requirements     services which
                                                                                will not         requires an
                                                                                change for       additional
                                                                                OSVs less than   mate.
                                                                                6,000 GT ITC.
Engineers....................  15.825.......  NOSAC            Requirements     Amends existing  No additional
                                               recommendation.  for the          Coast Guard      cost. Similar
                                                                minimum number   regulation by    sized vessels,
                                                                of assistant     requiring        such as 100%
                                                                engineers were   large OSVs       of OSVs
                                                                derived from     approved for     between 5,000
                                                                existing Coast   the use of       and 6,000 GT
                                                                Guard            automated        ITC, are
                                                                regulations      systems to       already
                                                                (46 CFR          carry at least   meeting this
                                                                15.825).         one assistant    requirement in
                                                                                engineer, as     order to
                                                                                recommended by   provide
                                                                                NOSAC.           services more
                                                                                typically
                                                                                performed by
                                                                                tank and cargo
                                                                                vessels.
----------------------------------------------------------------------------------------------------------------

                       Table 5--Changes to 46 CFR Part 61--Periodic Tests and Inspections
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Test procedure details.......  61.40-10.....  Administrative   Requirements in  Other test       No additional
                                               change of        existing CFR     techniques       cost as this
                                               Coast Guard      originally       must now be      is
                                               approval to      called for       approved by      administrative
                                               the Marine       other test       the Commanding   .
                                               Safety Center.   techniques to    Officer of the
                                                                be approved by   Marine Safety
                                                                the Commandant   Center.
                                                                of CG-ENG.
----------------------------------------------------------------------------------------------------------------

                           Table 6--Changes to 46 CFR Part 62--Vital System Automation
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Applicability................  62.01-5......  Change to        Requirements     Adds large OSVs  No additional
                                               clarify          for vital        to list of       cost. Similar
                                               applicability    system           vessels that     sized existing
                                               to include       automation       must comply      vessels, such
                                               large OSVs.      were derived     with existing    as 100% of
                                                                from existing    requirements     OSVs between
                                                                Coast Guard      in 46 CFR part   5,000 to 6,000
                                                                regulations.     62.              GT ITC,
                                                                                voluntarily
                                                                                agreed to be
                                                                                certificated
                                                                                by
                                                                                classification
                                                                                societies and
                                                                                participate in
                                                                                the Alternate
                                                                                Compliance
                                                                                Program (ACP).
                                                                                While there
                                                                                are some gaps
                                                                                between class
                                                                                rules and the
                                                                                provisions in
                                                                                46 CFR part
                                                                                62, they are
                                                                                closed through
                                                                                supplemental
                                                                                provisions
                                                                                required of
                                                                                vessels
                                                                                operating
                                                                                under the ACP.
----------------------------------------------------------------------------------------------------------------

                             Table 7--Changes to 46 CFR Part 90--General Provisions
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Applicability to OSVs........  90.05-20.....  Defines          Not Applicable.  Not Applicable.  No additional
                                               applicability                                      cost.
                                               of Subchapter                                      Definition.
                                               I for existing
                                               OSVs.
Definitions of offshore        90.10-40.....  Defines new and  Not Applicable.  Not Applicable.  No additional
 supply vessels.                               existing OSVs.                                     cost.
                                                                                Definition.
----------------------------------------------------------------------------------------------------------------

                             Table 8--Changes to 46 CFR part 110--General Provisions
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Incorporation by reference...  110.10-1.....  Incorporates     Requirements     Amends existing  No additional
                                               industry         for electrical   Coast Guard      cost. Similar
                                               standards into   engineering      regulation by    sized existing
                                               Title 46.        within           codifying        vessels, such
                                                                hazardous        alternative      as 100% of
                                                                locations were   industry         OSVs between
                                                                derived from     accepted         3,000 to 6,000
                                                                existing Coast   standards,       GT ITC,
                                                                Guard            which have       voluntarily
                                                                regulations      been approved    agreed to be
                                                                (46 CFR 110.10-  for similar      certificated
                                                                1).              large vessels.   by
                                                                                classification
                                                                                societies and
                                                                                participate in
                                                                                the ACP, whose
                                                                                rules align
                                                                                with the
                                                                                requirements
                                                                                in 46 CFR
                                                                                110.10-1.
                                                                                Provides
                                                                                industry with
                                                                                flexibility by
                                                                                incorporating
                                                                                alternative
                                                                                industry
                                                                                standards.
Definitions..................  110.15-1.....  Introduces       Not Applicable.  Not Applicable.  No additional
                                               definitions                                        cost.
                                               used in 110.25-                                    Definition.
                                               1.
Plans and information          110.25-1.....  Requirement for  Requirements     Clarifies        Potential cost
 required for new                              plans that       for hazardous    information      savings. This
 construction.                                 identify         locations in     required in      information
                                               hazardous        new builds       plans for OSVs   was already
                                               location         were derived     of at least      required of
                                               information.     from existing    6,000 GT ITC.    existing
                                                                Coast Guard      Requires plan    plans, but was
                                                                regulations      to include       often not
                                                                (46 CFR 110.25-  equipment        provided until
                                                                1).              identification   follow up
                                                                                number,          reviews. This
                                                                                equipment use,   provision will
                                                                                parameters of    expedite the
                                                                                systems,         process by
                                                                                equipment        more
                                                                                locations,       explicitly
                                                                                installation     delineating
                                                                                details, and     the required
                                                                                certificate of   information up
                                                                                testing.         front.
----------------------------------------------------------------------------------------------------------------

