Comment from Frank Mirarchi

I support the proposed elimination of upgrade limits on limited access federal fishery permits. Existing rules have failed to control "capacity creep' resulting from a number of technological advances which are not addressed by constraints on tonnage, length and horsepower. Meanwhile these constraints have suppressed the needed replacement of aging and inappropriate vessels, creating safety hazards and diminishing improved efficiencies. The imposition of ACLs and AMs under MSRA have essentially made moot the complex and costly input controls adopted at the outset of limited access programs. Upgrade limits are a prime example of these obsolete rules and should be terminated.