Cargo First: A Maritime Strategy Conversation

Cargo drives fleets. Fleets sustain mariners. And if we’re serious about maritime dominance, commercial cargo has to be part of the strategy. This week I wanted to connect a few threads that illustrate how the day-to-day mechanics of ocean shipping and the long-term future of the U.S. maritime system are unfolding at the same time.

I start with the D.C. Circuit decision in World Shipping Council v. Federal Maritime Commission, which upheld the FMC’s rule defining “unreasonable refusal to deal or negotiate” under the Shipping Act. We walk through the statutory background, the role of OSRA 2022, and how the rule frames the totality-of-the-circumstances test the Commission can use when evaluating vessel space disputes. That includes the controversial documented export policy requirement and the debate over whether quoting an extremely high rate can function as a refusal to negotiate without crossing into rate regulation.

Then I zoom out and offer what I jokingly call a “maritime strategy addendum from The Maritime Professor.” After reviewing the recent maritime policy conversations in Washington, I walk through a few pillars that I think deserve more attention in the national discussion. Commercial cargo needs to remain central to maritime strategy. Shipping policy can’t assume everything moves in containers when bulk and breakbulk cargo still dominate major commodity flows. Market incentives may be necessary if we want cargo to consistently move on U.S.-flag vessels. And if shipbuilding capacity is going to expand, we need to be realistic about the scale of investment required to move beyond incremental programs.

Finally, I reflect on witnessing the transfer of Maine Maritime Academy’s new National Security Multi-Mission Vessel. These ships are designed to replace aging training vessels at the state maritime academies, but they also highlight a bigger reality: none of these maritime strategies work without mariners. Training ships are floating classrooms, and workforce development remains one of the most important long-term investments the industry can make.

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(Cont.) Cargo First: A Maritime Strategy Conversation

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If you want maritime dominance, you have to start with cargo, right? Cargo is what drives the maritime system. It determines where the ships sail and whether fleets grow or disappear. So my point is a commercial shipping has to be part of the strategy. We're going to talk a lot more about that today. Hi, welcome back to By Land and By Sea, an attorney breaking down the weekend supply chain, presented by the Maritime Professor Me. I'm Lauren Beegan, founder of Maritime Professor, former FMC International Affairs Attorney, and founder of School Strategies. By Land and By Sea is your go-to resource for navigating the regulatory side of global ocean shipping. And me, well, I'm your favorite maritime attorney, aren't I? As always, this podcast for educational purposes only and should not be considered legal advice. There is no attorney client privilege created by this video or this podcast. If you need an attorney, contact an attorney. So let's get into it because as you know, ocean shipping moves the world. All right, well, let's jump right into it. I'd like to take us to our first segment. DC Circuit upholds FMC's rule on unreasonable refusal to deal. So let's start the week with the decision out of the U.S. Court of Appeals for the DC Circuit. Now, this is one that we've been waiting on. Now, if you follow this show, this podcast, we've been talking about these appeals on these regs, final rules that the FMC put out. This is the one about unreasonable refusal to deal or negotiate. We've been following this, I think it was about a year ago, just under a year ago, that we last visited this case, this appeal. Now, this is the case, the World Shipping Council versus the Federal Maritime Commission. And ultimately the court upheld the FMC's rules and some of the things within it. Now, this is defining what counts as unreasonable refusal to deal or negotiate when it comes to vessel space. Now, recall, this is the one that talks about the documented export strategy. This is the one that talks about rates being so high that they are clearly, you know, unreasonable refusal to deal. This one, honestly, I thought for sure was going to have some parts overturned. I thought the documented export strategy, while I could see the justification, but the filing with the FMC every year on this documented export strategy, honestly, I thought that this one probably was going to get knocked down. Overall, I thought that the court would side with the FMC saying it was going to be totality of the circumstances that they're reviewing. But some of these specific directed things, I thought I don't, I don't see the court going with them. Well, I was wrong, I guess. So, what are we talking about? Let's give a little bit of a background here, right? So, this is the shipping act itself. So, under the shipping act, a common carrier may not unreasonably refuse to deal or negotiate, including with respect to vessel space accommodations provided by an ocean common carrier. Now, this is something that came up in Osra 22. Congress had a lot of people reaching out to them during this Ocean Shipping Reform Act of 2022 that wanted specifics on unreasonable refusal to deal or negotiate because a lot of exporters were getting turned away. And so they went to Congress and they said, Can you fix this for us? And so originally when the Ocean Shipping