Recent Position Papers, Comments, Letters and Testimony

2018 Comments 

  • April 30 - Comments to U.S. Coast Guard regarding changes made to the Regulated Navigation Area on the Chicago Sanitary and Ship Canal
  • March 26 - Comments to Mr. Jonathan Smith, Office of Marine Environmental Response, U.S. Coast Guard, Regarding the 2016.1 National Preparedness for Response Exercise Program (PREP) Guidelines

2017 Comments

  • December 8 - Comments to Mr. Dennis Hamilton, Deputy for Programs and Project Management, U.S. Army Corps of Engineers, Regarding the Great Lakes and Mississippi River Interbasin Study (GLMRIS) Brandon Road Tentatively Selected Plan (TSP)
  • November 16 - Comments to MG Scott Spellmon, Commander, Northwestern Division, U.S. Army Corps of Engineers, Regarding the Draft Missouri River Mainstem System 2017-2018 Annual Operating Plan
  • September 11 - Comments Mr. Jeffrey Lantz, Director of Commercial Regulations and Standards, U.S. Coast Guard, Regarding Random Audits Under Subchapter M, Supplemental to Comprehensive Recommendations for Regulatory Reform  
  • July 26 - Comments to Mr. Jeffrey Lantz, Director of Commercial Regulations and Standards, U.S. Coast Guard, Regarding Comprehensive Recommendations for Regulatory Reform
  • July 5 - Comments to Secretary Rachel Dickon regarding the FMC’s regulatory reform initiative (Docket No. 17-04)
  • May 15 - Comments to Ms. Samantha Dravis, Office of Policy, U.S. Environmental Protection Agency, Regarding the Evaluation of Exisiting Regulations (Docket No. EPA-HQ-OA-2017-0190)
  • April 24 - Comments to MG Scott Spellmon, Commander, Northwestern Division, U.S. Army Corps of Engineers, Regarding the Missouri River Recovery Management Plan Draft Environmental Impact Statement
  • April 13 - Comments to Lynne Barre, National Marine Fisheries Service, Regarding San Juan Islands Whale Protection Zone
  • March 14 - Comments to Mr. Mark Lahare, U.S. Army Corps of Engineers Regarding the Inner Harbor Navigation Canal Lock Replacement Draft GRR/SEIS

2016 Comments

  • September 23 - Comments to Captain Joseph B. Loring, Chief, Office of Marine Environmental Response Policy Regarding Draft Updates to Alternative Planning Criteria (APC) National Guidelines
  • September 13 - Comments to U.S. Coast Guard on Draft Revisions to the Marine Safety Manual, Volume 3, Parts B and C, Change 2
  • July 8 - Comments to Mr. Rian Hooff, Oregon Department of Environmental Quality Regarding Follow-Up Questions About the Proposed Changes to State Ballast Water Regulations
  • June 6 - Comments to CAPT Richard Timme, Commander, Sector Ohio Valley Regarding the Sector Ohio Valley Annual and Recurring Safety Zones
  • May 24 - Comments to Mr. Rian Hooff, Oregon Department of Environmental Quality Regarding Proposed Changes to State Ballast Water Regulations
  • April 25 - Comments to the U.S. Department of Transportation Regarding the Draft National Freight Strategic Plan
  • April 13 - Comments to the U.S. Department of Transportation Regarding the Request for Comment on the ACPARS Final Report
  • January 25 - Comments to the Bureau of Ocean Energy Management Regarding Commercial Leasing for Wind Power on the Outer Continental Shelf Offshore South Carolina
  • January 22 - Comments to the State of Washington Energy Facility Site Evaluation Council Regarding the Vancouver Energy Draft Environment Impact Statement (DEIS)

2016 Letters

  • May 17 - Letter to RADM Linda Fagan, Commander, First Coast Guard District, Regarding the Proposal to Construct the Champlain Hudson Power Express (CHPE) Transmission System
  • April 23 - Letter to RADM Linda Fagan, Commander, First Coast Guard District Regarding Hudson River Anchorage Areas
  • April 5 - Letter to the Seattle City Council Regarding Plans to Give Away the Public Right-of-Way for Occidental Avenue South

