http://forum.surfermag.com/forum/showflat.php?Cat=0&Number=1950027
SUP's will be forced to stay within surf areas to avoid being classified as vessels.
“stand up paddling is presently the fastest growing water sport in the nation”
“Alternatively, as the SUP itself is a floatation device, we believe that the safest method of use is for riders to be required to wear ‘surf type leashes’…”
“While SUPs are not as powerful as some ‘larger craft’, they are much more maneuverable than just about any floating platform in existence, other than perhaps a small motorboat.”
“they are in most cases significantly more maneuverable than canoes, kayaks, or windsurfers (but are significantly more visible).”
“there is literally no way for an SUP to become disabled.”
and a favorite…
“There is no other manner of disability that can impact an SUP…”
“If the rider is tired, or injured, he or she will simply sit or lie on the floating SUP. The conclusion that an SUP provides a ‘minimal’ level of safety in such a situation misunderstands the nature of the SUP and is unsupported.”
They also argue that the legal definition of the word vessel, which “includes every description of watercraft or artificial contrivance used, or capable of being used, as a means of transportation on water,” cannot possibly apply to an SUP.
There are quite a few bad arguments and misstatements of fact - easy to see why the USCG didn’t find the letter warranted a detailed response.
IMO they need running lights, pfd, whistle or horn, and periodic boardings by USCG to check it all.