MarEx Readers Continue to Provide Input on Proposed Dismantling of Coast Guard

By MarEx 2012-12-18 15:01:00

Two weeks ago, a MarEx editorial (“Shortsighted Proposal to Break up Coast Guard, if Implemented, Will Not Serve Greater Good”) addressed the (growing) possibility that coming legislation could alter the substance of the U.S. Coast Guard, what it does and possibly divert certain responsibilities to other agencies. In some areas, the process has already begun. Our position was that this was not a good idea. Many readers have chided our managing editor for this position; others defend the current makeup of this nation’s fifth uniformed branch. The mail continues to pour in from a wide range of viewpoints; all of them qualified to speak on the subject. Once again, we’ve published a few more of these letters for your inspection.

Some compelling arguments were presented in this week’s batch of letters. We’ve added some editorial remarks at the end of each. One thing remains clear: the matter is not going away and there are real efforts currently underway in Washington to move the proposal forward. As that happens, here’s what some of our readers had to say:

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Mr Keefe,

As a member of the US Mechant Marine, and a Practicing Unlimited tonnage Master Mariner, I would like to voice my disagreement with your position on the move to reorganize the US Coast Guard. The Coast Guard multiple missions of Marine Inspections, Mariner Credentialing, Aids to Navigation, and Investigations represent a heinous conflict of interest. While many of us believe the officers of the CG to be individuals of excellent integrity, how can they possibly investigate accidents objectively if the cause of the incident was a poorly inspected vessel, poorly trained or improperly credentialled mariner, an out of position aid to Navigation, or any combination thereof.

The CG excels at Rescue, and Maritime Law enforcement and security and should stick to these primary missions. Aids to Navigation could be done more effectively and more cheaply by US Flag vessels with crews a fraction of the size. The capacity exists now.

Accident investigations should be handled by the NTSB or any other third party. Having investigations handled by a primary stakeholder taints each and every investigation. Simply compare results of CG investigations to concurrent NTSB investigations and note if they arrive at similar conclusions, you will find that they don’t.

There is a broad consensus among US Mariners regarding the CG's role in the credentialing process. The level of expertise and service has declined steadily for the last 20 or more years. We pay more, wait longer, and have more problems every year.

Inspections have also been on the decline. The CG Has been been farming out more and more of their inspectional responsibilities to ABS, which also represents a conflict of interest, as ABS is not a neutral third party, but a potential vendor of services. This is the same relationship that Enron and their Auditors had with disasterous results.

I dont know why you believe that the CG should to be overburdened with so many diverse missions, but I urge you to evaluate the issue more closely before taking a position.

Best Regards, (Name withheld)

MarEx Note: The writer brings up some excellent points regarding the continued “farming out” of certain oversight activity that was formerly done by actual Coast Guard personnel and also broaches the issue of possible conflicts of interest in those relationships. The arguments are not new ones, but they remain, to a large extent, unanswered.

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I read the other comments, especially that from Captain Hoppe. I have a lot of sympathy for Captain Hoppe’s opinion and actually share significant aspects of it. What the Coast Guard has done with the merchant marine licensing program is a disgrace. It is also, however, another example of a necessary function that was bastardized in the pursuit of cost cutting. It is cheaper to have clerks administer multiple guess exams than to have experienced mariners or watermen/women (the vast majority of licenses are not for blue water mariners anymore) make the more valid but more difficult subjective judgments of competency that used to be far closer to the norm. A more complete history of the bastardization of the licensing program is beyond the scope of this e-mail but it might be worth noting that it started back in the 1970s when the merchant marine safety program was staffed by the very kind of people who Captain Hoppe feel are better suited to this kind of work than modern Coasties.

The issue isn’t which agency does the work so much as it is a question of whether or not the agency doing the work has the resources necessary to do it right and is held accountable for doing it right. “Boxology” -- the drawing and re-drawing of organizational wiring diagrams -- is almost never an appropriate response to a dysfunctional government agency’s problems. Look at FEMA. FEMA has swung from one extreme (failure in Andrew) to another (FEMA’s performance in Hurricane Marilyn in St. Thomas, USVI was almost masterful) and back (failure in Katrina). The performance had little to do with organizational structure and far more to do with the FEMA leadership’s understanding of its mission, the resources available and the presence or absence of accountability for performance. But FEMA’s history also shows that, in a political environment where government is making more promises than it can afford to keep, resources and leadership attention will flow from problems that have not materialized in a while to the most recent big failure.

Again, the same thing happened in the Coast Guard with respect to vessel traffic management and oil spill prevention. These functions were downplayed until the EXXON VALDEZ incident, at which point they “got well” under the Oil Pollution Act of 1990. Now that it has been a while since a big ship-related oil spill, I can’t help but wonder how much capability in those areas has been lost as a result of newer priorities sucking up resources. My guess is a lot.

