Two-way Traffic

PUBLIC COMMENTS RE VESSEL SPEED RULE ASSESSMENT AND REBUTTAL

Wilmington Cape Fear Pilots Association

Commerce requires that large oceangoing vessels routinely meet within the confines of the federal channel. When meeting vessels are required to maintain speeds below 10 knots, the dynamic beams of both vessels are increased and therefore compounds the dangers of collision or grounding.

Savannah Pilots Association

It should be noted that the port of Savannah utilizes two-way traffic making the ability to navigate safely or failure to do so even more consequential.

Rebuttal:

Two-way traffic is a self-imposed condition, not an unavoidable adverse condition, like bad weather is. Two-way is often cited as a navigational safety concern, greatly impacting safe navigation. But it can be limited to calm conditions or eliminated altogether for safe navigation. Port authority vessel traffic services can manage its use under its existing authority. Full width of the channel, average wind conditions, compliant ship speed.

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.