Regarding the linked documented mentioned above as promulgated by the National Association of State Boating Law Administrators, I did find some information contained therein that seems to have been omitted from the local TV news broadcast that was the initial subject of this discussion. In particular, I note the following:
Boats Affected by Federal Regulations
Vessels imported or manufactured prior to November 1, 1972 do not fall within the regulations, but may be treated as such by the states[.]
Source:
http://www.nasbla.org/files/VIRT/2016/A ... deline.pdf, unnumbered folio, page 22 of 41 of the digital document file.
On boats built prior to November 1, 1972 [s]tates are not required to [generate] a [s]tate HIN but may do so.
Source:
http://www.nasbla.org/files/VIRT/2016/A ... deline.pdf, unnumbered folio, page 35 of 41 of the digital document file.
I do not find that the publishing organization, National Association of State Boating Law Administrators (NASBLA), to have any particular authority in this area. Their advice appears to be advisory and does not have regulatory implications. On that basis, I don't see how there can be nationwide concern about the possibility of difficulty in registration of an older Boston Whaler boat made prior to 1972 that has no manufacturer-provided, federally-compliant HIN. Whether or not a particular state will permit registration of such a vessel seems to be entirely left to the state to determine.
The linked document does contain a specific reference to actual federal law:
33 CFR ยง 174.16 (b)
As of January 1, 2017, before taking any action relating to a vessel imported or manufactured on or after November 1, 1972, the issuing authority must determine whether the vessel has a primary HIN meeting the requirements of 33 CFR part 181, subpart C.
Source:
http://www.nasbla.org/files/VIRT/2016/A ... deline.pdf, unnumbered folio, page 4 of 41 of the digital document file.
A better source of information on federal regulation for this specific section is perhaps found at
https://www.law.cornell.edu/cfr/text/33/174.16From that source, I quote:
As of January 1, 2017, before taking any action relating to a vessel imported or manufactured on or after November 1, 1972, the issuing authority must determine whether the vessel has a primary HIN meeting the requirements of 33 CFR part 181, subpart C.
Note that there is no mention in the federal regulations that the states "may" apply the same regulations to boats made prior to November 1, 1972. The notion that states "may" apply the same regulations to boats that were built 45-years ago seems to have been invented by the National Association of State Boating Law Administrators.
It would be rather stupid for a state to add to its own administrative burden of boat registration the additional task of creating state-generated HIN numbers for 45-year-old boats that complied with all the minutia of the federal regulations. That a state would do this, however, is not beyond belief. Some bureaucracies love to generate more work for themselves.