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Proposed Rule2026-20087

Clarification of Certain Mariner Training Requirements

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Published

October 1, 2026

Issuing agencies

Homeland Security DepartmentCoast Guard

Abstract

The Coast Guard proposes removing six requirements related to endorsements for the International Convention on Standards of Training, Certification, and Watchkeeping for Seafarers, 1978, as amended, and the Seafarer's Training, Certification, and Watchkeeping Code. Changes would affect Masters and Officers in Charge of a Navigational Watch of less than 500 GT in near-coastal waters; Officers in Charge of an Engineering Watch, Designated Duty Engineers, and Electro-technical Ratings of 750 kW/1,000 HP or more. This proposed action includes technical revisions to remove duplicative or outdated language from the regulatory text, reduces regulatory burdens, and promotes equivalent compliance standards with international requirements.

Full Text

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<title>Federal Register, Volume 91 Issue 189 (Thursday, October 1, 2026)</title>
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[Federal Register Volume 91, Number 189 (Thursday, October 1, 2026)]
[Proposed Rules]
[Pages 62383-62409]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-20087]

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DEPARTMENT OF HOMELAND SECURITY

Coast Guard

46 CFR Parts 11 and 12

[Docket No. USCG-2025-0392]
RIN 1625-AC48

Clarification of Certain Mariner Training Requirements

AGENCY: Coast Guard, Department of Homeland Security (DHS).

ACTION: Notice of proposed rulemaking.

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SUMMARY: The Coast Guard proposes removing six requirements related to
endorsements for the International Convention on Standards of Training,
Certification, and Watchkeeping for Seafarers, 1978, as amended, and
the Seafarer's Training, Certification, and Watchkeeping Code. Changes
would affect Masters and Officers in Charge of a Navigational Watch of
less than 500 GT in near-coastal waters; Officers in Charge of an
Engineering Watch, Designated Duty Engineers, and Electro-technical
Ratings of 750 kW/1,000 HP or more. This proposed action includes
technical revisions to remove duplicative or outdated language from the
regulatory text, reduces regulatory burdens, and promotes equivalent
compliance standards with international requirements.

DATES: Comments and related material must be received by the Coast
Guard on or before December 30, 2026.

ADDRESSES: You may submit comments identified by docket number USCG-
2025-0392 using <a href="http://www.regulations.gov">www.regulations.gov</a>. See the ``Public Participation and
Request for Comments'' portion of the SUPPLEMENTARY INFORMATION section
for further instructions on submitting comments. This notice of
proposed rulemaking with its plain language proposed rule summary of
100 words or less will be available in this same docket.
Collection of information. Submit comments on the collection of
information discussed in Section VI., Regulatory Analyses, of this
preamble both to the Coast Guard's online docket and to the Office of
Information and Regulatory Affairs (OIRA) in the White House Office of
Management and Budget (OMB), using their website <a href="http://www.reginfo.gov/public/do/PRAMain">www.reginfo.gov/public/do/PRAMain</a>. Comments sent to OIRA on the collection of
information must reach OMB on or before the comment due date listed on
their website.

FOR FURTHER INFORMATION CONTACT: For information about this document,
call or email Ms. Megan Johns Henry, Office of Merchant Mariner
Credentialing, Coast Guard; telephone 571-610-3303, email
<a href="/cdn-cgi/l/email-protection#c18ca4a6a0afef82ef8baea9afb281b4b2a2a6efaca8ad"><span class="__cf_email__" data-cfemail="18557d7f7976365b36527770766b586d6b7b7f36757174">[email&#160;protected]</span></a>.

SUPPLEMENTARY INFORMATION:

Table of Contents for Preamble

I. Public Participation and Request for Comments
II. Abbreviations
III. Executive Summary
A. Purpose
B. Legal Authority
C. Summary of Major Provisions
D. Benefits
IV. Background
V. Discussion of Proposed Rule
VI. Regulatory Analyses
A. Regulatory Planning and Review
B. Small Entities
C. Assistance for Small Entities
D. Collection of Information
E. Federalism
F. Unfunded Mandates Reform Act
G. Taking of Private Property
H. Civil Justice Reform
I. Protection of Children
J. Indian Tribal Governments
K. Energy Effects
L. Technical Standards
M. Environment

[[Page 62384]]

I. Public Participation and Request for Comments

The Coast Guard views public participation as essential to
effective rulemaking and will consider all comments and material
received during the comment period. Your comment can help shape the
outcome of this rulemaking. If you submit a comment, please include the
docket number for this rulemaking, indicate the specific section of
this document to which each comment applies, and provide a reason for
each suggestion or recommendation.
Submitting comments. We encourage you to submit comments through
<a href="http://www.regulations.gov">www.regulations.gov</a>. To do so, go to <a href="http://www.regulations.gov">www.regulations.gov</a>, type USCG-
2025-0392 in the search box and click ``Search.'' Next, look for this
document in the Search Results column, and click on it. Then click on
the Comment option. If you cannot submit your material by using
<a href="http://www.regulations.gov">www.regulations.gov</a>, call or email the person in the FOR FURTHER
INFORMATION CONTACT section of this proposed rule for alternate
instructions. We review all comments received.
Viewing material in docket. To view documents mentioned in this
proposed rule as being available in the docket, find the docket as
described in the previous paragraph, and then select ``Supporting &
Related Material'' in the Document Type column. Public comments will
also be placed in our online docket and can be viewed by following the
instructions on the Frequently Asked Questions web page, available at
<a href="http://www.regulations.gov/faq">www.regulations.gov/faq</a>. That page also explains how to subscribe for
email alerts that will notify you when comments are posted or if a
final rule is published.
Personal information. We accept anonymous comments. Comments we
post to <a href="http://www.regulations.gov">www.regulations.gov</a> will include any personal information you
have provided. For more information about privacy and submissions to
the docket in response to this document, see DHS's eRulemaking System
of Records notice (85 FR 14226, March 11, 2020).

II. Abbreviations

2013 final rule Implementation of the Amendments to the
International Convention on Standards of Training, Certification and
Watchkeeping for Seafarers, 1978, and Changes to National
Endorsements final rule
BLS Bureau of Labor Statistics
BRM Bridge resource management
BTS Bureau of Transportation Statistics
CFR Code of Federal Regulations
CSM Computer Systems and Maintenance
DDE Designated Duty Engineer
DHS Department of Homeland Security
DOT Department of Transportation
ECDIS Electronic Chart Display and Information System
ECI Employment Cost Index
ETR Electro-technical Rating
ETSO Engineering Terminology and Shipboard Operations
FR Federal Register
GDP Gross Domestic Product
GS General Schedule
GSA General Services Administration
GT Gross Tonnage
HVPS High Voltage Power Systems
HP Horsepower
IMO International Maritime Organization
kW Kilowatt
LMS Leadership and managerial skills
LTW Leadership and teamworking
M&IE Meals and incidental expense rates
MMC Merchant Mariner Credential
MMLD Merchant Mariner Licensing Documentation
MPH Miles per hour
NMC National Maritime Center
NPRM Notice of Proposed Rulemaking
OMB Office of Management and Budget
OICEW Officer in Charge of an Engineering Watch
OICNW Officer in Charge of a Navigational Watch
QA Qualified Assessor
RA Regulatory analysis
RFA Regulatory Flexibility Act
Sec. Section
SOC Code Standard Occupational Classification Code
STCW Code Seafarer's Training Certification and Watchkeeping Code
STCW Convention International Convention on Standards of Training,
Certification and Watchkeeping for Seafarers, 1978, as Amended
SME Subject Matter Expert
U.S.C. United States Code

III. Executive Summary

A. Purpose

The purpose of the proposed rule is to remove six requirements
related to Merchant Mariner Credential (MMC) endorsements for the
International Convention on Standards of Training, Certification, and
Watchkeeping for Seafarers, 1978, as Amended (STCW Convention) and the
Seafarer's Training, Certification, and Watchkeeping Code (STCW Code).
Changes would affect Masters and Officers in Charge of a Navigational
Watch (OICNW) of vessels less than 500 Gross Tonnage (GT) in near-
coastal waters; Officers in Charge of an Engineering Watch (OICEW),
Designated Duty Engineers (DDE), and Electro-technical Ratings (ETRs)
on vessels with propulsion machinery of 750 Kilowatt (kW)/1,000
Horsepower (HP) or more. The proposal would also remove a duplicate
provision and transitional provisions that expired on January 1, 2017.
This proposed action would reduce regulatory burdens and promote
equivalent compliance standards with international requirements.

B. Legal Authority

The legal basis of this proposed rule is 46 U.S.C. 2103, which
grants the Secretary of the Department of Homeland Security (DHS) the
authority to issue regulations to carry out the provisions of 46 U.S.C.
Subtitle II, Vessels and Seamen. More specifically, 46 U.S.C. 7101
authorizes the Secretary of DHS to prescribe the requirements of
licensed individuals, and 46 U.S.C. 7301 and 7313 establish the
requirements for rating endorsements in the engine department. The
Secretary of DHS has delegated these statutory authorities to the Coast
Guard through DHS Delegation No. 00170.1(II)(92)(e) and (f), which
authorizes the Coast Guard to determine and establish the experience
and professional qualifications required for the issuance of
credentials.

C. Summary of Major Provisions

The Coast Guard proposes to remove the following six requirements
related to STCW endorsements in 46 CFR parts 11 and 12.
<bullet> Leadership and managerial skills (LMS) training to qualify
as a Master of vessels of less than 500 GT limited to near-coastal
waters or to renew that endorsement (46 CFR 11.317(a)(3)(v) and
(b)(1)).
<bullet> Bridge resource management (BRM) training to qualify as an
OICNW on vessels of less than 500 GT limited to near-coastal waters (46
CFR 11.321(a)(3)(iv)).
<bullet> Demonstration of meeting the standard of competence \1\ in
leadership and teamworking (LTW) skills to qualify as OICNW on vessels
of less than 500 GT limited to near-coastal waters or to renew that
endorsement (46 CFR 11.321(b)(1)).
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\1\ ``Standard of competence'' is defined in 46 CFR 10.107(b) as
the level of proficiency to be achieved for the proper performance
of duties onboard vessels according to the national and
international criteria. Title 46 CFR 11.301 describes the accepted
methods mariners may utilize for meeting the standard of competence
required by the STCW Code. For LTW skills, the standard may be
demonstrated through the successful completion of assessments,
approved or accepted by the Coast Guard, and signed by a qualified
assessor (QA) through completion of a Coast Guard approved or
accepted training course.
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<bullet> Engineering Terminology and Shipboard Operations (ETSO)
training to qualify as OICEW in a manned engineroom or DDE in a
periodically unmanned engineroom on vessels powered by main propulsion
machinery of 750 kW/1,000 HP propulsion power or more (46 CFR
11.329(a)(4)(v)).
<bullet> Computer Systems and Maintenance (CSM) training to qualify
as an ETR on vessels powered by main

[[Page 62385]]

propulsion machinery of 750 kW/1,000 HP or more (46 CFR
12.611(a)(4)(i)).
<bullet> High Voltage Power Systems (HVPS) training to qualify as
an ETR on vessels powered by main propulsion machinery of 750 kW/1,000
HP or more (46 CFR 12.611(a)(4)(ii)).
The Coast Guard is also proposing some technical revisions to Sec.
11.317 to remove duplicative or outdated language. Specifically, we
propose to correct an administrative error in which the Radar Observer
requirement was inadvertently listed twice in 46 CFR 11.317(a)(3) to
remove language that references the one-time renewal of the endorsement
after January 1, 2017, from Sec. 11.317(b).
The Coast Guard identified these six requirements for removal as
part of the review-and-repeal effort required by Executive Order 14219
(Ensuring Lawful Governance and Implementing the President's
``Department of Government Efficiency'' Deregulatory Initiative (90 FR
10583, Feb. 25, 2025)) and Executive Order 14192 (Unleashing Prosperity
Through Deregulation (90 FR 9065, Feb. 06,2025)). In accordance with
these Executive orders, the Coast Guard re-evaluated the necessity of
LMS, BRM, ETSO, CSM, and HVPS training for specific endorsements and
the requirement to meet the standard of competence in LTW skills.
For the LMS and BRM training requirements, and the requirement to
meet the standard of competence in LTW skills, we have determined that
these training requirements exceed the requirements of the STCW
Convention and STCW Code for an officer operating at the operational
level on vessels less than 500 GT limited to near-coastal waters and do
not improve safety on board because these vessels have a limited number
of personnel on the bridge. Generally, these vessels have only one
credentialed mariner serving as a watchstander, and this deck officer
fulfills the role of OICNW as well as helmsman and lookout. Considering
that the bridge team consists of one person, the LMS and BRM training
requirements and meeting the standard of competence in LTW skills are
unnecessary for safe shipboard operations. In addition, these
requirements go beyond the skillset necessary for deck officers on
vessels of less than 500 GT limited to near-coastal waters. The need
for LMS and BRM training and meeting the standard of competence in LTW
skills remains valid for deck officers credentialed for service on
larger vessels (500 GT or more), or on ocean routes, who lead bridge
watch teams consisting of multiple personnel.
Regarding the ETSO training requirement to qualify for an STCW
endorsement as OICEW in a manned engineroom or as DDE in a periodically
unmanned engineroom, we have determined that this training requirement
exceeds the requirement of the STCW Convention and STCW Code for an
officer operating at the operational level on vessels with propulsion
power of 750 kW/1,000 HP or more. Engineering officers are expected to
have acquired this foundational knowledge through their broader
engineering training and experience, and their competency in these
subjects is further assessed through examination and onboard service.
Therefore, requiring a separate approved course is unnecessary and
imposes an undue burden on mariners without corresponding safety
benefits.
With regard to the requirement for CSM training to qualify for an
STCW endorsement as ETR on vessels powered by main propulsion machinery
of 750 kW/1,000 HP or more, an ETR would not be authorized to work on
computer equipment without being under the direct supervision of a
credentialed officer who would be responsible for directing the
appropriate computer work to be completed and would be the primary
person completing the work with an ETR supporting them. Therefore, in
addition to exceeding the requirements of the STCW Convention and STCW
Code, we have determined this training requirement goes beyond the
skillset necessary and the level of responsibility associated with an
ETR endorsement and thus is unnecessary and overly burdensome.
Similarly, with regard to the requirement for HVPS training to
qualify for an STCW endorsement as ETR on vessels powered by main
propulsion machinery of 750 kW/1,000 HP or more, an ETR would not be
authorized to work on HVPS without being under the direct supervision
of a credentialed officer who would be responsible for directing the
appropriate HVPS to be completed and would be the primary person
completing the work with an ETR supporting them. Therefore, in addition
to exceeding the requirements of the STCW Convention and STCW Code, we
have determined this training requirement goes beyond the skillset
necessary and the level of responsibility associated with an ETR
endorsement and thus is unnecessary and overly burdensome.

D. Cost-Savings

As a deregulatory action, this proposed rule would not impose any
new costs on mariners or the Federal Government. The removal of LMS
training, BRM training, ETSO training, CSM training, HVPS training, and
the requirement to meet the standard of competence in LTW skills would
reduce the burden on affected mariners, as they would no longer need to
complete these trainings or provide evidence of meeting the standard of
competence in LTW skills to obtain or retain their respective STCW
endorsements.
The benefits of this proposed rule would be realized as cost
savings for mariners and the Federal Government. Removing the LMS
training requirement would lead to an annualized cost savings for deck
officers of $991,977; removing the BRM training requirement would lead
to an annualized cost savings for mariners of $98,545; and removing the
ETSO training requirement would lead to an annualized cost savings for
mariners of $4,920,634. These cost savings would include tuition, the
opportunity cost of time spent attending training, the travel costs
associated with training, and the opportunity cost associated with
compiling the documentation required as part of an application for an
MMC. With regards to the removal of CSM and HVPS training, 46 CFR part
15 currently has no vessel manning \2\ requirement for an ETR on any
vessel. Because there are no manning requirements for ETR, it is not
possible to determine or estimate the population of mariners who would
be taking CSM and HVPS training to meet the requirements for this
endorsement, and we did not estimate costs and subsequent cost savings
associated with this regulatory provision.
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\2\ ``The manning of a vessel'' is the complement of officers
and ratings considered by the Coast Guard to be necessary for safe
operation, as described in 46 U.S.C. 8101(a).
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Removing the requirement to meet the standard of competence in LTW
skills and the opportunity cost associated with compiling documentation
required as part of an MMC application would lead to an annualized cost
savings for mariners of $83,094. The removal of the LMS, BRM, and ETSO
training requirements, and the removal of the requirement to meet the
standard of competence in LTW skills, would lead to an annualized cost
savings for the Federal Government of $1,947, since evaluating training
certificates and evidence of completed assessments of competence as
part of an MMC application would no longer be necessary.
We estimate the total cost savings of the proposed rule to mariners
and the Federal Government to be

[[Page 62386]]

approximately $42,817,136 ($6,967,231 for removing LMS training
requirements + $692,139 for removing BRM training requirements +
$583,617 for removing demonstration of the standard of competence in
LTW skills requirement + $34,560,474 for removing ETSO training
requirements + $13,675 for removing Federal Government costs) over a
10-year period of analysis (discounted at 7 percent). Furthermore, we
estimate the annualized total cost savings to be approximately
$6,096,197 ($991,977 for LMS + $98,545 for BRM + $83,094 for LTW skills
+ $4,920,634 for ETSO + $1,947 for removing Federal Government costs)
discounted at 7 percent. Using a perpetual period of analysis, we
estimate the total annualized cost savings of this proposed rule to be
$3,833,921 in 2024 dollars, using a 7 percent discounted rate.
We estimate that an average of 825 mariners (172 masters for LMS,
25 mariners for BRM, 168 mariners for LTW skills, and 460 mariners for
ETSO) would benefit each year from this proposed rule. The cost savings
for mariners would come from avoided expenses, as neither group would
need to complete the LMS, BRM, or ETSO training, nor demonstrate
meeting the standard of competence in LTW skills required for their
respective STCW endorsements. While the rule also removes the CSM and
HVPS training requirements for ETRs, no associated cost savings can be
estimated because there are currently no vessel manning requirements
for ETRs, which makes it impossible to determine the population of
mariners who would be affected by this change. In Section VI.,
Regulatory Analyses, in this preamble, we present the cost savings
analysis associated with this proposed rule.

