[PSUBS-MAILIST] Vessel for hire - subs as unique watercraft

Thu Oct 10 00:19:58 EDT 2019

 It's a can of worms that nobody wants to open.  Currently, US operations are governed by USCG NVIC 5-93 which is almost 27 years old and was authored in anticipation of a 1993 bill that ultimately never passed Congress.  What it provides, and limits, depends upon who you talk to.
However, it's clear that the USCG intended to scrutinize passenger carrying vessels much more than non-passenger vessels.  The specific rules depend upon number of passengers.  Vessels carrying more than 6 passengers are subject to 46 CFR Subchapter-T Small Passenger Vessels.  Vessels carrying 6 or less passengers are subject to 46 CFR Subchapter-C Uninspected Vessels.  Additionally, it states, "an uninspected submersible may be permitted inU.S. passenger operations only if it is designed and constructed to a recognizedindustry standard".  Note, there is no wording that specifically sets a requirement for "certification" but we can assume that's what they intended.
Recreational Submersibles are defined as "vessels manufactured or operated primarily for pleasure, or leased, rented, or chartered toanother for the latter's pleasure. Submersibles within this category are subject to therequirements of 33 CFR Subchapter S - Boating Safety, Parts 173-183."  Now interestingly the 5-93 circular is silent regarding passengers on recreational submarines.  In fact, it states, "The guidelines inthis circular generally do not apply..." which might lead you to think it was ok for us to take passengers, but there is other federal law describing "passenger carrying" vessels that would obviously restrict us from doing that.
Perhaps one loophole, workers on a vessel are not "passengers".
So anyway, it's an extremely complicated situation at the moment with too many rules and too many interpretations.  Most people don't want to discuss it for fear that drawing attention to them will cause stricter rules and enforcement.  MTSMUV has been trying to develop new rules based upon different classifications however I have found their suggested changes severely limit the personal/recreational market and thusfar we have been unable to find any middle ground.
Jon

    On Wednesday, October 9, 2019, 10:06:01 PM EDT, Brian Hughes via Personal_Submersibles <personal_submersibles at psubs.org> wrote:  

  Whilst recently enjoying a fine cigar and outstanding bourbon, five sub owners sat around a bonfire at Raystown Lake, Pennsylvania and contemplated US Coast Guard requirements for carrying passengers. Especially paying passengers. Does one need a Captain's License to do so in a submarine?
The distinction arose around diving in lakes or diving in waters normally patrolled by the Coast Guard. Further, what does piloting a boat on the surface have in common with piloting a boat that purposefully sinks and comes back up?
Thoughts? Internationally friends, what is your experience?
Brian

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