Dear N.M.F.S.,
I own the trawler"Last Straw"and have been cutting, freezing, and glazing ground fish at sea legally during 2010.
Under proposed rule 2011-2012Biennial Specifications and Management Measures:Amendment 16-5;and Amendment23, processing at sea will no longer be permitted.
My family and I reconstructed our vessel in 2008 making it vastly larger, more stable and efficient for freezing. In 2009 we added a back storage tank with low temperature storage for finished product, shelter decks, plate freezers, glazing chiller, etc.
By spring 2010 after capitalizing, engineering and trials, we perfected our process and are extremely proud of our product. Not an overnight sensation but at least a value added product that fits the system. Also we have kept one more "family wage" earner on our payroll this year.
I am requesting a permit or exception to your proposed rule, allowing my vessel and family to continue processing ground fish at sea.
Under Trawl Rationalization this enables us to continue trawling which will probably still be mixed species. We have both frozen at sea fish and iced fish when ever we deliver to our at-shore processor
Over all this is consistent with the Trawl Rationalization ITQ system as promoted to trawlers for the last seven years or so.
Thank you for your time and consideration. This is very important to us.
Sincerely
Brett Hearne
Comment from Brett Hearne
This is comment on Proposed Rule
Fisheries Off West Coast States: Amendments 165 and 23 to the Pacific Coast Groundfish Fishery Management Plan
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