Lakes Pilots Association, Inc.

As we have stated in the past, Lakes Pilots Association, Inc., District 2, again this year would like to state that we disagree with the way the Director’s office calculates bridge hours and the number of pilots in Areas 4 and 5. Please see our explanation below: First of all, at a minimum, the Director should round up the number of pilots in Area 4. It is impossible to pilot these waters without the proper number of people to do so. For example, if the number the director estimate is 10.48, we at Lakes Pilots believe 11 pilots should be in the rate. Otherwise .48 of the work goes undone or is a burden to the other 10 pilots included in the rate. The Director’s office rounded up in Areas 1 and 2 and used the discussion to increase pilotage numbers in that district. This methodology should be consistent across the different areas, not showing favoritism to one or two over the other(s). Secondly, the manner in which the Director calculates bridge hours is arbitrary and capricious. The Director’s office continues to count detention and delay in Areas 6, 7, and 8 – yet does not apply that same standard to Areas 4 and 5. The Director also allowed the inclusion of detention and delay in Areas 6, 7, and 8 to increase pilotage numbers but did not include detention and delay in Areas 4 and 5. This current method of inclusion/exclusion is unfair and capricious and we ask that the methodology be consistent across the different areas. Lakes Pilots Association, Inc. recommends the Director of Great Lakes Pilot and his staff include consistent ratemaking methodologies across all districts/areas by including detention and delay and rounding up the number of pilots for Areas 4 and 5 in their ratemaking methodologies.