Comment Submitted by Giles Candy
Giles CandyOtherIndividual
Summary: Giles Candy critiques the report's methodology, arguing that it lacks direct evidence of compliance and relies too heavily on estimated data from vessel operators. He suggests that a more rigorous biological analysis of ballast discharges is necessary to accurately determine the cost-benefit of BWDS compliance.
Doc P.3 "render harmless" - as noted in a footnote later, does not qualify (yet) in the U.S.
As an example - Doc P.27 "Our analysis of system selection was highly influenced by these conversations with BWMS system manufacturers and vessel operators, but largely depended on observed data reported by vessel operators as they comply with the 2012 rule."
The report presents no direct evidence of compliance - it is a fundamental weakness of this effort. Many variables and outcomes/results are rationalized or "estimated" or otherwise. However, since 2012; port water temps have changed, number of port calls have changed, length of port calls have changed, cleanliness of hulls has changed, size of vessels/ballast tanks has changed, sailing speeds have changed and on and on.
If the results of biological analysis of ballast discharges against the BWDS were presented, analysis of the cost benefit of BWDS compliance could be completed with much more confidence.
Giles Candy