ADDRESSING OPERATIONAL CHALLENGES AND REDUCING COMPLIANCE COSTS
■ Won federal court victory requiring EPA to consider compliance costs in reviewing state applications to establish No Discharge Zones
■ Prompted overhaul of EPA No Discharge Zone guidance that could save members millions in retrofits and operational modifications
■ Secured Coast Guard policy on proactive enforcement of Subchapter M to improve safety and protect members ’ investments in compliance
■ Achieved policy outcomes that reduce costs and promote practicability in Subchapter M compliance , including : – Regulation restoring the use of Letters of Designation for PICs of fuel transfers , relieving companies and mariners from credentialing costs – Approval of Visual Distress Signals equivalency to save members the expense of purchasing unnecessary equipment – Eighth Coast Guard District guidance allowing vessels on Rivers routes not to carry or install unneeded lights and day shapes
■ Secured legislation setting firm deadlines for the Coast Guard to review and update inspection user fees for TSMS and Coast Guardoption vessels
■ Pressed the Coast Guard to initiate a rulemaking to modify firefighting training requirements for inland operators to ensure relevance and practicality
■ Submitted comprehensive recommendations to EPA to ensure performance standards for vessel discharges under VIDA are timely and practicable for towing vessel and barge operators
■ Led a year-long member dialogue that resulted in changes to AWO membership requirements and the Responsible Carrier Program that enhance flexibility , eliminate duplication , and reduce burdens for members while continuing to promote high standards of safety and stewardship
2020 ANNUAL REPORT FORWARD TO BETTER 3