Robert Anthony Turner

Regarding mooring plans: What needs to be included in a mooring plan in order for it to be approved. What criteria will be used to determine adequacy? As a minimum, the plan should be designed/approved by an experienced qualified engineer. Regarding Storm Surge heights listed for the IHNC, Algiers Canal, and Harvey Canal: The 8’ and 10.5’ storm surge heights used to define "severe hurricane conditions" are inaapropriate for these areas. The USACE should investigate and set these heights based on ability of floating vessel to strike flood protection works such as floodwalls and floodgates. (probably 4’-5’ range) Wherever predicted winds or storm surge heights are called out in the rule, include the phrase "as predicted by the NWS or NHC". Rgarding Transient Vessels: There should be some specificity in the rule that defines what a valid "prearranged agreement" is and what the USCG will consider before approval of the agreement.