The URL can be used to link to this page

Home My WebLink About2023_02_02 - Manta Testimony - Manta Ray Viewing Boating Operations and Safety Assessment - Kirsten Moe-1- Manta Ray Viewing Boating Operations and Safety Assessment Prepared for the Hawaii Coral Reef Initiative Research Program (HCRI-RP) on September 6th, 2015 by Marine Science Consulting LLC samkahng@gmail.com (808)551-0904 -2- Report Outline Executive Summary Study objectives and scope  Acknowledgements of contributions Introduction/background Project methodology Manta ray viewing operations  Makako Bay  Keauhou Bay  Mooring Usage Hazards to human health and safety Risk factors contributing to severity and likelihood of incidents/accidents Risk assessment of individual hazards  Live vessel (while engines in gear) or propeller strike on swimmer/diver  Anchor strike on subsurface diver  In-water medical emergency (i.e., heart attack, stroke, etc.)  Drowning (e.g., due to panic, loss of floatation, or subsurface loss of air)  High speed boat-to-boat collision Existing Regulatory Frameworks Conclusions Executive summary The manta ray viewing operations at two primary locations (Makako Bay and Keauhou Bay) on the Kona coast of Hawaii Island were assessed for human safety. Stakeholder input, historical data, field surveys, and direct observations were used to identify safety issues, quantify activity levels, and independently verify current hazards. While the probability of an accident (e.g., motoring vessel striking an in-water person) causing severe injury or death is relatively low, the current activity provides ample opportunity for a severe accident to occur. Given the large number of vessels and in-water persons participating in this night-time activity, a severe accident will likely occur in the future without significant mitigation of the existing risk factors. The numbers of vessels and persons participating in manta ray viewing activities are major factors increasing the likelihood of an accident, however, there are currently no effective controls regulating capacity despite the growing demand for this activity. There are also no regulations governing recreational or commercial swimming/snorkeling activity at night amongst actively motoring vessels despite the inherent hazards associated with this activity. A formal assessment and vetting of regulatory options are recommended to determine how best to mitigate the severity of existing hazards and reduce the likelihood of severe accidents. -3- Study objectives and scope The overall objective of this project was to assess the current manta ray viewing operations relative to human safety. This study objectively and quantitatively reviews current operations and provides an independent verification and analysis of safety issues previously raised by various stakeholders. The scope of this assessment focuses on the operations at the two main viewing sites (Makako Bay and Keauhou Bay) and addresses only human safety issues, not the safety of marine life or the environmental impacts of the manta ray viewing activities. Acknowledgements of contributions This assessment has been led and conducted by Marine Science Consulting LLC under the leadership of Dr. Samuel E. Kahng in collaboration with the Hawaii Coral Reef Initiative Research Program (HCRI-RP) and Hawaii DLNR Division of Boating and Ocean Recreation (DOBOR). Contributors to this project include the following individuals:  Meagan Putts, GIS analyst – coordinated email survey, conducted field studies, generated report figures  Maria Robben Gaydos, DOBOR – coordinated and conducted stakeholder interviews; assessed regulatory frameworks  Risa Minato, HCRI – coordinated and conducted stakeholder interviews  Keller Laros, Manta Pacific Research Foundation – conducted mooring verification surveys, provided daily statistics on vessel activity  Dan Mersburgh, DOBOR – contributed boat support for conducting mooring verification surveys  Finn McCall, DOBOR – provided engineering assessments on mooring capacity  Teri Leicher, Malama Kai – provided specifications for day-use moorings  Jan War, NELHA – provided shoreline access to the Makako Bay site Introduction/background On the Kona coast of the Big Island of Hawaii, the commercial and recreational activity of viewing manta rays (Manta alfredi) at night has increased significantly thereby raising concerns about human safety in the midst of congested boating, snorkeling, and scuba diving activity in the dark. The night time manta ray viewing activities are centered around two main viewing sites: Makako Bay (also called “Garden Eel Cove”) and Keauhou Bay (“Manta Village” in front of the Sheraton Kona Resort & Spa at Keauhou Bay) (Figure 1). The Makako Bay site is primarily accessed via vessels from Honokohau harbor. The Keauhou Bay site is primarily accessed via vessels from the adjacent Keauhou Bay harbor and boat ramp, but it is also accessed by vessels from Kailua-Kona pier and from Honokohau harbor. Manta rays are large (up to 5.5 m wide), visually majestic creatures which feed by ingesting small zooplankton through their toothless mouths while swimming (Figure 2). Tiny marine animals called zooplankton (much of which hide in the reef during the Figure 1. Map of the Big Island of Hawaii and the location of the two primary manta ray viewing locations: Makako Bay and Keauhou Bay. -4- day) rise into the water column at night to feed and are attracted to artificial lights. At both sites, artificial lights are used to attract and aggregate zooplankton in high densities which in turn attract manta rays to nightly feeding opportunities. Tour operators use a variety of waterproof lights to localize and attract the manta rays for the viewing pleasure of their clients. Figure 2. Manta ray swimming amongst scuba divers (left) and feeding on zooplankton (right). Images from California Divers and Adrian Basques. The opportunity to view manta rays, sometimes in large numbers, is a significant attraction for both visitors and residents of Hawaii. The manta ray scuba diving and snorkeling tours in Kona (Figure 3) are widely advertised in the international travel & tourism media and are literally world renown. Scuba diving magazines and websites regularly list the Kona manta ray night dive and animal encounter as a top rated activity and scuba diving destination. The consistency with which mantas are available for viewing, the relatively easy access to these sites, and predominately calm ocean conditions of the Kona coast are major factors in their popularity. While not assessed in this study, the direct and indirect economic contributions of this activity to the local economy are likely substantial. Figure 3. Manta ray swimming amongst scuba divers at night (left) and underneath snorkelers (right). Images from Alert Diver and Splashers Ocean Adventures. Project methodology The project was conducted in three phases consisting of User Requirements, Field Investigations, and Synthesis. For the User Requirements phase the existing information relevant for the manta ray viewing operations was reviewed including the Manta Ray Working Group meeting notes, the voluntary Manta Tour Operator Standards (endorsed by 20 operators), and existing regulations. Via interviews and email surveys, voluntary stakeholder input was compiled from 26 stakeholder organizations/companies (Appendix A) to assess current operations (equipment, normal procedures, crew training & experience, -5- and emergency protocols), perceived human safety risk factors, efficacy & limitations of voluntary protocols, and perceived regulatory solutions & limitations. Attempts were made to contact all known manta ray tour operators via email survey to give everyone the opportunity to provide input. In addition to tour operators, input was received from safety and