IV. Background

The Coast Guard established a program for the training and
certification of personnel serving on U.S. vessels that is governed by
domestic law in 46 U.S.C. and in 46 CFR parts 11 and 12. Through these
domestic statutes and regulations, the United States implements the
provisions of the STCW Convention and the STCW Code.
The International Maritime Organization (IMO) establishes the
minimum training and certification requirements for seafarers and
maritime personnel through the STCW Convention and STCW Code. In 2007,
the IMO began a comprehensive review of the STCW Convention and STCW
Code that resulted in the 2010 STCW amendments. These amendments were
implemented by the Coast Guard through the 2013 final rule titled,
``Implementation of the Amendments to the International Convention on
Standards of Training, Certification and Watchkeeping for Seafarers,
1978, and Changes to National Endorsements'' (78 FR 77796, Dec. 24,
2013) (hereafter ``the 2013 final rule''). This rule included the
requirements for--
(1) LMS training to qualify as Master of vessels of less than 500
GT limited to near-coastal waters or to renew that endorsement after
January 1, 2017;
(2) BRM training to qualify as OICNW on vessels of less than 500 GT
limited to near-coastal waters;
(3) Demonstration of meeting the standard of competence in LTW
skills to qualify as OICNW on vessels of less than 500 GT limited to
near-coastal waters or to renew that endorsement after January 1, 2017;
(4) ETSO training to qualify as OICEW in a manned engineroom or a
DDE in a periodically unmanned engineroom on vessels powered by main
propulsion machinery of 750 kW/1,000 HP propulsion power or more;
(5) CSM training to qualify as an ETR on vessels powered by main
propulsion machinery of 750 kW/1,000 HP or more; and
(6) HVPS training to qualify as an ETR on vessels powered by main
propulsion machinery of 750 kW/1,000 HP or more.
Although not required by domestic statute or the minimum
international standards contained in the STCW Convention or the STCW
Code for these endorsements, the Coast Guard included these
requirements in the 2013 final rule as a means to ensure safe vessel
operations. After further review and for the reasons discussed below,
the Coast Guard has determined that these six requirements are
unnecessary for the safe operation of applicable vessels.

V. Discussion of Proposed Rule

With this rulemaking, the Coast Guard is promoting the goals of
Executive Orders 14219 and 14192 by determining that LMS, BRM, ETSO,
CSM, and HVPS training requirements, and the requirement to meet the
standard of competence in LTW skills, are unnecessary for the
endorsements identified in this proposal. In conducting a retrospective
review of 46 CFR parts 11 and 12, we have determined these requirements
should be removed to reduce the regulatory burden on mariners. These
proposed changes would also reduce the financial burden on mariners and
the Federal Government by removing overly burdensome regulatory
requirements.
We provide a section-by-section description of our proposed changes
in the following paragraphs.

46 CFR Part 11--Authority

The Coast Guard is revising the authority citation to remove ``14
U.S.C. 503.'' Section 503 provides general administrative authority
concerning the establishment and administration of the Coast Guard.
Because 46 U.S.C. chapters 21, 71, 75, 77, and 89 provide the specific
statutory authorities for the regulations in this part, citation to 14
U.S.C. 503 is unnecessary.
The Coast Guard is also proposing to remove ``46 U.S.C. 8903, 8904,
and 8906'' and replacing it with ``46 U.S.C. chapter 89.'' Part 11
governs the credentialing of mariners serving on vessels subject to
multiple provisions within chapter 89, including freight vessels, small
passenger vessels, and vessels subject to statutory exceptions. The
existing authority citation references only selected sections of
chapter 89 and does not fully reflect the scope of statutory provisions
underlying the regulations.

Section 11.317--Requirements To Qualify for an STCW Endorsement as
Master of Vessels of Less Than 500 GT Limited to Near-Coastal Waters
(Management Level)

The Coast Guard proposes to remove the requirement in Sec.
11.317(a)(3)(v) to provide evidence of having satisfactorily completed
LMS training to qualify for an STCW endorsement as Master of vessels of
less than 500 GT limited to near-coastal waters. The purpose of LMS
training is to improve the control of ship operations through the
effective management of resources and handling of personnel. We propose
removing the LMS training requirement for Master of vessels less than
500 GT limited to near-coastal waters because these vessels typically
operate with a single credentialed mariner who fulfills multiple roles,
making team-based training unnecessary; and LMS training is not
required by domestic statute or the minimum international standards in
the STCW Convention or the STCW Code for these particular mariners.
Additionally, the Coast Guard proposes to correct a typographical
error in which Sec. 11.317(a)(3)(iv) and (a)(3)(vii) both require
``Radar Observer, if serving on a vessel with this equipment.'' The
language currently at (a)(3)(iv) would be deleted, while the second
instance of the requirement currently at (a)(3)(vii) would be
redesignated as (a)(3)(v).
These proposed changes include redesignating Sec. 11.317(a)(3)(iv)
through

[[Page 62387]]

(a)(3)(viii) as Sec. 11.317(a)(3)(iv) through (a)(3)(vi),
respectively.
We also propose making several changes to existing Sec. 11.317(b).
We are proposing to remove language that references renewal of the
endorsement after January 1, 2017, which was a one-time requirement
implemented to ensure mariners with existing STCW endorsements meet the
same standards as new mariners. We propose this change because the
January 1, 2017, deadline has passed and is, therefore, no longer
relevant. We also propose removing Sec. 11.317(b)(1), which requires
evidence of having successfully completed LMS training to be eligible
for a renewal of an STCW endorsement as Master of vessels of less than
500 GT limited to near-coastal waters. If a mariner held an STCW
endorsement and has not renewed it since January 1, 2017, they would
not need to complete LMS training to reinstate the endorsement, if a
final rule is published.
Additionally, as previously discussed, LMS training focuses on
improving communication between shipboard officers and crew. Due to the
limited manning on this size of vessel, we do not believe that this
training is necessary for safe shipboard operations. LMS training is
also not required by domestic statute or the minimum international
standards in the STCW Convention or the STCW Code for these
endorsements.
Finally, we would revise existing Sec. 11.317(b) to incorporate
existing Sec. 11.317(b)(2), since we are proposing to remove Sec.
11.317(b)(1). Existing Sec. 11.317(b)(2) requires that each candidate
seeking to renew their STCW endorsement as Master of vessels of less
than 500 GT limited to near-coastal waters must provide evidence of
successful completion of an approved training in Electronic Chart
Display and Information System (ECDIS), if serving on a vessel with
this equipment. The training requirement for ECDIS (if serving on a
vessel with the equipment) would not change.

Section 11.321--Requirements To Qualify for an STCW Endorsement as
Officer in Charge of a Navigational Watch (OICNW) of Vessels of Less
Than 500 GT Limited to Near-Coastal Waters (Operational Level)

We propose to remove the requirement in Sec. 11.321(a)(3)(iv) to
provide evidence of having satisfactorily completed BRM training to
qualify for an STCW endorsement as an OICNW of vessels less than 500 GT
limited to near-coastal waters. The purpose of BRM training is to
improve the interaction between watchstanders to ensure that they
properly utilize data outputs from shipboard equipment and other
personnel while conducting watchstanding duties. We propose removing
the BRM training for OICNW of vessels of less than 500 GT limited to
near-coastal waters, as these vessels generally only have one
credentialed mariner serving as a watchstander, and this deck officer
fulfills the role of OICNW as well as helmsman and lookout. Therefore,
BRM training is not necessary for safe shipboard operations and is not
required by domestic statute or the minimum international standards in
the STCW Convention or the STCW Code for these endorsements. We also
propose to redesignate Sec. 11.321(a)(3)(v) through (a)(3)(vii) as
Sec. 11.321(a)(3)(iv) through (a)(3)(vi), respectively.
Additionally, we propose to remove the requirement in existing
Sec. 11.321(b)(1) to demonstrate meeting the standard of competence in
LTW skills to be eligible for renewal of an STCW endorsement as OICNW
of vessels less than 500 GT limited to near-coastal waters, and from
Sec. 11.321(b) the transitional provision specifying this after
January 1, 2017. As previously discussed, the purpose of LTW skills
training is to improve the ability of a watchstander to effectively
lead other personnel while conducting watchstanding duties. Due to the
limited manning on this size of vessel, we do not believe that this
training is necessary for safe shipboard operations. We propose the
removal of January 1, 2017, from Sec. 11.321(b) because the January 1,
2017, deadline has passed and is no longer relevant.
We would also revise existing Sec. 11.321(b) to incorporate
existing paragraph (b)(2). Existing Sec. 11.321(b)(2) requires that
each candidate seeking to renew their STCW endorsement as Master of
vessels of less than 500 GT limited to near-coastal waters must provide
evidence of successful completion of an approved training in ECDIS, if
serving on a vessel with this equipment. The training requirement for
ECDIS (if serving on a vessel with the equipment) would not change.

Section 11.329--Requirements To Qualify for an STCW Endorsement as
OICEW in a Manned Engineroom or DDE in a Periodically Unmanned
Engineroom on Vessels Powered by Main Propulsion Machinery of 750 kW/
1,000 HP Propulsion Power or More (Operational Level)

We propose to remove the requirement in Sec. 11.329(a)(4)(v) to
provide evidence of having satisfactory completion of ETSO training to
qualify for an STCW endorsement as OICEW or as DDE at the operational
level. This training was originally intended to ensure mariners possess
a foundational understanding of engineering terms and routine shipboard
engineering functions. However, mariners qualifying for an STCW
endorsement as OICEW in a manned engineroom or DDE in a periodically
unmanned engineroom on vessels powered by main propulsion machinery of
750 kW/1,000 HP propulsion power or more, already have at least 1,080
days of engine service in the engineroom. Such sufficient shipboard
experience, along with completion of practical assessments and written
examinations, make the course redundant, not necessary to ensure the
safety of operations, and imposes an undue training burden on mariners.
Additionally, this training is not required by domestic statute or by
the minimum international standards contained in the STCW Convention or
the STCW Code for officers serving at the operational level. We also
propose to redesignate Sec. 11.329(a)(4)(vi) through (a)(4)(xi) as
Sec. 11.329(a)(4)(v) through (a)(4)(x), respectively.

Section 12.611--Requirements To Qualify for an STCW Endorsement as
Electro-Technical Rating on Vessels Powered by Main Propulsion
Machinery of 750 kW/1,000 HP or More

The Coast Guard is also proposing to revise Sec. 12.611(a) as
follows. We would remove Sec. 12.611(4), including Sec.
12.611(a)(4)(i), requiring the completion of CSM training, Sec.
12.611(a)(4)(ii), requiring the completion of an approved course in
high-voltage power systems to qualify for an STCW endorsement as an ETR
on vessels powered by main propulsion machinery of 750 kW/1,000 HP or
more. The purpose of CSM training is to provide knowledge of computer
equipment for the purpose of performing equipment maintenance; however,
an ETR is not authorized to work on computer equipment without being
under the direct supervision of a credentialed officer. The officer
would be responsible for making determinations about the appropriate
computer work to be completed and would be the primary person
completing the work with an ETR supporting them. Similarly, the purpose
of training in HVPS training is to provide knowledge of the systems; an
ETR is not authorized to work on HVPS without being under the direct
supervision of a credentialed officer. The officer would be the primary
person completing the work with an ETR supporting them. Therefore,
these training requirements go beyond the

[[Page 62388]]

skillset necessary, and the level of responsibility associated with an
ETR endorsement; thus, the training is unnecessary and overly
burdensome.
For these same reasons, the Coast Guard would make a conforming
edit to Sec. 12.611(b) to remove the text referencing Sec.
12.611(a)(4).

VI. Regulatory Analyses

We developed this proposed rule after considering numerous statutes
and Executive orders related to rulemaking. A summary of our analyses
based on these statutes or Executive orders follows.

A. Regulatory Planning and Review

Executive Orders 12866 (Regulatory Planning and Review) and 13563
(Improving Regulation and Regulatory Review) direct agencies to assess
the costs and benefits of available regulatory alternatives and, if
regulation is necessary, to select regulatory approaches that maximize
net benefits. Executive Order 13563 emphasizes the importance of
quantifying both costs and benefits, of reducing costs, of harmonizing
rules, and of promoting flexibility. Executive Order 13610 also
promotes the goals of Executive Order 13563 as it aims to modernize the
regulatory systems and to reduce unjustified regulatory burdens and
costs on the public. Executive Order 14192 (Unleashing Prosperity
Through Deregulation) directs agencies to significantly reduce the
private expenditures required to comply with Federal regulations and
provides that ``any new incremental costs associated with new
regulations shall, to the extent permitted by law, be offset by the
elimination of existing costs associated with at least 10 prior
regulations.''
The Office of Management and Budget (OMB) has not designated this
proposed rule as a significant regulatory action under section 3(f) of
Executive Order 12866. Accordingly, OMB has not reviewed it.
This proposed rule, if finalized as proposed, is expected to be an
Executive Order 14192 deregulatory action.
A regulatory analysis (RA) follows. We use the most recent data
available. In many instances, we present values in year 2025 dollars.
However, to meet the requirements of Executive Order 14192, when
estimating the annualized net cost savings using perpetual discounting,
we deflate year 2025 dollars to year 2024 dollars.
The Coast Guard proposes to remove six requirements from its
regulations related to the STCW Convention and STCW Code endorsements:
LMS, BRM, ETSO, CSM, and HVPS training for specific endorsements, and
the requirement to meet the standard of competence in LTW skills.\3\
---------------------------------------------------------------------------

\3\ See Section IV., Background, of this preamble for a
discussion of these changes.
---------------------------------------------------------------------------

We assume that the cost of attending the required training (such as
tuition, travel, lodging, meals and opportunity cost of time) and
obtaining an MMC (such as attaching the appropriate documentation)
falls on the individual obtaining the credential, making the training
requirement economically burdensome to individuals. We acknowledge that
in some circumstances companies offer tuition subsidies as an incentive
to mariners, and therefore, some of the cost savings would be shared
between mariners and employers of mariners. However, we have no data on
the amount or frequency of these subsidies and cannot estimate a
division of cost savings between the parties, but we believe the
subsidies are rare. Therefore, when we refer to the costs to
``mariners,'' we are referring to ``mariners and employers of
mariners'' who bear the cost of these trainings. We request comments
from the public regarding the extent to which private sector employers
incur costs from these training requirements.
Using historical data on STCW endorsements issued from 2022 to 2024
from the Coast Guard's Merchant Mariner Licensing Documentation (MMLD)
database,\4\ we estimate that an average of 825 mariners \5\ would
benefit each year from this proposed rule.\6\ The reason we used data
from the 2022-2024 timeframe here, as well as in many other parts of
this Regulatory Analysis, is to avoid the distortions in the data
caused by the COVID crisis that immediately preceded these years. The
cost savings to those mariners would be avoided costs because they
would not be required to complete the LMS, BRM, ETSO, CSM, or HVPS
training, or be required to meet the standard of competence in LTW
skills to qualify for their respective STCW endorsements. The cost
savings to mariners includes avoided costs for tuition, travel and
related expenses; and the opportunity cost of time to attend training
or complete assessments and attach proof of training or assessment to
an application for an MMC. Currently, 46 CFR part 15 has no manning
requirement for the ETR on any vessel, and, therefore, no substantive
data on the population is available, and the Coast Guard cannot
estimate cost savings for the CSM or HVPS training in this analysis.
However, if data becomes available prior to the publication of the
final rule, the Coast Guard will revise the regulatory analysis
appropriately. We request comments from the public about the ETR
population.
---------------------------------------------------------------------------

\4\ The MMLD is utilized to issue MMCs.
\5\ 172 deck officers for LMS, 25 mariners for BRM, 168 mariners
for LTW (84 mariners taking the assessment and 84 mariners
evaluating them), and 460 mariners for ETSO.
\6\ The Coast Guard is not able to assess the affected
population due to lack of substantive data to determine how many
mariners would be taking an approved CSM to meet the requirements
for an ETR endorsement.
---------------------------------------------------------------------------

Training providers that offer these trainings may lose revenue from
these courses due to reduced demand. However, as shown in B. Small
Entities, we believe that this revenue loss will be minimal.
Table 1 provides a summary of the affected population and the cost
savings components of this proposed rule. The Coast Guard estimates the
total 10-year cost savings of this proposed rule to be about
$42,817,136 ($6,967,231 for removing LMS training requirements +
$692,139 for removing BRM training requirements + $583,617 for removing
the requirement to meet the standard of competence in LTW skills +
$34,560,474 for removing ETSO training requirements + $13,675 for
reducing administrative costs for the Federal Government), discounted
at 7 percent. Furthermore, we estimate the annualized total cost
savings to be about $6,096,197 ($991,977 for LMS + $98,545 for BRM +
$83,094 for LTW skills + $4,920,634 for ETSO + $1,947 for reducing
administrative costs of verifying training and assessments for the
Federal Government), discounted at 7 percent. Using a perpetual period
of analysis, we estimate the total annualized cost savings of this
proposed rule to be $3,833,921 million in 2024 dollars, using a 7
percent discounted rate.
---------------------------------------------------------------------------

\7\ The average is based on the three years 2022, 2023, and
2024.
\8\ The Coast Guard has 3 years of Merchant Mariner Licensing
Documentation (MMLD) data from 2022 to 2024; (515 divided by 3
equals 171.66), 172 (rounded). We obtained the population of Masters
who operate vessels of less than 500 GT limited to near-coastal
waters from the National Maritime Center (NMC).
\9\ The Coast Guard has 3 years of MMLD data from 2022 to 2024;
(74 divided by 3 equals 24.67), 25 (rounded). We obtained the
population of OINCWs, who operate vessels of less than 500 GT
limited to near-coastal waters from the NMC.
\10\ The Coast Guard has 3 years of MMLD data from 2022 to 2024;
(251 divided by 3 equals 83.67), 84 (rounded). We obtained the
population of OINCWs, who operate vessels of less than 500 GT
limited to near-coastal waters from the NMC. We then estimated that
for every such OICNW, there is one Qualified Assessor (QA) who
evaluated them.
\11\ The Coast Guard has 3 years of MMLD data from 2022 to 2024;
(1,379 divided by 3 equals 459.67), 460 (rounded). We obtained the
population of OINEWs in a manned engineroom, on vessels powered by
main propulsion machinery of 750 kW/1,000 HP propulsion power or
more from the NMC.

