AWO Letter - November 2, 2023

EPA Publishes Supplemental VIDA Proposal, Announces Virtual Meetings. In the October 19 newsletter, AWO announced that the U.S. Environmental Protection Agency had published a Supplemental Notice of Proposed Rulemaking (SNPRM) for vessel incidental discharge national standards of performance under the Vessel Incidental Discharge Act (VIDA). The SNPRM details supplemental regulatory options under consideration by EPA, including AWO’s recommendation to exempt new vessels over 400 gross tons from the requirement to install graywater treatment systems or discharge graywater shoreside for treatment if the vessel is certified to carry fewer than 15 people and does not provide overnight accommodations for those people. EPA has also chosen to preserve the exemption from ballast water treatment requirements for vessels less than 1,600 gross tons that do not operate outside the U.S. Exclusive Economic Zone and has reaffirmed that the current ballast water treatment standard is the only achievable, measurable standard. AWO continues to work with members and coalition partners to develop comments, which are due December 18. EPA has also scheduled two virtual meetings on November 8 and November 16 to discuss the SNPRM. You can register for those meetings here. If you have any questions, please contact Leah Harnish.
RCP Standards Board Issues Clarifying Guidance. AWO’s RCP Standards Board has issued a new memorandum clarifying the minimum requirements from 46 CFR Part 138 that must be met by members who choose to use a safety management system other than the AWO Responsible Carrier Program® or ISM Code to meet the AWO membership requirement for third party audited compliance with a SMS. The memo was issued in response to TPO and AWO member requests for clarification of RCP Addendum A.a., which states: “In order to be eligible for AWO membership, companies that own or operate tugboats, towboats, or barges engaged in U.S. domestic transportation must achieve third party audited compliance with a safety management system (SMS) that meets the minimum requirements of 46 CFR Part 138.” If you have any questions, please contact Mike Breslin.
New AWO Sustainability Resources Webpage Highlights Funding Opportunities. AWO has launched a new Sustainability Resources webpage, which features a compilation of federal and state funding programs that can be used to support the construction of lower-carbon vessels, the upgrade of marine engines, and other sustainability initiatives. The page includes short descriptions of each program with links to websites where members can find more information and will be updated as new funding opportunities are created or brought to our attention. If you see federal or state programs missing from the list, please contact Bradley Trammell. Development of the new webpage is part of AWO’s implementation of the Board-approved CEO Sustainability Task Force recommendations.
USCG Updates Vessel Cyber Risk Work Instruction. On October 17, the U.S. Coast Guard published an updated vessel cyber risk management work instruction (CVC-WI-027) that provides guidance for vessels subject to the ISM Code, which are required to address cyber risks in their safety management systems. The work instruction also includes guidance for U.S. vessels subject to the Maritime Transportation Security Act (MTSA) and lists cybersecurity questions for marine inspectors to ask during MTSA verifications. Revisions in the updated version include elaborating on the definition of “poor cyber hygiene,” clarifying procedures and standards for port state control exams, linking to cyber resources for marine safety personnel, and updating reporting procedures in response to suspected cyber incidents onboard vessels. This work instruction was last updated in 2021. If you have any questions, please contact the Coast Guard Port Safety Control Division (CVC-2) at 202-372-3567 or email Steve Kwan at
Register for November 9 AWO Mariner Workforce Forum. Register now for AWO's next Mariner Workforce Forum to learn about ways you can harness the Maritime Institute of Technology and Graduate Studies’ (MITAGS) Coast Guard-approved Maritime Apprenticeship Program to grow your mariner workforce. This Forum will highlight the program, which trains mariners with little or no maritime industry experience to obtain their mates' license in roughly two years through a combination of coursework and service on partnering companies' vessels. Tugboat, towboat, and barge operators that are participating in the program will also join and share their insights and experiences.
AWO Sustainability Tech Working Group Update. AWO’s Sustainability Tech Working Group recently met with Dan Yuska, Director of the Maritime Administration’s Office of Environment and Innovation, to discuss the Biden Administration’s plans for maritime decarbonization and working group members’ questions regarding federal funding opportunities for sustainability initiatives, the ongoing development of the Congressionally authorized Center for Maritime Innovation, and the status of interagency coordination. Mr. Yuska confirmed that the Biden Administration’s domestic strategy is focused on creating incentives and providing technical support as opposed to promulgating new regulations.
Future working group meetings will feature additional special guests and provide a forum for member companies to engage on timely topics relevant to sustainability programs and technologies. Meetings are held on a bi-monthly basis and the next one is scheduled for November 28. If you are interested in joining the Sustainability Tech Working Group, please email Bradley Trammell.
AWO Holds Mariner Workforce Meeting at Maine Maritime Academy. Towing vessel operators met with representatives from Maine Maritime Academy on October 18 to discuss ways to maximize the utility of the Academy’s towing vessel program to meet current and future industry workforce needs. Attendees discussed opportunities for tugboat, towboat and barge companies to help promote MMA’s renowned towing vessel training program, ways to improve cadet feedback on towing vessel mentoring programs, and the need for regular discussions between MMA and industry representatives on specific workforce issues. This meeting is the start of AWO’s ongoing effort to partner with MMA and other maritime academies towards the goal of helping young people forge careers in the tugboat, towboat and barge industry. For more information, please contact Patrick Parsons.
AWO PAC Corner
AWO and Inside Elections. AWO and Inside Elections have partnered for another special edition, featuring an overview of Senate races across the country as well as insights on elections in North Carolina and Alabama.
AWO PAC is the connected political action committee for The American Waterways Operators and serves as the trade association’s separate segregated fund. As a trade association, AWO is prohibited from using general treasury funds or membership dues to make federal contributions. AWO is one of the most effective advocacy associations in Washington, DC, and relies on voluntary personal contributions to fund AWO PAC.