                   Table 9--Changes to 46 CFR Part 111--Electric Systems General Requirements
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Flammable or Combustible       111.05-20....  Specifies        Requirements     None...........  No additional
 liquids and grounded                          ground           for ground                        cost.
 distribution systems on OSVs.                 distribution     distribution                      Incorporates
                                               system           system were                       international
                                               requirement..    derived from                      and Coast
                                                                existing                          Guard
                                                                international                     standards
                                                                standards and                     expected to be
                                                                Coast Guard                       used given
                                                                regulations                       industry
                                                                (SOLAS and 46                     practice and
                                                                CFR 111.05-19).                   desire to
                                                                                compete for
                                                                                work in
                                                                                international
                                                                                markets.
Hazardous Locations on OSVs..  111.106-1,     Requires owners  Requirements     There are no     No additional
                                111.106-3,     of OSVs with     for electrical   deviations       cost. Provides
                                111.106-5,     hazardous        installations    from standard    flexibility by
                                111.106-7,     locations to     inside           if the vessel    allowing
                                111.106-9,     choose a         hazardous        follows the      choice of
                                111.106-11,    standard that    locations were   national         standards
                                111.106-13,    addresses the    derived from     standard.        expected to be
                                111.106-15,    wide ranging     existing         However, two     used given
                                and 111.106-   services that    national and     changes were     current
                                17.            the vessel       international    made to the      industry
                                               performs.        standards        international    practice and
                                                                (National        standard. The    desire to
                                                                Electric Code    first change     compete for
                                                                standards and    appears in       work in
                                                                International    111.106-9, and   international
                                                                Electrotechnic   enlarges Zone    markets.
                                                                al Commission    1 to an area
                                                                60092-505).      of 8-meters.
                                                                                The other
                                                                                modification
                                                                                to the
                                                                                international
                                                                                standard is
                                                                                made in
                                                                                111.106-13
                                                                                (b). This
                                                                                modification
                                                                                will not allow
                                                                                enclosed
                                                                                spaces to be
                                                                                reclassified
                                                                                based upon
                                                                                mechanical
                                                                                ventilation..
                                                               Requirements     None...........  No additional
                                                                for cable and                     cost.
                                                                wiring between                    Incorporates
                                                                machinery                         international
                                                                spaces and                        and Coast
                                                                hazardous                         Guard
                                                                locations were                    standards
                                                                derived from                      expected to be
                                                                existing                          used given
                                                                international                     current
                                                                and Coast                         industry
                                                                Guard                             practice and
                                                                regulations                       desire to
                                                                (International                    compete for
                                                                Electrotechnic                    work in
                                                                al Commission                     international
                                                                60092-505 and                     markets.
                                                                46 CFR 153.461
                                                                and 154.1205).
----------------------------------------------------------------------------------------------------------------

                                  Table 10--Changes to 46 CFR part 125--General
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Applicability................  125.100......  Requirement      Not Applicable.  Not Applicable.  No additional
                                               directed by                                        cost.
                                               the Act.                                           Administrative
                                                                                to meet
                                                                                statutory
                                                                                mandate.
Tonnage Measurement..........  125.103......  Administrative   Not Applicable.  Not Applicable.  No additional
                                               changes made                                       cost.
                                               by the Coast                                       Administrative
                                               Guard to                                           to meet
                                               implement the                                      statutory
                                               Act.                                               mandate.
International certificates     125.105......  Requires large   Requires OSVs    None...........  No additional
 for OSVs of at least 6,000                    OSV to obtain    to hold                           cost.
 GT ITC.                                       international    certificates                      Incorporates
                                               certificates     that signify                      international
                                               that indicate    compliance                        standard
                                               compliance       with                              expected to be
                                               with SOLAS,      international                     used given
                                               MARPOL, and      standards                         industry
                                               ICLL.            (SOLAS--Cargo                     practice and
                                                                Ship Safety                       desire to
                                                                Construction,                     compete for
                                                                Cargo Ship                        work in
                                                                Safety                            international
                                                                Equipment and                     markets.
                                                                Safety                            Similar sized
                                                                Management                        existing
                                                                Certificates;                     vessels, such
                                                                MARPOL--Intern                    as 100% of
                                                                ational Oil                       OSVs 3,000 to
                                                                Pollution                         6,000 GT ITC,
                                                                Prevention and                    voluntarily
                                                                International                     agreed to
                                                                Air Pollution                     comply with
                                                                Prevention;                       the
                                                                ICLL--Internat                    requirements
                                                                ional Load                        in this
                                                                Line                              provision in
                                                                Certificate.                      order to
                                                                                compete in
                                                                                international
                                                                                markets.
Carriage of flammable or       125.110......  Requires         Double hull      None...........  Any changes in
 combustible liquid cargoes                    carriage of      (oil cargo                        the cargo
 in bulk.                                      oil on large     tank offset)                      capacity and
                                               OSVs to meet     requirements                      configuration
                                               existing Title   were derived                      can be
                                               33               from existing                     accommodated
                                               requirements.    Coast Guard                       in the design
                                                                regulations                       stage of the
                                                                (33 CFR                           new vessel
                                                                157.10d).                         with no or
                                                                                minimal, non-
                                                                                quantifiable
                                                                                cost.\13\
Oil fuel tank protection.....  125.115......  Requirement      Requirements     Deviates from    No additional
                                               directed by      for oil fuel     existing         cost. Similar
                                               the Act.         tank             international    sized existing
                                                                protection       standard by      vessels, such
                                                                were derived     requiring        as 100% of
                                                                from existing    compliance       OSVs 3,000 to
                                                                international    without          6,000 GT ITC,
                                                                standards        regards to       already comply
                                                                (MARPOL Annex    whether the      with the
                                                                I--Regulation    OSV will be      requirements
                                                                12A).            engaged in       in this
                                                                                coastwise or     provision.
                                                                                international
                                                                                trade.
Carriage of noxious liquid     125.120 and    Administrative-  Requirements     Deviates from    No additional
 substances in bulk by OSVs     125.125.       -sets            for carriage     existing         cost.
 less than 6,000 GT ITC (500                   applicability    of noxious       international    Incorporates
 GRT if GT ITC is not                          for carriage     liquid           standards by     interpretation
 assigned) and least 6,000 GT                  of NLS in bulk   substances in    codifying        of
 ITC (500 GRT if GT ITC is                     to demarcation   bulk were        parts of CG-     international
 not assigned).                                requirements     derived from     522 Policy       standard from
                                               and              existing         Letter 09-01,    existing
                                               incorporates     international    Rev. 1, which    policy letter.
                                               existing 46      standards and    was published    This will
                                               CFR 98.30 and    Coast Guard      April 5, 2010.   create
                                               interpretation   regulations      These            flexibility
                                               of IMO Res       (MARPOL Annex    modifications    for large OSVs
                                               A.673 from CG-   II, IMO          will allow       where they
                                               522 Policy       Resolution       applicable       might
                                               Letter 09-01.    A.673(16), and   vessels carry    otherwise have
                                                                33 CFR part      NLS in bulk in   been deemed in
                                                                151 and 46 CFR   its integral     violation of
                                                                part 163).       and fixed        MARPOL Annex
                                                                                independent      II.
                                                                                tanks.
Loadlines....................  125.140......  Requires large   Requirements     None...........  No additional
                                               OSVs to be       for load lines                    cost.
                                               assigned an      were derived                      Incorporates
                                               international    from existing                     international
                                               load line in     international                     standard
                                               accordance       standards                         expected to be
                                               with the ICLL.   (International                    used given
                                                                Convention of                     industry
                                                                Load Lines).                      practice and
                                                                                desire to
                                                                                compete for
                                                                                work in
                                                                                international
                                                                                markets.
Lifesaving systems...........  125.150......  Requires large   Lifesaving       None...........  No additional
                                               OSVs to meet     requirements                      cost.
                                               existing         for OSVSs of                      Incorporates
                                               lifesaving       at least 6,000                    international
                                               requirements     GT ITC were                       standard and
                                               of Title 46      derived from                      requirements
                                               CFR and SOLAS.   existing                          for similar
                                                                international                     vessels
                                                                standards and                     expected to be
                                                                Coast Guard                       used given
                                                                regulations                       industry
                                                                (SOLAS and 46                     practice and
                                                                CFR 199).                         desire to
                                                                                compete for
                                                                                work in
                                                                                international
                                                                                markets.
                                                                                Similar sized
                                                                                existing
                                                                                vessels, such
                                                                                as 100% of
                                                                                OSVs 3,000 to
                                                                                6,000 GT ITC,
                                                                                voluntarily
                                                                                agreed to
                                                                                comply with
                                                                                the
                                                                                requirements
                                                                                in this
                                                                                provision in
                                                                                order to
                                                                                compete in
                                                                                international
                                                                                markets.
----------------------------------------------------------------------------------------------------------------

