Joseph Greeley
10/13/07
jgreeley@gwu.edu
To Whom It May Concern:
The United States Coast Guard currently faces many difficulties in its ability to
protect America?s coast. One of the major difficulties that has always plagued the
organization is its ability to cover all American coastline at once. With the
simultaneous emergence of global trade and new terrorist threats, the Coast
Guard is finding that it needs to be in too many places at once. One step in the
direction of solving this problem is the Coast Guard?s modernization of its fleet.
The new technology allows the Coast Guard to move faster and cover more ground
in smaller amounts of time. Despite advances on the behalf of the Coast Guard,
the challenge still exists. One of the main duties of the Coast Guard, emergency
search and rescue, is hampered by this challenge. This proposed rulemaking is a
crucial way for individual vessels to assist the Coast Guard in search and rescue
efforts as well as in its ability to keep monitor United States ports.
Long Range Identification and Tracking of ships is the focus of the proposed
rulemaking. The preamble gives a good synopsis of the technology and the
international background of the topic. The topic is not one that ordinary people
would tend to know exists, unless they are involved with the shipping industry or
are well-versed on the issues of international maritime security. The rulemaking
calls for mandatory installation and/or upgrading of LRIT equipment on United
States flag ships and many foreign ships entering US waters, as well as
mandatory information transmissions to data centers in the United States. The
most important selling point for the necessity of this technology is stated in the
preamble, which states that search and rescue (SAR) is greatly reinforced with
regular LRIT transmissions. The rulemaking would affect foreign and American
passenger ships with twelve or more passengers, all mobile offshore drilling units,
and cargo ships carrying over 300 tons of cargo. These three types of ship would
be required to transmit four times per day their identity and position to an
American data center when traveling towards any American port. It is a good
rulemaking due to its possible benefits in reducing SAR response time in United
States waters. It also allows the Department of Homeland Security and the Coast
Guard to better track movement in and around ports, to determine which are
getting the most use, for resource allocation purposes.
Despite the usefulness of the rulemaking, there are a few questions that need to
be addressed. First, while the rule mentions the procedure for captains to follow if
LRIT technology is accidentally deactivated, there is no mention of penalties for
required vessels that do not transmit to the American data center. It may be
implied that the Coast Guard would intercept ships that fail to transmit information
upon entering American waters, however this is not clearly stated. Additionally, in
the cost-benefit analysis laid out in the preamble, there is no mention of the
effects this rule would have on the Coast Guard. Would more transmissions from
a greater number of ships require the Coast Guard to increase recruitment and fill
more staffing positions in data centers? The rulemaking states that ship-by-ship
inspection surveys would take place in late 2008 and early 2009 to ensure that the
proper equipment has been installed and/or upgraded. Would Coast Guard
inspection of this equipment require more specialization by members of the Coast
Guard, and the need for more inspectors? What would this inspection consist of,
and how long would companies have to fix problems with LRIT equipment? If
inspections do not require Coast Guard action, which agencies will administer
them?
I look forward to reading more information on the rulemaking in the coming
months, and look forward to its prompt implementation.
Sincerely,
Joseph Greeley
Joseph P. Greeley
This is comment on Notice
Long Range Identification and Tracking of Ships
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Joseph P. Greeley
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Joseph P. Greeley
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