PUBLIC SUBMISSION As of: 8/16/12 10:04 AMTracking No. 803a6ee4Comments Due: October 27, 2005Docket: USCG-2007-0030Passenger Weight and Inspected Vessel StabilityComment On: USCG-2007-0030-0003NoticeDocument: USCG-2007-0030-0013Captain Duck Tours, Inc.Submitter InformationName: Gabriel R EmanuelliAddress:176 San Jorge Street., Office 1-BSan Juan, PR, 33029Fax: 787-722-0009Organization: Captain Duck Tours, Inc. PresidentGeneral CommentLet me start by stating that Safety is our most important policy within our business. Still, we believe thatthis proposed measure does not take into consideration the avg. weight of Children? Thus only focusing onadult weights to determine-recommend new weight standards be increased from 160 pds to 185 pds x pax =25 pds. x passenger of added restrictions. For example, in our case, we are extremely popular Tours amongthe children, in a conservative manner we should avg. no less than 30% occupancy by children, notcounting the large number of schools, summer camps, others which we have over 80% children occupancy.If current Vessel passenger weights is increased to 185 pds. and such ruling has an impact on stability tests,current as well enforced to all existing vessel operations, this would have a significant economic impact forwhich investments may have been made based on existing regulations.For example, we have a COI certificate to carry up to 49 pax x vessel. If new weights changes from 160 to185 = 25 pds. dif. x 49 pax = 1,225 pds. we would be required to reduce. 1,225 % divided among 185 pds.= -(7) pax or seats removed and new pax capacity will be 42 pax max. We charge $24 x adult x $2.50booking = $26.50 x pax x -(7) pax = ($185.00) loss x tour x 3 tours avg. x day = ($557.00) loss x day x 21working day avg. x month = ($11,686.50) monthly loss x 12 = ($140,238.00) yearly losses.Again a tremenduos economic impact, specially for small businesses such as ours.On the other hand, considering that we currently avg. 30% occupancy are children (at a min. since we carryschools, etc.) this = 30% of 49 pax occupancy = 15 pax (seats) on avg. are children. Assuming an 80 pds.weight on avg. x children, comparing this with existing proposed wieghts of 185 pds. = 105 pds. differencex 15 children(30%) pax = 1,575 pds. less weight carried. Currently new proposed weight would changefrom 160 pds. over to 185 pds. = -(25pds) dif. which x 49 = 1,225 this measure is looking to reduce in ouroverall capacity yet you can notice that if children weight were to also be taken into consideration we areexceeding proposed weight savings not to mention again overall economic impact.We are all in favor for a measure which also takes into account avg. children weights into overallcalculations.New regulations of this type if considered should be considered to be applied by phases by 1st. into effecton new constructions and or new vessels stability test requierements on which new owners can better assessbusiness projecttions under new wieghts, pax capacity limitiations, yet quite different when measures suchas these would also be appllied retro-actively thus impacting existing operations which may have recentlymade large investments under profitable business models to find ourselves out of business with little to nocontrol.