
Hello my name is Ben Drake and I am the Project Manager for Illinois Marine Towing's Lemont Shipyard. Illinois Marine operates 9 towboats and serves as a regional tower and fleeter on the Illinois River and throughout the Chicagoland area. We are proud to be a critical part of the economic engine driving this region by supporting dozens of customers in a wide range of industries. The barges we move transport cargo such as construction materials for building our country's infrastructure as well as ethanol and coal to keep our cars running and our lights on. We move these cargos in the most environmentally friendly way possible because our industry has the smallest carbon footprint of any mode of freight transportation.  Anyone who has been stuck behind an 18 wheeler in traffic can appreciate that we help keep trucks off the road that emit 371% more carbon emissions than we do per mile-ton of cargo carried (which are carbon emissions generated from moving one ton of cargo one mile).This figure comes from a recent study from the Texas Transportation Institute which also determined that the rail industry produces 39% more carbon emissions than we do per mile-ton of cargo transported.     

In light of our industries environmental record, we believe that any regulation should take into account the fact that keeping our company running efficiently is good for the environment. While we appreciate some of the changes the EPA has made in the next version of the Vessel General Permit, or VGP 2.0, in an attempt to better reflect vessel operations, there are a number of changes that need to be made to achieve this end. Like most operators we were already in compliance with the VGP's Best Management Practices when they came into effect, which will also be the case with VGP 2.0. Fulfilling the numerous paperwork requirements is what creates the largest burden for operators like Illinois Marine, and the VGP 2.0 doesn't do much to reduce these obligations. These requirements are especially burdensome for smaller operators. Illinois Marine's primary operation is shifting barges owned by other companies, and sometimes we move the same barge multiple times in one day. These continual barge movements are critical to getting commodities where the need to go to keep our economy running. Furthermore, the numerous inspections, recordkeeping and reporting requirements associated with the permit are more suited to a company that both owns and operates it's vessels at all times.With other companies' barges constantly shifting in and out of our care and custody, it makes compliance even more difficult.    Frankly it's unclear how all of this paperwork is good for the environment. The VPG 2.0 doesn't help the situation. VGP 2.0's economic analysis states that barges make up 66% of all vessels covered by the permit. Domestically that number is a whopping 80%. It is time the EPA recognizes the vast majority of vessels that have to comply with this regulation are essentially large boxes which rely on towing vessels for movement, and tailor the regulation accordingly. Therefore we strongly recommend that unmanned, unpowered barges have the option of obtaining permit coverage under the Small Vessel General Permit or the SVGP. The SVGP's Best Management Practices approach and its streamlined inspection and reporting requirements make more sense for barges, in light of their limited discharges and the fact that they frequently move in and out of different operators' care and custody. 

Thank you very much for the opportunity to comment.  As you develop the final rule, please do not hesitate to let us know if we can serve as a resource for you.  
