Comment from Jeffrey Trulick, Citizen/Biologist

I have some concerns with the proposal and the FR information justifying it. While I agree that decisions should be fed from the botttom up with resource management (locals know better than Regions or national offices), it would be nice to have stated what the trend line is for this species since the fishery was created. Sharks in general are under great pressure and despite the species, the rule of thumb has been that since they were created as a fishery, the total numbers of organisms and the skew towards smaller sizes rules. With a projected shortfall by 2017 as stated in this FR notice, why is it acceptable to be at 0.11 vs. the "sustainable" threshold? How do we know that threshold is sound? What is the uncertainty in that 0.38 threshold and how close can we get with a skew in the male to female ratio? Is 0.37 OK? How about 0,25? Please consider managing this for the longer term recovery of larger adult and juvenile size classes as well as considering the effect on the prey items of Spiny dogifish and the effect on shark species as a whole as key pedators in the coastal chain. The rise of the rays and the hammering that the shellfish and other prey items are taking now due to the lack of an apex to predate tham needs to be considered and analyzed each time an FR notice is posted, not simply the biomass of landings.