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	<title>Comments for Bryant's Maritime Consulting</title>
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	<link>http://brymar-consulting.com</link>
	<description>Assisting the maritime industry in regulatory compliance</description>
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		<title>Comment on Bryant&#8217;s Maritime Blog &#8211; 4 August 2010 by admin</title>
		<link>http://brymar-consulting.com/?p=9898&#038;cpage=1#comment-481</link>
		<dc:creator>admin</dc:creator>
		<pubDate>Wed, 04 Aug 2010 20:41:11 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?p=9898#comment-481</guid>
		<description>John,
You have asked a good question, to which I have a good answer.  The US Coast Guard was established in 1915 when, by Act of Congress, the Revenue Cutter Service was combined with the Life-Saving Service.  The Revenue Cutter Service was both the older and the larger of these two organizations.  Thus, the Coast Guard naturally adopted the date of formation of the Revenue Cutter Service as the anniversary to be celebrated annually.  The Light House Service, as you point out, was founded before the Revenue Cutter Service, but was not merged into the Coast Guard until 1939.  
         Dennis</description>
		<content:encoded><![CDATA[<p>John,<br />
You have asked a good question, to which I have a good answer.  The US Coast Guard was established in 1915 when, by Act of Congress, the Revenue Cutter Service was combined with the Life-Saving Service.  The Revenue Cutter Service was both the older and the larger of these two organizations.  Thus, the Coast Guard naturally adopted the date of formation of the Revenue Cutter Service as the anniversary to be celebrated annually.  The Light House Service, as you point out, was founded before the Revenue Cutter Service, but was not merged into the Coast Guard until 1939.<br />
         Dennis</p>
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		<title>Comment on Bryant&#8217;s Maritime Blog &#8211; 4 August 2010 by JBennett</title>
		<link>http://brymar-consulting.com/?p=9898&#038;cpage=1#comment-480</link>
		<dc:creator>JBennett</dc:creator>
		<pubDate>Wed, 04 Aug 2010 20:31:12 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?p=9898#comment-480</guid>
		<description>Happy Birthday Dennis!

But why does the USCG use the Revenue Marine founding in 1790 as its starting point, rather than the establishment of the Light House Service in 1789?

Regards,
JB</description>
		<content:encoded><![CDATA[<p>Happy Birthday Dennis!</p>
<p>But why does the USCG use the Revenue Marine founding in 1790 as its starting point, rather than the establishment of the Light House Service in 1789?</p>
<p>Regards,<br />
JB</p>
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		<title>Comment on Bryant&#8217;s Maritime Blog &#8211; 30 July 2010 by JBennett</title>
		<link>http://brymar-consulting.com/?p=9776&#038;cpage=1#comment-470</link>
		<dc:creator>JBennett</dc:creator>
		<pubDate>Fri, 30 Jul 2010 16:58:31 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?p=9776#comment-470</guid>
		<description>Dennis,

I very much enjoyed your &quot;Black Tom&quot; article, but I don&#039;t see how it qualifies as a terrorist incident.  Agents of a belligerent, presumably acting under orders, at worst violated US neutrality, and it could be argued that their act constituted a valid reprisal for the US abandonment of true neutrality by tilting toward the allies.
Even if it was a terrorist incident, was it really the first in US history?  What about atrocities by partisans on both sides of the American Revolution against civilian populations of the opposite persuasion.  Raids by Indians along the frontier after the Revolution? 
Regards,
John</description>
		<content:encoded><![CDATA[<p>Dennis,</p>
<p>I very much enjoyed your &#8220;Black Tom&#8221; article, but I don&#8217;t see how it qualifies as a terrorist incident.  Agents of a belligerent, presumably acting under orders, at worst violated US neutrality, and it could be argued that their act constituted a valid reprisal for the US abandonment of true neutrality by tilting toward the allies.<br />
Even if it was a terrorist incident, was it really the first in US history?  What about atrocities by partisans on both sides of the American Revolution against civilian populations of the opposite persuasion.  Raids by Indians along the frontier after the Revolution?<br />
Regards,<br />
John</p>
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		<title>Comment on Bryant&#8217;s Maritime Blog &#8211; 6 July 2010 by Robert Douville</title>
		<link>http://brymar-consulting.com/?p=9298&#038;cpage=1#comment-450</link>
		<dc:creator>Robert Douville</dc:creator>
		<pubDate>Tue, 06 Jul 2010 14:53:06 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?p=9298#comment-450</guid>
		<description>White House – Long-Term Gulf Coast Restoration Support Plan 
For goodness sake!  This administration is a loose cannon.  The Secretary of the Navy!!!  Well wait.  Now that I think of it; we are all better off that he did not choose the current head of EPA.</description>
		<content:encoded><![CDATA[<p>White House – Long-Term Gulf Coast Restoration Support Plan<br />
For goodness sake!  This administration is a loose cannon.  The Secretary of the Navy!!!  Well wait.  Now that I think of it; we are all better off that he did not choose the current head of EPA.</p>
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		<title>Comment on Bryant&#8217;s Maritime Blog &#8211; 6 July 2010 by Robert Douville</title>
		<link>http://brymar-consulting.com/?p=9298&#038;cpage=1#comment-449</link>
		<dc:creator>Robert Douville</dc:creator>
		<pubDate>Tue, 06 Jul 2010 14:43:32 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?p=9298#comment-449</guid>
		<description>New Orleans – towing company and owner charged in collision/spill
I have great respect for US Atty. Jim Letten but this indictment, perhaps legally correct, is an ethical travesty. The owner of the towboat is, whatever its culpability, ultimately a scapegoat.  ACL, owner of the barge, doestn&#039;t even get mentioned in the BOI.  ACL set up and/or promoted and encouraged the establishment and business of the Mel Carter owner; surely with the notion (utterly successful) of distancing itself from culpability for an oil spill from one of its own barges. It continued to use the company when it knew or should have known of its poor performance. 
