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The Coast Guard created this timeframe problem when it promulgated the SMFF regulations and treated the CO-

NUS situation differently than the OCONUS situation. For marine casualties in OCONUS waters, the timeframes relate to casualties occurring within 50 nm of COTP cities. There- fore, the regulatory timeframes for SMFF responses do not apply to marine casualties occurring in nearshore coastal wa- ters off Hilo because Hilo is located more than 50 nm from

Honolulu. SMFF responses are still expected to occur as rapidly as possible, but there is no applicable regulatory con- struct. It would be wholly realistic and logical to apply the

OCONUS rule nationwide, because the problem exists not just off Fort Pierce but in numerous other locations where the distance between COTP cities is greater than 100 nm.

LPHABET OUP UB S

A S : VRP, S M & COI’

An unrelated situation is starting to impact the vessel re- sponse plan program. Towing vessels are in the process of be- coming inspected vessels of the United States. Previously, as uninspected vessels, very few regulations limited their opera- tions. As inspected vessels, though, towboats are being issued

Certi? cates of Inspection (COIs), which include routes the vessel is authorized to ply and activities in which the vessel is authorized to engage. Many towboats are identi? ed in ves- sel response plans as resource providers. The holders of plans that identify towboats as resources must now check to ensure that the towboats identi? ed are actually authorized to provide the identi? ed service in the location provided for in the plan.

Those complications aside though, the marine casualty response situation in U.S. waters generally exceeds that of any other nation worldwide. The U.S. Coast Guard and numerous stakeholders, including owners and operators of tank vessels and nontank vessels, and the oil spill response organizations (OSROs) and salvage and marine ? re? ght- ing (SMFF) resource providers can be justly proud of their achievements in this respect.

Dennis L. Bryant retired from the U.S. Coast Guard with the rank of Captain after 27 years active duty.

He had various tours as a law specialist, including an assignment as the Coast Guard’s Law of the Sea of