As you know, for some time I have been pleading with the Coast Guard to increase the dollar thresholds that trigger marine reporting requirements for “marine casualty” and “serious marine incident.”

I have argued, along with the Passenger Vessel Association (PVA) and other industry groups, that the thresholds simply don’t reflect today’s costs. The amounts should be increased substantially to account for inflation. According to the Coast Guard, the $25,000 threshold that triggers a 2692 marine casualty report was established in 1980 and has not been adjusted to account for inflation. As a result, mariners have had to submit numerous unnecessary casualty reports, an administrative burden which takes away from our core missions and exposes vessel operators to potentially costly legal and media scrutiny. But it now appears that our hard work is be paying off.

In late January, the Coast Guard published a proposed rule in the Federal Register to raise the marine casualty and incident reporting thresholds to $72,000 for a marine casualty and $200,000 for a serious marine incident. Current regulations call for amounts of $25,000 and $100,000. This long awaited change is not yet final and your input and support is needed.

While I am pleased that the proposed rule has been published, many of us, including PVA, had hoped that it would also include an automatic indexing feature. This would ensure that future threshold adjustments will account for increases in the consumer price index without going through the formal rulemaking process. The proposed rule does not do this, and we should continue to strongly encourage it.

All commercial vessel operators have a stake in this debate and your input and comments on this proposed rule are very important. I urge you to support increases in the Coast Guard’s marine casualty reporting thresholds.

The deadline for comments to the docket is March 24. Please join me in commenting on this proposed rule. My hope is that together we can improve this situation once and for all.

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