NACO Sends Comments on Life Raft Issue

This week NACO sent a comment letter outlining the unintended consequences of the requirement to install inflatable life rafts on all COI vessels. Click to read the letter 

April 25, 2012

Mr. Felix S. Yeung

Legislative Fellow

Office of Senator Dianne Feinstein

By Fax: 202-228-3954 and email: felix_yeung@feinstein.senate.gov 

Dear Mr. Yeung:

I appreciate your request for more information on the impact of the current USCG requirement (section 609 of the Coast Guard Authorization Act of 2010, 46 USC 3104).  I sincerely apologize for the delay in responding to your request.  As Mr. Welch with PVA and others have provided, the unintended consequences of the requirement to install USCG certified inflatable life rafts on all USCG COI passenger carrying vessels has serious ramifications on a significant number of small family passenger vessel businesses across the United States.

The National Association of Charterboat operators (NACO) is a national trade association established in 1991 and represents over 3,000 owners and operators of marine charters,who provide fishing sailing diving eco-tours and other excursion vessels who carry passengers for hite. We are the premier association that represents professional harter boat interests in our country. In addition, almost 400 vessels of our membership will be severely impacted by the current regulation.  

The passenger safety record for small USCG COI passenger vessels is impeccable.  Various type vessels have been required to carry a range of survival craft, most of which include USCG certified life floats.  These life floats have an excellent safety record and have never been the cause of any serious injury or death.  The USCG COI vessels we represent carry from 10 to 150 passengers and operate in inland, coastal, and offshore routes.  These vessels routinely operate in areas where they are in close proximity to other vessels and areas where any rescue efforts are quickly exercised.  

There are many issues with the new requirement that have serious impacts to the vast majority of the vessels.  First, the current life floats range in size from about 10” thick by 3’ wide to 5’ long and about 50 pounds to 18” thick by 5’ wide to 10’ long and about 100 pounds.  This is an estimation but I wanted to provide you a comparison to the comparable inflatable rafts.  A small inflatable, 8 person capacity, will be about 18” thick by 2.5 wide to 3.5 long and weigh close to 200 pounds, while a 25 person inflatable will be larger than a 55 gallon oil drum and weight over 500 pounds.  Many of the vessels we represent are sport fishing type where the wheel house is in the main cabin and the view is looking over the bow.  Most of the vessels carry the life floats on their bows as this where the structural strength is and also the location for the easiest and fastest deployment in case of emergency.  The current life floats that range from 12” to 18” high do not obstruct the view of the Captain.  As you can understand placing a device the size of a 55 gallon drum in the view from the wheelhouse can cause serious issues with safe navigation and will create a problem for the vessel owner as he/she will be forced to relocate the wheel house.

Relocation of the wheelhouse is not only expensive but in some cases is impossible without completely modifying the structural integrity of the vessel.  Any structural modification also affects the stability of the vessel which will require a new USCG stability test and could result in the loss of passenger capacity affecting the economic productivity of the vessel.  In some cases, with certain fishing vessels, a loss of passenger capacity as required by a new stability test and USCG COI will cause the loss of passengers allowed by the NMFS Federal Fishing Permits.  In addition to the vessel modifications with resulting expenses that may be required to carry the new required inflatable life rafts, the expense of the life rafts are very high (ranging from $3,000.00 to over $10,000.00 per raft) and also include yearly recertification that begin at $1,500.00 per raft.  The current life expectancy of these inflatables is 10 years or less where they have to be replaced with new.  This recertification process also puts the vessel out of commission for 2 to 4 weeks per year.

The House passed HR2838 which includes a provision to require a study by the USCG to provide an analysis to determine if there is a need to require an inflatable life raft over the current life floats.  S1665 also proposes such a study which will also include a cost/benefit analysis.  We have also requested that the Senate bill include a provision to place a moratorium on the current implementation date of January 2015 to require the new inflatable rafts on all vessels.  The purpose of this request is to allow the USCG time to do the studies and evaluate them and determine if the new requirements are truly necessary when the current safety record does not indicate a need for requirement of the inflatable rafts.

The small passenger vessel industry is very hopeful that the Senate will seriously consider our request and place the moratorium on the current implementation date along with requiring the studies to determine any need.  Should you have further questions please contact me and we look forward to working with you and other Senators in this process.

Sincerely,

Capt. Robert F. Zales, II

President