S3.E5 - Special Permission Applications and the FMC's Red Sea hearing

Topic of the Week (2/9/24):

The panelists at the FMC hearing spoke a lot about Special Permission Applications and approvals - what are they? Let's break it down.

The Maritime Professorᵀᴹ presents By Land and By Sea - an attorney breaking down the week in supply chain

with Lauren Beagen (Founder of The Maritime Professorᵀᴹ and Squall Strategies)

Let's dive in...

1 - The Federal Maritime Commission is still working through three rulemakings. No new movements.

2 - The INTERNATIONAL LONGSHOREMANS ASSOCIATION (ILA) is requiring local contracts be completed by May 17 before the Master Contract negotiation with UNITED STATES MARITIME ALLIANCE LIMITED (USMX) (current contract expires end of Sept 2024).

JOC.com article:
https://www.joc.com/article/ila-gives-chapters-mid-may-deadline-reach-agreement-local-issues_20240208.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%202%2F9%2F24%20NON-Subscriber_PC00000_e-production_E-166513_DS_0209_1117

3 - Rain on the way for Panama Canal??

gCaptain article:
https://gcaptain.com/end-of-el-nino-could-bring-relief-for-panama-canal-water-crisis/?subscriber=true&goal=0_f50174ef03-03ec5cc90a-170405670&mc_cid=03ec5cc90a&mc_eid=26e13788e2

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** As always the guidance here is general and for educational purposes only, it should not be construed to be legal advice and there is no attorney-client privilege created by this video. If you need an attorney, contact an attorney. **

#ByLandAndBySea

Transcript

Lauren Beagen: 0:57

If you watched the FMC hearing this week on the Red Sea, you undoubtedly heard the conversation around the special permission applications for adding surcharges on less than 30 days notice. Usually they require 30 days for rate changes, but did you know this was a thing, these special permission applications, and it's actually a permissible thing under the Shipping Act. We're going to break it down today. Hi, welcome to By Land and by Sea an attorney breaking down the weekend supply chain presented by the Maritime Professor Me. I'm Lauren Beagen, founder of the Maritime Professor and Squall Strategies, and I'm your favorite Maritime attorney. Join me every week as we walk through both ocean transport and surface transport topics in the wild world of supply chain. As always, the guidance here is general and for educational purposes only. It should not be construed to be legal advice and there is no attorney-client privilege created by this video or podcast. If you need an attorney, contact an attorney. So before we get into the discussion of the day, let's go through my top three stories of the week. Alright, story number one we're keeping it on.

Lauren Beagen: 2:01

As always, we're watching the FMC closely for the release of any movement on the three open rule makings. Still haven't seen much in a while. This week was the Red Sea hearing. The FMC actually said at the outset look, we are replacing our normal February FMC commission hearing with this Red Sea hearing. So we didn't get a lot of information out of what the FMC has been up to otherwise or any updates on any of the open rule makings. But again, just to remind you, we're looking at three different open rule makings defining unreasonable or feasible to deal with and negotiate with respect to vessel space accommodations Provided by an ocean common carrier. That last closed. The supplemental notice of proposed rulemaking closed July 2023. So last summer. We have the billing practices of detention to merge. That last closed a year ago, december. Hopefully that's coming soon. The industry keeps calling for it. It was brought up on the panel this week that they were looking for the final rulemaking there. Hopefully that comes out soon. Like I said last week, congress is even asking where is this? So we're waiting on the D&D rulemaking.

Lauren Beagen: 3:04

And the third rulemaking that we still haven't seen any independent language on is this defining unfair and just the discriminatory methods. This is the one that the FMC has said that they've included some of this language in that first rulemaking the defining unreasonable or feasible to deal or negotiate language rulemaking but they haven't created a standalone rulemaking. They said that there's still some issues that they want to tackle in this defining unfair or unjust, the discriminatory methods standalone rulemaking, but we haven't seen a first blush language on that in an independent sense. We're also looking at the federal, the maritime transportation data initiative. We haven't seen a second RFI round coming. It was. It was talked about that there might be another RFI round coming, but we haven't seen one yet. Still watching on. That maritime transportation data initiative came up a few times during the hearing too. I think that you should go take a look at this hearing. It was. It was pretty interesting. But that's it for the FMC. For the rulemaking, no new news here. I'm going to keep watching it.

