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However, although we have engaged armed security, we are concerned that the legal and regulatory framework relating to arming private vessels is inadequate to respond to the threat.

As a threshold matter, we believe that the primary role in protecting U.S. flag vessels operating in pirate waters off East Africa is and should be the United States Navy and/or Coast Guard. For over two hundred years, owners operating under the U.S. flag sailed the world’s oceans secure in the knowledge that, in flying the American flag, we sailed under the protection of the United States Navy. Historically, the primary mission of the Navy has been the protection of U.S. merchant shipping, and we believe that that mission is as important today as it was when the Navy responded to the last major threat of piracy against our ships 200 years ago.

We recognize the size of the ocean subject to these attacks, and do not dispute the difficulty in attempting to deploy fleet assets to provide adequate protection off the east coast of Africa. Nevertheless, we believe that deploying armed military security teams aboard U.S. merchant flag ships is the most effective, and cost-effective, means of protecting our shipping, at least in the near term. There are not that many U.S. flag ships operating in the region. Military forces are trained to respond to the armed threat we are experiencing. Military security avoids regulatory shortfalls, liability concerns, and international reluctance to permit armed merchant vessels into their ports. We are not suggesting this as a permanent solution, but as a solution for the near and intermediate term as our government engages in broader solutions to the pirate problem, both afloat and ashore. As an aside, the protection afforded by our Navy or Coast Guard can serve as an added inducement to owners to register their ships under the U.S. flag.

That said, to the extent that the U.S. is not going to provide military armed riding crews, we need the government to address the legal and regulatory regime, both domestically and internationally, to permit us to adequately provide armed private security.

First, we would note that we are not advocating arming our crews. The job of our crew is to run the ship, and they do not have the training to assume the added responsibility of providing an


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