Comment from Christina Lizzi

Please find attached comments regarding 0648-AY68. SPECIFIC SUGGESTIONS Given a number of deficiencies and failure to analyze other viable alternatives, we urge the Secretary to reject Am. 20 and 21 as written. The following are specific suggestions to improve Am. 20 and 21. Ownership and control of quota share and pounds should be restricted to owner-operators, defined as active seafaring fishermen - captains and crew that meet reasonable eligibility criteria. Accumulation caps should be conservative, and structured to optimize social results as opposed to economic efficiency. Systems should be adopted to ensure quota can be controlled by communities, not only individual large-scale operations to minimize adverse community impacts. The best scientific information available should be utilized, including lessons learned from the implementation of catch share systems both nationally and internationally. The implications of mandatory on-board observer coverage should be reviewed. The cost of mandatory observer coverage should not impair the ability of an operation to make a reasonable economic profit. Cost-sharing programs should be established for operations that fall below a specific revenue threshold to ensure diversity in the fleet. The adaptive management set-aside should be used to mitigate one-off transition impacts including the one time resolution of proven stranded capital issues. It should then be held, to provide an incentive pool for conservation results and for further transitions as required to improve the program. The Department of Commerce should delay its decision to approve Am. 20 and 21 until a robust cost recovery system is presented for review. To fully meet National Standards set forth in the M-S Act, we urge Am. 20 and 21 as written to be rejected and rewritten to reflect a cap-rent-recycle approach.