[PSUBS-MAILIST] Ethical obligation to inform

Mon Jul 17 16:55:46 EDT 2017

Thanks for searching that out Jon,
if they require a differentiation between commercial & non commercial
submersibles then the onus should be on the commercial vehicles to
mark their submersibles. ie. cars don't have "private vehicle" emblazoned
on them, but taxis have "taxi" written on them. Would a surface boat under 
20ft be required to have non commercial vessel written on it? I doubt it.
    I remember hearing that the MTS didn't include submersibles originally
& it was the submarine people that wanted in.  From what I have seen of
Will Kohnen's submersibles, they are a rich persons toy rather than a commercial
vehicle; so his interests would lie in limiting any rules for personal submersibles.
Regards Alan

 
Sent from my iPad

> On 18/07/2017, at 3:30 AM, Jon Wallace via Personal_Submersibles <personal_submersibles at psubs.org> wrote:
> 
> 
> Alan,
> 
> I've been contemplating options.  I happen to agree with Phil's suggestion that being a primary contributor to MTS is in many ways missing the point.  Additionally, I am convinced that the MUVMTS leadership will not accept anything less than labeling or categorizing personal submarines in a pretense to provide the CG an ability to severely regulate their use, and so my personal belief is that our efforts would simply fall on deaf ears.  I believe our best course is to move beyond MTS and start demanding the CG and other government entities deal with PSUBS directly for any issues of concern regarding personal submarines.
> 
> I looked back in my email archive and did find an exchange with Will Kohnen in late February of 2014 that I had forgotten about.  On 2/24/2014 I was contacted by a PSUBS member to make me aware that Will Kohnen was telling folks there was talk that the USCG was looking to "regulate home-built subs" (direct quote).  I contacted Kohnen via email and asked what was going on and whom at the CG was the primary contact seeking such regulations.  He responded that it was the Marine Safety Division and in particular an official named Ken Smith that was in charge of seeking rules from MTS.  The plan, according to Kohnen, was to attach these rules/regulations to the ASME PVHO document.  Since the document is used for self regulation there would be no immediate impact on anyone, however the idea was that the CG could then adopt these rules because they were now ASME rules, an industry standard.
> 
> I contacted Ken Smith at the USCG on 2/25/2014 and talked to him about this issue.  I do not remember the details of that conversation however I did write another PSUBS member on 2/26/2014 via email thereby preserving my thoughts at the time.  My message to the psubber was:
> 
> "I called Ken Smith at the CG yesterday and talked to him about this.  He claims the CG is has no current intention to regulate and Congress has not asked them to come up with any regulations.  Of course, if something happened they may be inclined to, but they don't see it as a major issue right now.  He suggested we work with ASME if we want to be proactive but of course they are not likely to listen to us.  So he suggested that I could filter things through him...he has a contact at ASME."
> 
> Based upon my conversation with the CG there was an obvious conflict between what Kohnen was asserting and what the CG was asserting in regards to the need for personal submarine regulations.  I engaged Kohnen further and learned that he believed a clear demarcation was necessary to separate commercial and personal submarines, rationalizing it as a need required by the public because they wouldn't be able to differentiate between the two disciplines if a personal submarine had an accident.  He further suggested, "The biggest concern of the USCG is that lack of differentiation in the submersible industry. They are aware that this type of cross-over linkage between the Personal and Commercial vehicles can put them in the spot light and they will be ill equipped to explain the differences. It is not to say there isn't a difference at the moment, but once the headlines are out there, the damage is done - unless something tangible can be shown."
> 
> It seemed clear to me that at least part of Kohnen's justification in creating these regulations was because he was worried about what the public thinks given a critical event involving a personal submarine, and a mechanism to bail out the USCG who might not be prepared to articulate the differences between commercial and personal submarines in such an event.  I believe those are illegitimate purposes for creating regulations.  I responded to Kohnen that labels of any kind targeting PSUBS was an issue for us and that there seemed to be "an element of contempt" for personal submersibles by some in the commercial industry.  I also wrote at length describing why I believed it was not axiomatic that an accident involving a personal submarine would negatively impact the commercial market.  Kohnen's response was "I am afraid it doesn't matter so much what we both believe."  This solidified in my mind that no matter what PSUBS recommended, MTS already had their minds made up.
> 
> That is the history I have on the matter other than what has been discussed in recent days.  I don't like the back-door approach being taken with the ASME PVHO document and expect I will be contacting the USCG shortly to reopen this matter with them.  If nothing else, I want to know definitively whether the CG is talking out of both sides of their mouths or if they are just being used as a vehicle for MTS to initiate regulations on personal submarines for their own purposes.
> 
> Jon
>  
> 
> 
>> On 7/15/2017 7:34 AM, Alan via Personal_Submersibles wrote:
>> Jon,
>> any thoughts on where we want to go with this?
> 
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