American Waterway Operators comments on proposed rulemaking


#1

Stumbled across this while googling. Dated 16 Feb 2010. Concerns American Waterway Operators (tugs, towboats and barge industry) comments on the proposed rulemaking on STCW 95 amendments. Covers deck and engines. http://www.americanwaterways.com/index/STCWNPRMComments.pdf


#2

All comments on the NPRM (over 200) can be viewed at:
http://www.regulations.gov/search/Regs/home.html#docketDetail?R=USCG-2004-17914


#3

Seems like a lot of excellent points were brought up. Seems like a lot came in after the deadline??? Don’t really understand that, but hopefully some will be taken into consideration.


#4

Mr Richard Wells, the spokesperson for the OMSA the supply boat lobbying organization, had the following to say. I copied and pasted directly from the comments section. [they need a better transcriber]

“A work boat is not a small ship.
It’s a boat. It’s a very simple vessel in
comparison to the complexity in the systems that are found on most deep draft vessels.
That was one major reason why after the last
interim regulation the Coast Guard was
convinced to create offshore supply vessel
licenses. It was just physically impossible
for a crew member on an OSV to complete some
of the STCW assessments, because that equipment just is not there.
It’s a bigger issue on the
engineering side, but it’s also an issue on
the deck side. Not OSVs have a gyrocompass,
for example. They’ve got magnetic compasses, or in this day and age they’ve got a compass
built in their GPS so they have no need, in
their mind, for a traditional gyrocompass. So
please remember, just because it looks like a
ship, it’s not. It’s a boat. It’s a much
simpler type of a vessel. It doesn’t have all of the bells and whistles that the typical
deep draft vessel has.”

One has to wonder if he’s been on a modern supply vessel. Most of the newer ones have at least as many ‘bells and whistles’ as any deep draft vessel. You might think they just want to keep the license ‘industry specific’ so they can control wages, benefits etc.
Teng


#5

[I][quote=Diesel;28241]Seems like a lot of excellent points were brought up. Seems like a lot came in after the deadline??? Don’t really understand that, but hopefully some will be taken into consideration.[/quote][/I]

The date is when they were posted to the docket, not the date they were received (note the column is titled “Posted Date”). If you look at some of ther comments that are in pdf you’ll see fax transmission headers and/or a DOT date stamp showing they made the 2/16 deadline.


#6

[QUOTE=jdcavo;28273][I][/I]

The date is when they were posted to the docket, not the date they were received (note the column is titled “Posted Date”). If you look at some of ther comments that are in pdf you’ll see fax transmission headers and/or a DOT date stamp showing they made the 2/16 deadline.[/QUOTE]

Oh. Awesome, Thank You.