Whenever someone says a certain sum of money is “trivial,” we should ask, “For whom?”
True, $26 does not sound like a lot of money. Heck, smokers in Florida can’t even buy a carton of Marlboros for that. The point is, unless you are the type of person who uses greenbacks to light tobacco products, when someone asks you to give up $26 you probably expect assurance that you will be receiving $26 in products or services in return or that the money is going to a good cause. Otherwise you would be judged a fool.
Until now, the Coast Guard has charged fees for a number of services related to federal vessel documentation, but routine renewals have been free. In March, the Coast Guard proposed a $26 renewal fee in an effort to raise the $6.1 million it spends processing those renewals.
Does the Coast Guard proposal stand up to the value-received or charitable-contribution standards outlined above? The public comment period ended May 3 and — as you might expect — the vast majority of the more than 1,300 respondents were against an annual documentation fee. The surprising thing was not the degree of opposition, but how thoughtful some of the comments really were.
Let’s review the bidding.
To be fair, a few supported the fee outright, either because they considered the amount trivial or because the Coast Guard is a worthy organization — or both. “I say charge 50 bucks. It is the cost of having fun and being protected by the best agency in the U.S. government,” wrote Dr. Henry “Skip” Lenz.
But among those favoring the fees, many qualified their support, saying they wanted to ensure the money was not siphoned to non-Coast Guard purposes by some bureaucratic shell game. David Berkel’s remarks were typical:
“I am a big supporter of the Coast Guard, so I don’t mind them getting a few extra bucks. They perform an extremely critical and much appreciated function. However, if the fees go into some kind of general fund where the politicians can get their hands on it to buy votes with, then I greatly oppose it. Put the fees in a lockbox labeled: “HANDS OFF! COAST GUARD ONLY.”
I checked my own boat’s documentation today and saw that since I bought her I had renewed my certificate 13 times. Each time, I filled out the form, put the form in the U.S. mail and received a certificate exactly the same as the one before, except for the expiration date.
My history is exactly like that of William Parke, who wrote:
“Instead of charging $26 a year for a new Documentation Certificate, why not stop issuing them yearly but rather charge a fee for a change, should that occur. When I bought my boat it was documented. I now have 13 certificates, all the same. If you can’t take this suggestion, please send me the form to de-document my vessel.”
Parke’s idea has precedent in the vehicle and vessel title system of many states. Once issued, a title stays in force until a change is made. Only then would a fee be charged. Similarly, many of Parke’s fellow boaters suggested that the Coast Guard could save time, money and effort by simply issuing documentation for multiyear periods rather than annually. Many respondents suggested five years — some even said that under those circumstances they would be OK with paying the fee.
“The proposed fee is reasonable for a five-year period. Is there a reason why the renewals cannot be for multiple years? This fee increase will not hurt the big-boat owners or the small-boat owners who are not documented, but it will add to the multiple fees that us boaters who are struggling to afford keeping our boats will have to deal with,” wrote Peggy Frazier.
Apparently Ms. Frazier represents those for whom $26 is not necessarily trivial, once added to dockage, insurance premiums, fuel costs, taxes and other fees boaters face.
Another cost-saving suggestion was to allow boaters to renew their documentation certificates online and print them at home or aboard their boats. For a couple of respondents, this was even more important than the fee. Keith Patterson was one of them:
“I don’t mind the fee and believe it’s a fair amount. But lots of us out here actually — you know, using our boats and sailing in places like the Caribbean and Mexico — have a tremendous problem getting the renewals done and getting a physical copy of the document, which is required in many marinas out there. When you move around, getting physical copies of documents can be very problematic. … Please make it possible to do all this ONLINE (not mail or scan and fax everything … make it a true online process. … C’mon, this is the 21st century for cryin’ out loud).”
Two boating groups with Washington lobbying arms, BoatUS and the National Marine Manufacturers Association, also logged comments. Interestingly, they split on the issue, with BoatUS against and the NMMA in favor.
BoatUS, which has more than a half-million members, opposed an annual fee and made some of the same suggestions that individual opponents did. BoatUS officials wrote:
“In our view, the Coast Guard should take a step back and re-evaluate the efficiency and technology currently utilized in processing initial vessel documentation applications and renewals. For example, the Coast Guard should strongly consider changing the one-year vessel documentation period and instead move to a two-, three- or perhaps even a five-year period.”
Like Patterson, BoatUS also criticized the Document Center’s technological backwardness. “Moving the vessel documentation process online is a logical step toward reducing the cost and inconvenience of this program. Given the large number of federal, state and local governmental transactions that are now securely conducted online, it is surprising that vessel documentation has not yet done so.”
So it’s a little perplexing that the National Marine Manufacturers Association, representing 1,400 members in the marine industry, is supporting the idea of a new fee. The NMMA’s comments were a mushy kind of mom-and-apple-pie argument about how documentation is good because it deters fraud and terrorism and how backlogs in issuing renewals are bad because they prevent boat buyers from getting out on the water right away.
To be fair, the NMMA also thinks online renewals are a good idea, but its statement never entertained the simple idea of multiyear renewals.
There is the fact that the NMMA relies, in part, on documentation data to publish its annual Boat Registration Report and Statistical Abstract, which it sells to non-members for $600. But it is difficult to see how the repeated reissuance of unchanged document certificates adds value to this enterprise, although perhaps it does. Maybe the NMMA would care to enlighten us.
Meanwhile, in case I have given short shrift to its position, you can read the organization’s comments in their entirety here.
If we must pay a new fee, I agree with those who say the Coast Guard should find a way to give us better value for our money. And I also agree with those who argue that the Coast Guard is a worthy organization, but it is not a charity case. Any additional money we send the Coast Guard would be better spent on search and rescue than processing unnecessary paperwork in West Virginia.
Till next time.