Peter H. Flournoy

The proposed rule does not mention, but should, the exception to the foreign crew rule of 46 USC 8103(i)(1) contained in the Magnuson Stevens Act for US flag fishing vessels fishing for highly migratory species on the high seas. Furthermore, the long time periods provided for the USCG to act under the proposed rule will not work in the commercial fishing business where due to death, injury, or sickness crew replacements must be made within hours or at most days.