[PSUBS-MAILIST] USCG Marine Investigation Report and Ramifications

Tue Aug 12 14:00:18 EDT 2025

Alan, hmm, I always wear my life preserver when diving inside the sub.
Best Regards,
David Colombo

804 College Ave
Santa Rosa, CA. 95404
(707) 328-1224
www.SeaQuestor.com

On Mon, Aug 11, 2025 at 12:06 PM Alan James via Personal_Submersibles <
personal_submersibles at psubs.org> wrote:

> To put it in perspective, in 2024 there were 556
> deaths in the USA attributed to recreational boating accidents, and
> 300,000 drowning deaths World wide.
> Most of those deaths could have been prevented if everyone wore life
> jackets while
> swimming & boating. But no one is going to
> agree to that.
> Alan
>
> Yahoo Mail: Search, organise, conquer
> <https://mail.onelink.me/107872968?pid=nativeplacement&c=US_Acquisition_YMktg_315_SearchOrgConquer_EmailSignature&af_sub1=Acquisition&af_sub2=US_YMktg&af_sub3=&af_sub4=100002039&af_sub5=C01_Email_Static_&af_ios_store_cpp=0c38e4b0-a27e-40f9-a211-f4e2de32ab91&af_android_url=https://play.google.com/store/apps/details?id=com.yahoo.mobile.client.android.mail&listing=search_organize_conquer>
>
> On Tue, 12 Aug 2025 at 1:21 am, via Personal_Submersibles
> <personal_submersibles at psubs.org> wrote:
> Thanks Jon, Will read it for sure!
>
> Br, Emilegoing
>
> -----Oorspronkelijk bericht-----
> Van: Personal_Submersibles <personal_submersibles-bounces at psubs.org>
> Namens Jon Wallace via Personal_Submersibles
> Verzonden: woensdag 6 augustus 2025 18:48
> Aan: Personal Submersibles Generalre   Discussion <
> personal_submersibles at psubs.org>
> Onderwerp: [PSUBS-MAILIST] USCG Marine Investigation Report and
> Ramifications
>
> Psubbers,
>
> This is a long message, but please read.
>
> The US Coast Guard has released their Marine Investigation report of the
> Titan submersible implosion at
> https://media.defense.gov/2025/Aug/05/2003773004/-1/-1/0/SUBMERSIBLE%20TITAN%20MBI%20REPORT%20(04AUG2025).PDF
>
> Since this report is going to generate chatter throughout the submersible
> industry I thought it appropriate to make a statement and start an official
> discussion relative to our own organization.
>
> Now that the Marine Boards report is public we are sure to see an uptick
> in attention to the operation of our vessels and potentially some movement
> to save ourselves, from ourselves, and need to be proactive in addressing
> this issue rather than allowing some other agency or organization to define
> our future.  While we are not the largest organization in the world, we ARE
> the largest organization in the world associated with private submersible
> fabrication, operation, and ownership and therefore have standing to be
> recognized and heard regarding any government regulation that might affect
> us.
>
> From PSUBS beginning it has always been my position, and still is, that
> private recreational use of our vessels is difficult for the government to
> regulate due to the “pursuit of happiness” founding principles of the USA.
> It is my opinion, for example, that this was one reason recreational
> submersibles had a specific section carved out for them in USCG NVIC 5-93
> (see Chapter 1, B, 4) and were equated to pleasure surface boats.
> To wit:
>
> USCG NVIC 5-93, Chapter 1, B, 4
> “Recreational vessels, as defined in 46 U.S.C. 2101(25), are vessels
> manufactured or operated primarily for pleasure, or leased, rented, or
> chartered to another for the latter's pleasure. Submersibles within this
> category are subject to the requirements of 33 CFR Subchapter S - Boating
> Safety, Parts 173-183. The guidelines in this circular generally do not
> apply; however, depending on the area of operation, COTP operating
> restrictions may be appropriate. This will be evaluated on a case-by-case
> basis. These guidelines may be of assistance to a manufacturer or owner of
> a recreational submersible.”
>
> As optimistic as I am regarding our rights as private submersible owners,
> the Titan disaster does represent a potential impact to us and we should
> have a message ready to deliver to the US Coast Guard to protect our
> interests.  Specifically, I have concerns related to carrying passengers
> (not for hire) and impacts to private submersibles participating in
> research and/or acting as a non-passenger commercial operator.  We enjoy
> quite a bit of latitude given the language of NVIC 5-93, 1, B, 4 and it
> should be our goal to preserve it as currently written.
>
>
>
> The USCG Marine Investigation Board made 14 safety recommendations to the
> USCG Commandant.  While the majority of these recommendations target
> vessels conducting commercial and oceanographic research operations, the
