Coast Guard Clarifies Master Key Control System Requirement. The Coast Guard’s Office of Commercial Vessel Compliance has advised AWO that it interprets the statutory requirement for certain commercial vessels to establish a master key control system (46 U.S.C. §3106) to apply to those vessels that are equipped with a master key or keys. CG-CVC Policy Letter 23-06 defines a master key as “a single or multiple keys or electronic access device[s] on a vessel that enables access to multiple, if not all, secure compartments, rooms, or areas on the vessel, especially staterooms, bathrooms, changing rooms, and any other space that when locked by individual occupants, are intended to be inaccessible to others without a master key.” The Office of Commercial Vessel Compliance confirmed to AWO that if a vessel does not have doors with keyed locks, and therefore has no keys or electronic access devices, a master key control system is not required.

 

AWO continues to seek member feedback on Policy Letters 23-04, 23-05, and 23-06, and to dialogue with the Coast Guard about our concerns with the policy development process. If you have any questions or comments, please contact Caitlyn Stewart.

 

Industry Partners Join AWO in Urging Coast Guard to Clarify Harassment Reporting Requirements. AWO was joined by the Chamber of Shipping of America, the Lake Carriers Association, and the Passenger Vessel Association on a letter to Assistant Commandant for Prevention Policy Rear Admiral Wayne Arguin recommending clarifications to Marine Safety Information Bulletin 23-01 to ensure the implementation and enforcement of the statutory requirement to report harassment are as practical as possible. RDML Arguin’s office is working to schedule a meeting with the signatories to the letter to discuss further. In the meantime, AWO continues to advocate with Congress for removal of the undefined term “harassment” from the statute.

 

Coast Guard Publishes Guidance on Navigating Near Offshore Wind Structures. The Coast Guard recently released Navigation and Vessel Inspection Circular (NVIC) 03-23, Guidance on Navigational Safety In and Around Offshore Renewable Energy Installations. The NVIC outlines standard safety features of offshore wind installations, provides a visibility table, explores different foundation types, and details navigational aids. The NVIC also provides identification signals, charting symbols, and more. As the number of offshore wind structures increases in the coming years, understanding the risks and navigation information necessary for transiting near offshore wind farms will be helpful in voyage planning to keep mariners, vessels and cargo safe.

 

AWO Members Featured in Military Families Magazine. The latest edition of Military Families Magazine includes an article about veterans working in the tugboat, towboat, and barge industry. Mariners from The Vane Brothers Company and Magnolia Marine are featured in the piece, which highlights their experiences and career trajectories. The article begins on Page 14.

 

AWO Members Discuss Inland Dry, Liquid Markets on Marine Money Panel. On November 30, AWO President & CEO Jennifer Carpenter moderated a panel on the inland dry and liquid barge sectors at Marine Money’s Marine Finance Forum in New Orleans. AWO Immediate Past Chairman of the Board Clark Todd, President & CEO of Blessey Marine Services; former AWO Chairman Del Wilkins, President of Illinois Marine Towing; Mike Ellis, CEO of American Commercial Barge Line; and Bob Thomas, Chief Operating Officer of Southern Devall, shared their assessments of 2023 and outlook for 2024, discussed the need for shippers and carriers to share the risk of operational disruptions due to extreme weather, and emphasized the importance of investment in the nation’s waterways infrastructure.

 

Reminder: AWO Seeks Member Feedback on Possible Inclusion of Fentanyl Testing. The U.S. Department of Health and Human Services recently published a notice soliciting public comments on whether fentanyl and norfentanyl should be included in the federal workplace drug testing program. Any change to those requirements would apply to mariners. To understand member views on the potential inclusion of fentanyl testing, AWO will hold a virtual meeting on Thursday, December 7 at 2 PM (Eastern). To participate in the call, please contact Patrick Parsons.

 

Call for AWO Board Nominations. If you are looking for a leadership opportunity within AWO, now or in the next few years, please take a few minutes to review the Board Member Responsibilities and consider whether serving on the AWO Board of Directors might be right for you.

 

The Board of Directors provides governance and strategic direction on all aspects of AWO’s work – from advocacy, safety and environmental sustainability to public affairs and communications, member outreach and budgeting. Serving on the Board is a significant opportunity for members who recognize the benefits of AWO membership and want to take an active role in shaping AWO’s priorities, ensuring the resources needed to accomplish our mission, and overseeing progress toward our goals.

If you are interested in being considered for a Board seat, please contact Board Secretary Maureen Moore at mmoore@americanwaterways.com or (703) 841-9300, ext. 256, by December 8.

 

AWO Develops Graphic Showcasing Industry’s GHG Emission Reductions. AWO produced the graphic below, highlighting emissions reductions since 2005, as part of our action plan to implement the Board-approved recommendations of the Sustainability Task Force. We will be deploying the graphic to help tell the positive story of our industry’s sustainability leadership to government stakeholders, the media and the public. For more information on AWO’s sustainability action plan, please contact Brad Trammell.

 

Crowley CEO Joins AWO President on AMP Podcast. On the latest episode of the American Maritime Podcast, Crowley CEO Tom Crowley shared his thoughts with host Jennifer Carpenter on the importance of the Jones Act, opportunities in offshore wind, and more.

 

AWO PAC Corner

 

AWO PAC and Inside Elections. AWO has partnered with Inside Elections for another special edition, featuring analyses of key House races.

