<html><body><div id="edo-message"><div></div>Agree! </div><div id="edo-message"><br></div><br><div id="edo-meta"><div id="edo-signature" style="font-family: sans-serif, 'Helvetica Neue', Helvetica, Arial;"></div></div><div id="edo-original"><div><br><br><blockquote type="cite" style="margin:1ex 0 0 0; height: min-content; border-left:1px #ccc solid;padding-left:0.5ex;"><div>On Aug 6, 2025 at 11:50 AM, <<a href="mailto:personal_submersibles@psubs.org">Jon Wallace via Personal_Submersibles</a>> wrote:<br><br></div><div><pre class="edo-pre">Psubbers,
This is a long message, but please read.
The US Coast Guard has released their Marine Investigation report of the Titan submersible implosion at
https://media.defense.gov/2025/Aug/05/2003773004/-1/-1/0/SUBMERSIBLE%20TITAN%20MBI%20REPORT%20(04AUG2025).PDF
Since this report is going to generate chatter throughout the submersible industry I thought it appropriate to make a statement and start an official discussion relative to our own organization.
Now that the Marine Boards report is public we are sure to see an uptick in attention to the operation of our vessels and potentially some movement to save ourselves, from ourselves, and need to be proactive in addressing this issue rather than allowing some other agency or organization to define our future. While we are not the largest organization in the world, we ARE the largest organization in the world associated with private submersible fabrication, operation, and ownership and therefore have standing to be recognized and heard regarding any government regulation that might affect us.
From PSUBS beginning it has always been my position, and still is, that private recreational use of our vessels is difficult for the government to regulate due to the “pursuit of happiness” founding principles of the USA. It is my opinion, for example, that this was one reason recreational submersibles had a specific section carved out for them in USCG NVIC 5-93 (see Chapter 1, B, 4) and were equated to pleasure surface boats.
To wit:
USCG NVIC 5-93, Chapter 1, B, 4
“Recreational vessels, as defined in 46 U.S.C. 2101(25), are vessels manufactured or operated primarily for pleasure, or leased, rented, or chartered to another for the latter's pleasure. Submersibles within this category are subject to the requirements of 33 CFR Subchapter S - Boating Safety, Parts 173-183. The guidelines in this circular generally do not apply; however, depending on the area of operation, COTP operating restrictions may be appropriate. This will be evaluated on a case-by-case basis. These guidelines may be of assistance to a manufacturer or owner of a recreational submersible.”
As optimistic as I am regarding our rights as private submersible owners, the Titan disaster does represent a potential impact to us and we should have a message ready to deliver to the US Coast Guard to protect our interests. Specifically, I have concerns related to carrying passengers (not for hire) and impacts to private submersibles participating in research and/or acting as a non-passenger commercial operator. We enjoy quite a bit of latitude given the language of NVIC 5-93, 1, B, 4 and it should be our goal to preserve it as currently written.
The USCG Marine Investigation Board made 14 safety recommendations to the USCG Commandant. While the majority of these recommendations target vessels conducting commercial and oceanographic research operations, the following draw my concern as potential serious impacts to our PSUBS related pursuits.
8.1.1. Recommendation #1: The USCG should establish an industry working group to review and update NVIC 5-93. During the investigation, submersible industry leaders indicated to the MBI that current USCG limitations on operating parameters, including the maximum depth of 150-feet for Coast Guard inspected passenger submersibles, was stifling submersible owners from exploring new passenger operations in U.S. navigable waters and also potentially incentivizing operators like OceanGate to conduct non compliant operations. An update to the NVIC would also provide an opportunity to clearly outline the process for certifying submersibles of novel design.
PSUBS POSITION
PSUBS *must* be included in any working group the government creates to update NVIC 5-93 and/or create regulations that may impact us. We cannot afford to sit idly by and allow “industry leaders” and/or the government itself to revise this document without our input. It is notable that the USCG regularly attends the MTS Underwater Intervention and participates in discussions with MUV commercial attendees; however the USCG has never accepted an invitation to a PSUBS convention. Regrettably, we own some responsibility for lack of communication with the USCG since we have often taken the philosophy of “let sleeping dogs lie” and “out of sight, out of mind” when considering our interaction with them; however I think we can no longer afford to take this approach. This month I will be writing the USCG Commandant seeking inclusion of a PSUBS representative in any working group organized to review NVIC 5-93 and/or any other regulatory act that may impact our organization. Additionally, I will be requesting the USCG send a representative to PC2026 to conduct discussions with PSUBS members regarding issues and concerns relative to our segment of the submersible industry and to start fostering communication between us.
8.1.6. Recommendation #6: The USCG should pursue a new regulation which requires all submersibles manufactured, owned, or operated by a U.S. entity or any submersible operating in U.S. navigable waters carrying any occupant other than the owner to be built to the standards of a USCG RO and maintained under those standards.
PSUBS POSITION
Any language requiring certification for privately owned submersibles is a serious detriment to our pursuits since from a financial perspective it essentially is a show stopper. This recommendation goes well beyond the current wording in NVIC 5-93 which clearly demarcates commercial, passenger carrying, and recreational submersibles. If implemented as suggested it would prevent us from carrying our own spouses, families, and friends as an occupant unless the vessel was certified. It is PSUBS position that this unreasonably restricts our right to pursue sharing our hobby with voluntary passengers who are not for hire.
8.1.7. Recommendation #7: The USCG should pursue an update to the vessel documentation requirements in 46 CFR § 67.7, to require all U.S. submersibles that conduct commercial or scientific operations to obtain a USCG Certificate of Documentation (COD) with an Official Number assigned and recorded in the MISLE database.
PSUBS POSITION
We currently have a number of privately owned submersibles that are used to conduct various types of research, free of charge, for universities and science organizations whom have a need for a deep diving vessel beyond the range of SCUBA. This recommendation by the Marine Investigative board could have severe impact on those missions and it is PSUBS position that this recommendation unreasonably restricts a private submersible owner from providing a donated service targeted for the advance of science.
WHAT YOU NEED TO DO (right now)
Minimally all PSUBS members should read the “Recommendations” section of the USCG Marine Investigation Board starting on page 324 and consider how this impacts you personally or our organization and raise it as a concern if it has not been addressed already.
Additionally, start thinking now about issues and concerns we should address with the USCG at PC2026 in February. The more that we can speak with one consistent message in terms of specific issues that we feel need to be preserved or modified to our benefit, the better we will present ourselves.
Jon
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