AUGUST 2017 • FOGHORN 27 REGULATORYREPORT The original notice asked for comments to the docket by July 7th – a 30-day window. Early commenters responses pointed out the conflict of the incredibly broad request with little time to research, reason, and reply. The Coast Guard has since extended the comment period to September 11, 2017. During the initial comment period, we polled the PVA Regulatory Committee and PVA staff for comments. That material is being reviewed and researched. As in past docket comment opportunities, the staff will provide a PVA position, suggested member comments, and encourage individual responses closer to the comment deadline. In the meantime, members should review the regulatory.gov website USCG-2017- 0480 for the Federal Register notice of June 8, 2017, review comments already in the docket, and prepare a list of your or your company’s candidate items for repeal, replace or modification. Share those with the PVA staffers Peter Lauridsen (peterlauridsen@msn.com) and Ed Welch (ewelch@passengerves- sel.com). This is not a last minute opportu- nity. The regulations in Title 33 and 46 U.S. Code of Code of Federal Regulations, Marine Safety Manual, Navigation and Vessel, Inspection Circulars is volumi- nous, making it a target-rich environ- ment. PVA members and staff who speak at the Marine Inspection Course in Yorktown receive a visual of the span of regulations and policies facing our industry. The student inspectors are preparing for their small passenger vessel and barge inspection qualifica- tions. Each student sits behind a row of reference material that spans the full width of their desk space. A quick start for your participation is to remember your own frustrations of this season, previous inspection in- teractions, plan and appeal processes you have been involved in, or those catch-22 situations where there is no rational outcome save comply for the sake of preservation of your businesses survival. What would have provided a better outcome? Your recommendation needs an explanation of need, along with an alternative or reason for not being, so your suggested change can be understood by the PVA staff preparing the Association docket comment and the Coast Guard receives a clear message of need and recommendation. As always, a member comment in addition to the PVA docket comment provides a direct message and helps the Coast Guard understand your needs in the context of your particular business environment. This may be a once-in-a-lifetime op- portunity: Everything in your experi- ence with the Coast Guard is open to review for change or repeal. Think ex- pansively. Let us help the Coast Guard help us to a better business environ- ment, and remember September 11, 2017 is the new deadline for docket comment. n HSC CODE ANNEX 10 ISO 9001:2008 Proud supplier of the New York Citywide Ferry Project marinegroupbw.com | leah@marinegroupbw.com | [619] 621-2220 Marine Group Boat Works is the finest California boatbuilder and repairer of steel and aluminum high-speed ferries, catamarans and passenger vessels up to 220 feet-long. Operating two shifts, six days per week for fast turnarounds and minimized vessel time out-of-service. WHENALLYOUHAVEISAWEEK... YOU’REIN YOU’REOUT