Validation of Merchant Mariners' Vital Information and Issuance of Coast Guard Merchant Mariner's License and Certificates of Registry
2006-03-09 2006-03-10 2006-03-10 2006-03-09 2006-03-15 2006-03-20 2006-03-21 2006-03-27 2006-03-27 2006-02-01
USCG-2004-17455-0114 USCG-2004-17455-0118 USCG-2004-17455-0119 USCG-2004-17455-0111 USCG-2004-17455-0145 USCG-2004-17455-0159 USCG-2004-17455-0165 USCG-2004-17455-0171 USCG-2004-17455-0172 USCG-2004-17455-0023
05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00 05:00:00
https://api.regulations.gov/v4/comments/USCG-2004-17455-0114 https://api.regulations.gov/v4/comments/USCG-2004-17455-0118 https://api.regulations.gov/v4/comments/USCG-2004-17455-0119 https://api.regulations.gov/v4/comments/USCG-2004-17455-0111 https://api.regulations.gov/v4/comments/USCG-2004-17455-0145 https://api.regulations.gov/v4/comments/USCG-2004-17455-0159 https://api.regulations.gov/v4/comments/USCG-2004-17455-0165 https://api.regulations.gov/v4/comments/USCG-2004-17455-0171 https://api.regulations.gov/v4/comments/USCG-2004-17455-0172 https://api.regulations.gov/v4/comments/USCG-2004-17455-0023
Michael Don Kenneth Charles Mark Douglas Timothy Joni David Roy
Radtke Weymiller Graybill iii. Cross Condon Bisdorf Cherry Brooks Strzok Beasley
As President of the Great Lakes Passenger Boat Association I represent our twenty, Tour and Ferry operators.  Our membership is extremely concerned about the impact and burden imposed by the recent rule requiring mariners to report to a REC for identification verification and fingerprinting.  GLPBA members employ over 130 USCG licensed personnel.  Many of these employees live over a days drive time from Toledo, OH or St. Louis, MO the closest RECs (licensed personnel from two members would have a 1600 mile round trip to Toldeo).  The cost of mileage, lodging, meals and time away from work is an unacceptable burden on businesses and their employees.In these rules there seems to be little if any consideration for efficiency. Does it make sense to have hundreds of people per year traveling hundreds of miles for a procedure that takes 20 minutes to perform.  Is it possible for mariners to be IDd and electronically finger printed at a local MSU?  or could a memorandum of agreement  be arranged with a partner agency within the Dept. of Homeland Security, allowing them to check IDs and electronically scan fingerprints for the REC?  One size does not fit all and some creative problem solving could resolve this issue as a win-win for the USCG REC and the mariner.Our members businesses and their licensed personnel would appreciate your serious consideration of this issue.Sincerely,Mike RadtkePresident, Great Lakes Passenger Boat AssociationMarine Operations Manager, USCG 100 ton MasterMadeline Island Ferry LineLaPointe, WI 54850 Please hold up on rule making untill you get more input from the river people March 8, 2006To whom it may concern,I would like to express my concerns regarding the extra time and expense for mariners, such as myself to travel at least twice to my local R.E.C. for any future license renewals. The new rule proposed would require one trip for finger printing and a second to obtain documents in person. This rule will place a daunting burden on mariners that do not live close to their respective R.E.C.s  Not all mariners are home for months at a time.  Crew rotations vary from (day on / day off) to (two months on / one month off) in most limited tonnage fleets. Traveling 450 miles or more, one-way is next to impossible for some licensees without taking unscheduled absences from their rotations. Travel, lodging, food, pay loss and document expenses will burden some of these salaries. It seems incomprehensible to me that a mariner can renew their United States Passport via the United States Postal Service but, the United States Coast Guard can not accept this procedure because of reasons that are unclear or overbearing.  Our pictures and fingerprints are recorded in our files from the procurement of our first document. A quick look into our jacket could reveal whether the face in the picture, matched with the fingerprints are the applicants. The State Department can do this after ten years. Five years should not require more training. This would take minimal effort compared to two personal appearances by every mariner from G.V.A.s to Masters.  Our R.E.C.s have not shown that they can handle the extra traffic! It takes two months to get your documents back for one appearance now. Will it take four or more for two?In closing, our time home is being consumed more and more by regulatory procedures, training and employee shortfalls. Our younger generation coming into the workforce will not put up with all this bureaucracy and workload. Time home and pay are the only real attributes that keep this workforce in place now.  