[[Page 62389]]

Table 1--Proposed CFR Changes and Estimated Cost Savings of the Proposed Rule
----------------------------------------------------------------------------------------------------------------
Affected
Change Description population Costs Cost savings
----------------------------------------------------------------------------------------------------------------
Eliminate 46 CFR 11.317(a)(3(iv) Remove the .................. No cost to No impact;
duplicate mariners or the editorial.
language Federal
requiring ``Radar Government.
Observer, if
serving on a
vessel with this
equipment.'' The
duplicate
requirement,
currently at
(a)(3)(vii) will
remain and will
be redesignated
as (a)(3)(v).
Eliminate 46 CFR 11.317(a)(3)(v) Remove LMS 515 total deck No cost to deck $991,977
& 11.317(b)(1). training officers, based officers or the annualized and
requirements for on a 3-year data Federal $6,967,231 for 10-
deck officers period,\7\ would Government. year cost savings
seeking an no longer be for deck officers
original or required to take (7% discount
renewal STCW LMS training. rate).
endorsement as Annual average of $452 annualized
Master of vessels 172 deck officers and $3,175 for 10-
of less than 500 would benefit year cost savings
GT limited to from the proposed for the Federal
near-coastal rule \8\. Government (7%
waters. discount rate).
Eliminate 46 CFR Remove BRM 74 total mariners, No cost to $98,545 annualized
11.321(a)(3)(iv). training based on a 3-year mariners or the and $692,139 for
requirement for data period, Federal 10-year cost
mariners seeking would no longer Government. savings for
an original STCW be required to mariners (cost
endorsement as take BRM training. savings) (7%
OICNW of vessels Annual average of discount rate)
of less than 500 25 mariners would $66 annualized and
GT limited to benefit from the $464 for 10-year
near-coastal proposed rule \9\. cost savings for
waters. the Federal
Government (7%
discount rate).
Eliminate 46 CFR 11.321(b)(1)... Remove the 251 mariners based No cost to $83,094 annualized
requirement to on a 3-year data mariners or the and $583,617 for
meet the standard period would no Federal 10-year cost
of competence in longer be Government. savings for
LTW skills for required to meet mariners (cost
mariners seeking the standard of savings) (7%
an original or competence in LTW discount rate).
renewal STCW skills. This $1,208 annualized
endorsement as would also reduce and $8,484 for 10-
OICNW of vessels the burden on the year cost savings
of less than 500 Qualified for the Federal
GT limited to Assessors (QAs) Government (7%
near-coastal who currently discount rate).
waters. assess these
mariners.
Annual average of
84 mariners would
benefit from
proposed rule
\10\.
Eliminate 46 CFR 11.329(a)(4)(v) Remove the ETSO 1,379 mariners No cost to $4,920,634
training based on a 3-year mariners or the annualized and
requirement for data period would Federal $34,560,474 for
mariners seeking no longer be Government. 10-year cost
an original STCW required to take savings for
endorsement as ETSO training. mariners (cost
OICEW in a manned Annual average of savings) (7%
engineroom on 460 mariners discount rate).
vessels powered would benefit $221 annualized
by main from the proposed and $1,552 for 10-
propulsion rule \11\. year cost savings
machinery of 750 for the Federal
kW/1,000 HP Government (7%
propulsion power discount rate).
or more.
Eliminate 46 CFR 12.611(a)(4)... Remove training The Coast Guard is No cost to Not able to assess
requirements for not able to mariners or the cost savings or
mariners seeking assess the Federal burden hour
an original STCW affected Government. reduction because
endorsement as population due to currently there
ETR on vessels lack of are no vessel
powered by main substantive data manning
propulsion to determine how requirements for
machinery of many mariners an ETR
750kW/1,000 HP or would be taking endorsement.
more. approved CSM or
HVPS training to
meet the
requirements for
an ETR
endorsement.
----------------------------------------------------------------------------------------------------------------

Affected Population
This proposed rule would affect mariners seeking the following
training or assessment to qualify for STCW endorsements:
<bullet> LMS training to be endorsed as Master of vessels of less
than 500 GT limited to near-coastal waters;
<bullet> BRM training to be endorsed as OICNW on vessels of less
than 500 GT limited to near-coastal waters;
<bullet> LTW skills assessment to be endorsed as OICNW on vessels
of less than 500 GT limited to near-coastal waters;
<bullet> ETSO training to be endorsed as OICEW in a manned
engineroom on vessels powered by main propulsion machinery of 750 kW/
1,000 HP propulsion power or more; and
<bullet> CSM training to be endorsed as ETR on vessels powered by
main propulsion machinery of 750 kW/1,000 HP or more; and
<bullet> HVPS training to be endorsed as ETR on vessels powered by
main propulsion machinery of 750 kW/1,000 HP or more.
Per Section IV., Background, and table 1 of this proposed rule,
there are no vessel manning requirements for ETRs and there was no
available data when we performed this analysis to forecast the number
of mariners who may seek ETR endorsements. Therefore, we cannot
estimate cost savings or the burden-hour reduction for the CSM or HVPS
training. However, if data becomes available prior to the publication
of the final rule, the Coast Guard will revise the regulatory analysis
appropriately. We request comments from the public about the ETR
population.
The MMLD database is utilized to issue MMCs at the National
Maritime Center (NMC). Table 2 presents the STCW endorsement data used
to calculate the affected population of mariners who would be required
to complete LMS, BRM, and ETSO training and to meet the standard of
competence in LTW skills in the absence of this rule. The data
presented in the table comes from MMLD.

[[Page 62390]]

Table 2--Estimated Annual Number of Mariners Applying for STCW Endorsements That Require LMS, BRM and ETSO Training
--------------------------------------------------------------------------------------------------------------------------------------------------------
OICNW of vessels
Master of vessels OICNW of vessels of less than 500
of less than 500 of less than 500 GT limited to OICEW in a manned
GT limited to GT limited to near-coastal engineroom,
near-coastal near-coastal waters, renewal original
Year waters, original waters, original endorsement endorsement Total
endorsement endorsement (currently (currently
(currently (currently required to meet required to take
required to take required to take the standard of ETSO training)
LMS training) BRM training) competence in LTW
skills)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2022........................................................ 293 34 82 456 865
2023........................................................ 151 17 64 462 694
2024........................................................ 71 23 105 461 660
-------------------------------------------------------------------------------------------
Total................................................... 515 74 251 1,379 2,219
-------------------------------------------------------------------------------------------
Average................................................. 172 25 84 460 741
--------------------------------------------------------------------------------------------------------------------------------------------------------

To estimate the population of mariners who currently need to take
LMS training and would be affected by this proposed rule, we estimate
the number of Masters of vessels of less than 500 GT limited to near-
coastal waters to whom the NMC issued an original (not renewal)
endorsement each year.\12\ We added together historical populations
from calendar year 2022 to calendar year 2024 to obtain the aggregate
number for these years, 515, and then divided this number by the total
number of years of available credentialing data, or 3 years, to obtain
the average size of the affected population per year, or about 172 \13\
(515 / 3). This is reflected in the column of table 2 titled ``Master
of vessels of less than 500 GT limited to near-coastal waters, original
endorsement (currently required to take LMS training).''
---------------------------------------------------------------------------

\12\ These mariners currently need to take LMS training but
would not need to under the proposed rule.
\13\ This number is rounded to the closest whole number.
---------------------------------------------------------------------------

To estimate the population of mariners who currently need to take
BRM training and would be affected by this proposed rule, we estimate
the number of OICNWs of vessels of less than 500 GT limited to near-
coastal waters to whom the NMC issued an original (not renewal)
endorsement each year. These mariners currently need to take BRM
training but would not need to under the proposed rule. As before, we
divide the total number of credentials issued between 2022 and 2024, to
obtain the number, 74, by the total number of years of available
credentialing data, or 3 years, to obtain the average number of
mariners per year, or about 25 (74 / 3).\14\ This is reflected in the
column of table 2 titled ``OICNW of vessels of less than 500 GT limited
to near-coastal waters, original endorsement (currently required to
take BRM training).''
---------------------------------------------------------------------------

\14\ Rounded to closest whole number.
---------------------------------------------------------------------------

To estimate the population of mariners who currently need to meet
the standard of competence in LTW skills and would be affected by this
proposed rule, we estimate the number of OICNW of vessels of less than
500 GT limited to near-coastal waters to whom the NMC issued a renewal
endorsement each year. These mariners currently need to meet the
standard of competency for LTW skills but would not need to be under
the proposed rule. As before, we divide the total number of credentials
renewed between 2022 and 2024, to obtain the number, 251, by the total
number of years of available credentialing data, which is 3 years, to
obtain the average number of mariners per year, or about 84 (251 /
3).\15\ This is reflected in the column of table 2 titled ``OICNW of
vessels of less than 500 GT limited to near-coastal waters, renewal
endorsement (currently required to meet the standard of competence in
LTW skills).''
---------------------------------------------------------------------------

\15\ Rounded to closest whole number.
---------------------------------------------------------------------------

To estimate the population of mariners who currently need to take
ETSO training and would be affected by this proposed rule, we estimate
the number of OICEW in a manned engineroom to whom the NMC issued an
original (not renewal) endorsement each year. These mariners currently
need to take ETSO training but would not need to under the proposed
rule. As before, we divide the total number of credentials issued
between 2022 and 2024, to obtain the number, 1,379, by the total number
of years of available credentialing data, which is 3 years, to obtain
the average number of mariners per year, or about 460 (1,379 / 3).\16\
This is reflected in the column of table 2 titled ``OICEW in a manned
engineroom, original endorsement (currently required to take ETSO
training).''
---------------------------------------------------------------------------

\16\ Rounded to closest whole number.
---------------------------------------------------------------------------

As stated previously, per Section IV., Background, and table 1 of
this proposed rule, there are no vessel manning requirements for ETRs
and there was no available data when we performed this analysis to
estimate the number of mariners who may seek ETR endorsements.
Therefore, there is no estimate for the affected population of mariners
seeking this endorsement; hence, we cannot estimate cost savings or the
burden-hour reduction for the CSM or HVPS training. However, if data
becomes available prior to the publication of the final rule, the Coast
Guard will revise the regulatory analysis appropriately. We request
comments from the public about the ETR population.
Costs
The regulatory changes in this proposed rule would not impose any
new or additional costs to mariners or the Federal Government. The
Coast Guard estimates that the cost of attending the required training
(such as tuition, travel, lodging, meals and opportunity cost of lost
income) and obtaining an MMC (such as attaching the appropriate
documentation) is borne by the individual obtaining the credential,
making the training requirement economically burdensome to individuals.
By removing the six requirements for these STCW endorsements, there
would be a reduced impact on the mariners and on the Federal Government
(in terms of the review process).
Cost Savings
The cost savings to mariners are the costs avoided by not attending
the LMS, BRM, ETSO, CSM, and HVPS training or meeting the standard of
competence in LTW skills. The cost savings to mariners are the total of
the avoided costs for

[[Page 62391]]

tuition, travel and related expenses, lost time to attend training or
to complete assessments, and the time to attach the relevant
documentation to an application for an MMC. The cost savings to the
Federal Government include the time to verify that the training or
skill assessments were completed.
Benefits
The primary monetized benefit of this proposed rule is the cost
savings mariners would realize from not having to complete either the
LMS, BRM, or ETSO training or having to meet the standard of competence
in LTW skills. Non-quantifiable benefits could be realized by mariners
who would not have to sacrifice their personal time and money
completing training and assessments for certain STCW endorsements.
Baseline
We based our cost estimates used in this RA for LMS, BRM, and ETSO
training and LTW skills assessments on information we obtained from the
websites of Coast Guard-approved training providers.\17\ Costs
associated with deck officer wage, travel and lodging are derived from
the Bureau of Labor Statistics (BLS), the U.S. Department of
Transportation (DOT)-Bureau of Transportation Statistics (BTS), and the
General Services Administration (GSA). Additionally, round-trip airport
transfer data is derived from a 2006 Coast Guard interim rule,
``Validation of Merchant Mariners' Vital Information and Issuance of
Coast Guard Merchant Mariner's Licenses and Certificates of Registry.''
\18\
---------------------------------------------------------------------------

\17\ We searched the websites of all training providers. For the
purpose of this analysis, we included only training courses with
information on course tuition and course duration easily accessible
online. We used the list of approved course providers as of May 15,
2025. Out of 22 training providers offering Coast Guard-approved LMS
training, 15 (68 percent rounded) list both tuition cost and course
duration. Out of 11 training providers offering Coast Guard-approved
LMS training, 9 (82 percent rounded) list both tuition cost and
course duration. Out of 2 training providers offering Coast Guard-
approved ETSO training, 1 (50 percent) listed both tuition cost and
course duration.
\18\ We adjusted for inflation the estimates obtained from this
published final rule on January 13, 2006 (71 FR 2154).
---------------------------------------------------------------------------

To obtain the cost calculations associated with this proposed rule,
the Coast Guard estimated the annual costs to mariners to fulfill the
six requirements listed in Section IV., Background. After establishing
the costs to mariners, we calculated the costs saved by not having to
fulfill these requirements. To find the annual costs associated with
LMS, BRM, and ETSO trainings, we estimated the current costs to
mariners including the tuition, the opportunity cost of the time to
take the training, the time to travel to the training, the mileage, the
lodging costs, when applicable, and the cost of purchasing meals and
incidentals. To obtain the annual costs associated with meeting the
standard of competence in LTW skills, we estimated the opportunity
costs of time associated with mariners completing the assessments
required to demonstrate meeting the standards of competence. We also
accounted for the time a mariner would spend preparing the
documentation of completing these requirements as part of an MMC
application, and in the following sections, we discuss these costs.
To assess the cost savings, the Coast Guard evaluated the
components of the current baseline costs for mariners and the Federal
Government. These costs are as follows:

<bullet> Tuition costs
<bullet> Opportunity costs of time
<bullet> Opportunity costs of travel time
<bullet> Fuel costs
<bullet> Meal and lodging costs
<bullet> Compiling documentation (for mariners) and verifying relevant
documentation (e.g. verifying the training certificate for LMS) (for
Coast Guard personnel)

We discuss each of the above-mentioned costs in greater detail
below.
Tuition Cost for LMS, BRM, and ETSO Training and Opportunity Cost for
Meeting the Standard of Competence in LTW Skills
To estimate the tuition cost, the Coast Guard used data from the
NMC, which includes information on 15 training providers offering Coast
Guard-approved LMS training, 9 training providers offering Coast Guard-
approved BRM training, and 2 training providers offering Coast Guard-
approved ETSO training. There are 8 training providers offering both
LMS and BRM training and list the course tuition and duration online.
The cost of LMS training ranges from $650 to $1,925 in terms of 2025
dollars, and the cost of BRM training ranges from $600 to $3,765 in
2025 dollars, which can be found in table 3 and table 4, respectively.
We then calculated an average tuition cost for both LMS and BRM
training from the training provider cost data in these tables to get
$1,118for LMS training and $1,287 for BRM training in 2025 dollars.

Table 3--LMS Training: Tuition, Completion Time, and Webpage Information
----------------------------------------------------------------------------------------------------------------
Tuition Time (in
Course provider ($2025) hours) Hyperlink
----------------------------------------------------------------------------------------------------------------
Chesapeake Marine Training Institute.......... $950 32 <a href="http://www.chesapeakemarineinst.com/cmti-course/leadership-and-managerial-skills/">www.chesapeakemarineinst.com/cmti-course/leadership-and-managerial-skills/</a> skills/.
Delgado Community College..................... 650 35 <a href="http://www.dcc.edu/documents/workforce-development/maritime/2qe2025.pdf">www.dcc.edu/documents/workforce-development/maritime/2qe2025.pdf</a>.
Eat on the Wild Side-Crawford Nautical 1,000 40 crawfordnautical.org/store/p/
Training. leadership.
Maine Maritime Academy_Continuing Education.. 1,200 40 <a href="http://mainemaritime.edu/cpmd/courses/stcw-gap-courses/">mainemaritime.edu/cpmd/courses/stcw-gap-courses/</a>.
Mariner Skills, LLC........................... 750 35 <a href="http://marinerskills.com/leadership-and-managerial-skills.php">marinerskills.com/leadership-and-managerial-skills.php</a>.
Maritime Institute............................ 1,200 35 <a href="http://maritimeinstitute.com/course/leadership-and-managerial-skills/">maritimeinstitute.com/course/leadership-and-managerial-skills/</a>.
Maritime Institute of Technology & Graduate 1,765 35 www.mitags.org/course/leadership-and-
Studies. managerial-skills/.
Maritime Professional Training................ 1,199 40 <a href="http://www.mptusa.com/course-details/human-element-leadership-management-helm-course-616">www.mptusa.com/course-details/human-element-leadership-management-helm-course-616</a>.
Northeast Maritime Institute.................. 1,075 40 <a href="http://nmi.edu/leadership-and-managerial-skills/">nmi.edu/leadership-and-managerial-skills/</a> skills/.
Quality Maritime Training, LLC................ 1,045 40 <a href="http://qualitymaritimetraining.com/courses/">qualitymaritimetraining.com/courses/</a>.
RCM Maritime, LLC............................. 1,049 36 <a href="http://www.rcmmaritime.com/course/leadership-and-managerial-skills/">www.rcmmaritime.com/course/leadership-and-managerial-skills/</a>.
RelyOn Nutec.................................. 657 32 <a href="http://shop.relyon.com/Course/CourseDetails?courseTypeId=71570&countryId=12">shop.relyon.com/Course/CourseDetails?courseTypeId=71570&countryId=12</a> tryId=12.

