Comment from Ivy Fredrickson

See attachment. Re: NOAA-NMFS-2012-0030, Magnuson Stevens Act Confidentiality, Proposed Rule On behalf of Ocean Conservancy, Earthjustice, Oceana, Natural Resources Defense Council, Environmental Defense Fund, Pew Environment Group and Conservation Law Foundation, we are writing in response to the National Marine Fisheries Service’s (NMFS) proposed rule regarding confidentiality of information under the Magnuson-Stevens Fishery Conservation and Management Act (MSA). Given the scope and great importance of this issue, we respectfully request an extension of the public comment period from 30 days (June 22) to 90 days (August 21). The regulations regarding confidentiality of information under the MSA is an issue that concerns not only MSA fishery permit holders, but also millions of Americans who benefit from the nation’s fishery resources. Fisheries observer data, in particular, is a foundation for sustainable fisheries management and for monitoring impacts on the oceans and ocean life including the incidental captures of marine wildlife species. The proposed rulemaking could significantly affect proper analysis of fisheries management decisions and severely limit the public’s ability to engage effectively in ensuring sustainability of our fisheries and marine wildlife populations. A 30-day public comment period is an insufficient amount of time for affected members of the public and scientific community to comment on the proposed regulations. The desire for expeditious regulatory revisions should not preclude allowing all stakeholders adequate time to comment on this critically important issue. Thank you for your consideration. Sincerely, Ivy N. Fredrickson, Ocean Conservancy Roger Fleming, Earthjustice Eric A. Bilsky, Oceana Seth Atkinson, Natural Resources Defense Council Peter Shelley, Conservation Law Foundation Monica B. Goldberg, Environmental Defense Fund Lee Crockett, Pew Environment Group