---------------------------------------------------------------------------

    \13\ Impact is negligible because the carriage of oil-based mud
is also covered by requirements for the carriage of noxious liquid
substances (46 CFR 125.120). Because of the various chemical
components within the muds, nearly all mud carried by larger OSVs is
authorized only if the vessel complies with international pollution
prevention standards (IMO Resolution A.673(16)), which already
requires minimum distances for cargo from the outer hull.

                       Table 11--Changes to 46 CFR Part 126--Inspection and Certification
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of  Deviation  from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Carriage of offshore workers.  126.170......  Increases large  Existing         Modifies         No additional
                                               OSV carriage     regulation       existing SPS     cost. Provides
                                               capacity of      precludes        Code by          industry
                                               offshore         carriage of      requiring        flexibility by
                                               workers.         more than 36     vessels          continuing to
                                                                offshore         authorized to    allow vessels
                                                                workers. In      carry more       authorized to
                                                                removing this    than 36          carry less
                                                                ban,             offshore         than 36
                                                                requirements     workers to       offshore
                                                                for the          carry the        workers to
                                                                carriage of      minimum amount   meet standards
                                                                offshore         of primary       required of a
                                                                workers were     lifesaving for   cargo vessel.
                                                                derived from     cargo vessel     Creates
                                                                existing         equipment as     opportunity
                                                                international    defined in       for vessels to
                                                                standards (IMO   SOLAS.           carry more
                                                                Code of Safety                    than 36
                                                                for Special                       offshore
                                                                Purpose Ships                     workers, but
                                                                (SPS Code)).                      would require
                                                                                increasing
                                                                                protection
                                                                                using
                                                                                internationall
                                                                                y accepted
                                                                                approach to
                                                                                offset growing
                                                                                potential
                                                                                consequence.
                                                                                For vessels
                                                                                authorized to
                                                                                carry more
                                                                                than 36
                                                                                offshore
                                                                                workers, the
                                                                                Coast Guard
                                                                                would require
                                                                                the vessel
                                                                                design meet a
                                                                                standard that
                                                                                is between the
                                                                                standard
                                                                                required of
                                                                                cargo vessels
                                                                                and that of
                                                                                passenger
                                                                                vessels. This
                                                                                flexibility
                                                                                takes into
                                                                                account the
                                                                                attributes and
                                                                                skill-sets of
                                                                                the
                                                                                passengers,
                                                                                and offers
                                                                                OSVs a less
                                                                                stringent
                                                                                standard as a
                                                                                result.
----------------------------------------------------------------------------------------------------------------

