So, it would appear that maybe when the volume gets turned up loud enough the Coast Guard IS able to respond in some fashion. Below, in italics, is a response to the Monday post sent to us yesterday via Mr. Ronald LaBrec, the Coast Guard’s Chief of Public Affairs. The post is written by Mr. Jeffrey Lantz, the Coast Guard’s Director of Commercial Regulations and Standards. Presumably this means that we’re getting it straight from the horse’s mouth. For the record, we at the MTVA are glad to see that there is finally an official and public acknowledgement of the fact that traditional licenses are, to quote from the post, an “important issue for many mariners”, including the Coast Guard personnel that are themselves licensed. Judging by the big spike in readership on Monday, about double the norm for us, we can conclude that this isn’t something that will go away on its own.
So read the post. I’ll respond with more commentary in a separate post, but leave you with this parting thought: If the Coast Guard was truly serious about working with mariners and addressing this issue to everyone’s satisfaction (simultaneously or separately, sooner or later) shouldn’t the information below have been incorporated into the text of the final rule in the Federal Register? As published, it offers no credible suggestion or assurance that the Coast Guard was seriously considering anything but getting rid of the traditional license for good.
Merchant Mariner Credentials and Licenses
Yesterday, 16 March 2009, the Coast Guard promulgated the Final Rule titled Consolidation of Merchant Mariner Qualification Credentials, commonly referred to the MMC Rule. Through this rulemaking multiple merchant mariner qualification documents will be consolidated into one credential, which is significantly different than the current version. Instead of one or several large certificates that resemble a diploma, the MMC resembles a passport. The Coast Guard did this for many reasons, including ease for mariners to maintain and provide proof of all qualifications and to meet international standards.
However the old licenses are quite impressive and suitable for framing and some mariners are suggesting the Coast Guard continue to also issue them for sentimental, historical and traditional reasons.
The Coast Guard considered whether or not to continue issuing the current certificates; not for proof of qualifications but for sentimental and traditional reasons. The Coast Guard asked the Merchant Personnel Advisory Committee (MERPAC) to consider the alternatives for MMC format. MERPAC recommended that the MMC be a booklet similar in size and design to a U.S. passport. MERPAC also recognized that the current form of license has traditional and sentimental value to many mariners, and recommended that a “suitable for framing copy of the license” remain an option that a mariner can choose to obtain for a nominal fee.
There are numerous factors to consider in deciding whether or not to also provide a “suitable for framing copy of the license.” These include the availability of Coast Guard resources, including personnel, paper stock, hardware, software and equipment, and the process for determining and collecting fees. And as a rulemaking process matter, since this traditional document would not be considered a required or a valid credential, we would need to address other administrative and legal issues that go beyond the Merchant Mariner Qualification Credentials final rule.
However, we know this is an important issue to many mariners. Traditional Coast Guard licenses also proudly adorn the walls of the Coast Guardsmen who have earned them nationwide. The Coast Guard continues to look at this issue from all angles and today’s MMC Rule does not preclude a “suitable for framing copy of the license” at a later date provided all administrative and legal issues are addressed. What the rule does do is provide for a single easily issued, maintained and updated credential aligned with international standards to certify the qualifications of the holder.
I appreciate the opportunity to provide this information to your readers and your continued sharing of information relevant to the professional mariner and Coast Guard operations.
Jeffrey Lantz Coast Guard Director of Commercial Regulations and Standards
This is an official U.S Coast Guard posting for the public’s information. Our posting does not endorse this site or anything on it, including links to other sites, and we disclaim responsibility and liability for its contents.
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