> following draw my concern as potential serious impacts to our PSUBS related
> pursuits.
>
> 8.1.1. Recommendation #1: The USCG should establish an industry working
> group to review and update NVIC 5-93. During the investigation, submersible
> industry leaders indicated to the MBI that current USCG limitations on
> operating parameters, including the maximum depth of 150-feet for Coast
> Guard inspected passenger submersibles, was stifling submersible owners
> from exploring new passenger operations in U.S. navigable waters and also
> potentially incentivizing operators like OceanGate to conduct non compliant
> operations. An update to the NVIC would also provide an opportunity to
> clearly outline the process for certifying submersibles of novel design.
>
> PSUBS POSITION
> PSUBS *must* be included in any working group the government creates to
> update NVIC 5-93 and/or create regulations that may impact us.  We cannot
> afford to sit idly by and allow “industry leaders” and/or the government
> itself to revise this document without our input.  It is notable that the
> USCG regularly attends the MTS Underwater Intervention and participates in
> discussions with MUV commercial attendees; however the USCG has never
> accepted an invitation to a PSUBS convention.  Regrettably, we own some
> responsibility for lack of communication with the USCG since we have often
> taken the philosophy of “let sleeping dogs lie” and “out of sight, out of
> mind” when considering our interaction with them; however I think we can no
> longer afford to take this approach.  This month I will be writing the USCG
> Commandant seeking inclusion of a PSUBS representative in any working group
> organized to review NVIC 5-93 and/or any other regulatory act that may
> impact our organization.  Additionally, I will be requesting the USCG send
> a representative to PC2026 to conduct discussions with PSUBS members
> regarding issues and concerns relative to our segment of the submersible
> industry and to start fostering communication between us.
>
>
>
> 8.1.6. Recommendation #6: The USCG should pursue a new regulation which
> requires all submersibles manufactured, owned, or operated by a U.S. entity
> or any submersible operating in U.S. navigable waters carrying any occupant
> other than the owner to be built to the standards of a USCG RO and
> maintained under those standards.
>
> PSUBS POSITION
> Any language requiring certification for privately owned submersibles is a
> serious detriment to our pursuits since from a financial perspective it
> essentially is a show stopper.  This recommendation goes well beyond the
> current wording in NVIC 5-93 which clearly demarcates commercial, passenger
> carrying, and recreational submersibles.  If implemented as suggested it
> would prevent us from carrying our own spouses, families, and friends as an
> occupant unless the vessel was certified.  It is PSUBS position that this
> unreasonably restricts our right to pursue sharing our hobby with voluntary
> passengers who are not for hire.
>
>
>
> 8.1.7. Recommendation #7: The USCG should pursue an update to the vessel
> documentation requirements in 46 CFR § 67.7, to require all U.S.
> submersibles that conduct commercial or scientific operations to obtain a
> USCG Certificate of Documentation (COD) with an Official Number assigned
> and recorded in the MISLE database.
>
> PSUBS POSITION
> We currently have a number of privately owned submersibles that are used
> to conduct various types of research, free of charge, for universities and
> science organizations whom have a need for a deep diving vessel beyond the
> range of SCUBA.  This recommendation by the Marine Investigative board
> could have severe impact on those missions and it is PSUBS position that
> this recommendation unreasonably restricts a private submersible owner from
> providing a donated service targeted for the advance of science.
>
>
>
> WHAT YOU NEED TO DO (right now)
> Minimally all PSUBS members should read the “Recommendations” section of
> the USCG Marine Investigation Board starting on page 324 and consider how
> this impacts you personally or our organization and raise it as a concern
> if it has not been addressed already.
>
> Additionally, start thinking now about issues and concerns we should
> address with the USCG at PC2026 in February.  The more that we can speak
> with one consistent message in terms of specific issues that we feel need
> to be preserved or modified to our benefit, the better we will present
> ourselves.
>
> Jon
>
>
>
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