                       Table 12--Changes to 46 CFR Part 127--Construction and Arrangements
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of  Deviation  from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Classification Society         127.200......  Requires OSVs    Meeting          None...........  No additional
 Standards.                                    be classed by    classification                    cost.
                                               an authorized    society                           Incorporates
                                               class society.   requirements                      industry &
                                                                is consistent                     international
                                                                with existing                     standards
                                                                international                     expected to be
                                                                standards                         used given
                                                                (SOLAS Chapter                    industry
                                                                II-1,                             practice and
                                                                Regulation 3-                     desire to
                                                                1) and                            compete for
                                                                existing Coast                    work in
                                                                Guard                             international
                                                                regulations                       markets.
                                                                (46 CFR 8.320).                   Similar sized
                                                                                existing
                                                                                vessels, such
                                                                                as 100% of
                                                                                OSVs 3,000 to
                                                                                6,000 GT ITC,
                                                                                voluntarily
                                                                                agreed to
                                                                                comply with
                                                                                the
                                                                                requirements
                                                                                in this
                                                                                provision in
                                                                                order to
                                                                                compete in
                                                                                international
                                                                                markets.
Structural fire protection...  127.225......  Requires SOLAS   Requirements     Deviates from    No additional
                                               compliance.      for structural   SOLAS by         cost.
                                                                fire             restricting      Incorporates
                                                                protection       large OSVs to    existing US
                                                                were derived     only use the     interpretation
                                                                from existing    non-             of
                                                                international    combustible      international
                                                                standards        materials        standard. An
                                                                (SOLAS).         (Method IC)      existing OSV
                                                                                option in        would already
                                                                                SOLAS. This is   be required to
                                                                                consistent       meet this
                                                                                with existing    requirement
                                                                                U.S.             under the
                                                                                regulations      existing
                                                                                for other        regulatory
                                                                                large vessels    regime if it
                                                                                (46 CFR          wished to
                                                                                subchapters D,   perform these
                                                                                H, and I).       services.
Subdivision and stability....  127.230......  Requires SOLAS   Subdivision and  Amends existing  No additional
                                               compliance.      stability        Coast Guard      cost. This
                                                                requirements     regulation (46   modification
                                                                were derived     CFR 127.230)     exempts large
                                                                from existing    by adding in     OSVs from
                                                                international    clause (b).      being required
                                                                standards and    This clause      to comply with
                                                                Coast Guard      exempts OSVs     this
                                                                regulations      of 80 meters     provision.
                                                                (SOLAS and 46    or more in
                                                                CFR 127.230).    length from
                                                                                being required
                                                                                to comply
                                                                                existing CFR
                                                                                stability
                                                                                requirement,
                                                                                since these
                                                                                large OSVs
                                                                                have to meet
                                                                                SOLAS
                                                                                stability
                                                                                requirements
                                                                                as described
                                                                                in 46 CFR
                                                                                125.105.

Construction and arrangements  127.600,       Requirements     Damage           None...........  No additional
 for OSVs carrying more than    127.620,       developed by     stability                         cost.
 36 offshore workers.           127.630,       the Coast        requirements                      Incorporates
                                127.640, and   Guard to         were derived                      existing
                                127.650.       provide safety   from existing                     international
                                               to persons in    international                     standards for
                                               addition to      standards                         given vessel
                                               the crew as      (SOLAS Chapter                    characteristic
                                               directed by      II-1, parts B-                    s and
                                               the Act.         1, B-2, and B-                    operations.
                                                                4, and                            Similar sized
                                                                Regulation II-                    existing
                                                                1/35-1).                          vessels, such
                                                                                as 100% of
                                                                                OSVs 3,000 to
                                                                                6,000 GT ITC,
                                                                                already comply
                                                                                with the
                                                                                requirements
                                                                                in this
                                                                                provision.
                                                               Marine           None...........  No additional
                                                                engineering                       cost.
                                                                requirements                      Incorporates
                                                                were derived                      existing
                                                                from                              international
                                                                international                     standards for
                                                                standards                         given vessel
                                                                (SOLAS                            characteristic
                                                                Regulation II-                    s and
                                                                1/<IP_ADDRESS>).                      operations.
                                                                                Similar sized
                                                                                existing
                                                                                vessels, such
                                                                                as 100% of
                                                                                OSVs 3,000 to
                                                                                6,000 GT ITC,
                                                                                voluntarily
                                                                                agreed to
                                                                                comply with
                                                                                the
                                                                                requirements
                                                                                in this
                                                                                provision in
                                                                                order to
                                                                                compete in
                                                                                international
                                                                                markets.
                                                               Electrical       None...........  No additional
                                                                installation                      cost.
                                                                requirements                      Incorporates
                                                                were derived                      existing
                                                                from                              international
                                                                international                     standards for
                                                                standards                         given vessel
                                                                (SOLAS                            characteristic
                                                                Regulation II-                    s and
                                                                1/42).                            operations.
                                                                                Similar sized
                                                                                existing
                                                                                vessels, such
                                                                                as 100% of
                                                                                OSVs 3,000 to
                                                                                6,000 GT ITC,
                                                                                voluntarily
                                                                                agreed to
                                                                                comply with
                                                                                the
                                                                                requirements
                                                                                in this
                                                                                provision in
                                                                                order to
                                                                                compete in
                                                                                international
                                                                                markets.
                                                               Fire-protection  None...........  No additional
                                                                requirements                      cost.
                                                                were derived                      Incorporates
                                                                from                              existing
                                                                international                     international
                                                                standards                         standards for
                                                                (SOLAS Chapter                    given vessel
                                                                II-2).                            characteristic
                                                                                s and
                                                                                operations.
                                                                                Similar sized
                                                                                existing
                                                                                vessels, such
                                                                                as 100% of
                                                                                OSVs 3,000 to
                                                                                6,000 GT ITC,
                                                                                voluntarily
                                                                                agreed to
                                                                                comply with
                                                                                the
                                                                                requirements
                                                                                in this
                                                                                provision in
                                                                                order to
                                                                                compete in
                                                                                international
                                                                                markets.
----------------------------------------------------------------------------------------------------------------

