USCG Update Requirements for Added Passenger Weight
The cutoff date for submitting the upgraded passenger weight to the USCG and not lose your passenger count is Dec 10th. That’s not much time people.
I had a meeting with Lt. Cmdr. Mark Neeland who is the chief of the USCG Small Vessel Branch. I was most concerned that the CFR 46, 170.173, (3) and (5)(1)(iii) declare catamarans unsafe. He did assure me that I have such a good track record of safe designs, that they will continue to ignore the offending parts of that rule. Changing the rule to reflect catamarans is not in the pipeline however.
He did assure me that if operators have their revision paperwork submitted by the deadline, they can keep their passenger count. Even if it takes months for them to run the numbers.
Again, for monohulls, the heavier passengers can present a hazard. For catamarans, they are more stable. The critical condition actually is lightship: dry and empty.
What I need from operators:
A copy of your stability letter. I have copies of many of them after 1996 or so, but some change over time and I might need to reflect that. Scan and email it or fax it. This must include the stamped sail plan.
The name and email address of your local USCG inspector so I can copy the submittal to him or her.
The vessel lightship weight. This can be more difficult. The best of all is to have had a Deadweight Survey and the results of that. That is best reflected in a Load Items file. That file lists lightship weight while noting; size of all tanks and their fullness, any gear to be added or subtracted, any food or drink items or other passenger items found on your trip.
Some vessels only have a weight listed on the Stability Letter with no other detail. Sometimes that is allowed. Other times it is rejected. One catamaran was rejected until I listed the count of soda cans onboard. If you nor I have a Load Items file for your boat, I propose that you try to recreate the information so I can create one that we can use. How full were your tanks when the Deadweight Survey was done? Have you added any equipment since that survey? What is the typical weight of your passenger food and drink?
If there is no record of a Deadweight Survey, but you do have a vessel weight, I suggest that we try the submittal with just the vessel lightship weight. They may come back later however and demand a Deadweight Survey. That is of course another task for me.
Over 49 Pax. I found the Damage Stability up upgrade for passenger weight easy in one way. It is easy to see the stability actually goes up when you toggle between the two passenger weights in Excel. Maybe more difficult as the vessel weights for those were listed before deadweight survey, so the new upgrade weight is quite large. The USCG should accept my results, but I won’t know until they process it. Tentatively I am calling this service 2 hours work but it could be more if they want more.
Funding for the submittal. I do need that first. Some operators have stated they wanted the work done then changed their minds. We take checks, cards or paypal. It looks like I can do the job, if I have all the needed information, for $500. I have been told that the rock star design offices charge more than 10 times that.
