b'22.Arethereanyadditionalfactorsthatwe(the Coast Guard) should consider?PVAS FLAGSHIP SMS Letter from the Executive Director: continued from p 7SAFETY As noted in questions 9 and 11 above, the CoastRoundtable sessions held during the PVA Virtual Convention at GuardhasidentifiedPVAsFlagshipSMSasaMariTrends 2021 continued:recognized system.Flagship SMS is an internally auditedsystemmuchlikethePVAAlternativeNew Business Ideas: Where are Your New Markets?SecurityProgram(ASP).Anumberofmember companieshelpeddevelopFlagshipSMSover Safety Management Systems and the PVA FLAGSHIP Program several years culminating in Coast Guard acceptance in2017.InformationofPVAsFlagshipSMSis How Will You Change Your Marketing in a Post-COVID World?available in the Member Download area of the PVA website.We look forward to having you join us for the PVA Virtual Convention at PVA WORKING GROUP MariTrends 2021.While we miss gathering for the face-to face event, we UponpublicationoftheANPRM,PVAstoodhope that this years event will be both productive and informative. up a working group made of up members of theIn the meantime, please let me know whenever we can be of assistance to you.RegulatoryandSafety&SecurityCommittees.TheworkinggroupdeliverablesincludePVAsSincerely, comment letter to the ANPRM docket addressing all 22 questions above, and a template for use by any PVA member who would like to comment on the ANPRM.It will be critically important that members comment to the docket about the potential impactsofaSMSrulemakingbothpositiveandJohn R. Groundwaternegative.Comments are due by April 15, 2021.IfExecutive Directoryou have any questions about the ANPRM or PVAs Flagship SMS, please contact me at echristensen@passengervessel.com.SAFETY MATTERS 32 FOGHORN'