Issues & Advocacy

Recent Position Papers, Comments, Letters and Testimony

2024 Comments, Letters and Testimony
  • March 4 - Comments to Ms. Dana S. Tulis, Director, Emergency Management, U.S. Coast Guard regarding Western Alaska Oil Spill planning criteria
  • March 4 - Comments to Hon. Michelle L. Phillips, Secretary to the Commission, New York State Public Service Commission regarding the Champlain Hudson Power Express Inc. (CHPE) application for construction, operation, and maintenance of a high voltage cable along the Hudson River
  • February 23 - Comments to RADM Charles E. Fosse, Commander, Thirteenth District, U.S. Coast Guard regarding notice of proposed rulemaking to establish anchorage ground: Crims Island Anchorage, Columbia River, Oregon, and Washington
  • February 23 - Comments to RADM Charles E. Fosse, Commander, Thirteenth District, U.S. Coast Guard regarding notice of proposed rulemaking to establish anchorage ground: Port Westward Anchorage, Columbia River, Oregon and Washington
  • February 23 - Comments to RADM Charles E. Fosse, Commander, Thirteenth District, U.S. Coast Guard regarding notice of proposed rulemaking to establish anchorage ground: Rice Island Anchorage, Columbia River, Oregon, and Washington
  • February 22 - Comments to California Governor Gavin Newsom regarding the California Air Resources Board Commerical Harbor Craft Rule.
  • February 22 - Testimony by Peter Schrappen, AWO Vice President - Pacific Region, before the Hawaii Senate Ways and Means Committee in opposition to SB 2746, Relating to Harbor Safety
  • February 16 - Comments to Ms. Lisa Gilbane, Pacific Regional Office of Environment, Bureau of Ocean Energy Management regarding BOEM’s programmatic environmental impact statement regarding the California offshore wine leases
  • February 13 - Comments to Mr. Douglas W. O’Donnell, Deputy Commissioner for Services and Enforcement, Internal Revenue Service regarding the Advance Manufacturing Production Credit (45X)
  • February 12 - Comments to Ms. Jessica Stromberg, Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding draft environmental assessment of offshore wind leases in the Central Atlantic
  • January 19 - Testimony by Kyle T. Burleson, AWO Director - State Advocacy, before the NH House State-Federal Relations and Veterans Affairs Committee regarding a resolution calling for repeal of the Jones Act
2023 Comments, Letters and Testimony
  • December 20 - Comments to Ms. Lisa S. Davis, Public Health Advisor, Division of Workplace Programs, Substance Abuse and Mental Health Services Administration regarding proposed changes to the authorized drug testing panels for urine and oral fluid
  • November 30 - Comments to Colonel Travis Rayfield, Commander, Kansas City District, U.S. Army Corps of Engineers regarding Lower Kansas River Water Control Manuals
  • November 27 - Comments to BG Geoff Van Epps, Commander, Northwestern Division, U.S. Army Corps of Engineers regarding Missouri River Mainstem System 2023-2024 Draft Annual Operating Plan
  • November 2 - Testimony by Kyle T. Burleson, AWO Director - State Advocacy, before CA Assembly Select Committee on Ports and Goods Movement regarding the California Air Resources Board's Commercial Harbor Craft rule
  • October 26 - Comments to Ms. Jean Thurston-Keller, Project Coordinator, Pacific Regional Office – Renewable Energy Section Bureau of Ocean Energy Management regarding Draft Wind Energy Areas – Commercial Leasing for Wind Power Development on the Oregon Outer Continental Shelf
  • October 6 - Comments to Ms. Diana Davis, Spill Prevention, Preparedness, and Response Program, Washington State Department of Ecology regarding Chapter 173-187 WAC Financial Responsibility Preliminary Rule Language
