A recent article mentioned the USCG's March 22, 1999, Notice of Proposed RuleMaking (NPRM) concerning Tank Vessel Response Plans for Hazardous Substances. Since that time I've spent a good deal of time thinking about this NPRM. I feel it appropriate to address some additional aspects of the proposal. There are many issues seemingly unresolved within the proposal. Is it the USCG's intent to establish a new industry for hazardous substance response recovery, developing techniques and recovery equipment not widely in use? If one takes seriously what the USCG has written, such would seem to be the case. It would seem the USCG is taking the experience gained from many years of working with oil recovery and attempting to apply it to chemical responses. Is that possible? Many think it isn't.