Comment from Eric Takakjian

I wish to comment on the proposed rule for Framework Adjustment 5 to the Atlantic Mackerel, Squid and Butterfish Fishery Management Plan. This rule making proposes to expand the list of individuals qualified to certify fish hold volume. I am concerned that the expanded list of qualified individuals, while better than what was originally proposed still is exclusionary in nature to independent marine surveyors that are not members of the private surveyors organizations SAMS or NAMS. There are many independent accredited marine surveyors working today with extensive experience conducting surveys on commercial fishing vessels that are not members of either SAMS or NAMS. These individuals should not be excluded from this legislation. In some cases these independent surveyors may have been the attending surveyor for a particular vessel or fleet of vessels over a period of time spanning years. These individual surveyors know these vessels better than anyone. Thus language should be added into this legislation to included "Independent Marine surveyors with a history of conducting commercial fishing vessel surveys. Due to the delay in the rule making process, and in fairness to the vessel owners, the deadline vessels with tier 1 and 2 permits for submitting fish hold measurements should be extended to december 31st 2013 as proposed.