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Updated: Nov 22, 2021

PUBLIC COMMENTS RE VESSEL SPEED RULE ASSESSMENT AND REBUTTAL


Georgia Ports Authority


Post Panamax vessels require different considerations when it comes to safe navigation in and out of our channel compared to those that that called on Savannah, Brunswick another east coast ports 13 years ago. Any consideration of a rule requiring vessels to travel at an unsafe speed for the navigability of these vessels must take the safety of the mariner into account. For the vast majority of ships calling at Brunswick and Savannah the minimum safe navigation speed is invariably well over 10 knots for all vessels.


Rebuttal:


At Savannah, during the 2020-2021 SMA season, yaw was less than ½ degree of difference between ships traveling at 10 knots and ships traveling 15 knots; 1.35 degrees and 0.96 degrees respectively. Analysis of pilotage at speeds of 10 knots or less, data show no loss of navigational margins of safety (figure 1).


In the Charleston entrance channel ships steaming 10 knots or less averaged 1.4 degrees of yaw (course/heading). Ships transiting non-compliant speed average 1.19 degrees of yaw, less than ¼ degree of difference. Analysis of pilotage at speeds of 10 knots or less, data show no loss of navigational margins of safety (figure 2).


Figure 1. VSPD ≤10 knots

Figure 2. VSPD ≤10 knots


Please see: Marine Mammal Commission and Southern Environmental Law Center’s public comments.


Also: "Court Rejects Federal Attempt to Sink Right Whale Ship Strike Lawsuit"(WDC); see lawsuit brought by Center for Biological Diversity, Conservation Law Foundation, Whale and Dolphin Conservation and Defenders of Wildlife challenges the National Marine Fisheries Service’s delay in responding to rulemaking petitions on vessel strikes.

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