Comment from Arni Thomson

Document ID: NOAA-NMFS-2010-0108-0002
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: June 04 2010, at 12:00 AM Eastern Daylight Time
Date Posted: June 15 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: May 5 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: June 4 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80afbf07
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June 2, 2010 M r. Earl Bennett Acting Chief Financial Services Division NMFS Attn: F/MB5 1315 East-West Highway Silver Spring, MD 20910 Re: Proposed Rule for the Fisheries Finance Program (“Proposed Rule”) Dear Sir: The following comment on the Proposed Rule, published in the Federal Register on May 5, 2010, is provided on behalf of the Alaska Crab Coalition (“ACC”). The ACC is a trade association representing the owners of crab fishing vessels that operate in the Bering Sea and Aleutian Islands (“BSAI”). The ACC strongly supports the Fisheries Finance Program, which has proved enormously beneficial to its participants. The ACC notes that extension of the IFQ loan program to the BSAI crab fisheries was integral to their rationalization and, accordingly, was expressly included in the Act of Congress that authorized and directed establishment of BSAI crab catch shares and related measures. The loan program is the only element of BSAI crab rationalization that has yet to be implemented, an approximately five-year delay that must not be further prolonged. The ACC, which has been deeply engaged in the development and implementation the BSAI crab catch share program, believes that the Proposed Rule conforms to the intent of Congress, the North Pacific Fishery Management Council, and the Secretary of Commerce, in the crab rationalization program. Accordingly, the ACC urges that the Proposed Rule promptly be made final. Thank you for the opportunity to comment on the Proposed Rule. Arni Thomson Executive Director Alaska Crab Coalition

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