Lauren Beagen: 4:03

All right, story number two. So we're starting to look at labor again this year the ILA and the US Maritime Alliance, the USMX. Their contract is set to expire this September 2024. Quite a while, quite a ways away. But as we've seen with some of these labor contracts, it's better to get started early. And so the ILA has actually said that its members will not work beyond a contract expiration, unlike the ILWU on the West Coast. We saw that they worked well beyond the contract expiration. Now the ILA, the International Longshore Association, they are the workforce essentially of the East Coast and the Gulf. So when the ILWU of the West Coast created their negotiation contract, that's different than the ILA on the East Coast the ILA, like I said, has said that its members will not work beyond a contract expiration. So even more reason why this needs to be concluded.

Lauren Beagen: 4:57

So JOC did an article on this this week. It looks, at least for now, promising that work is already being done here on these contract negotiations. It looks like the ILA has actually directed its local unions to complete their port level bargaining by May 17. And at that point the ILA and the US Maritime Alliance are going to start working or continuing working on, I would hope, working on settling on a master contract. So they have these port specific, port level bargaining with their local unions. That is important because that's part that goes into the overall discussion here, right, but then they're saying that needs to be concluded by May 17. That gives them almost five months of discussion time for a master contract. So look that five months might not seem like a lot, but since the ILWU and the Pacific Maritime Association didn't sit down until mid-May for their July 1 expiration date, I mean that was what? Two months, this is pretty promising. I like that people are starting to talk about this early. We'll see if this has any cargo diversion happening for it. For East Coast. I think with the easing of the Panama Canal that might be a factor here too of cargo returning back to the West Coast, certainly the ILWU concluding their negotiations and having a contract in place. We've already seen some diverting or repositioning of the cargo back to the West Coast where it was prior to the ILWU negotiations. So we'll see. We'll see if this has any effect, but we're going to be watching it. Something to pay attention to, all right.

Lauren Beagen: 6:31

Story number three G-Captain is reporting that the end of El Nino, which is a weather pattern partially related to the drought of the Panama Canal area could end by this April, june, kind of this spring 2024. Great news, and that's kind of why I brought up Panama on that last one. So apparently the National Weather Service Climate Prediction Center is predicting this with 79% probability. They're also predicting that with the moving away of El Nino or the ending of El Nino, that might be replaced by the La Nina weather pattern, which typically leads to higher rainfall levels. This was reported so previously we talked about the Panama Canal that they were planning to drop to 18 vessels by February 1st. That's down from their normal 36-ish days. They then changed that leading up to February and said that they would actually keep it up to 20. It appears that they've actually been allowing about 24 vessels daily and plan to maintain that level through at least the end of April. So if the rain comes, if the rain starts to fall in this area, the canal actually expects to return to normal levels of transit, which is awesome, which is the 36 vessels a day. So we've gone from 36 down to 24. Right now we haven't gone down to that 18, which is great. That's an extra six vessels a day, which makes a difference. So we'll see. We'll see what happens this spring. People are hopeful. I wanted to let you know people are hopeful.

Lauren Beagen: 7:55

I don't think this ever turned into a major deal, but this, paired with what was happening in the Suez, made it noteworthy and maybe something that, like I said a few episodes, maybe a month or two ago, to just start looking at contingency plans and and what happens when you, when things start to go awry in the, in the supply chain generally. But you know, it's funny with this talk of El Niño and La Nina. I don't know if this happens to you, but I remember it makes you remember the Saturday night live live episode, the one where Chris Farley dresses up as El Niño of the 90s. Anybody else? Think of that. It's funny how these comedy skits stick in your head. But what does he say? All tropical storms must bow before El Niño. And the one line that I remember is he said and for those of you who don'tablo espanol, el Niño is Spanish for and then kind of pauses, the Niño just thought that was funny. Well, hopefully, look, hopefully La Nina can bring some much needed relief to the area and help those lakes fill back up so normal shipping transits can return to the canal. All right with that let's get into the meat and potatoes of the day.

Lauren Beagen: 9:03

So we're talking about the FMC's informal hearing on the Red Sea and we're also talking a little bit about this special permission Application. So the Red Sea hearing happened on Wednesday of this week. We had some great panelists. It was really interesting conversations. At times it went to kind of general FMC Related issues. It edged into detention and demerge. But they were pretty good about bringing it back to the Red Sea specifically, since that's what the hearing subject matter was. But we had Sarah Gilmour of the Retail Industry Leaders Association. We had John Gold of the National Retail Federation. We had Peter Friedman of AgTC, agriculture Transportation Coalition and Laurie Felmer who was representing National Industrial Transportation League.

