b'REGULATORYREPORTtowing vessels. it increases the level of safety of life, en- ration for navigation and crew super-The Merchant Personnel Advisoryvironmental protection, or protection ofvision. More and more regulations Committee (MERPAC) was similarlyproperty at sea beyond that providedare requiring the master to exercise tasked with reviewing the issue.by the LOD option. oversight and logging of vessel prepa-MERPAC after determining that bothThe cost avoidance of this proposalration, drills and operational activity. schemes of endorsed MMCs and LODfor the towing industry is substantialThis administrative and performance personnel for PIC compliance providedand obvious but there is also a potentialloading of the vessels master requires effective pollution prevention duringcost benefit for our PVA members indelegation or elimination of lesser fuel transfers recommended thatthat a properly trained crewmemberduties, This NPRM proposes to transfer the LOD for crew be extended to allnow can be tasked with the fuel transferthe responsibility to crewmember with inspected vessels.duties. This can relieve the master forno loss of effi cacy or pollution preven-The Coast Guard reviewed thethe more significant duties of prepa- tion activity. n recommendations from both TSAC and MERPAC, and agreed with MERPACs broader recommendationEXCEED GLOBAL EMISSIONS STANDARDS that all inspected vessels should have the option of using an LOD to satisfy the requirement for designating the PIC of fuel transfers. Hence the Coast Guard moved the concept to a regula-tory change identifi ed as NPRM USCG-2018-0493. With the recommendations of two advisory committees in hand, the (t)he Coast Guard compared the requirement to complete approved training in order to obtain an MMC with a Tankerman PIC endorsement for PICs on inspected vessels and the formal instruction provided on uninspected vessels, as a requirement for issuing an LOD on uninspected vessels. The Coast Guard could not discern a meaningful differ-ence in fueling operations on uninspect-ed towing vessels and inspected vessels that require Tankerman-PIC endorse-ments. As uninspected vessels move to becoming inspected vessels their fuel oil transfer operations do not change, but the change in the requirement to hold an MMC means the individuals con-ducting the fuel oil transfer must obtain substantially more costly training and demonstrate experience with cargo transfers. While fuel oil transfers are similar in nature to cargo transfers, they cannot be used to demonstrate theBuild your next ferry to exceed the upcoming global environmental service requirements for a Tankermanemssions standards. Operate a lightweight vessel equipped with PIC endorsement described in 46 CFRhybrid or electric engines. Reduce your operating and maintenance 13.203(b). As a result, the Coast Guardcosts while minimizing your environmental impact. is proposing to allow the use of LODs on all inspected vessels. The existingBUILD A CARBON FIBER FERRY. 155.710(e)(1) requirement is overly burdensome on personnel engaged inLearn more about Americas only carbon T- and K-Class ferry builder:fuel oil transfers on inspected vesselswww. ARCADIA-ALLIANCE .comthat require a Declaration of Inspection (DOI), (8) and we have no evidence that NOVEMBER 2019FOGHORN 27'