Mysteries of the NVDC revealed — a little

NOVEMBER 14, 2017 — A veil has been at least partially lifted from one of the greatest mysteries of all time: How the Coast Guard's National Vessel Documentation Center (NVDC) arrives at its U.S. Build and Rebuild determinations on whether ships are eligible for, or can retain, Jones Act privileges.

An Action Item alert from law firm Blank Rome notes that "in October 2017, the NVDC quietly posted a policy guidance document under the determination letters section of the NVDC webpage. This 'Review Criteria for Steel Weight Components WRT U.S. Build and Foreign Rebuild Determinations' (the 'Review Criteria') offers important insights into how the U.S. Coast Guard Naval Architecture Division ("NAD") reviews various steel components with respect to the definitions of 'hull'" and 'superstructure'" under U.S. Coast Guard regulations. The Review Criteria are vital to the NVDC's ultimate determination of whether a vessel may receive a Certificate of Documentation with a Coastwise Endorsement to operate in the coastwise trade."

Blank Rome notes that the release of the publication may be a reaction to Freedom of Information Act (FOIA) requests for NAD reports used by the NVDC in making its determinations.

Blank Rome says the posting of the Review Criteria on the NVDC website is "an important step in helping stakeholders understand how the Coast Guard interprets the hull and superstructure with regard to making U.S. Build and Rebuild determinations on coastwise eligibility. This transparency should be welcomed by the maritime industry. However, industry stakeholders should be aware that the guidance document only provides a tool to assist stakeholders in understanding and complying with the complex nuances of the U.S. Build and Rebuild standards. In this regard, it would be prudent for stakeholders to obtain the advice of counsel specializing in this type of work when constructing vessels to help ensure the vessels meet U.S. Build and Rebuild coastwise trade standards."

Read the Blank Rome alert HERE

Download the Review Criteria HERE

 

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