There was technical guidance that was released a few weeks ago for part 2a. Your thinking of the Framework for Conditional Sailing Order. But that is very high level and doesn't have the detailed requirements. The industry was waiting on technical guidance for details. The technical guidance for 2a is the part they were missing (and the technical guidance for the remaining parts that still hasn't been released). The technical guidance is pages of details for step 2a, versus 3 paragraphs in the first document.
It was all over the news and cruise blogs when it was released and the lines and ports claimed to be very disappointed that was all they got, because it didn't even have the information on the important next step of test cruising, or a date when test cruises could start.
Here are the facts as explained from Alaska's Motion to Intervene in the Florida case (emphasis mine):
On October 31, 2020, the CDC issued a “Conditional Sail Order” that promised a “phased resumption of cruise ship passenger operations.” 85 Fed. Reg. 70153. The initial phase consisted of testing and additional safeguards for crew members while the CDC ensures operators build the laboratory capacity needed to test future passengers. Id. Subsequent phases would
include simulated voyages, certification for ships that meet specific requirements, and a phased return to passenger voyages. Id.
On April 2, 2021, the CDC issued technical guidance for phase 2a of its phased approach. Among other requirements, this phase requires operators to create “planning materials for agreements that port authorities and local health authorities must approve to ensure cruise lines have the necessary infrastructure in place to manage an outbreak of COVID-19 on their ships to include healthcare capacity and housing to isolate infected people and quarantine those who are exposed.”3 This plan, in addition to a host of other requirements, requires operators to obtain “medical care agreements” that include contractual arrangements to provide for emergency medical transport of critically ill persons and contractual arrangements with shoreside medical facilities to ensure that travelers receive appropriate clinical evaluation. In these agreements, the cruise ship operator “must document that its contractual shoreside medical facilities or healthcare systems either singularly or collectively have enough medical capacity in the judgment of the local health authorities to care for travelers if an unanticipated outbreak of COVID-19 occurs on board its ships.”
Along with the medical care agreements and other related requirements, cruise ship operators must enter housing agreements with shoreside facilities to allow for isolation of and quarantine of persons with suspected or confirmed COVID-19. The housing agreement provision includes another host of requirements, including an obligation by the cruise ship operator to “document that it has made contractual arrangements . . . in sufficient quantities as determined by the local health authorities to meet the housing needs of travelers until they meet CDC criteria to discontinue isolation.” In addition to the housing requirements, the CDC also directs the parties to the agreement—which includes the cruise ship operator, the U.S. port authority, and all health departments exercising jurisdiction over the port—to jointly consider the potential needs of travelers under quarantine and isolation. These needs include the availability and frequency of testing; availability of mental health services; pharmacy delivery and other essential
services; available of security; a check-in process, including delivery of luggage; procedures to ensure daily monitoring of travelers in quarantine; procedures to minimize contact between travelers in quarantine and support staff; and post-isolation and post-quarantine procedures to allow travelers to safely return home.
The CDC has yet to issue technical guidance for Phase 2b—simulated voyages—or any of the other remaining phases. Based on the Conditional Sailing Order, it will be at least a 90-day process for a cruise ship operator to complete a simulated voyage and possibly obtain a conditional sailing certificate. Alaska’s cruise season is limited, extending from mid-May to early October each year. Unless the CDC’s overly burdensome and opaque requirements are altered or lifted soon, it will be impossible for large-scale cruising to resume in the United States in time for any part of Alaska’s season. And, given the CDC’s current pace for issuing its technical guidance and the lead times necessary to arrange and market cruises, the CDC’s action
may jeopardize the 2022 cruise season as well.
Most of those specific details weren't available until this month. You can Google the two documents to compare them.
As of today, the test sailing guidance (for part 2b) still hasn't been released. With a minimum of 90 days from starting test cruising to actually having normal cruises, the lines will miss a big part of the summer cruising season, even if test cruising resumes very soon (it won't). Frankly, I think the cruise lines, ports, and states have a legitimate reason to be frustrated with the CDC at this stage.
You can argue that the CDC would release the next steps if they would simply comply with 2a, but they have only had a few weeks since specifics were available, I am not sure any line can actually comply with it, I too would be hesitant to start an expensive process without fully knowing what I was getting into, and I don't see any indication at all that the CDC will suddenly release the next parts just because they have complied with 2a - the CDC hasn't even claimed that it will.
By the way, I just learned the the
12-hour separation requirement for terminals was dropped from the guidance recently, and only requires it to the extent practicable.