TOWING VESSEL NATIONAL CENTER OF EXPERTISE Towing Vessel National Center of Expertise 1

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STAFF Active Duty CDR Pat Nelson LCDR Jaime Salinas LT Paris Stratton Civilian Roy Murphy Mike Kelly Steven Douglass Dave Phillips Towing Vessel National Center of Expertise 4

Vision Be the Coast Guard's forward thinking component in the towing industry to keep all TVBP stakeholders well- prepared to handle current and future needs Mission Serve as in-house consultants Provide technical advice to both industry and the Coast Guard Increase and maintain the Coast Guard’s collective competency Towing Vessel National Center of Expertise 5

Professional Objectives Towing Vessel National Center of Expertise 6 TrainingJob Aids Policy & Guidance Technical Advice On-Site Assistance Liaison w/ Industry

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TOWING VESSEL BRIDGING PROGRAM Program elements & expectations Towing Vessel National Center of Expertise 8

Purpose Bridge the gap – Ease the transition Towing Vessel National Center of Expertise 9

Goals Towing Vessel Outreach, Orientation and Indoctrination Workbook Outreach to Industry & CG Examine 100% UTV Towing Vessel National Center of Expertise 10

3 Phases Outreach & Education Qualification IIE’s UTV Course 1 Prioritized Exams IIE’s 2 COI Issuance Advanced Course 3 Towing Vessel National Center of Expertise 11 Law Enforcement Boardings & Surge Operations

UTV Fleet of Responsibility = 5571 Industry Initiated Exams = 5908 Prioritized Exams Remaining = 407

Timeline Towing Vessel National Center of Expertise 13 Steamboat inspections 1800’s 2004 CG Auth Act 2009 TVBP 2011 NPRM 03/15 Final Rule (?) Implementation COI

14 YR 11 YR 0 YR 6 YR 3 YR 4 YR 5 Towing Vessel National Center of Expertise Effective Date of Final Rule Implement TSMS Prepare vessel etc. 25% Deferred Machinery & Electrical 5yrs fm COI Full Compliance 50% Deferred Machinery & Electrical 5yrs fm COI 75% Deferred Machinery & Electrical 5yrs fm COI 100% Deferred Machinery & Electrical 5yrs fm COI YR 2 YR 8 YR 9 YR 10 Compliance Phase-in

POLICIES & GUIDANCE Problems & Solutions Towing Vessel National Center of Expertise 15

Lesson Objectives DETERMINE current policies and guidance STATE the Exemptions, Appeals and Equivalencies procedures. STATE sources to obtain current policies and guidance. Towing Vessel National Center of Expertise 16

Frequently Asked Questions Towing Vessel National Center of Expertise 17 TVNCOE Q. Where can I find information on maintenance and inspections required for portable fire extinguishers? Ans. National Fire Protection Association (NFPA) 10 Standard for Portable Fire Extinguishers. You may obtain a copy of NFPA 10 through the National Fire Protection Association. PORTABLE FIRE EXTINGUISHER INSPECTION/MAINTAINANCE

Fixed CO2 Systems Issue Some systems are not installed IAW 46 CFR Examples: Bottles over 300lbs capacity located inside space being protected Inadequate amount of CO2 for space Policy Letter Allows designation of “Excess Equipment” for certain circumstances. Towing Vessel National Center of Expertise 18

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EXEMPTIONS, APPEALS & EQUIVALENCIES Awareness Towing Vessel National Center of Expertise 20

Flexibility in the Law Allowance for substitution or alternate equipment Equivalency Relief from meeting specific regulations Exemption Relief from COTP/OCMI decision Appeals Towing Vessel National Center of Expertise 21

Equivalencies 46 CFR Granted by COMDT Substitution that is at least as effective as that specified in regulation. Examples of equivalencies granted so far: Fuel shut off valves NICET Level IV Technicians Towing Vessel National Center of Expertise 22

Exemption Only for a specific regulation Most can be granted by COTP If denied, owner/operator has right to appeal Examples: EPIRB - 46 CFR (b) Dist Cmdr exemption Fire Protection - 46 CFR (b)(4) & (c) Navigation Safety - 33 CFR (b)(4) Towing Vessel National Center of Expertise 23

Appeals References 46 CFR (will direct the reader to 1.03) 46 CFR CFR day time limit Written request Description of decision/action & why it should be revised Towing Vessel National Center of Expertise 24

Rules of Thumb for Equivalents, Exemptions, and Appeals Formal written requests from owner/operators Must provide justification for request Submitted thru Chain of Command (via cognizant OCMI/COTP) COMDT is the highest and final authority on decisions/actions See process guide at TVNCOE website for help (template letters/memos available) Towing Vessel National Center of Expertise 25 TVNCOE

Questions? Towing Vessel National Center of Expertise 26