This new rule will only drive the United States Merchant Mariner another step closer to extinction.  The United States Coast Guard should be encouraging the renewal of documents and experienced labor not driving them away.Thank you for the chance to express my concerns.Regards,Captain Kenneth C. Graybill III Requiring mariners to travel to a REC for fingerprinting and ID check when renewing documents and licenses is an excessive burden to the mariner.With recent changes to regulations and requirements to keep licenses current, it has become a significant burden just to keep a license at all.I currently hold a Master Oceans to 1600/3000 and have been licensed for over 25 years. Due to the extreme expense and burden of recent changes, i.e. STCW, MMDs, I am only able to use my license to the 100 ton level.   Now you are adding considerably more expense to retaining the license. At the current rate of increase in the burden of retaining and maintaining my license, I will have to seek an alternative career.  As a merchant seaman for all my adult life, and too old to start over, I find this additional burden quite unacceptable. I am writing regarding the recent interim rule published on January 13, 2006 regarding new identification procedures required for mariners.I am a recently qualified Coast Guard Masters applicant.  As part of the application process, I submit two fingerprint identification cards along with my application.  Unfortunately, I had no idea the rules were going to be changed and I mailed my application on January 13 and it was not received by the Toledo REC until two days later.The finger prints with my application were taken at the Police Department in the city of Edina, MN.  I am a resident of Edina and they would only do fingerprints for residents.  They require proof of identification via a picture ID.  Under the new interim rule, I am required to go to Toledo and present to them a valid picture identification and either a birth certificate or valid passport.Requiring people to go to a regional examination center seems burdensome and a significant additional expense.  I dont think I can fly to Toledo from Minneapolis and back in one day.I understand the need for additional security requirements in the post 9/11 era but there are a lot of ways to achieve the same purpose without the additional burden.  A few of those alternatives are as follows:1.There are numerous federal law enforcement offices throughout the country, such as the FBI, US Marshalls Office, Immigration authorities, etc.2.There are numerous Coast Guard offices that can be used instead of the RECs.3.The fingerprinting entity could require the same identification as the Coast Guard, i.e. a valid picture drivers license and a valid passport or birth certificate.Understanding the need for additional security, I would ask that you balance that need with the cost and burden of severely limiting where a person can be fingerprinted.I should also point out that most, if not all, of the people in my testing group were lucky enough to get their applications in before the unknown date of January 13, 2006 and do not have the extra burden and cost of going to Toledo.Thank you for your consideration. To whom it may concern,I am the Captain-in-Charge of the ferry boat the MV Sugar Islander II.  She is a 24 car passenger vessel that shuttles between Sault Ste. Marie, MI and Sugar Island, MI.  We have 10 men that hold their 100 Gross Ton PCV Masters ticket.The matter of fingerprinting for every transaction regarding our licenses has been brought to my attention.In these uncertain days I can certainly understand the need for due diligence regarding licensing procedures for anyone who has control of a vessel the size of the Sugar Islander II and the hundreds of souls it carries on a daily basis, 365 days a year.On the other hand, this fingerprinting/ID mandate, I feel, could be handled in several simpler ways that would be much less costly to the licensee and at the same time be just as effective.For us, here in Sault Ste. Marie, to travel all the way to Toledo for simple fingerprinting every time we wish to upgrade or even simply renew our licenses, would be costly and frankly just a plain old nuisance.  It would involve two days of driving, loss of wages, motel expenses, etc.In my instance, I earned my license in 1981.  I understand the need for the Dept. of Homeland Security to keep a tight rein on people in our profession.  However, after twenty seven (plus) years, I will not, suddenly, become a terrorist or any threat to Homeland Security.  