JULY 2019 • FOGHORN 21 REGULATORYREPORT The radar observer endorsement on the MMC will now be renewed together to comply with a congres- sional directive to the Coast Guard to harmonize MMC and radar endorse- ment renewal dates. This change to harmonize dates applies to MMCs at the time of renewal so for existing credentials.According to the Coast Guard, “Until July 22, 2024, a person may satisfy the requirements… by having immediately available a valid course completion certificate from an appropriate Coast Guard approved or accepted radar course that was issued within the previous five years.” As always, the best way to under- stand the Coast Guard intent of a reg- ulatory change is to read the Federal Register notice that not only states the final rule, but the notice preamble gives insight into the Coast Guard’s motiva- tion and how it addressed any public comments. This rule had a history that involved Coast Guard advisory committee input, a notice of proposed rulemaking (NPRM) with extensive public comment, congressional address, and then the final rule notice. While the regulations are clear in this final rule, the Coast Guard has also issued a CG-MMC Policy Letter No. 03-19 to assist “in applying statutory and regulatory requirements the guidance is not a substitute for applica- ble legal requirements nor is it in itself regulation.” The policy letter identifies that a completion of an appropriate or accepted original refresher or recertifi- cation course, having instructed a Coast Guard-approved or accepted radar course at least twice in the past five years, or the new provision of service on radar equipped vessels where radar is routinely used for navigation and collision avoidance will renew the radar endorsement. The policy letter also identifies vessels that by regulation are required to have radar for navigation and collision avoidance. Mariners reporting service on these vessels as master or mate will be presumed to have used the radar for navigation and collision avoidance during their service on these vessels. Small passenger vessels (Subchapter K and T) are not listed in the policy letter. Although small passenger vessels have a regulatory re- quirement for radar it lists some service EXCEED GLOBAL EMISSIONS STANDARDS Build your next ferry to exceed the upcoming global environmental emssions standards. Operate a lightweight vessel equipped with hybrid or electric engines. Reduce your operating and maintenance costs while minimizing your environmental impact. BUILD A CARBON FIBER FERRY. Learn more about America’s only carbon T- and K-Class ferry builder: www.ARCADIA-ALLIANCE.com As always, the best way to understand the Coast Guard intent of a regulatory change is to read the Federal Register notice that not only states the final rule, but the notice preamble gives insight into the Coast Guard’s motivation and how it addressed any public comments.