                 Table 13--Changes to 46 CFR Part 128--Marine Engineering: Equipment and Systems
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Equipment and systems........  128.110......  Incorporates     Marine           Removes OSVs of  No additional
                                               requirements     engineering      at least 6,000   cost. Similar
                                               of existing 46   requirements     GT ITC from      sized existing
                                               CFR Subchapter   for equipment    being exempt     vessels, such
                                               F.               and systems      from having to   as 100% of
                                                                for large OSVs   comply with      OSVs between
                                                                were derived     the              3,000 and
                                                                from existing    requirements     6,000 GT ITC,
                                                                Coast Guard      in 46            voluntarily
                                                                regulations      Subchapter F     agreed to be
                                                                (46 CFR          in their         certificated
                                                                Subchapter F).   entirety.        by
                                                                                classification
                                                                                societies
                                                                                whose rules
                                                                                align with the
                                                                                revised
                                                                                requirements
                                                                                in Subchapter
                                                                                F.
Fuel.........................  128.310......  Incorporates     Fuel             Modifies         No additional
                                               requirements     requirements     existing         cost. Similar
                                               of existing 46   were derived     provision by     sized existing
                                               CFR Subchapter   from existing    requiring        vessels, such
                                               F and SOLAS.     Coast Guard      large OSVs to    as 100% of
                                                                regulations      use fuel         OSVs between
                                                                (46 CFR          having a         3,000 and
                                                                128.310).        flashpoint of    6,000 GT ITC,
                                                                                at least         voluntarily
                                                                                60[deg] C        agreed to
                                                                                (140[deg] F),    comply with
                                                                                instead of       SOLAS and the
                                                                                being required   higher
                                                                                to meet the      flashpoint
                                                                                existing         requirement in
                                                                                standard,        order to
                                                                                which will       obtain
                                                                                still be used    international
                                                                                for OSVs under   certifications
                                                                                6,000 GT ITC,    .
                                                                                of 43[deg] C
                                                                                (110[deg] F).
----------------------------------------------------------------------------------------------------------------

                         Table 14--Changes to 46 CFR Part 129--Electrical Installations
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Applicability................  129.110......  Implements       Requirements     Removes OSVs of  No additional
                                               existing         for electrical   at least 6,000   cost. Similar
                                               Subchapter J     installations    GT ITC from      sized existing
                                               of this          were derived     being exempt     vessels, such
                                               chapter.         from existing    from having to   as 100% of
                                                                Coast Guard      comply with      OSVs between
                                                                regulations      the              3,000 and
                                                                (46 CFR          requirements     6,000 GT ITC,
                                                                Subchapter J,    in 46            voluntarily
                                                                Chapter I).      Subchapter J     agreed to be
                                                                                in their         certificated
                                                                                entirety.        by
                                                                                classification
                                                                                societies
                                                                                whose rules
                                                                                align with the
                                                                                requirements
                                                                                in the revised
                                                                                Subchapter J.
Power Sources for OSVs.......  129.315......  Implements       Requirements     Modifies         No additional
                                               existing         for power        existing         cost. 100% of
                                               Subchapter J     sources were     regulation to    OSVs between
                                               of this          derived from     ensure that      3,000 and
                                               chapter.         existing Coast   OSVs less than   6,000 GT ITC
                                                                Guard            6,000 GT ITC     voluntarily
                                                                regulations      will still be    agreed to be
                                                                (46 CFR          exempt from      certificated
                                                                Subchapter J,    being required   by
                                                                Chapter I).      to comply with   classification
                                                                                some parts of    societies
                                                                                46 Subchapter    whose rules
                                                                                J.               align with the
                                                                                requirements
                                                                                in revised 46
                                                                                CFR 129.315.
Overfill Protection..........  129.570......  Implements       Requirements     Compliance with  No additional
                                               existing         for alarms       existing         cost.
                                               Subchapter D     were derived     standard will    Incorporates
                                               of this          from existing    now be           industry &
                                               chapter.         Coast Guard      required of      international
                                                                regulations      large OSVs, in   standards
                                                                (46 CFR 33.25-   addition to      expected to be
                                                                1).              tank vessels.    used given
                                                                                industry
                                                                                practice and
                                                                                desire to
                                                                                compete for
                                                                                work in
                                                                                international
                                                                                markets.
                                                                                Similar sized
                                                                                existing
                                                                                vessels, such
                                                                                as 100% of
                                                                                OSVs between
                                                                                3,000 and
                                                                                6,000 GT ITC,
                                                                                voluntarily
                                                                                agreed to
                                                                                comply with
                                                                                SOLAS and
                                                                                MARPOL. These
                                                                                international
                                                                                standards
                                                                                align with the
                                                                                requirements
                                                                                in this
                                                                                provision.
----------------------------------------------------------------------------------------------------------------

          Table 15--Changes to 46 CFR Part 130--Vessel Control, and Miscellaneous Equipment and Systems
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard      justification
----------------------------------------------------------------------------------------------------------------
Steering and automated         130.140 and    Points to        Steering and     Modifies         No additional
 systems.                       130.400.       existing 46      automated        existing         cost.
                                               CFR              systems          regulation to    Administrative
                                               requirements.    requirements     ensure that      clarification
                                                                were derived     only OSVs        of
                                                                from existing    under 6,000 GT   applicability
                                                                Coast Guard      ITC must         of existing
                                                                regulations      comply with      regulations.
                                                                (46 CFR          the
                                                                130.140).        requirements
                                                                                in this
                                                                                provision.
                                                                                OSVs of at
                                                                                least 6,000 GT
                                                                                ITC are
                                                                                directed to 46
                                                                                CFR 128.110.
----------------------------------------------------------------------------------------------------------------

                                Table 16--Changes to 46 CFR Part 131--Operations
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard       justification
----------------------------------------------------------------------------------------------------------------
Maneuvering Characteristics..  131.990......  Existing SOLAS   Maneuvering      Expands          No additional
                                               and 46 CFR       capability       applicability    cost.
                                               requirements.    requirements     of existing      Incorporates
                                                                were derived     regulations to   standard
                                                                from existing    include large    expected to be
                                                                Coast Guard      OSVs.            used given
                                                                regulations                       current
                                                                (46 CFR                           industry
                                                                Subchapter I).                    practice and
                                                                                desire to
                                                                                compete for
                                                                                work in
                                                                                international
                                                                                markets.
                                                                                Similar sized
                                                                                existing
                                                                                vessels, such
                                                                                as 100% of
                                                                                OSVs 3,000 to
                                                                                6,000 GT ITC,
                                                                                already comply
                                                                                with the
                                                                                requirements
                                                                                in this
                                                                                provision.
----------------------------------------------------------------------------------------------------------------

