Comment submittted by Dwight Morrison, Co-Chair, Wheels On Trails Organization

Over 20 years ago, a number of science teachers ( myself included) recognized that the ballast water from international ships was discharging 'invasive species' into lake Superior. Twenty two years later there is finally some reaction to this obvious problem, by having the EPA initiate a permit process, that is long overdue. Wheels On Trails Organization adds its support, for this EPA Permit process. We strongly support the EPA process and recommend immediate implementation. The need is severe, so the strengthening of this EPA Permit process to eliminate this obvious problem is desired. We also recommend the starting of this Permit Process with all international shipping ASAP, as this type of change can take 10 years to implement if it only applies to new shipping or new boats. We need it to apply to ALL boats as soon as possible - and that may not be enough. We need to get this EPA Permit process in place now for ALL shipping - not wait another ten years while new ships are built. We have extensive examples of the damage done over the last 20 years by the Zebra muscle in the great lakes. Adoption of the weak 'International Maritime Organizations' Standard is a positive step, but the international agreement is also "to little - to late". Living in Duluth, we have seen the problem develop in the lake over the years. We need to deal with the invasive species now ! We need a stronger effort than even California, as the great lakes are far inland and need stronger protection. We would also like to request a copy of the final EPA Ballast Standards for our review and possible further comments? We would also like a copy of the 'Permit' form to see the actual details, and also an idea of the penalties that would be charged if the ships do not deal with the discharge issue? Are there any studies to show how effective the EPA rule would be? Dwight Morrison, Co-chair Wheels On Trails Org. 424 W. Superior St. Duluth Mn 55811