Please Comment on Throw Bag Reg - Mountain Buzz
 



Reply
 
Thread Tools Display Modes
 
Old 02-18-2017   #1
 
Tom Martin's Avatar
 
Flagstaff, Arizona
Join Date: Dec 2004
Posts: 920
Please Comment on Throw Bag Reg

RRFW Riverwire - Throw Bag In Lieu of Throw Cushion Comments Needed Today!
February 18, 2017

As most river runners know, United States Coast Guard (USCG) regulations say that ALL watercraft 16 feet long and over must carry a Type IV throwable personal flotation device (PFD) as per 33 CFR 175.15.

Since 2014, the State of Utah has allowed a Throw Rope with a minimum of 40 feet of line to be used in lieu of a throw cushion where all vessel occupants are required to wear PFD’s.

Now, Utah wants to drop this option. Your comments are due no later than 5:00 p.m. Friday March 3, 2017.

Did you know that in rough water, both the USCG and the Arizona Game and Fish Department acknowledge Type IV throwable devices are not recommended?

Indeed, the United States Coast Guard notes a Type IV PFD is “Not for rough water survival.”
(cite http://www.uscg.mil/hq/cg5/cg5214/ringlb.asp ).

The Boaters Guide of Arizona handbook of boating laws and responsibilities, page 38, notes the following with regards to TYPE IV throwable devices: “These cushions and ring buoys are designed to be thrown to someone in trouble. Since a Type IV is not designed to be worn, it is neither for rough waters nor for persons who are unable to hold onto it."

Many river runners know that Canyonlands and Dinosaur National Park and the Bureau of Land Management at Westwater Canyon all require a wearable PFD. They also allow a throw bag in lieu of a throw cushion.

The State of Utah notes “the intent of the rule is solid with swift water rescue techniques” but also notes they must be in compliance with 33 CFR 175.15. Utah also notes there “will be an anticipated additional cost of $15 per boat” for boats 16 feet and over.

Your comments are needed to keep the existing regulation in place.

Please send your comments by e-mail to Officer Tammy Wright [email protected]

With utmost respect, please tell Officer Wright that:

You want to see the rule R651-215-8 (River Throw Bag in Lieu of Type IV PFD) remain in effect.

The United States Coast Guard has recognized in rough water, Type IV throw cushions are not recommended.

Recreational rough water enthusiasts are already required to wear a pfd by regulation. Having a throwable device in lieu of a cushion makes sense on Rough water and has been recognized by the State of Utah as being a solid swiftwater rescue technique.

If you live and boat in Utah, please cc your Congressional representatives. You can find your Congressional Representative here:http://www.house.gov/representatives/find/

If you would like, please cc Lieutenant Robert Cole [email protected] with the United States Coast Guard, Sector San Diego, and Tom Martin [email protected] of River Runners For Wilderness.

For more information about this rule change, please see https://rules.utah.gov/publicat/bulletin/2017/20170201/41154.htm

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ~~~
RIVERWIRE is a free service to the community of river lovers from River Runners for Wilderness. To sign-up for future Riverwires, send an e-mail address to [email protected] and we'll add it to the RRFW Riverwire e-mail alerts list.
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ~~~

Tom Martin is offline   Reply With Quote
Sponsored Links
Advertisement
 
Old 02-18-2017   #2
 
Andy H.'s Avatar
 
Wheat Ridge, Colorado
Paddling Since: 1995
Join Date: Oct 2003
Posts: 3,620
Thanks for getting this out here, Tom.

Here's the email I sent, please cut, paste, and personalize as you wish:

Quote:
Ms. Wright,

I am a whitewater boater with ________ years experience running whitewater rivers in the Western US and frequently in Utah. I respectfully request that the State of Utah keep Rule R651-215-8 (River Throw Bag in Lieu of Type IV PFD) in effect. I have performed multiple river rescues using a throw bag in swift flowing water which were successful solely because I was able to haul in the “swimmer” rather than watch them continue floating downstream in rapids holding onto a Type IV throwable floatation device. The requirement to have a Type IV throwable floatation device for boaters who must, by law, wear personal floatation devices, places an unnecessary burden on recreational boaters to procure and carry this relatively useless piece of equipment. Furthermore, the United States Coast Guard has stated that in rough water, Type IV throw cushions are not recommended.

