Douglas Kirk Chapman

46CFR143.285 Additional Fuel System Requirements I’m guessing the intent of 46CFR143.285(b) Portable Fuel systems – was to prevent full portable fuel cans from being stored around the vessel in unapproved flammable or combustible locations. The proposed cite 46CFR143.285(b) says “must not incorporate or carry portable fuel systems, including portable tanks” It then (excepts) ”when used for outboard engines or when (permanently attached) to portable engines or when (permanently attached) to equipment” The problem I see is (how does the Coast Guard propose) the crew refuel the dewatering portable pumps located on damaged barges in the tow for transit allowed under a Coast Guard PTP or CG-835? If no portable fuel cans are allowed onboard the portable dewatering pumps located out hundreds of feet in the tow will run out eventually. You can see there is a need for portable fuel cans onboard which are not (permanently attached) to the equipment. Suggest the Coast Guard allow portable cans onboard as long as they are keep empty unless being actively used during refueling of portable equipment. Empty cans can be stored in an approved flammable & combustible location designated onboard. On the weather deck usually the 01 deck back by the fuel tank used for the skiff comes to mind. If portable fuel tanks are not allowed onboard the vessel, then the Coast Guard will be setting up a situation where the crew could possibly develop an unsafe practice to refuel their pumps. They might start using unapproved containers to refuel the portable pumps, there by creating a more hazardous situation than this proposed rule was attempting to eliminate.