Maritime Security

A.C. Cruise Line, Inc. Captain Alan D. Circeo 290 Northern Avenue Boston, MA 02210 617-261-6633 February 25, 2003 Response to U.S.C.G. Docket#2002-14069 Maritime Security December 30, 2002 A.C. Cruise Line, Inc. is a small family operated seasonal business. Founded in 1976 in Boston, Massachusetts. We operate two (2) small passenger vessels both classified as K vessels. The Virginia C II #289078 - 215 passengers and the Cape Ann#609646 - 539 Passengers. All of our charters operate from point A to point A. We do not consider any of our sailings to be transportation. Rather they are functions afloat. All types of private affairs such as corporate groups, weddings, school groups etc. Nowhere in NAVICS 10/02 - 11/02 or F.R. 12/30/02 do I find any reference to our type of private charter cruises. Simply the fact that our vessels can carry over the 150 passengers. We are in what is known as the Hospitality Industry. Our competition are the restaurants, function halls, veterans posts, non-profits such as the Aquarium, Children's Museum, Kennedy Library, Museum of Fine Arts, Thompson Island Educational Center etc, all chasing the same type of business that we and other charter dinner cruise type vessels, yet none of those shore side attractions will be required or expected to subject their clients to under go the Security Review that it appears you are expecting us to put our clients through. I suggest that we will soon be out of business should we continue on this road. We only need to look at the airline industry and the losses they have suffered since 9/11. Many major carriers have filed bankruptcy and experienced major layoffs of personal, reductions of schedules etc. Our industry has never been a high profit business. But an activity that we enjoy as providing recreation to the general public and seeing the happy faces as they leave the ship after a cruise. Most of us seasonal operations barely make our budget and usually have another occupation in the winter time as school teachers, trade workers or in our families case, the home heating oil business, as that fits quite well with the seasonal small passenger vessel operations. Your cost projections in the Federal Register are totally out of line for our small business. Extra staff, extra security equipment, AIS equipment are all off the wall for us. We can not pass the cost on to our clients as the population of people is very small and the cost per person would end up being more than twice what we charge now due to the small numbers of passengers in our case we only carried approximately 12,000 passengers all of 2002 season, hardly enough to pass on the large dollars for the expected compliance. Federal Grants as proposed will not filter down to small companies of our caliber. The suggestion that we could fence in our dock area with chain link and barbed wire is preposterous. In view of the fact of public access laws in Massachusetts, most of our docks are city docks on public piers and that would not be allowed in this Liberal state. I noticed as I read the Maritime Security Act of 2002 that was signed by President Bush. As I read the findings Section 101 it is quite obvious that the thrust of the Legislation is towards the International Cargo and Commercial Traffic. It is hard for me to understand how the Coast Guard can read out of this that the Domestic Small Passenger Vessel Industry could in any way possible be involved in and be burdened by this Legislation. I do not believe that was the intent of Congress. The Coast Guard is painting with to broad of a brush. This may make your job easier but will impose an extreme hardship on many small businesses. If the Coast Guard believes that K boats are in need of these regulations, than I would request that you comply with Section 70102 and produce the assessment in writing that the law requires you to do. You have not done this. Further to that, the F.B.I. Head of Terrorism Task Force from the Boston Office spoke at ou…

Filed on regulations.gov — full text not in the inline record.