Recent Position Papers, Comments, Letters and Testimony

2024 Comments, Letters and Testimony

October 18 - Comments to Mr. Seth Theuerkauf, Renewable Energy Program, Specialist Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding the Central Atlantic Call Area 2 Call for Information
October 17 - Comments to Mr. Victor Vourcos, Project Manager, Corpus Christi District Office, Texas Department of Transportation regarding Notice of Intent to prepare an Environmental Impact Statement for the Regional Parkway-North Padre Island transportation project
October 15 - Comments to Mr. David Eng, Secretary, Federal Maritime Commission regarding notice of extension of time for a decision in its investigation into conditions affecting United States carriers in connection with Canadian ballast water regulation in the United States/Canada Great Lakes trade
September 24 - Comments to Ms. Nicole Singh, Climate Protection Manager, Oregon Department of Environmental Quality regarding rulemaking to establish an improved climate mitigation program
September 6 - Comments to Mr. Charles Hall, LRD Regional Technical Specialist, Environmental Project Planning Branch, Nashville District, U.S. Army Corps of Engineers regarding the Invasive Carp Program Management Plan, Draft Programmatic Environmental Assessment, Finding of No Significant Impact
July 19 - Comments to The Honorable Merrick B. Garland, Attorney General, U.S. Department of Justice regarding the proposed transfer of marijuana from schedule I of the Controlled Substances Act (CSA) to schedule III of the CSA
July 19 - Comments to Mr. Jeffrey G. Lantz, Director of Commercial Regulations and Standards, U.S. Coast Guard regarding recordkeeping and reporting requirements to document environmental compliance on certain commercial vessels
June 28 - Comments to Ms. Jennie M. Easterly, Director, Cybersecurity and Infrastructure Security Agency regarding Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) Reporting Requirements
May 22 - Comments to RDML Wayne Arguin, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding the U.S. Coast Guard’s proposed rule to establish minimum cybersecurity requirements for U.S.-flagged vessels and facilities subject to the Maritime Transportation Security Act of 2002
May 13 - Comments to CDR Nicholas C. Seniuk, USCG Seventh District Waterways Management regarding the proposed regulated navigation area for the Port of Miami
May 8 - Comments to RADM Wayne R. Arguin Jr., Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding Mariner Credentialing Program transformation
April 8 - Comments to Ms. Brandi Sangunett, NEPA Coordinator, BOEM Environment Branch for Renewable Energy regarding draft Wind Energy Areas in the Gulf of Maine
April 2 - Comments to COL Cullen Jones, Commander and District Engineer, New Orleans District, U.S. Army Corps of Engineers regarding the scope of the Lower Mississippi River Comprehensive Study
March 25 - Comments to CDR Brandon Link, U.S. Coast Guard Office of Port and Facility Compliance and CDR Frank Strom, U.S. Coast Guard Office of Design and Engineering Standards regarding cybersecurity in the marine transportation system
March 22 - Comments to California Energy Commission regarding the Draft California Energy Commission Assembly Bill 525 Offshore Wind Strategic Plan
March 4 - Comments to Ms. Dana S. Tulis, Director, Emergency Management, U.S. Coast Guard regarding Western Alaska Oil Spill planning criteria
March 4 - Comments to Hon. Michelle L. Phillips, Secretary to the Commission, New York State Public Service Commission regarding the Champlain Hudson Power Express Inc. (CHPE) application for construction, operation, and maintenance of a high voltage cable along the Hudson River
February 23 - Comments to RADM Charles E. Fosse, Commander, Thirteenth District, U.S. Coast Guard regarding notice of proposed rulemaking to establish anchorage ground: Crims Island Anchorage, Columbia River, Oregon, and Washington
February 23 - Comments to RADM Charles E. Fosse, Commander, Thirteenth District, U.S. Coast Guard regarding notice of proposed rulemaking to establish anchorage ground: Port Westward Anchorage, Columbia River, Oregon and Washington
February 23 - Comments to RADM Charles E. Fosse, Commander, Thirteenth District, U.S. Coast Guard regarding notice of proposed rulemaking to establish anchorage ground: Rice Island Anchorage, Columbia River, Oregon, and Washington
February 22 - Comments to California Governor Gavin Newsom regarding the California Air Resources Board Commerical Harbor Craft Rule.
February 22 - Testimony by Peter Schrappen, AWO Vice President - Pacific Region, before the Hawaii Senate Ways and Means Committee in opposition to SB 2746, Relating to Harbor Safety
February 16 - Comments to Ms. Lisa Gilbane, Pacific Regional Office of Environment, Bureau of Ocean Energy Management regarding BOEM’s programmatic environmental impact statement regarding the California offshore wine leases
February 13 - Comments to Mr. Douglas W. O’Donnell, Deputy Commissioner for Services and Enforcement, Internal Revenue Service regarding the Advance Manufacturing Production Credit (45X)
February 12 - Comments to Ms. Jessica Stromberg, Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding draft environmental assessment of offshore wind leases in the Central Atlantic
January 19 - T estimony by Kyle T. Burleson, AWO Director - State Advocacy, before the NH House State-Federal Relations and Veterans Affairs Committee regarding a resolution calling for repeal of the Jones Act

