In last month’s column, it was explained how and why mariners should submit comments and suggestions to the rulemaking process that will eventually bring towing vessels under some form of inspection.
Despite the federal government’s trend toward more secrecy and the exclusion of the public from important public policy debates, anyone who wishes to participate in the uninspected towing vessel rulemaking process can. But how you participate can be just as important as the act of getting involved.
Historically, one of the Coast Guard’s pet peeves when reviewing and responding to comments and criticism is the tendency for mariners to air complaints that have no relation to the subject matter. This isn’t the appropriate time or place to rant about shortcomings with the Coast Guard’s licensing/certification program or to express your displeasure with security requirements. It doesn’t matter whether the criticism is valid or not. You are simply aiming in the wrong direction. The Coast Guard is extremely busy and understaffed. Don’t waste their time.
Mariners should closely follow the rulemaking process and pay careful attention to the wording of the notices published in the Federal Register. In the summary section is an outline of the overall goals for the current stage of the process. Listed in the questions section are specific questions, and the Coast Guard will be looking for specific answers. Staying within this framework will provide you with the best chance of influencing the outcome in a positive and meaningful way. But keep in mind that the Coast Guard is free to ignore the advice of mariners, regardless of whether it is good or bad.
It’s also a good idea to check the docket and read comments that have already been posted. Many operators have already weighed in, and the American Waterways Operators Responsible Carrier Program seems to be a popular model for the new regulations. Those who aren’t familiar with the AWO’s RCP should read it before submitting their own comments.
As of late February, the only mariner organization that has commented is the Houma, La.-based Gulf Coast Mariners Association. The rest of us need to speak up too.