Comment from Michael Miglini, Out to Sea Adventures

I oppose making vessels with a federal charter permit comply with federal regulations in state waters until such time as all anglers in a state must comply with federal regulations in the state’s waters. This interim rule unfairly discriminates against charter vessels and those who cannot afford to have their own private boat. It also circumnavigates the intent of the federal rulemaking process by using interim measures to effect the intent of federal regulations which were summarily rejected by several states as offensive and thus failed due process reasonably owed to the states. This interim rule will have the same effect as passing the rule permanently as most charter vessels will be unable to recover from the economic harm caused them during the interim period thus denying those stakeholders due process. NMFS owes it to our fishery and the stakeholders to use data and methods which so impress the people in each state that those people vote to allow the state to use federal regulations.