examinations and were provided in early 1973 to a newly established division at the USCG Institute (Wohlfarth, 1978). The Institute itself had been relocated to Oklahoma City, partly to take advantage of mainframe computer resources that could be used for scoring the license examinations.

There were significant problems in the revised licensing program during implementation, which were corrected as experience was gained with the new format. The multiple-choice format was generally accepted within the marine community. This initial success was attributed to the extensive coordination and consultations that were conducted (Wohlfarth, 1978). Dissatisfaction was limited principally to specific questions rather than to the format. Mariners and operating companies also benefited from the substantially reduced time needed to complete the examination. It is unclear how much this contributed to acceptance of the new format, although it was probably a significant factor.

In recent years, the USCG's multiple-choice examination approach has been criticized widely within the marine and towing industries and by marine pilots. One concern is that the examination does not ensure that an individual is professionally competent. Because all the examination questions were released by the USCG to the public in response to Freedom of Information Act requests, the integrity of the examination process has been compromised. This public release and the advent of computer-aided teaming techniques has enabled the creation of "electronic ponies," which are in wide use at many license-preparation schools. The rote memorization of the essay examination of the past has been replaced by the "programming" of license candidates to successfully pass license examinations.

Dissatisfaction with the multiple-choice examination format has caused some marine groups to call for a return to the essay format. Such an approach would be confronted by the same types of problems that the earlier essay system experienced. One alternative is to involve marine simulation in the process, either as required training, as an evaluation platform, or as a combination of these two options.

Nautical Credentials of USCG Marine Licensing Officials

The nautical expertise of marine licensing officials is an important consideration in applying marine simulation to professional regulation. The marine licensing authority must either maintain adequate resident expertise to fully administer the program or find alternative sources of expertise for the same purpose. It would be difficult for the USCG to revert to the earlier system of licensing, because the agency has not maintained a cadre of licensing examiners with the requisite qualifications. As discussed in the main body of this report, a move by the USCG to use simulators could also necessitate the maintenance of a staff with extensive marine qualifications to effectively oversee the validation and use of marine simulation.

The merchant marine and towing industry operational experience and expertise possessed by USCG personnel involved in marine licensing have

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