America Cargo Transport Corp. (ACTC) - Comments

See attached file(s) I am writing on behalf of America Cargo Transport Corp. (ACTC). ACTC operates U.S. flag, Jones Act-qualified vessels in the U.S. coastwise and international trades, and regularly engages in the transportation of U.S. government –impelled food aid cargoes sponsored by USAID. We believe re-designation is inconsistent with the intent of the law and will damage U.S. flag carriers engaged in transporting USAID cargoes. We strongly object to permitting the requested re-designations We believe the intent of the law is to require equitable distribution of cargoes on the basis of vessel type. Permitting re-designation by mere declaration of such designation fundamentally alters the distribution of US government cargoes in a manner not intended by the law. It further skews the country-based scoring method designed to assure equitable distribution of cargoes among U.S. flag carriers. We believe that MARAD should adopt a standard wherein vessel classification at construction should be the critical factor and should be considered in conjunction with the deployment of the vessel (operated as a tramp, charter, or liner). No other factors should be considered unless the owner has undertaken a bona fide reconstruction of the vessel that modifies its service criteria. Thank you for the opportunity to comment on this request.