Thank you for your consideration of my views,
__________________
Nothing in the world is more yielding and gentle than water. Yet it has no equal for conquering the resistant and tough. The flexible can overcome the unbending; the soft can overcome the hard. - Lao Tse
Andy H. is offline   Reply With Quote
Old 02-18-2017   #3
 
Fruita, Colorado
Paddling Since: 2014
Join Date: Jun 2015
Posts: 197
done and done!
T.O.Mac is offline   Reply With Quote
Sponsored Links
Advertisement
 
Old 02-18-2017   #4
 
Tom Martin's Avatar
 
Flagstaff, Arizona
Join Date: Dec 2004
Posts: 920
Hi Andy,

That's a very nice template letter you have crafted. Thank you for doing that. I have reached out to AW and ACA to see if they can get on board as well.

Thank you T.O.Mac.

Cordially yours, Tom
Tom Martin is offline   Reply With Quote
Old 02-18-2017   #5
 
Omak, Washington
Paddling Since: 1989
Join Date: Aug 2016
Posts: 36
Done. Thanks for the suggestion.
CurrentLY is offline   Reply With Quote
Old 02-18-2017   #6
 
Ashland, Oregon
Paddling Since: 2003
Join Date: Jul 2008
Posts: 123
Done. Thanks for the heads up!
daveb1 is offline   Reply With Quote
Old 02-18-2017   #7
 
Tom Martin's Avatar
 
Flagstaff, Arizona
Join Date: Dec 2004
Posts: 920
Here's my working draft letter, FYI.

Utah Office of Administrative Rules
Regarding the proposed removal of Utah Natural Resources Section R651-215-8

February 20, 2017

Dear Officer Wright ([email protected] ),

It was with some surprise that I recently became aware of a proposal by the State of Utah to rescind Utah Natural Resources Parks and Recreation Section R651-215-8 titled River Throw Bag in Lieu of Type IV PFD. (cite: https://rules.utah.gov/publicat/bull...0201/41154.htm )

Did you know Lewis and Clark used throw ropes when in swift (rough) waters with their canoes in the Voyage of Discovery with lifesaving effect? (Cite: October 25, 1805, Lewis and Clark Expedition) To this day, the use of a throwable rope is still recognized as an effective swift (rough) water safety device.

Since 2014, we in the swift (rough) water community have been thrilled that the State of Utah has allowed a Throw Rope with a minimum of 40 feet of line to be used in lieu of a throw cushion where all vessel occupants are required to wear lifejackets (PFD’s).

As most swift (rough) water river runners know, when in swift (rough) water, we are required to wear a lifejacket. We also know that the ability to throw a rope to someone who has been cast into the river to pull them either to shore or to another watercraft has proven to be a lifesaving device.

We understand that United States Coast Guard (USCG) regulations say that watercraft 16 feet long and over must carry a Type IV throwable personal flotation device (throw cushion or life ring) as per 33 CFR 175.15.

We note that in swift (rough) water, both the USCG and the Arizona Game and Fish Department acknowledge Type IV throwable cushions are not recommended. The United States Coast Guard notes a Type IV throwable cushion or ring is “Not for rough water survival.” (cite http://www.uscg.mil/hq/cg5/cg5214/ringlb.asp )

The Boaters Guide of Arizona handbook of boating laws and responsibilities, page 38, notes the following with regards to TYPE IV throwable devices: “These cushions and ring buoys are designed to be thrown to someone in trouble. Since a Type IV is not designed to be worn, it is neither for rough waters nor for persons who are unable to hold onto it."

The State of Utah notes the intent of R651-215-8 as presently written “is solid with swift water rescue techniques” and we support that determination 100%.
(cite https://rules.utah.gov/publicat/bulletin/2017/20170201/41154.htm )

The State of Utah also notes they must be in compliance with 33 CFR 175.15. With utmost respect, it may be possible you have overlooked that on swift (rough water), the managing agencies of these river sections have imposed a more restrictive and stringent standard than 33 CFR 175.15.
In these specific areas of swift (rough) water, all participants must wear a lifejacket (personal flotation device), a more restrictive and stringent standard than 33 CFR 175.15. Only within this more restrictive standard is R651-215-8 applied in these areas where participants are wearing a lifejacket (PFD) by regulation.

As such, we ask you to keep R651-215-8 (River Throw Bag in Lieu of Type IV PFD) in effect as written.