[[Page 62392]]

San Jacinto College Maritime Technology & 1,000 32 www.sanjac.edu/sites/default/files/
Training Center. inline-files/maritime-commercial-
class-schedule.pdf.
STAR Center................................... 1,925 40 <a href="http://www.star-center.com/schedule.html">www.star-center.com/schedule.html</a>.
State University New York Maritime College-- 1,300 35 https://www.sunymaritime.edu/about/
Department of Professional Education & visiting-maritime/community-programs/
Training. professional-education-training/
leadership-and-0.
Average....................................... 1,144 36
----------------------------------------------------------------------------------------------------------------
Note: Totals may not sum due to independent rounding (to nearest whole number). All websites last accessed on
June 4, 2026. To estimate the completion time in hours for courses that only had the completion time in hours,
we used the standard 8-hour business day to reflect the length of a workday. The time (in hours) for the LMS
course at Delgado Community College comes from <a href="http://www.dcc.edu/workforce-development/maritime/courses.aspx">www.dcc.edu/workforce-development/maritime/courses.aspx</a>. The
time (in hours) for the LMS course at Eat on the Wild Side-Crawford Nautical Training comes from <a href="https://crawfordnautical.org/credentialing">https://crawfordnautical.org/credentialing</a>. The time (in hours) for the LMS course at the Maritime Institute comes
from <a href="http://www.maritimeinstitute.com/wp-content/uploads/2025/04/2025-COURSE-SCHEDULE-4-22-2025_tc.pdf">www.maritimeinstitute.com/wp-content/uploads/2025/04/2025-COURSE-SCHEDULE-4-22-2025_tc.pdf</a>.

Table 4--BRM Training: Tuition, Completion Time, and Webpage Information
----------------------------------------------------------------------------------------------------------------
Tuition Time (in
Course provider (2025 $) hours) Hyperlink
----------------------------------------------------------------------------------------------------------------
Captain School USVI........................... $1,300 24 <a href="http://www.captainschoolusvi.com/class-schedule">www.captainschoolusvi.com/class-schedule</a> schedule.
Chesapeake Marine Training Institute.......... 750 32 <a href="http://www.chesapeakemarineinst.com/cmti-course/bridge-resource-management-brm/">www.chesapeakemarineinst.com/cmti-course/bridge-resource-management-brm/</a>
.
Eat on the Wild Side_Crawford Nautical 600 21 crawfordnautical.org/courses/p/bridge-
Training. resource-management.
Maritime Institute............................ 850 32 <a href="http://maritimeinstitute.com/course/bridge-resource-management/">maritimeinstitute.com/course/bridge-resource-management/</a>.
Maritime Institute of Technology & Graduate 3,765 35 www.mitags.org/course/bridge-resource-
Studies. management-35-hour/.
Maritime Professional Training................ 1,999 24 <a href="http://www.mptusa.com/course-details/bridge-resource-management-with-simulator-tasks-course-151S">www.mptusa.com/course-details/bridge-resource-management-with-simulator-tasks-course-151S</a>.
Northeast Maritime Institute.................. 825 24 <a href="http://nmi.edu/bridge-resource-management/">nmi.edu/bridge-resource-management/</a>.
Quality Maritime Training, LLC................ 695 24 <a href="http://qualitymaritimetraining.com/courses/">qualitymaritimetraining.com/courses/</a>.
San Jacinto College Maritime Technology & 800 24 www.sanjac.edu/sites/default/files/
Training Center. inline-files/maritime-commercial-
class-schedule.pdf.
Average....................................... 1,287 27
----------------------------------------------------------------------------------------------------------------
Note: Totals may not sum due to independent rounding (to the nearest whole number). All websites last accessed
on June 4, 2026. To estimate the completion time in hours for courses that only had the completion time in
hours, we used the standard 8-hour business day to reflect the length of a workday.

While there is not publicly available information on the tuition
cost for the two Coast Guard-approved training providers offering
stand-alone ETSO courses (STAR Center and ECO Training Center, LLC), we
estimate the tuition cost of an ETSO course based on other courses that
include the ETSO training requirements and the duration of the stand-
alone ETSO courses.
Four training providers offer courses that include the ETSO
training requirements. Table 5 presents the training provider, course
name, course duration, and tuition below, as well as the calculated
tuition cost per day.
At the STAR Center, the only training provider that both offers a
stand-alone ETSO course and has its course duration publicly available,
the ETSO course is 9 days.\19\ Using the average tuition cost per day
calculated in table 5 below and adjusting for inflation using the
previously mentioned GDP deflator multiplier, we estimate that tuition
for the ETSO course at the STAR Center is $2,061 (9 days x $229 average
tuition cost per day in 2025 dollars).
---------------------------------------------------------------------------

\19\ <a href="http://www.star-center.com/courses/OICEW.ETSO.pdf">www.star-center.com/courses/OICEW.ETSO.pdf</a> (accessed June
4, 2026).

Table 5--Courses That Include ETSO Training
----------------------------------------------------------------------------------------------------------------
Course
Course provider Course name Tuition duration Average tuition
(2025 $) (days) per day (2025 $)
(a) (b) (c) = (a) / (b)
----------------------------------------------------------------------------------------------------------------
Maritime Institute....................... Electrical Machinery and $4,200 20 $210
Basic Electronics (EMBE)
\20\.
Maritime Professional Training........... Auxiliary Machinery (MARTPT- 3,199 15 213
862) \21\.
San Jacinto College Maritime Technology & OICEW-Auxiliary Machinery 3,500 15 233
Training Center. \22\.

[[Page 62393]]

Training Mariners for Unlimited Engineer Electrical Machinery and 3,550 13 273
License. Basic Electronics (EMBE)
\23\.
-----------------------------------------
Total................................ ........................... 14,449 63 ................
-----------------------------------------
Average.............................. ........................... .......... .......... 229
----------------------------------------------------------------------------------------------------------------

The Coast Guard then estimated the cost of time it takes for
mariners to meet the standard of competence in LTW skills which is
required to qualify for an STCW endorsement as an OICNW of vessels of
less than 500 GT limited to near-coastal waters. The requirement to
provide evidence of meeting the standard of competence in LTW skills is
demonstrated through either the completion of shipboard assessments of
competence as witnessed by a QA \24\ or may be completed as part of
Coast Guard-approved training. Based on data provided by the NMC,\25\
there are 740 QAs approved to conduct LTW skills assessments. These QAs
all hold STCW endorsements as deck officers at either management or
operational levels. To estimate the time it would take to meet the
standard of competence in LTW skills, the NMC provided information on
nine training providers that offer Coast Guard-approved LTW
training.\26\ The Coast Guard used this information to determine the
average length of time it takes for a mariner to complete the
demonstration of competence in LTW skills, which is approximately 9
hours. Table 6 presents this information.\27\
---------------------------------------------------------------------------

\20\ <a href="http://www.maritimeinstitute.com/course/electrical-machinery-and-basic-electronics/">www.maritimeinstitute.com/course/electrical-machinery-and-basic-electronics/</a> (accessed June 4, 2026).
\21\ <a href="http://www.mptusa.com/course-details/auxiliary-machinery-course-271">www.mptusa.com/course-details/auxiliary-machinery-course-271</a> (accessed June 4, 2026).
\22\ <a href="http://noncredit.sanjac.edu/search/publicCourseSearchDetails.do?method=load&courseId=42193&selectedProgramAreaId=19569&selectedProgramStreamId=19629#courseSectionDetails_6302357">noncredit.sanjac.edu/search/publicCourseSearchDetails.do?method=load&courseId=42193&selectedProgramAreaId=19569&selectedProgramStreamId=19629#courseSectionDetails_6302357</a> (accessed June 4, 2026).
\23\ <a href="http://tmfuel.coursestorm.com/course/electrical-machinery-and-basic-electronics11">tmfuel.coursestorm.com/course/electrical-machinery-and-basic-electronics11</a> (accessed June 4, 2026).
\24\ 46 CFR 10.107 defines a ``Qualified Assessor or QA'' as a
person who is qualified to evaluate, for STCW endorsements, whether
an applicant has demonstrated the necessary level of competence in
the task for which the assessment is being made. This person must be
individually approved by the Coast Guard.
\25\ The data is current as of May 27, 2025.
\26\ We only consider courses with course duration readily
available online, representing at least 60 percent of all courses as
explained in the analysis.
\27\ The Coast Guard did not incorporate the tuition cost of LTW
skills training because we estimate all mariners use QAs to witness
the demonstration of the standard of competence in LTW skills as it
does not require travel and tuition and can be completed at a
mariner's workplace (onboard a vessel).

Table 6--LTW Skills: Completion Time and Webpage Information
------------------------------------------------------------------------
Time (in
Assessment provider hours) Hyperlink
------------------------------------------------------------------------
Chesapeake Marine Training 8 www.chesapeakemarineinst.
Institute. com/cmti-course/
leadership-and-
teamworking-skills/.
Mariner Skills, LLC.............. 8 <a href="http://marinerskills.com/leadership-and-teamworking-skills">marinerskills.com/leadership-and-teamworking-skills</a>.
Maritime Institute............... 8 <a href="http://maritimeinstitute.com/course/leadership-and-teamworking-skills/">maritimeinstitute.com/course/leadership-and-teamworking-skills/</a>.
Maritime Institute of Technology 7 www.mitags.org/course/
& Graduate Studies. leadership-and-
teamworking-skills/.
Maritime Professional Training... 8 <a href="http://www.mptusa.com/course-details/leadership-and-teamworking-skills-martpt-768-course-216">www.mptusa.com/course-details/leadership-and-teamworking-skills-martpt-768-course-216</a>.
Quality Maritime Training, LLC... 8 <a href="http://qualitymaritimetraining.com/courses/">qualitymaritimetraining.com/courses/</a> om/courses/.
San Jacinto College Maritime 8 www.sanjac.edu/sites/
Technology & Training Center. default/files/inline-
files/maritime-
commercial-class-
schedule.pdf.
Seafarers Harry Lundeberg School 14 www.seafarers.org/wp-
of Seamanship. content/uploads/2018/12/
PHCCatalogue.pdf (page
23).
Calhoon MEBA Engineering School.. 8 <a href="http://www.mebaschool.org/20-curriculum/courses/general-education-courses/105-leadership-teamworking">www.mebaschool.org/20-curriculum/courses/general-education-courses/105-leadership-teamworking</a> teamworking.
Average.......................... 9
------------------------------------------------------------------------
Note: Totals may not sum due to independent rounding (to the nearest
whole number). All websites last accessed on June 4, 2026. To estimate
the completion time in hours for courses that only had the completion
time in hours, we used the standard 8-hour business day to reflect the
length of a workday.

Table 7 presents the tuition cost for mariners taking LMS, BRM and
ETSO training. We calculated these costs by multiplying our affected
population, provided in Table 2, by the average tuition cost of the
LMS, BRM and ETSO training provided in Table 3 and Table 4. We estimate
the total undiscounted cost for mariners taking the LMS training to be
$192,296 ($1,118 x 172 mariners) annually, the total undiscounted cost
for BRM training to be $32,175 ($1,287 x 25 mariners) annually, and the
total cost for mariners taking the ETSO training to be $948,060 ($2,061
x 460 mariners) annually.

[[Page 62394]]

Table 7--Tuition Costs (Undiscounted) for LMS, BRM, and ETSO Training
----------------------------------------------------------------------------------------------------------------
Tuition cost Number of
Course (2025 dollars) mariners Total cost
(a) (b) (c) = (a) x
(b)
----------------------------------------------------------------------------------------------------------------
LMS............................................................. $1,118 172 $192,296
BRM............................................................. 1,287 25 32,175
ETSO............................................................ 2,061 460 948,060
----------------------------------------------------------------------------------------------------------------

Opportunity Cost of Time
The Coast Guard then estimated the cost of time required for
mariners to complete the LMS, BRM and ETSO training and to meet the
standard of competence in LTW skills. When analyzing a day of Coast
Guard-approved training, we used the standard 8-hour business day to
reflect the length of a workday. The duration of LMS training ranges
from 32 to 40 hours with an average time being 36 hours as shown in
table 3. The duration of BRM training ranges from 21 to 35 hours with
an average time of 27 hours as shown in table 4. The duration of the
ETSO training is 70 hours.\28\
---------------------------------------------------------------------------

\28\ This course length comes from the ETSO course at the STAR
Center (<a href="http://www.star-center.com/courses/OICEW.ETSO.pdf">www.star-center.com/courses/OICEW.ETSO.pdf</a>; (accessed June
5, 2026). This is the only school for which we were able to find
data. We request public comment on any additional data the public
may have.
---------------------------------------------------------------------------

The Coast Guard obtained wage rate information for mariners from
the BLS, specifically the 2025 Occupational Employment and Wage
Statistics.\29\ For deck officers required to complete LMS training we
used the mean hourly wage rate for Standard Occupational Classification
Code (SOC Code) ``Captains, Mates, and Pilots of Water Vessels (53-
5021),'' for mariners required to complete BRM training and to meet the
standard of competence in LTW skills we used SOC Code ``Sailors and
Marine Oilers (53-5011),'' and for mariners required to complete ETSO
training, we used SOC Code ``Ship Engineers (53-5031).'' The BLS
reports the mean hourly wage rate for a Captain, Mate, or Pilot to be
$49.87 per hour, which we used to estimate the wage rate of deck
officers seeking an STCW endorsement as Master of vessels of less than
500 GT limited to near-coastal waters.\30\ Similarly, the BLS reports
the mean hourly wage rate for a sailor or marine oiler to be $27.32,
which we used for mariners seeking an STCW endorsement as an OICNW on
vessels of less than 500 GT limited to near-coastal waters.\31\
Similarly, the BLS reports the mean hourly wage rate for a Ship
Engineer to be $53.75, which we use for mariners seeking an STCW
endorsement as an OICEW.\32\ To account for employee benefits, we used
a load factor of 1.42.\33\ We then estimated the loaded mean hourly
wage rate for a deck officer completing LMS training to be about $70.82
($49.87 wage rate x 1.42 load factor). Similarly, we estimated the
loaded mean hourly wage rate for a mariner completing BRM training and
meeting the standard of competence in LTW skills to be about $38.79
($27.32 wage rate x 1.42 load factor). Similarly, we estimated the
loaded mean hourly wage rate for a mariner completing ETSO training to
be about $76.33 ($53.75 wage rate x 1.42 load factor).
---------------------------------------------------------------------------

\29\ <a href="https://www.bls.gov/oes/2025/may/oes_stru.htm">https://www.bls.gov/oes/2025/may/oes_stru.htm</a> (accessed
August 17, 2026).
\30\ To find the mean hourly wage for a Captain, Mate or Pilot
refer to the table in the following link: <a href="https://data.bls.gov/oesprofile/?major_group=530000&occupation=535011&measure=01&areas=INDUSTRY,STATE,MSA">https://data.bls.gov/oesprofile/?major_group=530000&occupation=535011&measure=01&areas=INDUSTRY,STATE,MSA</a> (accessed August 17, 2026).
\31\ To find the mean hourly wage for a sailor or marine oiler
refer to the table in the following link: <a href="https://data.bls.gov/oesprofile/?major_group=530000&occupation=535011&measure=01&areas=INDUSTRY,STATE,MSA">https://data.bls.gov/oesprofile/?major_group=530000&occupation=535011&measure=01&areas=INDUSTRY,STATE,MSA</a> (accessed August 17, 2026).
\32\ To find the mean hourly wage for a ship engineer refer to
the table in the following link: <a href="https://data.bls.gov/oesprofile/?major_group=530000&occupation=535031&measure=01&areas=INDUSTRY,STATE,MSA">https://data.bls.gov/oesprofile/?major_group=530000&occupation=535031&measure=01&areas=INDUSTRY,STATE,MSA</a>.
\33\ A loaded mean hourly wage rate is what a company pays per
hour to employ a person, not the hourly wage an employee receives.
The loaded mean hourly wage rate includes the cost of non-wage
benefits (health insurance, vacation, etc.). The Coast Guard
estimated the load factor by using Table 4 of the BLS news release
titled ``EMPLOYER COSTS FOR EMPLOYEE COMPENSATION--MARCH 2025'' and
available at <a href="https://www.bls.gov/news.release/archives/ecec_06132025.pdf">https://www.bls.gov/news.release/archives/ecec_06132025.pdf</a>. The Coast Guard used the ``Total compensation''
and ``Wages and salaries'' values for the ``Transportation and
material moving occupations,'' which are $35.22 and $23.87,
respectively. The Coast Guard divided $45.38 by $31.89 and obtained
a load factor of 1.42, rounded. The Coast Guard last accessed this
BLS' website on August 17, 2026.
---------------------------------------------------------------------------

We multiplied the loaded mean hourly wage rate by the number of
hours to complete the training to find the current opportunity cost for
a deck officer to take the LMS training, which is about $2,550 ($70.82
wage rate x 36 hours). Figures rounded to the nearest dollar. The
opportunity cost for a mariner to take the BRM course is about $1,047
($38.79 wage rate x 27 hours). The opportunity cost for a mariner to
take the ETSO course is about $5,343 ($76.33 wage rate x 70 hours).
The Coast Guard estimated the cost of time it takes for mariners to
meet the standard of competence in LTW skills necessary to qualify for
an STCW endorsement \34\ as OICNW of vessels of less than 500 GT
limited to near-coastal waters. The requirement to provide evidence of
meeting the standard of competence in LTW skills is demonstrated
through either the completion of shipboard assessments of competence as
witnessed by a QA,\35\ or may be completed as part of Coast Guard-
approved training. Based on data provided by the NMC, there are 740 QAs
approved to conduct LTW skills assessments. To estimate the time, it
would take to demonstrate meeting the standard of competence in LTW
skills, the Coast Guard used information on nine Coast Guard approved
LTW training courses to determine the average length of time it takes a
mariner to complete the demonstration of meeting the standard of
competence in LTW skills, which is approximately 9 hours.\36\
---------------------------------------------------------------------------

\34\ This requirement is necessary for mariners seeking to
qualify or renew the OICNW endorsement after January 2017.
\35\ 46 CFR 10.107 defines a ``Qualified Assessor or QA'' means
a person who is qualified to evaluate, for STCW endorsements,
whether an applicant has demonstrated the necessary level of
competence in the task for which the assessment is being made. This
person must be individually approved by the Coast Guard.
\36\ For information on LTW skills training information, refer
to table 6 in this preamble.
---------------------------------------------------------------------------

The Coast Guard also accounts for the time of the QA to witness the
demonstration of meeting the standard of competence in LTW skills.
Because individual mariners bear the financial burden of meeting
professional requirements to qualify for an MMC endorsement, and
considering the number of QAs is substantially larger than the
estimated annual population of OICNWs seeking the endorsement for the
first time (740 compared to 84), the Coast Guard estimates mariners
seeking this endorsement would utilize a QA to witness the
demonstration of LTW skills assessments versus taking approved training
to meet this requirement. This

[[Page 62395]]

is because an assessment with a QA occurs onboard a vessel and so the
mariner does not incur any travel costs. The Coast Guard has no
additional data concerning the number of mariners who complete the
assessments of competence utilizing a QA as opposed to completing
approved training. For this reason, we request information and comments
from the public and interested stakeholders regarding this assumption.
The population of mariners required to meet the standard of
competence in LTW skills is identical to the number of mariners
completing BRM training and receiving the STCW endorsement as an OICNW
on vessels less than 500 GT limited to near-coastal waters in 46 CFR
11.321. We used the same loaded mean hourly wage rate of $38.79 for
mariners meeting the standard of competence in LTW skills as we did for
mariners completing BRM training. For each demonstration of the
standard of competence in LTW skills utilizing a QA, there would be two
mariners involved: (1) The mariner demonstrating LTW skills
assessments; and (2) A QA witnessing the demonstration of LTW skills
assessments. Therefore, the opportunity cost of time would be for 168
mariners to complete a demonstration of LTW skills assessments (84
mariners demonstrating LTW skills assessments and 84 QAs witnessing the
demonstration of LTW skills assessments). We estimate the opportunity
cost of time for a mariner to demonstrate LTW skills assessments to be
about $349 ($38.79 x 9 hours) and the opportunity cost of time for a QA
to witness the demonstration of LTW skills assessments to be about $637
($70.82 x 9 hours).<SUP>37 38</SUP> Table 8 presents the total
opportunity cost of time for all mariners affected by this proposed
rule, taking the LMS, BRM, and ETSO training and meeting the standard
of competence in LTW skills.
---------------------------------------------------------------------------

\37\ Qualified Assessors are deck officers; therefore, they
would have the same loaded wage rate as SOC Code ``Captains, Mates,
and Pilots of Water Vessels (53-5021):'' $67.61 per hour.
\38\ Rounded to closest whole number.

