Reg G. Gilbert

Dear sir or madame, With reference to USCG-2001-10486, please accept the following: Invasive species are the most serious pollution threat faced by the Great Lakes, as each new one, and the accumulated effects of the earlier ones, threaten at any time to cause the collapse of the Great Lakes food chain as we now know it. Thus, please strengthen the Phase 1 standards and make them effective earlier! The proposed Phase 1 standards are barely more protective than current rules and thus effectively thwart the intention of the regulations to be a bridge to the final standards. And why are the shippers allowed seven years to implement Phase 1 standards? Surely two or three years is enough time: 2011 or 2012. The final standards, Phase 2, are excellent, but, as above, take too long to be implemented. They should be implemented by 2015 or 2016. I notice a loophole in the regulations that allow "practicability" to delay implementation of the regulations. What is not practical is delaying protection. As with the automaker response to the introduction of the first auto pollution rules, if the shippers are certain the government is serious, they will meet the deadlines for practical implementation. Please remove practicability review from this process, as it will simply be abused. On another process note, I see that the regulations are issued under NISA, which preserves EPA's role. Although the Coast Guard may possibly wish to limit the degree to which it must work with another agency, preservation of EPA's role is essential. CG has authority here, but should keep in mind that this problem is above all an environmental one, and CG needs to work with EPA to properly carry out its ultimate mission, serving the public good. I see the proposed rules apply to lakers -- please protect this provision! Lakers are key vectors for the spread of invasives around the lakes and absolutely must be covered by the rules. Thank you for your time. Reg Gilbert