Comment from Jennifer Hagen

The Quileute Department of Natural Resources Submits the following comments in addition to those submitted from Quileute Tribal Council. These comments are specific to the document “Regulatory Impact Review and Initial Regulatory Flexibility Analysis Interim Allocation of Pacific Whiting for 2012 and Reinstatement of Authority to reallocate Tribal Whiting 2012 and beyond (February 2012)” which is referenced in the federal register notice for 2012 Tribal Whiting Fishery (Ref February 22, 2012: 2012 Tribal Fishery for Pacific Whiting RIN 0648-BB85). In the above IRFA on page 8 it states”NMFS has prepared this IRFA and is requesting comments on this conclusion”. When we sought clarification on how NMFS intends to receive comment, NMFS staff responded that the deadline for comments published in the above referenced Federal Register notice in which the IRFA is referenced under “Classification”. Our findings are that there are a number of issues with statements, analysis and conclusions of the document which require a more complete dialogue. We are including a list of our highest priority items (although not listed in priority order): 1) In consideration of the extent of description of Treaty Fisheries, Quileute were not consulted regarding the information included in this report. 2) The report cites no references for the information included and contains several inaccuracies: a. While this report is open for comment along with the 2012 Tribal Fishery for Pacific Whiting (reference February 22, 2012 Federal Register: RIN 0648-BB85), the report was not part of the regulations.gov docket folder and was only available from NMFS staff directly. Further, this report is not attributed to any author(s) for inquiries or clarifications that commenter’s may have. b. Report utilizes “Ex-vessel value” however it does not reveal how it is calculated. c. Specific reference to Executive Order 12866 does not cite specific source in document to verify “significant regulatory actio