Gail Krantzberg

I understand that the Coast Guard preferred option is to make the interim enforcement policy permanent and add standardized mandatory reporting requirements. The EIS analysis shows that more modern equipment and practices may greatly reduce the amount of cargo residue spilled. Nevertheless, the recommended option does not provide incentives to adopt best management practices. I believe that eliminating lost cargo would represent good business practices and demonstrate corporate responsibility. We cannot afford to assume that over time, industry will voluntarily adopt modern methods, install new equipment and eliminate discharges. Instituting a code of best practices aimed at minimizing bulk cargo loss, measuring compliance with the code and tracking results would provide a pathway to virtual elimination. The goal is to minimize stress on the environment and to safely and economically eliminate bulk cargo loss rather than minimizing the incentive for industry to improve operations as a result of the proposed preferred option.