Dear Maritime Industry Authority of the Philippines

There is much concern over the recently proposed removal of the Exemption of traditional-style wooden-hulled boats used for scuba diving, snorkelling and other tourism activities from Marina Circular MC2016-02, which mandates the phase-out of wooden-hulled passenger boat in the Philippines.

We, the undersigned, comprising interested parties and businesses both within and outside the Philippines, entreat the Maritime Industry Authority to RETAIN this Exemption from retirement from service of all such vessels, and not implement the proposed Amendment to MC2016-02 which would mean the phase out of all wooden-hulled scuba diving and snorkelling vessels by the end of 2023.

This Exemption ensured the continued safe operation of a much-loved Filipino cultural icon, prevented much economic hardship, and recognised wooden-hulled “Banca” boats engaged in scuba diving and similar tourist pursuits as offering a distinctly different service compared with regular passenger ferries of similar design and construction.

The reasons behind the Exemption introduced in MC2016-02 are still entirely valid and remain unchanged, especially considering the severe prolonged economic pressure the Tourism Industry is under during the Coronavirus Pandemic:

1.    Cost:  Upgrades to existing boats are not allowed, and new fibreglass or metal-hulled boats are more expensive to build and maintain that the traditional wooden ones.  The significant capital investment owners have made in their Bancas will be lost. 

2.    Safety:  There appears no significant evidence, either within the Philippines, or worldwide, that passenger vessels with hulls made from “technologically improved materials” are inherently safer than traditional wooden vessels.  All recent Philippine maritime incidents concerning wooden-hull passenger vessels involved frequently-overloaded passenger/cargo vessels travelling exposed sea routes - they very clearly were not Bancas involved in scuba diving or tourism activities, and it is far from clear that such accidents may have been avoided had the vessels been differently constructed.

3.    Timescale:  Commissioning and construction of suitable vessels within the next 2 years, under current business conditions, is unfeasible.  The lack of suitable construction businesses, and the severe economic impact of the Coronavirus Pandemic, mean businesses are barely operating now.  This will continue to be the case well into 2021 and beyond.

4.    Applicability: Bancas specializing in scuba diving, snorkelling and other tourism-related activities differ from other wooden-hulled passenger vessels in a number of important ways, which the original MC2016-02 recognized with the Exemption II.2:

a.    The vast majority of scuba and snorkelling trips made by Bancas are close to shore, or involve short inshore transits to protected islands.  For the comfort of guests, trips are frequently cancelled in poor or marginal weather conditions, unlike regular passenger routes

b.    Scuba diving and snorkelling boats do not tend operate anywhere near the stated capacity of the vessel, for the comfort and convenience of guests.  Indeed, following the tragic accidents of August 3, 2019 involving MBCAs crossing the IloIlo and Guimaras Strait in unexpectedly poor weather, Banca owners adhered to the requirements of the subsequent Marina Region 7 Advisory No. 08-04-2019 which included a reduction to 75% of the carrying capacity

c.     Scuba diving and snorkelling boats have greater flexibility in determining the activities of the day, unlike schedule passenger services operating on a single route.  This allows decisions to amend, reschedule or cancel trips at short notice to be made, should marginal or poor weather conditions develop suddenly

d.    Tourists welcome the Banca as a cultural icon, unique to the Philippines, and would view the loss of these vessels, and the opportunity to travel on them in a tourist capacity, as a disappointment

e.    Scuba divers used to handling heavy diving equipment prefer the stability and flat unimpeded deck space offered by outrigger vessels, with the relative ease of water entry and exit.

5.    Availability: There are very few local boat-building facilities currently able to produce vessels with hulls made from “technologically improved materials”.  Local boat-building companies are ill-prepared to transition to new forms of vessel construction within the timescales mandated by the Proposal. In contrast,

We hope that your good office will retain the existing Exemption to protect the continued safe operation of scuba diving and tourism-related Bancas in the Philippines.