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· Puget Sound Pounder
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· Catamarans are the best
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as I understand it, the $26 was to cover handling/processing fees.. so, if they can make the documentation good for 3 years.. wouldn't a one time fee of $26 for 3 year documentation about cover it? Why agree to, or think that a discounted fee.. like for instance, pay for 1 year = $26, pay for 2 years = $45, pay for 3 years = $65. Doesn't make sense in my book. Why not a one time fee of $26 for 5 year documentation?

· Registered
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Comments in the forum are not likely to be read by the rulemakers. Here for your ease of access is the URL of the page where your comment might actually be read:

*** stupid post count rule on this site - add a www to the front of this!submitComment;D=USCG-2010-0990-2737
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My comments:

1. Would you prefer a multiyear renewal program with fees charged at the time of renewal, or would you prefer to continue annual renewals including an annual fee for service? Please explain why you prefer the renewal period and its fee payment schedule.

A multiyear option would mean less costs for the government and less hassle and paperwork for both the government and the user.

2. Would you prefer having the option of choosing a multiyear or annual renewal each time you renew? Please explain why you prefer the option that you chose. If the only option for renewal is multiyear, how would you suggest the annual renewal is phased over to a multiyear renewal?

Simply use a check box or something similar, either on line or on paper, and allow the user the check for a single year renewal versus various options for how many years they wish to renew.

3. Would you prefer a multiyear renewal program that requires payment every other year, or one that requires payment every 3 years? Please explain why you chose this option.

You should only have to pay when the renewal happens. Furthermore, you should only charge for the paperwork, i.e. the charge for a multiyear renewal should be the same for a single year renewal since the workload to file is identical. This fee was not put in place as a tax or licensing system, but as a means to recoup costs associated with the filing and paperwork. If you charge more for multiyear renewals, it may be interpreted as a tax and could result in a court challenge.

4. What are the benefits of a multiyear renewal?

Less paperwork (more green), less workload for both NVDC and users.

5. Are there any negative impacts of a multiyear renewal?

You would have to form a means to cancel or amend existing documentation in the case of a vessel changing hands or being lost. This system should already be in place for single year renewals, in the case of an owner selling a vessel mid-year, but there may be some adjustments that need to be made to the process or paperwork.

6. What, if any, concerns would you need to have addressed prior to selecting the multiyear renewal option?

None, this is by far the better option. I would even go as far to say that lifetime documentation should be an option, provided that owners are informed that their documentation would need to be amended in the case of a change of address, and of course, sale or loss of a vessel. Vessel documentation is very similar to a title, a record of ownership. There is no reason to have to renew each year that which has undergone no change whatsoever.

7. What are the impacts to mortgages from multiyear information verification and COD renewal? Will lenders require additional information from the National Vessel Documentation Center (NVDC) to manage loans?

I don't see why they would. If the information of the sellers COD is correct, then everything should proceed as normal. If the information is wrong or outdated (e.g. seller moved residence and failed to update the COD with the NVDC), then it would be handled the exact same way that situation is handled at present.

8. What period of renewal is best for mortgage lenders?

Lifetime renewal would likely also reduce paperwork for mortgage lenders in the case that they have to deal with renewal for mortgaged vessels each year. If lifetime (until a change is necessary) is not considered feasible, then I would say that a period of renewal equal to the 'standard' payback time for marine promissory notes would be the correct maximum period.

9. What other suggestions do you have for reducing the burden of obtaining a COD?

Consider only requiring a change in the COD only in the event that any of the information has changed.
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