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32 OCTOBER 2015 FOGHORN26 MAY 2013 FOGHORN REGuLaTORyREPoRT grandfathered compliance deferred for good and sufficient reason by the new regulation. Also your own records may contain the informa- tion you need if a previous oCMI accepted the installation or process under the equivalency or alternative provisions contained in regulation. If the response to your request for a cited regulation and reason is vague or one that threatens addi- tional actions it is likely founded on less than regulation. A threatening response is both unwarranted and unprofessional. Under ordinary cir- cumstances resolution should be at the lowest level possible. In this case the route to resolution is less clear but still ultimately leads to the oCMI or higher authority if not resolved beforehand. Should you decide to appeal POWERFUL FLEXIBLE INTUITIVE. 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Use it At the office At home On your laptop On your smartphone On your iPad At the dock Free setup training and ongoing support Fully hosted and managed 247 Personal U.S.-based account reps MOST TOUR OPERATORS CAN USE STARBOARD SUITE FOR FREE remember an appeal under regu- lation only starts when an oCMI has made a decision and you wish to challenge it or take it to a higher authority with more discretionary authority. You have the right and an acknowledged opportunity to work your way through the chain of command with dispatch and without hindrance to the oCMI. Shortly after the adoption of the Coast guards Enhanced Marine Safety Program many Sector Commanders invited comment from their regulated entities on any matter and many included their cell phone numbers and personal email addresses on their business cards. This may be the case in your sector. While the foregoing instances are relatively few they must be addressed promptly. With industry support Congress has repopulat- ed and adequately resourced the marine safety programs with several hundred new positions and billets. These new marine safety resources need to be trained in regulation and administrative processes exposed to missions under supervision and then tested on their knowledge. one senior officer indicated that goal is probably three to five years off. Like all the other Coast guard missions marine safety has a re- quirement for training and qualifica- tion before being assigned particular tasks. The Commandant has noted that training and qualification alone is not necessarily proficiency and his goal for mission performance is pro- ficiency. In marine safety proficiency is not only knowing the regulations and policies but understanding and using the embedded authorities to exercise equivalency consistency and alternative compliance when ap- propriate. That program fails when the operator cannot access the chain of command or when discouraged by the inspector or intermediate su- pervisory personnel. n MEMBERNEWS Hornblower Cruises Events has named Gordon Loebl Senior Vice President Marine Operations according to Chairman and CEO Terry MacRae. Loebl will be responsible for supporting Hornblower Cruises Events multiple home ports over- seeing facilities capital projects and associated budgets establishing and maintaining relationships with regulatory agencies directing the corporate engineering and project team ensuring safety standards participating in new business de- velopment and leading efforts to develop and utilize new technol- ogy.In this hands-on executive man- Hornblower Announces New Senior VP of Marine Operations agement position Loebls focus will be on the development and growth of Marine Operations throughout the Hornblower group of companies. We are thrilled to have Gordon bring his experience and pro- fessionalism in the industry to Hornblower Cruises Events. With our continued growth and visibility our team will benefit from his deep contacts in the industry and its regu- lators according to MacRae. Prior to this new appointment Captain Loebls had a 28-year career in the U.S. Coast Guard. For 35 years Hornblower Cruises Eventshas been operating charter yachts and public dining cruises. The company operates over 70 vessels and has ports in San Francisco Berkeley Sacramento Long Beach Newport Beach Marina del Rey San Diego CA as well as in New York City. Two Hornblower subsid- iary businesses Alcatraz Cruises and Statue Cruises are National Park Service ferry concessioners to Alcatraz Island the Statue of Liberty and Ellis Island. In 2014 Hornblower Cruises Eventsbegan operating the third subsidiary Hornblower Niagara Cruises out of Niagara Falls Ontario Canada. n Gordon Loebl Hornblower Cruises Events.