Posted:
April 20, 2017
In a letter sent April 13 to U.S. Customs and Border Protection (CBP), American Maritime Officers National President Paul Doell stated the union's strong support for the agency's proposal to modify or revoke several ruling letters pertaining to the application of the Jones Act.
Doell's comments for the record on CBP's proposal, which was published January 18 in the Customs Bulletin (Volume 51, Number 3), drew focus on existing CBP rulings that allow foreign-flagged vessels to transport supplies and parts to offshore platforms in the Gulf of Mexico, deeming these payloads to be items fundamental to the mission or operation of the vessels carrying them, rather than cargo being transported domestically under the Jones Act - rulings the 2017 CBP proposal would correct.
"The record here is clear - the Jones Act works as intended," Doell wrote. "The proposed modification would ensure that the law is followed as written. This, in turn, would reaffirm the Jones Act's time-tested value and strengthen its standing as an important expression of U.S. sovereignty."
CBP's proposal has drawn widespread bipartisan support from lawmakers and from the maritime industry, including more than 33 members of the U.S. House of Representatives, 10 U.S. senators, 31 members of the Louisiana State House of Representatives, and the companies and organizations affiliated with the American Maritime Partnership coalition. In early February, CBP extended to April 18 the period during which it would be accepting comments on the modification and revocation proposal.
Commenting for AMO, Doell affirmed the extreme importance of the Jones Act to the job base for U.S. merchant mariners, U.S. defense sealift operations and capabilities, and U.S. economic interests, and noted the CBP's proposal to modify or revoke existing Jones Act ruling letters would create American jobs, bolster homeland security and national defense, and strengthen federal, state and local economies.
"The Jones Act sets a clear mandate: commercial waterborne cargoes moving between and among U.S. ports must be carried in vessels owned, documented, built and crewed in the United States," Doell wrote. "The law explicitly bars foreign-flag merchant vessels from providing 'any part of the transportation of merchandise by water, or by land and water, between points in the United States to which the coastwise laws apply.'
"Despite Jones Act clarity and consistently wise Congressional refusal to amend or repeal this domestic shipping law, the letter rulings addressed by the 2017 Notice have for years allowed foreign vessels to carry merchandise between U.S. points - specifically, in the Gulf of Mexico's offshore energy markets. Thus, these letter rulings should be revoked as proposed in the 2017 Notice," he wrote.
"The Jones Act already accounts for more than 500,000 private sector jobs nationwide and generates billions in federal, state and local tax revenues. The proposed modification and revocation of the ruling letters at issue would have a powerful multiplier effect on both economic benefit fronts.
"More importantly in this increasingly unstable world, the Jones Act sustains essential defense resources at no cost to U.S. taxpayers," he wrote.
"Many Jones Act ships operating between U.S. coastal points can carry military cargoes to overseas war zones if the need arises, and an estimated 80 percent of the highly skilled reliable and loyal civilian American merchant mariners who crew government-owned sealift ships during distant emergencies began their careers in Jones Act markets," Doell wrote. "Many officers and crewmembers aboard the 60 commercial U.S.-flag merchant ships providing defense services under the Maritime Security Program have at various times worked on vessels operating in domestic trades under the Jones Act.
"The Jones Act also ensures continued U.S. defense shipbuilding capability - large shipyards that can meet the Navy's vessel construction, maintenance and repair requirements now thrive on the three deep-sea coasts," he wrote. "In addition, the Jones Act enhances homeland security by ensuring that U.S. citizens staff all merchant vessels serving domestic deep-sea, Great Lakes and inland markets.
"This proposed modification would align Customs and Border Protection interpretation of the Jones Act with the law's requirements, all of which have served our nation so well since the Jones Act was enacted as Section 27 of the Merchant Marine Act of 1920," Doell wrote. "I urge immediate application of this modification to hasten new private investment in maritime industries that promote U.S. national, economic and homeland security interests."
