Comment from Rex Snyder

1. There has been limited or no meaningful consultation as per Ice Seal Co-management Agreement prior to listing. 2. A public scoping meeting needs to be held in Kotzebue, AK because of the high use of seal in the entire region and because the region sustains high densities of seal populations. 3. Traditional Knowledge needs to be included in stock assessment reports and other findings. 4. Hunters are, for the most part, reporting healthy seal populations. 5. Listing now may be premature and is difficult to undo – especially without knowing long-term trends. Is the population now at peak levels compared to fifty years ago? Is there a natural high/low cycle? 6. There has been consistently insufficient data on population dynamics in recent stock assessment reports. 7. There is insufficient data on prey dynamics and food availability; especially considering likely increases in primary production in arctic waters. 8. Habitat modeling trends are not sufficient and models can become drastically unbalanced based on a few covariate changes. 9. Seals may be more adaptable and resilient to environmental changes than thought. 10. Listing now may be premature with too many unknowns and will cause both overreaching and overarching federal management that will negatively influence customary and traditional subsistence.