Posted by: towmasters | December 13, 2008

The Coast Guard’s New Safety Plan?

The Coast Guard has released their new Marine Safety Performance Plan FY 2009-2014 and it makes for some interesting reading, especially pages 17 and 27, which specifically relate to the towing industry and the upcoming rulemaking process for the towing vessl inspection program. I’ll leave it to our readers to decide what they think of it all. But I will point out something that was readily apparent to me from just a quick once-over: despite the promise to “increase outreach and strengthen partnership efforts” there is no indication whatsoever that the Coast Guard either desires or intends to include mariners as partners. They’re very proud, however, of their “close working relationships” and “long-standing partnerships” with “organizations for improved safety” such as the American Waterways Operators (AWO). You remember them, don’t you, the cheerleaders for the 30-Day Wonder program? In the Summary, the CG claims that this plan is a “living document that will undergo continuous review.” Well, there’s no need to wait for the ink to dry on this one.

I quote, yet again, from The Talking Heads’ Once In A Lifetime: same as it ever was…..



  1. I’ve corresponded with Lt. Cdr. Eric Doll since this was released and offered my opinion regarding this “renewed effort”. His response was pragmatic and succinct. I include the letter I wrote for everyone’s consideration. I will paraphrase the Lt. Cmdr.’s comments since I doubt he would grant permission to post his answer.
    This letter was sent on October 2nd, 2008
    “Dear Commander Doll,
    For the record, this kind of program has been floating around for years. It is well intentioned, and beautifully illustrated but seldom manifests to it’s full potential.
    Among the issues that may need to be resolved before this plan can be taken seriously by me and those like me is the need to focus on a kind of “follow through” the USCG is not known for.
    The USCG is tasked with more and more and succeeding at less and less. The manpower issues that have haunted the mariner documentation process along with the miasma of Homeland Security compliance issues facing the maritime community are threatening the US Coast Guard’s primary mission eg; Marine safety, navigation aids, search and rescue ops, and licensing.

    The progress we may make during a certain officer’s tenure evaporates once they move on to their next billet in the USCG hive. Each successive man in the position waters down or mutilates the progress of the former. Turnover is the enemy of progress in our community. The USCG may find us irascible and uncooperative, we find them maddeningly oblivious and absurdly addicted to minutiae and counter intuitive..
    How can it make sense to allow some drone in West Virginia to evaluate my fitness for duty when I’ve submitted to a licensed doctor to evaluate my health and fitness. What credential will this drone hold that supersedes my doctor? Will my DOT physical need to be submitted for approval before its considered acceptable? And given the delay we already suffer waiting for our documents, how much more time do I need to set aside to get my documents approved on top of everything else?

    I’m seeing the Commandant caving to industry pressure with regard to licensing of towing masters, I’m watching the TWIC debacle continue (no real sense in that except as a revenue generator), and the continuing insult of reducing the American Mariner to the status of second class citizens without any consideration as to how deliberately we are being abused by the security plans of many facilities in the USA. In those cases, we may as well be in prison while we are serving our tours aboard our vessels.
    We have been calling at these terminals long before 9/11, now we’re the threat. Have you seen that we are escorted by security people that barely speak English, much less passing the muster we had to endure for our documents and clearances. I’d be willing to bet that I have been more heavily investigated and vetted than you and half your staff.

    We are the very people you are turning to to secure the ports and waterways with “eyes on the water”. I didn’t see one mariner impact the Trade Center, the Pentagon, or crash in that field in Pennsylvania. I did however see them respond in an all out rescue and evacuation of downtown Manhattan while the towers were smoldering and collapsing in spite of the dust and smoke and likelihood of continued mayhem.

    TSAC is not represented well with actual towing masters except for one Captain Joe Dady, the rest are management and not on the immediate front line. How credible can it be if it’s not populated with the folks that are being regulated. Talking about towing, towing masters are the ones you should be talking to. Better yet, help TSAC get better by seeing a majority of Towing Masters appointed to the commission and help them participate by giving them the travel expense that so many other groups (MERPAC for one) receive while advising the Commandant.

    The belief that adding more regulations to the recreational boating community is going to make things safer is ludicrous since we’ve already got enough rules on the books to satisfy the need for safe speeds and operating under the influence. All these issues are addressed in detail in the Rules of the Road and with federal and state laws throughout the country. Enforcement is what needs to take priority. Make everyone that operates a vessel, of any kind, get a license. Talk about a revenue generator. The idea of COEs is encouraging, but I will wait to see if it comes to fruition.

    Captain Bill Brucato ”

    In receiving his response I got the idea that the man I was corresponding with was the lightning rod. While he tried to assure me he sympathized with my complaints, all he could offer was the assurance he would pass my concerns on to the upper ranks with no promise inferred or expected.

    However some of what Lt. Cmdr. Doll relayed has come to pass. The concerns over NVIC 4-08 have been addressed in a new flier that sets out the new medical review officer’s impact on mariners renewing their documents. The uproar over this NVIC was a product of the USCG’s failure to guage the impact of releasing such a document without extensive attention being paid to explaining the way it would work. The details of finessing the issue were never highlighted by the USCG, instead a phone call to the National Maritime Center helped more than any flier could have. The advice I received was clear, intuitive, and to the point.
    This was of immediate concern to me since I’m renewing this year. See my posting at for the posting on NVIC 4-08 for the details of what I found out regarding the form CG-719k.
    As for many of the issues addressed in the new plan, recreational boaters will continue to visit mayhem upon the waterways without any movement from the Federal agencies toward requiring a license of any sort. The word I got is that the issue will be left to State govt. to administer.
    It remains to be seen what will come of this, it’s just more blather as far as I’m concerned.

  2. I agree with Capt. Bill Brucato’s remarks, the C.G. may want to do what they say but may not be able to, if they try it will be a step in the right direction.

    As far as the status of mariners in this plan – I like the concept of stakeholders. Mariners have a stake in safe waterways, we want to go home in one piece and not have to operate in a high risk environment. In the long run disregarding the well being of the mariner is going to be detrimental to safety.

  3. […] _____________________________________________ Master of Towing Vessels Association Forum […]

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