William E. Bvrucato

Subject: Docket No. USCG–2010–0797 Gentlemen: This letter is to serve as comment to the Notice of Proposed Rulemaking titled Recognition of Foreign Certificates Under the International Convention on Standards of Training, Certification, and Watchkeeping for Seafarers, 1978, as Amended, Regulation I/10 I wish to file my objection to the proposed rulemaking based on these two paragraphs found within it: “Given this need, the Coast Guard is developing a policy to start establishing a process for the United States’ recognition of foreign certificates held by foreign officers who may be employed on some United States flag vessels.” and; “The proposed policy could also offer guidance for mariners and/or vessel operators/employers with regard to applying for and obtaining a United States-issued endorsement of their foreign certificates.” Both paragraphs indicate that the proposed rule-making will facilitate the employment of foreign national mariners on all types of US flagged vessels. There are no provisions in this rule-making to protect US citizen mariners. By changing the current policy of not recognizing the S.T.C.W. certificates of foreign seafarers, US flagged vessel shipowners will be given incentive to find avenues to cease employing US mariners and begin to engage foreign seafarers due to the cost differential and other issues such as US citizen seafarer civil protections. There is no language in this proposed rule-making to prevent this from happening. Although the immediate impact of this proposal will affect the offshore and O.C.S. fleets, it provides a wedge to be driven into the Jones Act and its tenets. How long before this leak in the dike gushes forth and engulfs the inland fleets of the USA and decimates the few protections and employment opportunities left to the American Merchant Mariner? Honor the Mariner, indeed... Respectfully, Capt. Wm. E. Brucato