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Proposed subsections 118(e)(5)(C) and 118(e)(6)(C) would require 

 the Secretary, if Conservation Teams are unable to submit draft 

 plans within 6 months where takes exceed PBR or 11 months where 

 takes do not exceed PBR, to publish a proposed plan and 

 implementing regulations. Because the Secretary would not be 

 responsible for drafting a plan until the deadline passed, these 

 provisions should be changed to allow the Secretary to publish 

 the necessary plan and regulations as soon as practicable 

 following the deadline. 



Proposed subsections 118(e)(5)(E) and 118(e)(6)(E) would require 

 that Conservation Teams meet semi-annually or annually to update 

 Conservation Plans and review progress in their implementation. 

 NMFS feels that such regular meetings may not be necessary. Once 

 the plans are developed, reviews and updates could be 

 accomplished through communication among group members, then 

 making proposed revisions subject to public notice and comment. 

 The latter approach may be much less costly than requiring annual 

 meetings. However, convening these meetings should be an option. 



The proposal to establish regionally-based Conservation Teams may 

 raise questions of responsibility for stocks whose distribution 

 crosses regional boundaries. The team from the region where most 

 incidental mortality occurs should take the lead in preparing 

 conservation plans in consultation with teams from other affected 

 regions. 



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