Renee Bowen

We request clarification of the definition of "cargo" under 33 CFR.155.5020. We request that 33 CFR 155.1035 (e)(2) and 33 CFR 155.5035 (e)(2) be revised to include the name of a company that provides QI services, as well as the identification of a QI and alternate. More often than not, the QI service is provided through a company that employs a number of individuals that fill the role of QI and alternate. We request that 33 CFR 155.1035 (e)(3) and 33 CFR 155.5035 (e)(3) be revised to ask for the identification of the vessel's insurance provider instead of "insurance representatives". Asking for the applicable insurance representatives would require the plan to identify the local correspondent(s) by name for the vessel's areas of operation. Listing individuals in plans for this purpose can and will cause a never-ending revision process and added burden for plan holders to ensure that the individual person(s) listed in each port is accurate. The insurance providers all have 24 hour contact numbers and the owner/operator would contact the insurance provider immediately for their involvement in an incident. The insurance provider would then appoint a local representative to attend the vessel. We request that 33 CFR 155.1035(e)(4) and 33 CFR 155.5035(e)(4) be revised to allow for the plans to reflect a statement that the identification of the local agent will be available prior to arrival in port and noted in the eNOA. Most agents are not appointed until shortly before the vessel's arrival in a port. Including the specific names of local agents in individual ports would cause plans to be submitted without this information and delay approval of the plan which could then force the owner/operator to apply for one-time waivers or IOAs. In addition, listing the name of local agents in plans has the possibility of causing never-ending revisions to plans to keep this information current. Thank you.