Wind, Waves, Current

PUBLIC COMMENTS RE VESSEL SPEED RULE ASSESSMENT AND REBUTTAL

American Pilots’ Association

These SMAs...include areas encompassing offshore, narrow, federally-maintained dredged channels...cross currents, seas and winds greatly impact safe navigation. These entrance channels... are nearly perpendicular to the strong winds that are prevalent in the winter months (the very timeframe when NOAA’s 10 knot speed restrictions are imposed).

In these areas, it is common, especially in the winter months, that the “oceanographic, hydrographic and/or meteorological conditions severely restrict the maneuverability of the vessel,” so the use of the speed deviation clause will be required much of the time. In fact, to seasoned and highly skilled professional maritime pilots, the idea that greater maneuvering speeds would be required in these navigationally challenging areas, especially for vessels (like container ships and car carriers) with large sail areas, is seen simply as the most prudent course of action.

Rebuttal:

Wind data from NOAA’s National Buoy Data Center indicate generally non-adverse wind conditions.

NBDC’s offshore buoy at Charleston recorded a wind speed of 30 mph or higher 2.26% of the time during the 2020-2021 SMA season. Mean wind speed was 15.29 mph at Charleston during the study period, and mean gust speed (GST) 20.08 mph. Wind speed 25 mph or higher was recorded 10.03% of the time, and wind speed 20 mph or higher was recorded 27.17% of the time. Wind speed less than 20 mph was recorded 72.83% of the time. Therefore, wind speed is unlikely to have been a factor for most transits at Charleston.

Mean wind speed was 13.32 mph at Savannah during the 2020-2021 SMA season, with mean gust speed 17.81 mph. Wind speed of 30 knots or higher was recorded 0.96% of the time during the study period. Wind speed 25 mph or higher was recorded 6.01% of the time, and wind speed 20 mph or higher was recorded 14.22% of the time during the study timeframe. Wind speed less than 20 mph was recorded 85.78% of the time. Like Charleston, wind speed is unlikely to have been a factor for most transits at Savannah.

Average wind speed during March and April 2021, the timeframe for mother-calf migration, was 12. 6 mph at Charleston’s entrance channel and 12.9 mph at Savannah’s entrance channel. Average and below-average wind speed within the SMA are missed opportunities for slow steaming.

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.