48 FOGHORN 2. Status of unserviceable equipment and whether it can be replaced “in kind”; 3. Applicability of new requirements for “all vessels,” regardless of build date; 4. Any law, regulation, or Coast Guard policy that requires the application of current standards; and 5. If it is practicable for the alterations or modifications to meet current requirements. In some past instances, the local OCMI has allowed a vessel to be modified such that only the newly added components (deck, bulkheads, machinery, etc.) need to meet new regulations, while the rest of the ves- sel can maintain existing vessel status. This has been a good compromise and is consistent with the revised work instruction. CHANGES/ALTERATIONS IN LAID-UP STATUS? The Coast Guard needs to know what was done to the vessel, if anything, while not certificated. Did the previ- ous owner go down to Home Depot and re-wire the boat with Romex ca- ble, move bulkheads, and wood panel the interior like a 1970s den? If alterations were made during laid up status, the local OCMI will coordinate with the owner and MSC to determine if the owner must submit any plans to the Coast Guard for review or approv- al to demonstrate compliance with applicable standards as determined by the OCMI prior to recertification. If the owner or operator of a vessel requests multi-service endorsements that were not on the pre-laid up COI, the vessel will have to meet current regulatory standards for each inspec- tion subchapter (e.g., Subchapters M or T) that was not previously en- dorsed on the COI. REPLACEMENT IN-KIND As stated above, the OCMI will con- sider the ability unserviceable equip- ment to be replaced “in kind.” The re- vised work instruction in footnote 11 defines replacement in kind as follows: “Replacement in kind means replacement of equipment or components that have the same technical specifications as the original item and provide the same service. If the replacement item upgrades the system in any way, the change is not a replace- ment in kind.” This definition is taken from 46 CFR 136.110. The Coast Guard refers to this general definition of “replacement in kind” for all vessels covered in the work instruction, including passenger and small passenger vessels. Replacing equipment in kind has the advantage of not needing to submit plans to the OCMI or MSC. How- ever, swapping out a 25 GPM Jabsco bilge pump with a 44 GPM Jabsco pump is not replacement in kind. Put- ting a higher output electric motor on the end of an existing prime mover is not replacement in kind. CONCLUSION We hope to see more determinations made by local OCMIs consistent with the new clarified guidance so we can spend less time working through the reconsideration and appeals process. Unlike other inspection Subchapters, Subchapters K and T provide clear regulatory footing for an operator to bring a small passenger vessel back into certification under the regula- tions she was built and certified to prior to going out of service. SAFETY MATTERS *Available on engines equipped with JDLink™ modems. John Deere marine propulsion, generator, and auxiliary engines keep your vessels on schedule. When you register your engine and activate John Deere Connected Support™ remote monitoring and diagnostic services,* you get even more reliability and confidence. JohnDeere.com/JDPower STAY CONNECTED TO WHAT COUNTS
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