Reform Act of 2022, when it was first kind of being discussed during 2020, 2021, there was a lot of discussion about exports. So I wasn't surprised to see the unreasonable refusal to deal or negotiate was included as part of the things that came out of Osra. One of the things that Osra did, though, is it directed the FMC to write a rule actually defining what this unreasonable refusal to deal or negotiate means in practice. So they did. So they put it into a reg, right? So if it comes from Congress, it's a statute. Once the FMC gets a hold of it and translates it into a law, it becomes a regulation. So you can pass law school now, right? Statute versus regulation. But the statute is the shipping act, comes from Congress, and then the FMC basically translates that and puts that into kind of what it means in practice. So they did that. They came up with the final rule on unreasonable for deal and negotiate, focusing specifically on containerized cargo and ocean common carriers, right? That's what they do, that's what the FMC regulates for the most part. Although there are some arguments that they regulate other industries or that their authority can expand beyond just containerized cargo, but that's an episode for another day. What we're talking about here is this unreasonable fruits to deal and negotiate with respect to liner trades, containerized cargo movement. So the rule lays out the elements of a claim and defines unreasonable as carrier conduct that undoubtedly restricts the ability of shippers to meaningfully access ocean carriage services. Now, importantly, the FMC didn't make a bright line test, right? We often talk about that. The FMC doesn't necessarily make hard line pieces. They would rather work out the specifics in case law. So we've often seen them take the approach of a guardrails approach. I think that this one was no different, right? They said the rule provides factors that the FMC may consider when reviewing unreasonable refusal to deal and negotiate. So this is what they put in their final rule, right? They said that they consider whether the carrier followed a documented export policy, whether the carrier engaged in good faith negotiation, whether the refusal was based on legitimate transportation factors. Now it was that documented export policy piece that I've often talked about when I would bring up this case. Under the final rule that the FMC put out, ocean carriers were required to file a written export policy with the FMC each year, describing how they handle U.S. export cargo. Now, I'm still not quite sure how it sits with me, but you know, if the court said it was fine, the court said it was fine. But they have to file a written export policy annually and updated annually. So they have to basically say what they are information such as pricing strategies, services offered, equipment provisioning, market served. Now it's not even like very specific on what needs to be included in there, but this written export policy. And I think the intention here really is so that if you just don't do a certain trade lane or you don't do a certain commodity, or there's some sort of operational reason, or there's some sort of piece of what you do or don't do in exports, if you can get it written into an export policy, it can kind of be a little bit of, I guess let's call it an insurance policy, right? So that way if you do refuse cargo for some reason, you could say, well, look, FMC, we put it in our export policy. This is just something we don't do. We don't service this particular commodity or we don't service this particular trade lane, you know, whatever it is. Maybe we we don't usually there might be an operational piece to it, but for whatever the reason, maybe it's not in your pricing strategy, maybe it's not in your overall books, maybe it's just not a priority cargo. There I there might be a million different reasons why it might be something that you don't want to include in your export policy, but this is what the FMC kind of takes in a different way, is giving you the opportunity to put in writing and give to the FMC. Now, I believe that these are private, these are not public documents, these are just filed with the FMC privately, not publicly disclosed. And so the FMC can use this as part of their determination, right? They can look at specific dispute that comes in front of them and say, did the carrier follow its own documented export policy when making this decision? Now, the other part of the rule that received attention was about pricing, right? And this is where a lot of conversations with the FMC have to be so careful because the FMC doesn't set prices. They set and they talk about the unreasonableness of prices. And so it's a nuance. But the FMC doesn't actually review prices specifically, and that was part of the petition against this, because the regulation, the final rule notes that conduct may be unreasonable if a carrier quotes a rate so far above market levels, then it cannot reasonably be considered a good faith offer to negotiate. So if everybody else is offering 2,000 bucks and somebody comes back with$2 million, we'll take it if you pay it. That's kind of the essence of what they were getting to, right? Is like, look, that's so unreasonable that clearly you didn't want to do that, but you didn't want to say you weren't going to take their cargo, so you just price them out at an outrageous level. Now, of course, that's an easy example, right? 