AWO PAC supports federal candidates who are champions of the U.S. tugboat, towboat and barge industry and who are leaders on issues important to our industry. AWO PAC is dedicated to protecting AWO members’ investments in the safest, most environmentally responsible and most economical mode of freight transportation and safeguarding the integrity of the Jones Act to protect the bottom lines of our members. AWO PAC may solicit contributions from individuals of a member company once the member representative gives AWO written prior approval.

RIETF and AWO Meet with USCG Ninth District Leadership. River Industry Executive Task Force (RIETF) vice chair Russell Lampkin of Ingram Barge Company and AWO staff recently met with U.S. Coast Guard Ninth District Commander and RIETF co-chair RADM Jonathan Hickey and his senior staff. Mr. Lampkins thanked RADM Hickey for signing an endorsement to the RIETF Communication Memorandum of Understanding, and the group discussed the need for consistency between the Eighth and Ninth districts; safety issues with the Brandon Road project; and drydock availability in the Ninth District.
Washington Governor Launches Offshore Wind Initiative with AWO Members. On October 10, Washington Governor Jay Inslee launched the Blue Wind Supply Chain Initiative with AWO members Foss Maritime Company and Crowley Corporation, which combines public and private partners to advance the state’s standing as a manufacturer of advanced components for offshore wind turbines. This new effort is in response to President Biden’s goal to generate 30 GW of offshore wind energy by 2030.
AWO Members Meet with New District 13, Sector Puget Sound Leaders. As part of AWO’s ongoing work to build strong relationships with Coast Guard leadership at all levels, AWO members and staff recently briefed Coast Guard District 13 and Sector Puget Sound officials on British Columbia pilotage, No Discharge Zones, wind energy, the Pacific Port Access Route Study, and tug escort rules. District 13 Commander RADM Charles E. Fosse and Sector Puget Sound Commander CAPT Mark McDonnell both emphasized the importance of the tugboat, towboat, and barge industry’s role within the marine transportation system during the discussions.
AWO Submits Comments on Oregon Offshore Wind Proposal. AWO submitted comments to the Bureau of Ocean Energy Management (BOEM) supporting the positioning of newly proposed Wind Energy Areas (WEAs) off the Oregon coast which, in line with AWO’s previous advocacy, removes conflicts with fairways called out in the Pacific Port Access Route Study. AWO’s comments also ask BOEM to ensure that future alterations to the WEAs do not introduce new conflicts with navigation safety. This is the second in a five-stage process to designate offshore wind developments, which can take up to ten years from planning to implementation.
October Navigating to Zero Recap. The recently published October edition of Navigating to Zero, AWO’s Safety and Sustainability Newsletter, features information on opioid abuse and responding to an overdose; a recap of the OCIMF-AWO roundtable session held during AWO Fall Convention; an overview of the Coast Guard’s final rule for firefighting training for credentialed inland mariners; a member-submitted High Value Near Miss; two recent NTSB investigations; a review of recent American Waterways HERO Award winners from September and October; and more.
Please also remember to send in your SSRP reports for the 3rd quarter, share your High Value Near Misses, and recognize your crew's HEROic acts! Click on the links or use the QR codes below for these programs.
Visit AWO at WorkBoat. AWO will be at WorkBoat! Visit the AWO team at booth #956. As an AWO member you are eligible for a complimentary WorkBoat Show and Underwater Intervention exhibit hall pass, plus 25% off the UI Technical Conference Program -- register here and enter promo code IWBS2330462 when prompted.