Comment from Jan Jacobs, American Seafoods Company

RIN 0648-AT91, recordkeeping and reporting supplemental proposed rule comments. In regards to data entry time limits for trawl and longline catcher-processors, our vessel crew have found the provision that requires submission "by noon each day to record the previous day's discard and disposition information" to be unworkable. The most obvious example of how this reporting deadline is a problem is, for example when a tow or set is retrieved just before midnight. Processing of tows often does not begin until hours after the haulback time. Observers obviously can't start monitoring and sampling a tow until it is being processed and in some cases an observers' work shift may end in the morning. This means that the vessel crew may not know about discard and bycatch estimates until the afternoon of the day after the previous day's tow has been retrieved. Our request is to change the time limit for when data is entered in elandings or the DCPL from "by noon each day to record the previous day's discard and disposition information" to "by midnight each day to record the previous day's discard and disposition information."