A towing vessel may receive documentary inspection credit in four of five years. A small passenger vessel has no documentary-inspection baseline in the same proposal. That difference is the first budget fact for a mixed SIP fleet. The draft NVIC's proposed inspection table does not describe one fleetwide rate that can be applied to every hull.
The Coast Guard posted the draft change to NVIC 02-99 on August 24, 2026, and requested comments by September 23. The notice describes a risk-based verification model, broader digital-recordkeeping formats, third-party audit evidence, and updated deficiency-management and temporary-repair procedures. The draft is guidance for comment, not a final NVIC or a binding amendment to the inspection regulations. (Notice of availability; draft NVIC)
A compliance or operations director setting the next inspection-cycle and digital-compliance budget needs to ask which vessels could receive each documentary baseline, under what conditions, and what happens when those conditions fail.
The ratio is the budget input
The proposed baselines separate the fleet into materially different cases. For towing vessels, inland tank barges, and school ships, the five-year certificate-of-inspection cycle includes one onboard inspection at renewal and four documentary inspections in five. Cargo vessels, offshore-supply vessels, and seagoing barges receive a different proposal: two onboard inspections in five, at renewal and periodic inspection, plus three documentary inspections in five. (Draft NVIC, Enclosure 1, Table 1)
Small passenger vessels sit at the other end of the table. For Subchapters T and K, the proposed five-year cycle contains five onboard inspections and no documentary-inspection baseline. Passenger vessels under Subchapter H use a one-year cycle, with one onboard inspection in four at certificate renewal and three documentary quarterly inspections in four. Those are different operating and budgeting assumptions, not alternate labels for the same relief. (Draft NVIC, Enclosure 1, Table 1)
The multi-certificated rule makes a simple fleet average even less useful. Where a vessel carries more than one certification, the draft applies the most stringent inspection baseline. Its example is a vessel certificated under both Subchapter T and Subchapter L: it follows the Subchapter T baseline, including annual onboard inspections. A vessel roster that collapses certificates into a single “SIP vessel” flag can therefore produce the wrong planning case before anyone argues about software or staffing. (Draft NVIC, Enclosure 1, Note 3)
Build the budget from the class-specific baseline, then segment again for multi-certification. A whole-fleet summary is still possible, but only after those inputs stay visible. Averaging four documentary inspections in five with zero documentary baseline for small passenger vessels produces a neat number and a poor control.
Credit follows performance
“Documentary” also does not mean automatic. In the proposed process, the SIP Advisor conducts an administrative and performance review from shore using company records. When the data demonstrates sustained compliance, effective self-inspection, and the required material-review elements to the Homeport OCMI’s satisfaction, the OCMI may credit the annual inspection requirement. The operative words for planning are “may” and “to the OCMI’s satisfaction.” (Draft NVIC, Enclosure 1, section K)
The OCMI retains discretion to require onboard verification in any year when clear grounds exist, performance degrades, or the vessel enters SIP Probation. Probation removes the privilege of Remote Verification immediately; the vessel returns to a traditional physical onboard inspection regime until the systemic issues are corrected. That is a real downside case for a budget, not a footnote for a later compliance review. (Draft NVIC, Enclosure 1, Note 1 and section K)
The practical model should have at least two layers for every class: a proposed documentary baseline and an onboard-inspection downside. Then add the vessel’s certification mix and current performance position. A high-performing towing vessel and a probationary towing vessel belong to the same class, but they do not belong in the same inspection-cost scenario. That segmentation is an inference from the proposed rules, not a promise that any particular vessel will receive a credit.
The date matters too. The Coast Guard says comments will be considered when preparing the final version. Until that happens, the ratios are useful for scenario planning and unsuitable as a booked saving, contractual entitlement, or final eligibility decision. (Notice of availability; draft NVIC disclaimer)
Digital evidence remains the operator’s job
The draft is deliberately neutral about the container holding the evidence. An operator may use paper records, a locally developed digital system such as a structured spreadsheet or custom database, or a commercial digital compliance system. The draft describes a CAP/VAP System Framework and system crosswalk for mapping existing software to SIP requirements, while placing responsibility on the operator to demonstrate that its implementation and internal processes meet the proposed standard. (Draft NVIC, Enclosure 4)
Procurement still depends on the company-specific implementation. A programmatic technical assessment by the Marine Safety Center can complete a software assessment, but the OCMI still reviews the company’s CAP/VAP implementation and configuration. The assessment is not a general approval of one vendor for every operator. A digital system can organize, retrieve, and present evidence; it cannot turn a weak verification process into sustained compliance or guarantee fewer onboard inspections. (Draft NVIC, Enclosure 4)
Third-party work has the same boundary. A third-party report may serve as objective evidence after the Company SIP Examiner reviews it and signs the corresponding inspection record. Responsibility remains with the company. The draft says that using the report does not transfer liability, and a later Coast Guard deficiency in the covered area can be evidence of a failure in the company’s own verification process. The budget should fund internal review, ownership, and retrieval of evidence alongside the outside audit or software subscription. (Draft NVIC, third-party evidence)
Budget by class and performance
The notice presents the proposal as a way to reduce redundant physical inspections for high-performing operators and to broaden acceptable compliance formats. The notice and draft do not establish measured savings or safety outcomes. (Notice of availability; draft NVIC)
Remove the uniform remote-credit line from the next budget. Use conditional class scenarios with an onboard downside; do not book savings the draft does not measure.