First Name | Mugurel |
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Last Name | Calin |
Email Address | mugurel.calin@swirecnco.com |
Affiliation | |
Subject | Assigning VIE's for a small fleet |
Comment | Good afternoon, We, as a very small fleet operator, we are concerned with wording on legislation for assigning VIE to a fleet. For container fleets it is said to be 5% of total amount of visits from previous year and the number will be rounded to the nearest whole number. On our fleet, we average 9 to 11 port calls a year and that resulting in a total assigned VIE of 0.45 to 0.55. In a year where we would have only 9 port calls, assigned VIE for following year would be 0.44 which rounded to nearest whole number would become zero. While we are not planning to have non compliant call, as the board is very well aware, vessel breakdowns happens that sometime results in emergency replacement of tonnage. Could the board consider reviewing wording to read "The number of VIEs granted is rounded UP to nearest whole number"? Respectfully, |
Attachment | |
Original File Name | |
Date and Time Comment Was Submitted | 2020-05-01 17:31:04 |
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