Hello all, I am writing this email to call your attention to the fact (or remind you) that the U.S. National Oceanic and Atmospheric Administration is seeking comments on its draft List of Foreign Fisheries-a tool it is using to implement the US ban on imports of fish and fish products from foreign fisheries that do not meet US standards for marine mammal protection as required by the Marine Mammal Protection Act. Comments are due by May 1, 2020<https://www.federalregister.gov/documents/2020/03/17/2020-05380/fish-and-fish-product-import-provisions-of-the-marine-mammal-protection-act-2020-list-of-foreign>.
NOAA has created a fact sheet<https://www.fisheries.noaa.gov/webdam/download/67782930> that provides an overview of the process, and you can find more detailed information on the List of Foreign Fisheries, its development, and how it will be used on the NOAA Fisheries website: List of Foreign Fisheries<https://www.fisheries.noaa.gov/foreign/international-affairs/list-foreign-fisheries>. The main purpose of the List of Foreign Fisheries is to classify all fisheries exporting fish and fish products to the United States as either "exempt" or "export" based on the frequency and likelihood of incidental mortality and serious injury of marine mammals. The resulting classification will determine the kind of fishery-specific information that countries must provide to NOAA Fisheries in order for a foreign fishery to obtain a "comparability finding," which will allow its exports to enter the United States. Proper classification is crucial as only export fisheries must submit extensive information about the operations of its fisheries and their interactions with marine mammals and the status of those marine mammal populations in order to determine whether those fisheries are meeting US standards for marine mammal protection. Please consider reviewing the draft List of Foreign Fisheries and submitting comments directly to NOAA Fisheries<https://www.federalregister.gov/documents/2020/03/17/2020-05380/fish-and-fish-product-import-provisions-of-the-marine-mammal-protection-act-2020-list-of-foreign> if you have information that would help it correctly classify particular fisheries. For example, you may have information indicating that a fishery NOAA has preliminarily designated as "exempt," actually has a high likelihood of bycatch and should be reviewed as a potential "export" fishery. You may also reach out to myself Zak Smith ([email protected]<mailto:[email protected]>) or my colleagues, Sarah Uhlemann ([email protected]<mailto:[email protected]>) and Kate O'Connell ([email protected]<mailto:[email protected]>) as we prepare our comments. While the list is long (NMFS classified nearly 2,900 foreign fishery operations), you can easily focus in on fisheries you are familiar with to see if NMFS got it right or if it should reconsider its classification based on information you provide. Thank you for your time. Best, Zak Zak Smith Senior Attorney Director, International Wildlife Conservation Nature Program *Admitted in California Natural Resources Defense Council 317 E Mendenhall STREET, Suite D Bozeman, MT 59715 T 406.556.9305 [email protected]<mailto:[email protected]> NRDC.ORG<http://www.nrdc.org/>
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