摘要: |
The U.S. Coast Guard has been working on a fee schedule for Subchapter M since 2016. As you'll read in this issue, on January 13 it announced new annual fees for vessels to maintain their certificates of inspection. The proposed fees, for which the Coast Guard is accepting comments through April, are $973 for vessels using a third-party organization (TPO) and towing safety management system, and $2,184 for vessels that opt for a direct Coast Guard inspection. These are annual fees per vessel, even though vessels using a TPO get a Coast Guard inspection once every five years to maintain their certificates, whereas vessels choosing a direct Coast Guard option get a vessel inspection every year. The fees are supposed to reflect the Coast Guard's total actual costs for administering the program.At first glance, it may seem as if the proposed fee structure is encouraging vessels to use the TPO option. The Coast Guard has spoken in several communications about its need to partner with TPOs to spread the burden of Subchapter M monitoring and has expressed gratitude for the burden-sharing. But since companies using a TPO are already paying fees to them, using the Coast Guard option is still likely to be less expensive overall-at least in the short run. |