Dwayne Peter Boundreaux

This is in response to the proposed rule making on Seatime for vessels that only get underway or occasionally get underway. NMC Policy Letter 09-01 includes Liftboats and is a huge mistake to lump this type of vessel in with vessels that don't get underway. We have a letter dated 13 April 1998 from the Commander, Eighth CG District that went out to all eighth District REC's agreeing that Seatime on Liftboats should be credited one for one both for underway and elevated. We currently have a meeting set with Luke B. Harden Chief, Mariner Credentialing Program Policy Division (CG-5434) (202) 372-1206 (o) (202) 270-4901 (c) luke.b.harden@uscg.mil This meeting is set for August 23, 2011. We have been working on getting in front of someone since we sent letters back in Feb. of this Year. This is a burden on our industry and our Mariners. It violates all that we stand for concerning safety of our crews and customers, to think that we don't maintain the same level of competency when we are elevated VS underway. Our Crew Members without a question, do more training than other OSV Mariners that we are graded with according to our COI and would expect that before making rules changes and Policies that affect people's lives, take some time to investigate how it affects Safety Of Life at Sea (SOLAS). I am proud to say that I work with the best trained and most professional group of Mariners in our industry, but this Rule Making is hindering our Mariners from advancing and could dis-allow some from renewing current credentials due to the way you credit their seatime. Please take time to look at the level of Training and Competency needed to operate a liftboat that is classed with ABS and regulated under the CG COI, IMO and is ISM Certified. Regards, Dwayne Boudreaux Human Resources Director 1600 Master Superior Energy Services 504-367-0858 504-722-9894