 

AWO PAC is the connected political action committee for The American Waterways Operators and serves as the trade association’s separate segregated fund. As a trade association, AWO is prohibited from using general treasury funds or membership dues to make federal contributions. AWO is one of the most effective advocacy associations in Washington, DC, and relies on voluntary personal contributions to fund AWO PAC.

AWO PAC supports federal candidates who are champions of the U.S. tugboat, towboat and barge industry and who are leaders on issues important to our industry. AWO PAC is dedicated to protecting AWO members’ investments in the safest, most environmentally responsible and most economical mode of freight transportation and safeguarding the integrity of the Jones Act to protect the bottom lines of our members. AWO PAC may solicit contributions from individuals of a member company once the member representative gives AWO written prior approval.

 

Lawmakers Pushing for Hudson River Anchorage Ban. Last month, three New York Congressmen – Rep. Pat Ryan (D), Rep. Marc Molinaro (R), and Rep. Mike Lawler (R) – introduced a bill that would prevent the creation of additional anchorages on the Hudson River north of the Tappan Zee Bridge. The move comes in response to U.S. Coast Guard Sector New York’s Marine Safety Information Bulletin earlier this year that classified the Hudson River as being subject to Inland Navigation Rules and not part of the Port of New York, a step that critics claim will lead to a sizable increase in anchored vessels on the Hudson. The 2021 National Defense Authorization Act, with AWO support, affirmed the right of vessel operators to anchor as needed on the Hudson River in the event of an emergency. We continue to believe that prohibiting anchoring except in designated areas would undermine safety on the river.

 

In response to the controversy, the Coast Guard announced that it will undertake a Notice of Inquiry and “extensive public outreach opportunities to explore potential regulatory updates and limited access areas on the Hudson River.” AWO is working with federal and state stakeholders to uphold an operator’s right to anchor as needed for safety.

 

AWO Comments on Offshore Maryland Wind DEIS. AWO recently submitted comments on the Bureau of Ocean Energy Management’s (BOEM) draft Environmental Impact Statement (DEIS) for the Offshore Maryland wind development. AWO requested that BOEM adjust the cable paths to minimize interaction with navigation routes and that, if a cable must cross navigation routes, it be buried at least 15 feet deep to ensure anchors do not damage or interfere with offshore export cables.

 

AWO Comments on Gulf of Maine WEA. AWO recently provided comments to the Bureau of Ocean Energy Management in response to its draft wind energy area (WEA) in the Gulf of Maine. AWO thanked BOEM for listening to the association’s requests and removing certain areas that conflict with safe navigation from consideration for offshore wind leasing. AWO has requested that BOEM officially remove another small area, which BOEM is holding in reserve as a “secondary area,” from consideration, as it directly overlaps with a navigation safety fairway being considered by the Coast Guard and could cause a bottleneck for vessels transiting the Gulf of Maine.

 

CARB Releases Template for Opacity Testing. As EPA continues its consideration of California’s request for a waiver from the Clean Air Act, the California Air Resources Board (CARB) has released a template for opacity testing. The 2022 amendments to the Commercial Harbor Craft Rule require companies to track and report engine exhaust to CARB; the first of these annual reports must be submitted by March 31, 2024. More information can be found here.

 

Key Maritime Events Coming Soon in Washington State. AWO members are encouraged to register for two signature Washington state gatherings in the coming weeks: the Washington Maritime Federation’s annual meeting on December 14 at Centerline Logistics; and Maritime Advocacy Day in Olympia on February 1. To learn more or to sign up for either event, contact Peter Schrappen, AWO Vice President – Pacific Region.

 

AWO Comments on Missouri River Draft Annual Operating Plan. AWO recently submitted comments to the U.S. Army Corps of Engineers on the Missouri River Mainstem System 2023-2024 Draft Annual Operating Plan (AOP). AWO thanked the Corps for releasing the draft AOP before January 1, urged the agency to provide critical flow support to support navigation on the lower Missouri River and middle Mississippi River, and encouraged the Corps to host an in-person meeting on the draft AOP in the St. Louis area next year.

 

AWO Comments on Kansas River Water Control Manuals. On November 30, AWO submitted comments to the Army Corps of Engineers’ Kansas City District regarding planned changes to Water Control Manuals (WCMs) on the Lower Kansas River. Three of the reservoirs affected – Perry, Tuttle, and Milford – are Congressionally authorized for navigation releases to the Missouri River. While the agency states that it does not intend to alter navigation flows, AWO reminded the Corps that providing those flows is the agency’s responsibility. Additionally, AWO requested that the Corps consult with the ongoing Missouri River Navigation Study to gauge Missouri River System navigation needs before finalizing changes to the WCMs.

 

 

Coast Guard, AWO Honor Moran Towing Crews for Golden Ray Response. On November 27 in Brunswick, GA, the Coast Guard and Rep. Buddy Carter (R-GA) presented the crews of the Dorothy Moran and Ann Moran with the Coast Guard Public Service Commendation for their actions in response to the capsizing of the Golden Ray roll-on/roll-off cargo ship.

AWO was also on hand to present the crews with the American Waterways Honor and Excellence in Rescue Operations (HERO) Award in recognition of their heroic efforts.

 

The Golden Ray capsized in St. Simon’s Sound, GA on September 8, 2019. In response to the incident, the crews aboard the Dorothy Moran and Ann Moran, working together with the Georgia Department of Natural Resources and the Brunswick Pilots (also awarded commendations by the Coast Guard) acted quickly to rescue Golden Ray crew members and prevent further environmental damage and adverse economic impact to St. Simon’s Sound.