Comment from Patrick Flanigan, Law Office of Patrick Flanigan

Section 600.135 should provide a minimum of 45 calendar days, instead of 14 days, prior notice for meetings. Excluding FR publication and the day of a meeting, actual notice is 12 days. Fishermen do not have regular or easy access to the Federal Register, if any at all. It is unreasonable to consider publication as notice to the industry. Most notice to fishermen is through verbal communication. Being at sea for extended days may easily foreclose reasonable notice and the opportunity to participate. “Wide publicity” should require NMFS to regularly publish notices in trade magazines (local and national) and distribution via VMS, even though email is not sufficient.