SEAFARER ACCESS COMMENTS
The North Atlantic Ports Association (NAPA) is a trade organization of commercial seaports on the Atlantic Coast between the Commonwealth of Virginia and the Canadian Maritime Provinces. Our goal is to promote ocean commerce in a responsible manner in order to strengthen the economy and help our communities to prosper.
Below are our comments regarding Docket number USCG-2013-1087, Seafarers access to marine facilities, 79 Federal Register No. 248, December 29, 2014.
Our primary concern about these regulations is the cost of fulfilling them, which we think will be substantial in many cases, and what is to us the clear responsibility of vessel owners or operators, not the ports, to pay these expenses. The well-being of seafarers is the responsibility of their employer, in this case the vessel operator, and while the ports will cooperate in arranging access, it is not their responsibility to pay the expenses that will arise.
We believe that access covered by this regulation should include only seafarers, their welfare and labor organizations, vessel agents and pilots. We see no need or benefit in broadening the list of those covered, which would further complicate an issue that we are trying to simplify and advance.
We hope that all parties will keep in mind the potential for conflicts between access for seafarers and port security, two concepts that are likely to be incompatible in some ways. These conflicts will need to be thought through and resolved, probably on a case by case basis.
This proposed rule appears to have been written with the assumption that every seafarer has a transportation worker identity card, but it is more likely that the opposite is true; most of the seafarers coming off the ships may not have a TWIC. A review of how this could affect access plans could be worthwhile.
Setting time deadlines for implementation, as the regulation proposes, appears unrealistic to us because of the variables in terminal sizes, locations, configurations, cargo and vessel types, and the various capacities of all parties involved. We would prefer targets rather than deadlines.
Given the nature of the proposed regulation, its length and complexity, we think there is value in extending the comment period by 90 days to give all parties more time to understand how their terminals and their operations might be affected. Since no two terminals are alike, this extra time for comments could produce additional worthwhile viewpoints.
Thank you for this opportunity to comment.
Capt. F. Bradley Wellock