Table 8--Opportunity Cost (Undiscounted) for Affected Mariners To Complete LMS Training, BRM Training, ETSO
Training, and Meeting the Standard of Competence in LTW Skills
[2025$]
----------------------------------------------------------------------------------------------------------------
Opportunity cost of
Training/assessment training/ Number of Total cost
assessment mariners
(a) (b) (c) = (a) x
(b)
----------------------------------------------------------------------------------------------------------------
LMS Training............................................... $2,550 172 $438,600
BRM Training............................................... 1,047 25 26,175
ETSO Training.............................................. 5,343 460 2,457,780
LTW Skills Assessment Mariners............................. 349 84 29,316
LTW Skills Assessment QAs.................................. 637 84 53,508
----------------------------------------------------------------------------------------------------------------
Note: Data for column (a) calculated in preceding paragraph. Data for column (b) comes from the ``Average'' row
in table 2. While table 2 does not explicitly estimate the number of QAs needed to verify that mariners have
met the standard of competence for LTW skills, we assume that there is one QA for each mariner needing to
demonstrate the standard of competence in LTW skills.

Methodology for Finding Travel Distributions
To estimate the cost of travel and the opportunity cost of travel
time, we assume varying modes of travel for mariners getting to and
from approved training based on the distribution of travel modes,
derived in table 16 of CG-MMC Policy Letter 01-21: Guidelines for
Qualifying for STCW Endorsements for Basic and Advanced IGF Code
Operations cost analysis.\39\ We reflect the same percentages in this
NPRM as in the policy letter by assuming that 20 percent would drive to
the training center and return the same day, 46 percent would drive and
lodge, and 34 percent would fly and lodge.\40\ The percentages used in
CG-MMC Policy Letter 01-21 derived from the distance required to travel
to the nearest training provider for each mariner based on the ZIP Code
associated with their credential and the ZIP Codes associated with the
training provider locations. The policy letter utilized a random sample
of 100 mariners with STCW endorsements involving the International Code
of Safety for Ships Using Gases or Other Low Flashpoint Fuels (IGF
Code) travelling to training centers offering relevant IGF Code
training courses. In that analysis, we determined that 20 mariners
would commute to the nearest training provider (or live less than 85.4
miles from a training provider), 46 would drive to the nearest training
provider and lodge overnight (or live between 85.4 miles and 583.5
miles from a training provider), and 34 would fly to the nearest
training provider and lodge overnight (or live greater than 583.5 miles
from a training provider).
---------------------------------------------------------------------------

\39\ <a href="https://www.regulations.gov/document/USCG-2020-0181-0002">https://www.regulations.gov/document/USCG-2020-0181-0002</a>.
Similar methodology was also used in the Implementation of Training
Requirements for Personnel Serving on U.S.-Flagged Passenger Ships
That Carry More Than 12 Passengers on International Voyages proposed
rule, published on June 21, 2024, (89 FR 52324), available at:
<a href="https://www.regulations.gov/document/USCG-2022-0649-0001">https://www.regulations.gov/document/USCG-2022-0649-0001</a>.
\40\ Id.
---------------------------------------------------------------------------

We have determined to use the percentages as they appear in CG-MMC
Policy Letter 01-21. We acknowledge that this creates uncertainty
surrounding our cost estimates related to travel for this specific
population of mariners. The Coast Guard requests public comment on our
decision to use these predetermined rates of travel for this cost
analysis.
We use the same methodology from CG-MMC Policy Letter 01-21 to
estimate the thresholds and opportunity costs for travel among the
affected population. Using updated data, the Coast Guard estimates that
mariners who live or reside less than 93.9 miles from a training
provider would commute to the closest site without lodging or utilizing
overnight accommodations. We base this assumption on a report titled,
``Commuting in America (2): The National Report on Commuting Patterns
and Trends,'' from the American Association of State Highway and
Transportation Officials, which posits that Americans, on average, are
willing to spend up to a maximum of 90 minutes commuting to work each
way.\41\

[[Page 62396]]

This report, which used data from the American Community Survey,
illustrates that approximately 97.5 percent of American commuters spent
90 minutes (1.5 hours) or less commuting to work.\42\ To convert 90
minutes into a distance, we calculate an average driving speed using
data from the Department of Transportation (DOT's) National Highway
Traffic Safety Administration's report, ``National Traffic Speeds
Survey III: 2015.'' \43\ From this report, we take the mean speed from
the three road classes across the five time periods provided. We obtain
an average speed of 62.6 mph. We then multiply the average speed of
these three road classes by 1.5 hours (90 minutes) to obtain our
commuting distance threshold of 93.9 miles (62.6 mph x 1.5 hours).
---------------------------------------------------------------------------

\41\ The American Association of State Highway and
Transportation Officials conducted the report in 2013 and used
Census Bureau data in the report. Please see Figure 11-13 on page 16
to obtain the travel distribution time to work in minutes. Readers
can access the report at <a href="https://transportation.org/traveltrends/commuting-in-america/brief-13-11-commuting-departure-time-and-trip-time/">https://transportation.org/traveltrends/commuting-in-america/brief-13-11-commuting-departure-time-and-trip-time/</a>. Last accessed August 18, 2026.
\42\ The American Community Survey is an ongoing survey by the
U.S. Census Bureau. It regularly gathers information pertaining to
demographics and housing characteristics of U.S. households. More
information on this survey can be found at: <a href="https://www.census.gov/programs-surveys/acs/about.html">https://www.census.gov/programs-surveys/acs/about.html</a> (last visited August 18, 2026).
For information on ``mega-commuting'' refer to footnote 29 or
this brochure from the ACS: <a href="https://www.census.gov/content/dam/Census/library/working-papers/2013/demo/SEHSD-WP2013-03.pdf">https://www.census.gov/content/dam/Census/library/working-papers/2013/demo/SEHSD-WP2013-03.pdf</a> (last
visited August 18, 2026).
\43\ In order to convert this to distance, we take the mean
total of table 12's Speed by Road Type and Time of Day estimates
from 2015 to get at average road speed of 62.6 miles per hour. This
information can be found in table 12 using the ``Download Document''
link for Publication No. DOT HS 812 485 (March 2018) at this
website: <a href="https://rosap.ntl.bts.gov/view/dot/35961">https://rosap.ntl.bts.gov/view/dot/35961</a> (last visited
August 18, 2026).
---------------------------------------------------------------------------

The next threshold we estimated is the distance at which a mariner
would choose to drive to the training provider and lodge for the
duration of the training before returning to their place of residence.
To determine this distance, we establish a range by calculating the
minimum and maximum distances for this threshold. The minimum distance
at which mariners would drive and lodge during training must be equal
to the threshold established by those mariners commuting: 93.9 miles
(188 miles round trip).
The National Household Travel Survey estimates that 94.3 percent of
Americans travel by personal vehicle when making round trips of less
than 500 miles.\44\ We use this distance of 500 miles as the lower
bound of our maximum distance threshold. To estimate the upper bound of
our maximum distance threshold, we reference data from the Office of
Airline Information report, ``Average Length of Haul, Domestic Freight
and Passenger Modes (Miles),'' which calculated the average domestic
passenger flight length of 938 miles (1,876 miles round trip) in
2024.\45\ We use this average domestic passenger flight statistic
because it reflects a distance at which the average American prefers
flying over other modes of transportation when traveling from one
location to another.
---------------------------------------------------------------------------

\44\ The BTS conducted the National Household Travel Survey in
2001, and it was last updated in May of 2017. Please see table 4,
``Percent of Long-Distance Trips by Mode and Roundtrip Distance'' to
obtain the travel distance distribution of trips by miles and travel
mode. Readers can access the table at: <a href="https://rosap.ntl.bts.gov/view/dot/5475">https://rosap.ntl.bts.gov/view/dot/5475</a>. The table was accessed on August 18, 2026.
\45\ The Office of Airline Information at the BTS collects air
freight and domestic passenger summary data. This office divides
revenue passenger miles by revenue passenger enplanements to
calculate the average length of passenger trips. To find the average
length of a domestic flight, please see table 1-38, ``Average Length
of Haul, Domestic Freight and Passenger Modes (Miles)'' and refer to
cell AM:13. Readers can access the table at: <a href="https://www.bts.gov/content/average-length-haul-domestic-freight-and-passenger-modes-miles">https://www.bts.gov/content/average-length-haul-domestic-freight-and-passenger-modes-miles</a>. The table was accessed on August 18, 2026.
---------------------------------------------------------------------------

Additionally, to validate the value of an 1,876 miles round trip,
we reference the National Household Travel Survey data. A round-trip
distance of 1,876 miles is close to the 2,000 plus miles round-trip
distance category used by the National Household Travel Survey. For
trips of over 2,000 miles round trip, 22.2 percent of Americans would
travel by car and 74.8 percent would travel by flying. We then average
our lower and upper bounds for the maximum distance threshold to obtain
an average maximum distance of 1,188 miles [(500 miles + 1,876 miles) /
2], or 594 miles one-way.
Therefore, the Coast Guard determines that, beyond 594 miles
between a mariner's place of residence and the training provider they
attended, mariners would choose to fly and lodge instead of drive and
lodge. Table 9 displays the distance thresholds for all three choices
of transportation.

Table 9--Modes of Travel and Travel Distance Thresholds
------------------------------------------------------------------------
Travel distance (one-way)
threshold for a mariner to
Travel choice reach their nearest training
provider denoted by x
------------------------------------------------------------------------
Commute................................ x <93.9 miles.
Drive and Lodge........................ 93.9 miles <=x <=594 miles.
Fly and Lodge.......................... x >594 miles.
------------------------------------------------------------------------

The Coast Guard did not apply any of the cost estimates detailed in
the following methodology (opportunity cost of travel time, monetary
cost of travel, and meals and incidental expense rates (M&IE) and
lodging costs) to mariners meeting the standard of competence in LTW
skills because mariners can achieve this at their place of work
(onboard a vessel) and no travel outside of work would be required.
We then used the percentages from table 9 to estimate how many
mariners from our affected population (172 for LMS + 25 for BRM + 460
for ETSO) would choose to commute, drive and lodge, or fly and lodge to
their closest training provider by multiplying the percentages above by
the affected population. For mariners taking LMS training: 34 (172 x
0.20) would commute, 80 (172x 0.46) \46\ would drive and lodge, and 58
(172 x 0.34) would fly and lodge. For mariners taking BRM training: 4
(25 x 0.20) \47\ would commute, 12 (25 x 0.46) would drive and lodge,
and 9 (25 x 0.34).\48\ For mariners taking ETSO training: 92 (460 x
0.20) would commute, 212 (460 x 0.46) would drive and lodge, and 156
(460 x 0.34) would fly and lodge.\49\ Table 10 shows these numbers.
---------------------------------------------------------------------------

\46\ 80 is rounded up. 172 multiplied by 0.46 equals 79.12 which
ordinarily rounds to 79. However, 34 plus 79 plus 58 equals 171,
which is less than the annual average of 172 mariners taking LMS
training. To rectify this, we decided to round up for one of the
transportation modes. Because mariners are most likely to drive and
lodge, we rounded up that transportation mode to 80.
\47\ 4 is rounded down. 25 multiplied by 0.20 equals 5.00 which
ordinarily rounds to 5. However, 5 plus 12 plus 9 equals 26, which
is more than the annual average of 25 mariners taking BRM training.
To rectify this, we decided to round down for one of the
transportation modes. Because mariners are least likely to commute,
we rounded down that transportation mode to 4.
\48\ All numbers rounded to nearest whole figure.
\49\ All numbers rounded to nearest whole figure.

[[Page 62397]]

Table 10--Travel Distribution by Mode for Affected Population
----------------------------------------------------------------------------------------------------------------
Drive and Fly and
Transportation Commute lodge lodge Total
----------------------------------------------------------------------------------------------------------------
Percentage...................................................... 20% 46% 34% 100%
Number of Deck Officers taking LMS Training..................... 34 \50\ 80 58 172
Number of Mariners taking BRM Training.......................... \51\ 4 12 9 25
Number of Mariners taking ETSO Training......................... 92 212 156 460
----------------------------------------------------------------------------------------------------------------

After establishing the travel distributions, we examined the costs
associated with each mode of travel. Four inputs comprise these costs:
the opportunity cost of travel time, the direct costs of travel, M&IE,
and lodging costs (if applicable). Each of these is discussed below.
---------------------------------------------------------------------------

\50\ 80 is rounded up which ordinarily rounds to 79. However, 34
plus 79 plus 58 equals 171, which is less than the annual average of
172 mariners taking LMS training. To rectify this, we decided to
round up for one of the transportation modes. We decided that
because mariners are most likely to drive and lodge, we should round
up that transportation mode to 80.
\51\ 4 is rounded down which ordinarily rounds to 5. However, 5
plus 12 plus 9 equals 26, which is more than the annual average of
25 mariners taking BRM training. To rectify this, we decided to
round down for one of the transportation modes. We decided that
because mariners are least likely to commute, we should round down
that transportation mode to 4.
---------------------------------------------------------------------------

Opportunity Cost of Travel Time
A mariner incurs an opportunity cost during the time spent
traveling to the closest LMS, BRM, or ETSO training provider. To
calculate these opportunity costs, we utilized the commuting distances
and times calculated in CG-MMC Policy Letter 01-21. The policy letter
calculated that the average commuter faces a 61.2-mile round trip, and
those driving and lodging face approximately a 498.8-mile round
trip.\52\
---------------------------------------------------------------------------

\52\ The calculations for average trip distances were obtained
from page 31 of the CG-MMC Policy Letter 01-21: Guidelines for
Qualifying for STCW Endorsements for Basic and Advanced IGF Code
Operations cost analysis. See <a href="https://www.regulations.gov/document/USCG-2020-0181-0002">https://www.regulations.gov/document/USCG-2020-0181-0002</a> (last visited August 18, 2026).
---------------------------------------------------------------------------

Next, we calculated the opportunity cost of travel. To calculate
these costs, we took the recommended hourly values of travel time
savings from the DOT, $25.40 for intercity business travel driving and
$63.20 for intercity business travel flying.\53\ First, we adjusted the
value to 2025 dollars using the Employment Cost Index (ECI). We then
multiplied it by the average time required to travel to and from the
closest training provider. The ECI in 2015 was 124.3 ([123.6 + 123.8 +
124.6 + 125.1] / 4, rounded), and the ECI in 2025 was 172.0 ([169.9 +
171.4 + 172.9 + 173.6] / 4, rounded), giving a multiplier of 1.4 (172.0
/ 124.3, rounded).\54\ For mariners commuting (and not lodging), it
would take an average round-trip time of approximately 1.0 hours to
commute to a training provider, the average round-trip distance divided
by the average mean speed (61.2 miles round trip / 62.6 mph, rounded).
Similarly, we performed this calculation for those mariners driving and
lodging to get an average round-trip time of about 8.0 hours (498.8
miles round trip / 62.6 mph). However, mariners driving (and lodging)
would be traveling only half of the round-trip distance, or 4.0 \55\
hours twice (8.0 / 2), the day of arrival and the day of departure
(each). The Coast Guard assumes that it would take mariners the
equivalent of an entire workday (8 hours) to fly to a training provider
and an entire workday to fly back to their place of residence.\56\
---------------------------------------------------------------------------

\53\ Table 3 (page 17) of White, Vinn. September 27, 2016.
``Revised Departmental Guidance on Valuation of Travel Time in
Economic Analysis.'' <a href="http://www.transportation.gov/sites/dot.gov/files/docs/2016%20Revised%20Value%20of%20Travel%20Time%20Guidance.pdf">www.transportation.gov/sites/dot.gov/files/docs/2016%20Revised%20Value%20of%20Travel%20Time%20Guidance.pdf</a>
(accessed June 4, 2026).
\54\ At <a href="http://www.bls.gov/web/eci/eci-historical-dataset.xlsx">www.bls.gov/web/eci/eci-historical-dataset.xlsx</a>
(accessed August 19, 2026). We used the value for Estimate with the
following filters: Ownership: Civilian works; Characteristic: All
workers; Industry: All industries; Occupation: All occupations;
Geographic Area: United States (National); Estimate Type: Total
compensation; Periodicity: Current dollar index numbers; Year: 2015
and 2025.
\55\ Rounded to the nearest tenth.
\56\ This again follows the assumption of the CG-MMC Policy
Letter 01-21: Guidelines for Qualifying for STCW Endorsements for
Basic and Advanced IGF Code Operations cost analysis. See <a href="https://www.regulations.gov/document/USCG-2020-0181-0002">https://www.regulations.gov/document/USCG-2020-0181-0002</a> (last visited
August 18, 2026).
---------------------------------------------------------------------------

For each travel mode, we multiplied the loaded mean hourly wage
rate by the average commuting time, the days traveling, and the number
of mariners traveling to arrive at the total opportunity costs of
travel for our affected population. Table 11 presents the opportunity
cost of travel per deck officers by travel type for LMS training. We
estimate the total undiscounted opportunity cost of travel time for 172
deck officers taking LMS training to be about $81,352 annually. Unless
presented otherwise, numbers in tables 11, 12, and 13 are rounded to
the nearest whole number. To get the opportunity cost of travel time,
we multiplied the hourly values of travel times savings ($63.20 or
$25.40) by the ECI multiplier (1.4) to get $88 ($63.20 x 1.4) or $36
($25.40 x 1.4).

