b'vessels passenger capacity, route, and passenger accommodations are variables that impact the risk assessment and generally speaking vessel owners want to maintain a vessels value by maximizing its revenue generating potential.That leaves fleet and individual SAFETY vessel performance.Casualties, deficiencies, and detentions are factored into the risk assessment and as CAPT Edwards pointed out, the Coast Guard used 20 years of MISLE (the Coast Guards activity database) data to assess performance.In addition, if a particular vessel type or service type has a greater risk of casualties, then other vessels in that type will also be impacted during the risk assessment.That is why nearly all overnight small passenger vessels were sent Tier 1 letters.The only exception discussed by the Coast Guard is for vessels enrolled in the Streamline Inspection Program (SIP).SIP is an accepted alternative inspection program laid out in 46 CFR, Part 8.SIP vessels are not subject to the inspection tier policy and those vessels that have received Tier 1 letters have had those letters rescinded.Vessels that have implemented a voluntary SMS can also seek reconsideration of a Tier 1 determination through the local OCMI.Because there is no requirement for an SMS on domestic passenger vessels, there is no way of Coast Guard Headquarters automatically knowing a vessel has a voluntary SMS when they are put through the risk screening algorithm.In addition, because there is a range of management systems available from internally audited (PVAs Flagship SMS) to full blown third party audited systems downgrading at the OCMI level is not guaranteed for thePVA staff and leadership will continue to work with the Coast 2021 operating season.That said, Coast Guard HeadquartersGuard at the highest levels through the Quality Partnership to will be reviewing the risk model annually and is looking at how toaddress and resolve members concerns.credit vessels and companies that implement a SMS.SAFETY MATTERS 34 FOGHORN'