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Comment 78 for To Consider Proposed Control Measure for Ocean-Going Vessels At Berth (ogvatberth2019) - 15-1.

First NameMugurel
Last NameCalin
Email Addressmugurel.calin@swirecnco.com
Affiliation
SubjectAssigning 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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