of coral reefs around the world.
The Coral Reef Conservation Act of 2000, which Senator Snowe and I developed five years ago, helped us begin to identify our national coral reef resources, assess their condition and current threats, develop a national action strategy, and mobilize states, territories and the federal government to address the problem. Today, we see how far we have come, and how far we still need to go.
In our reauthorization of the Act, we must increase and focus funding on coral protection and conservation and provide new authorities to prevent and respond to coral reef damage. We need to bring private and public resources together at the local level to ensure full community participation in protecting and conserving these sensitive areas. I look forward to working with my colleagues to pass this much needed reauthorization.
I am very pleased that we have assembled this group of experts today to discuss these very important issues. I look forward to your testimony.
SENATOR BARBARA BOXER
HEARING ON AQUATIC INVASIVE SPECIES AND BALLAST WATER MANAGEMENT AND CORAL REEF PROTECTION
Thank you, Mr. Chairman, and may I begin by saying how pleased I am to be serving as your Ranking Member and that we are holding our first hearing.
By reestablishing this Subcommittee, Congress is again acknowledging the importance of the oceans to our nation’s and the world’s health and to the economy and how important it is to understand and act to lesson the threats to our oceans.
That was underscored twice in the last two years with the release of two separate reports by two distinguished Commissions–the U.S. Commission on Ocean Policy, headed by Admiral Watkins, and the Pew Ocean Commission, headed by Leon Panetta. Last week, I introduced comprehensive legislation, the National Oceans Protection Act, to implement the recommendations of these two Commissions.
Mr. Chairman, I look forward to a good working relationship with you and the other members of this subcommittee, and I hope we can approve good oceans legislation in this Congress.
It is appropriate that the first two issues on deck are combating aquatic invasive species and protecting coral reefs.
Harvard’s E.O. Wilson, one of the world’s greatest living biologists, says that invasive species are second only to loss of habitat as the causes most destructive to biodiversity. Invasive species destroy habitat, attack native species, and upset the ecological balance that has been in place for thousands and thousands of years.
In San Francisco Bay alone, more than 175 invasive species threaten to overwhelm native fish and other wildlife–and, nationally, the total economic damage of invasive species is estimated to be $137 billion each year.
One of the most common causes of invasive species is ballast water from ships, which brings water from around the world–including a host of creatures– into America’s waters.
My comprehensive oceans bill includes new regulations on ballast water, including prohibiting nearly all discharges into U.S. waters. My bill also addresses the need for early detection and rapid response, including assisting states in combating invasive species.
I commend Senator Inouye for introducing the Ballast Water Management Act . I appreciate his leadership on this issue, and I look forward to working with him.
The other subject of this hearing is coral reefs. Coral reefs are critical habitat for ocean creatures and are home to potential cures for human ailments. They have been called the rainforests of the seas.
But warming seas and warming climate, water pollution, and harmful fishing practices threaten the world’s coral reefs. We must reauthorize the Coral Reef Conservation Act of 2000, which was an important start in promoting scientific research and sound management of our coral reefs. But we must go further.
My oceans legislation contains important provisions to preserve critical coral habitat, including creating Coral Management Areas to provide a higher level of protection.
I look forward to working with my friend, Senator Lautenberg, one of the Senate’s true champions for our coral reefs, and other members of the Committee to advance protections for coral reefs this Congress.
Again, Mr. Chairman, I am very pleased to be your Ranking Member, and I look forward to the testimony of the witnesses.