2,000 to 2 million, totally disparate, totally different rates. But what about if everybody's 2,000 and somebody comes back with 1,500 or 5, sorry, excuse me, 15,000? Is that so far above market levels that it cannot reasonably be considered? Now that's where the concern kind of comes into it, right? FMC doesn't set rates. Now, this is just supposed to go into their totality of the circumstances, the things that they're going to be reviewing. And so I think that's what the court was getting behind here. And through some of their discussion, that's what they were saying is that it's not just about a rate so far above market levels that it cannot reasonably be considered. It's the totality. And if also there's a rate that's so wildly high that it just kind of seals the deal of like this was you guys were, this was unreasonable, this was unreasonable, refusing to deal or negotiate, then it comes into it. However, it really is kind of a very sensitive area, right? And that's what was being petitioned here, challenging the language, arguing that it could turn into an indirect right rate regulation. And I don't think we want government agencies setting the rates. I think we want them staying in the guardrails area of watching, reviewing, and making sure that it's fair and efficient and reasonable, but not setting the specific rates, right? The court explained that the FMC is not setting rates. Instead, it is allowed to consider whether a rate quote is so extreme that it effectively functioned as a refusal, right? And that's kind of what I'm just saying. In other words, quoting a price that no one could realistically accept could be treated the same as simply refusing to deal. The FMC framework of this final rule survived the judicial review. The rule defining unreasonable refusal to deal does remain in place. And so does the requirement that carriers file a documented export policy with the commission. I'm surprised on this one, but you know what? I can see the justification behind it, and I think that's part of it, is that they really want to make sure that it's part of the totality of the circumstances, that it's part of the entire thing that they're looking at. So I thought that this was an interesting discussion. I thought that the court did a really good job of looking at it. And I really like that this one remains with the intention that these refusal to deal cases will continue to be evaluated on a case-by-case basis under the totality of the circumstances, including negotiations, operational realities, and the carrier's own export policies. But interesting, right? Interesting. So the other one that we're we're still waiting to hear on is detention demerge, the final rule on detention demerge. There was a petition against that. Let's see what the court comes up with for that one. But for this unreasonable refusal deal, the FMC, they they came away with some W's here. But yeah, we'll see. Now let's see how it looks in case law. That's where we really get some specifics about how the FMC will be reviewing this. So stay tuned. All right, segment number two. Now, this one is a little bit outside of where I usually talk about. Well, I guess not so much. I've been talking a lot about the maritime dominance and, you know, the intention to have more of a robust maritime presence in out of the US. After giving some of the recent reports a thought, you know, we talked about CNA, the Center for Naval Analysis, Maritime Strategy Report, and the Maritime Action Plan. You know, I did a live coverage of that with Caitlin Hardy. We we went over it kind of section by section. And in a very real, I think it was a half hour after it had been published, we were like, let's just react to it. So we did. You know, as I've been giving the whole thing a little bit more thought, I still have some areas that I think aren't being captured with enough attention. So it got me thinking, maybe, maybe, if it's not too bold, maybe I should present my own roadmap to maritime dominance or maritime strategy according to the maritime professor. So look, these are just some of my thoughts. Who knows? Maybe I'll put these together into a detailed report just to add it to the conversation. Maybe it'll be the maritime strategy according to the maritime professor report, or I don't know. I I was just kind of thinking about it this week. How do I, how do I get some of my thoughts out there beyond just this podcast, which I'm so appreciative for all of you who listen and stick with me on this? But look, if we're serious about maritime dominance, the conversation has to expand a bit because so much of national maritime discussion is focused on military readiness. And it has to be, and that absolutely matters. And I do see a change in this administration and those who are leading on the maritime side with the intention of having a commercial part of the conversation, but it's gotta be throughout, it's gotta be in all of our documents, it's gotta be in the way that we all talk about it. And so while I love to see the budget come out with giant numbers for ships on order, and it has to be maritime or military, it has to be military, it has to, but we need to have more commercial shipping as part of that too. Ships follow cargo, mariners follow ships, and if we're serious about maritime dominance, commercial cargo has to be part of the foundation. Now, if I may, let me offer a few pillars that I think should be part of this conversation. Commercial cargo must be central to maritime strategy. Again, if we really are serious, and I trust that we are, I know that we are. I'm excited that we are, and I love things that I'm hearing from this administration. I was just up in Maine a few weeks ago and I heard Sang Yi give a lot of give some remarks about the state of Maine and and the receiving of the new