  • October 6 - Comments to Mr. Steven M. Neugeboren, Associate General Counsel, Water Law Office, Office of General Counsel, U.S. Environmental Protection Agency regarding the proposed consent decree to require the EPA to set a date for final action on the Vessel Incidental Discharge National Standards of Performance
  • October 6 - Comments to Mr. David Bernhart, Assistant Regional Administrator, Protected Resources Division, National Marine Fisheries Services, Southeast Regional Office regarding Endangered and Threatened Species; Designation of Critical Habitat for the Rice’s Whales
  • August 21 - Comments to California Governor Gavin Newsom regarding CARB's recent amendments to the Commercial Harbor Craft rule
  • August 17 - Comments to the Mississippi River Commission regarding optimizing safe navigation on the river
  • August 12 - Comments to Ms. Mirian Sandova, Air Pollution Specialist, Mobile Source Control Division, California Air Resources Board regarding proposed revisions to the Carl Moyer Memorial Air Quality Standards Attainment Program
  • August 11 - Comments to Mr. Michael Walker, Bridge Management Specialist, 9th Coast Guard District regarding the Stephen Street Bike Trail Bridge
  • July 6 - Comments to Richard W. Spinrad, Ph.D., Under Secretary of Commerce for Oceans and Atmosphere, National Oceanic and Atmospheric Administration regarding Endangered and Threatened Species Petition to Establish a Vessel Speed Restriction and Other Vessel-Related Measures to Protect Rice’s Whales
  • July 1 - Comments to U.S. Environmental Protection Agency regarding the California Air Resources Board's request for authorization to enforce amendments to the commercial harbor craft rule 
  • June 28 - Comments to Rear Admiral Jo-Ann F. Burdian, Assistant Commandant for Response Policy, U.S. Coast Guard regarding Coast Guard Vessel Response Plan and Maritime Oil-Spill Response Plan Advisory Group (MORPAG) Recommendations
  • May 4 - Comments to CDR Nicole Auth, Inspections & Investigations Branch Chief, U.S. Coast Guard, District Nine regarding draft D9 guidance for inland towing vessels on Western Rivers and Lake Michigan
  • April 25 - Comments to Ms. Tershara Matthews, Chief, Office of Emerging Programs, Bureau of Ocean Energy Management regarding Proposed Sale Notice for the commercial offshore wind leases in the Gulf of Mexico
  • April 17 - Comments to Ms. Brandi Canada, U.S. Coast Guard, Eighth Coast Guard District regarding Port Access Route Study in the Gulf of Mexico
  • April 12 - Testimony by AWO State Advocacy Representative Kyle Burleson before the New Hampshire House Commerce and Consumer Affairs Committee in opposition to SB102
  • April 5 - Comments to Ms. Kim Morley, Spill Prevention, Preparedness, and Response Program, Washington State Department of Ecology regarding rulemaking to amend Chapter 363-116 WAC, Pilotage Rules
  • April 3 - Testimony by AWO Vice President - Pacific Region Peter Schrappen before the Columbia River Base Mediation listening session regarding the importance of the Lower Snake River Dams
  • March 27 - Comments to Ms. Sarah Dunham, U.S. Environmental Protection Agency Docket Center, requesting that EPA hold a virtual public hearing on the California Air Resources Board’s request for authorization of amendments to its Commercial Harbor Craft rule
  • March 21 - Comments to Ms. Amy Frantz, U.S. Army Corps of Engineers regarding Water Resources Development Act of 2022 Implementation Guidance
