[PSUBS-MAILIST] Submersible Rules

Tue Jul 18 17:52:31 EDT 2017

Hi all,
I recently emailed Will Kohnen from the position of a foreigner concerned
that any submersible regulations that his organization draughted would 
eventually be adopted by my Country.
I also mentioned lack of consultation with Psubs. Below is his reply.

I am extremely sensitive to the Psubs issues and there is no need to change
much in the Psubs community. It is rather everybody else that needs
attention. There are many Psubs members that participate in the dialogue and
also talk with Jon. I would encourage Psubs to come and participate and you
may find life is a happy place. I don't know what else to say.

The US Coast Guard current regulations are reasonably clear that any
self-built, recreational submersible can do whatever they want, as long as
no money changes hand. This works for Psubs, no problem, and there is no
reason to change that. There is the slight footnote in the regulations that
notwithstanding, the Captains of the port can ignore the rules and decide to
allow or deny operations as they see fit. This can lead to a lot of
confusion and inconsistency. Again, the problem is not with Psubs (although
the tenure is tenuous), but with the rest of the industry that is trying to
make a viable economic development in the field. The moment there is a
single person in the sub that pays $1, it is considered a "Passenger for
Hire" and you are treated like an Atlantis submarine. That leaves an awfully
large gap between Psubs and Atlantis and to suggest that the entire industry
has to position itself on one side or the other is a bit lacking in
granularity. The industry has moved and evolved since 1993.

So, No - the Psubs will always remain free to do what they want, and it may
even be helpful for the world at large that this freedom be better defined
so as to secure this right. In the US, since the US Coast guard has come
under Homeland Security, the freedom of Psubs (and everybody else) is one
incident away from serious "Broad-level" regulation, written by folks in
govt that really don't give a hoot for the sub industry. So it may not be a
bad idea to be pre-emptive.

That's all.
What we are discussing in much greater detail is the need to allow companies
to operate "Without" Coast Guard regulations if the sub is Classed and
carries less that 6 "Occupants", and where we define what an "Occup0ant" is,
as NOT a passenger. This would open up the economic feasibility for
companies to do submarine work and charge money without the egregious Coast
Guard certification (which still remains perfectly fine and applicable if
you want to run a 40 passenger sub and carry innocent tourists underwater).

There should also be a separate category for companies making subs that are
made commercially but which are not Classed, and also carry 6 "occupants" or
less. If you build a number of subs and you sell them commercially,
unclassed, this is NOT a Psub anymore, or at least there needs to be a clear
line. When Oceangate or Deepflight build subs that cannot be classed, for
one reason or another, these are not Psubs. Where do they fit in the
spectrum? Due to the economic impact and higher public profile of such subs,
it behooves everyone to pay some attention to the proper "Categorization" of
each group so that they are not all treated with one broad brush. This is
fairly basic industry positioning for the well being of the industry and the
protection of each group.

I don't think the Coast Guard in any nation can properly sort that out, not
in the US, NZ, AUS, Europe or China....
So that leaves us to think, be pragmatic, invest some time, energy, goodwill
and work in good faith so we may end up with a regulatory environment that
lets the entire MZUV industry become economically viable, while also
preserving the freedom of the hobbyist.

I've attached a rough categorization of sub types to include the "Atlantis
Pax" subs (remaining as they are, the "Psubs" as they are today and added,
Commercial Sub, Uninspected Subs and Submarines, which were never attended
to and which may in the future.

The door is wide open at the conference and I hope Psubs will increase its
participation beyond a handful of individuals.

There is no big rush but it is worth pushing forward. The govt's everywhere
would be more than happy to find a template they can adopt and use as a
baseline for their handling of these issues.

Again, thank you for reaching out and I hope we get to discuss this in more
detail as we go.
All the best
Will

Sent from my iPad
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