Thursday, October 3, 2013

2nd Coast Guard Stay of CDC Barge Reporting

As expected the Commander of the Ninth Coast Guard District (essentially the Great Lakes Region) published a notice in today’s Federal Register (78 FR 61183-61185) announcing the same stay of the Certain Dangerous Cargo (CDC) Barge reporting requirements that was announced on Tuesday for the 8th Coast Guard District.

I did not specifically mention this in the earlier post, but the standard comment and response process is not required for these actions because they are removing a regulatory requirement so they are lessening the burden on the ‘affected’ population. This never triggers a comment and response requirement.

Unfortunately, this fails to take into account the counter-terrorism reason for these reporting requirements and the apparent fact that the reduced ability of the Coast Guard to track these barges makes it easier for successful terrorist attacks to be executed against them (though it does remove one of the ways that terrorists might have been able to track their location).

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