Comment on FR Doc # E8-11253

June 17th, 2008 Rodney R. McInnis Regional Administrator - Southwest Region National Marine Fisheries Service 501 West Ocean Blvd., Suite 4200 Long Beach, CA 90802 E-mail: 0648–AU26.SWR@noaa.gov Fax: (562) 980–4047 Docket No. 071106669–7824–02 Rule ID No. 012607A-PR Dear Mr. McInnis, The Pew Charitable Trusts Antarctic Krill Conservation Project is an international nonprofit coalition that recognizes Antarctic krill’s role as the foundation of the Antarctic marine ecosystem and, consequently, works to secure a precautionary and ecosystem-based management regime for the krill fishery in the Antarctic. We would like to convey our support for the proposed rule 012607A-PR providing complete protection for all species of krill off the West Coast of the United States. This rule correctly establishes krill’s need for protection by recognizing it as a keystone species of the West Coast marine ecosystem. In the Pacific, krill is the major food source for many marine organisms, including some threatened and endangered species, many of which have been either overfished or seriously depleted. We commend the Pacific Council for taking this action and for the issuance of this rule and we urge you to finalize it as soon as possible. We further urge NMFS/NOAA to (1) quickly set in motion new decision-making processes that expand the merits of this rule and make the prohibition on future harvesting of krill a national policy in U.S. waters; and (2) work with the U.S. Department of State to ensure that an ecosystem-based approach to preserving the ocean forage base informs U.S. international fishery policy. This rule importantly recognizes the growing market for krill as a food source for farmed fish. Currently, krill is being fished from the Antarctic for a variety of uses, including as a component of aquaculture feed, despite the fact that Antarctic krill fills the same role and importance in the marine food web of the Southern Ocean that other krill species fill in the West Coast of the United States. As mentioned in the proposed rule, in the Antarctic the complete overlap of the krill fishery with the foraging areas of krill-dependent predators is of high concern due to the fishery’s potential for causing localized depletion of Antarctic krill and subsequent impacts on krill predator colonies that have krill as the main food source. The impact of the krill fishery combined with climate change related effects, which are especially acute on the areas where the fishery operates, could have serious consequences for the Antarctic marine ecosystem. As recognized in the proposed rule, a reduction of krill availability for predators in the Antarctic has already been observed. While the proposed rule to ban the krill fishery in the West Coast is commendable, it is also important to remember that the U.S. is planning to significantly increase, by up to six, the number of vessels flying the U.S. flag fishing for Antarctic krill. This development is of major concern to the Antarctic Krill Conservation Project, and is particularly relevant in light of the likelihood that these krill fishing operations could have the same impacts in the Southern Ocean as the proposed rule is attempting to prevent in the Pacific. Regards, Gerald Leape Director, Antarctic Krill Conservation Project Pew Environment Group