                         Table 17--Changes to 46 CFR Part 132--Fire-Protection Equipment
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard       justification
----------------------------------------------------------------------------------------------------------------
Fire pump, extinguishers, and  132.100,       Implements       Requirements     Adds new         No additional
 emergency outfits.             132.200, and   existing 46      for fire         provision to     cost.
                                132.365.       CFR              pumps,           clarify          Incorporates
                                               requirements.    extinguishers,   applicable       existing U.S.
                                                                and emergency    U.S.             interpretation
                                                                outfits were     requirements     of
                                                                derived from     for fire         international
                                                                existing         pumps, fire      standard.
                                                                international    hoses, and       Similar sized
                                                                standards        nozzles,         existing
                                                                (SOLAS Chapter   portable and     vessels, such
                                                                II-2) and        semiportable     as 100% of
                                                                Coast Guard      fire             OSVs 3,000 to
                                                                regulations      extinguishers,   6,000 GT ITC,
                                                                (46 CFR          and              voluntarily
                                                                125.105).        firefighter's    comply with
                                                                                protective       the
                                                                                clothing and     requirements
                                                                                personal         in this
                                                                                safety           provision in
                                                                                equipment.       order to
                                                                                compete in
                                                                                international
                                                                                markets.
Added requirements for         132.390......  Requires 46 CFR  Requirements     Deviates from    No additional
 carriage of low flashpoint                    76, and 46 CFR   for carriage     existing CFR     cost.
 flammable or combustible                      161.002.         of low           by requiring     Incorporates
 cargo.                                                         flashpoint       that large       standard
                                                                flammable or     OSVs also        expected to be
                                                                combustible      comply with      used given
                                                                cargo and fire-  cargo area and   industry
                                                                protection       cargo-pump       practice and
                                                                equipment were   room fire-       desire to
                                                                derived from     extinguishing    compete for
                                                                existing Coast   systems          work in
                                                                Guard            requirements     international
                                                                regulations      that are         markets. An
                                                                (46 CFR 76 and   currently only   existing OSV
                                                                161.002).        required of      would already
                                                                                tank vessels.    be required to
                                                                                meet this
                                                                                requirement
                                                                                under the
                                                                                existing
                                                                                regulatory
                                                                                regime if it
                                                                                wished to
                                                                                perform these
                                                                                services.
----------------------------------------------------------------------------------------------------------------

                      Table 18--Changes to 46 CFR Part 134--Added Provisions for Liftboats
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard       justification
----------------------------------------------------------------------------------------------------------------
Applicability................  134.100......  Liftboats are    Requirements     Modifies         No additional
                                               regulated        for liftboats    existing         cost, as the
                                               under            were derived     applicability    construction
                                               Subchapter L;    from existing    of provision     of liftboats
                                               this requires    Coast Guard      to allow the     of at least
                                               large            regulations      construction     6,000 GT ITC
                                               liftboats to     (46 CFR          of large         are not
                                               obtain Coast     134.100).        liftboats on a   affected by
                                               Guard approval.                   case-by-case     this
                                                                                basis, which     rulemaking.
                                                                                must be
                                                                                approved by
                                                                                the Commandant
                                                                                (CG-5PS).
----------------------------------------------------------------------------------------------------------------

             Table 19--Changes to 46 CFR Part 174--Special Rules Pertaining to Specific Vessel Types
----------------------------------------------------------------------------------------------------------------
                                                Coast Guard     Origination of   Deviation from  Cost impact and
           Subject                Sections         action          standard         standard       justification
----------------------------------------------------------------------------------------------------------------
Applicability................  174.180......  Administrative   Requirements     Modifies         No additional
                                               change           for stability    existing         cost.
                                               conforms to      for OSVs under   regulations to   Administrative
                                               Part 127.        6,000 GT ITC     exempt large     change
                                                                were derived     OSVs from        clarifies that
                                                                from existing    being required   large OSVs are
                                                                Coast Guard      to meet the      excluded from
                                                                regulations      stability        certain
                                                                (46 CFR part     requirements     requirements.
                                                                174).            in 46 CFR
                                                                                Subpart G.
                                                                                Instead, large
                                                                                OSVs will be
                                                                                subject to the
                                                                                SOLAS
                                                                                stability
                                                                                requirements
                                                                                discussed
                                                                                earlier in
                                                                                this RA.
----------------------------------------------------------------------------------------------------------------

Benefits of the Interim Rule
    In the Act, Congress removed the tonnage limit on vessels
certificated under subchapter L as OSVs, and directed the Coast Guard
to implement regulations for the safe carriage of oil, hazardous
substances, and individuals in addition to the crew on OSVs of at least
6,000 GT ITC. However, the provisions in the Act allow ship owners and
operators to construct vessels that can operate as OSVs, by meeting
subchapter I and additional requirements from design basis agreements,
during the period between the effective date of the Act and the
effective date of this rulemaking provided they obtain Coast Guard
approval. This process creates regulatory inefficiencies as there are
no large OSV subchapter L-specific standards and regulatory
flexibilities for industry to reference, which could result in
construction and design delays. First, industry must submit a proposed
design to begin the process, and each time a change to the vessel's
design is made, the process must start over as the company must
resubmit a new design letter. After this step has been completed,
industry must then wait for the design basis to be approved before
beginning construction of the vessel. According to a Coast Guard
subject matter expert, this design basis process can take, at a
minimum, 30 days to complete, with additional time taken for the
company to respond to the draft design basis agreements. However, it is
likely that, based on the complexity of the design of OSVs of at least
6,000 GT ITC, this process would take the Coast Guard much longer to
complete.
    Accordingly, the Coast Guard developed this interim rule to rectify
this lack of transparent standards to ensure consistent design,
construction, and operation of OSVs, as well as to comply with the Act.
    On top of rectifying this lack of transparent standards, it is
expected that this rule will reduce costs overall. Because vessels
approved under the 617(f)(3) interim process are approved under a case-
by-case basis, a substantial amount of resources are used throughout
the approval process.

