Paul Lawrence Newman

Please see the attached document for full comments. This is for the agenda item: Safety Equipment Carriage Requirement: Stand-Up Paddleboards (SUP) and Other Vessels There are 3 main points: 1. Revise the definition of "Racing shell, rowing scull racing canoe and racing kayak" to just say "Racing paddlecraft." That eliminates lists that are out of date. 2. Since SUP are not designed to carry PFDs, we either eliminate the carriage requirement or make the regulation that operators/passengers must wear the PFD. 3. Include in the CFR the PFD exemption for SUP in the surfline and swimming/bathing areas. Not doing so has led to states not honoring the USCG-intended exemption and local law enforcement giving citations to SUP operators in the surfline for not carrying a PFD.