To make that kind of journey in question is simply a case of overkill.I have no problem having my fingerprints in your database, I just believe there are far simpler and less costly (to the mariner) ways to accomplish this.  Whether it be by being printed by local law enforcement, the closest Michigan State Police post, or even the nearest U.S. Coast Guard base---all would be acceptable.  But a 400+ mile trip to Toledo is, as I said, overkill.Surely there is a FAR better solution to getting Mariners fingerprints on file than this complicated, costly solution that has been proposed.Thank you for your time and the opportunity to respond.Sincerely,Douglas M. BisdorfCaptain-in-Charge I am submitting comments in regard to docket ID USCG-2004-17455, Validation of Merchant Mariners Vital Information.  I have problems with your proposed rule change requiring a licensed mariner to appear in person at a USCG REC for license renewal or upgrades.  I understand that heightened security measures are needed, especially post 9/11, but this new requirement of appearing in person at one of the limited REC locations after original license issuance is unnecessary and unreasonable.  The region I am employed as a mariner is the Great Lakes and travel to and from REC Toledo can easily take more than one day.  This new requirement is not just inconvenient, but can also be a costly burden placed on us mariners.  Since the CG License is not used as a picture identification it is unclear what this new requirement is actually solving in the field.  If you are trying to head in this direction for security purposes then look into a major regulatory change and marry up the documentation and licensing processes and streamline the whole bureaucracy.  Actual compliance in the field under the current system is still working with a piece of paper as a license with just a name on it, no picture or other biometrics.  In the field compliance is not there yet to tie this license to whoever is holding it in the field with whatever fake ID they may have if they are actually a terrorist trying to sail under a fraudulent license.  At this time forcing us mariners to show up in person at the REC for renewal or upgrade doesnt really solve the field compliance issue.  In closing, if this requirement goes forward and you feel the need to have an independent verification of the mariners identification and fingerprint, after the original issuance, than leverage other local agencies or provide more locations for mariners to get the process completed.  Your plan to use just the 17 USCG RECs is unsatisfactory.  Also, dont tie this identification and fingerprinting visit it into the rigid renewal and upgrade administrative process within the specific REC.  Work in flexibility for this piece of the process and allow walk up service at any REC at the mariners convenience.  Also let them walk up at any time during the renewal period.  You already have the original information in the computer system.  The goal is to re-verify the mariners identification and fingerprints for the action on the license.  Let the rest of the REC administrative process to evaluate expertise, character, and fitness for duty stay in the established rigid cycle.  I urge you to not place additional bureaucratic and costly blocks to a mariners livelihood. I am writing to voice my concern about the electronic fingerprinting requirement.  If this requirement passes, it will cause considerable undo harm in the renewal process of my 100-ton great lakes master license this fall.  The two closest REC are 2-1/2 days of wages plus expenses.  There is an electronic device 200 miles away in Minneapolis at the US Marshall Service.  That federal agency is located in a one-days time for me and my 12 fellow daptains.  I hope something reasonable can be worked out.  Thank you.  Joni Brooks  Our four captains are characteristically present at each annual vessel inspection. For each of them in turn to travel to either St. Louis or Toledo amounts to two days of travel time, a hundred dollars for fuel, overnight accommodations. We knowo our USCG marine inspectors and vice versa. Wouldnt this waste of energy and resources be better served using personnel in place? The local MIO. Its far more cost-efficient to send electronic equipment to user sites than to send people.   I do not believe there is a need for somebody to have to appear in person at a REC to check their ID and fingerprints.  I think the Coast Guard should document how many cases they know of where they received incorrect fingerprints, or issued a license to someone other than the person who should have received it.  I think the requirements they used in the past should be sufficient without putting an undue travel burden on applicants who live a long way from a regional exam center.