Lauren Beagen: 9:45

That was panel one. There were two shipper panels. So that was shipper panel one. Then we broke and we had the second panel, which was Mario Cordero, former chairman of the FMC, now the executive director of Port of Long Beach, joe Cremak, the director of government relations for the World Shipping Council. That was the carriers and ports panel. And then we had a separate second panel for shippers which was Tim Avanzado of Lanka sales. We had Eric Barch of US Dry Pain Lental Council. We had Eric Bayer of Alliance for Chemical Distribution. Ian Raulby of Iron Concilium. So Ian actually was just on the house print transportation and infrastructure hearing as well. He is what seems to be the expert in the region and certainly the expert on the Houthi conflict and kind of what's happening in the Middle East and in the region.

Lauren Beagen: 10:35

So some of my biggest takeaways from this and the recent TNI hearing of the Red Sea well, a few things really. Number one, though Appropriately so the carriers remain first and foremost focused on mariners safety. That comes through so clearly. I actually want to highlight that Bud Dar of MSC was on the house TNI hearing a few weeks ago, I believe it was, and he made that abundantly clear that mariners safety is of paramount importance. Look, that's great, right, and it should be. Our mariners rarely ever get the appreciation that they deserve for keeping the world literally turning and enabling the world's goods To get where they're going. And having a top executive of the largest container line say that mariners safety is the most important thing, that's great. I I really believe that's great. That needs to be. The focus here is that there are innocent mariners being attacked and and actually in Bud's hearing, some of the firefighting is not just a short thing. I think he set up to an hour, maybe two that it's. It's much longer than you might assume For some of these Misses that are happening even in transiting the Red Sea. So I just think that's great, that Mariners safety is truly the most important thing that's happening.

Lauren Beagen: 11:48

So my second takeaway from particularly the FMC hearing is that the Red Sea crisis is probably less of a crisis but rather Managed problem. That was my sense from the conversation. It's important to get the Suez canal back open and and the Red Sea certainly passable, but at least from the shippers on the person on the respective panels at the FMC, it seems that the disruption is just that a disruption, and not necessarily a pandemic level crisis. So this was noted by some of the panelists that this is, that this account is different from what the trade press might actually be reporting Recently, and that the doom and gloom is actually probably misplaced in the trade presses. Look, yes, this is a serious problem. That was. That was abundantly clear, and the fact that there's no end in sight is certainly concerning. But it really truly rang. I felt it. My interpretation of it was that it's not a pandemic level disruption, and not by a long shot.

Lauren Beagen: 12:43

So my final takeaway just kind of an overview of the hearing and one that we're actually going to drill down on a little bit more today is the special permission surcharges. My guess is that they're likely going to have more transparency for approval out of the FMC. The shippers repeatedly said that they wanted to know more about what went into these approvals, for these special permission approvals, and they even cited that some of the approvals were made within minutes of the submissions being posted, which they suggested made it seem not that maybe not much consideration was made for these approvals, like whether that's true or not. The FMC didn't exactly respond, but they said look the approval. The application went up on the website and minutes later you can see that the approval was also given. Perhaps that's when it was posted, but look it was, the point being that it was a pretty quick turnaround with not a lot of transparency.

Lauren Beagen: 13:35

So let's look at this special permissions process. So first, as always, let's go to the direct text of the law and build from there, right? So this is based on 46 CFR, section 520.14. This is special permission. So this is under the part 520 carrier automated tariffs. So section 520.14, special permissions.

Lauren Beagen: 13:58

This is something that Chairman Maffei actually talked about and brought up specifically in the hearing. So it says that under the Shipping Act, under 46 USC 40501E, it authorizes the commission, in its discretion and for good cause shown, to permit increases or decreases in rates or the issuance of new or initial rates on less than the statutory notice, and for the most part the statutory notice is 30 days. They also talk about controlled carrier rates, authorizing the commission to permit a controlled carrier's rates, charges, classifications, rules or regulations to become effective on less than 30 days notice. And the rule the reg goes on to state the commission may also, in its discretion and for good cause shown, permit departures from the requirements of this part. So this for a first little section. It says it's the general section. It says the commission, in its discretion and for good cause shown. So is that twice, but it doesn't give clarity on what good cause shown is.