regulatory organizations, relevant nonprofit organizations, adjacent land owners/managers, and a private boater. For the Field Investigation phase, the two primary viewing sites were surveyed and mapped, all existing moorings were inspected and photographed, and night time operations were observed in detail on nine nights. Visual observations of operations were conducted at both sites from land and onboard tour operator vessels. Four days of operations were observed at Makako Bay and six days of operations were observed at Keauhou Bay. The operational observations quantified & characterized in-water activities, quantified & characterized boating activity, recorded behavior or activities increasing/decreasing safety risks, independently verified & confirmed potentially hazardous operational aspects. Manta ray viewing operations As of August 2015, at least 42 commercial tour operators (Appendix B) have been identified as visiting these two sites providing night time snorkeling and/or scuba diving tours for viewing manta rays. While some companies operate on a nightly basis, others provide manta tours less frequently or service the private charter vessel market. A few of the larger companies operate multiple motorized vessels on a nightly basis. The capacity of the vessels also varies from small six passenger boats to large vessels with over 40 passengers (Appendix C). Depending on weather, the number of vessels, snorkelers, and divers varies widely by date but averages 12-13 motorized vessels at one time. However, maximum number of vessels at each site on the busiest night is roughly double the average (Figure 4). Figure 4. Frequency distribution of number of motorized vessels per night at each manta ray viewing site. Data derived from daily observation logs January-July 2015 from Manta Pacific Research Foundation. These data were collected from an operating vessel and therefore represent concurrent vessels on site. Total number of vessels visiting per night may be higher. Makako Bay (Garden Eel Cove) At Makako Bay, some scuba diving boats providing two tank dives arrive early, well before sunset, but most vessels arrive just prior to sunset while there is sufficient ambient light facilitate mooring/anchoring. Snorkelers entering the water and are generally associated with floating rafts (Figure 3). Peak in-water activity occurs 30-45 minutes after sunset before the first groups of snorkelers leave and after most scuba divers enter for their final night dive. A few vessels either operate a second shift or arrive very late (~2 hours after sunset) after most vessels have already departed the site. -6- During observations on Aug 10-13, 2015, a total of 16-19 vessels per night were observed with a visual count of 160-190 persons (snorkelers and divers) in the water concurrently. Due to limitations in visibility at night, this count represents a conservative estimate and the actual number was likely higher. Considering that up to 26 concurrent vessels have been recorded at this site (on April 3, 2015), the maximum number of persons in the water concurrently likely exceeds 290 persons on the busiest nights. During the observation period, the arrival and departure of vessels to the manta viewing area was somewhat synchronous with little live boating activity when a majority of persons are in the water (Figure 5). The tour operators who only cater to snorkelers tend to depart early while scuba divers are still underwater. Due to the limited number of moorings, the amount of live boating activity on busy nights is likely higher than observed during this study. Figure 5. Time-motion statistics at Makako Bay on August 13, 2015 from 6:10-9:00 pm. Yellow bars indicate when each vessel, watercraft, or group was present at the manta viewing site. Each cell represents a 10 minute block of time. The beginning and end of each continuous yellow bar denotes when each vessel/group arrived and departed respectively. A nightly total of 19 vessels were observed with approximately 209 persons. During peak in-water activity 7:00-7:40 pm, most vessels were moored/anchored and relatively few were underway (i.e., actively motoring). Snorkelers are accompanied by a guide, associated with rafts (e.g., floating boards with handles and equipped with downward facing lights, Figure 3), and remain at the surface of the water (free diving is discouraged by tour operators). In some cases the rafts are tethered to the originating vessel but in other cases, the rafts are free floating enabling the group to adjust their location independent of the originating vessel. While a majority of the snorkelers observed had individual lights, many regularly do not. On occasion, individual snorkelers or guides without lights were observed straying > 40 ft from their group raft. Scuba divers are accompanied by a diver master/professional and generally begin their descent next to their originating vessel before transiting underwater to a central “campfire” site where underwater lights are aggregated to attract manta ray feeding. Given the dispersion of vessels, the underwater transits originate from all directions. In general, divers return to their originating vessel prior to ascending to the surface. However, an individual scuba diver was observed briefly surfacing in an unplanned location during their transit to/from an originating vessel. Keauhou Bay (Sheraton Kona Resort) At Keauhou Bay, the activity by “regular” operators (who are based on Keauhou Bay) are primarily focused on snorkelers and the boat activity can be considerably lower than at Makako Bay (Figure 4). Unlike the operations at Makako Bay which is adjacent to restricted shoreline access (i.e., Kailua-Kona International Airport and Natural Energy Laboratory of Hawaii Authority), the Keauhou Bay site is accessible from shore by kayaks, stand up paddleboards (SUPs), and individual swimmers via a nearby Vessel Name Hale Kai RIB #1 Jack's #1 Kamanu Big Isand Divers #1 Ocean Encounters Neptune Charlie's Wicked Wahine Big Isand Divers #2 Big Isand Divers #3 Hang Loose Coral Reef Adventures Kona Ocean Adventures RIB #2 Hawaii Oceanic Jack's #2 RIB #3 2nd Shift #1 3rd Shift #1 6:10 PM 7:00 PM 8:00 PM -7- public shoreline access point. Given the proximity of the snorkeling site to Keauhou harbor and boat ramp, a few commercial operators operate up to three shifts nightly. When manta rays are not frequenting the Makako Bay site, commercial operators who normally visit Makako Bay move their scuba diving and snorkeling operations south to Keauhou Bay. The result is a bimodal distribution in activity and the potential for very high boating activity on certain nights (Figure 4). During observations on June 22-23 and Aug 19-21, 2015, a total of 7-22 vessels per night were observed with a visual count of 114-177 snorkelers and divers (including customers and guides) in the water concurrently. A few of the Keauhou based snorkel charters operate vessels (i.e., Hula Kai, Hokuhele, Kona Style) with high capacity. On the busiest days (e.g., 28 boats on July 6, 2015), the maximum number of persons in the water concurrently likely exceed 310 persons. In general, the activity at Keauhou Bay is less synchronous than at Makako Bay with vessels continuously arriving and departing throughout the night. The result is continuous live boating activity at the site. To help illustrate the overlap in boating activity with in-water snorkelers and divers, an intensive time & motion study was conducted on August 21, 2015 from 6:20-10:00 pm from the 2nd floor of the Sheraton Kona Resort. In addition to static totals (21 vessels, 6 kayaks, 1 SUP, and 301 persons), the arrival & departure and the live boating activity for each vessel was tracked across time along with the timing of persons entering and exiting the water from each vessel and