Letter to Coast Guard

12.18.16

Regarding: Docket ID: USCG-2012-0025

Agency: Coast Guard (USCG)

Parent Agency: Department of Homeland Security (DHS)

Commercial Fishing Vessels- Implementation of 2010 and 2012 Legislation

To Whom it may concern,

·       As a commercial fisherman for over fifty years I have grave concerns about the practicality, viability, and financial burden imposed by the section of the regulation regarding survival craft.  I am a sea urchin (su) diver who operates a 26-foot inboard/outboard vessel.  My boat is typical of the 100 boats in the fleet, however there are boats as big as 40 feet and as small as 16 feet.  Harvesting su is  space exhaustive, therefore the boats in the fleet are specific in their design.  Basically, a surfboard with a motor.  Most if not all boats have enough flotation built into the hull to keep the boats afloat.

·       Requiring the diverse su fleet to have a device on board that keeps one out of the water is well meaning, but poorly informed and likely unsafe.  The su fleet is unique to the commercial fleet.  These boats are designed to have little windage due to needing to safely anchor during diving operations.  As a result of the low silhouette and small cabin there is no safe space to stow the considered device.  These devices are normally stowed on top of cabins.  The su fleet has no room on cabin tops and will likely make the vessel top heavy and prone to capsizing.  Su are a dangerous load to carry as it is, for obvious reasons, without adding to the windage and stability of the boats.

·       Financially the burden on the small su fishery will be onerous.  Beyond the initial cost there will be inspections.  These inspections will force the fleet to have two devices.  One on the boat and one being inspected or in transit from being inspected.  This is a financial obligation that that is not commensurate with the supposed increase in safety.  

·       Finally, the su fleet respect and understand the wishes of those who write these regulations to make all fisheries safe.  Unfortunately, the broad-brush approach, while convenient, is uninformed, unwise and ultimately is contrary to the stated goal.  Fishermen are always aware of safety.  If it is watching knuckles while turning a wrench, stepping off the boat onto the dock to tightening the packing gland.  Safety is number one and if the su fleet thought that the life raft regulation would increase safety we would be endorsers

I respectfully request that the exemption for life rafts that the su fleet has received,  has served the goal of safety well.  The old saying “If it works, don’t fix it” is most appropriate.

Respectfully,

Michael Harrington

Executive Committee

Commercial Fishermen of Santa Barbara, Inc.

6 Harbor Way

Santa Barbara, CA 93109

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