  • March 17 - Comments to Mrs. Megan Johns-Henry, Alternate Designated Federal Officer, National Merchant Marine Personnel Advisory Committee encouraging amendment of its task statement on the mariner shortage to consider a wider range of the industry
  • February 13 - Comments to Ms. Jessica Stromberg, Project Coordinator, Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding Draft Environmental Impact Statement for the Coastal Virginia Offshore Wind Commercial Project
  • February 13 - Comments to LTJG Thomas Davis, U.S. Coast Guard - First District regarding Port Access Route Study: Approaches to Maine, New Hampshire, and Massachusetts
  • February 13 - Comments to Ms. Jessica Stromberg, Project Coordinator, Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding Draft Environmental Impact Statement for Sunrise Wind, LLC's Proposed Sunrise Wind Farm Offshore New York
  • February 13 - Comments to LT Ryan Gilbert, U.S. Coast Guard - Seventh District regarding Southeast Atlantic Coast Port Access Route Study
  • January 17 - Comments to Ms. Jessica Stromberg, Project Coordinator, Office of Renewable Energy Programs, Bureau of Ocean Energy Management regarding the environmental impact statement of Empire Wind’s offshore operations off the coast of New York
2022 Comments, Letters and Testimony
  • December 17 - Comments to Ms. Jennifer Brown, Vicksburg District, U.S. Army Corps of Engineers regarding application for a permit along the Yazoo River Diversion Canal at Vicksburg, MS
  • December 16 - Comments to Mr. Dean Amundson, U.S. Coast Guard, Shore Infrastructure Logistics Center, Environmental Division regarding Expansion and Modernization of Base Seattle
  • December 13 - Comments to Ms. Amy DeBisschop, Director, Division of Regulations, Legislation, and Interpretation, Wage and Hour Division, U.S. Department of Labor regarding Employee or Independent Contractor Classification Under the Fair Labor Standards Act
  • December 4 - Comments to Dr. Caroline Good, Office of Protected Resources, National Marine Fisheries Service regarding BOEM/NOAA Offshore Wind Strategy
  • November 21 - Comments to BG Geoff Van Epps, Commander, Northwestern Division, U.S. Army Corps of Engineers regarding the Missouri River Mainstem System 2022-2023 Draft Annual Operating Plan
  • November 18 - Comments to Mr. Scott Doney, Office of Science and Technology Policy, Executive Office of the President regarding the Ocean Climate Action Plan
  • November 8 - Comments to LCDR Sara Conrad, Pacific Area (PAC-54), U.S. Coast Guard regarding draft Pacific Coast Port Access Route Study (PACPARS)
  • November 7 - Comments to Mr. Douglas Blakemore, Chief, Bridge Administration Branch, U.S. Coast Guard, Eighth Coast Guard District regarding Drawbridge Operation Regulation; Bay St. Louis, MO
  • November 7 - Comments to Mr. Douglas Blakemore, Chief, Bridge Administration Branch, U.S. Coast Guard, Eighth Coast Guard District regarding Drawbridge Operation Regulation; Pascagoula River, Pascagoula, MS
  • October 31 - Comments to Dr. Caroline Good, Office of Protected Resources, National Marine Fisheries Service regarding amendments to the North Atlantic Right Whale Vessel Strike Reduction Rule
  • October 25 - Comments to Steven S. Cliff, Ph.D., Executive Officer, California Air Resources Board regarding additional recommendations on the Commercial Harbor Craft Rule
  • October 24 - Comments to Mr. Craig D. Carrington, Chief, Project Planning Branch, Nashville District, U.S. Army Corps of Engineers regarding scoping to evaluate measures and alternatives to manage and prevent the spread of invasive carp in the Tennessee River, Cumberland River, and northern section of the Tennessee-Tombigbee Waterway.