Lauren Beagen: 14:58

The next section, subsection B, says clerical errors, typographical or other clerical areas constitute good cause for the exercise of special permission authority, but every application based there on must plainly specify the error and present clear evidence of its existence, together with a full statement of the attending circumstance, and shall be submitted with reasonable practice after publishing the defective tariff material. Okay so this is saying, look, you can do it on less than 30 days if it's a clerical error. But this gives some pretty good specifics on what needs to accompany a clerical error. Good cause, right, they're saying clerical errors, good cause. Every application must plainly specify the error, present clear evidence of its existence and together with a full statement of the attending circumstances, and shall be submitted with reasonable promptness. After publishing the defective tariff material. Okay. So they're saying, look, you can fix it. They're giving some pretty good specifics there. And I point that out because part of the problem, like I introed with, is that there isn't a lot of transparency on a general special permission. All they said in this reg is discretion is for the commission and for good cause shown. Clerical errors has some pretty good specificity there.

Lauren Beagen: 16:11

So, going under section C, the application applications for special permission to establish rate increases or decreases on less than statutory notice or for waiver of the provisions of this part shall be made by the common carrier, conference or agent for publishing. Every such application must be submitted to the Bureau of Trade Analysis and be accompanied by a filing fee of $394. Okay, so that's what they're saying. That's it. If you want to submit an application, do so Must be made by the common carrier, the conference or the agent, and it needs to be sent over to BTA Bureau of Trade Analysis and be accompanied by $394. So almost $400. Applications for special permission shall be made only by letter. Okay, that it has to be submitted in letter, except that in emergency situations application may be made by telephone or fax if the communication is promptly followed by a letter and the filing fee. So, depending on how high of an emergency this is, it has to be made by a letter or you can call it in. Okay, all right.

Lauren Beagen: 17:13

So this is applications for special permission. So applications for special permissions must contain the following information Okay, this is the specifics of what must be in this application the organization, name, number and trade name of the conference or carrier, the tariff number and title and, third, the rate, commodity or rules related to the application and the special circumstances which the applicant believes constitutes good cause to depart from the requirements of this part or to warrant a tariff change upon less than the statutory notice. So that's it. In the application you just have to say your name, your name, your number, your tariff name I mean administrative your tariff number and title. Also administrative, the rate that you want to be implementing the rate, commodity or rules related to the application. And then the special circumstance. And this is where I think the shippers were having a problem. It just says the special circumstance which the application believes constitutes good cause to depart. There's no real clear definition of what good cause is and they're saying you just need to state, not a lot. They're not even telling you everything that you need to state, they're just saying state the special circumstance that you believe constitutes this good cause. It's up to the applicant to make that lengthy or precise Implementation. The authority granted by the commission so, assumingly your application gets approved authority granted by the commission shall be used in its entirety, including the prompt publishing, the material for which permission was requested. So that's it. That's the whole section on special permission applications.

Lauren Beagen: 18:48

So let's take it a step out. Right? So the regulation is created by the FMC directly, right? So that's what we just read, based on the authority given in the Shipping Act. So this gets a little legal. But basically the statute is created by Congress that's the Shipping Act and the regulation that I just read is created by the agency, in this case the Federal Maritime Commission. So that regulation that I just read is their interpretation of what the Shipping Act says that they can do. Again, congress created the Shipping Act and gave the authority to the FMC. So if you go back, it referenced this in the very beginning of that FMC reg. If you go back, it talks about the Shipping Act.

Lauren Beagen: 19:27

And so under 46 US Code, section 40501, this is general rate and tariff requirements, subpart E is effective date and then subpart one of that is increases a new or initial rate or change in an existing rate that results in an increased cost to a shipper may not become effective earlier than 30 days after publication. Right? So this is that 30 days notice. However, for good cause, the FMC may allow the rate to become effective sooner. So the Shipping Act only says good cause. That's all they say, which is fine. Typically a reg might have more specificity, but not always, and that's what we see here. So the Shipping Act says good cause, the reg says good cause, that's the threshold, right? That's the test. Is this for good cause? But the good cause isn't necessarily defined. It also says for decreases, the change in an existing rate that results in a decreased cost to a shipper may become effective on publication. If you're going to lower the rates, the Shipping Act says by all means, by all means, please do, please lower those rates, all right. So that's the law, right? Those are the different sections. That's the statutory authority.

