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regulation of migratory fisheries in state waters. This approach 

 has effectively resolved the non-implementation problem for 

 striped bass, and needs to be extended to all east coast 

 interjurisdictional species. 



With respect to the draft legislation and the specific 

 issues on which you have requested comments, we offer the 

 following: 



o Roles of the Secretaries of Interior euid Ccmnierce - New 



York recognizes and appreciates the strong involvement 

 of both the U.S. Fish and Wildlife Service and the 

 National Marine Fisheries Service in the Atlantic 

 States Marine Fisheries Commission's Interstate Fishery 

 Management Program. Under the current organization of 

 the federal government, the continuing involvement of 

 both agencies is critical to maintaining this 

 successful state-federal partnership. Therefore, we 

 support establishing a role for each Secretary in 

 implementation of sanctions under the proposed 

 legislation. The consultation process established in 

 Sec. 5(a) of the proposed legislation is one way of 

 establishing such roles. 



o Time Frames for Plan Implementation - Section 



3(a)(4)(B) of the proposed legislation gives states up 

 to one year following enactment to fully implement and 

 enforce the provisions of most management plans 

 previously adopted by the Atlantic States Marine 

 Fisheries Commission, and six months for wea)cfish. 

 While we strongly support prompt implementation of all 

 existing management plans. New Yorlt recognizes that 

 some states may need more than one year to do so, 

 particularly when state legislative action is needed. 

 We recommend that a maximum period of 18 months be 

 allowed, following adoption of an implementation 

 schedule by the Commission. The proposed 90-day 

 period for the Commission's preparation of such an 

 implementation plan is adequate. 



New York is gratified that, under your leadership Mr. Chairman, 

 the Fisheries Management Subcommittee is actively considering 

 legislation which would implement the recommendation of the 

 Governor's Coastal Task Force, and which will help assure 

 implementation of necessary management measures for all east 

 coast fisheries. We urge you to act favorably upon this 

 legislation, and look forward to working with you on other 

 important issues. 



WP51:C 

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