Comment from Timothy Ragen

The Service proposes to require replacement of currently required Mobile Transmitting Units (MTU) Vessel Monitoring System (VMS) units with Enhanced Mobile Transmitting units (E-MTU) VMS Units in Atlantic Highly Migratory Species (HMS) fisheries; implement a declaration system that requires information on target fishery and gear type(s) on board; and require that qualified marine technicians install all E-MTU VMS units. The replacement of VMS units will enhance enforcement by requiring the best available technologies for tracking and communicating with fishing vessels. Under domestic requirements and international obligations, the Service must maintain viable VMS programs in certain Atlantic HMS fisheries, including pelagic longline, bottom longline, and shark gillnet fisheries. VMS programs are vital in fisheries management, allowing enforcement of closed or restricted areas intended to reduce bycatch of fish, sharks, sea turtles, and marine mammals. E-MTUs will improve vessel tracking efforts and enable two-way, real-time communications on management, safety, and environmental matters affecting the fleet. Having qualified marine technicians install the E-MTUs will promote effective unit operation. The Service also should require vessels in the Atlantic HMS fleet to declare their target fishery and gear two hours before leaving port and provide three hours advanced notice of landing. Doing so would facilitate enforcement and monitoring, allowing enforcement agents to know what species would be targeted, what gear would be allowed on board, and what regulations would apply during a fishing trip. The pelagic longline gear used in the Atlantic HMS fishery (a Category I fishery) is subject to the Pelagic Longline Take Reduction Plan regulations (50 CFR 229.36), and the proposed declaration activities would facilitate enforcement and have conservation benefits for several stocks of dolphins, beaked whales, and pilot whales.