2023 Comments, Letters and Testimony

December 20 - Comments to Ms. Lisa S. Davis, Public Health Advisor, Division of Workplace Programs, Substance Abuse and Mental Health Services Administration regarding proposed changes to the authorized drug testing panels for urine and oral fluid
November 30 - Comments to Colonel Travis Rayfield, Commander, Kansas City District, U.S. Army Corps of Engineers regarding Lower Kansas River Water Control Manuals
November 27 - Comments to BG Geoff Van Epps, Commander, Northwestern Division, U.S. Army Corps of Engineers regarding Missouri River Mainstem System 2023-2024 Draft Annual Operating Plan
November 2 - Testimony by Kyle T. Burleson, AWO Director - State Advocacy, before CA Assembly Select Committee on Ports and Goods Movement regarding the California Air Resources Board's Commercial Harbor Craft rule
October 26 - Comments to Ms. Jean Thurston-Keller, Project Coordinator, Pacific Regional Office – Renewable Energy Section Bureau of Ocean Energy Management regarding Draft Wind Energy Areas – Commercial Leasing for Wind Power Development on the Oregon Outer Continental Shelf
October 6 - Comments to Ms. Diana Davis, Spill Prevention, Preparedness, and Response Program, Washington State Department of Ecology regarding Chapter 173-187 WAC Financial Responsibility Preliminary Rule Language
October 6 - Comments to Mr. Steven M. Neugeboren, Associate General Counsel, Water Law Office, Office of General Counsel, U.S. Environmental Protection Agency regarding the proposed consent decree to require the EPA to set a date for final action on the Vessel Incidental Discharge National Standards of Performance
October 6 - Comments to Mr. David Bernhart, Assistant Regional Administrator, Protected Resources Division, National Marine Fisheries Services, Southeast Regional Office regarding Endangered and Threatened Species; Designation of Critical Habitat for the Rice’s Whales
August 21 - Comments to California Governor Gavin Newsom regarding CARB's recent amendments to the Commercial Harbor Craft rule
August 17 - Comments to the Mississippi River Commission regarding optimizing safe navigation on the river
August 12 - Comments to Ms. Mirian Sandova, Air Pollution Specialist, Mobile Source Control Division, California Air Resources Board regarding proposed revisions to the Carl Moyer Memorial Air Quality Standards Attainment Program
August 11 - Comments to Mr. Michael Walker, Bridge Management Specialist, 9th Coast Guard District regarding the Stephen Street Bike Trail Bridge
July 6 - Comments to Richard W. Spinrad, Ph.D., Under Secretary of Commerce for Oceans and Atmosphere, National Oceanic and Atmospheric Administration regarding Endangered and Threatened Species Petition to Establish a Vessel Speed Restriction and Other Vessel-Related Measures to Protect Rice’s Whales
July 1 - Comments to U.S. Environmental Protection Agency regarding the California Air Resources Board's request for authorization to enforce amendments to the commercial harbor craft rule
June 28 - Comments to Rear Admiral Jo-Ann F. Burdian, Assistant Commandant for Response Policy, U.S. Coast Guard regarding Coast Guard Vessel Response Plan and Maritime Oil-Spill Response Plan Advisory Group (MORPAG) Recommendations
May 4 - Comments to CDR Nicole Auth, Inspections & Investigations Branch Chief, U.S. Coast Guard, District Nine regarding draft D9 guidance for inland towing vessels on Western Rivers and Lake Michigan
April 25 - Comments to Ms. Tershara Matthews, Chief, Office of Emerging Programs, Bureau of Ocean Energy Management regarding Proposed Sale Notice for the commercial offshore wind leases in the Gulf of Mexico
April 17 - Comments to Ms. Brandi Canada, U.S. Coast Guard, Eighth Coast Guard District regarding Port Access Route Study in the Gulf of Mexico
April 12 - Testimony by AWO State Advocacy Representative Kyle Burleson before the New Hampshire House Commerce and Consumer Affairs Committee in opposition to SB102
April 5 - Comments to Ms. Kim Morley, Spill Prevention, Preparedness, and Response Program, Washington State Department of Ecology regarding rulemaking to amend Chapter 363-116 WAC, Pilotage Rules
April 3 - Testimony by AWO Vice President - Pacific Region Peter Schrappen before the Columbia River Base Mediation listening session regarding the importance of the Lower Snake River Dams
March 27 - C omments to Ms. Sarah Dunham, U.S. Environmental Protection Agency Docket Center, requesting that EPA hold a virtual public hearing on the California Air Resources Board’s request for authorization of amendments to its Commercial Harbor Craft rule
March 21 - Comments to Ms. Amy Frantz, U.S. Army Corps of Engineers regarding Water Resources Development Act of 2022 Implementation Guidance
March 17 - Comments to Mrs. Megan Johns-Henry, Alternate Designated Federal Officer, National Merchant Marine Personnel Advisory Committee encouraging amendment of its task statement on the mariner shortage to consider a wider range of the industry
February 13 - Comments to Ms. Jessica Stromberg, Project Coordinator, Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding Draft Environmental Impact Statement for the Coastal Virginia Offshore Wind Commercial Project
February 13 - Comments to LTJG Thomas Davis, U.S. Coast Guard - First District regarding Port Access Route Study: Approaches to Maine, New Hampshire, and Massachusetts
February 13 - Comments to Ms. Jessica Stromberg, Project Coordinator, Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding Draft Environmental Impact Statement for Sunrise Wind, LLC's Proposed Sunrise Wind Farm Offshore New York
February 13 - Comments to LT Ryan Gilbert, U.S. Coast Guard - Seventh District regarding Southeast Atlantic Coast Port Access Route Study
January 17 - Comments to Ms. Jessica Stromberg, Project Coordinator, Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding the environmental impact statement of Empire Wind’s offshore operations off the coast of New York

