Page 12: of Marine News Magazine (March 2022)

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Insights

Guard does not get this money. Guard is serious about enforcing that deadline, which they

So, as we look at this rule, the Coast Guard didn’t just need to be and which is only fair to the vast majority of decide to do this. They are required to assess user fees. operators who have worked really hard to get ready.

But they have the authority, under law, to consider fac- tors, including the public interest, in deciding what fees to

Technology in areas like vessel autonomy charge. We’re going to be convening our members to do a and electri? cation is advancing ahead of deeper dive into their proposed rule. But what I would say regulations. What’s the solution to this problem, at this point is we would like to see fees slashed for TSMS and how can the industry and regulators best vessels and frozen for Coast Guard option vessels. TSMS strike a balance to ensure vessels remain safe vessel owners pay tens of thousands of dollars in fees to without sti? ing innovation?

Coast Guard approved third parties. They have been really JC: Great question. A few thoughts on that. One is to re- overpaying Coast Guard inspection user fees since the user ally recognize the safety and environmental bene? t of in- fee went into effect for some as early as 2020. They really novation and lean into it. Sometimes you hear innovation deserve a timeout from fees. For Coast Guard vessels, we technology and you think, “Oh, this is something to be bal- think, keep it the same for now. Don’t triple it. Compa- anced against safety.” And I think there are certainly times nies who are using both options, TSMS and Coast Guard, when that’s true. But I think it’s important to recognize that have invested millions of dollars in compliance costs to get technology has huge potential to make things safer for the ready for the hundred percent COI to deadline in July of industry, to give mariners and shore side employees new this year. And we really think coming up, a pandemic and and better tools to do things safely. It’s important that we a recession and facing labor shortage and increased costs ? rst and foremost, make sure that the adoption of safety en- across the board, now is not the right time to increase fees hancing technology is not being discouraged with ill-? tting that don’t increase safety or bene? t Coast Guard programs. regulations. So for example, if a vessel owner is installing certi? ed, automated equipment in the engine room, which by regulation should qualify it for a manning level, a crew-

With regard to Subchapter M, how are things ing level that takes into account that automation, then we looking on that front? And do you expect that need to make sure that it really does and not, “Wow, I’ve almost everybody will be ready on time?

JC: I am feeling very bullish about AWO members being made this enormous investment in safety enhancing tech- ready, being where they need to be, and getting to 100% nology and I’m being told that I have to crew this engine ? eet certi? cation by July 19. We are increasingly seeing room in exactly the same way I would if I didn’t have it.”

Subchapter M doing what it was intended to do, which That is a discouragement to the adoption of technology.

was raise the bar of safety across the board. We’ve begun Two would be, we need to make sure that the Coast to see the retirement of some more marginal equipment. I Guard has the statutory authority and ? exibility to estab- think we’re going to see more of that as we get closer to July lish appropriate standards. And if they don’t, then they 19. So that we really get to that date and it’s like, “Hey, the need to get it. They need to go to Congress and get it. And vessels that are ready, the vast majority of vessels that are we, as an industry, will certainly support it. So that could ready and meet the standards, off they go, and it’s going to take a form of seeking statutory authority to authorize cer- be a positive thing for industry safety.” tain pilot projects and report back to Congress within a

Those vessels that just can’t get there. They need to go; certain period of time on the safety bene? ts or on safety they need to be retired. They need to be taken out of ser- needs. It doesn’t need to be as complicated as, “Oh boy. vice. And AWO members who are going to be ready on We have to be stuck here until we can rewrite the whole

July 19 are expecting the Coast Guard to hold the whole code of federal regulations or the whole US code as it ap- industry accountable. The deadline is the deadline. It’s plies to certain subjects.” No. There’ll be time to go back been a long time coming. Everybody needs to be ready. and make strategic changes, but there’s an opportunity to

And I think we’re increasingly feeling good that the Coast make sure that the Coast Guard has the broad authority to 12 | MN March 2022