FR 2024-27026

The document issued by the Coast Guard proposes significant updates to the Merchant Mariner Credentialing system. It primarily shifts the processing of mariner credential applications and related fee payments to an electronic format. This move aims to modernize the credentialing process, making it more efficient and user-friendly. The new rule will take effect on January 19, 2025.

Summary of Changes

The Coast Guard's final rule permits electronic submissions and payments for mariner credentialing applications. This change not only supports a new IT system but also removes the requirement for prospective mariners to take an oath in person. Additionally, the rule simplifies procedures related to the Certificate of Discharge and adopts gender-neutral language across regulatory texts. These modifications seek to improve clarity and streamline processes, making it easier for mariners to manage their credentials.

Issues and Concerns

One significant issue is the complexity of the regulatory analysis in the document, which includes a detailed cost savings analysis under multiple assumptions. This complexity may cause confusion, particularly for readers who are not experts in regulatory or economic analysis. Furthermore, the reliance on outdated data, such as postal service fees, could potentially undermine the accuracy of the cost evaluations presented.

There is also concern regarding technological assumptions. The document assumes a widespread capability among mariners to access and utilize electronic systems, which may not be true for all. The digital divide still affects many, and assuming universal access could disenfranchise some stakeholders.

The extensive use of footnotes can make the document difficult to navigate, as readers must frequently switch context to gather necessary details. Additionally, references to external data and reports without summarizing their content within the document may reduce clarity and ease of understanding for the general public.

Broad Public Impact

Broadly speaking, this document indicates a shift toward digital technology in governmental processes. For the general public, this means an expectation of more efficient interactions with maritime credentialing processes. However, it also means that individuals must be prepared to engage with technology, which may require additional learning and adaptation.

Impact on Specific Stakeholders

For mariners, these changes could streamline the credentialing procedure, reducing the need for physical paperwork and in-person appointments. This could save time and money, providing flexibility and convenience. However, mariners without easy access to digital payment methods might find themselves at a disadvantage as the rule eliminates options to pay fees by cash or check.

Additionally, government employees involved in in-person processing may see changes in their workload, redirecting focus toward managing electronic submissions instead of manual transactions. This could potentially improve efficiency within government processes, though it may also require additional training for the staff to adapt to the new system.

Overall, while the rule aims to promote modern and efficient processes, it must ensure that no segment of stakeholders is unfairly burdened or left behind due to technological gaps. As such, addressing these concerns through additional support and resources to affected stakeholders will be crucial to the rule’s successful implementation.

The Federal Register document addresses several financial aspects associated with the transformation of the Mariner Credentialing Program. Here is a detailed examination of these components:

Summary of Financial References

The document outlines cost savings resulting from regulatory changes. The primary financial reference is the shift from in-person to electronic payment methods for mariner credentialing fees. Applicants who previously paid fees at Regional Exam Centers (RECs) with cash or credit card will now complete payments electronically, primarily through Pay.gov. This change is estimated to result in annualized cost savings of $141,320 for applicants, when considering the transition from cash, credit cards, and checks. Over a 10-year period, the discounted total cost savings using a 7-percent discount rate is projected to be approximately $1.0 million.

Impact of Financial References on Identified Issues

One of the main issues identified in Section V is the complexity of the regulatory analysis. The detailed cost savings analysis in section § 10.225(c), particularly the use of multiple assumptions (Assumptions 1 and 2), underscores this complexity. These assumptions pertain to how original applicants can save costs when obtaining an oath through a notary public or bank branch, estimated to save applicants a total discounted amount of $1.7 million under Assumption 1 or $2.3 million under Assumption 2. These extensive financial analyses could confuse readers, and the document might benefit from simplified summaries or visual aids to clarify these complex calculations.

Additionally, the removal of in-person payment options could impact certain applicants negatively, especially those lacking access to electronic payment methods. While a prepaid card option could mitigate this concern, the overall elimination of cash and check payment options may pose challenges for applicants accustomed to or reliant on traditional methods.

Technological Assumptions and Financial Impacts

The document assumes high digital accessibility among applicants, suggesting that utilizing electronic payments such as Pay.gov will save costs and offer convenience. However, the financial references could overlook segments of the population affected by the digital divide, who may struggle with accessing electronic payment methods. Compounding this are concerns raised about outdated postal rates, like the $0.63 cost for USPS stamps mentioned in the context of mailing checks, highlighting areas where updated data could enhance financial analysis accuracy.

Administrative Savings

The document estimates that shifting the processing of payments to an electronic system will save the Coast Guard about $32,817 annually, with a total discounted 10-year cost saving of approximately $230,491. This suggests significant reductions in administrative burdens and costs through digitization, aligning with broader goals of streamlining government operations. However, the heavy reliance on footnotes and external data sources could hamper comprehension of these savings’ implications if the document's structure makes it difficult for readers to immediately access contextual information.

Overall, while the regulatory changes are positioned as cost-saving measures with potential benefits for both applicants and the administrative agency, the complexity and assumptions underlying these savings present clarity challenges. Simplifying the financial analysis and making it more accessible could better convey these reforms' economic impacts to a broad audience.