[PSUBS-MAILIST] Submersible Rules

Tue Jul 18 18:32:39 EDT 2017

Thank you Alan

That seems to be thoughtful response.
Best regards,
Greg

> On Jul 18, 2017, at 4:52 PM, Alan via Personal_Submersibles <personal_submersibles at psubs.org> wrote:
> 
> 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
> 
> 
> 
> 
> <CATEGORY of OPS TABLE - MUV Operating CONSENSUS STD (Feb-2017).pdf>
> 
> Sent from my iPad
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