Great Lakes United believes this proposed rule is essential to improve, adopt and fully implement, as 72% of the invaders that have established since 1959 are from the ballast discharge of ocean-going ships (Reid, et al, 2002). In general, Great Lakes United supports the provisions under the proposed rule, “Penalties for Non-Submission of Ballast Water Management Reports” that require mandatory Ballast Water Management reporting and would apply penalties to ships operating without the required reports. Great Lakes United believes that strong enforcement and application of penalties are needed to analyze the effectiveness of existing ballast water management requirements-- requirements created to protect the Great Lakes from invasive species.