vessel for Maine Maritime Academy, the deputy maritime administrator Sang Yi, and he did such a great job of capturing, we have to keep focused on cargo. And I'm saying that now. The conversation has to keep focused on cargo. A maritime strategy cannot focus only on a maritime on a military sea lift because commercial shipping is what sustains the maritime ecosystem over the long term. And arguably, I'd say that's why we are where we are, because we let the commercial side go. Military operations rely on surge capacity and contingency planning, but commercial shipping is what keeps these vessels operating day in and day out and makes them viable so that we can support the uplift when we need it. It's a commercial cargo market that supports ship operations, creates stable career pathways for mariners, creates reliability in repair and repair yards, ship repair yards. It keeps port infrastructure economically viable without those cargo flows moving regularly through the system and with that U.S. flag, right? Because it's not a question. Do we have commercial cargo movement? Of course, obviously we do. I wouldn't have a show if we weren't talking about commercial cargo, ocean shipping. The US has to be part of that. Without these US flows moving through the system, the rest of the maritime ecosystem becomes much harder to sustain from a US perspective. So when we talk about the maritime strategy, commercial cargo cannot be treated as a secondary consideration. It has to be part of the foundation of the strategy itself. It just has to. And while we're talking about commercial shipping, I'd also like to offer as a second pillar here, commercial shipping is not just containers. That's a piece that often gets lost, I think, in the conversation. I've seen it in a few different realms. When people talk about commercial shipping, I do the same. We tend to picture container ships. Containers dominate supply chain domination, discussion, excuse me. Containers dominate supply chain discussion. So it's easy to assume that containerized cargo represents the bulk of globe global shipping activity. But a significant portion of US trade actually moves outside the container system entirely. Bulk and breakbolt cargo still represent major components of global trade. And think about commodities, especially prioritized commodities in the U.S. We've heard a lot about this. If we're going to increase our exports, things like grain, soybeans, fertilizer, steel, forest products, energy cargo. When soybeans leave the Gulf headed for Asia, that cargo is not moving necessarily in containers. It might be moving a bulk or break bulk. And much of that trade today moves on foreign-built vessels, many of them Chinese-built vessels, simply because that's a structure of the current global fleet. So again, while the US is exploring policies aimed at strengthening maritime capacity, we have to be careful not to inadvertently disrupt the movement of those commodities. The example that I'm thinking of when I think of these kind of bulk or break bulk is when we had the USCR port fees announced, one thing that became very clear to me, I went to the Women in Agribusiness conference over this over the fall. One thing that became very clear to me is that there was almost no way that imports of bulk or imports of grain or imports of these commodities were not going to be hit. There wasn't a modification on kind of a larger scheme that could be made to avoid that fee, even though it might be a commodity that we're prioritizing to come in, only because the vessels that move it were tramper vessels, so not on a liner trade, but also vessels, so more of a likelihood that they wouldn't actually be coming to the US with the tramper reference. But then also that we didn't have non-Chinese built vessels that could be used for those. And many of these markets operate on extremely thin margins. And so having these port fees, which I think that the port fees were serving the purpose that they were set out to serve. And actually they're paused now, anyways, right? Because we have our China deal. But it's something that we need to be careful of. And if we are in such a bad place with the bulk and the brake bulk that we don't have non-Chinese vessels to serve these markets, maybe we should also be building in bulk and brake bulk into our shipbuilding plans, right? Commercial cargo, of course, we're talking containerized cargo, but we should also be talking about US builds of bulk and brake bulk. Because we have to, because this is going to be affecting our American exporters in the ag world and in the importers too for the ag world. And just anybody who's moving goods on US on with US goods for exports or imports that might be using brake bulk or bulk. All right, pillar number three, market incentives for U.S. flags. So policies alone aren't just going to sustain our maritime industry. Ships need that cargo, right? So how do we get that cargo? We're talking about commercial cargo and how it needs to stay a priority and a foundation to the discussion. How do we create conditions where cargo actually moves on U.S. flag? I've talked about this many times before, but because I'm putting together my addendum to the discussion presented by the maritime professor, one idea worth exploring is targeted market incentives, right? Importers could receive tariff waivers or similar benefits when cargo moves on U.S. flag vessels, right? Why not? Why not? Importers, whether it is high value or heavy, are probably getting hit somehow with a tariff. If you were to say we would waive that tariff or maybe even have a tax incentive, I bet you, I bet