I got this today... Kinda boneheaded for USCG.... Joe P. -----Original Message----- From: John G. Rako Date: Sunday, January 30, 2000 2:25 AM Subject: Anchor requirements for small craft >Please Respond to a proposal for a USGS anchor requlation by going to. >http://dms.dot.gov/search/ enter 4447 for the docket number. > >Here's mine: >Docket Management Facility >U.S. Department of Transportation >400 Seventh Street S.W. >Washington, D.C. 20590-0001 >Regarding Docket Number USCG 1998-4447 > >Speaking for the Delaware Valley Division of the American Canoe >Association, I echo the many thoughtful comments by those opposed to the >proposed ground tackle regulation. Any one-size-fits-all rule is bound >to be inapplicable in many cases and counter-productive in many others. >I emphasize the fact, as pointed out by others, that ground tackle in >canoes, kayaks, rafts and other small craft may be deadly. The greatest >danger is, of course, the risk of entanglement by anchor line. Running a >close second are the consequences of inadvertent anchoring in rivers and >other moving water. The craft then becomes deadly, not only to its >passengers but becomes a dangerous obstruction to other craft. I know of >one case where a light recreational fishing boat with a small outboard >motor attempted to anchor in the Maumee River South of Toledo Ohio and >became unstable in the current and capsized, killing its passengers. I >also agree with comments by representatives of the National Park Service >and canoe livery operators that canoes and kayaks, in particular, >present a risk when transported over-land if they are carrying ground >tackle. > >The proposed regulation is wrong-headed and dangerous and was >ill-considered by those proposing it and supporting it who used as >evidence only their own limited experience. > >John G. Rako, Ph.D. >Safety Education and Instruction Chair, ACA Delaware Valley Division >American Canoe Association Instructor Trainer >American Red Cross Instructor Trainer > >=============================================================== >Here is the response by the fellow who alerted me: > >Docket Management Facility >U.S. Department of Transportation >400 Seventh Street S.W. >Washington, D.C. 20590-0001 >Regarding Docket Number USCG 1998-4447 > >I oppose the implementation of a federal requirement to require anchors >on all vessels. The prudent mariner will always have appropriate ground >tackle. However, I can not see a blanket federal ground tackle >requirement saving lives. In fact, a federal requirement may cost lives. >Lack of ground tackle is not a large cause of deaths. The data indicates >only 14 of 8047 accidents may have been prevented by better anchors. >Using USCG resources for implementation and enforcement of an anchor >requirement will divert resources from more effective efforts i.e. >drunken boaters. If it is decided to have an anchor requirement, as >usual the devil is in the details. > >The abstract states, "that all recreational vessels in the United States >carry proper anchoring gear and that the gear be in useable condition." >How would a federal requirement define "proper anchoring gear?" For >small boats on lakes, kayaks and canoes "proper" gear is NONE. Danforths >are good in mud and sand, but bad in grass and near useless in rock. >Plows, kedges, and North-Hills all have their strengths and weaknesses. >How much chain? How much line? Answers to these questions are dictated >by the local conditions, and are best answered by the responsible adult >using the vessel. > >A regulation will inhibit innovation in the anchor business. When I >first started boating the non-articulated plow (Simpson Lawrence Delta) >did not exist. Another recent innovation (looking like a small back hoe >bucket mounted on a shank) is marketed under the name "The Max." An >anchor requirement is likely to lead to an anchor specification or >certification. Even a well written specification can stifle new >innovations. > >In our 27' sailboat we cruised the Chesapeake Bay and the Bahamas. We >carried 3 ground tackle systems for different bottom conditions. We even >have a small hook in the dinghy to prevent the undesired exit of a tide >swept anchorage in the event of an outboard failure. Not having the >proper ground tackle is often its own reward, and as the accident data >indicates the usual price is embarrassment. >Thanks, >------------------------------------------------------------ *************************************************************************** PaddleWise Paddling Mailing List - All postings copyright the author and not to be reproduced outside PaddleWise without author's permission Submissions: paddlewise_at_lists.intelenet.net Subscriptions: paddlewise-request_at_lists.intelenet.net Website: http://www.paddlewise.net/ ***************************************************************************Received on Sun Jan 30 2000 - 07:57:25 PST
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