On a personal note, I have greatly enjoyed whitewater (swift/rough) recreation in the State of Utah for decades, and have written two riverguides for whitewater enthusiasts in Utah, the Guide to the San Juan River and the Guide to the Colorado & Green Rivers in the Canyonlands of Utah & Colorado. River safety is of the highest priority to me, my family, and all of the individuals cc’d in this letter.

This proposed rule change does nothing to enhance or benefit the issue of swift (rough) water river safety that even Lewis and Clark understood two centuries ago.

Cordially yours,


Tom Martin PT
419 West Navajo Road
Flagstaff, AZ 86001

cc

United States House Subcommittee on Coast Guard and Maritime Transportation
Representative Hunter, Chairman, Representative Garamendi, Ranking Member

United States Senate Commerce Subcommittee on Oceans, Atmosphere, Fisheries, and Coast Guard, Senator Sullivan, Chairman, Senator Peters, Ranking Member, Senator Lee, Member

Governor Herbert

Utah Department of Natural Resources
Executive Director Michael Styler [email protected]
Law Enforcement Director Sid Groll [email protected]
Watershed Director Alan Clark [email protected]

United States Coast Guard, Sector San Diego, Lieutenant Robert Cole [email protected]
Tom Martin is offline   Reply With Quote
Old 02-18-2017   #8
 
Tom Martin's Avatar
 
Flagstaff, Arizona
Join Date: Dec 2004
Posts: 920
Someone else sent this in:

Dear Officer Wright,

I have been a whitewater boater for fifty-five years, with experience that includes five Grand Canyon floats as a boatman. I've come to realize the uselessness of throw cushions in a rough-water environment, wasting precious time and energy when a river throw-bag rope would best serve.

I would, with the utmost respect, strongly recommend that the state of Utah keep the rule R651-215-8 (River Throw Bags in Lieu of Type IV
PFD) in effect.

Thank you for your public service,
Tom Martin is offline   Reply With Quote
Old 02-18-2017   #9
Misspellingintothefuture!
 
mattman's Avatar
 
Tabernash, Colorado
Paddling Since: 2000
Join Date: Jan 2015
Posts: 1,901
Thanks for the heads up, email sent!
I also mentioned that River Rangers at West Water, Desolation Canyon, Cataract Canyon, and Grand Canyon which I have talked to, feel the same.
Tactfully( I believe) suggested involving the agency's, which regulate white water sections in Utah, in helping to shape future Utah Boating law, as it pertains to white water, since they deal with river running everyday, and are responsible for rescues on the sections which they regulate.

I have found Blm and Park service river regs to mostly be very reasonable in the state of Utah, but State regs often not very appropriate to white water.
__________________
We can't always agree, but we can still be civil to each other.
mattman is offline   Reply With Quote
Old 02-22-2017   #10
 
Tom Martin's Avatar
 
Flagstaff, Arizona
Join Date: Dec 2004
Posts: 920
Bump!!
Tom Martin is offline   Reply With Quote
Reply


Tags
bag

Thread Tools
Display Modes

Posting Rules
You may not post new threads
You may not post replies
You may not post attachments
You may not edit your posts

BB code is On
Smilies are On
[IMG] code is On
HTML code is Off
Trackbacks are Off
Pingbacks are Off
Refbacks are Off


Similar Threads
Topic Thread Starter Forum Replies Last Post
Should I Get A Throw Bag Trout Hunter Whitewater Kayaking 16 06-19-2013 04:49 PM
Throw Bag ? pvsprme Kayaking | Gear Talk 7 08-28-2012 07:13 PM
Lost: PFD, throw bag, helmet, bag of cams rvrcat Lost & Found 0 06-30-2010 06:30 PM
Throw Bag JBaker2 Kayaking | Gear Talk 4 03-21-2010 05:07 PM
how to throw a throw bag? johnovice River Access & Safety Alerts! 24 08-12-2009 10:36 PM

» Classified Ads
Powered by vBadvanced CMPS v3.2.3

All times are GMT -6. The time now is 10:46 AM.


Powered by vBulletin® Version 3.8.8
Copyright ©2000 - 2019, vBulletin Solutions, Inc.
vBulletin Security provided by vBSecurity v2.2.2 (Pro) - vBulletin Mods & Addons Copyright © 2019 DragonByte Technologies Ltd.