Comment from Alice Schreiber

Sharks are an invaluable species as an apex predator. The Shark Conservation Act does not include language to prevent states from banning the sale of shark fins. It's sole purpose was “to adopt shark conservation measures, including measures to prohibit removal of any of the fins of a shark (including the tail) and discarding the carcass of the shark at sea”. NMFS should NOT include text in the proposed rule to implement the Shark Conservation Act that would preempt the state and territory shark fin laws. The federal government should not force states and territories to participate in the shark fin trade. Requiring states and territories to allow the shark fin trade only for fins from sharks caught in US federal waters would 1) likely be illegal as it would violate international trade laws by creating unfair trade barriers; and 2) create enormous burdens on state law enforcement agencies, which do not have the capacity to track the chain of custody for every shark fin.