STATE OF CALIFORNIA ARNOLD SCHWARZENEGGER, *Governor*

**CALIFORNIA STATE LANDS COMMISSION PAUL D. THAYER,** *Executive
Officer*![](media/image1.png){width="1.1659722222222222in"
height="1.1381944444444445in"}

100 Howe Avenue, Suite 100-South (916) 574-1800 FAX (916) 574-1810

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> ***Contact Phone:*** **(****916-574-2568)**
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> ***Contact FAX:*** **(****916-574-1950)**
>
> June 3, 2008
>
> File Ref: W 9777.234

Docket Management Facility

U.S. Department of Transportation

West Building Ground Floor, Room W12-140

1200 New Jersey Avenue, SE.

Washington, DC 20590

# VIA Electronic Submittal (http://www.regulations.gov)

Re: Docket No. USCG-2007-0040: Comments on the Application for the
Cruise Ship CORAL PRINCESS, Review for Inclusion in the Shipboard
Technology Evaluation Program; Draft Environmental Assessment.

To Whom It May Concern:

The Marine Facilities Division (MFD) of the California State Lands
Commission has long supported the United States Coast Guard (USCG)
efforts with regards to their Shipboard Technology Evaluation Program
(STEP) and we welcome the opportunity to provide comments to the USCG on
the DEA, which describes the application of the *Coral Princess* for the
STEP.

As stated in the Draft Environmental Assessment for the *Coral
Princess*, acceptance into the STEP has negligible potential for
negative environmental effects, while providing regulators with real
world data on controlling invasive species in commercial vessels. MFD
believes that acceptance of the *Coral Princess* into STEP should be
granted.

Several minor issues in the DEA that require attention are identified
below. However, these issues do not impact our support for this
application.

**Overall**

1)  There are some basic issues regarding document consistency and
    continuity. The writing style varies by section, as does the level
    of detail.

2)  Regarding species descriptions, all genus and species names should
    be italicized. If a species name is not known, or if there are
    multiple species within a genus, the sp. or spp. epithet should not
    be italicized because it is not part of the Latin name. Family names
    are not italicized.

3)  The vessel name, *Coral Princess,* should always be italicized.

4)  Nonindigenous -- choose one spelling, "nonindigenous" or
    "non-indigenous"

**Docket No. USCG-2007-0040**

**June 3, 2008**

**Page 2**

**Specific Comments**

[1.2 Background]{.underline}

Pg 1-2, Para 1 -- Florida and Alaska are listed as US ports where
discharges might occur, but earlier in the Background (Pg 1-1, Para 1)
California is included, as well as the USVI. Please include all
potential discharge ports.

[1.3 Purpose and Need]{.underline}

Para 2 = Please clarify that USCG is the lead **federal** agency to
prevent....ballast water discharges **in the US**

[1.4 PEA for STEP]{.underline}

Bullet 2 -- Describes "no treatment at all under frequent
circumstances," however the vessel is described as not ballasting
frequently to begin with. Please define "frequent", and what are the
circumstances?

[1.5 Scope and Related Activities]{.underline}

Para 3 -- The vessel is described as making infrequent port arrivals (up
to 10/year), but cruise ships, by nature make frequent repeated arrivals
at ports. Looking at Table 2-1, it appears that the vessel may visit up
to 10 U.S. ports in a year, but there are likely significantly more
arrivals at those 10 ports. Please clarify.

[2.2 Alternative 2]{.underline}

Para 2 -- "The vessel would be free to discharge ballast..." Clarify
that the vessel is free to discharge treated, un-exchanged ballast, and
this would be in compliance with the federal ballast water management
laws.

[2.2.1 Typical Vessel Activities]{.underline}

Pg 2-5, Para 3 -- This Section needs to be explained better. Will the
Coral Princess be treating ballast during all ballasting operations from
Years 1 through 5, but biological efficacy (performance) will only be
examined on 120 cubic meters of water per ballasting operation prior to
arrival at specific ports in years 1 and 5? Will testing in the other
years be for operation and maintenance?

[2.2.2 Description of Technology]{.underline}

Please list State Codes for turbidity requirements and interpret how
your findings compare to the state code. For example, Alaska state code
refers to turbidity measurements as nephelometric turbidity units (NTU),
and it allows for 25 NTU in discharge. Florida does not allow discharge
to "produce color, odor, taste, turbidity, or other conditions in such
degree as to create a nuisance." Has the appropriate state agency in
Florida been contacted about whether or not this will be a nuisance, as
seagrasses are sensitive to turbulence? It would be important to measure
the turbulence (density of sediments) generated from the discharge, and
not just the volume of the plume.

Pg 2-5, Para 2 - How long, on average, does it take the vessel to
ballast? If the filter is backflushed at the end of ballast and filtered
organisms returned to the water, how far will the vessel have traveled
from the point of origin? Will those filtered organisms truly be
returned to the point of uptake?

Para 2 - "...fitted with 55-micron screens." Is 55 microns the
length/width of the mesh openings (typical for 55 micron mesh nets) or
is the diagonal opening 55 microns? If length/width is 55

**Docket No. USCG-2007-0040**

**June 3, 2008**

**Page 3**

microns, the diagonal length would be \~ 78 microns; therefore,
organisms larger than 55 microns could pass.

Para 4 - "...at 90% UV transmittance in the water." Is this 90%
transmittance typical of the water that would be taken up at the
specific ports described? This value would be decreased in turbid water,
especially in the Alaskan waters that were highly turbid due to glacial
melt runoff.

