Comment from Sera Drevenak, n/a

Good Afternoon, Thank you for the opportunity to submit comments on the NS1 guidelines. The draft rule provides inadequate accountability for a failed rebuilding plan when it states that the rebuilding F should be reduced to no more than 75% MFMT at 73 FR 32532; §600.XX. In many cases this F rate is sufficient to overfish, and as such is not appropriate and does not provide incentive for the Councils to comply with their rebuilding plans. A more appropriate level such as 50% MFMT would help to ensure the success of rebuilding. Furthermore, the Councils have had a tendency (see South Atlantic red snapper) to avoid stock assessments for decades on stocks in rebuilding plans to avoid the news that the rebuilding has failed. At the end of a rebuilding plan, a stock update or assessment must be done in order not to trigger the failed rebuilding accountability measures. An accountability measure of 75% MFMT is, in the South Atlantic, very close to status quo for healthy fisheries, so it is certainly not effective as an accountability measure. I believe that the failure of a rebuilding plan (at Tmax, not Ttarget) should carry the most severe consequences of any missed limit since it is indicative of chronic overfishing. Thank you, Sera Harold Drevenak Bolivia, NC