Issues & Advocacy

Recent Position Papers, Comments, Letters and Testimony

2020 Comments, Letters and Testimony

  • July 31 - Comments to VADM David Pekoske, Administrator, Transportation Security Administration regarding establishment of an online process to renew Transportation Worker Identification Credentials
  • July 7 - Comments to Mr. Jerry Barnes, U.S. Coast Guard Fifth District regarding Anchorage Ground; Cape Fear River Approach, North Carolina
  • July 6 - Comments to Mr. Jerry Barnes, U.S. Coast Guard Fifth District regarding Port Access Route Study: Seacoast of New Jersey Including Offshore Approaches to the Delaware Bay
  • July 6 - Comments to Mr. Damien Reinhart, Project Manager, Bureau of Reclamation, Dakotas Area Office regarding the Bureau of Reclamation’s Draft Environmental Impact Statement (DEIS) for the Eastern North Dakota Alternate Water Supply (ENDAWS) Project
  • June 11 - Comments to Mr. Dane Morris, Project Manager, U.S. Army Corps of Engineers regarding Draft Environmental Assessment for MRRP Chute Repairs and Modifications
  • May 29 - Testimony by Jennifer Carpenter, President & CEO before House Subcommittee on Coast Guard and Maritime Transportation
  • April 13 - Comments to BG D. Peter Helmlinger, P.E., U.S. Army Corps of Enginers; Ms. Lorri Gray, U.S. Department of Interior; and Mr. Elliot Mainzer, U.S. Department of Energy, regarding Columbia Snake River Operations Draft Environmental Impact Statement
  • March 16 – Comments to Ms. Denise Koch, Alaska Department of Environmental Conservation, regarding Oil Discharge Prevention and Contingency Plan Public Scoping
  • March 16 - Comments to Rear Admiral Andrew Tiongson, Commander, U.S. Coast Guard - First District, regarding Port Access Route Study in Areas Offshore Rhode Island and Massachusetts
  • March 3 - Comments to Rear Admiral Shepard M. Smith, Office of Coast Survey, National Oceanic and Atmospheric Administration, Sunsetting of Raster Nautical Charts Production
  • March 3 - Comments to Ms. Jannine Miller, Deputy Assistant Secretary for Policy, U.S. Department of Transportation, regarding National Freight Strategic Plan Request for Information
  • February 26 – Letter to The Honorable Elaine L. Chao, Secretary, U.S. Department of Transportation regarding support of the Seattle Department of Transportation’s (SDOT) Infrastructure for Rebuilding America
  • February 21 – Letter to The Honorable Elaine L. Chao, Secretary, U.S. Department of Transportation regarding Washington State Department of Transportation’s Infrastructure for Rebuilding America grant application for the Puget Sound Gateway Program
  • February 10 – Comments to Mr. Craig Kenworthy, Executive Director, Puget Sound Clean Air Agency, regarding the Puget Sound Clean Air Agency’s (PSCAA) draft Regional Clean Fuel Standard
  • January 31 - Comments to Ms. Thareth Casey, Project Manager, U.S. Army Corps of Engineers regarding Draft Pelican Bend Interception Rearing Complex
  • January 28 - Comments to Mr. Jerry Barnes, U.S. Coast Guard Fifth District, regarding Anchorage Grounds; Delaware Bay and Atlantic Ocean, Delaware
  • January 27 - Comments to Mr. Jerry Barnes, U.S. Coast Guard Fifth District, regarding Port Access Route Study: Approaches to the Chesapeake Bay, Virginia