More fundamentally the Coast Guard had a questionable appearance if not manifest conflict of interest in investigation of the incident. First, it had just given ACL the Benkert environmental award practically on the eve of teh spill.    Second, Mario Muñoz; Director of Fleet Operations; American Commercial Lines was, at the time of the spill, chairman of the Coast Guard&#039;s Towing Safety Advisory Committee.  To my knowledge these relationships of the CG with the owner of the spill source were not brought to the attention of the public or interested parties before or during the investigation. To my knowledge neither the relationship of DM to ACL nor the that of the CG to ACL were brought to the attention of the public or the interested parties, perhaps not to the attention of U.S. Attorney Letten either.  Had this come to me as a civil penalty case in my former role as a Coast Guard civil penalty hearing officer I would have, on my own motion, noticed the party of these facts and requied the Coast Guard to explain why there was no appearance of or actual conflict of interest.  I am not concerned that there was no potential financial issue as between ACL and CG.  The CG had a high degree of interest in shielding itself from public embarrassment over ts relationship to ACL, particularly if the scapegoat relationship of the towboat owner and ACL had been fully exposed in the media.</description>
		<content:encoded><![CDATA[<p>New Orleans – towing company and owner charged in collision/spill<br />
I have great respect for US Atty. Jim Letten but this indictment, perhaps legally correct, is an ethical travesty. The owner of the towboat is, whatever its culpability, ultimately a scapegoat.  ACL, owner of the barge, doestn&#8217;t even get mentioned in the BOI.  ACL set up and/or promoted and encouraged the establishment and business of the Mel Carter owner; surely with the notion (utterly successful) of distancing itself from culpability for an oil spill from one of its own barges. It continued to use the company when it knew or should have known of its poor performance.<br />
More fundamentally the Coast Guard had a questionable appearance if not manifest conflict of interest in investigation of the incident. First, it had just given ACL the Benkert environmental award practically on the eve of teh spill.    Second, Mario Muñoz; Director of Fleet Operations; American Commercial Lines was, at the time of the spill, chairman of the Coast Guard&#8217;s Towing Safety Advisory Committee.  To my knowledge these relationships of the CG with the owner of the spill source were not brought to the attention of the public or interested parties before or during the investigation. To my knowledge neither the relationship of DM to ACL nor the that of the CG to ACL were brought to the attention of the public or the interested parties, perhaps not to the attention of U.S. Attorney Letten either.  Had this come to me as a civil penalty case in my former role as a Coast Guard civil penalty hearing officer I would have, on my own motion, noticed the party of these facts and requied the Coast Guard to explain why there was no appearance of or actual conflict of interest.  I am not concerned that there was no potential financial issue as between ACL and CG.  The CG had a high degree of interest in shielding itself from public embarrassment over ts relationship to ACL, particularly if the scapegoat relationship of the towboat owner and ACL had been fully exposed in the media.</p>
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		<title>Comment on Bryant&#8217;s Maritime Blog &#8211; 7 June 2010 by CG</title>
		<link>http://brymar-consulting.com/?p=8486&#038;cpage=1#comment-407</link>
		<dc:creator>CG</dc:creator>
		<pubDate>Mon, 07 Jun 2010 13:21:19 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?p=8486#comment-407</guid>
		<description>Congrats on 42 years of bliss.</description>
		<content:encoded><![CDATA[<p>Congrats on 42 years of bliss.</p>
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		<title>Comment on Blog by Day 46 Links &#124; Maitri&#39;s VatulBlog</title>
		<link>http://brymar-consulting.com/?page_id=6&#038;cpage=1#comment-404</link>
		<dc:creator>Day 46 Links &#124; Maitri&#39;s VatulBlog</dc:creator>
		<pubDate>Fri, 04 Jun 2010 16:14:40 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?page_id=6#comment-404</guid>
		<description>[...] A good maritime law blog on the legal machinations surrounding the oil spill. As Brad says, &#8220;He begins each day with a summary of the relevant legal developments pertaining to the spill, then expands on them individually and includes hyperlinks to underlying documents.&#8221; [...]</description>
		<content:encoded><![CDATA[<p>[...] A good maritime law blog on the legal machinations surrounding the oil spill. As Brad says, &#8220;He begins each day with a summary of the relevant legal developments pertaining to the spill, then expands on them individually and includes hyperlinks to underlying documents.&#8221; [...]</p>
