Nathan Wallace Hatfield

The Coast Guard proposal to finalize the regulation to require vessels to carry adequate discharge removal equipment is obviously much needed. This proposal would significantly reduce the risk posed by vessels carrying oil or hazardous substances in bulk without creating a significant increase in the cost of business for the transporter. It is the next logical step to convey the desired effect intended by the Oil Pollution act of 1990 (OPA 90). OPA 90 currently requires facilities to carry adequate discharge containment and removal equipment, as well as, training and annual certification of that training and equipment. I believe that this should also be a requirement included in the proposed regulation. It is not enough that the vessel carry adequate discharge removal equipment on board the vessel. The vessel also needs to create and submit a "vessel response plan", akin to the facility response plan required for facilities that conduct business of a similar nature. This vessel response plan should require that the crew is competent in deploying the required discharge removal equipment as well as certification that the discharge removal equipment is in proper and working order. Simply having discharge removal equipment onboard the vessel does no good if the crew does not know how to implement its use. In the event of a release, the crew of the vessel should be prepared ahead of time, and know their role and responsibility to limit and mitigate that release as well of the hazards of that release. For example the concentration of a gasoline spill creates an explosive environment and should not be handled the same as a release of diesel.