Gregory T. Absten

I am not supportive of the proposed rule for requiring a mandatory engine cut-off and it's use. There are options available to boaters on a voluntary basis and no additional requirements should be imposed. I believe that this level of a requirement imposes too much of micromanagement upon the skipper/captain of a vessel. Skippers must be able to continuously make informed judgements as to the total environment and circumstances and such a dogmatic requirement would usurp their ability to do this. The proposed rule already acknowledges that some situations such as docking, trailering or emergencies might give cause to over-ride this requirement, and this is correct. However you are not able to project all of the potential situations where it is better NOT to use such a device and it therefore should be left to the judgement of the skipper. Costs for such devices are also not negligible and should not be imposed upon boaters. My background includes almost 20 years of Boating safety instruction through the power squadrons, a past commander of the squadrons, port captain for the Yacht Club, and 100ton offshore USCG captain.