Don’t throw out the baby with the bath water. And don’t let the pendulum (i.e. resources and leadership attention) swing so widely between the extremes of malignant neglect and malignant attention.

If the Coast Guard has problems, and it does, then Congress should fix the Coast Guard.

Regards, (A Coast Guard Official - Name withheld)

MarEx Note: “Don’t throw the baby out with the bath water.” Indeed. Also under this category might go the saying, “Be careful what you wish for,” or “Don’t cut your nose off to spite your face.” A good question to ask here would be: Who is going to perform these duties when and if the Coast Guard is separated from the task? Who will be willing to step up at the pay scales available from the federal government and, more importantly, will they be any more qualified to perform these duties than the personnel that they replace?

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Dear Mr. Keefe,

Mind your Rudder, Shipmate.

After reading some of the many letters you received berating the US Coast Guard’s performance in the realm of marine safety and other mission areas, I am compelled to respond. First, as is the way of today’s maritime professionals, I must qualify my remarks with my pedigree (résumé). I am a commissioned Chief Warrant Officer (CWO3) Marine Safety Specialist with over 28 years of experience currently serving the nation as a senior marine inspector. I have been in such service for the past decade of my career. I earned my commission from the deck plates up as an enginemen and have a varied background ranging from years at sea on Coast Guard cutters, assignments at search and rescue (SAR) stations, shore based ship maintenance augmentation (marine engineering) teams, numerous maritime law enforcement and security details and last, but not in any way the least, several assignments in the Coast Guard’s Marine Safety program. In addition to my Coast Guard commission, I hold a Merchant Marine Officers License, 3rd Assistant Engineer, Unlimited Horsepower. While it is true that I have not yet served aboard what is left of the US flagged ocean going fleet, as a USCG inspector I have had the pleasure (and disgust) of inspecting hundreds, if not thousands, of ships, boats, yachts, barges, scows, tugs, fishing vessels, ferries, liners, tankers, freighters and so on, flying the US flag and the flags of a majority of the world’s seafaring nations. I have worked “on deck” with some of the worlds best and worst maritime professionals(?) I have witnessed first hand the very best, but more too often, the ragged underbelly of the maritime transportation industry.

I choose not to respond to any one contributor, but rather focus my comments based on my experiences in the Coast Guard to date and with the maritime community which I am currently charged to regulate on behalf of the public at large, weather they know, understand or appreciate my (our) efforts or not. The Coast Guard has in fact undergone many sweeping changes over the span of my career. The events of 9/11 have without a doubt set the table for the most sweeping changes that have yet to be fully realized. As previously documented the Coast Guard is faced with many challenges including increased maritime security responsibilities, re-capitalization procurement projects (Deepwater), internal re-organization to meet mission responsibilities and responses to national needs such as the war in Iraq (yes, we have ship’s and shipmates in harms way) and natural disasters (Hurricane Katrina was a terrible tragedy, but was only one of many calls we answered that year). We are certainly stretched a bit thin to say the least. We do make mistakes. We are human. But we do not run from our failures. We do not bury our shortcomings in the “in boxes” of bureaucrats. We face them, head on and do our best. That is what the public demands. From my perspective, that is what our Coast Guard is moving forward with at this very hour.

I do share many of the concerns that industry and your readers have expressed with regard to the regulation of the US maritime industry. I understand the frustration caused by laborious bureaucratic processes to obtain mariner credentials and vessel documentation, and the inconsistency of the US vessel inspection program. I too am directly affected by the difficulties that impact the mariner. But there are two sides to that coin. As an inspector in the field, I am often faced with daunting task of verifying compliance with the volumes of laws, regulations, policies, memos, and opinions that the maritime industry must demonstrate to the satisfaction of the administration. Shipboard lifesaving and firefighting equipment, navigation safety equipment, environmental protection, dangerous cargo containment and carriage, complex marine engineering mechanical and electrical systems code compliance, crew training and preparedness, passenger safety, operational requirements and on and on. The rules are so varied and so complex it is no wonder there are inconsistencies in their application and interpretation. That is not an excuse. It is reality. Coast Guard inspectors sometimes make mistakes. However from my view point, one of the most glaring inconsistencies is how these rules are applied and observed by industry. I have interviewed countless ship captains and engineer’s who are at best only vaguely familiar with the myriad of duties and responsibilities spelled out in the laws and regulations. These industry professionals are so focused on the daily execution of their assigned duties that on occasion they fail to do their homework. They are often ignorant to the operational and technical regulations that govern their industry. They in fact have come to rely on the USGC to provide them the answers in the form of merchant marine inspection requirements documented after grueling inspections instead of doing the work in the books before hand and mastering the rules of their trade. This compounds “the Coast Guard is the problem, not me” attitude that often prevails in industry. Shipping management’s concern with regulatory compliance is often overshadowed by the overwhelming concept that “Cargo is King”. While there are many model companies with excellent compliance histories, well maintained fleets and expertly trained crews there are also many that are often quick to seek relief from compliance issues, forestall maintenance and neglect training requirements when profits are at stake. Masters, mates and engineers know exactly what I am referring to. I say to my brothers at the bitter end of the hawser “remove the log from your own eye, and then concern yourself with the speck in that of your brother’s eye”. Industry must do more to educate mariners to the complexities of the rules that govern their business and provide the resources to ensure compliance that will enhance safety, improve operational efficiency, reduce un-necessary delays and avoid regulatory enforcement uncertainty. In a nut shell…know the rules and live by them.

