Comment Submitted by MORAN TOWING

As an Operations Manager for a tug and barge company operating in the Port of New York and New Jersey, I oppose the proposed rule as written. Safe, designated anchorage areas are a critical tool for commercial mariners. Tug and barge operators rely on them to safely manage changing weather, tides, traffic, mechanical issues, crew considerations, and other operational circumstances. Removing or restricting these anchorage options reduces flexibility and could force vessels to operate in less safe conditions. Commercial towing plays a vital role in moving fuel, construction materials, and other essential cargo throughout the region while reducing congestion on our highways. Any changes to anchorage availability should be based on sound navigation and operational considerations and should fully account for the impact on the Maritime Transportation System. I respectfully ask the Coast Guard to reconsider this proposal and continue working with the maritime industry to develop a solution that maintains safe navigation while meeting the objectives of the rulemaking. Thank you for the opportunity to comment.