Joseph P. Greeley

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