Comment from William Schmicker, Pegasus Group

Document ID: WCPO-2010-0003-0007
Document Type: Public Submission
Agency: Workers Compensation Programs Office
Received Date: October 26 2010, at 12:00 AM Eastern Daylight Time
Date Posted: November 1 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: October 15 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: November 17 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b78230
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We are a small business operating two marinas catering to recreational boaters. Our employees, about 12 total, are covered by state workers compensation, which is not inexpensive. As a rule, we do not perform work on customers boats, but the ambiguities created attempting to define what is a commercial boat and a recreational boat causes us great concern. We do not want to have our insurance coverage increased to cover LHWCA potential liabilities. We have never had a LHWCA claim, but we try to run our business conservatively and maintain good coverage for our risks generally. Clearly any incidental commercial business would be a rarity. Make changes cautiously and make it for the preponderance of business as commercial and except out the occassional occurance. Otherwise we will be forced to purchase LHWCA coverage to protect our assets and this would be devastatingly expensive.

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