Page 13: of Maritime Reporter Magazine (July 2017)

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squarely on the vessel owners and op- ? re? ghting requirements the Coast where signi? cant salvage and marine erators. No explanation was provided Guard adopted a system of measuring ? re? ghting resources may be located. for the agency’s rejection of the Marine response times in two ways. For casu- Examples of such distant CONUS lo-

Board’s recommendation in this regard, alties off the shores of the 48 continen- cations include, but are not limited to: although it appears that the Coast Guard tal states (CONUS), response time was Crescent City, CA; the entrance to the believed that it did not have the resourc- measured based on the distance from Strait of Juan de Fuca; Fort Pierce, FL; es to properly evaluate and classify shore (the nearest point of land). For Bar Harbor, ME; and many portions of these additional resource providers. It is casualties off the shores of other U.S. the Great Lakes and Western Rivers.

wholly unrealistic, though, to expect the locations (i.e., Alaska, Hawaii, Guam), It is therefore recommended that the vessel owners and operators are better response time was measured based on Coast Guard initiate a rulemaking to situated than the Coast Guard to evalu- the distance of the casualty from the rel- amend the salvage and marine ? re? ght- ate the adequacy of salvage and marine evant Captain of the Port (COTP) city. ing regulations to re? ect reality. Among ? re? ghting resource providers. Many A comment stating that the proposed other things, the Coast Guard should of these owners and operators are small response time regime was inappropri- adopt the Marine Board recommenda- entities and the burden of determining ate for certain CONUS locations was tion mentioned above and institute a the adequacy of the resource providers rejected with the statement: “All con- classi? cation system for salvage and

About the Author can exceed their capability. In addition, tinental U.S. (CONUS) coastlines are marine ? re? ghting resource providers,

Dennis L. Bryant is with Bryant’s Mari- since there are only four national full- covered by this ? nal rule and this rule similar to that already in place for OS- time Consulting, and a regular contribu- service providers of salvage and marine does not impose any additional capital ROs. It should also revise the response tor to Maritime Reporter & Engineering ? re? ghting services and a handful of requirements on industry.” time requirements of CONUS locations

News as well as online at MaritimePro- specialized or regional providers, a clas- While that statement may techni- so as to measure response times based fessional.com. t: 1 352 692 5493 si? cation program for these elements cally be true, it did not respond to the on the distance from the nearest COTP e: dennis.l.bryant@gmail.com would be relatively straightforward. relevant comment. In fact, there are city. The current regulations, at least in

In the 31 December 2008 ? nal rule various CONUS locations that are quite these respects, are highly aspirational implementing the salvage and marine distant from a COTP port or other port and unrealistic.

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