Iberia Marine Service, LLC 3015 Gene Flash Rd., New Iberia, La. 70560 Office (337) 365-3784 Fax (337) 359-8880 Email: forms@iberia-marine.com 12/01/09

Docket Management Facility (M-30) U.S. Department of Transportation West Building Ground Floor, Room W12-140 1200 New Jersey Avenue, SE. Washington, DC 20590-0001

RE: Standards for Living Organisms in Shi ps’ Ballast Water Discharged in U.S. Waters; Notice of Proposed Rulemaking (USCG–2001–10486)

Dear Sir or Madam:

I represent Iberia Marine Service, LLC located in New Iberia, Louisiana. We operate a fleet of six large crew boats in the Gulf of Mexico that service offshore oil and ga s facilities. We have been in business for over 35 years and employ approximately 40 mariners who live across the United States. Iberia Marine Service, LLC is also a member of the Offshore Marine Service

Association.

We have some concerns with the new proposed ru lemaking referenced above. It requires vessels to install ballast water management systems regard less of the fact that the Coast Guard has stated that they our vessels do not carry ballast water. This means that companies like mine would have to spend large amounts of money to install these systems that we do not need.

There is an exemption in the proposed rulema king for crude oil tanker engaged in coastwise trade. It is not expl ained why oil tankers operating in coas twise trade are exempt and why other type of coastwise trade vessels like the ones in our fleet are not. It is onl y fair that Coast Guard should make all vessels engaged in coastwise trade exempt from this rule. If this exemption is added, it would allow the vessels in our fleet to be exempt from having to install these costly water managements systems which we can not afford.

All of the vessels in our fleet oper ate strictly in the Gulf of Mexi co within the same COTP zone. It is unnecessary to require our vessels to inst all these water management systems when we only carry municipal water to offshore facilities. This municipal water is taken on at docks within the same COTP zone and are never used to adjust fo r cargo. This water is strictly used for ship’s potable water and for transfer to offshore facilities.

My company is one of many that will be affect ed by this new rulemaking proposal. There are over 1,200 vessels in the OMSA membership which operate within the same COTP zone. CoastIberia Marine Service, LLC 3015 Gene Flash Rd., New Iberia, La. 70560 Office (337) 365-3784 Fax (337) 359-8880 Email: forms@iberia-marine.com Guard has underestimated the number of vesse ls affected by this rulemaking and should

reevaluate the number of vessels wh ich will be impacted by this rule.

The financial burden of installing these systems is enormous. It was mentioned to cost between $250,000-$580,000 to install one of these systems on a vesse l. This is half the cost of what it cost our company to build one of our vessels br and new. This does not include the maintenance cost that is figured to cost around $50,000 annually. We will have no choice but to pass this cost on to our customers. With how depressed the offs hore market is today, this may not be an option and we will have to seek other means of compen sation. We will ultimately have to decrease our

overhead. This means that our mariners will have to take a pay decrease. With the cost of these

units and the trouble to find marine rs who will want to work for a decreased pay, it will put most of the smaller operators like ourselves out of business.

The final point I will make is that we have no room on our vessels for these units. Everything is designed to be compact on our vessels and there is no extra room for large equipment like these water managements systems. Our mariners sleep on bunks that are smaller then a twin bed. If I had this much room on our vessels, my first capta in would at least have a full sized bed in his bunk being that he spends more then half of his life aboard our vessels. Also, the engines on the vessel are so close together that you have to walk sideways to pass in between them. These are just some examples of how limited space is among our vessels.

I urge you to reevaluate the proposed rulemaki ng for these water management systems and we appreciate the opportunity to comm ent on this important rulemaking.

Sincerely,

Blake Miguez

Vice President