I support removal of the income qualification requirements for renewal of Gulf of Mexico (Gulf) commercial reef fish permits. Income qualification during rebuilding places an undue and unnecessary hardship on artisanal fishermen trying to stay in the fishery while working other jobs. Income qualifications are also an unfair burden to small owner-harvesters of IFQ allocations.
I support the removal of any crew size limit on dual-permitted vessels since I have heard no strong reason crew sizes should be micromanaged by federal regulation especially given the IFQ requires declaration of trip type. If the crew size could not be completely removed then increasing the maximum crew size to four for dual-permitted vessels (i.e. vessels that possess both a charter vessel/headboat permit for Gulf reef fish and a commercial vessel permit for Gulf reef fish) that are fishing commercially would at least be a step in the right direction.
Comment from Michael Miglini
This is comment on Proposed Rule
Fisheries of the Caribbean, Gulf of Mexico, and South Atlantic: Reef Fish Fishery of the Gulf of Mexico; Amendment 34
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