Table 11--Total Opportunity Costs (Undiscounted) of Travel Time by Travel Type for Deck Officers Going to LMS
Training
[$2025]
----------------------------------------------------------------------------------------------------------------
Opportunity
Commuting time cost of travel Number of deck Total
Mode of Travel per day Days traveling time (2025 officers opportunity
(hours) dollars) cost
(a) (b) (c) (d) (e) = (a) x
(b) x (c) x
(d)
----------------------------------------------------------------------------------------------------------------
Flying to Training Provider..... 8.0 2 $88 34 $47,872
Driving to Training Provider and 4.0 2 36 80 23,040
Lodging........................
Commuting to Training Provider.. 1.0 5 36 58 10,440
-------------------------------------------------------------------------------
Total....................... .............. .............. .............. 172 81,352
----------------------------------------------------------------------------------------------------------------

[[Page 62398]]

Table 12 presents the opportunity cost of travel per mariner by BRM
training. We estimate the total undiscounted opportunity cost of travel
time for 25 mariners taking BRM training to be about $10,384 annually.

Table 12--Total Opportunity Costs (Undiscounted) of Travel Time by Travel Type for Mariners Going to BRM
Training
----------------------------------------------------------------------------------------------------------------
Opportunity
Commuting time cost of travel Number of Total
Mode of Travel per day Days traveling time (2025 mariners opportunity
(hours) dollars) cost
(a) (b) (c) (d) (e) = (a) x
(b) x (c) x
(d)
----------------------------------------------------------------------------------------------------------------
Flying to Training Provider..... 8.0 2 $88 4 $5,632
Driving to Training Provider and 4.0 2 36 12 3,456
Lodging........................
Commuting to Training Provider.. 1.0 4 36 9 1,296
-------------------------------------------------------------------------------
Total....................... .............. .............. .............. 25 10,384
----------------------------------------------------------------------------------------------------------------

Table 13 presents the opportunity cost of travel per mariner by
ETSO training. We estimate the total undiscounted opportunity cost of
travel time for 460 mariners taking ETSO training to be about $241,136
annually.

Table 13--Total Opportunity Costs (Undiscounted) of Travel Time by Travel Type for Mariners Going to ETSO
Training
----------------------------------------------------------------------------------------------------------------
Opportunity
Commuting time cost of travel Number of Total
Mode of travel per day Days traveling time (2025 mariners opportunity
(hours) dollars) cost
(a) (b) (c) (d) (e) = (a) x
(b) x (c) x
(d)
----------------------------------------------------------------------------------------------------------------
Flying to Training Provider..... 8.0 2 $88 92 $129,536
Driving to Training Provider and 4.0 2 36 212 61,056
Lodging........................
Commuting to Training Provider.. 1.0 9 36 156 50,544
-------------------------------------------------------------------------------
Total....................... .............. .............. .............. 460 241,136
----------------------------------------------------------------------------------------------------------------

Direct Cost of Travel
We assume that mariners who commute or drive and lodge use their
own personal vehicles. To account for the direct costs of driving, such
as gasoline, insurance, and wear and tear, we used the reimbursement
rates from the GSA.\57\ The GSA approximates the privately-owned
vehicle mileage reimbursement rate to be $0.70 per mile in 2025
dollars.\58\ To calculate the direct costs of travel for those mariners
commuting and not lodging, we multiplied this reimbursement rate by the
number of days a mariner commutes (5 days for LMS, 4 days for BRM, and
9 days for ETSO) \59\ and by the average round-trip distance for
commuting, 61.2 miles. We used this same method when calculating the
costs for those mariners driving and lodging with the difference being
they spend the equivalent of two days when completing their round-trip
distance of 498.8 miles. Therefore, a deck officer commuting to LMS
training would incur direct costs of travel of $214 ($0.70
reimbursement rate x 61.6 miles x 5 days), a mariner commuting to BRM
training would incur a direct cost of travel of $171 ($0.70
reimbursement rate x 61.6 miles x 4 days), and a mariner commuting to
ETSO training would incur a direct cost of travel of $386 ($0.70
reimbursement rate x 61.6 miles x 9 days).\60\ For a mariner traveling
by personal vehicle and then lodging for the duration of the training
(driving on the first day and returning on the last day of the
training), the direct cost of travel would be about $349 (498.8 miles x
$0.70 reimbursement rate). Lastly, for a mariner flying and lodging, we
used the average cost of a round-trip flight in 2025 as an
approximation for the direct cost of travel associated with traveling
by air. Using this data from the BTS, we estimated the average
unadjusted round-trip airfare to be $387.\61\
---------------------------------------------------------------------------

\57\ The GSA's privately owned vehicle mileage reimbursement
rate covers the costs associated with using a personal vehicle for
official government travel. This rate encompasses both fixed and
variable costs of operating the vehicle. Specifically, it includes
expenses like gasoline, oil, tires, maintenance, repairs, insurance,
registration, and depreciation. However, it does not include the
cost of parking or tolls.
\58\ <a href="https://www.gsa.gov/travel/plan-a-trip/transportation-airfare-rates-pov-rates/pov-mileage-reimbursement">https://www.gsa.gov/travel/plan-a-trip/transportation-airfare-rates-pov-rates/pov-mileage-reimbursement</a> (accessed August
19, 2026).
\59\ We assume that one day of a course is eight hours. From
table 3, the average length of an LMS course is 37 hours. Rounding
up, this equates to 5 days (37 hours divided by 8 hours per day).
From table 4, the average length of a BRM course is 27 hours.
Rounding, this equates to 4 days (27 hours divided by 8 hours per
day). Recall, from earlier in this Regulatory Analysis, that the
STAR Center offers a 9-day ETSO course.
\60\ We multiplied by 5 days a week for deck officers commuting
to LMS training because the average training time is 37 hours to
complete, which is essentially equivalent to 5 business days. For
mariners commuting to BRM training, we multiplied by 4 days a week
because the average training time is 27 hours to complete, which is
equivalent to 4 business days.
\61\ <a href="http://www.bts.gov/content/annual-us-domestic-average-itinerary-fare-current-and-constant-dollars">www.bts.gov/content/annual-us-domestic-average-itinerary-fare-current-and-constant-dollars</a> (accessed August 19, 2026).
\62\ We adjusted for inflation the value of the round-trip
airport transfer presented in table 4 in the following link: <a href="https://www.federalregister.gov/d/06-369">https://www.federalregister.gov/d/06-369</a>.
---------------------------------------------------------------------------

In addition to paying for round-trip airfare, mariners flying and
lodging would need taxi fare to and from the airport. To calculate the
round-trip airport transfer, we used the value of $50,\62\ and inflated
this value using the 2025 and the 2006 GDP implicit price

[[Page 62399]]

deflator values of 128.979 and 84.071, respectively.\63\ After dividing
the values, we obtained a factor of about 1.534. We multiplied this
value by $50 to obtain a transfer cost of about $77 in 2025
dollars.\64\ We request comments on this cost.
---------------------------------------------------------------------------

\63\ <a href="https://fred.stlouisfed.org/series/A191RD3A086NBEA">https://fred.stlouisfed.org/series/A191RD3A086NBEA</a>,
(accessed August 19, 2026).
\64\ This methodology parallels that found in 85 FR 31677 at
page 31684.
---------------------------------------------------------------------------

Table 14 presents the direct costs of travel associated with deck
officers completing LMS training. We estimate the total undiscounted
direct costs of travel for 172 deck officers taking LMS training to be
about $56,108 annually.

Table 14--Annual Direct Costs of Travel (Undiscounted) for Deck Officers Completing LMS Training
[$2025]
----------------------------------------------------------------------------------------------------------------
Cost to take a
Mode of travel Mileage/ taxi to and Number of deck Total cost
airfare cost from airport officers
(a) (b) (c) (d) = [(a) +
(b)] x (c)
----------------------------------------------------------------------------------------------------------------
Flying and lodging.............................. $387 $77 34 $15,776
Driving and lodging............................. 349 0 80 27,920
Commuting....................................... 214 0 58 12,412
---------------------------------------------------------------
Total....................................... .............. .............. 172 56,108
----------------------------------------------------------------------------------------------------------------

Table 15 presents the direct costs of travel associated with
mariners completing BRM training. We estimate the total undiscounted
direct costs of travel for 25 mariners taking BRM training to be about
$7,583 annually.

Table 15--Annual Direct Costs of Travel (Undiscounted) for Mariners Completing BRM Training
[$2025]
----------------------------------------------------------------------------------------------------------------
Cost to take a
Mode of travel Mileage/ taxi to and Number of Total cost
airfare cost from airport mariners
(a) (b) (c) (d) = [(a) +
(b)] x (c)
----------------------------------------------------------------------------------------------------------------
Flying and lodging.............................. $387 $77 4 $1,856
Driving and lodging............................. 349 0 12 4,188
Commuting....................................... 171 0 9 1,539
---------------------------------------------------------------
Total....................................... .............. .............. 25 7,583
----------------------------------------------------------------------------------------------------------------

Table 16 presents the directs costs of travel for mariners
completing the ETSO training. We estimate the total undiscounted direct
costs of travel for 460 mariners taking ETSO training to be about
$176,892 annually.

Table 16--Annual Direct Costs of Travel (Undiscounted) for Mariners Completing ETSO Training
----------------------------------------------------------------------------------------------------------------
Cost to take a
Mode of travel Mileage/ taxi to and Number of Total cost
airfare cost from airport mariners
(a) (b) (c) (d) = [(a) +
(b)] x (c)
----------------------------------------------------------------------------------------------------------------
Flying and lodging.............................. $387 $77 92 $42,688
Driving and lodging............................. 349 0 212 73,988
Commuting....................................... 386 0 156 60,216
---------------------------------------------------------------
Total....................................... .............. .............. 460 176,892
----------------------------------------------------------------------------------------------------------------

Meal and Incidental Expense (M&IE) Rates and Lodging Costs
Mariners incur M&IE during training and travel days and mariners
not commuting incur lodging expenses during training days. To calculate
the average M&IE for our affected population, the Coast Guard
calculated an average of these expenses based on GSA travel per diem
rates for calendar year 2025 for the areas the course providers are
located in.\65\ For example,

[[Page 62400]]

we found the M&IE cost for mariners in ZIP code 23072, where the
Chesapeake Marine Training Institute is located, to be $68 on average
during calendar year 2025 (see table 17). Averaging over all course
provider ZIP codes, we obtain an average cost for M&IE of about $83 for
LMS courses, $86 for BRM courses, and $86 for ETSO courses during
training days. For travel days, we multiplied this value by 0.75 based
on GSA guidance to obtain an M&IE cost of about $62 ($83 x 0.75) for
LMS courses, about $65 ($86 x 0.75) for BRM courses, and about $65 ($86
x 0.75) for ETSO courses. \66\ During the first and last day of travel,
GSA calculates that Federal employees are only eligible for 75 percent
of the total M&IE rate for their temporary duty travel location.\67\ We
used this reimbursement rate as an approximation for what mariners
would spend on their first and last travel day; however, for mariners
commuting, we applied this rate for the duration of their training.
---------------------------------------------------------------------------

\65\ To obtain information on the GSA per diem or M&IE, the
reader should access the following website: <a href="http://www.gsa.gov/travel/plan-book/per-diem-rates">www.gsa.gov/travel/plan-book/per-diem-rates</a> (accessed August 19, 2026). We entered each
training center's ZIP Code into the search function for the 2024 and
2025 Fiscal Year to find the respective M&IE and lodging rates; we
did this for our deck officer population. Because GSA tabulates per
diem for the 48 contiguous states, we needed to find the per diem
rates for the US Virgin Islands. We used the following website for
this information: <a href="http://www.travel.dod.mil/Travel-Transportation-Rates/Per-Diem/Per-Diem-Rate-Lookup/">www.travel.dod.mil/Travel-Transportation-Rates/Per-Diem/Per-Diem-Rate-Lookup/</a> (accessed August 19, 2026). The
reader should search for ``Virgin Islands (U.S.)'' in the tab
denoted as ``Foreign & Non-Foreign OCONUS.''
\66\ Rounded to closest whole number.
\67\ <a href="http://www.gsa.gov/travel/plan-a-trip/per-diem-rates/faqs#15">www.gsa.gov/travel/plan-a-trip/per-diem-rates/faqs#15</a>,
(accessed June 4, 2026).
---------------------------------------------------------------------------

We multiplied the weighted M&IE value during training days by 5
(number of days) for deck officers receiving LMS training to get $415
(5 x $86). We multiplied the same M&IE value by 4 (number of days) for
mariners receiving BRM training to get $344 (4 x $86). We multiplied
the M&IE value by 11 (9 training days + 2-day weekend) for mariners
receiving ETSO training to obtain $946 (11 x $86). Then, we multiplied
the M&IE value during travel days by 2 (number of days traveling) to
obtain a value of about $124 for deck officers driving and lodging to
LMS training (2 x $62), $130 for the mariners driving and lodging to
BRM training (2 x $65), and $130 for the mariners driving and lodging
to ETSO training (2 x $65). See table 17.
---------------------------------------------------------------------------

\68\ Hazinski, Thomas A. and Michael Ferguson. September 23,
2024. 2024 HVS Lodging Tax Report--USA. <a href="http://www.hvs.com/article/10015-2024-hvs-lodging-tax-report-usa">www.hvs.com/article/10015-2024-hvs-lodging-tax-report-usa</a> (accessed August 20, 2026).
\69\ Rounded to closest whole number.

Table 17--Values for M&IE and Lodging
--------------------------------------------------------------------------------------------------------------------------------------------------------
Average daily
lodging rate M&IE Average daily ETSO
Training provider ZIP code over the span Average during lodging rate LMS course BRM course course
of a year M&IE travel including tax offered? offered? offered?
(2025 dollars) days
--------------------------------------------------------------------------------------------------------------------------------------------------------
Captain School USVI........................... 00802 $354 $150 $113 $404 No Yes No.
Northeast Maritime Institute.................. 02719 126 80 60 144 Yes Yes No.
Maine Maritime Academy-Continuing Education... 04420 194 92 69 222 Yes No No.
State University New York Maritime College- 10465 277 92 69 316 Yes No No.
Department of Professional Education &
Training.....................................
Maritime Institute of Technology & Graduate 21090 143 80 60 163 Yes Yes No.
Studies......................................
Chesapeake Marine Training Institute.......... 23072 110 68 51 126 Yes Yes No.
Maritime Institute............................ 23513 110 68 51 126 Yes Yes No.
RCM Maritime, LLC............................. 29420 246 92 69 281 Yes No No.
Quality Maritime Training, LLC................ 32250 110 68 51 126 Yes Yes No.
STAR Center................................... 33004 177 86 65 202 Yes No Yes.
Maritime Professional Training................ 33316 177 86 65 202 Yes Yes No.
Delgado Community College..................... 70119 158 80 60 180 Yes No No.
San Jacinto College Maritime Technology & 77571 128 80 60 146 Yes Yes No.
Training Center..............................
Maritime Institute............................ 92110 205 86 65 234 Yes Yes No.
Maritime Institute............................ 98020 120 86 65 137 Yes No No.
Eat on the Wild Side-Crawford Nautical 98107 208 92 69 238 Yes Yes No.
Training.....................................
Maritime Institute of Technology & Graduate 98134 208 92 69 238 Yes No No.
Studies......................................
Average if LMS course offered................. .......... 169 83 62 193 .......... .......... ..........
Average if BRM course offered................. .......... 167 86 65 191 .......... .......... ..........
Average if ETSO course offered................ .......... 177 86 65 202 .......... .......... ..........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note: The reimbursement rates for lodging from the GSA do not include taxes (see <a href="http://www.gsa.gov/travel/plan-a-trip/per-diem-rates/faqs#11">www.gsa.gov/travel/plan-a-trip/per-diem-rates/faqs#11</a>, (accessed August
20, 2026). To calculate the ``Average Daily Lodging Rate Including Tax'' column, we take the ``Average Daily Lodging Rate over the span of a Year
(2025)'' and multiplying it by 14.19 percent (the average total lodging tax rate in the 150 largest US cities \68\) and then adding that value to the
``Average Daily Lodging Rate over the span of a Year (2025)'' column. For example, in the first row we multiplied $354 by 0.1419 and added it to $354
to get $404 ($354 x 0.1419) + $354).\69\ We repeated this process for the remaining rows. The average of these totals is approximately $193 for
training providers offering LMS courses and $191 for training providers offering BRM courses. This number is the average for our average daily lodging
rate for our affected population. Similarly, we did the same multiplication with the ``Average M&IE Rate'' and the ``M&IE during Travel Days'' columns
to get an average rate of $83 and $62, respectively, for training providers offering LMS courses.

