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 Ships’ 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 gas 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 rulemaking referenced above. It requires vessels 

to install ballast water management systems regardless 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 rulemaking for crude oil tanker engaged in coastwise 

trade. It is not explained why oil tankers operating in coastwise trade are exempt and why other 

type of coastwise trade vessels like the ones in our fleet are not. It is only 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 operate strictly in the Gulf of Mexico within the same COTP zone. 

It is unnecessary to require our vessels to install 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 for 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 affected by this new rulemaking proposal. There are 

over 1,200 vessels in the OMSA membership which operate within the same COTP zone. Coast 
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 

Guard has underestimated the number of vessels affected by this rulemaking and should 

reevaluate the number of vessels which 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 vessel. This is half the cost of what it 

cost our company to build one of our vessels brand 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 offshore market is today, this may not be an option 

and we will have to seek other means of compensation. 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 mariners 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 captain 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 rulemaking for these water management systems and we 

appreciate the opportunity to comment on this important rulemaking. 

Sincerely, 

Blake Miguez 

Vice President