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july 2015 FOGHORN 21 how pva benefits you Navigating your risks day and night. As the owner of a passenger vessel you face tough decisions every day from hiring qualied crew to making sure your vessel is in prime condition. At Aon we spend day and night thinking about your maritime risks so buying insurance doesnt have to be another tough decision. We work with you to develop creative approaches and customized solutions that deliver more efficiencies improved protability and greater value. For more information please call 1.800.730.7053 or visit passengervessel.commember-resources.htmlinsurance Risk. Reinsurance. Human Resources. Navigating your Aon Risk Solutions Marine It was PVAs advocacy efforts that lead to this authority and penalty statutorily mandated by a Congressional amendment to the pre-existing law. Previous versions of the statute only allowed an operator to be charged but this amendment provided the Coast Guard the ability to peruse a civil penalty against any individual that interfered with the safe operation of a vessel. Recently there have been at least two instances of Coast Guard en- forcement that have garnered media attention reinforcing the dangers and costly consequences of rail jumping. In April Coast Guard Sector Puget Sound fined a man 5000 for inten- tionally jumping off a vessel.Another civil fine was issued for rail jumping in the San Francisco Bay area where the Coast Guard fined a passenger 5000 for jumping off a moving vessel in June. In both instances the individuals were safely recovered by the crew but the individuals were later met shore side with enforcement actions by Coast Guard authorities. Challenging Cost Analysis of Proposed Regulation PVA challenged the Coast Guards regulatory cost analysis in its additional comments on the recently re-opened proposed rule Consolidation of Cruise Ship Security Measures USCG-2006- 23846. PVA had previously commented both at a public hearing and through written comments on the appropriate application of this rule. As currently defined this proposal would go beyond the scope of large terminals and extend to facilities that receive cruise ship tenders even though they do not receive cruise ships them- selves. PVA additionally challenged the Coast Guards cost impact analyses. These important components of eval- uating every rulemaking include the Preliminary Regulatory Analysis and the Regulatory Flexibility Analysis which include a variety of evalua- tion factors including examining the scope and size of businesses that will be impacted and the actually cost of implementing the new rule. When the Coast Guard found that it had failed to post on www.regua- tions.gov the required Regulatory Analyses it posted the document and reopened the comment period for further public review. In its follow-up comments PVA stated that these released analyses dramatically un- derestimate the cost to be incurred