Similarly, we applied this M&IE rate during travel days to each day
of training for mariners commuting to obtain a total of $310 ($62 x 5
days) for deck officers completing LMS training, $260 ($65 x 4 days)
for mariners completing BRM training, and $585 ($65 x 9 days) for
mariners completing ETSO training.\70\ We applied this cost to mariners
commuting because every day a mariner is in training is also considered
a travel day.
---------------------------------------------------------------------------

\70\ Some mariners commute to ETSO training, and some drive and
lodge or fly to ETSO training, as shown in table 9. ETSO training is
nine days. For commuters, they would only have to commute on days of
training, i.e., nine days. For mariners who drive and lodge or fly,
they would incur M&IE and lodging expenses on the weekend as well,
i.e., their M&IE and lodging rates are based on 11 days.
---------------------------------------------------------------------------

We applied the same weighting method when calculating the average
lodging costs for mariners taking LMS, BRM, and ETSO training. The
costs for the average daily lodging rate include the daily lodging per
diem rate, the state sales tax rate, and the lodging sales tax rate.
The GSA provides the daily per diem rate for lodging costs. A 14.34
percent lodging tax was added to the lodging per diem.\71\ After
applying the tax, we estimated the average lodging rate to be $193 per
deck officer attending LMS training per day, $191 per mariner attending
BRM training per

[[Page 62401]]

day, and $202 per mariner attending ETSO training per day, based on the
average daily lodging rate in the ZIP codes of the training providers.
Using the same example as above, we found the lodging rate for ZIP Code
23072 to be $126 ($110 x 1.1434 which includes the 14.34 percent total
tax rate for lodging). Averaging over all course provider ZIP codes, we
obtained a total average cost for lodging of about $193 for deck
officers attending LMS training, $191 for mariners attending BRM
training, and $202 for mariners attending ETSO training. For LMS, BRM,
and ETSO training, we estimate the lodging costs to be about $965 ($193
x 5 days) and $764 ($191 x 4 days), and $2,222 ($202 x 11 days),
respectively. Table 18 details the total undiscounted costs for M&IE
and lodging expenses for deck officers taking LMS training, table 19
details the total undiscounted costs for M&IE and lodging expenses for
mariners taking BRM training, and table 20 details the total
undiscounted costs for M&IE and lodging for mariners taking the ETSO
training. We estimate the total undiscounted M&IE and lodging costs for
172 deck officers taking LMS training to be about $222,610 annually.
---------------------------------------------------------------------------

\71\ Average total lodging tax rate in the 150 largest US cities
from Hazinski, Thomas A. and Henry Detmer. October 29, 2025. 2025
HVS Lodging Tax Report--USA. <a href="https://www.hvs.com/article/10299-2025-lodging-tax-report-usa">https://www.hvs.com/article/10299-2025-lodging-tax-report-usa</a> (accessed August 24, 2026).
\72\ This value includes M&IE of 75% for mariners who commute to
a training center every day.

Table 18--M&IE and Lodging Costs (Undiscounted) for Deck Officers Completing LMS Training
[$2025]
----------------------------------------------------------------------------------------------------------------
M&IE at travel M&IE on travel Number of deck
Mode of Travel location Lodging costs days officers Total cost
(a) (b) (c) (d) (e)
= [(a) + (b) +
(c)] x (d)
----------------------------------------------------------------------------------------------------------------
Flying and lodging.............. $415 $965 $415 34 $61,030
Driving and lodging............. 415 965 415 80 143,600
Commuting....................... 0 0 \72\ 310 58 17,980
-------------------------------------------------------------------------------
Total....................... .............. .............. .............. 172 222,610
----------------------------------------------------------------------------------------------------------------

We estimate the total undiscounted M&IE and lodging costs for 25
mariners taking BRM training to be about $22,148 annually.
---------------------------------------------------------------------------

\73\ This value includes M&IE of 75% for mariners who commute to
a training center every day.

Table 19--M&IE and Lodging Costs (Undiscounted) for Mariners Completing BRM Training
[$2025]
----------------------------------------------------------------------------------------------------------------
M&IE at travel M&IE on travel Number of deck
Mode of Travel location Lodging costs days mariners Total cost
(a) (b) (c) (d) (e)
= [(a) + (b) +
(c)] x (d)
----------------------------------------------------------------------------------------------------------------
Flying and lodging.............. $344 $764 $130 4 $4,952
Driving and lodging............. 344 764 130 12 14,856
Commuting....................... 0 0 \73\ 260 9 2,340
-------------------------------------------------------------------------------
Total....................... .............. .............. .............. 25 22,148
----------------------------------------------------------------------------------------------------------------

We estimate the total undiscounted M&IE and lodging costs for 460
mariners taking the ETSO training to be about $1,093,852 annually.
---------------------------------------------------------------------------

\74\ This value includes M&IE of 75% for mariners who commute to
a training center every day.

Table 20--M&IE and Lodging Costs (Undiscounted) for Mariners Completing ETSO Training
----------------------------------------------------------------------------------------------------------------
M&IE at travel M&IE on travel Number of
Mode of travel location Lodging costs days mariners Total cost
(a) (b) (c) (d) (e)
= [(a) + (b) +
(c)] x (d)
----------------------------------------------------------------------------------------------------------------
Flying and lodging.............. $946 $2,222 $130 92 $303,416
Driving and lodging............. 946 2,222 130 212 699,176
Commuting....................... 0 0 \74\ 585 156 91,260
-------------------------------------------------------------------------------
Total....................... .............. .............. .............. 460 1,093,852
----------------------------------------------------------------------------------------------------------------

[[Page 62402]]

Cost To Compile Documentation for an MMC Application
In addition to the costs associated with travel, mariners must
provide supporting documentation to form CG-719B, Application for MMC,
to verify training or skill assessments. Therefore, mariners incur an
opportunity cost of time when compiling the necessary documentation.
According to a subject matter expert (SME) at the NMC who processes
these applications, it takes a mariner an average of 5 minutes
(approximately 0.083 hours) to compile training certificates or
documentation of meeting the standard of competence to submit to the
NMC for evaluation.
Based on our affected population, we estimate there would be 172
deck officers who would compile LMS training certificates, 25 mariners
who would compile BRM training certificates, 84 mariners who would
compile evidence of meeting the standard of competence in LTW skills,
and 460 mariners who would compile ETSO training certificates on an
annual basis. Using the loaded hourly wage rate data for those deck
officers completing LMS training, $70.82, those mariners completing BRM
training, $38.79, and those mariners completing ETSO training, $76.33,
we estimate the total cost to mariners to submit LMS, BRM, and ETSO
training certificates and evidence of meeting the standard of
competence in LTW skills. We estimate the total cost to mariners to be
approximately $4,275 annually [($70.82 x 0.083 x 172) + ($38.79 x 0.083
x 25) + ($38.79 x 0.083 x 84) + ($76.33 x 0.083 x 460)]. Table 21
presents these costs.

Table 21--Annual Costs To Compile Documentation for an MMC
----------------------------------------------------------------------------------------------------------------
Loaded mean Time per
Population hourly wage submission Population Total cost
rate (hours)
(a) (b) (c) (d) = (a) x
(b) x (c)
----------------------------------------------------------------------------------------------------------------
Deck Officers Submitting LMS Training $70.82 0.083 172 $1,011
Certificates...................................
Mariners Submitting BRM Training Certificates... 38.79 0.083 25 80
Mariners Submitting Evidence of meeting the 38.79 0.083 84 270
Standard of Competence in LTW Skills...........
Mariners Submitting ETSO Training Certificates.. 76.33 0.083 460 2,914
---------------------------------------------------------------
Total....................................... .............. .............. 741 4,275
----------------------------------------------------------------------------------------------------------------

Total Cost to Mariners
We estimate the total undiscounted annual costs for deck officers
taking LMS training by adding the total costs in tables 7, 8, 11, 14,
18, and 21, for mariners taking BRM training by adding the total costs
in tables 7, 8, 12, 15, 19, and 21, for mariners taking ETSO training
by adding the total costs in tables 7, 8, 13, 16, 20, and 21, and for
mariners demonstrating meeting the standard of competence in LTW skills
by adding the total costs in tables 8 and 21. We estimate the total
undiscounted annual cost for deck officers who take the LMS training to
be $991,977 ($192,296 total cost to take LMS training + $438,600 total
opportunity cost to take the training + $81,352 total opportunity costs
of travel for deck officers + $56,108 direct costs of travel + $222,610
M&IE and lodging costs + $1,011 opportunity cost to compile MMC
application documentation). Similarly, we estimate the total
undiscounted annual cost for mariners taking the BRM training to be
$98,545 annually ($32,175 total cost to take training + $26,175 total
opportunity cost to take the training + $10,384 total opportunity cost
of travel for mariners + $7,583 direct costs of travel + $22,148 M&IE
costs and lodging costs + $80 training certificate submission costs).
Similarly, we estimate the total undiscounted annual cost for mariners
taking the ETSO training to be $4,920,634 annually ($948,060 total cost
to take training + $2,457,780 total opportunity cost to take the
training + $241,136 total opportunity cost of travel for mariners +
$176,892 direct costs of travel + $1,093,852 M&IE costs and lodging
costs + $2,914 training certificate submission costs). Lastly, we
estimate the total undiscounted (opportunity) annual cost for mariners
demonstrating meeting the standard of competence in LTW skills to be
$83,094 ($82,824 opportunity costs of demonstrating LTW skills + $270
opportunity cost to compile MMC application documentation). Table 22
presents a summary of these total costs.

Table 22--Total Undiscounted Annual Costs for Mariners Taking LMS Training, BRM Training, and Meeting the Standard of Competence in LTW Skills
--------------------------------------------------------------------------------------------------------------------------------------------------------
Opportunity
Opportunity cost of Direct Meals, Opportunity
Type of training /assessment Tuition costs travel per costs of incidentals cost MMC Total annual
cost training/ mariner by travel and lodging application costs
assessment travel type costs
(a) (b) (c) (d) (e) (f) (g) = (a) +
(b) + (c) +
(d) + (e) +
(f)
--------------------------------------------------------------------------------------------------------------------------------------------------------
LMS Training................................................ $196,768 $438,600 $81,352 $56,108 $222,610 $1,011 $991,977
BRM Training................................................ 32,175 26,175 10,384 7,583 22,148 80 98,545
ETSO Training............................................... 948,060 2,457,780 241,136 176,892 1,093,852 2,914 4,920,634
LTW Skills.................................................. .......... 82,824 ........... .......... ........... 270 83,094
-------------------------------------------------------------------------------------------
Totals.................................................. 1,172,531 3,005,379 332,872 240,583 1,338,610 4,275 6,094,250
--------------------------------------------------------------------------------------------------------------------------------------------------------

[[Page 62403]]

Cost to the Federal Government
To estimate the cost to the Federal Government, the Coast Guard
examined the evaluation process for MMC applications. According to SMEs
at the NMC who review MMC applications, Federal employees with a pay
grade of General Schedule (GS)-07 review incoming LMS, BRM, and ETSO
training certificates and evidence of meeting the standard of
competence in LTW skills. According to the GS published by the Office
of Personnel Management for civilian government personnel, the hourly
wage rate for a GS-07 employee at Step 5 in the Washington-Baltimore-
Arlington locality is $31.04 in 2025 dollars.\75\
---------------------------------------------------------------------------

\75\ <a href="https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/25Tables/html/DCB.aspx">https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/25Tables/html/DCB.aspx</a> (accessed August
24, 2026).
---------------------------------------------------------------------------

The Coast Guard calculated the share of total compensation of
Federal Government employees to account for the non-wage benefits to
determine the load factor that the Coast Guard applied to the hourly
wage rate of employees. In a Congressional Budget Office (CBO) report
titled ``Comparing the Compensation of Federal and Private-Sector
Employees in 2022,'' the CBO reports total compensation of Federal
Government employees to be approximately $75.90, and wages and salaries
to be approximately $45.20.\76\ From these values, the Coast Guard
determined the load factor to be about 1.68 \77\ ($75.90 / $45.20).
---------------------------------------------------------------------------

\76\ Readers can view the report at, <a href="https://www.cbo.gov/system/files/2024-04/59970-Compensation.pdf">https://www.cbo.gov/system/files/2024-04/59970-Compensation.pdf</a>. See Table 2-3 and Table 2-1 of
the report, respectively. The Coast Guard last accessed this report
in August 2026.
\77\ Rounded to closest whole number.
---------------------------------------------------------------------------

Multiplying by 1.68 to account for benefits and indirect costs paid
for by the employer, the loaded hourly wage rate is $52.15 in 2025
dollars ($31.04 hourly wage x 1.68). The Coast Guard does not have
sufficient data to assess the cost of review for ETR training
certificates.
We then estimated the cost of time it takes NMC personnel to review
training certificates and evidence of meeting the standard of
competence in LTW skills as part of the evaluation process for an STCW
endorsement. According to personnel at the NMC familiar with processing
MMC applications, an evaluator takes 2.5 minutes to ensure all required
documentation is present in an application; additionally, 5 percent of
the time, the application may need further review because of
inconsistencies in documentation, which requires 10 minutes. To
calculate the initial review cost, the Coast Guard calculated this time
in hours (2.5 minutes / 60 minutes/hour) or 0.042 hours. To calculate
the cost of further review, we multiplied 5 percent by the number of
certificates or assessments being reviewed (172, 25, and 460,
respectively) and multiplied these numbers by the time it takes to
conduct a further review, or 0.167 hours (10 minutes / 60 minutes/
hour). Table 23 presents the total annual undiscounted cost of
reviewing an LMS, BRM, or ETSO training certificate or documentation of
LTW skills as well as the cost of any further review time that may be
required. We estimate the total annual undiscounted cost to the Federal
Government to perform the necessary reviews to be approximately $1,947.

Table 23--Total Undiscounted Cost for Coast Guard Review of LMS or BRM Training Certificates or Demonstration of
LTW Skills
[$2025]
----------------------------------------------------------------------------------------------------------------
Number of Percent of Loaded hourly
Cost category Time to review certificates time review is wage rate of Total
(in hours) being reviewed required evaluator
(a) (b) (c) (d) (e) =(a) x (b)
x (c) x (d)
----------------------------------------------------------------------------------------------------------------
Initial review LMS.............. 0.042 172 100 $52.15 $377
Initial review BRM.............. 0.042 25 100 52.15 55
Initial review ETSO............. 0.042 460 100 52.15 1,008
Initial review LTW Skills....... 0.042 84 100 52.15 184
Further review LMS.............. 0.167 172 5 52.15 75
Further review BRM.............. 0.167 25 5 52.15 11
Further review ETSO............. 0.167 460 5 52.15 200
Further review LTW Skills....... 0.167 84 5 52.15 37
-------------------------------------------------------------------------------
Total....................... .............. .............. .............. .............. 1,947
----------------------------------------------------------------------------------------------------------------

Summary of Total Cost Savings
The Coast Guard does not anticipate mariners or the Federal
Government to incur any costs with this proposed rule. To obtain the
total undiscounted cost savings of $6,096,197 for this proposed rule,
we added the total undiscounted costs in table 22 ($6,094,250) to the
total undiscounted costs in table 23 ($1,947). Since the rule removes
these requirements, cost savings are represented as the avoided costs
captured in tables 22 and 23. We estimate the total cost savings of
this proposed rule to mariners and the Federal Government over a 10-
year period of analysis to be about $42,817,136, discounted at 7
percent and the annualized cost savings to be about $6,096,197 using
the same discount rate. Table 24 summarizes the aggregate cost savings
of this proposed rule, which includes the cost savings to mariners and
the Federal Government.

[[Page 62404]]

Table 24--Total Estimated Cost Savings of the Proposed Rule Over a 10-Year Period of Analysis
[2025$]
----------------------------------------------------------------------------------------------------------------
Total Total cost
Year undiscounted -------------------------------
cost savings 7% 3%
----------------------------------------------------------------------------------------------------------------
1............................................................... $6,096,197 $5,697,380 $5,918,638
2............................................................... 6,096,197 5,324,655 5,746,250
3............................................................... 6,096,197 4,976,313 5,578,884
4............................................................... 6,096,197 4,650,760 5,416,392
5............................................................... 6,096,197 4,346,504 5,258,633
6............................................................... 6,096,197 4,062,153 5,105,469
7............................................................... 6,096,197 3,796,405 4,956,766
8............................................................... 6,096,197 3,548,042 4,812,394
9............................................................... 6,096,197 3,315,927 4,672,227
10.............................................................. 6,096,197 3,098,997 4,536,143
-----------------------------------------------
Total....................................................... 60,961,970 42,817,136 52,001,796
-----------------------------------------------
Annualized.................................................. .............. 6,096,197 6,096,197
----------------------------------------------------------------------------------------------------------------

Analysis of Annualized Cost Savings Using a Perpetual Period of
Analysis
Using a perpetual period of analysis, we estimate the total
annualized cost savings of this proposed rule to be $3,833,921 in 2024
dollars, using a 7-percent discount rate, with 2026 as the target
implementation year.
Alternatives
Although not required by domestic statute or the minimum
international standards contained in the STCW Convention or the STCW
Code for these endorsements, the Coast Guard included these
requirements in the 2013 final rule as a means to ensure safe vessel
operations. The Coast Guard reviewed all MMC requirements and
determined that the six discussed in this proposed rule were the only
ones that could be removed without compromising the safe operation of
applicable vessels.
The Coast Guard considered three alternatives beyond the selected
proposal. This section examines how the cost of the proposal would
change if this alternative were implemented in place of the proposed
alternative.
(1) No Action
Using this alternative, the Coast Guard would accept the status quo
and not remove either the LMS, BRM, or ETSO training requirements or
the requirement to demonstrate meeting the standard of competence in
LTW skills as discussed in this proposed rule for certain STCW
endorsements. The Coast Guard would also not remove the training
requirement discussed in this proposed rule for CSM or HVPS for ETRs.
This alternative would not promote an equivalent compliance standard
with international requirements and would not reduce the burden or
create cost savings for mariners; therefore, we rejected this
alternative. Table 26 displays the potential cost savings with the no
action alternative as well as that associated with each alternative.
(2) Addressing Only Deck Endorsement Requirements
Under this alternative, the Coast Guard would divide the removal of
requirements between deck and engineering endorsements. Specifically,
the Coast Guard would:
<bullet> Remove the LMS training (46 CFR 11.317(a)(3)(v) and
11.317(b)(1)), BRM training (46 CFR 11.321(a)(3)(iv)), and LTS renewal
requirement (46 CFR 11.321(b)(1)) for deck endorsements, including
Masters and OICNW on vessels of less than 500 GT limited to near-
coastal waters.
<bullet> Retain the ETSO training (46 CFR 11.329(a)(4)(v)) for
OICEW and the CSM and HVPS training (46 CFR 12.611(a)(4)(i)) for ETR on
vessels powered by main propulsion machinery of 750 kW/1,000 HP or
more.
This approach would provide targeted regulatory relief for deck
officers, reducing their training burden and associated costs, while
maintaining certain training standards for engineering officers and
ratings. The Coast Guard considered this alternative to ensure that any
changes to training requirements would not compromise safety in
engineering operations, which may present distinct risks.
However, the Coast Guard rejected this alternative because the
retained engineering requirements are not mandated by the STCW
Convention or the STCW Code and do not provide a demonstrable safety
benefit beyond existing international standards. In addition,
maintaining these requirements would not achieve the full regulatory
burden reduction or international equivalency sought by the proposed
rule. Therefore, this alternative would not fully align with the Coast
Guard's objectives for this rulemaking.
(3) Addressing Only Engine Endorsement Requirements
Under this alternative, the Coast Guard would focus on removing
requirements for engineering endorsements, while retaining those for
deck endorsements. Specifically, the Coast Guard would:
<bullet> Remove the ETSO training (46 CFR 11.329(a)(4)(v)) for
OICEW and the CSM and HVPS training (46 CFR 12.611(a)(4)(i)) for ETR on
vessels powered by main propulsion machinery of 750 kW/1,000 HP or
more.
<bullet> Retain the LMS training (46 CFR 11.317(a)(3)(v) and
11.317(b)(1)), BRM training (46 CFR 11.321(a)(3)(iv)), and LTW skills
requirement (46 CFR 11.321(b)(1)) for deck endorsements, including
Masters and OICNW on vessels of less than 500 GT limited to near-
coastal waters.
This approach would provide regulatory relief and cost savings for
engineering officers and ratings, while maintaining additional training
requirements for deck officers and ratings. The Coast Guard considered
this alternative to address the distinct operational and safety
considerations associated with engineering roles, while continuing to
require certain deck-related training believed to contribute to safe
vessel operations.
However, the Coast Guard rejected this alternative because the
retained deck requirements are not mandated by