from shore. Data was aggregated for each 10 minute block of time, where the number of in-water persons were quantified verses the number of vessels actively motoring at the site. Peak overlap occurred between 7:20-8:00 pm with 98- 177 persons in the water while 5-10 vessels were actively motoring in the confined area (Figure 6-7). Greater overlap between actively motoring vessels and in-water persons would occur on busier days especially given the limited availability of moorings. For example, up to 28 concurrent vessels have been observed at Keauhou (April 3, 2015) which would represents a 38% increase over the maximum of 16 concurrent vessels observed on the date of this time-motion study. Figure 6. Time-motion chart at Keauhou Bay on Aug, 21, 2015 from 6:20-10:00 pm. Yellow bars indicate when each vessel, watercraft, or group was at the manta viewing site. Each cell represents a 10 minute block of time. The beginning and end of each continuous yellow bar denotes when each vessel/group arrived and departed respectively. Note that some vessels visit the site multiple times per night. Vessel Name Kona Style RIB #1 Wicked Wahine Zodiac w/outboard Kamanu Hang Loose RIB #2 Kona Ocean Adventures #1 Hokuhele Kona Ocean Adventures #2 Kona Ocean Adventures #3 RIB #3 Sunlight on Water Hula Kai Kini Kini sailing canoe RIB #4 Hawaii Ocean and Island Tours Myka I Makai Plan B Unidentified boat 6:20 PM 7:00 PM 8:00 PM 9:00 PM -8- Figure 7. Overlap between in-water persons and live boating activity (i.e., vessels underway) at the Keauhou Bay manta ray viewing site on August 21, 2015. A total of 21 vessels and 301 persons visited the site. Attempts to collect similar quantitative details at Makako Bay were not successful due to the lack of a feasible observation platform. The distance and elevation of the available shoreline observation stations did not provide sufficient night time visibility to obtain reliable counts. The elevation and motion stability from available vessel observation platforms also did not support the ability to obtain consistently reliable counts across time. Mooring usage At Makako Bay, seven moorings with subsurface floats are used on a nightly basis (Figure 8, Table 1). Five are anchored using double pins, one (north inside) is anchored with a single pin, and one (north outside) is secured to a large boulder via chains (Figure 9). The north outside mooring is not a U.S. Army Corp of Engineers (USACE) permitted mooring. These moorings are located in close proximity and surround the circle of rocks known as the stone circle “campfire” where scuba divers place lights and sit on the seafloor to view manta rays (Figure 8). The campfire is the primary manta ray viewing site for scuba divers in Makako Bay. Given the number of vessels compared to available moorings, at least 2-3 vessels simultaneously use each mooring on a nightly basis. The boats are attached end-to-end (“daisy chained”) to each other. Given that the number of vessels observed at Makako Bay during this study was well short of its peak activity, the number of vessels per mooring likely increases on busier days. Due to the limited number of moorings and space constraints, vessels also commonly anchor Figure 8. Map of the Makako Bay manta viewing site and the day-use mooring locations – both official and unofficial. The red outline indicates the 100 yard perimeter surrounding the official day-use moorings. -9- nearby (within 100 yards of the moorings). Some vessels, particularly smaller boats arriving after dark, do not moor or anchor but “live boat” throughout the duration of the night. These boats typically drop- off and pick-up snorkelers near the campfire and wait offshore in the interim. Figure 9. Day-use moorings at Makako Bay: (left) middle outside with double pin anchor, (middle) north inside single pin anchor, and (right) north outside with chain anchor. At Keauhou Bay, there are seven moorings but only four have subsurface floats. Three are anchored using double pins, one (inside north) is anchored with a single pin, and three (Aggressor north, Aggressor south, south chain) are anchored to large boulder via chains (Figure 10, Table 1). The three chain moorings do not have subsurface floats and are not USACE permitted moorings. Additionally, the south chain mooring is not secure and consists of a chain loosely looped over a boulder (Figure 11). The Keauhou moorings are located in close proximity to the boat channel which is actively used throughout the day and night by vessels not associated with the manta ray viewing operations. Figure 10. Map of the Keahou Bay manta viewing site (left) and the day-use mooring locations– both official and unofficial. The red outline indicates the 100 yard perimeter surrounding the official day-use moorings and the yellow star indicates the location of the public shoreline access. The NOAA nautical chart (right) showing the Keauhou harbor boat channel and its proximity to the day-use moorings. -10- Based observations, the four moorings with subsurface floats are regularly used by at least one vessel. Some vessels, arriving after dark, do not moor but instead drop anchors presumably due to their inability to locate available moorings. Boats have also commonly been observed live boating throughout the duration of the night. During busy nights, 3-4 boats were observed using each mooring simultaneously. Compared to the Makako Bay site, the vessels at Keauhou Bay are less centralized and more dispersed along the shoreline and anchoring is much more frequent. While not assessed within the scope of this study, the live coral cover was observed to be quite high throughout the area where anchoring was observed. Damage to live coral colonies is likely unavoidable when anchoring in this area, especially at night. Figure 11. Day-use moorings at Keauhou Bay: (left) middle south with double pin anchor, (middle) inside north with single pin anchor, and (right) south chain which is only loosely wrapped around a boulder. Attempts were made to reconcile the moorings verified during this study with existing records from Malama Kai (http://www.malama-kai.org/) and DLNR DOBOR administrative rules. However, GPS coordinates listed in the records do not align with the high sensitivity GPS coordinates recorded by a Garmin 72H directly over each mooring in this study (Table 1). Assuming that the Malama Kai records list all day-use moorings approved by the Army Corp of Engineers and the Hawaii DLNR Land Board, there are several unapproved moorings which are being used at both sites. Despite the discrepancies with the Malama Kai online records, Teri Leicher of Malama Kai states that all of the double pin and single pin moorings at both sites are approved. At Makako Bay, at least one or two of the moorings with subsurface floats are not permitted/approved. At Keauhou Bay, three chain based moorings and possible one of the moorings with a subsurface float are not permitted/approved. Of all day-use moorings at both sites, only one at Makako Bay is actually codified in the DLNR DOBOR administrative rules which guide enforcement activities (per Dan Mersburgh, DLNR DOBOR). The risk of mooring failure was not thoroughly assessed in this study due to external dependencies for information and engineering expertise which were not met in time for issuing this report. However, rough engineering calculations on the available mooring specification data suggest that the mechanical force exerted on a single mooring from four rafted vessels may easily exceed the design specifications of the mooring causing potential failure under conditions of high wind (e.g., 30 mph) and significant swell (per Finn McCall, DLNR DOBOR). More detailed analysis should be performed to assess what level of vessel rafting and what weather conditions can be safety