Gerry Ken Lopez

The regulation requiring a Stand Up Paddle (SUP) board to carry a PFD aboard is faulted. This regulation does not apply to the same exact board when it is used in the surf. This regulation also does not apply to prone paddle boards when they are being used in the same environment (open ocean or open water paddling) as the regulated SUP boards. Essentially a SUP board is a surfboard, just designed wider and thicker to facilitate a standing position when paddling. As a floatation device, it possesses considerably more buoyancy than any other type of single person watercraft. I think I'm safe in declaring that a 14' SUP board requiring a PFD aboard when in use in open water, would easily float 20 people safely and if you would like, I can produce a photograph to prove it. That your regulation states the PFD must be aboard but not actually be worn only reinforces the faulted ness, obviously the need for a PFD should the paddler become separated from his board does him little good if his PFD is on the board and not on his person. I believe a more sensible requirement would be that a SUP paddler in open water use a surf leash to stay connected to his board should he fall and become separated. I am sure almost every single SUP surfer/paddler will agree with me on these points. Thank you. Gerry Lopez