The only audited number applied to the rate methodology is the yearly expenses of each pilot district. The expense number with the seasonal adjustments is so-posed to compensate each district for their yearly expenses. this level of compensation is only reached when the bridge hour standard has been achieved in its entirety. In District Three where I have worked since 1979 this has only happened twice since the over twenty year old new rate methodology has been in place. All of the other years the portion of the expenses that is not received is paid for by the pilots significantly reducing their rightful compensation.
Andrew James Sciullo
This is comment on Proposed Rule
NPRM: Great Lakes Pilotage Rates, 2013 Annual Review and Adjustment (Federal Register Publication)
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