b'requiredthehulltobedividedintomainorder for pulling the COI was recalled. The fi rstearly spring weekend. This interaction with vertical zones with transverse fi bulkheadsriverboat gambling vessel opened in Dubuque,the Coast Guard happened immediately priorre separated by no more than 60 meters. ThisIowa with a NAPVO owner on time on April 1,toEasterweekend.Feedbackindicatedthat vessel exceeded those dimensions. Determining1991, with the governor presiding. manyCoastGuardfamilieshadtoamend that a signifi cantly completed structure wasEaster and spring vacation plans. NAVPO was dimensionally defi cient was bad enough, butThis interaction not only saved the Iowa openingnow an entity of infamy, but also one that facing a kick offof the law on April 1, 1991but paved the way for many, many more riverboatwould become recognized as the voice of the with the Governor of Iowa presiding at thecasinosthatfollowedinMid-Westernandbroader passenger-carrying vessel industry. dedication there was no changing the vessel asGulf states.it had been constructed.Whileriverboatgamblinghaschangedand Whenthecasinovesselmarketbegantomovedoff vessels,thevesselsthemselves Negotiations involving the architect, builder,expandandgamingentitieswithoutmaritimeareseeingnewlifeinovernight,excursion, and owner with the U.S. Coast Guard are notbackgroundsbidforlicenses,theysawtheiranddiningservice.PVAmemberAlan a matter of retrievable record. What is knowncredibility was enhanced with their membershipBernsteinledthewayinthisphaseof is that in an attempt to resolve the conundrumin and through NAPVO. They shared the aurarenewal with the conversion of the Emerald the vessel owner used a personal connectionand reality of equivalent fi safety created thatLadyofBettendorf,IowaintotheBellere withtheWhiteHouse.TheWhiteHouseof Cincinnati. contacted Coast Guard headquarters. When the Coast Guard experiences external pressure on a safety issue the reaction is often contrary to what initiator hopes to achieve. The Coast Guard saw this as an attempt to circumvent fi re safety in a fi rst-of-its-kind major passenger vessel. The commandant directed that as the vessel passed St. Louis on its way to Iowa the local Officer in Charge, Marine Inspection was to board the vessel and remove the Certifi cate of Inspection. The vessel was due to pass St. Louis on March 31 enroute to Dubuque, Iowa for the April 1 launch of riverboat gambling.Theowner,withNAPVOassistance,met withaWashingtonlawfi familiarwithrm Coast Guard regulatory functions. A strategy was developed to reassure the Coast Guard ofthevesselsfi resafetyandthatthere wasanequivalencewiththeprovisionsof regulationbasedonserviceconsiderations. Subchapter H and its foundation on SOLAS 60 saw passenger vessels as entities in overnight cruisingwithhundredsofsmallspacesand cabinscontainingsourcesofignitionand combustiblematerials.Hence,thefeaturePOWER TO KEEP called main vertical zones where the interior wasdividedintosectionsbyacontinuousYOU MOVING re transversebulkheadfi barrier.However, casinovesselsweredesignedandbuiltwithWithouruncompromisingstandards,putting large open spaces where fi was unlikely; ifre started it would have few combustibles andperformance and reliability at the heart of every-would be readily identifi ed and extinguished. thing we do, HamiltonJet deliver waterjet systems The rationale was Subchapter H and casinoto keep your operation moving. re vessels provided safety from fi in diff erent but equally eff ective ways. In addition to the law fi rm, the NAPVO owner with association assistancesoughtouttheCoastGuard decisionmakersforpersonalreassuranceof the safety of riverboat gambling. After a few intense days while the Coast Guard reviewed and tested the viability of the proposal, the SEPTEMBER 2021 31 REGULATORY REPORT'