![](media/image1.jpeg){width="0.9583333333333334in"
height="0.8125in"}[**E.N. BISSO & SON, INC. HARBOR TUGS -- OFFSHORE
TOWING -- HEAVY LIFT DERRICK**]{.underline}

Corporate Office: 3939 N. Causeway Blvd., Suite 401, Metairie, LA 70002
Tel. (504) 828-3296 Fax (504) 831-6701

Operations Office: Foot of Walnut St., New Orleans, LA 70118 Tel. (504)
861-3551 Fax: (504) 861-1403

[BY U.S. MAIL AND ELECTRONIC SUBMISSION]{.underline}

April 25, 2007

Docket Management Facility

U.S. Department of Transportation

Room PL-401

400 Seventh Street, S.W.

Washington, DC 20590-0001

> Re: Docket No.: USCG-2006-24371; *Consolidation of Merchant Mariner
> Qualification Credentials*; 72 Fed R. 3605 (Jan. 27, 2007)

Dear Sir:

E.N. Bisso & Son, Inc. ("E.N. Bisso") appreciates the opportunity to
comment on the Supplemental Notice of Proposed Rulemaking ("SPRM")
addressing the proposed consolidation of merchant mariner qualification
credentials. E.N. Bisso is a New Orleans based tugboat company, with 16
vessels and about 140 employees, most of whom are mariners. Our primary
business is assisting ocean-going vessels safely in and out of berths
and anchorages, and escorting those vessels for safety and security
purposes. A secondary segment of our business is the offshore towing of
seagoing barges, sometimes to foreign destinations, and tug support for
offshore oil exploration and exploitation in the Gulf of Mexico.

After a careful review of the SPRM, E.N. Bisso has these specific
points:

1.  E.N. Bisso agrees with the need for properly identifying and
    credentialing mariners because it is critical to the safe operation
    of vessels as well as national security.

2.  The issuance---indeed the form---of the Transportation Worker
    Identification Credential ("TWIC"), which is supposed to address the
    national security aspects of a mariner's identity under the auspices
    of the Transportation Security Administration ("TSA") is not yet a
    practical reality. Thus, the Coast Guard's SPRM may be pre-mature.
    The MMC, as proposed, is meant to consolidate the current license,
    Merchant Mariner's Document ("MMD"), Certificate of Registry and
    STCW certificate into one all-purpose document. The MMC can only be
    issued after the TWIC's application or issuance, since without
    holding a TWIC (or at least having applied for one), the MMC would
    not be valid. Hence, the TWIC's well-documented rollout problems
    will likely interfere with the timeline for the creation and
    issuance of the first MMC's by August 2008. E.N. Bisso agrees with
    the Merchant Marine Personnel Advisory Committee ("MERPAC") that the
    implementation of the MMC be delayed until the TWIC is a proven
    credential. Once the TWIC is proven, then the phase-in process as
    described by the Coast Guard should then commence.

3.  The U.S. Coast Guard proposes that its Merchant Marine Credential
    ("MMC") would only address the competency of the mariner since the
    TSA would be solely responsible for vetting a mariner's identity and
    background checks. This undermines the principle that the Coast
    Guard must be vigilant in its issuance of its credentials.

4.  The SPRM does not decide whether the MMC should be issued in as a
    passport-sized bound volume, as a certificate or some other format.
    However, the SPRM does state that the Coast Guard rejected the
    proposal that the TWIC and MMC be combined as one document to
    establish a mariner's identity and competence. Thus, the mariner
    will still have to carry multiple credentials and documents. For
    example, those mariners who work on towing vessels offshore will
    need to carry a passport and required training records---*i.e.* a
    Towing Officers' Assessment Record ("TOAR") and/or STCW Training
    Record Book ("TRB") to show proof of competency of the towing vessel
    tasks in the TOAR as well as any relevant STCW practical
    assessments. Thus, the synergetic effect of the Coast Guard's
    proposed consolidation of the mariner's credentials is somewhat
    diluted.

5.  Assuming that a mariner's proof of competency is best served by a
    single document, the Coast Guard's stated intent in the SPRM that
    MMC's be issued by mail (or in person if an applicant so chooses)
    when there is no requirement for an examination is laudable.

6.  A passport-sized and style booklet may be the most practical format
    for the proposed MMC. However, we recommend that the Coast Guard
    consider issuing a licensed mariner (who makes an appropriate
    request) a certificate suitable for framing similar to the
    present-day license (but which is not intended to be a MMC) listing
    the nature of the mariner's licensure. Furthermore, in E.N. Bisso's
    opinion, the proposed formats that were posted to the docket do not
    satisfy the notice and comment requirement as they were neither
    displayed in nor referenced in the SPRM. That being said, E.N. Bisso
    believes that the passport style is preferable to the proposed
    certificate(s).

7.  E.N. Bisso agrees with the changes to the previously-stated rule
    that invalidation of a TWIC automatically invalidated the
    holder's MMC. Absent due process, automatic revocation of the
    credential is inappropriate. However, a temporary suspension may be
    a proper method of ensuring that mariners be correctly credentialed
    and accurately identified.

Thank you for the opportunity to comment.

Sincerely yours,

/s/

Michael F. Vitt

General Counsel

cc: file