Public Statements


United States

Bureau of Census:

The WSC submits comments to Bureau of Census regarding the agency's proposed modifications to the Foreign Trade Regulations and Automated Export System (AES) requirements. (March 22, 2011) Read these comments.

The WSC submits comments to Bureau of Census regarding Mandatory Automated Export System (AES) Filing proposed rule. (November 12, 2003) Read these comments.


Bureau of Ocean Energy Management (BOEM):

The WSC submits comments to BOEM on the agency's call for information and nominations on four proposed wind farm lease areas in the New York Bight (i.e. the approaches to the Port of New York/New Jersey.) (July 30, 2018) Read these comments.

The WSC submits comments to BOEM on the agency's request for feedback on windfarm development plans for the U.S. Atlantic Coast. (July 5, 2018) Read these comments.

The WSC submits comments to BOEM regarding the agency's proposed wind farm lease area off the coast of California. (September 19, 2016). Read these comments. 

The WSC submits comments to BOEM regarding the agency's call for information and nominations and notice of intent to prepare an environmental assessment for wind farm development off the coast of New York state. (July 14, 2014). Read these comments.

The WSC submits comments to BOEM regarding the agency's proposed sale notice for wind farm leases off the coast of Maryland (February 18, 2014).  Read these comments.

The WSC submits comments to BOEM regarding the agency's proposed wind farm lease area off the coast of New York (March 5, 2013).  Read these comments.  

The WSC submits comments to BOEM regarding the agency's call for information and the completion of an Environmental Assessment for the contruction of wind energy projects off the coast of North Carolina (January 28, 2013) Read these comments.

The WSC submits comments to BOEM regarding the agency's call for information and nominations for the construction of wind energy projects off the coast of New Jersey. (June 6, 2011)  Read these comments.

The WSC submits comments to BOEM regarding the agency's plans to conduct environmental risk assessments for proposed wind farm lease areas which overlap with major commercial shipping lanes. (March 11, 2011)  Read these comments

The WSC submits comments to BOEM regarding a request for interest in siting wind farms off the coast of Massachusets in a major commercial shipping lane. (March 10, 2011) Read these comments.

The WSC submits comments to BOEM regarding a request for interest in siting wind farms off the coast of Maryland in a major commercial shipping lane.  (January 10, 2011) Read these comments.


California State Lands Commission (CSLC):

The World Shipping Council comments on the Commission's proposal to adopt protocols to assess compliance with California's ballast water treatment standards, which are not achievable using commerically available shipboard treatment systems. (March 24, 2017) Read these comments.

The World Shipping Council files comments in support of the adjustments incorporated into the November 23, 2016 proposal for amendments to the biofouling management regulation. (January 9, 2017). Read these comments.

The World Shipping Council submits additional comments regarding proposed amendments to biofouling managment regulations to minimize transfer of non-indigenous species from vessels operating in California waters. (June 16, 2015) Read these comments.

The WSC, along with the American Waterways Operators, the Chamber of Shipping of America, the Cruise Lines International Assocation, Inc., and the International Association of Independent Tanker Owners, submitted their response to the revised proposed amendments to Article 4.8 biofouling management regulations for vessels operating in California waters. (June 26, 2012) Read these comments.

The WSC, together with shipping industry partners, the American Waterways Operators, the Chamber of Shipping of America, Cruise Lines International Association, Inc., Intertanko and the Pacific Maritime Shipping Association, submitted comments regarding proposed amendments to performance standards and assessment protocols for the discharge of ballast water for vessels operating in California waters.  (April 17, 2012)  Read these comments.

The World Shipping Council submitted comments regarding the revised proposal to amend biofouling management regulations for vessels operating in California state marine waters. (January 30, 2012). Read the comments.

The WSC submits comments regarding the initial proposal to amend the biofouling management regulations for vessels operating in California state marine waters, including a statement by expert John Lewis regarding the technical issues in the practical application and achievement of the proposed regulations and their benefit in protecting California state marine waters from invasions by harmful marine species. (November 21, 2011) Read the comments and the statement.


