Comment from Malcolm Mclellan

Document ID: NOAA-NMFS-2008-0325-0005
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: September 23 2011, at 12:00 AM Eastern Daylight Time
Date Posted: September 30 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: July 25 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: September 23 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80f295b1
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The section title of proposed section 680.20(i) appearing on Federal Register page 49430 is broader than the substance of the regulation. The title states "Other Procedures, Policies, and Decisions" whereas the substance of the regulation refers to "procedures." The title and substance should conform to prevent ambiguity. Furthermore, the proposed section 680.20(i) states "The arbitration organizations, market analysts, arbitrators, or third party data providers are authorized..." The term "arbitrators" is assumed to refer to both "Contract Arbitrator(s)" and "Formula Arbitrator." Referencing both functions rather than using the single term provides clarity and prevents ambiguity. Also, the proposed regulation refers to the plural "market analysts" whereas the existing regulations refer to one Market Analyst for each fishery. Use of the singular term avoids ambiguity. Finally, the existing regulations capitalized the terms "Market Analyst, Formula Arbitrator, Contract Arbitrator(s) and Third-Party Data Provider" whereas the proposed regulation uses the lower case. Use of the capalized terms provides consistency with the rest of the regulations. Please also consider these comments in Docket No. 0812081573-1423-02.

Related Comments

   
Total: 2
Comment from Malcolm Mclellan
Public Submission    Posted: 09/30/2011     ID: NOAA-NMFS-2008-0325-0005

Sep 23,2011 11:59 PM ET
Comment by Steven K. Minor, NPCA
Public Submission    Posted: 10/04/2011     ID: NOAA-NMFS-2008-0325-0007

Sep 23,2011 11:59 PM ET