Witness Panel 1
Mr. Joel MandelmanVice President and General CounselNuTech 03 Incorporated
Ms. Kim HumThe Nature Conservancy, Hawaii
Mr. Tim R.E. KeeneyDeputy Assistant Secretary of Commerce for Oceans and AtmosphereNational Oceanic & Atmospheric Administration
Ms. Kathy MetcalfDirector of Maritime AffairsChamber of Shipping of America
THE OCEAN POLICY STUDY SUBCOMMITTEE
SENATE COMMITTEE ON COMMERCE, SCIENCE
WEDNESDAY, JUNE 15, 2005
9:30 A.M. IN SR-253
MS. KATHY J. METCALF
DIRECTOR, MARITIME AFFAIRS
CHAMBER OF SHIPPING OF AMERICA
ON BEHALF OF THE SHIPPING INDUSTRY BALLAST WATER COALITION
Mr. Chairman, we appreciate the opportunity to testify before you today on the subject of invasive species management and specifically the provisions of Senate Bill 363, the Ballast Water Management Act of 2005 as introduced by Senator Inouye on behalf of himself and Senators Akaka, Cantwell, Lautenberg, Sarbanes and Stevens. The Shipping Industry Ballast Water Coalition (the “Coalition) is an informal organization of maritime trade associations and companies that own, operate or charter commercial vessels of all types engaged in both domestic and international trade and represents over 90% of the vessels calling in US ports. The types of vessels owned and operated by coalition members include oceangoing and coastwise containerships, tankers, roll-on/roll-off vessels, bulk carriers, and passenger vessels as well as tug/barge units which operate in oceangoing, coastwise and inland waters. While the testimony we provide today highlights points of agreement by the vast majority of the Coalition, individual members of the coalition would respectfully reserve their right to provide written comments to this record to provide additional information as they deem necessary. The Coalition was formed over four years ago by a number of entities that believed resolution of this complex issue required the coordinated efforts of all stakeholders. Since that time, the Coalition has provided testimony or comments to both legislative and regulatory initiatives regarding ballast water management both at the international and domestic level. GENERAL COMMENTS The Coalition congratulates Senator Inouye and his colleagues for drafting the proposed legislation as it is, to date, the legislation which most closely mirrors the management structure as contained in the recently agreed upon International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 (“the IMO Convention”) by the member states of the International Maritime Organization. The Coalition has always and continues to support the prompt enactment of domestic legislation which will establish a national ballast water management program and that reflects, to the maximum extent possible, the substantive provisions and regulatory framework of the IMO Convention. In this regard, the Coalition supports the provisions of S 363 with a few specific changes as noted below. THE BALLAST WATER MANAGEMENT PERFORMANCE STANDARD The Coalition supports changing the performance standard as currently included in S 363 to reflect the standard contained in the IMO Convention. As currently drafted, S 363 contains a performance standard that is one hundred times more stringent than that contained in the IMO Convention. It is important to note that at this point in time, there is no published peer-reviewed data that suggests the existence of technology which can achieve the IMO standard, although we are hopeful that this technology will emerge from testing programs which are underway around the world and on a variety of ships. It is this data, once published and peer-reviewed, that will become part of the pre-review process conducted at IMO, and under the pre-review process as contained in S 363 as introduced. What is critical here is that the first standard be achievable, recognizing future adjustment of the standard during the periodic review process which will reflect the capabilities of emerging technology to provide even more efficient treatment results. The Coalition also strongly supports including a quantitative performance standard in the legislation itself and not leaving the establishment of the performance standard to the regulatory process. For a number of years, members of our coalition have had discussions with technology developers and reviewed various ballast water treatment technologies. I can unequivocally state that it was only when the fixed quantitative standard was established by IMO, that shipowners and technology developers alike were in a position to commit vast sums of financial and human resources to finding a solution to this perplexing problem. Once this quantitative standard was established, shipowners and technology developers alike had a “hard target” at which to aim. While the concept of “best available technology” is a viable one, it has no place in establishing initial performance standards for ballast water treatment systems. It will more appropriately, by default, become the general criteria for later adjustments of the standard to reflect developing technology. REVIEW OF STANDARDS AND FEASIBILITY REVIEW Section 3(f) of S 363, entitled Ballast Water Treatment Requirements, contains provisions for a periodic review of standards (3(f)(4)) and an initial feasibility review (3(f)(6)). These are key provisions in ensuring that appropriate technologies are available to achieve the initial standard and provide for periodic reviews of the established standard in light of new technologies that provide even more effective treatment results. While the Coalition strongly supports inclusion of both of these provisions, we believe that more detail is necessary in the legislation to guide the regulatory program which will implement these provisions. Specifically, the Coalition believes that the legislation should explicitly include five specific criteria on which these reviews will be based. The five criteria are considerations of safety, environmental acceptability, practicability, cost effectiveness and biological effectiveness. By including these specific criteria, Congress will more clearly outline the charge to the agencies which will be responsible for implementing these review programs. URGENT NEED FOR A COORINDATED FEDERAL PROGRM WHICH MAY BE IMPLEMENTED BY THE STATES Shipping is international and the regulation of shipping should be, too. While this is not always possible, the Coalition believes that regulation of shipping through international requirements as established by IMO is the correct way to comprehensively regulate the industry in a clear manner. However, there