[PSUBS-MAILIST] USCG Marine Investigation Report and Ramifications

Wed Aug 13 10:50:47 EDT 2025

Awesome to see this all coalescing- When Titan happened I was dismissive of concerns about potential impacts, but once there is any board suggesting regulation, I expect someone will latch onto it.

A potential avenue for useful information may be the advocacy experience of a similar group: General aviation, and specifically the homebuilt set. 

John Bussard
Sent from my iPhone

> On Aug 12, 2025, at 21:29, Jon Wallace via Personal_Submersibles <personal_submersibles at psubs.org> wrote:
> 
> Thanks for the feedback folks.  I read all the messages and give due weight to everyone’s comments and suggestions.  Let me address some issues that have been brought up thus far.
> 
> As Jim Todd and Hugh Fulton have suggested, PSUBS is a safety conscious organization and we need to highlight to the Coast Guard the fact that we have a 28 year record of self-imposed safety guidelines to our credit.  For example, we have numerous publicly available documents on our website that demonstrate our commitment to safety including:
> 
> 1)      PSUBS member agreement published at http://www.psubs.org/membership/PSUBSMembershipAgreement.pdf
> 
> 2)      Links to ABS, ASME, and Germainischer Lloyd AG certifying authorities.
> 
> 3)      An established collection of official PSUBS guidelines including Design, Construction, and Operations of submersibles as well as event related guidelines including “Dive Ops Planning Guide”, “Vessel Emergency Plan” and checklists published at http://www.psubs.org/guidelines/PSUBS/
> 
> 4)      An online submission form that provides members with an opportunity to submit additions and/or changes to our collection of guidelines.
> 
> 5)      Links to existing US and Canadian Laws and/or Regulations that affect recreational submarines.
> 
> 6)      A PSUBS side project called http://WWW.SUBDB.INFO where private/recreational submarines can register themselves and upload information/documentation pertaining to their vessel.  In the event of an emergency situation this vessel information is always available online to help foster rescue and recovery using detailed data about the vessel.
> 
> As referenced above, over our nearly three decades of existence we have adopted and published a considerable amount of safety related material for public consumption.  These were established and adopted of our own volition to foster safety and responsibility in our underwater pursuits.  Not only should we be proud of what we have produced (all of us are contributors) but our collection should draw the respect of the Coast Guard and other government entities.
> 
> In regards to a PSUBS inspector as suggested by Hugh Fulton, I have had the same thought numerous times over the years and it is my opinion that PSUBS could perhaps become some sort of overseer of the recreational submersible market if it made sense to do so.  I could see a PSUBS “approval” being a badge of honor and potentially valuable asset thereby encouraging members to participate in achieving it.  On the other hand, in the case of a denial I can also see such oversight leading to a loss of membership by those who think they have built a safe vessel and end up viewing PSUBS as “red tape”.  It would be a big commitment for the organization and there would be numerous hurdles to overcome such as determining criteria for an approval and probably the need to stipulate “grandfathering” clauses for older vessels.  As Hugh correctly observed some items in his list would be out of reach for many home builders and we would have to keep that in mind.  Additionally, this is not something I could do by myself and would require some commitment from other dedicated members.  Overall, definitely not out of the realm of possibilities but a lot of work to conceptualize and then formalize.
> 
> Alan James observation is well taken and I think our message to the Coast Guard must include those kinds of analogies.  Comparing apples to apples, a home built surface boat is not immune from foundering or involvement in an accident with loss of life.  When such an event does occur it does not seem to be a first priority of the government to severely regulate such vessels by limiting their occupancy to only the owner and it seems hypocritical to take that approach with our submersible vessels.
> 
> In summary, thanks for all your comments and please keep them coming.  As an update to my previous message, I am authoring a letter to Coast Guard leadership and will share that when it is complete.  I have two immediate goals, the first is for PSUBS to be included in any “industry working group” that the government creates; and second, ongoing participation by Coast Guard representatives at PSUBS conventions equitable to their participation at the MTS underwater intervention.  In the event I do not receive a response in a reasonable time we will need to take additional steps and potentially author a petition that we can send to our combined congressional delegations.  I will be looking for your cooperation should we need to take that approach.
> 
> Additionally, I have approved River Dolfi acting as a PSUBS representative to the Coast Guard effective immediately.  River has extensive oceanographic work experience, is a “psubber” currently refurbishing his own personal submarine, and more importantly was part of the Titan recovery team which allowed him to build associations with some Marine Investigation Board Coast Guard officials.  River will be seeking audience with his CG contacts concurrent with our letter to CG leadership.  I have impressed upon River the importance of zealously defending PSUBS interests and I have confidence he will do so.
> 
> As always, I will keep you informed of updates.
> 
> Jon
> 
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