2022 Comments, Letters and Testimony

December 17 - Comments to Ms. Jennifer Brown, Vicksburg District, U.S. Army Corps of Engineers regarding application for a permit along the Yazoo River Diversion Canal at Vicksburg, MS
December 16 - Comments to Mr. Dean Amundson, U.S. Coast Guard, Shore Infrastructure Logistics Center, Environmental Division regarding Expansion and Modernization of Base Seattle
December 13 - Comments to Ms. Amy DeBisschop, Director, Division of Regulations, Legislation, and Interpretation, Wage and Hour Division, U.S. Department of Labor regarding Employee or Independent Contractor Classification Under the Fair Labor Standards Act
December 4 - Comments to Dr. Caroline Good, Office of Protected Resources, National Marine Fisheries Service regarding BOEM/NOAA Offshore Wind Strategy
November 21 - Comments to BG Geoff Van Epps, Commander, Northwestern Division, U.S. Army Corps of Engineers regarding the Missouri River Mainstem System 2022-2023 Draft Annual Operating Plan
November 18 - Comments to Mr. Scott Doney, Office of Science and Technology Policy, Executive Office of the President regarding the Ocean Climate Action Plan
November 8 - Comments to LCDR Sara Conrad, Pacific Area (PAC-54), U.S. Coast Guard regarding draft Pacific Coast Port Access Route Study (PACPARS)
November 7 - Comments to Mr. Douglas Blakemore, Chief, Bridge Administration Branch, U.S. Coast Guard, Eighth Coast Guard District regarding Drawbridge Operation Regulation; Bay St. Louis, MO
November 7 - Comments to Mr. Douglas Blakemore, Chief, Bridge Administration Branch, U.S. Coast Guard, Eighth Coast Guard District regarding Drawbridge Operation Regulation; Pascagoula River, Pascagoula, MS
October 31 - Comments to Dr. Caroline Good, Office of Protected Resources, National Marine Fisheries Service regarding amendments to the North Atlantic Right Whale Vessel Strike Reduction Rule
October 25 - Comments to Steven S. Cliff, Ph.D., Executive Officer, California Air Resources Board regarding additional recommendations on the Commercial Harbor Craft Rule
October 24 - Comments to Mr. Craig D. Carrington, Chief, Project Planning Branch, Nashville District, U.S. Army Corps of Engineers regarding scoping to evaluate measures and alternatives to manage and prevent the spread of invasive carp in the Tennessee River, Cumberland River, and northern section of the Tennessee-Tombigbee Waterway.
September 14 - Comments regarding the California Office of Administrative Law’s Decision of Disapproval of Regulatory Action for the California Air Resource Board’s Commercial Harbor Craft Rule
September 7 - Comments to Ms. Heidi Craswell, Manager, Marine Safety Management System Regulations, Marine Safety and Security, Transport Canada regarding Canada’s proposed Marine Safety Management System Regulations
August 26 - Comments to Ms. Radhika Fox Assistant Administrator, Office of Water, U.S. Environmental Protection Agency, regarding Draft Guidance for Vessel Sewage No-Discharge Zones
August 1 - Comments to Mr. Andrew Richard, Regional Aquaculture Coordinator, Southeast Regional Office, National Marine Fisheries Service regarding Notice of Intent to Prepare Programmatic Environmental Impact Statement for Identification of Aquaculture Opportunity Areas in Federal Waters of the Gulf of Mexico
August 1 - Comments to Ms. Sara Guiltinan, Pacific Regional Office, Bureau of Ocean Energy Management regarding the proposed sale notice of offshore wind leases in California’s Humboldt and Morro bays
June 28 - Comments to COL Stephen Murphy, Commander and District Engineer, New Orleans District, U.S. Army Corps of Engineers and CAPT Kelly Denning, Commander, Sector New Orleans, U.S. Coast Guard regarding Navigation Safety Risk Assessment for CEMUS, LLC Permit
June 27 - Comments to RDML Wayne Arguin, Assistant Commandant for Prevention Policy U.S. Coast Guard, regarding Electronic Chart and Navigational Equipment Carriage Requirements
June 24 - Comments to Ms. Bridgette Duplantis, Office of Leasing and Plans, Bureau of Ocean Energy Management regarding Commercial Leasing for Wind Power Development on the Central Atlantic Outer Continental Shelf
June 23 - Comments to Dr. Whitney Hauer, Renewable Energy Specialist, Office of Strategic Resources, Bureau of Ocean Energy Management regarding Commercial Leasing for Wind Energy Development on the Outer Continental Shelf (OCS) Offshore Oregon
June 8 - Comments to California Senate Budget Committee Chair Nancy Skinner, Assembly Budget Committee Chair Philip Ting, Senate Budget Subcommittee Chair Bob Wieckowski, and Assembly Budget Subcommittee Chair Richard Bloom regarding Proposed 2022-2023 Budget to Transition Commercial Harbor Craft Vessels to Low, Zero and Near-Zero Emissions
June 3 - Comments to Chair Liane Randolph, California Air Resources Board regarding proposed amendments to the Commercial Harbor Craft (CHC) regulation
May 16 - Comments to LTJG Thomas Davis, U.S. Coast Guard - First District regarding Port Access Route Study: Approaches to Maine, New Hampshire, and Massachusetts
May 13 - Comments to Ms. Jean Thurston-Keller, California Intergovernmental Renewable Energy Task Force Coordinator, Office of the Environment, BOEM regarding Morro Bay Wind Energy Area Draft Environmental Assessment
April 28 - Comments to Ms. Lauren Smith, Sound Transit, regarding the West Seattle and Ballard Link Extensions draft Environmental Impact Statement
April 25 - Comments to the Honorable Pete Buttigieg, Secretary, Department of Transportation, regarding a proposed amendment of transportation industry drug testing program regulations to include oral fluid testing
April 25 - Comments to Mr. Matthew Creelman, U.S. Coast Guard Fifth District, regarding Port Access Route Study: Seacoast of North Carolina
April 18 - Comments to LCDR Sarah Krolman, U.S. Coast Guard, regarding the final programmatic environmental impact statement for the Waterways Commerce Cutters
March 24 - Comments to Chair Liane Randolph, Harbor Craft California Air Resources Board regarding Proposed Regulations for Commercial Harbor Craft
March 7 - Comments to Mr. William Cody, Secretary, Federal Maritime Commission regarding conditions created by Canadian ballast water regulations in the U.S./Canada Great Lakes Trade
February 28 - Comments to Kirk Sunderman, Project Engineer – Brandon Road Interbasin Project, Inland Navigation Design Center, US Army Corps of Engineers regarding Brandon Road Interbasin Project - Engineered Channel Layout - Final Draft Engineering Evaluation Report
February 5 - Comments to Ms. Jean Thurston-Keller, California Intergovernmental Renewable Energy Task Force Coordinator, BOEM, Office of Strategic Resources regarding Humboldt Wind Energy Area Draft Environmental Assessment
January 25 - Comments to LCDR Sara Conrad, Pacific Area (PAC-54), U.S. Coast Guard regarding the U.S. Coast Guard’s notification of study for the Pacific Coast Port Access Route Study
January 10 - Comments to Ms. Jean Thurston-Keller, California Intergovernmental Renewable Energy Task Force Coordinator, BOEM, Office of Strategic Resources regarding Morro Bay Wind Energy Area Environmental Assessment Scoping