are cases where domestic legislation has been enacted which varies with international requirements. Not without some pain, the industry has adjusted to these US requirements. However, in the case of ballast water management, the industry has, over the past several years, been exposed to state requirements that, in some cases, have varied from the federal requirements. We fear this trend will continue without the inclusion of appropriate language in S 363. Continuing this patchwork-quilt approach would be catastrophic for the environment and the industry and undermine the progress that we can make on this issue by the establishment of a strong, uniform federal program. Therefore, the Coalition strongly advocates the modification of the current preemption language found at Section 3(q) to reflect the recognition that the program as established under this legislation is the sole program established in the United States for the management and control of ballast water discharges. With the implementation of this strong federal program, there should be no need for state, regional or local implementation of additional or conflicting ballast water management requirements and thus the inclusion of strong preemption language is appropriate. S 363 AS THE EXCLUSIVE FEDERAL PROGRAM WHICH REGULATES BALLAST WATER MANAGEMENT AND DISCHARGES IN US WATERS The Coalition strongly believes that enacted ballast water legislation should be the exclusive federal program which regulates ballast water management and discharges in US waters. As a result of a recent US District Court decision, there is some question as to whether Congress intended to include ballast water discharges under provisions of the Clean Water Act and specifically the National Pollutant Discharge Elimination System permitting program. The coalition strongly supports congressional action to clear up this confusion and recommends the inclusion of appropriate text to clearly manifest Congress’s intent to regulate ballast water management under the provisions of ballast water-specific legislation such as S 363. NEED FOR A SPECIFIC EXEMPTION FROM BALLAST WATER EXCHANGE REQUIREMENTS FOR TUG/BARGE OPERATIONS A vast majority of the Coalition believes that an express provision should be included in S 363 which exempts tug and barge operations from the ballast water exchange requirements. The basis for this specific exemption relates to the inherently unsafe nature of maneuvering a tug alongside a barge and then place a human life at risk by requiring a crew member to scale what is essentially a 20 to 30 foot vertical steel wall, in order to allow exchange to be conducted on the barge at sea. While the existing safety exemption would arguably cover such an operation, it would be more appropriate to clearly manifest the intent of Congress that such an operation would not be condoned by including specific language exempting tug/barge operations from the ballast water exchange requirements. In fact, Washington and Oregon have exempted tug and barge operations from state requirements to conduct ballast water exchange. These states have acknowledged the inherent risks in requiring barges to conduct ballast water exchange. It is important to note that this exemption would not apply to the integration of ballast water treatment systems as they become available, provided that the system would enable treatment of ballast while the vessel was berthed and thus obviate the need to conduct an unsafe operation at sea. We appreciate the opportunity to provide testimony to your subcommittee and would be please to answer any questions you may have.
Ms. Maurya B. FalknerCalifornia Marine Invasive Species Program, California State Lands Commission
Rear Admiral Thomas H. GilmourAssistant Commandant for Marine Safety, Security, and Environmental ProtectionUnited States Coast Guard
DEPARTMENT OF HOMELAND SECURITY
UNITED STATES COAST GUARD
STATEMENT OF REAR ADMIRAL THOMAS GILMOUR
BALLAST WATER MANAGEMENT AND THE BALLAST WATER
MANAGEMENT ACT OF 2005, S.363
COMMITTEE ON COMMERCE, SCIENCE AND TRANSPORTATION
JUNE 15, 2005 Good Morning, Mr. Chairman and distinguished Members of the Subcommittee. I am Rear Admiral Thomas Gilmour, Assistant Commandant for Marine Safety, Security and Environmental Protection. It is my pleasure to appear before you today to provide the Coast Guard’s views on ballast water management and the Ballast Water Management Act of 2005, S.363, and to touch briefly upon coral reef protection. The Administration shares this Committee’s concern with the significant environmental and economic damage that has been caused by aquatic invasive species and recognizes that ballast water discharge is one of the important pathways for such invasions. Over the past several years, the US has been a leader in international efforts to address this problem. While we have made significant progress domestically under the current legislative framework, there is no question that this framework needs to be upgraded to move us to a higher level of protection. We are committed to working with the Congress to enact effective legislation that will address the ballast water issue and substantially reduce the threat of damaging invasions through this pathway. The Coast Guard is a leader in ensuring America’s maritime environment is protected. We take great pride in providing valuable services that preserve and protect our nation’s waters, making them cleaner, safer, and more secure for legitimate use. The Coast Guard remains committed to providing a leadership role on ballast water management both domestically and internationally and working diligently with all stakeholders to protect U.S. waters from the introduction of aquatic nuisance species. In early 2001, through a series of international workshops, the Coast Guard began working with scientists, marine engineers, experts from the water treatment industry, and our federal agency partners to develop the criteria for a ballast water discharge standard. These workshops concluded that the standard should address all organisms at all life stages, that it be concentration based and set at values that are scientifically sound, environmentally protective and enforceable. These criteria informed our approach for international negotiations at IMO as well as to our rulemaking to develop a ballast water discharge standard, currently in process. The ballast water discharge standard will be used to approve ballast water management equipment installed on ships as an alternative to ballast water exchange, under our current authority. The standard will