Firstly, is a 22 foot boat that goes further than 3 miles from shore required by SOLAS laws to carry a life raft?[From the SOLAS website: "The SOLAS Convention in its successive forms is generally regarded as the most important of all international treaties concerning the safety of merchant ships.(emphasis mine.) The first version was adopted in 1914, in response to the Titanic disaster, the second in 1929, the third in 1948, and the fourth in 1960."]


Secondly, your reply sounds like the excuses that victims of boat accidents come out with after they have been rescued.

If a group end up in the water it is very hard to keep together, each person in that situation would really benefit from a PLB.[Safety tethers notwithstanding? If we can't clip together then we are probably dead already.]

At 20 miles out, the water is going to be cold. [We know this. I live in the Pacific Northwest. The water is cold at 100 yards out.] If no one notices your distress, you have failed radio coms and have to rely on the Epirb to alert to a problem; you could be in the water for some time. [Did you notice my remark on redundancy, specifically hand held vhf? Did you get the part where I mentioned travelling in a wolfpack?] If you have an older 121.5 Mhz Epirb you could be in the water for 6 hours before the message is passed to the relevant ground resources.[We carry a 406mhz unit.] You may be an hour’s flight time for a helo.[Anything can happen, of course, but the USCG patrols on land and air over the sportfishing grounds.] You are likely to be at least very cold if not floating face down.

Relying on NOAA and USCG reports can not be relied on. Weather reporting is very fickle at the best of times. [That's why their is no substitute for judgment. You also have to know what to watch for and when to turn back. This omission, not poor forecasting, was Kennedy's downfall. (Oops. Bad Pun.)]I think it was the Kennedy plane crash where one of the contributing factors was poor weather forecasts. There are plenty other examples of this fact too.

Cost and space is again a common excuse for not having equipment and another is my boat is unsinkable. If you can afford a boat you should be a able to afford the safety equipment. Space is a very poor excuse; there are always options available to you that take up dead space. [You clearly have no idea of the layout of my boat. Of course, I could tow a liferaft behind my boat.]
I’m not judging you, just highlighting the facts.[The facts as you see them. how can you possibly understand what is factual half a planet away?] At the end of the day the decisions are yours.[ As I said, it becomes a question of risk adversion and trade-off. Of course I could buy a larger boat...]