you that the US flag demand would go up. And maybe we're not quite ready for that, but I do think that it needs to stay part of the conversation, mostly because we don't have enough U.S. flags to serve that industry. But it might also be a good problem to have, right? We need to be making that market driver so that way we can have support of the U.S. flag system. Perhaps exporters could receive tax incentives or fee reductions when their cargo moves on U.S. flag vessels as well. Like the goal really would be to create economic drivers, incentives, not just cash, not just stipends, not just money that goes toward it, but economic drivers that make U.S. flag shipping more competitive and more of the choice, the chosen choice. Because if cargo begins moving consistently on US flag vessels, that creates demand for ships, right? That's what I'm saying, right? We would have, we potentially would have a problem that we wouldn't have enough US flag. What a wonderful market driver to get more vessels going. And if ships are sailing regularly, that supports stable employment for mariners as well. And maybe we have some kind of gap insurance, right? Gap coverage. Maybe we even negotiate, and this is something that I liked coming out of the Center for Naval Analysis report that maybe we find a way. They they had it in respect of if we needed to uplift on vessels, maybe we work with partner countries and have kind of a contingency agreement with partner countries. I'm going to Take that a step further. Maybe we have contingency agreements with private ocean carriers. So that way, if we did do incentives for cargo to move on U.S. flags, we could actually perhaps uplift and maybe there was an incentive to bring U.S. flag or reflag some of the vessels into U.S. flag. There are probably ways that we could have vessels that are out there be brought over. Well, also I want to be very careful here because I'm not suggesting that we totally abandon Jones Act because right now there is uh there is some sensitivity there, and I totally understand. But if we need more vessels, right, they don't just get built in a day. If we need something to hold us over, we just need a fleet, right? We need a much larger fleet than what we have. And so I think it's going to be chicken or the egg for a few different things, for mariners, for cargo, for the actual vessels themselves, and also for the port's ability to handle all of this. But I'll get to that in a minute. My next pillar is shipbuilding realism. Rebuilding the U.S. shipbuilding base is clearly part of the maritime strategy, but it's also important to recognize the scale of what that would require, right? Programs like the small shipyard grant program are helpful. They are helpful. But the scale of those programs is actually nowhere near what's necessary to rebuild large-scale commercial shipbuilding capacity, even at small shipyards. Shipbuilding is an industrial effort measured in years and decades, which means maritime strategy may need to consider more large injections into the small shipyard grant program, higher dollar amounts that go out to the shipyard grant program, so that these small shipyards, these smaller shipyards, can actually make the investments, this infrastructure improvements that they need to be able to answer the call that the new wave of Maritime is requesting. Right? Fleet expansion. We need these domestic shipbuilding capacities to grow. And we need it from all angles, right? All shipyard grants, but also these small shipyard grants. I think that they need to be increased. Now, again, these are all just food for thought pieces. Instead of just piecemeal bringing them up, I thought I might just take the opportunity to list out a few of my top. Now, I only have about one more. I think it's one more to talk about here, but but bear with me here. I hope that these are helpful just for discussion's sake, right? The last one I brought up many times, and this I would say is a workforce pathway for boomerang mariners. That's kind of what I've been calling it, right? Marinette Mariner workforce. There's a group of people that I think kind of fall into this almost boomerang mariner category. Individuals that went to sea earlier in their careers, right? They they loved it, they sought it out in their early 20s, they went out to sea, they loved the adventure, they made oodles of cash. And then maybe they start having families, right? They're in their late 20s, they're in their early 30s, and they decide, you know, I don't want to be gone for six, nine, 10, 12 months, a year. I don't want to miss these moments. So they try to come back to shore. And maybe when they come back to shore, maybe they're a little kind of mad that they had to make that decision. They had to totally change their life and their career and what they thought they were going to do. So maybe they don't renew their license because they think I'm not going back out there. I can't tell you how many times I've mentioned this, and people say, Well, that was me. I know that I could do a contingency or a continuity, but I didn't, because I had no intention of going back out there. And then you start coming into your 40s and your 50s, and all of a sudden, you wish you could. You wish you could get back out there, but you let your license lapse 10, 15, 20 years ago. And the pathway back can be difficult enough that many simply just don't pursue it. So while it's not going to solve all our problems, I think one idea worth exploring might be refreshers or re-entry pathways for experienced mariners who want to return to sea. Look, during COVID, we saw other similar programs