Comment from Lyle Kessler

Requirement to use a TDD, 648.51(5)(ii)(3) - The line stating "only one side of the flaring bar may be attached to the dredge frame" should be removed. This was discussed at the PDT. With the additional requirement that the flaring bar be no closer than 12" to the cutting bar, this requirement to have it attached at one end is obsolete. Also, eliminating it would allow FV to attach a D-ring to use as a flaring bar, which some like to do. Same paragraph, next sentence. "The appendage should at no point be closer than 12 inches (30.5 cm) to the cutting bar so that it does not interfere with the space created by the bump out." "so that it does not interfere with the space created by the bumpout" can/should be removed from the text. This is the purpose of keeping the flaring bar greater than 12" from the cutting bar, and this text may very well be my exact recommended language, however, dredges are being made with bumpouts greater than 12", I've seen some as long as 15". Leaving this language in the CFR could lead to situation where a TDD has a flaring bar greater than 12" from the cutting bar, yet inteferes with the space created by a 15" bumpout. (i.e. flaring bar 13" from cutting bar, but b/c the bumpout is 15" long the flaring bar extends into and 'interferes with the space created by the bumpout'). As long as the flaring bar is greater than 12" from the cutting bar, then the TDD should be in complaince because it won't interfere in the space required to be created by a 12" bumpout. Eliminating the text "so that it does not interfere with the space created by the bumpout" will remove this potential misunderstanding but still allow the 12" from the cutting bar to be enforced.