John F. Hughes

The proposed rule increases the security zone around all tankers, passenger vessels, and high interest vessels underway, moored or anchored in San Francisco Bay from 100 yards to 500 yards; for the stated purpose of providing increased reaction times for patrol boat coxswains to respond to incursions into the security zone by targets of interest. I have specific objections to the proposed change in San Francisco Bay Anchorages Five, Eight, and Nine when no USCG patrol boat is present. In cases where no USCG patrol boat is present, the proposed change serves no purpose and severely limits recreational boaters’ access to large parts of the bay. Using Anchorage Nine as an example, each anchored tanker occupying a security zone that, on average, measures 1,250 yards by 1,050 yards removes access to a substantial part of the Bay from recreational boaters – for no reason at all. (i.e. There is no need to provide more reaction time for patrol coxswains if no patrol boat is present.). When, as frequently happens, five or six tankers are anchored in Anchorage Nine, it would be challenging to sail through the anchorage without encroaching on the expanded security zones. Staying out of the anchorage altogether puts recreational vessels into the main shipping channels – not a desired result. I have sailed my 35 foot sailboat through Anchorage Nine over 800 times in the past five years, passing thousands of anchored tankers. I have never seen a USCG patrol boat enforcing a security zone around a tanker in Anchorage 9. I request that the proposed rulemaking be modified to expand the security zone around tankers, passenger vessels, and high interest vessels from 100 to 500 yards - only when a USCG patrol boat is in attendance; modifying the proposed 33cfr165.1183(a)(1) to read: “San Francisco Bay. All waters, extending from the surface to the sea floor, within 100 yards (92 meters) [500 yards (457 meters) when a USCG patrol boat is present] ahead, astern, and extending 100 yards (91 meters) [500 yards (457 meters) when a USCG patrol boat is present] along either side . . . “ Making the modification that I suggest would allow attending USCG patrol boat coxswains the desired additional reaction time without limiting access to large parts of the bay to recreational boaters when no patrol boat is present. Thank you for the opportunity to comment.