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Federal Register / Vol. 86, No. 164 / Friday, August 27, 2021 / Proposed Rules
Year
1 2
3 4
5 6
7 8
9 10
Total Average
Un discounted Industry Cost Savings a t
Un discounted Government Cost Savings b t
Un discounted Total Cost Savings c 1 = at +
b t
Discounted 7%

Discounted 3%

-

-

-

-

-

$37,945
$37 763
$37,583

$28,595
$28.459
$28,322

$66,541
$66.222
$65,905

$54,317
$50 520
$46,989

$60,894
$58.837
$56,850

-

-

-

-

-

$37 046
$36 868
$36,692

$27,918
$27.784
$27,651

$64,963
$64.652
$64,343

$37 809
$35 167
$32,709

$51,283
$49.551
$47,877

$223,897
$37,316

$168,729
$28,121

$392,626
$65,438

$257,511
$42,918

$325,292
$54,215

$36,664

$38,134

Annualization
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Benefits There are quantifiable benefits to this proposed rule. However, they are the cost savings accounted for above, including savings to mariners from less frequent submissions of medical certificate applications. This would subsequently reduce the NMCs workload and generate government cost savings.
In addition, there are unquantifiable benefits for some FCPs because they would be less likely to have a lapse in a medical certification due to the less frequent submission requirement. The Coast Guard does not have data to quantify the savings this would produce for this small percentage of affected FCPs, but we are aware that it may happen. For these pilots, economic losses occur when a current medical certificate expires prior to the time that a new medical certificate is approved and issued. Such circumstances can occur if the mariner has a complex medical history that requires frequent or prolonged correspondence between the mariners medical practitioner and the NMC. This lapse in medical certification can have significant costs for both individual pilots and for employers, because pilots cannot work under the
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authority of their credential without a valid medical certificate. By establishing the proposed 5-year medical certificate for pilots, instead of the current 2-year medical certificate, the likelihood of such lapses would decrease, would ensure that they do not incur additional medical exam costs, and would also be a mitigating factor against a potential loss of income.
Alternatives When analyzing alternatives, we considered two factors: the period of validity of the medical certificate for FCPs; and the requirement to submit physical examination results to the Coast Guard. Under current regulations, the period of validity of the medical certificate is 2 years for FCPs, and the submission of physical examination results is correspondingly every other year, unless the medical certificate contains a waiver requiring more frequent submission of the physical examination results.
Alternative 1. The first alternative we considered in this analysis was retaining the status quo, under which FCPs would continue to apply for their medical certificates every other year.
The status quo would also continue to require FCPs to report their physical
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examination results every other year, unless their medical certificate contains a waiver requiring more frequent submission. As discussed previously, we estimated the opportunity cost of retaining the status quo at $36,664, annualized at 7 percent, or an undiscounted total of $257,511 over a 10-year period of analysis. We rejected this alternative. Although there would be no additional costs to mariners or the government, there would also be no cost savings.
Alternative 2. The second alternative we considered was extending the maximum period of validity of medical certifications to 5 years without interim self-reporting requirements, which would require mariners to submit the results of their medical examination to the Coast Guard if they no longer meet the medical standards. FCPs would only submit the results of the physical examination every 5 years with a medical certificate application, unless their medical certificate contains a waiver and requires more frequent submission. We rejected this alternative.
The Coast Guard finds the potential for increased risk from mariners with underlying health issues operating as FCPs, and not self-reporting medical or health conditions that may impact their
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Table 11. Total Estimated Costs Savings of NPRM over a 10-year Period of Analysis in $2020 Using 7- Percent and 3-Percent Discount Rates