Council Staff Council Meeting June 23, 2016 1 The MSA requires - - PowerPoint PPT Presentation

• Dr. Rachel Feeney

Council Staff

1

Council Meeting June 23, 2016

• 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• NMFS issued draft guidance for CSP reviews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.

2

TODAY: Approve NEFMC comments on revised draft.

• 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

NEFMC comments (January)

4

NOAA response to comments

NEFMC comment NOAA response

• 1. Review scope too

extensive. Regional flexibility, (throughout)

• 2. LAPP review

requirements unclear. Requirements listed (p. 8)

• 3. Council should lead

review. Council led, NMFS partner (p. 3-4)

• 4. Review team members

too prescriptive. Council sets team (p. 3)

• 5. Annual interim reports

unnecessary. Use existing reports (p. 4)

5

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)

6

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)