The Coast Guard is taking steps to address industry concerns in mission areas under our control. Improved Mariner Licensing and Vessel Documentation processes were recently commissioned. The National Vessel Documentation Center (NVDC) ( and the National Maritime Center (NMC) ( have been established to centralize and streamline the vessel documentation and mariner credential issuing processes. I encourage all with interests in these areas to visit their resources posted on the World Wide Web and learn the rules. With regard to vessel inspections, the regulations, policies, Navigation and Inspection Circulars (NVIC) and a host of other related information is widely available. Much of it exists in ships libraries and on book shelves behind the desks of port captains and engineers. They are all accessible on the internet. I challenge those affected by these regulations to read them. Make it your business to know these rules and strive to ensure compliance with them. I should be a major part of your job, not just an annual nuisance. The Coast Guard inspector is not off the hook here. Not only should inspector know the rules, they should be experienced shipboard professionals. It is true that that is not always the case. There are many inspectors in the “bull pen” that are highly skilled and trained in various Coast Guard specific disciplines but do not posses the ideal skills to execute the vessel inspection mission. Inspector training programs designed years ago were supposed to fill those gaps. Inspector training and qualification has eroded over the years and some programs have just plain failed. The current system has failed both the inspector and industry. The Coast Guard recognizes these problems and is taking action. ALCOAST 205/07 ( outlines the frame work of a recent initiative to overhaul inspector recruitment, training and education policies. The stated objective is to establish a program that results in superior execution of the domestic and foreign vessel inspection program. I encourage the marine industry to do what they can to assist the Coast Guard in our efforts to improve. The USCG Inspector should be viewed as an important member of the team when it comes to vessel safety, not the enemy. I may not posses the expertise that a Chief engineer with 20+ years at sea has, but I do bring 28 years of Coast Guard experience, a new set of eyes and a fresh mind to a potential problem. Together, we exceed the sum of our parts.

The bottom line here is that the Coast Guard may have many missions and many responsibilities but we are working to improve and enhance our capabilities and expertise, not shed them. Now is not the time to dismantle the Coast Guard Marine Safety program. Now is the time for the Coast Guard, the maritime industry and the professional mariner to get back to work. We must all sharpen our focus and meet the demands of our respective professions. Safety of life at sea and our collective environmental health demand it from us. The global economy depends on us. We all share the responsibilities for success as well as failure. Each of us must look within and take steps to correct our collective course before we founder upon the shoal ahead.

(Name Withheld) Chief Warrant Officer / United States Coast Guard

MarEx Note: I don’t think that there is very much I could add to this letter. No doubt, there are many who would disagree with some points therein; few could argue with the base of experience and knowledge from which it was written.

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Mr. Keefe,

I, like Mr. Hoppe, have nearly 4 decades of experience in the U.S. deepwater Merchant fleet as an Engineering Officer and Chief Engineer. I realized a long time ago that the USCG was not doing an adequate job with regards to Marine Inspection. Too bad as now the Mariner is sort of on his own battling forces of economic pressure from a shrinking and cutthroat U.S. fleet. I too remember the professional mariners who were on the front lines doing the inspecting. There was no wet behind the ears recent college grad (perhaps with a degree in Marine Biology) inspecting steam drums. Today, a Coast Guard inspector would be hard pressed to actually find the steam drum, much less know what he was looking at. The Coast Guard is manned by fine individuals. My hard words are for the administrations that have allowed this to happen over the last 3 decades.

As for license renewals...I have always dreaded these encounters (with a few exceptions) with the Coast Guard. Actually, it is usually the civilian staff that I feel are rude. There seems to be no recognition from them of a life well and honorably lived at sea. Well, even though I have retired, I hope to renew my license in a few years. Hopefully, they will have forgotten this piece by then. It would be less onerous if one wasn't paying hundreds of dollars to be snubbed by the clerks.

The Coast Guard is at present overwhelmed by the tasks assigned them. Of course, their budget and manning should be seriously increased, but also I think they could do better.