Centers for Disease Control and Prevention (CDC):

The WSC submits comments on proposed changes to rules governing the control of communicable diseases. (February 10, 2006) Read these comments.


Customs and Border Protection (CBP):

The WSC files comments in response to CBP's Notice on "Reducing Regulation and Controlling Regulatory Costs" in which CBP invited suggestions from industry on specific regulations or paperwork requirements that could be altered or eliminated to reduce burdens while still allowing CBP to perform its missions. (December 11, 2017) Read the comments.

The WSC files comments on CBP's Notice of Proposed Rulemaking to clarify which party is responsible for the Importer Security Filing for shipments in which a non-vessel operating common carrier (NVOCC) is involved (September 6, 2016).  Read these comments.

The WSC files comments to CBP and the Office of Management and Budget (OMB) recommending that the paper "Vessel Entrance or Clearance Statement" form be eliminated since most of the form's data elements are already being provided electronically to the government (February 10, 2014).  Read these comments.

The WSC files comments on CBP's Notice of Proposed Rulemaking to automate and modify the current in-bond process (April 23, 2012).Read these comments.

The WSC files comments urging DHS to phase-out, by the end of 2010, the ocean carrier requirement to submit the paper I-418 "Passenger List/Crew List" form, which contains virtually the same data elements already submitted electronically via the electronic Notice of Arrival/Departure (eNOA/D) system. (December 22, 2009) Read these comments.

The WSC files comments on the Interim Final Rule on importer security filing (ISF) and additional carrier requirements (a.k.a. 10 plus 2) (June 1, 2009) Read these comments.

The WSC comments on proposed rule for Importer Security Filing (ISF) and Additional Carrier Requirements (a.k.a. 10 plus 2) (March 3, 2008) Read these comments.

The World Shipping Council submits joint comments to the Bureau of Customs and Boarder Protection (CBP) and asks CBP to refine its approach on gathering information on importers' suppliers. (February 2, 2004) Read these comments.

The World Shipping Council files comments on Customs Service's Straw man Proposals for the Collection of Mandatory Advanced Electronic Cargo Information. (February 18, 2003) Read these comments.

The World Shipping Council opposes Customs Service's Proposed Rule on confidentiality of trade data for U.S. imports. (February 10, 2003) Read these comments.

The World Shipping Council files comments on Customs Service rulemaking requiring that cargo manifests be filed 24 hours before loading at a foreign port. (September 9, 2002) Read these comments.

The WSC comments on the proposed rules for Advanced Passenger Information Systems. (October 12, 2006) Read these comments.

The World Shipping Council responds to Customs' Request for Information on secure container technology and proposes a framework for e-seals and other RFID technology. (February 17, 2004) Read these comments.

The World Shipping Council submits comments to the Bureau of Customs and Border Protection on proposed Trade Act regulations. (August 22, 2003) Read these comments.


U.S. Coast Guard (USCG):

The WSC comments on the USCG's Atlantic Coast Port Access Route Study (ACPARS) Final Report to prevent navigational safety conflicts between commercial vessel traffic and offshore renewable energy sites (April 13, 2016). Read these comments.

The WSC files comments on the USCG's proposed rule that would clarify its views on preemption of state laws and regulations by the federal laws and regulations administered by the Coast Guard (March 27, 2014) Read these comments.  

The WSC files comments on the Supplemental Notice of Proposed Rulemaking (SNPRM) on cargo securing manuals and reporting of lost or jettisoned cargo (February 13, 2014)  Read these comments.

The WSC files comments on the Notice of Proposed Rulemaking (NPRM) for requirements for ballast water reporting and record keeping (August 5, 2013) Read these comments.

The WSC comments on the USCG's Atlantic Coast Port Access Route Study (PARS) to prevent navigational conflicts between vessel traffic and offshore renewable energy sites (August 9, 2011). Read these comments.

The WSC recommends that the U.S. Government establish a single, environmentally protective, federal  ballast water treatment standard (December 4, 2009). Read these comments.

The WSC comments on the proposed rulemaking for vessel requirements for notices of arrival and departure, and automatic identification system. (April 15, 2009) Read these comments.