supported by the moorings. Hazards to human health and safety -11- Consistent with classical risk assessment and management methodology, this safety assessment defines and assesses the hazards to human health & safety independently from their likelihood (i.e., probability) of occurrence (Figure 12). Hazards are prioritized in order of potential severity. Risk factors which increase hazard severity and/or likelihood will be assessed. Mitigating factors employed to reduce severity and/or likelihood will also be assessed. Figure 12. Classical risk assessment and management framework. The severity or impact of a hazardous incident occurring is represented in the vertical axis while the likelihood or probability of occurrence is represented in the horizontal axis. The resulting gradient represents the highest threats (upper right corner) which should be prioritized for management attention. Risk factors increase the threat level either by increasing severity of a hazard and/or increasing the likelihood of occurrence. Conversely, mitigating factors reduce the threat level posed by hazards by reducing the severity of the hazard and/or reducing the likelihood of occurrence. Given the nature of the manta viewing operations, there are several potential human safety hazards which range in level of severity. Some hazards are inherently associated with any in-water activity but others are exacerbated by specific nature of the manta viewing operations and/or the level of congestion on a given night. Hazards have been classified based on potential severity of injury and resulting consequences. For purposes of this assessment, hazards have been classified as high if they can result in severe injury or death, medium if they can result in injury requiring professional medical attention but are most likely non-life threatening, and low if they can result in minor injury (i.e., not requiring professional medical attention) but possibly ending recreational activity for the individual(s). Specific hazards identified via stakeholder input and review of current operations include the following: High: severe injury or death possible (1) Live vessel (while engines in gear) or propeller strike on swimmer/diver (2) Anchor strike on subsurface diver (3) In-water medical emergency (i.e., heart attack, stroke, etc.) (4) Drowning (e.g., due to panic, loss of floatation, or subsurface loss of air) (5) High speed boat-to-boat collision Medium: injury requiring medical attention possible (6) Drifting vessel strike (engines off) (7) Swimmer/diver hitting idle vessel (e.g., swimming into boat or surfacing under boat), or accidentally kicking idle propeller -12- (8) Manta ray colliding with swimmer/diver (9) Slow-no-wake speed boat-to-boat collision Low: minor injury possibly ending recreational activity (10) Contact with hazardous marine life (urchins spines, coral abrasion, stinging organisms) (11) Swimmer accidentally hitting/kicking another swimmer (12) Mild hypothermia (13) Swimmer fatigue The scope of this assessment will address high severity hazards relative to the manta ray viewing operations and factors affecting their severity and likelihood. While the likelihood of hazardous incidents occurring cannot be definitively calculated without substantial, detailed historical data, valuable qualitative insights can be gleaned from the available data, assessment of stakeholder input, and limited observations performed in this study. Generic diving or boating related hazards not specific to or exacerbated manta ray viewing operations are not addressed. Risk factors contributing to severity and likelihood of incidents/accidents For each type of hazard there are risk factors that influence the severity and likelihood of hazards occurring (i.e., incidents/accidents). Some of these factors can be influenced to varying degrees by operating procedures employed by individual tour operators. For purposes of this assessment, these factors have been classified in the following categories with an indication of whether they are addressed within the scope of this study and if so, what information was used in their assessment.  Natural ocean & atmospheric conditions including level of ambient light, wave swell, wind speed, currents, and underwater visibility o not addressed in this study; can be mitigated via operator decision to cancel tours  Customer health and snorkeling/diving ability o not addressed in this study; can be mitigated via operator screening of customers  Operator skill/experience/readiness including number of crew, level of training & experience of captain & crew, crew utilization & attentiveness, emergency procedures & medical equipment o voluntary stakeholder input collected via interviews & email survey  Operating procedures & equipment including in-water supervision ratios, aggregation versus dispersion of swimmers/divers, use of group flotation & lights, use of individual flotation & lights o Assessed via direct observations, and voluntary stakeholder input collected via interviews & email survey  Crowding/congestion including number of boats and divers/swimmers in water o Assessed via direct observations, compilations of statistics provided by Manta Pacific Research Foundation, and voluntary stakeholder input collected via interviews & email survey  Live boating near swimmers & divers including the synchronicity of operations and the behavior of vessel captains, swimmers, and divers o Assessed via direct observations, and voluntary stakeholder input collected via interviews & email survey  Mooring availability & integrity including mooring specifications, number of vessels using each mooring, and vessel size(s) -13- o Assessed via mooring verification survey, commercial vessel specifications, mooring specifications, and DLNR DOBOR engineering calculations Risk assessment of individual hazards Live vessel or propeller strike on swimmer/diver at night Probably the most severe hazard associated with the night time manta viewing operations is a live vessel or propeller strike on a person in the water, particularly on the head. Several risk factors which can increase the likelihood of a live vessel or propeller strike include the following: (a) Number of live boating vessels and in-water persons (b) Timing overlap of in-water persons and live boating activity (c) Spatial proximity of live boating vessels and in-water persons (d) Visibility of in-water persons (including use of lights) and surfacing behavior of scuba divers & free divers (e) Speed of live boating vessels (f) Crew utilization and attentiveness, and use of spot lights on live boating vessels Of these risk factors, vessel speed (e) is the only factor which also increases severity of hazard. In the operational statistics previously reviewed, the level of congestion and overlap of in-water persons and live boating vessels have been quantified and demonstrate ample opportunity for an accident to occur due to (a) and (b), especially on the busiest days. Additionally, the spatial proximity of the Keauhou manta viewing site to an active boat channel increases the likelihood of an accident (Figure 10). Ten days of direct observations (confirming stakeholder input) have recorded operator and swimmer/diver behavior which needlessly increases the likelihood of an accident occurring due to (c), (d), and (e). On a nightly basis, multiple vessels have been observed traveling above minimum operating speeds (e) and passing within 10-20 ft of in-water persons (not associated with the vessel) (c) who are not wearing individual lights (d). Unlit swimmers have also been observed venturing away (>40 ft) from their groups/rafts or swimming to/from shore (at Keauhou Bay). On one occasion, a scuba diver was observed briefly surfacing unexpectedly (d) halfway between their originating vessel and the campfire (at Makako Bay). The visibility of in-water persons (d) by vessel operators can be both enhanced and degraded by the use of strong lights. The use of strong lights by one operator can substantially enhance their vision and ability to avoid in-water persons while concurrently hampering the vision of other operators. During the night-time observation periods, unrelated vessels exiting and entering the Keauhou harbor at high speed avoided the manta ray viewing area where most moored/anchored vessels were well lit. This behavior contrast to day-time activity when vessels commonly transit over the day-use moorings at high speed when entering & exiting the Keauhou boat harbor. However, on one night multiple groups of swimmers associated with lighted rafts were observed following manta rays well into the boat channel (north of the North Middle mooring) as defined by the NOAA nautical chart (Figure 10). On three occasions, vessels were observed transiting above minimum operating speed directly over submerged divers (c) visible from their dive light and in one case confirmed by the diver’s behavior afterwards (i.e., waving their dive light upward in response). Due in part to congestion, vessels regularly pass within 20 ft of subsurface divers (c). The movement and dispersion of subsurface divers relative to moored/anchored vessels contributes to this spatial proximity. On one occasion, subsurface divers moved to within 10 ft of the stern of a moored vessel (c) and remained stationary for an extended period of time (>30 minutes). Subsurface divers transiting underneath moored/anchored vessels is a common occurrence due to the congestion of vessels in a confined area. -14- Direct observations also confirm some operators employing mitigating behavior to reduce the likelihood of accidents. Many vessels (but not all) clearly take the most evasive route possible (c) and use minimum operating speed (e) exercising an abundance of caution when approaching or leaving the area with in-water persons. Some (but not all) moving vessels also employ extra crew on the bow or stern with spotlight(s) to avoid in-water persons (f). A majority of operators place individual lights on in- water persons (d) although this practice appears less consistent on the snorkeling guides themselves. The general procedure practiced by all scuba diving operators is to descend and surface next to their originating vessel (d), however, unplanned surfacing inevitably occurs for a small percentage of scuba divers. Scuba divers at the manta viewing sites do not use surface markers or dive flags due to the entanglement hazard they pose to the manta rays at night. Free diving (d) is also discourage by all tour operators but has been observed, especially at Keauhou Bay. In close proximity to moving vessels, lengthy free dives which may include transiting a significant distance underwater disproportionately increases the risk of an accident. Anchor strike on subsurface diver Another potentially severe hazard associated with the night time manta viewing operations is an anchor strike on a subsurface diver, especially on the head. Risk factors which can increase the likelihood of an anchor strike include the following: (g) The number of vessels using anchors and number of subsurface scuba divers (h) Timing overlap of subsurface diving and arrival time of vessels (i) Anchor deployment procedures Of these risk factors, anchor deployment procedures (i) is the only factor which can also increase the severity of hazard. The risk factors associated with this hazard differ by manta ray viewing site. At Makako Bay where scuba diving occurs nightly weather permitting, the vessel arrival schedules are more synchronized with fewer vessels arriving after dark while subsurface scuba divers are in the water (h). At Keauhou Bay, scuba diving is less regular but the vessel constantly arrive throughout the night (e.g., Figure 6). At both locations, the busier nights (g) result in an increase in both the need for anchoring (due to limited availability of moorings) and the timing overlap between subsurface divers and arriving vessels (h). Dropping an anchor from a vessel at night without inspecting the seafloor and allowing it to free-fall at maximum speed to the bottom not only increases the likelihood of an accident but also maximizes the severity of the hazard. This behavior was observed on several occasions at Keauhou Bay and appears to be a common practice. This practice was not observed at Makako Bay during the four days of observation. Less caution at Keauhou Bay may be the result of scuba diving being less common there. Direct observations also confirm this most operators mitigate this risk by slowly lower their anchor hand-over-hand and/or employing an in-water observer to help guide the anchor. However, even when lowered hand-over-hand, an anchor strike on the head on a subsurface diver has the potential to injure or render them unconscious. In-water medical emergency Due to preexisting medical conditions, medical emergencies (i.e., heart attacks, strokes, etc.) will be directly proportional to the number of at-risk persons involved in any physical activity. Due to the increasing number of persons engaging in night time manta ray viewing, its widening appeal to snorkelers, and the low barriers to entry (i.e., no prerequisite training or skill required), such incidents can be expected at a consistent ratio. Based on stakeholder input, such events appear to occur every year and should increase as the number of participants increase. The most direct and possible only effective way for operators to lower the likelihood of such incidents is to screen customers for medical condition and skill level prior to in-water activities. While -15- this practice is institutionalized in the scuba diving industry, there are no standards associated with snorkeling tours. Some snorkeling operators have indicated that they deliberately screen customers based on health or snorkeling experience. However, customer dishonesty about their medical condition or skill level has been noted in the past. Another practice which prevents operators from proactively screening customers is the use of independent third party booking agents. In these situations, the operators do not meet the customers until they are ready to board the vessel. The risk major factors affecting the severity of incidents and conversely the mitigating factors reducing severity are as follows: (j) Response time to medical attention (k) Ratio of crew/guides to customers and their vigilance (l) Crew preparation, response training, skill, and equipment While no in-water medical emergencies occurred during the observation period, risk factors were assessed based on observations and stakeholder input. Response time (j) will be directly affected by the level of congestion blocking the shortest path of getting a victim onto a responding vessel, the proximity of originating vessel to in-water persons, and in some cases the sheer size of the in-water victim. The number and size of floating rafts and number of snorkelers can impede the ability to quickly transfer an in-water victim to a responding vessel. Due to the configuration of snorkeling rafts and the absence of fins on some snorkelers the speed and mobility of a raft is often dependent on a single guide’s ability to pull everyone through the water. Noise levels (e.g., people shrieking with delight as they see manta rays) can also inhibit timely detection of a medical emergency and subsequent communication to a responding vessel. Direct observations of operations suggest that response time to an in-water victim can be hampered by distance and congestion on busy days. Some operators commonly allow their free floating rafts of snorkelers to travel >100 yds from their vessel and out of direct