[[Page 62405]]

the STCW Convention or the STCW Code and do not provide a demonstrable
safety benefit beyond existing international standards. Retaining these
requirements would not achieve the full regulatory burden reduction or
international equivalency sought by the proposed rule. Therefore, this
alternative would not fully align with the Coast Guard's objectives for
this rulemaking.
(4) Preferred Alternative
Under the preferred alternative, the Coast Guard would remove the
following requirements:
<bullet> The LMS training described in 46 CFR 11.317(a)(3)(v) and
11.317(b)(1) for an STCW endorsement as Master of vessels of less than
500 GT limited to near-coastal waters;
<bullet> The BRM training described in 46 CFR 11.321(a)(3)(iv) for
an STCW endorsement as an OICNW on vessels of less than 500 GT limited
to near-coastal waters;
<bullet> Evidence of meeting the standard of competence in LTW
skills to renew an STCW endorsement as OICNW on vessels of less than
500 GT limited to near-coastal waters in 46 CFR 11.321(b)(1);
<bullet> The ETSO training described in 46 CFR 11.329(a)(4)(v) for
an STCW endorsement as OICEW; and
<bullet> The CSM and HVPS training to qualify as an ETR on vessels
powered by main propulsion machinery of 750 kW/1,000 HP or more in 46
CFR 12.611(a)(4)(i).
This alternative would reduce the financial burden on mariners and
the Federal Government by removing overly burdensome regulatory
requirements. The cost savings associated with this alternative are
greater than those associated with other alternatives.

Table 25--Alternatives
[2025$]
----------------------------------------------------------------------------------------------------------------
Annualized
industry and Annualized
Alternative government industry Impact of the alternative
cost--savings cost--savings
(7%) (7%)
----------------------------------------------------------------------------------------------------------------
Alternative 1: No Action....................... $0 $0 The Coast Guard would continue to
require training in LMS, BRM,
ETSO, CSM, and HVPS, and
demonstration of the standard of
competence in LTW skills to
qualify for certain STCW
endorsements as discussed in the
NPRM. The burden to mariners
would not be reduced and cost
savings would not be realized.
This alternative would not
promote compliance with
international standards.
Alternative 2: Addressing Only Deck Endorsement 1,174,355 1,173,616 Remove the current requirements:
Requirements. Training in LMS, BRM, and
demonstration of meeting the
standard of competence in LTS
either through training or
assessments from the respective
STCW deck endorsements. This
alternative would promote
compliance with international
requirements.
Alternative 3: Addressing Only Engine 4,921,842 4,920,634 Remove the current requirements:
Endorsement Requirements. Training in ETSO, CSM, and HVPS
from the respective STCW engine
endorsements. This alternative
would promote compliance with
international requirements.
Alternative 4: Proposed Rule................... 6,096,197 6,094,250 Remove the current requirements:
Training in LMS, BRM, ETSO, CSM,
and HVPS from the respective
STCW endorsements. Demonstration
of meeting the standard of
competence in LTW skills for the
respective STCW endorsement.
This alternative would promote
compliance with international
requirements.
----------------------------------------------------------------------------------------------------------------

B. Small Entities

Under the Regulatory Flexibility Act (RFA), 5 U.S.C. 601-612, we
have considered whether this proposed rule would have a significant
economic impact on a substantial number of small entities. The term
``small entities'' comprises small businesses, not-for-profit
organizations that are independently owned and operated and are not
dominant in their fields, and governmental jurisdictions with
populations of less than 50,000 people.
This proposed rule would not impose any new costs on mariners or
companies that employ mariners and would reduce the burden on mariners
by removing the requirement to complete LMS, BRM, ETSO, CSM, or HVPS
training, or demonstrate evidence of meeting the standard of competence
in LTW skills to qualify for certain STCW endorsements. An MMC and the
associated endorsements are maintained by the mariner, so mariners
would receive cost savings from this proposed rule. The Coast Guard
assumes the cost of attending required training and obtaining an MMC is
borne by the individual obtaining the credential, making mariners the
primary affected population of this proposed rule, which is estimated
to be 741 mariners annually. Mariners are individuals and, as such, are
not considered small entities under the RFA. We do not have further
information that any companies reimburse mariners for these costs, and
therefore the mariners would realize the cost savings estimated in this
proposed rule.
The proposed rule does not impose any new costs or additional
regulatory burdens on training providers or other small entities.
Maritime training providers are invited to comment on the economic
impact of this proposed rule.
Maritime training providers may qualify as small entities, as many
are small businesses or not-for-profit organizations. From our
analysis, we found 23 training providers offering Coast Guard-approved
courses: 22 offer LMS training, 11 offer BRM training, and 2 offer ETSO
training.

[[Page 62406]]

Based on publicly available information from the online searches of
these companies, we found revenue or employee information on 21 of the
23 companies. Using the Small Business Administration's (SBA) ``Table
of Size Standards'' and the North American Industry Classification
System (NAICS) codes listed in the table, we identified 12 of the 21
companies to be small entities. We found the other 9 companies to not
be small entities. We did not find information on the remaining 2
companies; therefore, we assumed these companies to be small entities
for a total of 14 small entities out of 23 companies, or 61 percent.
The removal of these training requirements may result in reduced
demand for the affected courses, which could lead to a minor decrease
in revenue for some training providers. However, the proposed rule does
not impose any new costs or additional regulatory burdens on training
providers. Table 26 shows the forgone enrollment revenue for the
affected training providers by this rule. LMS, BRM, and ESTO training
providers would lose annually, on average, approximately $8,944,
$2,574, and $474,030, respectively.

Table 26--Summary of Annual Revenue Impacts per Training Provider
----------------------------------------------------------------------------------------------------------------
Forgone
Number of Number of Average number Average enrollment
Training training mariners of mariners tuition per revenue per
providers applying for per training training training
STCW provider providers provider
(a) (b) * (c) = (b) / (d) ** (e) = (c) x
(a) (d)
----------------------------------------------------------------------------------------------------------------
LMS............................. 22 172 8 $1,118 $8,944
BRM............................. 11 25 2 1,287 2,574
ETSO............................ 2 460 230 2,061 474,030
----------------------------------------------------------------------------------------------------------------
* Table 2.
** Table 7.

Based on this analysis, in Table 27, we estimated the impact on
revenues for each of the small entities with available revenue
information. Two-thirds (67%) of small entities with available revenue
information would face a <1% revenue loss; 25% would face between a 1
and 3% revenue loss; and 8% would face a >3% revenue loss.

Table 27--Distribution of Revenue Impacts
----------------------------------------------------------------------------------------------------------------
Number of small Portion of small
Percent of revenue impact entities with known entities with known
revenue revenue (%)
----------------------------------------------------------------------------------------------------------------
<1%........................................................... 8 67
1-3%.......................................................... 3 25
>3%........................................................... 1 8
----------------------------------------------------------------------------------------------------------------

Based on available information, the Coast Guard does not anticipate
that this proposed rule would have a significant economic impact on a
substantial number of small entities. Therefore, the Coast Guard
certifies under 5 U.S.C. 605(b) that this proposed rule would not have
a significant economic impact on a substantial number of small
entities. If you think that your business, organization, or
governmental jurisdiction qualifies as a small entity and that this
proposed rule would have a significant economic impact on it, please
submit a comment to the docket at the address listed in the ADDRESSES
section of this preamble. In your comment, explain why you think it
qualifies and how and to what degree this proposed rule would
economically affect it.

C. Assistance for Small Entities

Under section 213(a) of the Small Business Regulatory Enforcement
Fairness Act of 1996, Public Law 104-121, we want to assist small
entities in understanding this proposed rule so that they can better
evaluate its effects on them and participate in the rulemaking. If the
proposed rule would affect your small business, organization, or
governmental jurisdiction and you have questions concerning its
provisions or options for compliance, please call or email the person
in the FOR FURTHER INFORMATION CONTACT section of this proposed rule.
The Coast Guard will not retaliate against small entities that question
or complain about this proposed rule or any policy or action of the
Coast Guard.
Small businesses may send comments on the actions of Federal
employees who enforce, or otherwise determine compliance with, Federal
regulations to the Small Business and Agriculture Regulatory
Enforcement Ombudsman and the Regional Small Business Regulatory
Fairness Boards. The Ombudsman evaluates these actions annually and
rates each agency's responsiveness to small business. If you wish to
comment on actions by employees of the Coast Guard, call 1-888-REG-FAIR
(1-888-734-3247).

D. Collection of Information

This proposed rule would call for a change to an existing
collection of information under the Paperwork Reduction Act of 1995, 44
U.S.C. 3501-3520. As defined in 5 CFR 1320.3(c), ``collection of
information'' comprises reporting, recordkeeping, monitoring, posting,
labeling, and other similar actions. The title and description of the
information collection, a description of those who must collect the
information, and an estimate of the total annual burden follow. The
estimate covers the time for reviewing instructions, searching existing
sources of data, gathering and maintaining the data needed, and
completing and reviewing the collection.
Title: Application for Merchant Mariner Credentials and Medical
Certificates.
OMB Control Number: 1625-0040.

[[Page 62407]]

Summary of the Collection of Information: The Coast Guard currently
collects information from applicants for an MMC under 46 CFR parts 10,
11, 12, 13, and 16, and requires that each applicant for an MMC or
Medical Certificate submit an application to the Coast Guard.
The proposed rule would modify the existing reporting and
recordkeeping requirements under 46 CFR 11.317(a)(3)(v) and (b)(1),
11.321(a)(3)(iv) and (b)(1), 11.329(a)(4)(v), and 12.611(a)(4), by
eliminating the requirements for MMC applicants to submit certificates
of completion for LMS, BRM, ETSO, CSM, and HVPS training, and by
removing the requirement to demonstrate evidence of meeting the
standard of competence in LTW skills. These requirements were
implemented through the 2013 final rule. In the current regulations,
mariners seeking an MMC endorsement must submit an application to the
Coast Guard using the CG-719B Form.
Need for Information: The collection of information is needed to
verify that mariners fulfill requirements related to: (1) LMS training
in Sec. Sec. 11.317(a)(3)(v) and (b)(1); (2) BRM training in Sec.
11.321(a)(3)(iv); (3) demonstration of standard of competence in LTW
skills in Sec. 11.321(b)(1); (4) ETSO training in Sec.
11.329(a)(4)(v); (5) CSM training in Sec. 12.611(a)(4)(i), and (6)
HVPS training in Sec. 12.611(a)(4)(ii) for the reasons described in
Section III., Executive Summary, C. Summary of Major Provisions. The
Coast Guard, in the proposed rulemaking, is removing the requirements
for items (1) thorough (6) listed above. Hence it would eliminate any
reporting requirements associated with those items.
Proposed Use of Information: The collection of information is
intended to ensure mariners meet the regulatory requirements for
issuance of certain STCW endorsements.
Description of the Respondents: The respondents are mariners
applying for STCW endorsements as Masters of vessels of less than 500
GT limited to near-coastal waters, or OICNW on vessels of less than 500
GT limited to near-coastal waters, and mariners applying for STCW
endorsements as OICEW in a manned engineroom on vessels powered by main
propulsion machinery of 750 kW/1,000 HP propulsion power or more, or
ETR on vessels powered by main propulsion machinery of 750 kW/1,000 HP
or more.
Number of Respondents: According to the Coast Guard MMLD database,
currently there is an annual average of approximately 741 mariners that
were issued either an original STCW endorsement as Masters of vessels
of less than 500 GT limited to near-coastal waters, or an original STCW
endorsement as OICNW on vessels of less than 500 GT limited to near-
coastal waters, or an original STCW endorsement as OICEW in a manned
engineroom on vessels powered by main propulsion machinery of 750 kW/
1,000 HP propulsion power or more, over the 3-year period from 2022-
2024.
The Coast Guard estimates the number of future applicants for these
STCW endorsements that would need to complete LMS, ETSO, or BRM
training, or demonstrate evidence of meeting the standard of competence
in LTW skills based on this historical average. This proposed rule
would not reduce the number of annual respondents because these
mariners are still submitting an application but attaching less
documentation.
Frequency of Response: The current collection of information
requires respondents to submit training certificates showing completion
of LMS training, BRM training, ETSO training, and standard of
competence assessments when applying for their respective STCW
endorsement; the Coast Guard is eliminating the need for respondents to
submit these documents when applying for an MMC.
Burden of Response: This would decrease the burden for a mariner by
approximately 0.083 hours (5 minutes) per application. Since there are
a total of 741 documents that need to be reviewed (172 from LMS + 25
from BRM + 460 from ETSO + 84 for the demonstration of competence in
LTW skills), the total reduction in burden on mariners is approximately
62 hours annually (0.083 x 741).
Estimate of Total Annual Burden: The existing OMB-approved total
annual burden is 61,850 hours. This proposed rule would decrease the
annual hour burden by approximately 62 hours to a requested amount of
about 61,788 hours.
As required by 44 U.S.C. 3507(d), we will submit a copy of this
proposed rule to OMB for its review of the collection of information.
We ask for public comment on the proposed collection of information
to help us determine, among other things--
<bullet> How useful the information is;
<bullet> Whether the information can help us perform our functions
better;
<bullet> How we can improve the quality, usefulness, and clarity of
the information;
<bullet> Whether the information is readily available elsewhere;
<bullet> How accurate our estimate is of the burden of collection;
<bullet> How valid our methods are for determining the burden of
collection; and
<bullet> How we can minimize the burden of collection.
If you submit comments on the collection of information, submit
them to both the OMB and to the docket where indicated under ADDRESSES.
You need not respond to a collection of information unless it
displays a currently valid control number from OMB. Before the Coast
Guard could enforce the collection of information requirements in this
proposed rule, OMB would need to approve the Coast Guard's request to
collect this information.

E. Federalism

A rule has implications for federalism under Executive Order 13132
(Federalism) if it has a substantial direct effect on States, on the
relationship between the National Government and the States, or on the
distribution of power and responsibilities among the various levels of
government. We have analyzed this proposed rule under Executive Order
13132 and have determined that it is consistent with the fundamental
federalism principles and preemption requirements described in
Executive Order 13132. Our analysis follows.
It is well settled that States may not regulate in categories
reserved for regulation by the Coast Guard. It is also well settled
that all of the categories covered in 46 U.S.C. Chapters 33, 37, 71, 73
and 81 (inspection, design, construction, alteration, repair,
maintenance, operation, equipping, personnel qualification, and manning
of vessels), as well as the reporting of casualties and any other
category in which Congress intended the Coast Guard to be the sole
source of a vessel's obligations, are within the field foreclosed from
regulation by the States. See, e.g., United States v. Locke, 529 U.S.
89 (2000) (finding that the states are foreclosed from regulating
tanker vessels); see also Ray v. Atlantic Richfield Co., 435 U.S. 151,
157 (1978) (state regulation is preempted where ``the scheme of federal
regulation may be so pervasive as to make reasonable the inference that
Congress left no room for the States to supplement it [or where] the
Act of Congress may touch a field in which the federal interest is so
dominant that the federal system will be assumed to preclude
enforcement of state laws on the same subject.'' (citations omitted)).
Because this proposed rule involves the credentialing

[[Page 62408]]

of merchant mariners under 46 U.S.C. Chapters 71 and 73, it relates to
personnel qualifications for vessels subject to a pervasive scheme of
federal regulation and is foreclosed from regulation by the States.
Therefore, because the States may not regulate within this category;
this proposed rule is consistent with the fundamental federalism
principles and preemption requirements in Executive Order 13132.
While it is well settled that States may not regulate in categories
in which Congress intended the Coast Guard to be the sole source of a
vessel's obligations, the Coast Guard recognizes the key role that
State and local governments may have in making regulatory
determinations. Additionally, for rules with federalism implications
and preemptive effect, Executive Order 13132 specifically directs
agencies to consult with State and local governments during the
rulemaking process. If you believe this proposed rule would have
implications for federalism under Executive Order 13132, please contact
the person listed in the FOR FURTHER INFORMATION CONTACT section of
this preamble.

F. Unfunded Mandates Reform Act

The Unfunded Mandates Reform Act of 1995, 2 U.S.C. 1531-1538,
requires Federal agencies to assess the effects of their discretionary
regulatory actions. In particular, the Act addresses actions that may
result in the expenditure by a State, local, or tribal government, in
the

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This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.