b'Continued from page 4: Letter from the PresidentAT THE HELM SeparatefromtheTWICrequire- VRP rule by using a Coast Guard-grace period. PVA believes that a two-ment,CoastGuardcredentialedapproved ATEP. year interval would reduce the finan-mariners are required to undergo acial burden to vessel operators but in background check that not only ad- PVA requested that the Coast Guardno way compromise safety.dressesprofessionalqualifications,provide more flexibility to extend five-butalsothesafetyandsuitabilityyeardrydockintervalregulation.AAcoupleofotherregulatoryappeal oftheapplicant.Themandatoryvessel operating in fresh water shouldrequests included:issuance of a TWIC card and usebe subject to risk-based decision mak-of that card for access to vessels anding in considering to extend the five- Eliminatingtherequirementthat facilities is redundant and, in mostyear drydocking interval. Conditionsa vessel operating on inland waters cases, not required by regulation. of operating environment, operatingmust carry flares. Carrying flares as history,andpreviousdrydockin- a means of emergency signaling is anA request was also made in the letterspection results should be part of theobsolete and outdated requirement. to the OMB to amend the Non-Tankprocess. Also, the nations drydocking VesselResponsePlan(NTVRP)infrastructurewillbesorelytestedThe same argument could be made rule to enable more passenger vesselsover the next few years with the ad- for Rule 27 Vessels Not Under Com-to comply with training and exerciseditionoffivethousandplusvesselsmand or Restricted in their Ability to requirements by using an approvedto the population of vessels subject toManeuver. The requirement to have alternativetrainingandexerciseCoast Guard inspection.these light and day shapes is unnec-program (ATEP). PVA recommend- essarily redundant and obsolete with ed that the Coast Guard amend thePVA requested that the Coast Guardtodays technology.rule to enable a small passenger ves- change the required interval to service sel or a passenger vessel with a fuelinflatablebuoyantapparatus(IBA)Another topic of discussion at the QP capacity of between 250 and 2,499to once every two years or more. Thewas PVA seeking clarification on the barrels to comply with training andtypical service interval for an IBA isdetermination of sea service related to exerciserequirementsoftheNT- once per year after an initial two-yearserviceonboarddomesticpassenger vessels. Just as a clarification, individ-uals employed on domestic passenger vessels,credentialedornon-creden-tialed,canincludedocksideactivi-tiesinsupportofvesseloperations, including but not limited to mainte-nance,startup,drillsandexercises, securing for the night, etc., in addi-tion to time underway, in calculating the number of hours worked in a day for the purpose of determining days of sea service.Also,PVArecommendedthatthe Coast Guard establish a policy to al-low individuals employed on domestic passenger vessels of at least 100GRT, to be credited for a half day of sea ser-vice when the time employed on board the vessel is at least four hours but less than eight hours in a day. Just as the FOGHORN 58'