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		<title>Comment on Blog by Alaska Fish Notes: December 4, 2009 : Marine Conservation Alliance</title>
		<link>http://brymar-consulting.com/?page_id=6&#038;cpage=1#comment-382</link>
		<dc:creator>Alaska Fish Notes: December 4, 2009 : Marine Conservation Alliance</dc:creator>
		<pubDate>Mon, 10 May 2010 04:51:38 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?page_id=6#comment-382</guid>
		<description>[...] USCG Loran C Termination (11/25/09).  The US Coast Guard released an internal message advising of the imminent termination of the long range aid to navigation Loran-C. Current plans call for the termination process to commence on 4 January 2010. The process is expected to take several months. ALCOAST 675/09 (11/25/09). Note: This will mark the end of an era that started during World War II. The Loran system has improved greatly over the years and was on the edge of yet another advance: to enhanced Loran (eLoran). It is unclear how other nations, which operate their own independent Loran-C systems, will react to this development.  (Bryant Marine Consulting) Link [...]</description>
		<content:encoded><![CDATA[<p>[...] USCG Loran C Termination (11/25/09).  The US Coast Guard released an internal message advising of the imminent termination of the long range aid to navigation Loran-C. Current plans call for the termination process to commence on 4 January 2010. The process is expected to take several months. ALCOAST 675/09 (11/25/09). Note: This will mark the end of an era that started during World War II. The Loran system has improved greatly over the years and was on the edge of yet another advance: to enhanced Loran (eLoran). It is unclear how other nations, which operate their own independent Loran-C systems, will react to this development.  (Bryant Marine Consulting) Link [...]</p>
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		<title>Comment on Bryant&#8217;s Maritime Blog &#8211; 22 April 2010 by JBennett</title>
		<link>http://brymar-consulting.com/?p=7450&#038;cpage=1#comment-363</link>
		<dc:creator>JBennett</dc:creator>
		<pubDate>Thu, 22 Apr 2010 21:41:28 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?p=7450#comment-363</guid>
		<description>Dennis,
Thanks for providing the Florida Seaport Security Assessment 2010 Report.  From local press reports, the Office of Drug Control, which for some reason has a major role in Florida seaport security, was so incensed over the report&#039;s suggesting the State get out of the business that it tried to block the consultant&#039;s payment.</description>
		<content:encoded><![CDATA[<p>Dennis,<br />
Thanks for providing the Florida Seaport Security Assessment 2010 Report.  From local press reports, the Office of Drug Control, which for some reason has a major role in Florida seaport security, was so incensed over the report&#8217;s suggesting the State get out of the business that it tried to block the consultant&#8217;s payment.</p>
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		<title>Comment on Bryant&#8217;s Maritime Blog &#8211; 15 April 2010 by R. T. Douville</title>
		<link>http://brymar-consulting.com/?p=7284&#038;cpage=1#comment-357</link>
		<dc:creator>R. T. Douville</dc:creator>
		<pubDate>Thu, 15 Apr 2010 12:23:31 +0000</pubDate>
		<guid isPermaLink="false">http://brymar-consulting.com/?p=7284#comment-357</guid>
		<description>Somalia Pirates--What is needed is a leaflet drop over the coast announcing a no go zone say XX miles off the coast extending out XXX miles or so. It should contain a warning that any craft under XX meters found in the zone will be considered a pirate craft and subject to destruction without further warning by air or surface patrols.  Collectively nations have paid off pirates in the past.  But we have also used armed force against them, thus the &quot;shores of Tripoli&quot; in the USMC Hymn.  And we&#039;ve done so unilaterally without waiting for a &quot;Dithering Nations&quot; resolution. Not much hope of that with this Administration though, is there?</description>
		<content:encoded><![CDATA[<p>Somalia Pirates&#8211;What is needed is a leaflet drop over the coast announcing a no go zone say XX miles off the coast extending out XXX miles or so. It should contain a warning that any craft under XX meters found in the zone will be considered a pirate craft and subject to destruction without further warning by air or surface patrols.  Collectively nations have paid off pirates in the past.  But we have also used armed force against them, thus the &#8220;shores of Tripoli&#8221; in the USMC Hymn.  And we&#8217;ve done so unilaterally without waiting for a &#8220;Dithering Nations&#8221; resolution. Not much hope of that with this Administration though, is there?</p>
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