2015 Comments

  • December 28 - Comments to the Bureau of Ocean Energy Management Regarding the Request for Information on the State of the Offshore Renewable Energy Industry.
  • November 20 - Comments to the U.S. Army Corps of Engineers Northwest Dision Regarding the Draft Missouri River Mainstem System 2015-2016 Annual Operating Plan
  • October 19 - Comments to the Docket Management Facility (M3) USDOT Regarding Navigation Area: Ice-Covered Waterways in Fifth Coast Guard District
  • October 15 - Comments to the Seattle Department of Transportation Regarding Potential Changes to Lake Washington Ship Canal Bridges' Opening Restrictions
  • September 8 - Comments to the Federal Energy Regulatory Commission on the Notice of Preliminary Permit Application for the Mississippi Rover Lock and Dam 14 Hydropower Project
  • August 17 - Comments to the Marine Invasive Species Program on the Proposed Modifications to Article 4.8 - Biofouling Management to Minimize the Transfer of Nonindigenous Species from Vessels Operating in California
  • June 16 - Comments to the Marine Invasive Species Program on Biofouling Management to Minimize the Transfer of Nonindigenous Species from Vessels Operating in California Waters
  • June 3 - Comments on to the U.S. Coast Guard on the Port Access Route Study in the Chukchi Sea, Bering Strait, and Bering Sea.
  • April 15 - Comments to the U.S. Department of Transportation on Guidance on Maritime Cybersecurity Standards
  • February 27 - Comments to the U.S. Department of Transportation on the Seafarers' Access to Maritime Facilities
  • February 23 - Comments to the Bureau of Ocean Energy Management on Environmental Assessment for Commercial Wind Lease Insurance and Site Assessment Activities
  • February 19 - Comments to the Federal Energy Regulatory Commission on the Environmental Assessment for the Newburgh Hydroelectric Project
  • February 18 - Comments to the U.S. Army Corps of Engineers on Supplemental Environmental Impact Statement for the Inner Harbor Navigation Canal Lock Replacement Project
  • January 30 - Comments to U.S. Army Corps of Engineers on Proposed GLMRIS Project at Brandon Road Lock and Dam
  • January 23 - Comments to U.S. Army Corps of Engineers on Upper St. Anthony Falls Lock Closure

2015 Letters

  • December 18 - Letter to the Assistant Secretary of the Army-Civil Works, Jo-Ellen Darcy, Regarding Congressional Opposition to Proposed Changes to the Missouri Water Control Plan

2015 Testimony

  • February 4 - Testimony before the Subcommittee on Oceans, Atmosphere, Fisheries and Coast guard Committee on Commerce, Science and Transportation

2015 Memorandum

  • Memorandum signed by District 8 and District 9 regarding the enforcement of fire extinguisher brackets on Western River Tank Barges
  • Memorandum regarding the Hudson River Anchorage Grounds

2014 Comments

  • October 8 - Comments to the U.S. Coast Guard on the Regulated Navigation Area; Lake Michigan, Chicago Harbor Lock
  • September 19 - Comments to the Bureau of Ocean Energy Management on Commercial Leasing for Wind Power on the Outer Continental Shelf
  • September 15 - Comments to the U.S. Army Corps of Engineers on the Champlain Hudson Power Express Transmission Project Environmental Impact Statement
  • August 29 - Comments to the U.S. Coast Guard on IMO Polar Code
  • August 25 - Comments to the U.S. Coast Guard on its Petition to Establish a Special Load Line Exemption for Lake Michigan
  • August 15 - Comments to California State Land Commission on Draft Biofouling Management Regulations
  • July 14 - Comments to the U.S. Coast Guard on its Workplace Safety and Health for Merchant MarinersPetition
  • June 16 - Comments to U.S. Coast Guard on Proposed Arthur Kill Waterway Regulated Navigation Area
  • May 14 - Comments to U.S. Coast Guard on Draft Revisions to the Marine Safety Manual, Volume 3, Chapters 20-26
  • April 21 - Comments to Washington State Department of Ecology on Draft Petition to EPA to Declare Puget Sound a No Discharge Zone
  • March 31 - Comments to U.S. Army Corps of Engineers on the Great Lakes and Mississippi River Interbasin Study (GLMRIS) Report
  • February 18 - Comments to U.S. Bureau of Ocean Energy Management on Notice of Commercial Leasing for Wind Power in the Maryland Wind Energy Area
  • February 13 - Comments to the U.S. Department of Transportation Regarding Cargo Securing Manuals
  • February 7 - Comments to Chicago Department of Public Health on Proposed Regulations for Handling and Storage of Bulk Material Piles
  • February 7 - AWO Comments City Petcoke

2014 Letters

  • June 20 - Letter to U.S. Senate Commerce Committee leadership on S. 2094
  •  May 15 - Letter to Illinois Attorney General on HB 5939

2014 Testimony

  • March 25 & 31 - Testimony before Tennessee House and Senate on SB 2076 and HB 1769
  • March 4 - Testimony before the U.S. House Subcommittee on Coast Guard and Maritime Transportation on Need for Ballast Water Regulation

2013 Comments

  • Comments to the U.S. Department of Transportation on the Ballast Water Management Reporting and Recordkeeping