Issuance of this interim rule would streamline the construction process
by removing this case-by-case process and replacing it with transparent
requirements that all newly constructed vessels wishing to be
certificated as large OSVs must adhere to. This is expected to
significantly reduce costs.
    Therefore, this rule will replace government's existing ad hoc
processes and requirements with a more streamlined and predictable
system, thereby reducing resources and, consequently, costs.

              Table 20--Beneficial Impacts of Interim Rule
------------------------------------------------------------------------
            Subject                  Sections        Beneficial impacts
------------------------------------------------------------------------
                    46 CFR part 2--Vessel Inspections
------------------------------------------------------------------------
Inspections...................  2.10-25..........  Fulfills statutory
                                                    mandate by modifying
                                                    the definition of
                                                    OSV to remove size
                                                    ceiling.
------------------------------------------------------------------------
                  46 CFR part 15--Manning Requirements
------------------------------------------------------------------------
Watches.......................  15.705...........  Provides flexibility
                                                    by implementing
                                                    exception that
                                                    allows for 2 watches
                                                    on short voyages.
                                                    According to an OCMI
                                                    from the Eighth
                                                    District, a
                                                    navigation watch has
                                                    an average wage of
                                                    $44.37 per hour.
                                                    This exception could
                                                    result in cost
                                                    savings for owners
                                                    and operators of
                                                    large OSVs engaged
                                                    on a voyage of less
                                                    than 600 miles, as
                                                    these owners and
                                                    operators may employ
                                                    one fewer
                                                    navigational watch
                                                    on voyages of this
                                                    length.
Mates.........................  15.810...........  Provides flexibility
                                                    by lowering manning
                                                    requirements for
                                                    OSVs less than 6,000
                                                    GT ITC and OSVs of
                                                    at least 6,000 GT
                                                    ITC. For OSVs less
                                                    than 6,000 GT ITC,
                                                    the number of
                                                    required
                                                    credentialed mates
                                                    on voyages less than
                                                    600 miles decreases
                                                    from two to one, and
                                                    for voyages of at
                                                    least 600 miles from
                                                    three to two.
                                                    Further, for OSVs of
                                                    at least 6,000 GT
                                                    ITC, the number of
                                                    required
                                                    credentialed mates
                                                    on voyages less than
                                                    600 miles decreases
                                                    from three to two.
                                                    The number of
                                                    required mates on
                                                    voyages of at least
                                                    600 miles remains
                                                    the same. According
                                                    to an OCMI from the
                                                    Eighth District, a
                                                    navigation watch has
                                                    an average wage of
                                                    $44.37 per hour.
                                                    This exception will
                                                    therefore result in
                                                    cost savings for
                                                    owners and operators
                                                    of OSVs of all
                                                    sizes, since owners
                                                    and operators may
                                                    employ fewer
                                                    navigation watches
                                                    depending on the
                                                    size of the OSV and
                                                    on the voyage
                                                    length.
Engineers.....................  15.825...........  Ensures that
                                                    sufficient
                                                    engineering
                                                    personnel are
                                                    onboard to be able
                                                    to respond to
                                                    shipboard
                                                    emergencies and
                                                    equipment failure.
                                                    Provision retains
                                                    existing OCMI
                                                    authorities.
------------------------------------------------------------------------
             46 CFR part 61---Periodic Tests and Inspections
------------------------------------------------------------------------
Test procedure details........  61.40-10.........  Administrative change
                                                    that will provide
                                                    the Coast Guard
                                                    Headquarters with
                                                    more flexibility
                                                    regarding the use of
                                                    its resources.
------------------------------------------------------------------------
                46 CFR part 62---Vital System Automation
------------------------------------------------------------------------
Applicability.................  62.01-5..........  Change that will
                                                    provide transparency
                                                    to industry and
                                                    government officials
                                                    for use in the
                                                    approval process.
------------------------------------------------------------------------
                   46 CFR part 90--General Provisions
------------------------------------------------------------------------
Applicability to OSVs.........  90.05-20.........  Contains criteria for
                                                    grandfathering OSVs
                                                    and sets the
                                                    applicability of
                                                    Subchapter I for
                                                    OSVs that pre-dated
                                                    the creation of
                                                    Subchapter L.
Definitions of offshore supply  90.10-40.........  Clarifies terms
 vessels.                                           relating to tonnage
                                                    measurement.
------------------------------------------------------------------------
             Changes to 46 CFR part 110--General Provisions
------------------------------------------------------------------------
Incorporation by reference....  110.10-1.........  Provides for use of
                                                    industry standard as
                                                    alternative to use
                                                    of approved
                                                    equipment.
Definitions...................  110.15-1.........  Clarifies
                                                    definitions.
Plans and information required  110.25-1.........  Requires plans
 for new construction.                              consistent with
                                                    other similarly
                                                    sized vessels, while
                                                    also adding option
                                                    of using
                                                    international
                                                    standards. Plans
                                                    must include
                                                    information on the
                                                    equipment,
                                                    intrinsically safe
                                                    systems,
                                                    installation
                                                    details, and/or
                                                    approved control
                                                    drawings, and
                                                    testing certificates
                                                    or listing by an
                                                    independent
                                                    laboratory or an
                                                    IECEx Certificate of
                                                    Conformity to ensure
                                                    existing levels of
                                                    safety in hazardous
                                                    locations.
------------------------------------------------------------------------