line of sight. In some cases due to congestion, the originating vessel remains unmoored/unanchored offshore. A past fatality associated with slow response to an in-water medical emergency has prompted one operator to keep their snorkeling rafts tethered to the vessel keeping them in close proximity at all times. Supervision of recreational scuba divers by diving professionals is governed industry standards (i.e., PADI, SSI, NAUI, etc.) in terms of training & certification requirements and the appropriate supervision ratios associated with each type of diving situation. All scuba diving operators reportedly adhere to industry standards and guidelines due in part to certification and insurance requirements. For swimming or snorkeling tours, there are no industry standards on training & certification requirements for operators or guidelines on supervision ratios. Via voluntary input, tour operators have indicated that they maintain in-water snorkeler to guide ratios ranging from 6:1 to 13:1 (k). Given the scuba diving orientation of many tour operators, snorkel guides are often PADI certified Dive Masters or Rescue Divers. At least one company states that they only hire snorkeling guides with American Red Cross Lifeguard certification, CPR & First Aid certification, and prior lifeguarding work experience. Based on stakeholder input, companies can and do employ snorkel guides without any formal training or certification. The extent and level of lifeguard training associated with operators and their crew were not confirmed by this study. Since there are no uniform requirements, the medical equipment available on vessels varies by operator but can include First Aid equipment, Medical Oxygen (e.g., DAN Oxygen), and Automated External Defibrillators (AED). The formal training associated with this medical equipment also varies by operator. Drowning (excluding medical emergencies) -16- As with any in-water activity, drowning is a potential hazard that increases proportionately with the number of persons in the water. The risk major factors affecting the likelihood of a drowning incident include the following: (m) Ocean conditions (n) Swimming ability (o) Availability and use of personal floatation The most direct ways for operators to lower the likelihood of a drowning are via preventative measures including cancellation of operations during adverse ocean conditions (m), screening customers for skill level prior to in-water activities (n), and requiring the proper use of adequate personal flotation (o). While reported by multiple stakeholders as a potential risk factor, this study was not designed to assess the swimming ability of visitors to the manta ray viewing sites. However, small children were observed joining in night time snorkeling activity and having to be individually escorted back to their originating vessel prematurely by their snorkeling guide. The use of flotation in the form of group rafts appears to be universally employed by commercial snorkel operators. However the use of personal floatation varies and includes the use of inflatable swim vests, naturally buoyant neoprene wet suits, and unattached floats (e.g., foam noodles for keeping legs afloat). All operators surveyed indicated that personal floatation devices (PDFs) are always made available for customer utilization. Some snorkelers, presumably those comfortable in their swimming ability have been observed without personal floatation which can interfere with swimming efficiency. The risk major factors affecting the severity of drowning incidents and conversely the mitigating factors reducing severity are analogous to those of an in-water medical emergency (j) (k) (l) and discussed in the prior section. In the opinion of Hawaii Fire Department Ocean Safety Division Capt. Chris Stelfox, formal lifeguard training and certification should be required of all snorkeling guides with a maximum swimming to lifeguard ratio of 25:1 when swimmers are associated with a central floating raft. Capt. Stelfox does not consider scuba diving training and certification (e.g., PADI Rescue Diver) as a sufficiently rigorous qualification for snorkel guides. High speed boat-to-boat collision The major risk factors which can increase the likelihood of a high speed boat collision include aforementioned (f) crew attentiveness, (e) vessel speed, and the following: (p) Proximity of vessels to boat channel traffic (q) Visibility of vessel moored/anchored or underway (including natural ocean & atmospheric conditions) Given the isolation of the Makako Bay site and the shape of the embayment, the only vessels visiting the site are those participating in the manta ray viewing activities. Therefore, a high speed collision at the site is unlikely. However, due to the multiple shifts of tours conducted at Makako Bay, there is concurrent high speed vessels traffic travelling in both directions between Honokohau harbor and Makako Bay at night. While this hazard is not unique to manta ray viewing operations, the nature of the scheduling guarantees that vessels will encounter each other on busy nights. At Keauhou Bay, the proximity of the boat harbor elevates the interaction between manta ray operators and unrelated vessel traffic. For regular night-time Keauhou harbor users, familiarity with the manta ray viewing site likely mitigates the likelihood of a collision due to (e) (f) (q) despite (p). During the observation period, vessels entering & exiting the harbor at night consistently gave the manta ray viewing site a wide berth. Under normal conditions, significant operator negligence would be required for an accident to occur. However, a few vessels at the Keauhou manta ray viewing site have been observed mooring/anchoring without the use of lights in the midst of several well lit vessels. Additionally, on one occasion a zodiac without any lights was observed repeatedly entering & exiting the harbor to/from the manta ray viewing site. -17- Existing regulatory frameworks Several regulatory frameworks currently regulate various aspects of the manta ray viewing operations. These frameworks include permits, zone restrictions, mooring use, navigation restrictions, and environmental protection. Manta ray tour operators are required to obtain a Commercial Use Permit for State Ocean Waters and either a Harbor Commercial Use Permit or a Launch Ramp Permit depending on the status of their vessel(s). The recent increase in the number of permits issued has led to an increase in the number of tour operators offering manta ray viewing activities. There are currently no activity-specific restrictions (e.g., associated with manta ray diving or snorkeling or night time activities), capacity restrictions (e.g., number of persons), location restrictions, or equipment requirements/restrictions (e.g., lighting, propeller guards, medical equipment, etc.) associated with these state permits. While location and activity specific restrictions within Ocean Recreation Management Areas (ORMAs) have been applied to regulate and limit activities and ensure safety at other locations, activities at Makako Bay and Keauhou Bay are not currently regulated by location or activity specific administrative rules. There are currently no regulations restricting the locations for live boating, diving, or swimming at these sites. With respect to mooring and anchoring at the manta ray viewing sites, a few regulatory frameworks are currently in place. Day-use moorings are required to be approved by the Army Corp of Engineers and the DLNR Land Board. As mentioned in the previous section, unapproved day-use moorings exist at both sites and are used on a nightly basis. DLNR administrative rules limit day-use mooring usage to 2.5 hrs while another vessel is waiting and prohibit anchoring within 100 yds of a day-use mooring. See HAR §§ 13-257-3, 13-257-4. There are currently no regulations or restrictions associated with rafting multiple vessels on a single mooring. General DLNR and U.S. Coast Guard navigation related rules govern vessel navigation in proximity to a displayed dive flag and light/signaling requirements for vessels anchored/moored, with divers in the water or with restricted movement. Vessels are prohibited from approaching within 100 ft of a displayed dive flag unless there are intending to conduct diving or swimming activities in which case they are required to approach at a speed of slow-no-wake. This buffer is reduced to 50 ft within navigational channels. From discussions with the U.S. Coast Guard and DOBOR, the definition of the regulatory term “slow-no-wake speed” is potentially ambiguous and may include speeds in excess of minimum operating speed (required to maintain steerage). There are currently no regulations governing how close vessels (involved in diving/snorkeling operations) are allowed to travel to unrelated in-water persons. For examples, vessels are allowed to motor over subsurface divers at slow-no-wake speed. DLNR administrative rules and U.S. Coast Guard require divers (SCUBA and free divers) to display dive flags within 100 ft of them either in the water or on the highest point of their vessel. Despite the lack of flag visibility in the dark, there are no regulations regarding the use of lighted flags/markers by divers at night. There are currently no regulations governing the visibility of surface snorkelers/swimmers (i.e., non-divers) in the ocean at night despite the obvious hazard. Unrelated to human safety, DNLR environmental protection regulations prohibit knowingly capturing or killing manta rays and anchor damage to stony corals. See HRS § 199-39.5, HAR § 13-95-70. As with any government regulation, compliance can vary and is affected by practical constraints on enforcement. During this study, several technical violations of existing regulations were observed. During this study, a vessel was observed operating at night without running lights (at Keauhou Bay) and anchored/moored without any lights (in the midst of several other vessels with proper lights). One vessel was observed dropping off an individual with a lighted raft at the Keauhou Bay manta ray viewing site, leaving the site to go to the harbor, then returning 20 minutes later. -18- At both sites, vessels often occupy day-use moorings longer than 2.5 hrs and routinely anchor within 100 yds of occupied day-use moorings. Since only a single mooring at Makako Bay (DLNR #13, Table 1) and none at Keauhou Bay are formally listed in the DLNR administrative rules, enforcement of existing day-use mooring regulations may not be feasible until the administrative rules are updated. At both sites, vessels routinely operate at speeds above minimum operating speed within close proximity to in-water persons. Arguably these vessels are not violating the slow no-wake speed requirement but they are easily exceeding minimum operating speed required to maintain steerage which is considerably slower when conditions are calm. Voluntary tour operator standards Independent of government regulations, community cooperation and voluntary standards can govern aspects human safety of manta ray viewing operations. A working group of tour operators have established a list of voluntary operating standards aimed at maintaining human safety and environmental stewardship. These standards were finalized in March of 2013 and promoted online by Manta Pacific Research Foundation (http://www.mantapacific.org/#!manta-tour-operator- standards/ci5b) and the Manta Ray Green List (http://www.mantaraygreenlist.com/operator- standards/). While not universally adopted by all operators, these voluntary standards have in many ways have improved the safety of manta ray viewing operations despite the high number of participants. For example, the widely adopted and voluntary practices of using individual lights on snorkelers/swimmers, centralizing them on floating rafts, and prohibiting free diving, have substantially (but not totally) mitigated some of the risks associated with placing large numbers of persons in the water at night amongst actively motoring vessels. Since the goals of this study was to assess the current operation relative to human safety, it is important to acknowledge the substantial contributions to human safety associated with some of these voluntary standards. It is also important to acknowledge that some of the provisions in the voluntary operating standards are unrelated to human safety. Some provisions also conflict with the operating model employed by some tour operators (e.g., providing dry boat-based manta ray viewing opportunities) and are a source of contention among tour operators. Providing a critical assessment and/or endorsement of the individual provisions within these voluntary standards was not an objective of this study and not performed. Conclusions Severe safety hazards are currently associated at the manta ray viewing activities at Makako Bay and Keauhou Bay. The probability for a severe accident is relatively low since a concurrent overlap in both time & space of two or more hazardous behaviors is required for a severe accident to occur (e.g., vessel motoring over subsurface divers and unplanned/uncontrolled diver ascent). However, on a nightly basis substantial overlap in the timing of hazardous behaviors occurs, and complete spatial overlap in hazardous behaviors occurs. These existing data and observations suggest that a severe accident is mathematically inevitable and will occur in the future without significant mitigation of the existing risk factors. While voluntary tour operator standards have contributed to increased human safety and current government regulations address general boating and diving safety, the unique human safety issues associated with this activity (e.g., high density of in-water persons and vessels in the ocean at night) warrant special attention. In particular, night-time congestion and the overlap (in time & space) between live boating and in-water persons are major factors which substantially increase the likelihood of a severe accident. Existing permit requirements provide an overall level of capacity control for all -19- commercial vessels; however, no other regulatory control is in place to prevent further growth commercial and recreational activity. Unsuccessful attempts to “develop” additional manta ray viewing sites by tour operators have exacerbated the congestion at Makako Bay and Keauhou Bay. If popular demand for this activity continues to exceed supply (e.g., tour operators often fully booked during peak season) and commercial revenue potential remains high, continued growth in commercial activity can be expected. The onset of adverse weather conditions reducing visibility (e.g., rain), increasing minimum operating speed (e.g., wind), or the rapid departure from normal operations associated with an unexpected event (e.g., medical emergency, mooring failure, large shark sighting, etc.) can significantly elevate risk and the likelihood of an accident. The extent of elevation is dependent in part on the skill, experience, and reaction of tour operators and their crew and may be disproportionately influenced by the lowest common denominator, especially in a confined & congested area. A formal assessment and vetting of regulatory options are recommended to determine how best to mitigate the severity of existing hazards and reduce the likelihood of severe accidents. This process should include an assessment of regulatory limitations with detailed input from all stakeholders to anticipate the potential for unintended consequences, identify regulatory loopholes, and recognize practical enforcement limitations. -20- Table 