  • September 14 - Comments regarding the California Office of Administrative Law’s Decision of Disapproval of Regulatory Action for the California Air Resource Board’s Commercial Harbor Craft Rule
  • September 7 - Comments to Ms. Heidi Craswell, Manager, Marine Safety Management System Regulations, Marine Safety and Security, Transport Canada regarding Canada’s proposed Marine Safety Management System Regulations
  • August 26 - Comments to Ms. Radhika Fox Assistant Administrator, Office of Water, U.S. Environmental Protection Agency, regarding Draft Guidance for Vessel Sewage No-Discharge Zones
  • August 1 - Comments to Mr. Andrew Richard, Regional Aquaculture Coordinator, Southeast Regional Office, National Marine Fisheries Service regarding Notice of Intent to Prepare Programmatic Environmental Impact Statement for Identification of Aquaculture Opportunity Areas in Federal Waters of the Gulf of Mexico
  • August 1 - Comments to Ms. Sara Guiltinan, Pacific Regional Office, Bureau of Ocean Energy Management regarding the proposed sale notice of offshore wind leases in California’s Humboldt and Morro bays
  • June 28 - Comments to COL Stephen Murphy, Commander and District Engineer, New Orleans District, U.S. Army Corps of Engineers and CAPT Kelly Denning, Commander, Sector New Orleans, U.S. Coast Guard regarding Navigation Safety Risk Assessment for CEMUS, LLC Permit
  • June 27 - Comments to RDML Wayne Arguin, Assistant Commandant for Prevention Policy U.S. Coast Guard, regarding Electronic Chart and Navigational Equipment Carriage Requirements
  • June 24 - Comments to Ms. Bridgette Duplantis, Office of Leasing and Plans, Bureau of Ocean Energy Management regarding Commercial Leasing for Wind Power Development on the Central Atlantic Outer Continental Shelf
  • June 23 - Comments to Dr. Whitney Hauer, Renewable Energy Specialist, Office of Strategic Resources, Bureau of Ocean Energy Management regarding Commercial Leasing for Wind Energy Development on the Outer Continental Shelf (OCS) Offshore Oregon
  • June 8 - Comments to California Senate Budget Committee Chair Nancy Skinner, Assembly Budget Committee Chair Philip Ting, Senate Budget Subcommittee Chair Bob Wieckowski, and Assembly Budget Subcommittee Chair Richard Bloom regarding Proposed 2022-2023 Budget to Transition Commercial Harbor Craft Vessels to Low, Zero and Near-Zero Emissions
  • June 3 - Comments to Chair Liane Randolph, California Air Resources Board regarding proposed amendments to the Commercial Harbor Craft (CHC) regulation
  • May 16 - Comments to LTJG Thomas Davis, U.S. Coast Guard - First District regarding Port Access Route Study: Approaches to Maine, New Hampshire, and Massachusetts
  • May 13 - Comments to Ms. Jean Thurston-Keller, California Intergovernmental Renewable Energy Task Force Coordinator, Office of the Environment, BOEM regarding Morro Bay Wind Energy Area Draft Environmental Assessment
  • April 28 - Comments to Ms. Lauren Smith, Sound Transit, regarding the West Seattle and Ballard Link Extensions draft Environmental Impact Statement
  • April 25 - Comments to the Honorable Pete Buttigieg, Secretary, Department of Transportation, regarding a proposed amendment of transportation industry drug testing program regulations to include oral fluid testing
  • April 25 - Comments to Mr. Matthew Creelman, U.S. Coast Guard Fifth District, regarding Port Access Route Study: Seacoast of North Carolina
  • April 18 - Comments to LCDR Sarah Krolman, U.S. Coast Guard, regarding the final programmatic environmental impact statement for the Waterways Commerce Cutters
  • March 24 - Comments to Chair Liane Randolph, Harbor Craft California Air Resources Board regarding Proposed Regulations for Commercial Harbor Craft
  • March 7 - Comments to Mr. William Cody, Secretary, Federal Maritime Commission regarding conditions created by Canadian ballast water regulations in the U.S./Canada Great Lakes Trade
  • February 28 - Comments to Kirk Sunderman, Project Engineer – Brandon Road Interbasin Project, Inland Navigation Design Center, US Army Corps of Engineers regarding Brandon Road Interbasin Project - Engineered Channel Layout - Final Draft Engineering Evaluation Report