AMO stands in strong support of U.S. Customs and Border Protection's proposed modification and revocation of Jones Act ruling letters
In a letter sent April 13 to U.S. Customs and Border Protection (CBP), American Maritime Officers National President Paul Doell stated the union's strong support for the agency's proposal to modify or revoke several ruling letters pertaining to the application of the Jones Act.
Doell's comments for the record on CBP's proposal, which was published January 18 in the Customs Bulletin (Volume 51, Number 3), drew focus on existing CBP rulings that allow foreign-flagged vessels to transport supplies and parts to offshore platforms in the Gulf of Mexico, deeming these payloads to be items fundamental to the mission or operation of the vessels carrying them, rather than cargo being transported domestically under the Jones Act - rulings the 2017 CBP proposal would correct.
"The record here is clear - the Jones Act works as intended," Doell wrote. "The proposed modification would ensure that the law is followed as written. This, in turn, would reaffirm the Jones Act's time-tested value and strengthen its standing as an important expression of U.S. sovereignty."
CBP's proposal has drawn widespread bipartisan support from lawmakers and from the maritime industry, including more than 33 members of the U.S. House of Representatives, 10 U.S. senators, 31 members of the Louisiana State House of Representatives, and the companies and organizations affiliated with the American Maritime Partnership coalition. In early February, CBP extended to April 18 the period during which it would be accepting comments on the modification and revocation proposal.
Commenting for AMO, Doell affirmed the extreme importance of the Jones Act to the job base for U.S. merchant mariners, U.S. defense sealift operations and capabilities, and U.S. economic interests, and noted the CBP's proposal to modify or revoke existing Jones Act ruling letters would create American jobs, bolster homeland security and national defense, and strengthen federal, state and local economies.
"The Jones Act sets a clear mandate: commercial waterborne cargoes moving between and among U.S. ports must be carried in vessels owned, documented, built and crewed in the United States," Doell wrote. "The law explicitly bars foreign-flag merchant vessels from providing 'any part of the transportation of merchandise by water, or by land and water, between points in the United States to which the coastwise laws apply.'
"Despite Jones Act clarity and consistently wise Congressional refusal to amend or repeal this domestic shipping law, the letter rulings addressed by the 2017 Notice have for years allowed foreign vessels to carry merchandise between U.S. points - specifically, in the Gulf of Mexico's offshore energy markets. Thus, these letter rulings should be revoked as proposed in the 2017 Notice," he wrote.
"The Jones Act already accounts for more than 500,000 private sector jobs nationwide and generates billions in federal, state and local tax revenues. The proposed modification and revocation of the ruling letters at issue would have a powerful multiplier effect on both economic benefit fronts.
"More importantly in this increasingly unstable world, the Jones Act sustains essential defense resources at no cost to U.S. taxpayers," he wrote.
"Many Jones Act ships operating between U.S. coastal points can carry military cargoes to overseas war zones if the need arises, and an estimated 80 percent of the highly skilled reliable and loyal civilian American merchant mariners who crew government-owned sealift ships during distant emergencies began their careers in Jones Act markets," Doell wrote. "Many officers and crewmembers aboard the 60 commercial U.S.-flag merchant ships providing defense services under the Maritime Security Program have at various times worked on vessels operating in domestic trades under the Jones Act.
"The Jones Act also ensures continued U.S. defense shipbuilding capability - large shipyards that can meet the Navy's vessel construction, maintenance and repair requirements now thrive on the three deep-sea coasts," he wrote. "In addition, the Jones Act enhances homeland security by ensuring that U.S. citizens staff all merchant vessels serving domestic deep-sea, Great Lakes and inland markets.
"This proposed modification would align Customs and Border Protection interpretation of the Jones Act with the law's requirements, all of which have served our nation so well since the Jones Act was enacted as Section 27 of the Merchant Marine Act of 1920," Doell wrote. "I urge immediate application of this modification to hasten new private investment in maritime industries that promote U.S. national, economic and homeland security interests."