Dr. Rachel Feeney Council Staff Council Meeting June 23, 2016 1
• The MSA requires periodic review of all Limited Access Privilege Programs (LAPPs) established after 2007. • NOAA expects reviews of all catch share programs (CSPs), LAPP or not. • NMFS issued draft guidance for CSP reviews in October 2015. • Most Councils commented in January 2016. • Revised draft issued May 2016. TODAY: Approve NEFMC comments on revised draft. 2
NEFMC comments (January) 1. Review scope too extensive; focus on what applies to all CSPs; provide latitude to tailor reviews. 2. Distinguish legal requirements for LAPP reviews from recommendations/best practices. 3. The Council should lead review; report should be a Council document. 4. Too prescriptive on the review team members. 5. Annual interim reports unnecessary, unfeasible given current human resources and commitments. 3
NOAA response to comments NEFMC comment NOAA response 1. Review scope too Regional flexibility, extensive. (throughout) 2. LAPP review Requirements listed requirements unclear. (p. 8) 3. Council should lead Council led, NMFS review. partner (p. 3-4) 4. Review team members Council sets team too prescriptive. (p. 3) 5. Annual interim reports Use existing reports unnecessary. (p. 4) 4
NEFMC DRAFT comments (June) 1. Acknowledges NOAA’s responsiveness to input from all the Councils. 2. For allocation reviews, silent on how to weigh tradeoffs when determining if net benefits to the Nation have been maximized? (Use 2015 NMFS allocation review guidance) 3. Review team should not judge whether a program should be continued or eliminated. (Council’s job) 5
NEFMC DRAFT comments (June) 4. Review team should not judge if reporting burden and administrative costs are being “minimized to the extent practicable.” (NMFS’ job) 5. Review team should not judge if enforcement activities/resources ensure “high” (???) compliance. (NMFS’ job) 6. Remove reference to Scallop Amendment 11 goal as being “unclear”. (means objectives OK) 6
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