  • February 5 - Comments to Ms. Jean Thurston-Keller, California Intergovernmental Renewable Energy Task Force Coordinator, BOEM, Office of Strategic Resources regarding Humboldt Wind Energy Area Draft Environmental Assessment
  • January 25 - Comments to LCDR Sara Conrad, Pacific Area (PAC-54), U.S. Coast Guard regarding the U.S. Coast Guard’s notification of study for the Pacific Coast Port Access Route Study
  • January 10 - Comments to Ms. Jean Thurston-Keller, California Intergovernmental Renewable Energy Task Force Coordinator, BOEM, Office of Strategic Resources regarding Morro Bay Wind Energy Area Environmental Assessment Scoping
2021 Comments, Letters and Testimony
  • December 21 - Comments to Mr. Ryan Johnson, U.S. Army Corps of Engineers, Chicago District regarding USACE Draft EA for the Chicago Area Waterway System
  • November 15 - Comments to Ms. Liane Randolph, Chair c/o Harbor Craft California Air Resources Board regarding Proposed Regulations for Commercial Harbor Craft in California
  • November 8 - Comments to LCDR Sarah Krolman, U.S. Coast Guard Headquarters regarding Waterways Commerce Cutter Acquisition Program; Preparation of a Programmatic Environmental Impact Statement
  • October 5 - Comments to Rear Admiral John Mauger, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding Coast Guard Programs, Regulations, and Policies for Addressing Climate Change
  • September 30 - Comments to Mr. Alex Hess, Maritime Risk Lead, Department of Ecology, State of Washington regarding Tug Escort Analysis - Scope of Work
  • September 30 - Comments to Mr. Alex Hess, Maritime Risk Lead, Department of Ecology, State of Washington regarding Emergency Response Towing Vessel Analysis - Scope of Work
  • September 28 - Comments to MST2 Monika Spies, Waterways Management Division, Sector Upper Mississippi River, U.S. Coast Guard regarding Missouri River Waterways Analysis and Management System
  • September 13 - Comments to Ms. Jean Thurston-Keller, California Intergovernmental Renewable Energy Task Force Coordinator, BOEM, Office of Strategic Resources regarding call for information and nominations for the proposed extensions at Morro Bay
  • August 3 - Comments to The Honorable Pete Buttigieg, Secretary, U.S. Department of Transportation regarding support for the Paducah-McCracken County Riverport Authority’s application for the Port Infrastructure Development Program
  • August 3 - Comments to The Honorable Jenny Durkan, Mayor; The Honorable Lorena Gonzalez, City Council President; City Councilmembers; and Mr. Adrian Diaz, Chief of Police, Seattle, WA regarding reduced numbers of Seattle Harbor Patrol personnel
  • July 16 - Comments to CAPT Maureen Kallgren, U.S. Coast Guard Fifth District regarding Port Access Route Study: Approaches to the Chesapeake Bay, Virginia
  • July 14 - Comments to Ms. Lucinda Lessley, Acting Administrator, Maritime Administration, U.S. Department of Transportation opposing the application for a foreign-built motor barge for coastwise trading endorsement
  • June 30 - Comments to LTJG Katie Matha, U. S. Coast Guard, Thirteenth District regarding Waterways Analysis and Management System Study of the Columbia River Entrance
  • June 11 - Comments to LCDR Sarah Krolman, U.S. Coast Guard regarding the scoping process of the Programmatic Environmental Impact Statement for the Waterways Commerce Cutter program
  • June 2 - Memo to state and federal partners regarding ESHB 1578 Tug Escort Implementation Framing Safety Risk Management
  • May 25 - Comments to BG Peter D. Helmlinger, Commander, Northwestern Division, U.S Army Corps of Engineers regarding Draft Fort Peck Dam Test Flow Release Environmental Impact Statement
  • May 7 - Comments to Lieutenant General Scott A. Spellmon, Chief of Engineers, U.S. Army Corps of Engineers regarding WRDA 2020 Sec. 129 Implementation
  • April 30 - Comments to Ms. Bonnie Soriano, Chief, Freight Activity Branch, Transportation and Toxics Division, California Air Resources Board regarding Proposed Amendments to the Regulations to Reduce Emissions from Diesel Engines On Commercial Harbor Craft Operated Within California Waters and 24 Nautical