developed in other professions. I've heard about nursing, doing refresher programs that allowed experienced professionals to return to practice through updated training. I think a similar concept could potentially work in the maritime sector. Because look, expanding the workforce doesn't always mean starting from scratch, and I don't think it should. Sometimes it means making it easier for the experienced professionals to just get back into the industry. And maybe there's little periods where if it's only been five years or only been 10 years, it's it's a smaller refresher course than if it's been 20 years. But you don't forget how to ride the bike, right? You don't forget how to go to sea. And I think that these are really important categories of mariners that we should be trying to capture. Well, thank you for listening to my addendum on the report of maritime dominance or whatever I'm calling it. I don't know. At one point, maybe I'll put it into an actual report, like I said, but I appreciate you listening to me and the few thoughts that I have, just feeling like these pieces weren't getting enough attention. Everything's important, but these are some of the most important ones to me. The last segment is just a quick one. Before we wrap up today, I briefly wanted to mention I did have the opportunity to witness a few weeks ago, I think it was last week actually, Maine Maritime Academy, the state of Maine, recently completed the transfer of MAREDS transferring of the new training vessel to the Academy as part of the National Security Multi-mission Vessel Program or the NSMV program. We've talked about this a lot. This is where they had the vessel construction manager. It was a public-private partnership. They had Maritime Services, who was overseeing the build of all of these NSMV vessels. We are now halfway through that program. This is the third of five. How exciting! These vessels are designed to replace aging training ships at these state maritime academies across the country, but they're built to do more than just train the cadets. And I don't know if you've if I've ever really gone too far into this side, but they can also support disaster response, humanitarian missions, and other national needs if called upon. Look, I I really truly felt like it was an honor to be invited to witness this transfer ceremony. And it was a really special moment for the academy and for the broader maritime education community. I was actually there with a few other state maritime academies, and just such a wonderful thing to be able to see this. I'm especially happy for uh Maine Maritime Academy's president Craig Johnson, who's leading Maine Maritime through this exciting new chapter for the Academy. Because look, when you step back and look at the bigger maritime conversation we've been having over the past year, we are one year. This is April 10th. A year ago, April 9th is when we had that executive order drop. Do you remember that? The executive order of maritime dominance. Here we are, one year later. We have some pretty exciting things happening, right? We have a giant vessel order coming out of the president's budget. We have the maritime action plan in the works. We have conversations happening left and right, and we have an incredible National Maritime Day coming up next month that we'll all be celebrating across the country, but especially in DC. But look, none of it works without mariners. None of it works without cargo, right? Training ships like this are essentially floating classrooms to help prepare the next generation of licensed officers, maritime professionals. And that really brings us back to the broader point of running through today's episode. This month and recently, we've seen developments across almost every level of the maritime policy landscape. And some of those stories were about the day-to-day mechanics of the industry, regulatory oversight, carrier behavior, some of these cases that we've been going through. And others are about the longer-term questions, which is something we've been talking a little bit more about throughout the past year. We're in a once-in-a-lifetime opportunity here to be talking more about how we get our shipbuilding in order, how we get our workforce in order, how we get our cargo policy in order, and how the future of U.S. maritime capability shakes out. These two timelines are unfolding at the same time, day-to-day and longer term, and they all tie back to the same question: how the United States will maintain or create a resilient and competitive maritime system. Because look, at the end of the day, ocean shipping isn't just another industry, it's a system that quietly keeps the global economy moving. Thank you for joining me today. If you like this episode, be sure to follow, subscribe, and leave a review. Want to go deeper on these topics or bring this kind of insight to your team, visit themaritimeprofessor.com to explore corporate trainings, tailored briefings, and on-demand webinars, all designed to make complex maritime regulations practical and easy to understand. And if your organization needs help navigating the legal or strategic side of ocean shipping regs, help, head over to School Strategies. That's where I provide consulting services, regulatory guidance, and policy support for clients working directly with any of these agencies and across the global supply chain. As always, this podcast is for educational purposes only and not legal advice. If you need an attorney, contact an attorney. So until next time, I'm Lauren Beegan, the Maritime Professor, and you just listen to By Land and By C. See you next time.