SEAFA Submits comments on Proposed Rules

SEAFA has written comments on several proposed rules with comment periods that have ended recently. We are posting links to the letters we submitted.  

The one comment period was for an advanced notice of proposed rulemaking for fishing vessel safety regulations in particular regarding stability and watertight integrity regulations for vessels 50 to 79 feet with training required of all operators and owners of vessels over 30 feet.  As of yesterday, the only other Alaska commercial fishing organization to write in was United Fishermen of Alaska and only approx 10-15 letters were received from across the country.

Fishing Vessel Safety requirements proposed rule Aug. 2008

The second comment period was regarding the EPA proposed rule for general discharge permits for the normal operation of a vessel.  EPA was pursuing these permit due to a court case regarding ballast water that required EPA to permit these discharges and that they did not have legal authority to exempt the discharges under the clean water act as they had been doing for these many years.  Legislation was introduced and passed by both houses of Congress to exempt recreational boats from permit requirements and gives the fishing industry a two year exemption while discharges from commercial fishing vessels are studied.   THE EXEMPTION DOES NOT APPLY TO FISH TENDERS!  We felt submitting comments on the proposed rule was important to help focus the study of discharges from commercial fishing vessels and to correct two very large erroneous assumptions made about commercial fishing vessels.  EPA in the proposed rule had commercial fishing vessels included with small cruise ships, ferries, barges tankers etc.  They assumed that every commercial fishing vessel has a certificate of documentation, since a commercial fishing vessel under 5 gross tons does not qualify for a certificate of documenation they are underestimating the number of commercial and size of commercial fishing vessels.  They also assumed that commercial fishing vessels were classified and regularly scheduled drydock maintenance.

EPA Discharge Proposed rule comments Aug. 2008

The documents for these proposed rules and all comments received by the public may be viewed from the following website by typing in the  document number listed on SEAFA’s letter in the search box.



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