Comment on FR Doc # E8-07068

The Center for Biological Diversity submits these comments regarding proposed modifications to permitting and reporting requirements for the Highly Migratory Species (“HMS”) International Trade Permit (“ITP”) (RIN 0648-AU88). While we agree with efforts to more effectively regulate trade in highly migratory species, we believe that the proposed rule should be strengthened in order to provide meaningful protection to these species, especially sharks. As noted in the preamble to the proposed rule, export of shark fins drives much of the Atlantic shark fishery and has contributed to the depletion of a number of shark species. 73 Fed. Reg. 18473, 18475 (April 4, 2008). Currently, it is difficult to track where shark fins are exported to or if they are obtained, transported, and exported according to relevant regulations. The proposed rule would require shark fin traders to obtain an HMS ITP, resulting in some additional information regarding the identity of individuals involved in the shark fin trade. However, the proposed rule stops short of providing much of the information needed to track and enforce limits on shark fishing, fin trade and export because it excludes shark fins from most of the proposed rule’s reporting, documentation, and recordkeeping requirements. NMFS should amend the proposed rule to apply the same reporting, documentation, and recordkeeping requirements to shark fin traders as are applied to traders in other highly migratory species. The additional information NMFS would gain from applying these requirements to shark fins could prove vital to efforts to conserve shark populations and enforce existing regulations. Given the substantial threat that the shark fin trade poses to shark populations and the prevalence of illegal shark fin trading activity, it is critical that NMFS closely track any trade in shark fins. We appreciate your consideration of these comments.