Coast Guard Needs To Get Their Hearing Checked…..

This should get your new work week started on an upbeat note: Coast Guard blows off mariners yet again!

But here’s the critical question: would the members of the Coast Guard’s Marine Safety Directorate, which controls the licensing and certification functions, be able to meet the same medical standards that they demand of the mariners they superintend? It sure doesn’t look like it. That’s because to work in this industry you must be able to hear, and it has become painfully obvious that the Coast Guard cannot hear a damn thing. They’ve just confirmed that they are 100% deaf when it comes to listening to the concerns and opinions of mariners, even when the issue at hand is primarily a symbolic one. The traditional, formal Merchant Marine Officer’s License as we have always known it, the actual paper certificate, is now on the fast track into the the waste bin of history as the Coast Guard, like a bull in a china shop, blunders into the implementation of their Merchant Mariner Credential final rule, which was published yesterday in the Federal Register.

As the post-9/11 TWIC rule-making process began washing over the maritime community like a tsunami the Coast Guard saw their opening and also started a rule-making process for consolidating the various credentials (license, merchant mariners document, STCW letter, and certificate of registry) we may carry into a single document known as the Merchant Mariners Credential (MMC), which is now supposed to take the form of a “passport-like” booklet. In some ways this might be construed as a good thing, reducing the amount of official papers that some of us tote around and possibly reducing costs for some mariners in the process. But much more importantly it will also significantly ease the administrative burden on the Coast Guard and, make no mistake about it, that’s the only reason it was done. Any small benefit to mariners would have been considered to be an unfortunate and unintentional (but unavoidable) consequence of improving their own position.

After the original Notice of Proposed Rulemaking was published the response from mariners was loud and clear: modernize the credentialing process as needed but please don’t mess with the traditional license. Why? Because seafaring is a very old and traditional vocation, and mariners as a whole respect this and try to hold onto the few totems of tradition that we can. Perhaps the most significant of these is the Merchant Marine Officer’s License that is earned by the deck and engineering officers manning our nation’s fleet and serving as pilots. Furthermore, the vast majority of licensed mariners have never been to college and a considerable number didn’t graduate high school. Given that fact, our licenses are, in most cases, the highest expression of professional or educational achievement we’ll ever have, giving them a powerful symbolism. Maritime academy graduates, too, understand the significance of the license. One tug engineer I worked with, a graduate of Mass. Maritime, said to me last year “It’s way more important to me than my Bachelor’s degree.” Numerous other academy graduates I spoke with expressed the same opinion. So this isn’t just an issue for the great masses of uneducated and unwashed boat trash like me.

But despite mariner’s nearly universal opposition via comments on the rulemaking, columns in the trade magazines, recommendations to the contrary from their own Merchant Marine Personnel Advisory Committee (MERPAC), and direct phone conversations with Coast Guard officials that all expressed widespread opposition against doing away with the traditional license the Coast Guard has again chosen to ignore the wishes of mariners and do whatever they feel like doing, bad blood be damned. This is to their deep shame as an institution. More importantly, it drives the wedge between us and them even deeper. Relations between the Coast Guard and mariners were at an all-time low already, and this will surely serve only to worsen them.

Quoting from page 5 of the final rule, “We received one comment stating that the majority of licensed officers favor retaining the license as a separate document and as a certificate of qualifications at the licensed level. We disagree. This statement is not represented by the comments received during this rulemaking.” Who do they think they’re kidding?

You’d think that a military outfit like the Coast Guard would have a lot more respect for tradition and easily recognize the importance of the license. Coast Guard officers earn bachelor’s degrees at their academy and receive an officer’s commission upon graduation. Many go on to advanced studies and earn master’s degrees. Official qualification letters and “suitable for framing” certificates recognizing the successful completion of formal training are in everyone’s service record. How would they feel if someone said “we’re taking all of that away to ‘streamline the process.’ But anyway, congratulations. Here’s your passport-like booklet!” As cynical as I’ve become through long-term exposure to them, even I’m somewhat surprised at their behavior, and I really thought I was beyond that at this point.

It could have been a very simple matter to appease the vast majority of us who wanted to hold onto the traditional license: make it an “upon request” option by checking a box on the application. If it’s not important to you, don’t check the box and be happy with your new MMC. Or it could have been limited to your first issue and upon any upgrade, if desired. MERPAC suggested, as an alternative, that a certificate, suitable for framing and display, be made available. If needed, they could have required that mariners pay an additional small fee for exercising any of these  alternative options to defray the costs, even though we already pay for these “services” with a user fee. If, over time, it became apparent that mariners no longer cared at all about maintaining the traditional license it could then have been allowed to fade gracefully away into the history books. In the meantime they could have accomplished all of the things that they wanted to accomplish (consolidate and clarify the regulations, reduce their administrative burden and costs, streamline the process, enhance security, etc.) while still offering the traditional license to those that wanted them. But in the end they simply could not bring themselves to compromise at all, generally responding to the various suggestions with a curt “the Coast Guard disagrees.” At this point it seems obvious that the U.S. Merchant Marine and the U.S. Coast Guard have irreconcilable differences. It’s time for a divorce. Maybe the chairman of the House Transportation Committee, Rep. James Oberstar of Minnesota, has finally grown as tired of the Coast Guard’s anti-mariner antics as we have. Tired enough, perhaps, to initiate the necessary congressional actions required to strip them of their licensing and marine safety functions.

If you think the Coast Guard has got this one all wrong contact the U.S. House of Representatives Transportation & Infrastructure Committe, which oversees the Coast Guard, at (202) 225-4472. Ask to speak to someone on the oversight staff and refer specifically to the rulemaking title Consolidation of Merchant Mariner Qualification Credentials (federal docket # USCG-2006-24371). The U.S. Senate also has a Transportation Committee, with additional specific subcommittees. You can reach the Oceans, Atmosphere, Fisheries & Coast Guard Subcommittee at either 202-224-4912 (majority) or 202-224-8172 (minority). The Surface Transportation and Merchant Marine Infrastructure, Safety & Security Subcommittee can be reached at 202-224-9000 (majority office) or 202- 224-4852 (minority office). 

Click here to go to that docket, where you can read all of the comments submitted for consideration and subsequently rejected by the Coast Guard. If you want to go straight to the source, here are the relevant documents as published in the Federal Register. The SNPRM and FR both contain excerpts of the many comments received, along with the Coast Guard’s responses. By reading them you will come to realize just how tone-deaf to us they really are.

1. MMC Notice of Proposed Rulemaking
2. MMC Supplemental Notice of Proposed Rulemaking
3. MMC Final Rule