2021 Comments, Letters and Testimony

December 21 - Comments to Mr. Ryan Johnson, U.S. Army Corps of Engineers, Chicago District regarding USACE Draft EA for the Chicago Area Waterway System
November 15 - Comments to Ms. Liane Randolph, Chair c/o Harbor Craft California Air Resources Board regarding Proposed Regulations for Commercial Harbor Craft in California
November 8 - Comments to LCDR Sarah Krolman, U.S. Coast Guard Headquarters regarding Waterways Commerce Cutter Acquisition Program; Preparation of a Programmatic Environmental Impact Statement
October 5 - Comments to Rear Admiral John Mauger, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding Coast Guard Programs, Regulations, and Policies for Addressing Climate Change
September 30 - Comments to Mr. Alex Hess, Maritime Risk Lead, Department of Ecology, State of Washington regarding Tug Escort Analysis - Scope of Work
September 30 - Comments to Mr. Alex Hess, Maritime Risk Lead, Department of Ecology, State of Washington regarding Emergency Response Towing Vessel Analysis - Scope of Work
September 28 - Comments to MST2 Monika Spies, Waterways Management Division, Sector Upper Mississippi River, U.S. Coast Guard regarding Missouri River Waterways Analysis and Management System
September 13 - Comments to Ms. Jean Thurston-Keller, California Intergovernmental Renewable Energy Task Force Coordinator, BOEM, Office of Strategic Resources regarding call for information and nominations for the proposed extensions at Morro Bay
August 3 - Comments to The Honorable Pete Buttigieg, Secretary, U.S. Department of Transportation regarding support for the Paducah-McCracken County Riverport Authority’s application for the Port Infrastructure Development Program
August 3 - Comments to The Honorable Jenny Durkan, Mayor; The Honorable Lorena Gonzalez, City Council President; City Councilmembers; and Mr. Adrian Diaz, Chief of Police, Seattle, WA regarding reduced numbers of Seattle Harbor Patrol personnel
July 16 - Comments to CAPT Maureen Kallgren, U.S. Coast Guard Fifth District regarding Port Access Route Study: Approaches to the Chesapeake Bay, Virginia
July 14 - Comments to Ms. Lucinda Lessley, Acting Administrator, Maritime Administration, U.S. Department of Transportation opposing the application for a foreign-built motor barge for coastwise trading endorsement
June 30 - Comments to LTJG Katie Matha, U. S. Coast Guard, Thirteenth District regarding Waterways Analysis and Management System Study of the Columbia River Entrance
June 11 - Comments to LCDR Sarah Krolman, U.S. Coast Guard regarding the scoping process of the Programmatic Environmental Impact Statement for the Waterways Commerce Cutter program
June 2 - Memo to state and federal partners regarding ESHB 1578 Tug Escort Implementation Framing Safety Risk Management
May 25 - Comments to BG Peter D. Helmlinger, Commander, Northwestern Division, U.S Army Corps of Engineers regarding Draft Fort Peck Dam Test Flow Release Environmental Impact Statement
May 7 - Comments to Lieutenant General Scott A. Spellmon, Chief of Engineers, U.S. Army Corps of Engineers regarding WRDA 2020 Sec. 129 Implementation
April 30 - Comments to Ms. Bonnie Soriano, Chief, Freight Activity Branch, Transportation and Toxics Division, California Air Resources Board regarding Proposed Amendments to the Regulations to Reduce Emissions from Diesel Engines On Commercial Harbor Craft Operated Within California Waters and 24 Nautical
April 27 - Comments to Mr. Peterson Vollmann, Planner IV, City of Oakland Bureau of Planning regarding Draft Environmental Impact Report (EIR) for the Oakland Waterfront Ballpark District Project
April 14 - Comments to General Stephen R. Lyons, Commander, United States Transportation Command regarding acquisition policy for coastwise/noncontiguous vessel carriage of Dept. of Defense cargoes
March 15 - Comments to The Honorable Pete Buttigieg, Secretary, U.S. Department of Transportation regarding Washington Department of Transportation’s application for 2021 INFRA federal discretionary grant funding for the Salmon Bay Bridge Rehabilitation Project
March 9 - Comments to LT David Lieberman, Office of Navigation Systems, U.S. Coast Guard regarding Shallow Draft Waterways Analysis and Management System Study
February 22 - Comments to Ms. Christine Kluge, Department of Fish and Wildlife, Office of Spill Prevention and Response regarding Notice of Proposed Rulemaking: Non-tank Vessel Fee Increase
February 5 - Comments to Mr. Ryan Johnson, U.S. Army Corps of Engineers, Chicago District regarding USACE Scoping for Chicago Area Waterway System NEPA Document