2019 Comments, Letters and Testimony 

  • December 18 - Comments to Mr. Barry A. Thom, West Coast Regional Administrator, National Marine Fisheries Services, National Oceanic and Atmospheric Administration regarding Proposed Revision to the Critical Habitat Designation for the Southern Resident Killer Whale Distinct Population Segment
  • December 2 - Comments to Mark H. Buzby, Administrator, Maritime Administration, U.S. Department of Transportation regarding proposed renewal of the Voluntary Tanker Agreement Program
  • November 22 - Comments to BG Peter D. Helmlinger, Commander, Northwestern Division, U.S. Army Corps of Engineers regarding the Missouri River Mainstem System 2019-2020 Draft Annual Operating Plan
  • November 20 - Comments to U.S. Customs and Border Protection Office of Trade, Regulations and Rulings regarding Proposed Modification and Revocation of Ruling Letters Relating to CBP’s Application of the Jones Act to the Transportation of Certain Merchandise and Equipment between Coastwise Points
  • November 18 - Comments to RDML Richard V. Timme, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding Crediting Recent Sea Service of Personnel Serving on Vessels of the Uniformed Services
  • November 12 - Comments to Mr. Derrick J. Croinex, Chief, Spectrum Management and Telecommunication, U.S. Coast Guard regarding Proposed Termination of U.S. Coast Guard Medium Frequency (MF) Broadcast of Navigational Telex (NAVTEX) and Shift to Satellite
  • November 8 – Comments to Mr. Peterson Vollmann, Planner IV, City of Oakland Bureau of Planning, regarding the draft environmental impact report for the proposed Downtown Oakland Specific Plan
  • November 8 – Comments to the City of Oakland, regarding Downtown Oakland Specific Plan Public Review Draft
  • November 4 - Comments to Mr. Michael Emerson, Director, Marine Transportation Systems, United States Coast Guard regarding Use of Electronic Charts and Publications in Lieu of Paper Charts, Maps and Publications
  • October 28 - Comments to Chairman Peter DeFazio and Ranking Member Sam Graves, House Transportation and Infrastructure Committee and Chairwoman Grace Napolitano and Ranking Member Bruce Westerman, Subcommittee on Water Resources and the Environment regarding H.R. 2440, the Full Utilization of the Harbor Maintenance Trust Fund Act
  • October 21 - Comments to Andrew R. Wheeler, Administrator, U.S. Environmental Protection Agency regarding Tier 4 standards
  • October 8 - Comments to RDML Richard V. Timme, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding Person in Charge of Fuel Transfers
  • September 17 - Comments to the Maritime Administration, U.S. Department of Transportation regarding Centers of Excellence for Domestic Maritime Workforce Training and Education
  • September 10 – Comments to Ms. Kate Gordon, Director, Office of Planning and Research for the State of California, regarding the Supplemental Application by the Oakland A’s proposed project at Howard Terminal in the Port of Oakland
  • August 30 - Comments to RADM Matthew T. Bell Commander, Seventeenth District, U.S. Coast Guard, regarding Port Access Route Study: Alaskan Arctic Coast
  • August 21 - Comments to Mr. D. Lee Forsgren, Jr., Deputy Assistant Administrator, Office of Water, Environmental Protection Agency and CAPT Sean Brady, Chief, Office of Operating and Environmental Standards, U.S. Coast Guard regarding AWO Recommendations for Draft Regulations to Implement the Vessel Incidental Discharge Act
  • April 12 - Responses  by Tom Allegretti, President & CEO, to written questions submitted by Senator Maria Cantwell for the Record of the March 6 Senate Commerce Committee hearing
  • April 5 - Responses by Tom Allegretti,  President & CEO, to written questions submitted by Senator Roger Wicker for the Record of the March 6 Senate Commerce Committee hearing
  • April 5 - Responses  by Jennifer Carpenter, Executive Vice President & COO, to written questions submitted by Rep. Peter DeFazio for the Record of the March 6 House Subcommittee on Coast Guard and Maritime Transportation hearing
  • March 6 - Testimony by Jennifer Carpenter, Executive Vice President & COO before the House Subcommittee on Coast Guard and Maritime Transportation
  • March 6 - Testimony by Tom Allegretti, President & CEO before the Senate Commerce Committee
  • February 22 - Comments to Mr. Dennis W. Hamilton Deputy, Programs and Project Management U.S. Army Corps of Engineers regarding the Brandon Road Recommended Plan
  • February 13 - Comments to Mr. Jeffrey G. Lantz Director, Commercial Regulations and Standards, U.S. Coast Guard, regarding the Coast Guard’s Draft Merchant Mariner Medical Manual.
  • February 1 - Amicus Brief in The Dutra Group v. Batterton, Jones Act Case before the Supreme Court.
  • January 31 - Testimony by Charles Costanzo, Vice President – Pacific Region before the Washington Senate Environment, Energy & Technology Committee on SB 5578. Video here.
  • January 14 - Comments to Mr. Peterson Vollmann, Planner IV, City of Oakland Bureau of Planning, regarding the City of Oakland's Environmental Impact Report for the potential Oakland Waterfront Ballpark District Project.

2018 Comments 

  • November 13 - Comments to Mr. John Goodin, Acting Director, Office of Wetlands, Environmental Protection Agency, regarding establishing No-Discharge Zones
  • November 9 - Comments to BG Peter Helmlinger, Northwestern Division Manager, U.S. Army Corps of Engineers, regarding the Missouri River Recovery Management Plan Final Environmental Impact Statement 
  • November 1 - Comments to Mr. Kenneth D. Allen Contracting Officer, Strategic Sealift Program Support Office Military Sealift Command Norfolk regarding a proposal to change the threshold for repair maintenance work for companies to receive a preference in contracting. 
  • October 2 - Comments to Mr. Kenneth D. Allen, Contracting Officer, Strategic Sealift Program Support Office Military Sealift Command Norfolk regarding a proposal to change the threshold for repair maintenance work for companies to receive a preference in contracting. 
  • September 26 – Stakeholder letter to the Elected Leadership Group, Cathal Ridge, Central Corridor Director, regarding Sound Transit 3 alignment through Interbay and Ballard
  • August 24 - Comments to Ms. Neomi Rao, Administrator, Office of Information and Regulatory Affairs, Office of Management and Budget regarding regulatory reform request for information.
  • July 30 - Comments to Office of Renewable Energy Programs regarding proposed Wind Energy Areas within the New York Bight region
  • July 23 - Comments to CAPT Ryan Manning, Chief, Office of Port & Facility Compliance regarding TWIC reader rule partial delay
  • June 8 - Comments to Mr. Jeffrey Lantz, Director of Commerical Regulations and Standards, U.S. Coast Guard, Regarding the Ballast Water Management Annual Reporting Requirement
  • 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