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FOR REVIEW and DISCUSSION: USCG Federal Register Request for Comments: Evaluation of Regulations - Info and Drafts

  • 1.  FOR REVIEW and DISCUSSION: USCG Federal Register Request for Comments: Evaluation of Regulations - Info and Drafts

    Reporting Project
    Posted 07-05-2017 11:37 AM

    This is regarding the U.S. Coast Guard's
    Request for Comments: Evaluation of Existing Coast Guard Regulations, Guidance Documents, Interpretative Documents, and Collections of Information. Docket No. USCG–2017–0480 at  Comment deadline: Monday, July 10, 2017

    A bit of background: Since January, the Trump administration has issued a series of Executive Orders (EO) and memoranda pertaining to federal regulations. The actions are intended to prompt federal agencies to make recommendations for repealing, replacing, or modifying their existing regulations and for reducing regulatory costs. In response to these directives, the U.S. Coast Guard (USCG) published a Federal Register Notice/Request for Comments seeking public input on regulations, guidance documents and interpretative documents that should be considered for repeal, replacement, or modification based on criteria described in the notice. It is also seeking input on USCG collections of information, whether or not they are associated with a regulation. The purpose of this open comment period is to assist the USCG in its work with the Department of Homeland Security's Regulatory Reform Task Force, established under the terms of Executive Order 13777.

    On June 15, John Johnson, NASBLA CEO/Executive Director, distributed a "NASBLA Member Alert" to all BLAs provide information on the notice and links to relevant reference documents, to describe next steps in the process, and offering some things to consider in your own review. The Alert is attached here.

    Responding to the request: Since the publication of this notice, NASBLA has been in process of formulating an organizational submission. The latest draft of the comments (draft of letter and appendices) is attached to this post. Your review and additional input to the draft will help NASBLA develop a more meaningful organizational response to the request. At the same time, we hope that sharing these items will help you and your state or organization should you also be working on a separate set of comments.

    Some things to note about the draft items:
    The tack taken in this draft is very similar to that of past NASBLA comments to such notices--a letter that would be over leadership's signature with the basic descriptions of issues and supplemental materials or appendices with more detail. In this case, the draft presents the assumptions on which the comments are based, and then focuses specifically on two areas where NASBLA has had a significant interest in regulatory updates--accident reporting and UCOTVA. The appendices present resolutions, reports, and summaries to supplement the basic descriptions.

    Questions for you as you review them:

    Are the descriptions and supplemental items for each of these two areas sufficient? What edits would you suggest? And yes, it does need an ending, but that is the easiest part of the content!
    As critical, are there other areas that should be included in this association submission? The accident reporting and UCOTVA issues are reasonable to include from NASBLA given the level of work that has been conducted in these areas and the fact that there are already supportive documents from members in place. They are also areas in which the Coast Guard has done significant work toward regulatory projects that are now in limbo. Nevertheless, there are other areas of potential regulatory reform that could be broached, though perhaps in a different way in the comments. Some examples that have already been floated include carriage requirements (33 CFR 175.15) and visual distress signals (as in alternatives; 33 CFR 175.101). What do you suggest as additions?

    Other things to be aware of:
    ---As noted in the Member Alert, our understanding is that the Coast Guard will take additional steps to gather input before wrapping up its internal work on recommendations at year's end. For example, the members of the National Boating Safety Advisory Council (NBSAC) will be embarking on a review process and as part of this effort, the full Council will conduct a teleconference on July 21. The announcement of this teleconference, and description of this task for NBSAC will be published in the July 6 Federal Register at Comments will be taken from the public both during and prior to the call (docket USCG-2017-0618).

    ---A quick review of comments already submitted to the original Coast Guard docket at USCG–2017–0480 reveals that a few organizations have already requested extensions to the 30-day comment period. While it is possible that an extension to the July 10 deadline could be granted, there are no assurances of that. Until you hear otherwise, assume that Monday at 11:59pm ET is the deadline for submissions to

    Please post your thoughts, suggestions, questions, edits, etc., here or send them directly to me at

    Thank you, in advance.

    Deb Gona
    NASBLA Research Consultant
    Gona & Associates