Monday, July 15, 2013

Let the Shark Nerds Help You Comment

The Shark Conservation Act closes loopholes in the U.S. finning law by requiring that all sharks be landed with their fins naturally attached. It amends the Magnuson-Stevens Act, the law that manages fishing in US waters. The state laws are more restrictive than the federal law, but have nothing to do with finning. Although there are exceptions, the state laws ban the sale, trade, and possession of shark fin. The federal government is proposing that the federal rules implementing the shark finning ban overturn the state bans on the sale, trade, and possession of shark fin.

A search of the Internet this morning discovered that the U.S. federal government has started posting the comments concerning the implementation of the Shark Conservation Act online. Mostly the comments are made by everyday activists, but some are from government officials and shark conservation organizations.

As of this writing, 2,188 comments have been posted. This is in addition to the 100,000 comments collected collectively by the Pew Charitable Trusts, Oceana, and Humane Society International (which will be submitted on the day of the deadline). We encourage you to sign all three organization’s well-written and effective petitions. Other organizations have encouraged their supporters to comment directly using the government’s website.

We do not encourage our supporters to comment on the government’s website because it has been our experience that these comments are often unhelpful, wrong, and ultimately a waste of your time. We want you to participate in this process, but we also want to make sure your voice is asking for the right thing. If your comment does not use the proper language, your voice will be heard, but it won’t help.

We have previously explained how to write a comment letter by providing the example of 8-year old Nick Silverstein’s letter. In three simple paragraphs Nick (1) introduces himself and explains why the President should listen to him, (2) gives some background information on the issue, and (3) makes a specific ask on how to amend the proposed regulations. Nick has an understanding of the issues at hand and does not confuse “shark finning” and the “shark fin trade.” Nick's letter is also handwritten and contained to a single page, which is preferable.

Many of the comments submitted to the government so far are problematic. We did a quick assessment of the 10 most recent comments posted and found that only 2 (but really only one) of them were actually helpful for preventing NOAA from overturning the state laws. (It is worth noting, however, that despite most comments being unhelpful, they were all at least supportive of our cause).

The best way for you to comment is to sign the petitions of the Pew Charitable Trusts, Oceana, and Humane Society International. Individual letters are also helpful, but only if they are factual, to the point, and make the proper specific ask.

We are shark nerds and we can help you. Email us at info@sharkdefenders.com.  The deadline to submit comments is July 31.

And in case you are interested, here is our short analysis of the 10 most recent comments:
“Sharks are an essential part if the ocean ecosystem. Please do not allow their needless killing.”
This comment is not helpful. This has nothing to do with this particular issue.

“I understand that the National Oceanic and Atmospheric Administration's fisheries management division recently proposed a rule that says state and territory shark fin laws are pre-empted if they are found to be inconsistent with federal fishery management plans or regulations. California recently passed a law banning shark fin trade. It is just being implemented, after a difficult fight put up by the shark fin lobby. I am writing to OPPOSE this rule. It allows the shark fin trade a loophole to start up again. I urge you to reconsider, and void the proposed rule. Sharks are a unique and essential part of our ocean ecosystem. We need to allow sharks to build back up their numbers. This rule will only lead to more dead sharks killed for their fins to make soup!!!”
A good comment!

“I want the Shark Conservation Act enacted”
Not helpful. SCA will be enacted, the question is how it will it be enacted.

“This potential regulation just allows a loophole to avoid punishment. The effort to save sharks would be seriously undermined if this is passed. Vote no on this correction to the Shark Conservation Act!”
The first sentence in this comment is false. The rest isn’t specific enough to be of any use.

“Even though I know that cultural traditions are very hard to give up, some - like killing sharks just for their fins - involve such barbaric and wantonly destructive practices that they must be banned in countries that claim to practice even a modicum of civilized behavior. Not only does shark finning threaten the survival of a magnificent species and ocean ecology in general, but it also is deplorably wasteful of what is otherwise a sustainable food source.”
This comment is not helpful because it only references shark finning, not the preemption of the state trade bans.  It also suggests that sharks would be a sustainable food source if they weren't finned, which is a controversial statement.

“Shark finning is ecologically unsound as well as inhumane. It has been banned with good reason where these prohibitions have been enacted. For a federal agency to try to preempt the will of the people is folly: fins "attached to a corresponding carcass" is hoo-doo verbiage to enable senseless killing of a dwindling marine population. Federal fishery management needs to honor the environmental choices of areas in which educated citizens have chosen a course of action suited to their locale and ecosystem.”
This comment is not helpful because it confuses finning and the state trade bans.

“Please don't undermine any state's ability to protect sharks from any more predation by humans (for fins or other parts of their bodies). We worked very hard in California to provide legal protection for these animals that are necessary for a healthy marine ecosystem.”
This is a decent comment, but it doesn’t get into specifics.

“I urge you not to change the Federal regulations in a way that would weaken or supercede the recently enacted California ban on shark finning, which is a barbaric and unacceptable practice.”
This is almost useable, but California does not ban shark finning. The federal law does that. California bans the shark fin trade.

“The National Oceanic and Atmospheric Administration's fisheries management division recently proposed a rule that says state and territory shark fin laws are pre-empted if they are found to be inconsistent with federal fishery management plans or regulations. The proposed regulation would allow fishermen to possess shark fins as long as they are "naturally attached to the corresponding carcass." This proposal once again opens the door to shark finning, a barbaric practice that has led to a dwindling shark population, which in turn threatens our entire ocean ecology. Please make a wise decision and do not allow shark finning in any form for any reason. This proposed NOAA rule should not be put into effect: If states make more restrictive (and thus wiser) laws, these should be honored in ordered to protect the long-term health of shark species, and the ocean. Thank you.”
This comment started off well, but implodes halfway through. California’s law doesn’t ban finning; it bans trade.

“Please do not implement your propsed rule that says state and territory shark fin laws are pre-empted if they are found to be inconsistent with federal fishery management plans or regulations. The proposed regulation would allow fishermen to possess shark fins as long as they are "naturally attached to the corresponding carcass." This will be the reintroduction of catastrophe for the shark species. This proposal once again opens the door to shark-finning, a barbaric practice that has led to a severely dwindling shark population, which in turn direly threatens our entire ocean ecology. Congressman Jared Huffman, who co-authored our California law as a member of the state Assembly, is working with other members of Congress to oppose the regulation. But he needs more voices to join him a loud chorus of "NO!" As a frequent visitor to California, with family and friends in the northern and southern sections of the state, I feel a close connection, and I realize the impact such a law would have. In JAWS, the shark was the villain, and still today this misinformation is put forth and believed. But in reality, humans are preying on sharks with devastating consequences for shark species and our environment, threatening our oceans and living planet. If passed, the proposal by the fisheries management division proposal would be a huge blow to global shark conservation and the movement to stop the cruel and wasteful practice of shark finning.”
The ask in this comment is correct, but the supporting information is false. The rule would not open California up to shark finning.

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