Monday, March 21, 2011

Small Vessel Security - Expanded HIN Rulemaking Withdrawn

On February 11, 2011, in Federal Register Volume 76, Number 29, the Coast Guard announced its decision to not initiate a rulemaking addressing an expanded hull identification number (HIN) for recreational vessels. The Coast Guard had requested comments on the costs and benefits of expanding the existing 12-character HIN in order to provide additional information identifying vessels, and received 29 comments. The Coast Guard made its decision based on consideration of the comments received as well as the challenges from data uncertainty in describing, estimating, and quantifying potential costs and benefits of such a rulemaking. The Federal Register notice stated, In addition to seeking information from the public on an expanded HIN proposal, the Coast Guard also performed its own evaluation of the potential costs and benefits of such a proposal. The Coast Guard found a lack of available data regarding potential costs and benefits.

The notice states in conclusion: “ At this time, the Coast Guard has decided that it is in the best interest of the public and the boating safety community to focus its attention and devote its resources to other regulatory actions. If the Coast Guard decides in the future to reconsider an expanded HIN, we will provide notice in a new Federal Register publication.”

The National Association of State Boating Law Administrators, NASBLA, is among the groups supporting the expanded HIN, stating that it will aid law enforcement officers in quick identification of correctly registered vessels by the type of vessel, hull material, length of vessel, propulsion and fuel type. Through use of the added characters, including a check or verifying digit, our officers on the water will be better able to properly identify suspicious vessels in and around security zones.”

The National Marine Manufacturers Association, which describes itself as “a powerful voice for the recreational boating industry,” is among the groups opposing the expanded HIN, stating that the expanded HIN would “ impose excessive costs on boat builders, and the marine industry as a whole including marine bankers, dealers and distributors and yield no improvement to boating safety.”

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