Indiana Department of Natural Resources Law Enforcement Div.

October 15, 2010 Re: 33 CFR Parts 173, 174,181 and 187 [Docket No. USCG–2003–14963] To whom it may concern: I want to thank you for the opportunity to comment and voice concern on the proposed amendments to the listed federal regulations. My agency will be tasked with the implementation of some of the proposed changes and the Bureau of Motor Vehicles will face significant challenges as well. My comments are based on my position as Indiana’s Boating Law Administrator and the states delegate to the National Association of State Boating Law Administrators (NASBLA). I recently had an opportunity to review these proposed changes with personnel from the Bureau of Motor Vehicles who will also be charged with implementing these proposed amendments. I can’t begin to tell you the fiscal ramifications these changes will demand of state budgets, at a time when states are enduring layoffs, furlong days and facing ever lower numbers of personnel to carry out more responsibilities. These changes will have very significant fiscal impacts on manpower, changes to existing databases and extensive training on new categories and terminologies. Even in good fiscal times, a three year window to achieve these changes is not realistic. The goal of harmonizing terminology is understandable and needed, but every effort should be made to ease the financial and manpower burden on the states. My agency normally has less than 160 officers who would be tasked with issues arising from HIN’s. The proposed language placing the total burden of HIN verification on state personnel is absolutely unacceptable and unachievable in Indiana. This should be reconsidered. Again, I would like to thank you for the opportunity to comment on these proposals and I would encourage everyone involved in this process to partner with the NASBLA Executive Staff to create workable solutions for these issues. Thank You Major Felix Hensley Commander Support Services IDNR Law Enforcement Div.