         46 CFR part 111--Electric Systems General Requirements
------------------------------------------------------------------------
Flammable or Combustible        111.05-20........  Clarifies
 liquids and grounded                               requirements for
 distribution systems on OSVs.                      large OSVs, which
                                                    will provide more
                                                    transparency to
                                                    industry and
                                                    government officials
                                                    for use in the
                                                    approval process.
                                                    Permits the use of
                                                    grounded
                                                    distribution systems
                                                    on large OSVs
                                                    designed to carry
                                                    flammable or
                                                    combustible liquids
                                                    under certain
                                                    conditions to
                                                    maintain safety.
                                                    Aligns standards
                                                    with international
                                                    requirements,
                                                    thereby creating a
                                                    universal standard
                                                    which will enable
                                                    vessels to more
                                                    easily compete for
                                                    work on
                                                    international
                                                    market.
Hazardous Locations on OSVs...  111.106-1,         Clarifies
                                 111.106-3,         requirements for
                                 111.106-5,         large OSVs, which
                                 111.106-7,         will provide more
                                 111.106-9,         transparency to
                                 111.106-11,        industry and
                                 111.106-13,        government officials
                                 111.106-15, and    for use in the
                                 111.106-17.        approval process.
                                                    Provides flexibility
                                                    as to the choice of
                                                    a standard that
                                                    addresses the wide
                                                    ranging services
                                                    that the vessel
                                                    performs and
                                                    enhances the safety
                                                    of personnel and
                                                    vessels. List of
                                                    standards is
                                                    expanded from
                                                    existing Subchapter
                                                    L, thereby
                                                    increasing options
                                                    for industry.
------------------------------------------------------------------------
                        46 CFR part 125--General
------------------------------------------------------------------------
Applicability.................  125.100..........  Fulfills statutory
                                                    mandate by
                                                    implementing the
                                                    Act.
Tonnage Measurement...........  125.103..........  Fulfills statutory
                                                    mandate by
                                                    implementing the
                                                    Act.
International certificates for  125.105..........  Requires large OSVs
 OSVs of at least 6,000 GT ITC.                     to obtain all
                                                    applicable
                                                    international
                                                    convention
                                                    certificates in
                                                    areas such as safety
                                                    and pollution
                                                    prevention. Use of
                                                    international
                                                    certificate enables
                                                    industry to
                                                    simultaneously
                                                    comply with U.S.
                                                    requirements and
                                                    obtain certificates
                                                    needed to compete
                                                    for work on
                                                    international
                                                    market.
Carriage of flammable or        125.110..........  Clarifies
 combustible liquid cargoes in                      requirements for
 bulk.                                              large OSVs, which
                                                    will provide more
                                                    transparency to
                                                    industry and
                                                    government officials
                                                    for use in the
                                                    approval process.
                                                    Provides enhanced
                                                    level of
                                                    environmental
                                                    protection to the
                                                    large volumes of oil
                                                    and oil-based
                                                    cargoes large OSVs
                                                    are capable of
                                                    carrying, applying
                                                    requirements for
                                                    similar vessels and
                                                    systems.
Oil fuel tank protection......  125.115..........  Clarifies
                                                    requirements for
                                                    large OSVs, which
                                                    will provide more
                                                    transparency to
                                                    industry and
                                                    government officials
                                                    for use in the
                                                    approval process.
Carriage of noxious liquid      125.120 and        Clarifies
 substances in bulk by OSVs      125.125.           requirements for
 less than 6,000 GT ITC (500                        large OSVs, which
 GRT if GT ITC is not                               will provide more
 assigned) and least 6,000 GT                       transparency to
 ITC (500 GRT if GT ITC is not                      industry and
 assigned).                                         government officials
                                                    for use in the
                                                    approval process.
                                                    Requirements mirror
                                                    those for similar
                                                    vessels and systems.
Loadlines.....................  125.140..........  Aligns standards with
                                                    international
                                                    requirements,
                                                    thereby creating a
                                                    universal standard
                                                    which will enable
                                                    vessels to more
                                                    easily compete for
                                                    work on
                                                    international
                                                    market.
Lifesaving systems............  125.150..........  Aligns standards with
                                                    international
                                                    requirements,
                                                    thereby creating a
                                                    universal standard
                                                    which will enable
                                                    vessels to more
                                                    easily compete for
                                                    work on
                                                    international market
                                                    and ensures that
                                                    vessels with a
                                                    larger number of
                                                    personnel on board
                                                    have sufficient
                                                    safety and
                                                    survivability.
------------------------------------------------------------------------
              46 CFR part 126--Inspection and Certification
------------------------------------------------------------------------
Carriage of offshore workers..  126.170..........  Allows large OSVs to
                                                    carry more personnel
                                                    and thereby increase
                                                    revenue while
                                                    ensuring protection
                                                    scales with number
                                                    of personnel.
------------------------------------------------------------------------
             46 CFR part 127--Construction and Arrangements
------------------------------------------------------------------------
Classification Society          127.200..........  Incorporates industry
 Standards.                                         and international
                                                    standards expected
                                                    to be used given
                                                    industry practice
                                                    and desire to
                                                    compete for work on
                                                    international
                                                    markets.
Structural fire protection....  127.225..........  Requires traditional
                                                    US standard while
                                                    maintaining
                                                    alignment with
                                                    international
                                                    requirements,
                                                    thereby using a
                                                    universal standard
                                                    which will enable
                                                    vessels to more
                                                    easily compete for
                                                    work on
                                                    international
                                                    market, while
                                                    ensuring that
                                                    vessels with a
                                                    larger number of
                                                    personnel on board
                                                    have sufficient
                                                    safety and
                                                    survivability.
Subdivision and stability.....  127.230..........  Uses international
                                                    standard for
                                                    stability, thus
                                                    enabling vessels to
                                                    compete for work on
                                                    international market
                                                    and ensuring that
                                                    vessels with larger
                                                    numbers of personnel
                                                    on board have
                                                    sufficient safety
                                                    and survivability.

Construction and arrangements   127.600, 127.620,  Allows large OSVs to
 for OSVs carrying more than     127.630,           carry more personnel
 36 offshore workers.            127.640, and       and thereby increase
                                 127.650.           revenue while
                                                    ensuring protection
                                                    scales with number
                                                    of personnel.
------------------------------------------------------------------------
       46 CFR part 128--Marine Engineering: Equipment and Systems
------------------------------------------------------------------------
Equipment and systems.........  128.110..........  Clarifies
                                                    requirements for
                                                    large OSVs, which
                                                    will provide more
                                                    transparency to
                                                    industry and
                                                    government officials
                                                    for use in the
                                                    approval process.
                                                    Provides enhanced
                                                    level of safety and
                                                    environmental
                                                    protection to the
                                                    larger and more
                                                    complex systems