I have commented to the government:
I would like to comment in favour of the proposed regulatory change to require the wearing of life jackets by occupants of commercial (or really all) water borne aircraft (or indeed, all water borne craft - but that's a broader battle!).
I have been a pilot for 39 years, a seaplane pilot for 30 years, a seaplane owner for 8 years, and a volunteer firefighter with extensive marine search and rescue experience for 24 years. I have taken the underwater egress course, and trained fire fighters in "go type" marine rescue. It is my first hand experience that any person entering the water by surprise, and worse if the water is cold, or the person injured, is at a very much greater risk of drowning if they do not have a lifejacket on already. Having done it in training, with briefing and practice, it is very hard to locate a stowed lifejacket, and exit a submerged plane with it, let alone don it afterward - and worse if injured or hypothermic. An injured or unconscious person in the water can be much more easily assisted, if all the rescuer has to do to stabilize the situation is to pull the inflate tab of their life jacket to keep them afloat. Otherwise both people are at an increased risk.
It is, and always has been less than fully responsible for an operator or pilot to allow any occupant of the aircraft to fly without wearing a life jacket. (I provide, and require wearing one of all my passengers). As the passengers won't take responsibility for demanding a life jacket or carrying their own, and operators won't take responsibility for requiring wearing one, it's time for regulation. Indeed, with the exception of larger vessels, I suggest that while a passenger on anything that operates on water, where water entry is a risk, the wearing of a life jacket should be mandatory. Were this an enforced regulation, hundreds of aircraft passengers, boaters, kayakers, rafters, snowmobiliers - and the whale watchers off Tofino a few years ago, would still be alive.
The risk is not the passenger's alone to assess (and dismiss). The person who accidentally enters the water, and requires rescue (or recovery) imposes risk and cost on society far out of proportion to the cost and inconvenience of wearing the lifjacket in the first place. I have personally gone into the water, and onto thin ice, and lifted a drowned person out, it's risky, and just not very nice. None were wearing a life jacket.
Therefore, I wholeheartedly support this regulatory change, and hope that in the future it will extend more broadly to all smaller water borne craft. Perhaps, like seatbelts, life jacket use will become more common and accepted, if required to begin with!
For those who have not, go and take the underwater egress course, and
after that, return here to comment lifejacket use. I thought I could always get out with a life jacket in hand, until I tried to do it! I have swum in an inverted 185 during recovery, it is dark, and very disorienting. Somethings are much more difficult than you imagine!