Lauren Beagen: 20:34

The second part we read, and the first part was the regulation from the commission itself and whenever they created that regulation based on the Shipping Act. So at one point Chairman Maffey said that just because it's approved does not dissolve the applicant of their duty to not engage in deceptive practices. So he basically said if this is just a way of hiding otherwise general rate increases, that's a deceptive practice. And he also reminded that the Federal Maritime Commission does not regulate rates, their rate levels, specifically. So Maffey asked the panelists so what? After they had said look, we want more transparency, we're interested in finding out more about how these applications are approved and what these rate increases actually mean. So he said, okay, well, what kinds of things do you want with respect to this clarity? And they said they want clarity on when this applies. Right, they want clarity on when the rate applies.

Lauren Beagen: 21:29

They said how they arrive at the numbers and what they're supposed to pay for. I mean, of course this is if the shippers could know everything about what's happening. So they said they want to know how the rate increase part of this application, what it's supposed to pay for, maybe like an itemized breakdown with fuel costs how much is going for fuel, how much is going for added services? What exactly is this going towards? Shippers are willing to pay and that seemed to be kind of a theme throughout that shippers are willing to pay as long as they know what they're paying for. They understand that this is a unique situation, that the Red Sea is a dangerous time, but they said transparency is one of those major concerns and the discrepancy of the rates between the carriers, they said, was also. They questioned that because they said this is obviously based on something. If there's discrepancy among the rates which actually Chairman Mfa made a pretty good point in saying, look, that's indicative of competition. If there's discrepancy among the rates that are listed in these special application, in these special permission applications, that's indicative of competition. So he said I'm not too worried about the discrepancy of the rates.

Lauren Beagen: 22:35

Another panelist said look, if cargo loaded on a ship that actually transited the Suez they wanted clarity on, would the charge? Would the special permission application charge. Would that charge still apply, because the whole reason was for the Suez, but now you're actually going through the Suez would the rate still apply? And at one point, at what point in time, would these charges come to an end? And so that was also being discussed, as there was no temporal element to these applications that are not required by the regulations, right, that's what they're saying is that at what point in time does the emergency end and the application approval be rescinded or extinguished? They said an acute emergency. Sure, they understand that, but a lack of communication for the need for these is what they were asking for. So that's what the shippers were asking for.

Lauren Beagen: 23:26

The ragging question like we were talking about was the 46 CFR 520.14. And Chairman Maffey stated that first part about it. He talked about the good cause. He said may charge less than 30 days under special conditions for good cause. He also added that approving special permissions does not eliminate the FMC's ability to investigate for deceptive practices or really any other shipping act violations that might be part of all that. He also added you can't just up a fee on a cargo that's already gone, and I thought that that was kind of an interesting thing as well, saying that I don't know. It was just an interesting piece to add that you can't just up a fee on a cargo that's already gone. But the approving special permissions does not eliminate the FMC's ability to investigate was also an important piece to be made and I think helped the shippers at least by saying the FMC's still watching, right, this doesn't extinguish the FMC's ability and responsibility to watch the overall shipping act requirements. And so one of the panelists said some of the surcharges are not just limited to directly affected cargo and they said that we're actually seeing and this was from one of the panelists saying that they're actually seeing it on other lanes as well. Now, perhaps that's a problem, but with the FMC chairman Maffay saying that this does not extinguish their ability to look at all the different things that are happening, he said the FMC has the authority to also examine that right If any of this is going into other lanes. But that's not necessarily not permitted, right, and that's part of the problem with the general nature of the exchange of the application and the approval is that some of these fine points aren't exactly clear.

Lauren Beagen: 25:14

So I wanted to go look at the e-reading room of the FMC. This is where kind of all of this documentation is housed, and there's actually multiple special permissions in there. Unsurprisingly, most of them came in recently, but they're not only based on the Suez. There's some special permissions from October relating to the war in Israel. Zim at the time asked to assess a $100 charge per TEO as a war risk surcharge, and this is all public. You can look at this in the e-reading room. That's where I'm getting any of this information.

