USCG "VIDA In-Person Listening Session", Merchant Marine Academy, Kings Point NY, May 29-30, 2019
Ballast Water Discharge Session Public (5 minute) Statement on UV Treatment and MPN (May 30, 2019)
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My name is Randy, and I am speaking today as outside Counsel to Trojan Technologies.
We have heard from a number of key interests in the shipping community about the importance of low energy UV treatment systems and MPN over the last two days. What have we learned?
--through VIDA, Congress has directed the USCG and USEPA to describe "type approval methods and protocols for ballast water management systems that render nonviable organisms in ballast water";
--low energy UV systems are clean and green technologies that render invasive aquatic species nonviable and provide an effective, chemical free alternative to killing invasives with heavy doses of chlorine;
--the Best (and most recent) Available Science has undergone vigorous peer review and unequivocally shows that MPN is the state-of-the-art method for evaluating viability, and is as good or better a method than the preferred-by-USCG "vital stains" method;
--there is no peer-reviewed science challenging the effectiveness of MPN and low-energy UV treatment systems;
--the IMO, the global shipping community as well as the USCG's own independent labs have embraced the MPN method and low-energy UV treatment systems and want that technology to be approved and available as a commercial option in the marketplace;
--by redefining USCG's regulations such that nonviable organisms are no longer considered "living", VIDA has taken away the USCG's prior basis for rejecting MPN as the method for establishing the effectiveness of low energy UV treatment systems; and
--therefore, in response to this overwhelming support in favor of MPN and low energy UV treatment systems and the new directives contained in VIDA, the USCG should immediately approve such systems for use in U.S. waters.
Thank you for the opportunity to comment.