2020 Comments, Letters and Testimony

December 11 - Comments to Ms. Christine Kluge, Department of Fish and Wildlife, Office of Spill Prevention and Response regarding Clarification of Convention (GT ITC) and Regulatory (GRT) Tonnage Measurement Systems to U.S. Flag Towing Vessels
December 11 - Comments to Mr. BJ Murray, Illinois Department of Transportation regarding the Draft 2020 Illinois Marine Transportation System Plan and Economic Analysis
November 24 - Comments to Mr. D. Lee Forsgren, Jr., Deputy Assistant Administrator, Office of Water, U.S. Environmental Protection Agency regarding Vessel Incidental Discharge National Standards of Performance
November 18 - Comments to BG Peter D. Helmlinger, Commander, Northwestern Division, U.S. Army Corps of Engineers regarding Missouri River Mainstem System 2020-2021 Draft Annual Operating Plan
November 9 - Comments to Mr. Eugene D. Hayes, Substance Abuse and Mental Health Services Administration, Center for Substance Abuse Prevention regarding Mandatory Guidelines for Federal Workplace Drug Testing
October 30 - Comments to Mr. David C. Quiros, Manager, Freight Technology Section, Transportation and Toxics Division regarding Proposed Amendments to the Commercial Harbor Craft Regulation in California
October 23 - Comments to Mr. Matthew A. Konfirst, Administrator, U.S. Environmental Protection Agency Mid-Atlantic Region regarding City of Annapolis and Anne Arundel County Vessel Sewage No-Discharge Zone
October 13 - Comments to ADM Karl L. Schultz, Commandant, U.S. Coast Guard regarding Integration of Automated and Autonomous Commercial Vessels and Vessel Technologies Into the Maritime Transportation System
September 14 - Comments to Ms. Christine Kluge, Department of Fish and Wildlife, Office of Spill Prevention and Response regarding Proposed Rulemaking to Adopt New Regulations for the Certification of Spill Management Teams and Amend Regulations for Contingency Plans
September 3 - Comments to the Committee on Equitable Allocation of Vaccine for the Novel Coronavirus, National Academy of Medicine, National Academies of Sciences, Engineering, and Medicine regarding the Discussion Draft of the Preliminary Framework for Equitable Allocation of COVID-19 Vaccine
August 20 - Comments to The Honorable Andrew R. Wheeler, Administrator, U.S. Environmental Protection Agency regarding Total Maximum Daily Load for Temperature in the Columbia and Lower Snake Rivers
August 18 - Comments to Rear Admiral Richard Timme, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding ANPRM for Shipping Safety Fairways Along the Atlantic Coast
August 17 - Comments to Colonel Aaron Reisinger, Commander, U.S. Army Corps of Engineers, Chicago District regarding Chicago Area Waterways System Dredged Material Management Plan
August 13 - Comments to The Honorable Andrew R. Wheeler, Administrator, U.S. Environmental Protection Agency regarding Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process
July 31 - Comments to VADM David Pekoske, Administrator, Transportation Security Administration regarding establishment of an online process to renew Transportation Worker Identification Credentials
July 7 - Comments to Mr. Jerry Barnes, U.S. Coast Guard Fifth District regarding Anchorage Ground; Cape Fear River Approach, North Carolina
July 6 - Comments to Mr. Jerry Barnes, U.S. Coast Guard Fifth District regarding Port Access Route Study: Seacoast of New Jersey Including Offshore Approaches to the Delaware Bay
July 6 - Comments to Mr. Damien Reinhart, Project Manager, Bureau of Reclamation, Dakotas Area Office regarding the Bureau of Reclamation’s Draft Environmental Impact Statement (DEIS) for the Eastern North Dakota Alternate Water Supply (ENDAWS) Project
June 11 - Comments to Mr. Dane Morris, Project Manager, U.S. Army Corps of Engineers regarding Draft Environmental Assessment for MRRP Chute Repairs and Modifications
May 29 - Testimony by Jennifer Carpenter, President & CEO before House Subcommittee on Coast Guard and Maritime Transportation
April 13 - Comments to BG D. Peter Helmlinger, P.E., U.S. Army Corps of Enginers; Ms. Lorri Gray, U.S. Department of Interior; and Mr. Elliot Mainzer, U.S. Department of Energy, regarding Columbia Snake River Operations Draft Environmental Impact Statement
March 16 – Comments to Ms. Denise Koch, Alaska Department of Environmental Conservation, regarding Oil Discharge Prevention and Contingency Plan Public Scoping
March 16 - Comments to Rear Admiral Andrew Tiongson, Commander, U.S. Coast Guard - First District, regarding Port Access Route Study in Areas Offshore Rhode Island and Massachusetts
March 3 - Comments to Rear Admiral Shepard M. Smith, Office of Coast Survey, National Oceanic and Atmospheric Administration, Sunsetting of Raster Nautical Charts Production
March 3 - Comments to Ms. Jannine Miller, Deputy Assistant Secretary for Policy, U.S. Department of Transportation, regarding National Freight Strategic Plan Request for Information
February 26 – Letter to The Honorable Elaine L. Chao, Secretary, U.S. Department of Transportation regarding support of the Seattle Department of Transportation’s (SDOT) Infrastructure for Rebuilding America
February 21 – Letter to The Honorable Elaine L. Chao, Secretary, U.S. Department of Transportation regarding Washington State Department of Transportation’s Infrastructure for Rebuilding America grant application for the Puget Sound Gateway Program
February 10 – Comments to Mr. Craig Kenworthy, Executive Director, Puget Sound Clean Air Agency, regarding the Puget Sound Clean Air Agency’s (PSCAA) draft Regional Clean Fuel Standard
January 31 - Comments to Ms. Thareth Casey, Project Manager, U.S. Army Corps of Engineers regarding Draft Pelican Bend Interception Rearing Complex
January 28 - Comments to Mr. Jerry Barnes, U.S. Coast Guard Fifth District, regarding Anchorage Grounds; Delaware Bay and Atlantic Ocean, Delaware
January 27 - Comments to Mr. Jerry Barnes, U.S. Coast Guard Fifth District, regarding Port Access Route Study: Approaches to the Chesapeake Bay, Virginia

