Alabama State Port Authority

Comments for Docket USCG-2008-1013, Security Zones; Escorted Vessels, Mobile, AL, Captain of the Port Zone The Alabama State Port Authority is concerned on the impact to shipping in the Mobile River that this new security zone will impose on escorted vessels once they moor. Based on 2006 Army Corps of Engineer data on overall tonnage, Mobile is the 10th largest port in the United States with over 59 millions tons over cargo moved within the port. Most of this tonnage is handled through a stretch of the Mobile River that is about 5 miles long and less than 500 yards wide. Cargo barges and ships constantly transit this stretch of river along with numerous recreational vessels. If any escorted vessel ties up within the main harbor, there will be a security zone that will extend across the entire main shipping channel. This will effectively shut down the river requiring every vessel to check in with the Coast Guard or its on scene patrol and could be hazardous if a vessel has to hold up depending on weather, traffic and tidal conditions. As described in the new regulation in 33 CFR 165.836(d) (2), “A vessel may request the permission of the COTP Mobile or a designated representative to enter the security zone….” This does not specifically state that there will be an on scene asset. The fact that there will be times that an on scene asset will not be present is also explicitly stated in 165.836 (a) under the definitions of an escorted vessel as “….is identifiable by the use of day boards or other visual indications such as lights or buoys when law enforcement assets are no longer on-scene.” It will not be possible to enforce this security zone without the presence of an on scene asset. Most of the commercial traffic will comply with the rule, but there is little chance that recreational traffic will be aware and/or comply with this rule. Also, if vessel traffic has to make a radio call to the Coast Guard for every transit of the security zone, there will be no way for the Coast Guard to monitor the situation from their office at Brookley. Lights and buoys extending across the main shipping channel will not only be problematic to maintain but would be a hazard to navigation if they stretch across and into the channel. If a vessel that is escorted arrives at a dock within the harbor, we are concerned about sustainability of the Coast Guard on scene presence. If the escorted vessel takes more than a couple of days in port, we are concerned about the Coast Guard’s ability to enforce the security zone 24/7 for any extended duration. Finally, we are concerned that once the security zone is established on a moored vessel that the ruling does not clearly state when and how the security zone will end. Does it end when the vessel departs the port, when the broadcast to mariners ends, when the cargo is offloaded or whenever the on scene asset departs? Is it in place for the entire time in port? Once a vessel is offloaded and remains at the dock, will the security zone end at that point? Depending on the cargo, once a vessel has offloaded cargo, they could be more of a risk than when the vessel is fully laden. These answers did not appear to be explicitly addressed in the interim rule. The Alabama State Port Authority is committed to maintaining safe and secure commerce and will continue to partner with the Coast Guard to ensure that all parties involved work together toward this common goal.