Comment from Rosamonde Cook

I am writing to comment on proposed rules to implement the Shark Conservation Act, signed into law in 2010. This law marks an important step forward in the management of U.S. shark populations and a critical move toward reducing the threat of extinction faced by many shark species worldwide due to the unremitting demand for shark fin soup. In particular, I ask you to remove any language from the proposed rule that would preempt, attenuate, or overturn laws passed by states such as mine (California) to ban the possession, sale, and trade in shark fins. It is within the rights of the people of any state to implement bans on such activities that pose an imminent threat to the wildlife within its jurisdictional borders and beyond. The ban on trade in shark fins passed last year by California was overwhelmingly approved by the general public. The Shark Conservation Act will help protect sharks within U.S. waters, but it will not go far enough to control the terrible harm to our marine life caused by the massive international trade in shark fins, demand for which remains the greatest threat to the survival of shark populations worldwide. Laws implemented at the federal level should complement, not diminish the effectiveness of efforts by the states to reduce the impact of this demand. I believe it was never the intention of the Shark Conservation Act to restrict or overturn laws passed by individual states to protect sharks. I further believe that the Fisheries Service must withdraw this portion of the rule because it would 1) issue regulations before understanding the full environmental and economic impacts of the proposed action, 2) impose regulations about potentially preempted state laws without explicitly identifying specific laws in question, and 3) send a message to individual states that they lack the legal authority to implement laws protecting wildlife that go above and beyond federal requirements, which is certainly not the case. We need a Shark Conserv