"On the Record"


1. Original Petition from Delta Towing forming  the catalyst for the change

2. " MEMORANDUM", (Rave review), from the Towing Safety Advisory
Committee on the seatime reduction, ( Note: Those Captains who openly
opposed the change appear to be considered "participants" only for the sake
of including a name, however their comments are not reflected in this review.)

3.  USCG-NPRM 2006-26202 proposing to "REDUCE SEA-SERVICE TIME"

4.  Environmental "Checklist"  for USCG-NPRM-2006-26202  

5.  AWO Letter supporting  the goal of  "streamlining" the  current seatime
requirements "onboard" Towing  Vessels by reducing them by 95.8%.  

6.  Questions on the record from Senator Ted Stevens and the USCG response.

7.  Questions on the record from Congresswoman Jane Harmans office and the
USCG response

8.  Questions on the record from Senator Maria Cantwells office and the USCG
response

9. Below are the "four comments" submitted on record in the Federal Register
which "expressed concern regarding the alternate progression"
(Note: We were assured that all comments submitted would be considered.
The  wording in the upper right of each "Public Submission" stating "Late
Comments are Accepted" might also lead one to that conclusion).

1. USCG-2006-26202-0017
2. USCG-2006-26202-0013
3. USCG-2006-26202-0278
4. USCG-2006-26202-0011
5. USCG-2006-26202-0019
6. USCG-2006-26202-0021
7. USCG-2006-26202-0022
8. USCG-2006-26202-0023
9. USCG-2006-26202-0024
10. USCG-2006-26202-0025
11. USCG-2060-26202-0026
12. USCG-2006-26202-0027
13. USCG-2006-26202-0029
14. USCG-2006-26202-0030

10.  USCG  Final Rule in 9/11/08  Federal Register. Towing Vessel Seatime
Reduction from 720 days "onboard" a Towing Vessel  to "a minimum of" 30
days "onboard "a Towing Vessel.

11.  AWO Newsletter from 9/12/08 commenting on the Rule Change and the
Towing Vessel Captains who misunderstood the "level of experience required
for mariners operating  towing vessels".

13.   HOUSE SUBCOMMITTEE HEARING ON TOWING SAFETY  Sept. 16, 2008.
No mention was made at this hearing of the 95.8% reduction in seatime
required "onboard"  towing vessels for the Towing License. This "Final Rule"
was implemented on 9/11/08 by the USCG, effective 10/14/08. The change was
described in the hearings "Full Summary of Subject Matter"
Our primary  issue  with  USCG NPRM-2006-26202 has been the reduction
of seatime required "onboard" a Towing Vessel.  At this point we
question whether  the proponents even fathom what the current
minimum of 720 days "onboard" a Towing Vessel actually means or if they
in fact believe "a minimum of " 30 days "onboard" a Towing Vessel is the
equivalent.
How and why the required 720 days "onboard" a Towing Vessel became 30 days.
Master of Towing Vessels Association