Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28 Page 29 Page 30 Page 31 Page 32JUNE 2016 • FOGHORN 15 REGULATORYREPORT www.incatcrowther.com OPERATIONAL STUDIES | FUNCTIONAL DESIGN | PRODUCTION DESIGN | PROCUREMENT | CONSTRUCTION SUPPORT | THROUGH-LIFE SUPPORT | CONSULTING DESIGNER OF ROBUST, EFFICIENT PASSENGER VESSELS 41m Catamaran Passenger Ferry 2 x 400 pax ferries under construction for WETA San Francisco 27m Catamaran Passenger Ferry 2 x 150 pax ferries under construction for MBTA Boston Incat Crowther E V E R E V O L V I N G E V E R I M P R O V I N G did not fit the scope of the existing Subchapter T. To address the growth of small passenger vessels in physical size, complexity, and especially significant– increases to hundreds of passenger or overnight service–Subchapter T no longer was appropriate. As a result, Headquarters (Merchant Vessel Inspection (MVI) and now Marine Technical and Hazardous Materials Division (MTH) – technical was combined with hazardous materials) and the local OCMIs were now engaged in policy development that brought the often international-driv- en regulations of engineering redun- dancy and complexity plus passenger vessel (Subchapter H) structural fire protection and passenger accommo- dation regulations to small passenger vessel COI decisions. This guidance was captured in Navigation and Vessel Inspection Circulars (NVIC) and distant authority’s more direct involve- ment in OCMI decisions. There were other changes in that MIOs were becoming Marine Safety Office (MSOs) so that the OCMI now wore two hats and was not necessar- ily a marine inspector, and Public Law 219ers who were licensed merchant mariners who “had come ashore”’ to bring their career experience to the Coast Guard as commissioned officers, were retiring in large numbers. The 1980s also brought a significant shift to regulations through broader reliance on referenced standards that are technical and consensus standards created and published outside the Coast Guard. The body of standards printed in the regulations was no longer complete or necessarily the best or last source. This combined with the rounding out of marine safety officers being rotated through MSO depart- ments and duties left reduced opportu- nities to develop true marine inspector expertise. The next change was to close the MMTs and create what became the Marine Safety Center collocated with Headquarters. I was personally sorry to see the MMTs go. When I was assigned to Captain of the Port (COTP) New York, it gave me a level of comfort in sending a “techie” out on one of my 41-footers in the dark of night to be part of my team that I put on scene of a grounded vessel to give my go–go spill chasers naval engineering and stability expertise. I liked seeing the cross polli- nation that occurred. The Exxon Valdez accident put a whole different priority of effort for those officers who were OCMIs and COTP. The tendency was to rely more and more on distant technical people to make or greatly influence local decisions because plan approval became a perceived burden on the local MSO whose priority was now primarily environmental response and pollution prevention. The dramatic impact that 9/11 had on the Coast Guard organization was the event that eventually gave us today’s relationships. MSC picked up security plan approval and all plan approval including small passenger