AUGUST 2018 • FOGHORN 23 REGULATORYREPORT The NPRM meets several condi- tions and criteria that achieve other goals. The following information is repeated from the PVA’s comment to the docket: “The proposed rule is fully consistent with President Trump’s recent executive orders.  They pose no obstacles whatsoever to rapid finalization of the proposed rule. The Executive Order of January 30, 2017, is entitled “Presidential Executive Order on Reducing Regulation and Controlling Regulatory Costs.”  Its purpose is to ensure the “prudent and financially responsible” expenditure of funds from private sources.  It declares, “It is essential to manage the costs associated with the governmental imposition of private expen- ditures required to comply with Federal reg- ulations.” The Executive Order establishes certain conditions (“two for one” and “no net increase in regulatory costs”) for the issuance of a “new” regulation. The proposed rulemaking does not constitute a “new” regulation.  It simply amends an existing rule that under current regulatory policies is identified as overly burdensome for a certain population of mariners. The adjustment leaves in place the existing process where experience can and does show a need for a much smaller segment of mariners. And: “The Regulatory Analysis establishes that the proposed rule brings no added costs. The elimination of the refresher course for qualified mariners identifies cost avoidance or cost savings in the ten-year undiscounted amount of $67,883,830 to an average of 7,000 mariners per year. PVA has repeatedly highlighted the cost of regulation in its comments to regula- tory dockets. Not so long ago the Small Business Administration estimated that the cost of federal regulation to small business to be approximately $10,585 per year per employee. The proposed withdrawal of this one burdensome requirement illustrates the validity of that analysis and will take a small but appreciated step toward reducing that average cost for certain vessel operators and mariners.” There are similar radar observer changes for radar course instructors that do not have vessel-related service. PVA did address those in its comment to the docket. Members and mariners interested in reading the complete NPRM and the comments submitted to the docket can find the material at https://www. regulations.gov/ with docket number USCG-2018-0100. n