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

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4. 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

5. 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

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

7. NEW TVNCOE www.uscg.mil/tvncoe

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

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

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

11. 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

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

13. 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. 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

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

16. 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

17. 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

18. Fixed CO2 Systems Issue Some systems are not installed IAW 46 CFR 76.15 Examples: Bottles over 300lbs capacity located inside space being protected Inadequate amount of CO2 for space Policy Letter 10-06 Allows designation of “Excess Equipment” for certain circumstances. Towing Vessel National Center of Expertise 18

19. NEW TVNCOE www.uscg.mil/tvncoe

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

21. 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

22. Equivalencies 46 CFR 24.15-1 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

23. Exemption Only for a specific regulation Most can be granted by COTP If denied, owner/operator has right to appeal Examples: EPIRB - 46 CFR 25.26-60(b) Dist Cmdr exemption Fire Protection - 46 CFR 27.100(b)(4) & 27.100(c) Navigation Safety - 33 CFR 164.01-(b)(4) Towing Vessel National Center of Expertise 23

24. Appeals References 46 CFR 24.01-7 (will direct the reader to 1.03) 46 CFR 1.03 46 CFR 1.01 30-day time limit Written request Description of decision/action & why it should be revised Towing Vessel National Center of Expertise 24

25. 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

26. Questions? Towing Vessel National Center of Expertise 26