<html><head><meta http-equiv="content-type" content="text/html; charset=utf-8"></head><body dir="auto"><div>Thanks for searching that out Jon,</div><div>if they require a differentiation between commercial & non commercial</div><div>submersibles then the onus should be on the commercial vehicles to</div><div>mark their submersibles. ie. cars don't have "private vehicle" emblazoned</div><div>on them, but taxis have "taxi" written on them. Would a surface boat under </div><div>20ft be required to have non commercial vessel written on it? I doubt it.</div><div> I remember hearing that the MTS didn't include submersibles originally</div><div>& it was the submarine people that wanted in. From what I have seen of</div><div>Will Kohnen's submersibles, they are a rich persons toy rather than a commercial</div><div>vehicle; so his interests would lie in limiting any rules for personal submersibles.</div><div>Regards Alan</div><div><br></div><div> <br><div>Sent from my iPad</div></div><div><br>On 18/07/2017, at 3:30 AM, Jon Wallace via Personal_Submersibles <<a href="mailto:personal_submersibles@psubs.org">personal_submersibles@psubs.org</a>> wrote:<br><br></div><blockquote type="cite"><div>
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Alan,<br>
<br>
I've been contemplating options. I happen to agree with Phil's
suggestion that being a primary contributor to MTS is in many ways
missing the point. Additionally, I am convinced that the MUVMTS
leadership will not accept anything less than labeling or
categorizing personal submarines in a pretense to provide the CG
an ability to severely regulate their use, and so my personal
belief is that our efforts would simply fall on deaf ears. I
believe our best course is to move beyond MTS and start demanding
the CG and other government entities deal with PSUBS directly for
any issues of concern regarding personal submarines.<br>
<br>
I looked back in my email archive and did find an exchange with
Will Kohnen in late February of 2014 that I had forgotten about.
On 2/24/2014 I was contacted by a PSUBS member to make me aware
that Will Kohnen was telling folks there was talk that the USCG
was looking to "regulate home-built subs" (direct quote). I
contacted Kohnen via email and asked what was going on and whom at
the CG was the primary contact seeking such regulations. He
responded that it was the Marine Safety Division and in particular
an official named Ken Smith that was in charge of seeking rules
from MTS. The plan, according to Kohnen, was to attach these
rules/regulations to the ASME PVHO document. Since the document
is used for self regulation there would be no immediate impact on
anyone, however the idea was that the CG could then adopt these
rules because they were now ASME rules, an industry standard.<br>
<br>
I contacted Ken Smith at the USCG on 2/25/2014 and talked to him
about this issue. I do not remember the details of that
conversation however I did write another PSUBS member on 2/26/2014
via email thereby preserving my thoughts at the time. My message
to the psubber was:<br>
<br>
<font size="-1">"<font face="Arial, Helvetica, sans-serif" color="black">I called Ken Smith at the CG yesterday and
talked to him about this. He claims the CG is has no current
intention to regulate and Congress has not asked them to come
up with any regulations. Of course, if something happened
they may be inclined to, but they don't see it as a major
issue right now. He suggested we work with ASME if we want to
be proactive but of course they are not likely to listen to
us. So he suggested that I could filter things through
him...he has a contact at ASME."</font></font><br>
<br>
Based upon my conversation with the CG there was an obvious
conflict between what Kohnen was asserting and what the CG was
asserting in regards to the need for personal submarine
regulations. I engaged Kohnen further and learned that he
believed a clear demarcation was necessary to separate commercial
and personal submarines, rationalizing it as a need required by
the public because they wouldn't be able to differentiate between
the two disciplines if a personal submarine had an accident. He
further suggested, "The biggest concern of the USCG is that lack
of differentiation in the submersible industry. They are aware
that this type of cross-over linkage between the Personal and
Commercial vehicles can put them in the spot light and they will
be ill equipped to explain the differences. It is not to say there
isn't a difference at the moment, but once the headlines are out
there, the damage is done - unless something tangible can be
shown."<br>
<br>
It seemed clear to me that at least part of Kohnen's justification
in creating these regulations was because he was worried about
what the public thinks given a critical event involving a personal
submarine, and a mechanism to bail out the USCG who might not be
prepared to articulate the differences between commercial and
personal submarines in such an event. I believe those are
illegitimate purposes for creating regulations. I responded to
Kohnen that labels of any kind targeting PSUBS was an issue for us
and that there seemed to be "an element of contempt" for personal
submersibles by some in the commercial industry. I also wrote at
length describing why I believed it was not axiomatic that an
accident involving a personal submarine would negatively impact
the commercial market. Kohnen's response was "I am afraid it
doesn't matter so much what we both believe." This solidified in
my mind that no matter what PSUBS recommended, MTS already had
their minds made up.<br>
<br>
That is the history I have on the matter other than what has been
discussed in recent days. I don't like the back-door approach
being taken with the ASME PVHO document and expect I will be
contacting the USCG shortly to reopen this matter with them. If
nothing else, I want to know definitively whether the CG is
talking out of both sides of their mouths or if they are just
being used as a vehicle for MTS to initiate regulations on
personal submarines for their own purposes.<br>
<br>
Jon<br>
<br>
<br>
<br>
On 7/15/2017 7:34 AM, Alan via Personal_Submersibles wrote:<br>
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<div>Jon,</div>
<div id="AppleMailSignature">any thoughts on where we want to go
with this?</div>
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