2019 Comments, Letters and Testimony

December 18 - Comments to Mr. Barry A. Thom, West Coast Regional Administrator, National Marine Fisheries Services, National Oceanic and Atmospheric Administration regarding Proposed Revision to the Critical Habitat Designation for the Southern Resident Killer Whale Distinct Population Segment
December 2 - Comments to Mark H. Buzby, Administrator, Maritime Administration, U.S. Department of Transportation regarding proposed renewal of the Voluntary Tanker Agreement Program
November 22 - Comments to BG Peter D. Helmlinger, Commander, Northwestern Division, U.S. Army Corps of Engineers regarding the Missouri River Mainstem System 2019-2020 Draft Annual Operating Plan
November 20 - Comments to U.S. Customs and Border Protection Office of Trade, Regulations and Rulings regarding Proposed Modification and Revocation of Ruling Letters Relating to CBP’s Application of the Jones Act to the Transportation of Certain Merchandise and Equipment between Coastwise Points
November 18 - Comments to RDML Richard V. Timme, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding Crediting Recent Sea Service of Personnel Serving on Vessels of the Uniformed Services
November 12 - Comments to Mr. Derrick J. Croinex, Chief, Spectrum Management and Telecommunication, U.S. Coast Guard regarding Proposed Termination of U.S. Coast Guard Medium Frequency (MF) Broadcast of Navigational Telex (NAVTEX) and Shift to Satellite
November 8 – Comments to Mr. Peterson Vollmann, Planner IV, City of Oakland Bureau of Planning, regarding the draft environmental impact report for the proposed Downtown Oakland Specific Plan
November 8 – Comments to the City of Oakland, regarding Downtown Oakland Specific Plan Public Review Draft
November 4 - Comments to Mr. Michael Emerson, Director, Marine Transportation Systems, United States Coast Guard regarding Use of Electronic Charts and Publications in Lieu of Paper Charts, Maps and Publications
October 28 - Comments to Chairman Peter DeFazio and Ranking Member Sam Graves, House Transportation and Infrastructure Committee and Chairwoman Grace Napolitano and Ranking Member Bruce Westerman, Subcommittee on Water Resources and the Environment regarding H.R. 2440, the Full Utilization of the Harbor Maintenance Trust Fund Act
October 21 - Comments to Andrew R. Wheeler, Administrator, U.S. Environmental Protection Agency regarding Tier 4 standards
October 8 - Comments to RDML Richard V. Timme, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding Person in Charge of Fuel Transfers
September 17 - Comments to the Maritime Administration, U.S. Department of Transportation regarding Centers of Excellence for Domestic Maritime Workforce Training and Education
September 10 – Comments to Ms. Kate Gordon, Director, Office of Planning and Research for the State of California, regarding the Supplemental Application by the Oakland A’s proposed project at Howard Terminal in the Port of Oakland
August 30 - Comments to RADM Matthew T. Bell Commander, Seventeenth District, U.S. Coast Guard, regarding Port Access Route Study: Alaskan Arctic Coast
August 21 - Comments to Mr. D. Lee Forsgren, Jr., Deputy Assistant Administrator, Office of Water, Environmental Protection Agency and CAPT Sean Brady, Chief, Office of Operating and Environmental Standards, U.S. Coast Guard regarding AWO Recommendations for Draft Regulations to Implement the Vessel Incidental Discharge Act
April 12 - Responses by Tom Allegretti, President & CEO, to written questions submitted by Senator Maria Cantwell for the Record of the March 6 Senate Commerce Committee hearing
April 5 - Responses by Tom Allegretti, President & CEO, to written questions submitted by Senator Roger Wicker for the Record of the March 6 Senate Commerce Committee hearing
April 5 - Responses by Jennifer Carpenter, Executive Vice President & COO, to written questions submitted by Rep. Peter DeFazio for the Record of the March 6 House Subcommittee on Coast Guard and Maritime Transportation hearing
March 6 - Testimony by Jennifer Carpenter, Executive Vice President & COO before the House Subcommittee on Coast Guard and Maritime Transportation
March 6 - Testimony by Tom Allegretti, President & CEO before the Senate Commerce Committee
February 22 - Comments to Mr. Dennis W. Hamilton Deputy, Programs and Project Management U.S. Army Corps of Engineers regarding the Brandon Road Recommended Plan
February 13 - Comments to Mr. Jeffrey G. Lantz Director, Commercial Regulations and Standards, U.S. Coast Guard, regarding the Coast Guard’s Draft Merchant Mariner Medical Manual.
February 1 - Amicus Brief in The Dutra Group v. Batterton, Jones Act Case before the Supreme Court.
January 31 - Testimony by Charles Costanzo, Vice President – Pacific Region before the Washington Senate Environment, Energy & Technology Committee on SB 5578. Video here.
January 14 - Comments to Mr. Peterson Vollmann, Planner IV, City of Oakland Bureau of Planning, regarding the City of Oakland's Environmental Impact Report for the potential Oakland Waterfront Ballpark District Project.