also be used to evaluate compliance on vessels performing treatment. We are currently completing a Programmatic Environmental Impact Statement analyzing the environmental impacts of several alternative standards as well as the cost-benefit analysis associated with this rulemaking. In February of 2004, the Coast Guard led the interagency United States delegation to the International Maritime Organization’s (IMO) Diplomatic Conference on Ballast Water Management for Ships. The Conference adopted the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004, which is a significant step forward in the international effort to combat invasive species introduced by ships’ ballast water. The U.S. delegation played a major role in development of the Convention's basic structure and in ensuring that a number of key objectives were included in this new treaty. One significant provision of the Convention calls for ships to meet a ballast water discharge standard according to a schedule of fixed dates, beginning with certain ships constructed in 2009. These fixed dates serve as a signal to the shipping industry as well as to the emerging ballast water treatment industry of the need for investment, plans and inventory to meet ballast water management requirements. Another key feature of the implementation schedule is the phasing out of the practice of ballast water exchange, which means most ballast water discharges will eventually have to meet a maximum concentration standard. The Convention contains provisions for the experimental testing of prototype ballast water treatment systems on operating vessels. In addition, the Convention contains a U.S. backed provision that allows the sampling of ballast water from ships as a port state control activity for the purposes of evaluating compliance with the Convention. While there were many important and positive provisions adopted by the Conference, one significant element is the stringency of the ballast water discharge standard. For example, the standard in the Convention would allow less than 10 organisms of a given size range per cubic meter of discharged ballast water. The Coast Guard believes that the Convention’s level of stringency may not be sufficient to adequately reduce invasions, and that technologies currently under development may be able to do better. However substantial uncertainty remains in both of these areas. Significantly, the standard adopted by IMO is concentration-based rather than expressed as a percent removal. This was desired by the U.S. because the concentration approach provides for more effective monitoring of compliance and a more uniform and protective level of risk reduction across all vessels. Further, the standard, as adopted, when met by all vessels, will likely significantly reduce the discharges of potentially invasive species via ballast water. Since the adoption of the Convention, the Coast Guard has led an interagency delegation in the development of supporting guidelines for the implementation of the Convention, the first set of which will likely be adopted by IMO resolution in July. The Ballast Water Management Act of 2005 contains many provisions similar to the IMO Convention adopted in 2004 and is consistent with the basic structure of the Convention. In addition to authorizing an amendment to the Non-indigenous Aquatic Nuisance Prevention and Control Act/National Invasive Species Act, the legislation provides for the eventual sunset of the practice of ballast water exchange, in favor of an environmentally protective ballast water treatment standard. The ballast water discharge standard in S.363 is the same format of a concentration-based standard found in the IMO Convention, which deals with all organisms and their life states. This concentration-based standard is important in that it provides a threshold for the maximum number of organisms in a volume of discharged ballast water regardless of the source of the ballast water or type of vessel. This is essential for both the approval of ballast water treatment systems and enforcement of the discharge standard on ships. However, the standards in S. 363 are 100 times more stringent than the standards found in the IMO Convention. There has been no evaluation to date of currently-available technologies to show whether extant and prototype ballast water treatment systems would be able to achieve the standards set in the bill. The Administration believes it may be premature to fix these standards in legislation, given the substantial uncertainties in the future capabilities of emerging technologies. The Ballast Water Management Act of 2005 also addresses the movement of non-indigenous species by ballast water between ports within the U.S., which is a critical step in controlling the spread of invasive species. To date, there has been no significant analysis of the risks presented by these ballast water discharges against the feasibility of various ballast water management options. The continued ability to evaluate the performance of prototype technologies under the Ballast Water Management Act of 2005 is also important, as the Coast Guard launched the Shipboard Technology Evaluation Program in 2004 as an incentive to assist vessel owners in the installation of prototype ballast water treatment systems under our current regulations. In addition, we have been working closely with the U.S. Environmental Protection Agency's Environmental Technology Verification Program in the development of rigorous technical protocols for land-based testing and evaluation of ballast water treatment technologies. This provision will allow the Coast Guard to continue facilitating the development of improved ballast water treatment technology, even after the application of a ballast water discharge standard to all vessels. The Coast Guard also works closely with the National Oceanic and Atmospheric Administration (NOAA) to help preserve and protect coral reefs. In 2004, the Coast Guard dedicated 2,032 aircraft, 323 boat and 1,708 cutter hours at a cost of over $13 million, in such enforcement efforts. The Coast Guard has also worked with NOAA, the State of Hawaii, the Department of Interior, and local organizations to help remove marine debris from coral reefs surrounding the Northwestern Hawaiian Islands. Thank you for the opportunity to provide comments on the Ballast Water Management Act of 2005. The Coast Guard looks forward to working with Congress as we continue our ongoing efforts to implement an effective ballast water management regime. I will be happy to answer any questions you may have.