June 27, 2019 —
Career Sea Pay (CSP) is intended to compensate members assigned to sea duty for the general arduousness of life aboard any CSP-eligible vessel (not to be confused with the unusual arduousness of certain classes of vessels that meet the requirements of being away from homeport in long time segments for over 50% of each year). While reviewing the issue, we have to consider the intent as well as the letter of the Coast Guard's regulations (U. S. Coast Guard Pay Manual, COMDTINST M7220.29 (series), Section 4-B) concerning entitlement to CSP. In general, TDY on a CSP-eligible vessel involves performing duty as a member of the crew or in direct support of the unit's mission while that vessel is underway and away from homeport. We extend CSP entitlement to members of mobile units who regularly deploy to CSP-eligible vessels (e.g., mobile units) and to personnel assigned on a TDY basis aboard CSP-eligible vessels who are performing duty as a crewmember.
What is not envisioned in the Coast Guard's CSP regulation is creation of an entitlement through the technicality of TDY orders assigning a member to a ship when the circumstances of that assignment are not commensurate with its intent. CSP for assignment to a WPB while it is in a shipyard or in a "Charlie" (Maintenance) status for dockside maintenance availability was never intended, unless the TDY member was in receipt of CSP prior to the vessel entering the shipyard or maintenance availability (U. S. Coast Guard Pay Manual, Rule 6 of Figure 4-5). It is hard to characterize TDY aboard a cutter while it is in a shipyard as "sea duty" when a member receives travel allowances for residing in commercial quarters and subsistence at the same time. It could certainly be considered sea duty if a member were berthed and subsisted aboard a vessel while TDY - but such a situation would preclude travel allowances per JFTR U4102.J. An order by itself does not create an entitlement, only the conditions of duty or status within the context of the authorizing law and regulation creates an entitlement.
Further, in considering the "letter" of the regulation, U. S. Coast Guard Pay Manual, Subsection 4-B-2 states that CSP is authorized for members that are permanently or temporarily assigned for duty to a vessel pursuant to competent orders and that the unit's mission is underway. If duty performed was on or about the vessel while it was not underway and the TDY member was not accruing CSP prior to the cutters entry into the shipyard means that there is no entitlement to CSP during that period.
Look for future changes to the U. S. Coast Guard Pay Manual's language and rules concerning CSP entitlement while TDY to a vessel to remove any future confusion on this subject.
Military Pay & Benefits Policy Team Leader
USCG Headquarters (CG-1332)