Comment from William Sardinha, Sardinha & Cileu Management Inc

I assist with the management of 4 US tuna vessels that fish in the Western Pacific. I understand the intent of the US Govt to issue regulations to comply with the conservation ideals of the WCPFC. However at this time I have to support the only real Alternative to the Proposed rule -"The No-Action Alternative" as there are many items that are still being discussed and are a "Work in Progress". The method of Conservation to limit Fishing Effort, the FAD restrictions, and Observer Requirements although seem to be simple have a lot of details that if not written and applied correctly can have adverse effects. The US vessels have been following diligently the substance of the WCPFC ideals without the regulations. The US was one of the few countries that complied with the High Seas Pocket and FAD closure when CMM 2008-01 was put into effect. I also would be very careful with limiting the number of fishing days, Intl or otherwise, as not to put the US vessels at a disadvantage. It seems right after the US limits their fishing days by law, additional days magically appear for the region except for the US vessels. Yes we want to conserve, but we cannot cut back while everyone else expands their fishing fleets and fishing days. We must be careful. The US was the first vessels to agree to have observers in the West. Observers are a must but we must define our obligations and rights of observers especially when the PNA is requiring everyone to convert to Vessel Days. I do not believe we should jeopardize our vessels by an unstantiated claim from an untrained or inexperienced observer. The US vessels do not need more regs at this time. What is needed is enforcement on Non-US vessels that break the rules. Us Vessels have not had any major problems with the Treaty or WCPFC and I do not see the necessity at this time to regulate a "Work in Progress". I support the No-Action Alternative at this time.