FR 2021-00372

The document from the Federal Register outlines a notice from the Coast Guard making available a policy letter titled "Guidelines for Obtaining STCW Endorsements for Basic and Advanced IGF Code Operations." This policy provides guidance for mariners on how to voluntarily obtain endorsements for working on vessels that use gases or low flashpoint fuels, in line with international safety standards as defined by the International Maritime Organization (IMO). These endorsements are not mandatory, but they are important for ensuring compliance with international standards, particularly when operating in foreign ports.

General Summary

The policy is a response to industry requests for guidance on obtaining endorsements that certify mariners' ability to operate vessels using gases or low flashpoint fuels. This is significant because these types of fuels are becoming more common as the marine industry seeks to reduce its environmental impact. The policy aligns with the International Convention on Standards of Training, Certification, and Watchkeeping for Seafarers, which sets global training and certification standards.

Significant Issues and Concerns

One concern is the lack of transparency regarding how the estimated costs to industry and the Federal Government were calculated. The document mentions a total cost of over $11 million but does not provide detailed data to support this figure. This could raise questions about the accuracy and justification of these costs.

The document also lacks a clear explanation of the difference between the newly issued CG-MMC Policy Letter 01-21 and the previous Policy Letter 02-19, which could lead to confusion for those not familiar with these specific policy letters. Additionally, while mariners will not be charged a fee for the endorsements themselves, the potential costs of training required to meet the endorsement requirements are not addressed, which could be a hidden financial burden for mariners.

Moreover, there is mention of an increased time burden on mariners for submitting documentation, estimated at 42 hours annually, but there is no context provided about how significant this burden is in relation to their overall workload.

Finally, while the policy’s compliance is voluntary, the document does not address potential consequences for mariners or vessel operators who choose not to comply, especially concerning foreign port state control actions that could affect operations in international waters.

Impact on the Public

Broadly, this policy could have varying impacts on the public and stakeholders within the maritime industry. For the general maritime workforce, the policy provides an opportunity to enhance their skills and credentials, potentially leading to better job prospects. However, the time and financial costs associated with obtaining these endorsements might deter some mariners from pursuing them.

Impact on Specific Stakeholders

For vessel operators and the maritime industry, having crew members qualified with these endorsements could facilitate smoother operations, especially in international ports where compliance with the International Convention on Standards of Training, Certification, and Watchkeeping for Seafarers is scrutinized. It may also contribute to safer and more efficient fuel operations.

On the negative side, operators might face increased operational costs due to training investment and potential delays if mariners are not adequately certified, affecting scheduling and profitability. Regulatory bodies could potentially benefit as well, as this move aligns U.S. policies with international standards, possibly reducing non-compliance incidents in foreign ports.

In conclusion, while this policy offers clear benefits in terms of aligning with international standards and enhancing mariner certifications, the potential costs and burdens should be carefully considered by all stakeholders to ensure broad compliance and minimize negative impacts.

The document from the Federal Register provides details regarding a policy related to Merchant Mariner Credential endorsements for operations on vessels using gases or low flashpoint fuels. The financial implications of this policy are a core component of the notice and worth a closer look.

The Coast Guard estimates that the policy will generate a total cost of $11,068,608 over a ten-year period. This figure is broken down into $10,917,059 for costs to industry and $151,549 for costs to the Federal Government, presented in 2019 dollars and discounted at 7 percent. These costs reflect the financial impact anticipated from the policy's implementation on both the private sector (maritime industry) and public sector (government bodies supporting or enforcing the policy).

Despite providing these financial estimates, the document does not offer detailed insight into how these costs were calculated, which appears to be an issue noted within the document. This lack of transparency may lead to questions about the accuracy and justification of the stated financial impact. For stakeholders such as maritime companies and mariners, having a clearer breakdown of these costs could be crucial for understanding their potential financial obligations and budgeting appropriately.

The document also indicates that there will be no fees for mariners to add an STCW endorsement to a Merchant Mariner Credential (MMC), which on the surface might seem favorable. However, the document fails to elaborate on the potential hidden costs associated with obtaining the necessary training to qualify for such endorsements. Mariners seeking to meet the endorsement requirements would likely incur costs related to training, though these are not detailed or quantified in the document.

Furthermore, the document briefly mentions that the policy may result in an increased annual hourly burden for mariners submitting documentation, estimated at around 42 hours collectively. While this is identified as an additional demand on mariners' time, further context on how significant this burden is in relation to their workload is not provided. Understanding this could be vital for comprehensively assessing the indirect costs of compliance with this policy.

In summary, while the financial references in the document provide some insights into the anticipated costs associated with the policy, there is a notable lack of detail in how these figures were derived. Additionally, the document does not fully address the potential hidden costs or the broader implications of the policy's implementation on mariners and the industry. Providing more comprehensive information would aid in a clearer understanding for those affected by these measures.