Jason R. Johnson

The liftboat sector of the industry feels that they have a particular exception to the proposed blanket rule. The particular functions of a liftboat do require for the exchange of ballast water; however ,the nature of a liftboat’s dynamics cause for the liftboat not to sail with the ballast water from one area to another. When a preload is conducted to stabilize the vessel, the ballast water is taken on and once the pre load is complete the ballast water is then dumped back at the same site that it was taken on. Therefore, any organism that is dumped there would have already existed there. We also feel compelled to present the point that even though we may work across different COTP zone and residual organism may exist within the tanks, it would be organisms from within the GOM only. Again, highlighting that liftboats take on and dump ballast water at the same location. We feel that further research should be done to see if there are any actual contamination issues that may be present from one COTP zone to the other, assuming that no travel outside of the GOM has taken place. The applicability of the propose rule seems to be taking on a "one size fits all" approach and that seems to be unjustified considering the cost that will be imposed on companies that are not creating any exposure to the environment.