On June 7, the Passenger Vessel Association filed
written comments with the Federal Communications Commission
(FCC) on a proposed rule on maritime communications
. FCC had sought comments on whether to require all small passenger vessels to have a reserve power source for their radios (currently, such a requirement applies only to passenger vessels of 100 or more gross tons).
PVA recommended that the FCC not require all small passenger vessels to have a reserve power source. Such a requirement would be “too sweeping” and would “unnecessarily impact large numbers of small vessels including water taxis, vessels in narrow waterways, cable ferries, passenger barges, launches, and a host of small vessels using hand-held and/or portable radios.”
Instead, said PVA, the requirement should apply only to a subset of small passenger vessels, those that fall within Subchapter K of Title 46 Code of Federal Regulations and those Subchapter T vessels that are required to carry EPIRBS (“small passenger vessels operating on the high seas or more than 3 miles from shore on Great Lakes voyages”). This would direct the reserve power source requirement to those vessels whose safety would be most enhanced by it, while minimizing the requirement’s economic impact on those smaller-capacity vessels that operate in more restricted environments.
Before taking this position, the PVA Regulatory Affairs Committee confirmed that the reserve power source requirement could be satisfied by means of a battery.