Lauren Beagen: 25:44

In 2020, though, I found it notable that this special permission application wasn't actually often used. None of the major carriers seemed to have requested an emergency special permission at that time. Okay, that's fine, but now we're seeing quite a few around the Suez, and there was only what looked like maybe one related to the Panama Canal drought, but there seems to have been what looks like about eight requests for Red Sea surcharge variances, so that's a pretty big increase. In some of the applications, there was associated justification also submitted, and so not all of them, but certainly it wasn't necessarily required, but at least one attached an email from an underwriter saying that they required additional premiums for this route, so that's justification, but most didn't have much other than saying what they wanted to do and the basic reason why.

Lauren Beagen: 26:34

So, like Red Sea dangers, et cetera, and according to the rags right, none of this is wrong or incorrect, and I'm not actually suggesting that any of this is wrong either. I'm just kind of highlighting. I wanted to explain what was happening and explain what the shippers were talking about, what the FMC was talking about and really kind of the general nature of this overall process. That's in the rags. But the shippers I do think that the shippers maybe made a good point about the transparency, but as of right now, it's not required. So if the FMC really wants to take this up and like I bet that they will I think that this is gonna be something that they wanna look into and I'm assuming, I'm guessing, they'll probably throw it into a rule making format at some point, because if they wanna amend their reg, that's a rule making right, that's an amendment to a rule, that's a rule making process.

Lauren Beagen: 27:22

They're ultimately, the FMC is ultimately gonna be faced with really balancing the need for transparency which these are pretty good arguments made on why the transparency isn't currently there and what the shippers are requesting through these limited number of panelists that were representative of different shipping interests. But they also need to balance the need for expediency and speed, right. So the very nature of this special permission application is for assumedly fast approval, right? Fast in the sense that 30 days is too long for the change to take place. So anybody can change their rates. Well, not anybody. In general, you can change your rates on 30 days notice, and so this special permission application allows less than 30 days. Okay, so that's what they're saying is we need less than 30 days notice to make this change, so there's an element of expediency.

Lauren Beagen: 28:14

So if a government agency does a deep dive, right? So let's say that they want to change the transparency, they want to change the review process. I mean, maybe we're talking about two weeks right there of just a government agency, especially if we had a multiple come in all at once, because, assuming if it's an emergency, you're going to have multiple applications filed all at the same time. That could potentially take a while, and hopefully that a while is less than 30 days, right? So I mean, let's say, for argument's sake, that might be two weeks. That's not always going to be true, right? I think that there could be a mild increase in approval criteria and not have it slide into a two week approval, even if everybody files at the same time, because, right, that's the nature of an emergency. If multiple carriers are going through the same route and they're all having the same emergency happen at the same time, you're going to expect that there's going to be multiple applications submitted all at the same time.

Lauren Beagen: 29:07

So it needs to be a balance of, perhaps, transparency, perhaps maybe a little bit more specificity, and I think this is what might be introduced in a rulemaking, should the FMC decide to go this way. But I think that it needs to be balanced because there also needs to be expediency, for that, if we get eight to 10 applications all at the same time, you can do a review. That's not just a blanket approval, you can do a review. That's also fast, and I think that's really the crux here. Perhaps the FMC also could build something in that checks them where they're required to submit a determination within four to eight hours of receipt, not including weekends, right, or maybe even a one week turnaround, because we're also talking about clerical errors too, and that's something that is important to keep in mind. Clerical errors should be maybe quicker to review, right. Maybe little to no review for a clerical error approval, but some of these larger geopolitical emergencies or pandemic level emergencies. Had this been used at that time? Maybe that's going to require a little bit more review. I don't know. This is interesting. I don't think anybody had review of special permissions on their bingo card for the FMC this year. But look, here we are and I just want to give you a little bit of an overview of it, just a little snapshot of what they were talking about in the hearing this week, what the rule and the reg actually say and where we might go from here.

Lauren Beagen: 30:38

But, as always, the guidance here is general and for educational purposes. It should not be construed to be legal advice directly related to your matter. If you need an attorney, contact an attorney, but if you have specific legal questions, feel free to reach out to me at my legal Squall, Strategies. Otherwise, for the non-legal questions, the e-learning and general industry information and insights, come find me at the Maritime Professor. If you like these videos, let me know, comment, like and share. If you want to listen to these episodes on demand or if you missed any previous episodes, check out the podcast by Land and by Sea. If you prefer to see the video, they live on my YouTube page by Land and by Sea, presented by the Maritime Professor. And while you're at it, check out the website at TheMaritimeProfessor. com. So until next week, this is Lauren Beagen, The Maritime Professor, and you've just listened to by Land and by Sea. See you next time.