The WSC comments on the proposed rulemaking for Long Range Identification and Tracking of Ships. (December 21, 2007) Read these comments.

The World Shipping Council comments in support of the Coast Guard's Temporary Interim Rules on maritime security. (July 31, 2003) Read these comments.

The World Shipping Council submits comments to the Coast Guard regarding implementation of new maritime security regulations. (February 28, 2003) Read these comments.

The World Shipping Council responds to Coast Guard Rulemaking on Notices of Arrival; supports permanent 96-hour requirement. (August 19, 2002) Read these comments.


Environmental Protection Agency (EPA):

The WSC submits comments on the draft of the EPA's next Vessel General Permit (February 21, 2012). Read these comments.

The WSC files comments recommending that EPA's next Vessel General Permit contain a numeric ballast water treatment standard that is science based, aligns with the U.S. Coast Guard's impending Final Rule, and includes a reasonable compliance schedule for technology installation.  (December 23, 2010) Read the comments.

The World Shipping Council submits comments in response to a Notice of Proposed Rulemaking (NPRM), which proposes to establish a no discharge zone for sewage for all California state waters. (November 1, 2010) Read the comments.

The WSC submits comments on its proposed rule for Control of Emissions from New Marine Compression Ignition Engines at or Above 30 Liters per Cylinder. (September 28, 2009) Read the comments.

The WSC submits comments on the EPA's Advance Notice of Proposed Rulemaking (ANPRM), regarding the agency's preliminary plans to issue a proposed regulation of ship air emissions that tracks with the U.S. ship air emission proposal to IMO. (February 27, 2008) Read the comments.

The WSC responds to a request for comments on procedures on National Pollutant Discharge Elimination System Permits. (August 6, 2007) Read the comments.


Federal Maritime Commission (FMC):

Docket 18-06: Comments of the World Shipping Council in response to the Commission's Notice of Proposed Rulemaking (NPRM) on Interpretive Rule, Shipping Act of 1984. (October 10, 2018) Read the comments.

Petition P4-16:   John Butler testifies before the FMC in a hearing to consider the issues related to detention, demurrage and per diem charges. (January 17, 2018) Read the oral statement. (The WSC previously submitted formal comments to the petition.)

Docket 17-04: World Shipping Council submits comments in response to a notice of inquiry regarding the FMC's regulatory reform initiative. (July 5, 2017) Read the comments.

Petition P4-16: WSC submits comments regarding the Petition of the Coalition for Fair Port Practices for a rulemaking proceeding for the purpose of adopting a rule to clarify what constitutes "just and reasonable rules and practices" with respect to demurrage, detention and per diem charges assessed by ocean carriers and marine terminal operators. (February 28, 2017) Read the comments.

Docket 16-04: The World Shipping Council submits comments in the matter of ocean common carrier and marine terminal operator agreements subject to the Shipping Act of 1984. (October 14, 2016) Read the comments.

Docket 16-05: The World Shipping Council submits comments supporting the FMC's proposal that service contract amendments be allowed to be filed up to thirty days following the parties' agreement to the amendment, with the amendment allowed to become effective prior to filing. (September 23, 2016) Read the comments.

The World Shipping Council submits comments to the Advanced Notice of Proposed Rulemaking (ANPR) regarding service contracts and NVOCC service arrangements. (March 30, 2016) Read the comments.

The World Shipping Council submits comments regarding a Notice of Proposed Rulemaking regarding possible statuatory changes to the FMC's authority to grant attorney fees in complaint proceedings. (Docket: 15-06) (August 6, 2015) Read the comments.

The World Shipping Council submits comments regarding a Petition by the National Customs Brokers and Forwarders Association of America Inc. for initiation of rulemaking to amend the FMC's regulations governing Negotiated Service Arrangements (NSAs) and Negotiated Rate Agreements (NRAs). (Petition 2-15) (June 5, 2015) Read the comments.

The World Shipping Council submits comments on the FMC's Initial Draft Strategic Plan for FY 2014-2018. (August 26, 2013) Read the comments.