2018 Comments

November 13 - Comments to Mr. John Goodin, Acting Director, Office of Wetlands, Environmental Protection Agency, regarding establishing No-Discharge Zones
November 9 - Comments to BG Peter Helmlinger, Northwestern Division Manager, U.S. Army Corps of Engineers, regarding the Missouri River Recovery Management Plan Final Environmental Impact Statement
November 1 - Comments to Mr. Kenneth D. Allen Contracting Officer, Strategic Sealift Program Support Office Military Sealift Command Norfolk regarding a proposal to change the threshold for repair maintenance work for companies to receive a preference in contracting.
October 2 - Comments to Mr. Kenneth D. Allen, Contracting Officer, Strategic Sealift Program Support Office Military Sealift Command Norfolk regarding a proposal to change the threshold for repair maintenance work for companies to receive a preference in contracting.
September 26 – Stakeholder letter to the Elected Leadership Group, Cathal Ridge, Central Corridor Director, regarding Sound Transit 3 alignment through Interbay and Ballard
August 24 - Comments to Ms. Neomi Rao, Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget regarding regulatory reform request for information.
July 30 - Comments to Office of Renewable Energy Programs regarding proposed Wind Energy Areas within the New York Bight region
July 23 - Comments to CAPT Ryan Manning, Chief, Office of Port & Facility Compliance regarding TWIC reader rule partial delay
June 8 - Comments to Mr. Jeffrey Lantz, Director of Commerical Regulations and Standards, U.S. Coast Guard, Regarding the Ballast Water Management Annual Reporting Requirement
April 30 - Comments to U.S. Coast Guard regarding changes made to the Regulated Navigation Area on the Chicago Sanitary and Ship Canal
March 26 - Comments to Mr. Jonathan Smith, Office of Marine Environmental Response, U.S. Coast Guard, Regarding the 2016.1 National Preparedness for Response Exercise Program (PREP) Guidelines

2017 Comments

December 8 - Comments to Mr. Dennis Hamilton, Deputy for Programs and Project Management, U.S. Army Corps of Engineers, Regarding the Great Lakes and Mississippi River Interbasin Study (GLMRIS) Brandon Road Tentatively Selected Plan (TSP)
November 16 - Comments to MG Scott Spellmon, Commander, Northwestern Division, U.S. Army Corps of Engineers, Regarding the Draft Missouri River Mainstem System 2017-2018 Annual Operating Plan
September 11 - Comments Mr. Jeffrey Lantz, Director of Commercial Regulations and Standards, U.S. Coast Guard, Regarding Random Audits Under Subchapter M, Supplemental to Comprehensive Recommendations for Regulatory Reform
July 26 - Comments to Mr. Jeffrey Lantz, Director of Commercial Regulations and Standards, U.S. Coast Guard, Regarding Comprehensive Recommendations for Regulatory Reform
July 5 - Comments to Secretary Rachel Dickon regarding the FMC’s regulatory reform initiative (Docket No. 17-04)
May 15 - Comments to Ms. Samantha Dravis, Office of Policy, U.S. Environmental Protection Agency, Regarding the Evaluation of Exisiting Regulations (Docket No. EPA-HQ-OA-2017-0190)
April 24 - Comments to MG Scott Spellmon, Commander, Northwestern Division, U.S. Army Corps of Engineers, Regarding the Missouri River Recovery Management Plan Draft Environmental Impact Statement
April 13 - Comments to Lynne Barre, National Marine Fisheries Service, Regarding San Juan Islands Whale Protection Zone
March 14 - Comments to Mr. Mark Lahare, U.S. Army Corps of Engineers Regarding the Inner Harbor Navigation Canal Lock Replacement Draft GRR/SEIS

2016 Comments

September 23 - Comments to Captain Joseph B. Loring, Chief, Office of Marine Environmental Response Policy Regarding Draft Updates to Alternative Planning Criteria (APC) National Guidelines
September 13 - Comments to U.S. Coast Guard on Draft Revisions to the Marine Safety Manual, Volume 3, Parts B and C, Change 2
July 8 - Comments to Mr. Rian Hooff, Oregon Department of Environmental Quality Regarding Follow-Up Questions About the Proposed Changes to State Ballast Water Regulations
June 6 - Comments to CAPT Richard Timme, Commander, Sector Ohio Valley Regarding the Sector Ohio Valley Annual and Recurring Safety Zones
May 24 - Comments to Mr. Rian Hooff, Oregon Department of Environmental Quality Regarding Proposed Changes to State Ballast Water Regulations
April 25 - Comments to the U.S. Department of Transportation Regarding the Draft National Freight Strategic Plan
April 13 - Comments to the U.S. Department of Transportation Regarding the Request for Comment on the ACPARS Final Report
January 25 - Comments to the Bureau of Ocean Energy Management Regarding Commercial Leasing for Wind Power on the Outer Continental Shelf Offshore South Carolina
January 22 - Comments to the State of Washington Energy Facility Site Evaluation Council Regarding the Vancouver Energy Draft Environment Impact Statement (DEIS)