Jon A. Eaton

MarEx Note: This letter expresses some opinions that we have heard before. The highlighting of the failures of previous administrations and the Congress to adequately fund the Coast Guard’s many missions is certainly appropriate. On the other hand, there are those who would suggest that, while the necessary funds were absent for many years, that is certainly not the case today. Or, at least, it wasn’t until the Deepwater fiasco reared its ugly head.

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This letter is written from the Council of American Master Mariners, Inc., (CAMM) a nonprofit association of persons having common professional interests, the objects of which are:

• To promote an effective, efficient, prosperous American Merchant Marine which is of maximum benefit to the nation, the shipper, the mariner, the ship owner, and the financial community.

• To render a public service by expressing the considered professional opinions of Master Mariners regarding maritime issues.

• To encourage and promote advances in nautical education, training standards, and the publication of professional literature for the American mariner.

• To cultivate an attitude of continuing education within the profession.

• To foster an exchange of information between, and promote a spirit of friendship and common purpose among, all organizations whose members are dedicated to a strong United States flag merchant fleet.

• To support and encourage improvement in all nautical facilities.

• To enhance the rightful prestige of the American Master Mariner. (amended 1992)

CAMM takes the following position on the issue of splitting the responsibilities of the Coast Guard:

The Council of American Master Mariners takes the position that the Coast Guard give up the following responsibilities:

• Licensing of Merchant Marine Officers

• Issuing of Mariner’s Document

• Certification of Officers and unlicensed seamen covering those certificates now required by Federal law and International agreements

• Investigation of marine accidents involving vessels and marine personnel. Rendering judgment as to the cause and penalties to be assessed.

• Vessel log books, bridge, engine and official crew lists and reports required by law.

Essentially a new government entity or MARAD would take over these functions.

The inspection of vessels, regulatory requirements, and documentation would be assigned to the American Bureau of Shipping which does the greater part of the work now and has the expertise and personnel to handle the additional work load.

We do not recommend stripping the Coast Guard of the foregoing and placing under a new or understaffed agency but we do support splitting the responsibilities between ABS and MARAD.


Captain Tom Bradley
National President

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Hi Joe,

Just an observation. At the most recent Houston Maritime Association, RADM Whitehead (CO 8th District) was the speaker. During the question and answer period, he was asked about breaking up the Coast Guard by VADM (ret.) Jim Card, former Vice Commandant. Whitehead was very non committal. Card then made the statement, “This is a very bad idea.” At my table, there were three former ship Masters sitting next to each other (including myself). The three of us looked at each other and said, “no, it's a VERY GOOD idea”. Obviously, a difference of opinion.

I am on, and have been a member of a large number of industry/USCG committees, including being a member of the (***** deleted *****), and over the last couple of years I've seen a marked deterioration in the relationship between industry and the USCG. At the very least, the threat of breaking up the Coast Guard is making them rethink their approach. Last Monday, ADM Thad Allen met with a group of senior industry leaders in Houston to start a dialogue. (That might make for an interesting article). Hopefully, that will start some change. Right now, a large chunk of industry feel the Coasties consider themselves policemen first, inspectors a distant last.

Regards, (Name withheld / Master Mariner, Current Industry Executive)

MarEx Note: Industry dialogue with the Coast Guard is a very good thing. Let’s hope Congress and the current administration will include industry in their decision process, if and when this idea moves forward in a substantive way.

* * *

Dear Joe,

I hear that there are forces in DC that are quite serious about moving this forward. I think this will have the effect of making the Coast Guard fight for, and ultimately increase its resources for marine safety missions. If the forces for taking this away from the Coast Guard win, this MAY be a chance to establish an agency that could be more 'in tune' with the maritime industry. However, like a lot of knee jerk reactions by lawmakers, it's the actual laws and regulations that need to be amended to effect positive changes, not who enforces them. When and IF this agency is stood up, who will operate this "ship"? Most likely the same people who now complete these missions for the Coast Guard.

As you know my background, I am not confident that simply using the "Big Spoon" theory of shaking things up is the correct way to fix a problem. The Coast Guard's restructuring of the mariner licensing program, underway right now, is but a small example of the effect of large scale plans like this one will have. There will many years of pain for the maritime industry before the kinks are worked out. Imagine the pain endured during the set up of whole new agency to deal with all of the various marine safety roles!

Name withheld -- the author is a licensed mariner with considerable experience in Coast Guard issues & affairs. He is active in our industry today.

MarEx Note: A short, but I think very wise letter. We need to keep our eye on the ball here. Dismantling something because we don’t like it, won’t necessarily have the effect of making it better. In fact, the exact opposite is likely to happen, if it is not done correctly. Is Washington up to the task? I’ll leave that answer to our readers…