  • April 27 - Comments to Mr. Peterson Vollmann, Planner IV, City of Oakland Bureau of Planning regarding Draft Environmental Impact Report (EIR) for the Oakland Waterfront Ballpark District Project
  • April 14 - Comments to General Stephen R. Lyons, Commander, United States Transportation Command regarding acquisition policy for coastwise/noncontiguous vessel carriage of Dept. of Defense cargoes 
  • March 15 - Comments to The Honorable Pete Buttigieg, Secretary, U.S. Department of Transportation regarding Washington Department of Transportation’s application for 2021 INFRA federal discretionary grant funding for the Salmon Bay Bridge Rehabilitation Project
  • March 9 - Comments to LT David Lieberman, Office of Navigation Systems, U.S. Coast Guard regarding Shallow Draft Waterways Analysis and Management System Study
  • February 22 - Comments to Ms. Christine Kluge, Department of Fish and Wildlife, Office of Spill Prevention and Response regarding Notice of Proposed Rulemaking: Non-tank Vessel Fee Increase
  • February 5 - Comments to Mr. Ryan Johnson, U.S. Army Corps of Engineers, Chicago District regarding USACE Scoping for Chicago Area Waterway System NEPA Document
2020 Comments, Letters and Testimony
  • December 11 - Comments to Ms. Christine Kluge, Department of Fish and Wildlife, Office of Spill Prevention and Response regarding Clarification of Convention (GT ITC) and Regulatory (GRT) Tonnage Measurement Systems to U.S. Flag Towing Vessels
  • December 11 - Comments to Mr. BJ Murray, Illinois Department of Transportation regarding the Draft 2020 Illinois Marine Transportation System Plan and Economic Analysis
  • November 24 - Comments to  Mr. D. Lee Forsgren, Jr., Deputy Assistant Administrator, Office of Water, U.S. Environmental Protection Agency regarding Vessel Incidental Discharge National Standards of Performance
  • November 18 - Comments to BG Peter D. Helmlinger, Commander, Northwestern Division, U.S. Army Corps of Engineers regarding Missouri River Mainstem System 2020-2021 Draft Annual Operating Plan
  • November 9 - Comments to Mr. Eugene D. Hayes, Substance Abuse and Mental Health Services Administration, Center for Substance Abuse Prevention regarding Mandatory Guidelines for Federal Workplace Drug Testing
  • October 30 - Comments to Mr. David C. Quiros, Manager, Freight Technology Section, Transportation and Toxics Division regarding Proposed Amendments to the Commercial Harbor Craft Regulation in California
  • October 23 - Comments to Mr. Matthew A. Konfirst, Administrator, U.S. Environmental Protection Agency Mid-Atlantic Region regarding City of Annapolis and Anne Arundel County Vessel Sewage No-Discharge Zone
  • October 13 - Comments to ADM Karl L. Schultz, Commandant, U.S. Coast Guard regarding Integration of Automated and Autonomous Commercial Vessels and Vessel Technologies Into the Maritime Transportation System
  • September 14 - Comments to Ms. Christine Kluge, Department of Fish and Wildlife, Office of Spill Prevention and Response regarding Proposed Rulemaking to Adopt New Regulations for the Certification of Spill Management Teams and Amend Regulations for Contingency Plans
  • September 3 - Comments to the Committee on Equitable Allocation of Vaccine for the Novel Coronavirus, National Academy of Medicine, National Academies of Sciences, Engineering, and Medicine regarding the Discussion Draft of the Preliminary Framework for Equitable Allocation of COVID-19 Vaccine
  • August 20 - Comments to The Honorable Andrew R. Wheeler, Administrator, U.S. Environmental Protection Agency regarding Total Maximum Daily Load for Temperature in the Columbia and Lower Snake Rivers
  • August 18 - Comments to Rear Admiral Richard Timme, Assistant Commandant for Prevention Policy, U.S. Coast Guard regarding ANPRM for Shipping Safety Fairways Along the Atlantic Coast
  • August 17 - Comments to Colonel Aaron Reisinger, Commander, U.S. Army Corps of Engineers, Chicago District regarding Chicago Area Waterways System Dredged Material Management Plan
  • August 13 - Comments to The Honorable Andrew R. Wheeler, Administrator, U.S. Environmental Protection Agency regarding Increasing Consistency and Transparency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process
  • 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