Re: what brakes
in the FMVSS it states that trailer brakes must be capable of independant activation from the cab. This was squarely aimed at heavy commercial trucks and trailers, but there is no exception for our pickups and SUV's. Surge brakes do not meet this requirement.
I hate it when people give incorrect and outdated information.
First of all, these rules were in the Federal Motor Carrier Safety Regulations which are solely concerned with COMMERCIAL vehicles and not the Federal Motor Vehicle Safety Standards which govern all vehicles. So they don't apply to private trailers and never have.
Secondly, these rules were overturned last year. The new rules, directly from the FMCA website (section 3.93.48) clearly state:
(d) Surge brakes. (1) Surge brakes are allowed on:
(d)(1)(i) Any trailer with a gross vehicle weight rating (GVWR) of 12,000 pounds or less, when its GVWR does not exceed 1.75 times the GVWR of the towing vehicle; and
(d)(1)(ii) Any trailer with a GVWR greater than 12,000 pounds, but less than 20,001 pounds, when its GVWR does not exceed 1.25 times the GVWR of the towing vehicle.
(d)(2) The gross vehicle weight (GVW) of a trailer equipped with surge brakes may be used instead of its GVWR to calculate compliance with the weight ratios specified in paragraph (d)(1) of this section when the trailer manufacturer?s GVWR label is missing.
(d)(3) The GVW of a trailer equipped with surge brakes must be used to calculate compliance with the weight ratios specified in paragraph (d)(1) of this section when the trailer?s GVW exceeds its GVWR.
(d)(4) The surge brakes must meet the requirements of ?393.40.
Even if these rules applied to private trailers (which they don't), I don't think there is a trailerable boat that falls outside these limits.