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Bryant's Maritime Consulting

March 7th, 2019 at 12:21 pm

Bryant’s Maritime Blog – 7 March 2019


USCG – Policy Letter re 2009 MODU Code;

MARAD – proposed DWP in Gulf of Mexico;

Senate – hearing on American maritime industry;

House – hearing re maritime & shipbuilding industries; and

Court – Certificate of Need for NDZ.

March 7, 2019

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Note: This blog is one section of the Bryant’s Maritime Consulting website. Visit the site for more extensive maritime regulatory information. Individual concerns may be addressed by retaining Dennis Bryant directly. Much of the highlighted text in this newsletter constitutes links to Internet sites providing more detailed information. Links on this page may be in PDF format, requiring use of Adobe Acrobat Reader. Comments on these postings are encouraged and may be made by clicking the envelope that appears at the end of each posting. Be aware that the daily blog entry is a single posting, even though it contains a number of individual items. Once a job is fouled up, anything done to improve it will only make it worse.

USCG – Policy Letter re 2009 MODU Code

clip_image004 The US Coast Guard issued an updated policy letter establishing that the Coast Guard considers the design and equipment standards of the IMO Code for the Construction and Equipment of Mobile Offshore Drilling Units, 2009 (2009 MODU Code) and its amendments to be at least as effective as the design and equipment standards of 1979 and 1989 MODU Codes. CG-ENG Policy Letter 02-12 CH-1 (3/4/19) [].

MARAD – proposed DWP in Gulf of Mexico

clip_image006 The Maritime Administration (MARAD) issued a notice stating that a public scoping meeting will be held on 20 March in Lake Jackson, Texas to receive comments on the proposed deepwater port (DWP) in the Gulf of Mexico to be constructed and operated by SPOT Terminal Services LLC. Written comments must be received by 5 April. 84 Fed. Reg. 8401 (3/7/19) [].

Senate – hearing on American maritime industry

clip_image008 The Senate Committee on Commerce, Science & Transportation conducted a hearing entitled “The State of the American Maritime Industry”. Testimony was received from: Mr. Thomas Allegretti, American Waterways Operators; Mr. Bert Eriksson, Sailors’ Union of the Pacific; Mr. Austin Golding, Golding Barge Line; Mr. Matthew Paxton, Shipbuilders Council of America; and Mr. Matthew Woodruff, American Maritime Partnership. (3/6/19) [].

House – hearing re maritime & shipbuilding industries

clip_image010 The Subcommittee on Coast Guard and Maritime Transportation of the House Committee on Transportation and Infrastructure conducted a hearing entitled: “US Maritime and Shipbuilding Industries: Strategies to Improve Regulation, Economic Opportunities, and Competitiveness”. Testimony was heard from RADM John Nadeau, US Coast Guard; RADM Mark Buzby, Maritime Administration; RADM Michael Alfultis, SUNY; Ms. Jennifer Carpenter, AWO; Mr. John Crowley, National Association of Waterfront Employers; Mr. Michael Roberts, American Maritime Partnership; and Mr. Augustin Tellez, SIU. (3/6/19) [].

Court – Certificate of Need for NDZ

clip_image012 The Court of Appeals of the State of Washington ruled that the Pollution Control Hearings Board does not have jurisdiction to hear an appeal of the Certificate of Need prepared by the Department of Ecology as part of its application to the federal Environmental Protection Agency (EPA) for permission to engage in rulemaking to prohibit marine vessel sewage discharges into Puget Sound by designating Puget Sound as a No Discharge Zone (NDZ). The Certificate of Need asserts that Puget Sound requires greater environmental protection than the federal standard provides. American Waterways Operators v Department of Ecology, No. 51547-4-II (Wash. App., March 5, 2019) []. Note: This item was brought to my attention by my good friend Keith Heard of Lennon Murphy & Phillips.

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Dennis L. Bryant

Bryant’s Maritime Consulting

4845 SW 91st Way
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© Dennis L. Bryant – March 2019



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    logo11 HazSub spill response plans

    In the March 2019 edition of Maritime Reporter and Engineering News, you can find my article entitled "HazSub spill response plans". The article discusses the recent decision of the US Coast Guard to withdrawal its proposed rulemakings for hazardous substance spill response plans for tank vessels and marine transportation-related facilities. In my opinion, the USCG proposals evidence a failure of imagination. I recommend that the Coast Guard meet with the marine transportation chemical sector and determine which current industry measures can be considered as providing an equivalent level of safety to measures mandated in OPA 90. The gaps identified can then be filled in a rulemaking.