Comment from Cleo Small

BirdLife strongly urges an extensino of the public comment period from 30 days (June 22) to 90 days (August 21). Under the FAO Code of Conduct for Responsible Fisheries and the UN Fish Stocks Agreement, there is clear responsibility for fishing nations to share data. BirdLife’s interest is in the impact of global fishing fleets on non-target species such as threatened albatrosses, turtles and sharks. In order to understand and mitigate the impacts of global fishing fleets, it is vital that it is possible to pool data from global observer programs and make these data available to non-target taxa experts to analyze. Public access to such information is vital to ensure that fisheries management decisions are made in a manner consistent with public trust management global marine resources. A 30-day public comment period is an insufficient amount of time for affected members of the public and scientific community to voice their concerns. The desire for expeditious regulatory revisions should not outweigh the need for transparency in this process. All stakeholders must be allowed adequate time to comment on this critically important issue. Thank you for your consideration. Sincerely, Dr Cleo Small Senior Policy Officer BirdLife International Global Seabird Programme RSPB, The Lodge, Sandy, Bedfordshire, SG19 2DL, UK Tel: +44 (0)1767 693586