2016 Letters

May 17 - Letter to RADM Linda Fagan, Commander, First Coast Guard District, Regarding the Proposal to Construct the Champlain Hudson Power Express (CHPE) Transmission System
April 23 - Letter to RADM Linda Fagan, Commander, First Coast Guard District Regarding Hudson River Anchorage Areas
April 5 - Letter to the Seattle City Council Regarding Plans to Give Away the Public Right-of-Way for Occidental Avenue South

2015 Comments

December 28 - Comments to the Bureau of Ocean Energy Management Regarding the Request for Information on the State of the Offshore Renewable Energy Industry.
November 20 - Comments to the U.S. Army Corps of Engineers Northwest Dision Regarding the Draft Missouri River Mainstem System 2015-2016 Annual Operating Plan
October 19 - Comments to the Docket Management Facility (M3) USDOT Regarding Navigation Area: Ice-Covered Waterways in Fifth Coast Guard District
October 15 - Comments to the Seattle Department of Transportation Regarding Potential Changes to Lake Washington Ship Canal Bridges' Opening Restrictions
September 8 - Comments to the Federal Energy Regulatory Commission on the Notice of Preliminary Permit Application for the Mississippi Rover Lock and Dam 14 Hydropower Project
August 17 - Comments to the Marine Invasive Species Program on the Proposed Modifications to Article 4.8 - Biofouling Management to Minimize the Transfer of Nonindigenous Species from Vessels Operating in California
June 16 - Comments to the Marine Invasive Species Program on Biofouling Management to Minimize the Transfer of Nonindigenous Species from Vessels Operating in California Waters
June 3 - Comments on to the U.S. Coast Guard on the Port Access Route Study in the Chukchi Sea, Bering Strait, and Bering Sea.
April 15 - Comments to the U.S. Department of Transportation on Guidance on Maritime Cybersecurity Standards
February 27 - Comments to the U.S. Department of Transportation on the Seafarers' Access to Maritime Facilities
February 23 - Comments to the Bureau of Ocean Energy Management on Environmental Assessment for Commercial Wind Lease Insurance and Site Assessment Activities
February 19 - Comments to the Federal Energy Regulatory Commission on the Environmental Assessment for the Newburgh Hydroelectric Project
February 18 - Comments to the U.S. Army Corps of Engineers on Supplemental Environmental Impact Statement for the Inner Harbor Navigation Canal Lock Replacement Project
January 30 - Comments to U.S. Army Corps of Engineers on Proposed GLMRIS Project at Brandon Road Lock and Dam
January 23 - Comments to U.S. Army Corps of Engineers on Upper St. Anthony Falls Lock Closure

2015 Letters

December 18 - Letter to the Assistant Secretary of the Army-Civil Works, Jo-Ellen Darcy, Regarding Congressional Opposition to Proposed Changes to the Missouri Water Control Plan

2015 Testimony

February 4 - Testimony before the Subcommittee on Oceans, Atmosphere, Fisheries and Coast guard Committee on Commerce, Science and Transportation

2015 Memorandum

Memorandum signed by District 8 and District 9 regarding the enforcement of fire extinguisher brackets on Western River Tank Barges
Memorandum regarding the Hudson River Anchorage Grounds

2014 Comments

October 8 - Comments to the U.S. Coast Guard on the Regulated Navigation Area; Lake Michigan, Chicago Harbor Lock
September 19 - Comments to the Bureau of Ocean Energy Management on Commercial Leasing for Wind Power on the Outer Continental Shelf
September 15 - Comments to the U.S. Army Corps of Engineers on the Champlain Hudson Power Express Transmission Project Environmental Impact Statement
August 29 - Comments to the U.S. Coast Guard on IMO Polar Code
August 25 - Comments to the U.S. Coast Guard on its Petition to Establish a Special Load Line Exemption for Lake Michigan
August 15 - Comments to California State Land Commission on Draft Biofouling Management Regulations
July 14 - Comments to the U.S. Coast Guard on its Workplace Safety and Health for Merchant MarinersPetition
June 16 - Comments to U.S. Coast Guard on Proposed Arthur Kill Waterway Regulated Navigation Area
May 14 - Comments to U.S. Coast Guard on Draft Revisions to the Marine Safety Manual, Volume 3, Chapters 20-26
April 21 - Comments to Washington State Department of Ecology on Draft Petition to EPA to Declare Puget Sound a No Discharge Zone
March 31 - Comments to U.S. Army Corps of Engineers on the Great Lakes and Mississippi River Interbasin Study (GLMRIS) Report
February 18 - Comments to U.S. Bureau of Ocean Energy Management on Notice of Commercial Leasing for Wind Power in the Maryland Wind Energy Area
February 13 - Comments to the U.S. Department of Transportation Regarding Cargo Securing Manuals
February 7 - Comments to Chicago Department of Public Health on Proposed Regulations for Handling and Storage of Bulk Material Piles
February 7 - AWO Comments City Petcoke

2014 Letters

June 20 - Letter to U.S. Senate Commerce Committee leadership on S. 2094
May 15 - Letter to Illinois Attorney General on HB 5939

2014 Testimony

March 25 & 31 - Testimony before Tennessee House and Senate on SB 2076 and HB 1769
March 4 - Testimony before the U.S. House Subcommittee on Coast Guard and Maritime Transportation on Need for Ballast Water Regulation

2013 Comments

Comments to the U.S. Department of Transportation on the Ballast Water Management Reporting and Recordkeeping