1: Day-use moorings at Makako Bay and Keauhou Bay Existing moorings verified in this study Day-use moorings listed in the Malama Kai records Day-use moorings listed in the DLNR DOBOR administrative rules Site Name Mooring Type Latitiude N Longitude W depth (ft)photos Makako North Outside chain around rock 19 44.242 156 03.281 80 G7 Makako North inside single pin 19 44.233 156 03.244 23 G3 Makako Aggressor double pin 19 44.209 156 03.256 72 G6 Makako Middle outside double pin 19 44.198 156 03.243 38 G2 Makako Middle inside double pin 19 44.192 156 03.223 30 G1 Makako South outside double pin 19 44.161 156 03.246 34 G5 Makako South inside double pin 19 44.159 156 03.235 23 G4 Keauhou Outside double pin 19 330543 155 58.065 36 K01 Keauhou Aggressor North chain around rock 19 33.538 155 58.079 47 K02 Keauhou Aggressor South chain around rock 19 33.532 155 58.083 48 K03 Keauhou Inside North single pin 19 33.564 155 58.027 29 K04 Keauhou Middle South double pin 19 33.550 155 58.045 34 K05 Keauhou Middle North double pin 19 33.565 155 58.053 38 K06 Keauhou South Chain chain around rock - loose 19 33.552 155 58.021 26 K07 Site Name Mooring Type Latitiude N Longitude W depth (ft) Makako Garden Eels North 19 44.230 156 03.240 Makako Garden Eels Central 19 44.202 156 03.235 Makako Garden Eels East 19 44.198 156 03.215 Makako Garden Eel Cove-1 19 44.186 156 03.260 Makako Garden Eel Cove-2 19 44.186 156 03.260 Keauhou Keauhou Manta-1 19 33.558 155 58.023 Keauhou Keauhou Manta-2 19 33.558 155 58.023 Keauhou Keauhou Manta-3 19 33.558 155 58.023 Site Name Mooring Type Latitiude N Longitude W depth (ft) Makako DLNR #13 19 43.940 156 03.470 -21- Appendix A: Manta ray tour operation stakeholders Name/Contact Company/Organization Inteview Participant Survey Response Survey Recipient Iwa Kalua Aloha Kayak Co.x x (808) 557-5668 Aloha Kona Tours Captian Kris Henry Aloha Ocean Excursion (formerly Sea Hawaii Rafting)x Craig Napier Big Island Divers x Frank Hendricks Big Island Divers x Kristina Dowling Big Island Divers x x x Norman Cinch Big Island Divers x Sarah Rafterty Big Island Divers x x Erica Blue Sea Cruises Inc.x x Ray Lemay Blue Sea Cruises Inc.x x Denise Vidosh Blue Wilderness x x Mariko Breeze Hawaii x x coralreefadventures@gmail.com Coral sea Adventures (Coral Reef Snorkel Adventures)x Alex Dent Fair Wind Cruises x Mendy Dant Fair Wind Cruises x x Mitch Stauffer Fair Wind Cruises x Daniel Mersburgh Hawaii DOBOR Honokohau x Capt. Chris Stelfox Hawaii Fire Department Ocean Safety x x Johnathan Droge Hawaii Island and Ocean Tours LLC x LeeAnn P. Leslie Hawaii Island and Ocean Tours LLC x x Jason Thurber Hawaii Oceanic x Bari Mims Hawaii Pack and Paddle x http://www.hawaiianscubashack.com/Hawaii Scuba Shack x Lisa Christensen Honu Sports x Keller Laros Jacks Diving Locker x Teri Leicher Jacks Diving Locker x x Wendy Laros Jacks Diving Locker x x info@kamanu.com Kamanu Charters x kohalakayak@yahoo.com Kohala Kayaks x Captian Chris Wade Kona Agressor x x Evin Kona Agressor x Katie Gaab Kona Diving Company x Kerry Key Kona Diving Company x x Ralph Jewell Kona Glass Bottom Boat x x info@konahonudivers.com Kona Honu Divers x Laure and Danny Scott Kona Ocean Adventures x x info@konaoceanx.com Kona Ocean Experience x Ty and Cyrus Widhalm Kona Sea Adventures x Kalani Nakoa Kona Snorkel and Sail x x info@konasnorkelandsail.com Kona Style x liquid@liquidhawaii.com Liquid Hawaii x Keller Laros Manta Pacfic Research Foundation x Seth Conae Manta Ray Dives of Hawaii x Robert Hudson Miss Mojo Sports x x Jan War Natural Energy Laboratory of Hawaii Authority x Dani Knapp Neptune Charlies Ocean Safaris x Seth Conae Neptune Charlies Ocean Safaris x ecoinfo@oceanecotours.com Ocean Eco Tours x Brain Wargo Ocean Encounters x Deenen Wargo Ocean Encounters x Yumi Ocean Spirit Diving x x James and Martina Wing Ocean Wings Hawaii Inc.x Frank and Patrice Heller Pacific Rim Divers x x Bob Gladden private boater x x x Jay Smith Scuba Shack x x Kris Henry Sea Hawaii Rafting x Rich and Holly Kersten Sea Paradise x x Kyle Sea Quest Hawaii x Lily Dudoit Sheraton Keauhou Kona Resort x info@splashersoceanadventures.com Splashers x Colin Adams Sunlight on Water x Josh Sunlight on Water x Melainah and Mike Yee Sunlight on Water x x x Nicole Milligan Torpedo Tours x x Lt. Joshua Williams U.S. Coast Guard Marine Safety x www.wahinecharters.com Wahine Charters x -22- Appendix B: Manta Ray Tour Operators serving the Kona coast Aloha Kayak Company Aloha Kona Tours Aloha Ocean Excursions Big Island Divers Blue Sea Cruises Breeze Hawaii Diving Coral Reef Snorkel Adventures Dolphin Journeys Fair Wind Cruises Hang Loose Boat Tours Hawaii Island and Ocean Tours Hawaiian Scuba Shack Honu Sports Hawaii Oceanic Iruka Hawaii Jack's Diving Locker Kamanu Charters Kohana Iki Kona Aggressor Kona Diving Company Kona Honu Divers Kona Nature School Kona Ocean Adventures Kona Ocean Experience (KOEX) Kona Sea Adventures Kona Style (Kona Snorkel & Sail) Kukio Boats Liquid Hawaii Miss Mojo (Kiholo Inc.) My Kona Ocean Adventure Neptune Charlies Ocean Safaris/Manta Ray Dives Ocean Encounters (Bite Me) Ocean Eco Tours Ocean Spirit Hawaii Pacific Rim Divers Sandwich Isle Divers Sea Paradise SeaQuest Snorkel Tours Splasher's Ocean Adventures Sunlight on Water Torpedo Tours Wahine Charters LLC -23- Appendix C: Vessels operating manta ray viewing activities at Makako Bay and Keauhou Bay Company Vessel Name Length (ft) Gross Register Tonnage Max Passengers Max Total Height (ft)Width (ft) Official Number Aloha Kayak Company (kayaks) Aloha Kona Tours Aloha Kona Tours 12 Aloha Ocean Excursions Zodiac Hurricane 733 25 Big Island Divers Moana Olapa 35 14 1166964 Big Island Divers Moana Lu'u 28 Big Island Divers Hono Iki 36 20 1206121 Big Island Divers Naia Breeze Hawaii Diving Umi Katana 27 5 11 HA1357CP Blue Sea Cruises Makai 46 14 32 84 18 16 978116 Blue Sea Cruises Spirit of Kona 70 78 100 149 20 28 11955628 Coral Reef Snorkle Adventures Makua 25 2 6 8 12 1636CP Fair Wind Cruises Fair Wind II 58 55 124 132 993088 (U.S.) Fair Wind Cruises Hula Kai 55 27 48 51 21 1176109 (U.S.) Hang Loose Boat Tours Hang Loose 29.3 8 24 26 9.4 1251486 (U.S) Hawaii Island and Ocean Tours Box top 6 Hawaiian Scuba Shack White force 28 Hawaii Oceanic Pueo Kai 30 6 Honu Sports The Honu Adventure 28 8 10 Iruka hawaii Kona Naia 32 13 21 23 1030297 (U.S.) Jack's Diving Locker Kea Nui 46 40 38 40 16 1196519 (U.S.) Jack's Diving Locker Nai'a Nui 32 8 15 17 1189298 (U.S.) Jack's Diving Locker Na Pali Kai 33.8 12 25 27 687068 (U.S.) Jack's Diving Locker Diver II 38 28 Kamanu Charters Kamanu 36 4 24 26 HA463CP Kohana Iki Kaikea Kiholo Inc. Miss Mojo 41 24 6 982338 (U.S.) Kona Aggressor Kona Aggressor II 73 Kona Diving Company Hale Kai 34 Kona Honu Divers Honu I 46 44 36 39 16 9 1122486 Kona Nature School Black and yellow Zodiac Kona ocean Adventures Ipo Kai Kona ocean Adventures Mega Bites Kona Ocean Adventures White Fishing cat 28 12 17 Kona Ocean Experience Lei Plana Kona Ocean Experience Horizon RIB Kona Sea Adventures Ahi Lani 34 Kona Snorkel & Sail Kini Kini 38 under 5 6 HA1705CP Kona Snorkel & Sail Noa Noa 50 43 Kona Snorkel & Sail Kona Style Kukio Boats ? Liquid Hawaii Liquid Hi 25 6 HA1949CP Neptune Charlies Ocean Safaries The Manta 36 20 29 32 6 1179815 (U.S.) My Kona Adventure (white boat red letters) Ocean eco Tours Zodiac Ocean Encounters Ocean Encounters 41.8 26 35 40 25 14.2 548605 Ocean Spirit Hawaii White force 25 Pacific Rim Divers Hapa Naia 26.5 6 Pacific Rim Divers Boundless 34 n.a.n.a.n.a. Sandwich Isle Divers (force with fly bridge) Sea Paradise Hokuhele 50 unk 39 42 SeaQurst Snorkel Tours Vitos boat Splasher's Ocean Adventures Orca 26.7 8 19 21 3.8 972712 (U.S) Sunlight on Water Uhani Nui O Naia 40 35? Torpedo Tours Napali Kai II 38 27 Wahine Charters LLC Wicked Wahine 27 9 14 16 5.1 1097318 (U.S.)