The definition of "unsafe conditions" is too restrictive. The formula while being simple
does not adequately address other critical factors such as wind speed/direction and
wave/swell period and current speed. Also, the direction of travel should be taken into
account as it is much safer to travel with a wave vs into a wave while crossing the bar.
Under the proposed formula, most of the vessels under 24 feet in length would
be "locked out" of the ocean most of the time. Also, not all vessels are created equal
(ie a 20 foot boat with a low center of gravity is far more seaworthy than a 25 footer
that is top heavy.) In additon, the experience of the captain is critical.
With a 20 foot boat, the current formual would only allow bar passage when waves are
4 feet or less. I have crossed the bar over 1000 times in a 20 foot boat (designed for
ocean conditions) and probably only 20-30 percent of the crossings were with waves of
less than 4 feet. About 20% of the crossings were with waves in the 6-8 foot range.
Based on my experience, 6 foot waves are almost always safe when one avoids strong
ebb currents and strong winds. The 8 foot waves have only been a concern when the
wave period is insufficient. I have also crossed the bar with 12 foot waves, but the
wave period was quite long and the waves were merely large swells.
The document indicates there would not be a taking of private property. This would not
be accurate in my opinion since it would drastically reduce the ability to use one's
property (ie what good is a 20 foot boat if one can't use it). To implement the proposed
formula would greatly impact the coastal communities involved with sport fishing as it
would eliminate a large percentage of the private vessels used for recreational fishing.
For my boat, I use a "formula" of 10. If the combined swell/wave height exceeds 10 or
if the wind speed in MPH exceeds the length of my boat, I stay home. If the simple
proposed formula was used, I would change the divider to 5 so that a 20 foot boat could
generally go out on 6 foot seas.
In summary, wind and wave period need to be considered. The proposed formula will
kill recreational salmon fishing by "locking out" the small private fishing vessels.
Lyle R. Heimbigner
This is comment on Rule
NPRM: Regulated Navigation Areas: Bars along the Coasts of Oregon and Washington (Federal Register Publication)
View Comment
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