Comment from Sean Fitzpatrick

A senior in Political Science and Economics at The Ohio State University, I took a course on Food Politics where I wrote a term paper on the political, social, and economic effects of the collapse of the Atlantic cod. In the course of work for my class on the bureaucracy, I came across this ANPR and felt that after all my research I might have something to offer the discussion. So I wrote a memo on the rule detailing the issue, background, and explanation of the possible changes that were being considered and I have the following thoughts on numbers 2 and 4 of the discussed changes: 2. Eliminate the one-time upgrade provision Eliminating the one time upgrade makes a lot of economic sense. You incentivize vessel owners to make changes slowly overtime, a much more affordable solution for them while also making the process simpler to understand. The baseline vessel restrictions need not be significantly altered either to allow for this change. 4. Remove baseline upgrade restrictions for vessels under 30 ft Removing the baseline restrictions for smaller vessels will only shift the demand from larger regulated vessels to smaller unregulated ones. These new vessels while maybe shorter will be able to incorporate significantly larger tonnage and have a higher horsepower engine to make this more effective. Now these smaller vessels will simply be able to compete with many larger ones in overall capacity which allows for more potential dangers for overfishing by at the least creating a climate where it is easier to deviate from other regulations concerning catch size and while increasing negative effects to the fisheries and environment from emissions and access.