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USCG-1998-4734
Question:
1. Should the
Coast Guard formally recognize a definition of PWC?
Response:
Yes. But because there is a
mandate for change in the design of PWC to include off-throttle
steering and braking capabilities, the definition should not limit
itself to the present design of a PWC. Since there is no other
water-going vehicle like a PWC, the definition should be easy
enough. Sub-categories of PWC may include those craft which are
designed to carry more than one individual.
A simple definition
is:
An inboard vessel less than
13 feet in length which uses an internal combustion engine
powering a water jet pump as its primary source of propulsion,
and is designed to be operated by a person or persons positioned
on, rather than within the confines of the hull. The vessels are
designed to carry from one to three persons and be operated by a
person sitting, standing or kneeling on the
vessel.1
So long as PWC remain vessels
unlike traditional boats, with no sides to prevent falling
overboard, the number of people who can be potentially injured by
falling from the craft, or injured by exposure to collision with
other craft or fixed objects because of no enclosure should not
effect the basic definition of a PWC.
Other terms, such as jet skis,
water scooters, and sport boats are not adequate, because the
industry itself has, for the most part, adopted the term PWC in
self-description.
Question:
2. Should the Coast
Guard continue to require PWC manufacturers to petition the Coast
Guard for exemptions to the manufacturing regulations for
recreational boats?
Answer:
Yes. The PWIA should be
required to petition for any exemptions to regulations for
recreational boats because they are unlikely to self-police.
Although the industry has recently expressed interest in safety,
it is the same industry which pushed to develop a vehicle which
began at only about 30 mph to a vehicle which will now exceed 60
mph, ignoring the Human Factor relative to off-throttle
steering.
Question:
3.* Should the Coast
Guard develop a method other than the exemption process to require
PWC manufacturers comply with Federal recreational boating safety
laws?
Answer:
Yes. SAE standards along with
regulations that address accidents associated with the specific
design of PWC would be most desirable. Industry self-regulation
has not been adequate in providing safety to PWC users.
* Since submission of this
statement, the Coaliton has learned that the Coast Guard had to
pull a report by a SAE member because of heavy industry bias,
therefore we have retracted this statement, and ammended it to say
we would prefer to see an unbiased entity set standards for the
industry.
Question:
4. The Coast Guard also
grants exemptions for other categories of non-conventionally
designed recreational boats. Some include airboats, hovercraft,
submarines, drift boats, race boats, and mini bass boats. Should
the Coast Guard develop a method other than the exemption process
to require those non-conventionally designed boats to comply with
Federal recreational boating safety laws?
Answer:
Yes. The Coast Guard should
consider design, and accident statistics and data in the same way
it has considered them relative to PWC when developing methods
other than the exemption process for other non-conventional
boats. |