Comment from sharon young

By the agency’s own admission, important breeding and resting habitat is disappearing. Further, the agency acknowledges that there is no recent or reliable information on the current abundance and trends for this species. This is compounded by poorly quantified and largely unregulated levels of hunting both in Russia by Alaskan native hunters that may increase as ice cover shifts. There is already evidence of significant seasonal habitat loss and a high likelihood that the species will continue to lose important habitat. Additonal, more detailed, comments are attached.