The WSC submits comments regarding possible amendments to regulations governing ocean transportation intermediary (OTI) licensing and financial responsibility requirements and general duties. (July 18,2013) Read the comments.

The World Shipping Council responds to a Notice of Inquiry (NOI), Docket No. 12-07, regarding development and release of container freight rate indices for U.S. agricultural exports based on a sampling of service contracts filed with the FMC. (June 28, 2012) Read the comments.

The WSC, together with the National Industrial Transportation League (NITL) and the National Retail Federation, filed joint comments in response to a Notice of Inquiry (NOI) regarding U.S. inland containerized cargo moving through Canadian and Mexican seaports. (December 21, 2011) Read the comments.

The WSC responds to a Notice of Inquiry (NOI) to solicit public comment on the impact of slow steaming in U.S. liner commerce. (April 14, 2011) Read the comments.

WSC submits comments to the FMC in support of the joint petition seeking authority for NVOCCs to enter into service contracts with shippers. (September 30, 2004) Read the comments.

The World Shipping Council submits comments to the Federal Maritime Commission in response to Notices regarding various petitions. (October 10, 2003) Read the comments.


Food and Drug Administration (FDA):

The World Shipping Council submits comments with the Food and Drug Administration regarding their Interim Final Rules on Prior Notice of Imported Food and Registration of Food Facilities. (December 23, 2003) Read the comments.

The World Shipping Council submits comments to the Food and Drug Administration regarding Notice of Proposed Rulemaking on advance reporting of imported food. (April 4, 2003) Read the comments.


National Oceanic and Atmospheric Administration (NOAA) and National Marine Fisheries Service (NMFS):

The World Shipping Council comments on a petition to the National Oceanic and Atmospheric Administration's National Marine Fisheries Service (NOAA/NMFS) that proposes establishment of a Southern Resident Killer Whale protection zone that would conflict with and narrow the U.S. Coast Guard and the International Maritime Organization's designated safe shipping routes in the Haro Strait off the coast of Washington. (April 13, 2017) Read the comments.

The World Shipping council comments on the NMFS Proposed Rule to Eliminate the Expiration Date Containeed in the Final Rule to Reduce the Threat of Ship Collisions With North Atlantic Right Whales. (August 2, 2013) Read the comments.

The WSC comments on NMFS's Proposed Rule to Implement Vessel Speed Restrictions and the corresponding Draft Environmental Impact Statement (DEIS). (October 5, 2006) Read the comments.

The World Shipping Council submits comments on NMFS's Notice of Intent to prepare on Environmental Impact Statement on Right Whale Ship Strike Reduction Strategy. Council Supports the EIS but calls for additional research on ship strikes. (July 22, 2005) Read the comments.

 


New York State Department of Environmental Conservation (NYSDEC):

The WSC files comments in response to the New York State Department of Environmental Conservation's draft Clean Water Act Section 401 Certification for the 2013 Commercial and Large Recreational Vessel General Permit. (June 6, 2012). Read the comments.

The WSC submits comments in response to the New York State Department of Environmental Conservation's proposed Section 401 Water Quality Certification for the Environmental Protection Agency's (EPA) Vessel General Permit. (October 20, 2008). Read the comments.


Office of Management and Budget

 

The WSC files comments with the Office of Information and Regulatory Affairs in the Office of Management and Budget in response to its request for information on Maritime Regulatory Reform. (August 30, 2018) Read the comments.


State Department:

The WSC files comments on U.S. State Department interim final rule to eliminate crew list visa system. (May 17, 2004) Read the comments.

The WSC files comments on U.S. State Department Interim Rule on personal appearance and interview requirements for non immigrant visa applicants. (September 4, 2003) Read the comments.

The World Shipping Council files comments with the State Department with recommendations on seafarer visa process. (February 11, 2003) Read the comments.


Transportation Security Administration (TSA):

The World Shipping Council supports Operation Safe Commerce (OSC) and calls on the Transportation Security Agency to establish an open, transparent process, involving shippers and carriers, in the evaluation of OSC projects. (December 5, 2002) Read the comments.