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MM&P has joined forces with the American Pilots Association and other major maritime groups in a bid to halt a plan by the National Oceanic and Atmospheric Administration to extend marine mammal protection speed limits to pilot boats.

In a letter to Congress, the group warns that the proposal, if implemented, would create grave safety risks for pilots and pilot boat operators, and hamper port operations up and down the East Coast.

MM&P and the other signatories to the Aug. 30 letter said that while they would normally work through Congressional staffers, the risk of critical safety and supply chain threats made it necessary in this case to take urgent action.

Existing regulations, which limit vessels 65 feet and larger to 10kts during half of the calendar year to protect North Atlantic right whales, have been in place for many years.

NOAA proposes changes that would, among other things, apply the speed restrictions to vessels as small as 35 feet, including the small boats used to transfer pilots to and from large vessels.

“Applying speed restrictions to pilot vessels… would be dangerous for pilots and the crews that operate these boats, increase pilot/pilot boat crew fatigue, negatively impact port efficiency in ports throughout the country, and unduly burden both the shipmaster and the pilot…,” the group wrote.

“Pilot transfer operations are inherently dangerous, and the proposed rule would make these operations even more dangerous as it would force both pilot boats and commercial vessels to operate outside of the ideal operational parameters…”

Increasing pilot and pilot boat operator fatigue is an additional problem, they wrote.

“Pilot boats were designed so as not to subject pilots to long, pounding pilot vessel transits that would significantly add to pilots’ and pilot boat operators’ workload and fatigue levels.”

“If pilots were forced to transit at 10 knots or less, this would dramatically increase the risk of fatigue.”

“The dangers of mariner fatigue are a principal factor that can negatively impact mariner well-being, marine operations, and navigation safety.”

MM&P and the other signatories to the letter also noted that the paperwork that would be required to document compliance with the rule would be “significant, lengthy, detailed, and extremely cumbersome.”

It would “cause masters and pilots, at a critical point when they are considering whether to increase speed for the safety of the ship—and its crew, passengers, and cargo—to be worrying about whether or not their decision could subject them to criminal penalties, including imprisonment.”

They propose “a targeted and narrow speed restriction exemption for pilot vessels and federal navigation channels/pilot boarding areas,” and note that to their knowledge, there has never been a recorded instance of a pilot boat striking a North Atlantic right whale.

The letter was signed by: MM&P President Don Marcus; Jorge J. Viso, president of the American Pilots’ Association; Kathy J. Metcalkf, president and CEO of the Chamber of Shipping of America; and Christopher J. Conner, president and CEO of the American Association of Port Authorities.

Click here for the letter.