Pg 2-6, Figure 1 -- The figure needs to be enlarged to be legible.

[Pg 2-7, Management of Waste streams]{.underline}

Para 1 -- Wasn't the filter size 55 microns, if so it would remove
particles bigger than 55 not 50?

Para 3 - please spell out "in accordance with" rather than "iaw"

[3.1.1 Alaska]{.underline}

This section seems fairly vague given the enormous size of Alaska. Can
we get some specific detail for an area(s) around several of the ports?

Para 1 -- This Section makes reference to several sensitive areas within
Alaskan waters. What are these areas/reserves and what types of
activities are allowed? Can vessels discharge in these areas?

Plants and Wetlands - Is there any specific, pertinent information on
Alaskan wetlands that should be included? Please provide references.
This section seems to be lacking the detail seen in other sections.

*Fish and invertebrates*

Taxonomic family names are not italicized

[3.1.2 Florida]{.underline}

Plants and Wetlands, Para 2 -- Is the Essential Fish Habitat within the
Port Everglades area?

Fish and Invertebrates -- This section lacks sufficient detail. Please
provide examples of the major fish and invertebrate species in the Port
Everglades area. Are any species associated with mangroves also found in
the Port?

Non-Indigenous Species -- The number of species that are nonindigenous
in Florida is interesting, but Florida is a large state with many
habitats. How many and what invasive species are found around Port
Everglades? Have any of these species been shown to have any
environmental or economic harm associated with them?

[3.1.3 U.S. Virgin Islands]{.underline}

Fish and Invertebrates -- The essential fish habitats were designated
for which economically important fish species?

Non-Indigenous Species -- Please list the NIS, since there are only 7
marine/aquatic species. Have any of these species been shown to have any
environmental or economic harm associated with them?

**Docket No. USCG-2007-0040**

**June 3, 2008**

**Page 4**

[3.2 Water Quality]{.underline}

There is no continuity among these sections (Alaska, Florida, and USVI).
The salinity and turbidity for the ports appears to be listed for
Florida, but not the other two areas. It would be useful if we knew the
average turbidity values for the filter backwash and what the average or
range of turbidity is for each of the potential discharge ports.

3.2.1 Alaska Water Quality - Paragraph 3 "Small percentages of estuarine
areas in the ports of interest were rated "poor"..." Is it possible to
avoid discharging in these areas? Or is it possible to list which ports
have poor light conditions? What is meant by "small percentages"? A
simple map of the ports and the naturally impaired system would clarify
this matter. Even though the water is naturally impaired due to glacial
runoff doesn't mean that the system wouldn't be more susceptible to
anthropogenic stress.

[3.4 Socioeconomic Resources]{.underline}

See comment for section 1.5. Does this mean 10 visits a year to a single
port or 10 ports visited during the year?

[4.0 Environmental Consequences]{.underline}

While Section 3 describes the conditions at the potential discharge
ports, the environmental consequences are generalized across all regions
with little to no specific reference to any of the previously described
discharge ports. While many of the environmental consequences will be
similar at the discharge ports, please provide specific examples for the
various habitats/ports.

[4.1.1 No Action Alternative]{.underline}

Para 2 -- Although the *Coral Princess* discharges infrequently, it's
important to remember that the dose-response curve for introductions is
unknown and one discharge may be sufficient for a species to be
introduced.

[4.1.2 Propose Action Alternative (Biological Resources)]{.underline}

Pg 4-1, Para 1, last sentence -- Please provide references and or data
to support this statement.

Pg 4-1, Para 2 - "Smaller organisms (less than 55 microns)..." Depending
on whether 55 microns is diagonal distance or length/width of mesh,
organisms up to 78 microns in length may be able to pass through.

Pg 4-2, Para 2 -- This type of information would be useful for all of
the ports examined.

4[.2.2 Proposed Action Alternative (Water Quality)]{.underline}

Please provide data or references to support conclusions related to
turbidity at the end of this section.

[4.3.2 Proposed Action Alternative (Health and Safety)]{.underline}

The document should also note that the disposal of UV bulbs will be
necessary. Though if disposed of property they should not be a public
health hazard.

[4.4.1. No Action Alternative (Socioeconomic and Environmental
Justice)]{.underline}

Explain how nonindigenous species impact low income and minority
populations.

**Docket No. USCG-2007-0040**

**June 3, 2008**

**Page 5**

[5.1.1 No Action Alternative (Cumulative Impacts)]{.underline}

Para 1 -- It should be made clear that ballast water treatment by the
experimental system (if the vessel is not in STEP) will not fulfill
federal ballast water management requirements.

[5.1.2 Proposed Action Alternative (Cumulative Impacts)]{.underline}

Please clarify, the HBWTS will be used to treat all discharges, but the
treated water will only be tested for biological performance during
Years 1 and 5 (see comments for section 2.2.1)?

In summary, the MFD-CSLC supports the USCG's Shipboard Technology
Evaluation Program and we look forward to a continued collaboration with
the USCG on the evaluation of ballast water treatment technologies.

Thank you for your consideration of these comments. If you have any
questions, please do not hesitate to call.

Sincerely,

![](media/image2.jpeg){width="1.93125in" height="0.5923611111111111in"}

Maurya B Falkner

California Marine Invasive Species Program

Marine Facilities Division

Cc: Gary Gregory, Chief, Marine Facilities Division