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operations at night,? because of therisk to personnel. So spending a lot of money on this technology doesnt make sense, he said. And before the cost has to be passed on to his cus-tomers, he wants to know, Does this technology work as well as the manu- facturers say it does?? Charlie Costanzo, Pacific Region Vice President of the American Waterway Operators (AWO) has also been involved in the conversation over the proposed changes. There is a tendency to throw everything but the kitchen sink into contingencyplan requirements ? that more is bet- ter. But sometimes more is just more. This kind of oil spill response overkill doesnt benefit anybody. We need to look at what works and focus on enhancing those proven tools and methodologies.?Another concern with Washington States proposed rulemaking is a requirement to maintain a vessel of opportunity system focused on small boats, such as fishing vessels. The concept is OK, because in a crisis you do need to use additional people,?said Candito, but in this case theproposal is so prescriptive that the cost would just be astronomical.? A major concern AWO has regard- ing the vessel of opportunity system is the crew safety standards,? said Costanzo. We are worried about the safety of vessels and their crews and were concerned that unforeseen issues could delay or hinder response activities. Our member companies focus on safety and environmental protection every day. Every member company of AWO participates in the Responsible Carrier Program (RCP). We believe that this regulation must include an equivalency to the RCP and include Best Management Practices for participating vessels in the rulemaking ? including training that matches the task of the respond- ing vessel of opportunity and drug and alcohol testing policies forcrews.? Luckily, Costanzo reported that to date, the Department of Ecology has been responsive to our concerns and the maritime industry has been deeply involved in the rulemaking process and the Rulemaking Advisory Committee.?California has seen court cases which pit state laws against federallaws, but Costanzo said, I havent 44MNApril 2012