Boston March 15^th, 2015 NFI supports many of the recommendations of the Presidential Task Force on Combating IUU Fishing and Seafood Fraud. A focus on strengthening international capabilities, enforcement and enhancing tools already in place will be essential to address illegal fishing.

Questions remain about execution, duplication of existing government efforts and funding.

It is essential that NOAA resources continue to focus on the science-based decision-making that is the basis of sound U.S. fisheries management. Diverting resources from stock assessments to fund programs that duplicate other agencies responsibilities would be a mistake

Calls for greater coordination to avoid duplication and waste of government resources should be heeded.

For instance, the FDA has already identified commercial species at risk for fraud through its DNA testing program and NOAA has already identified regions, countries and companies at risk for IUU. Leaning on this already completed work will help avoid duplication.

Likewise, consideration of changing regulations, like using the common name of fish, rather than the market name, should be avoided in order not to confuse shoppers while costing producers, processors, restaurants, retailers and ultimately consumers.

We are pleased the Task Force has focused on this challenge and appeal to the agencies now tasked with carrying out these recommendations to do so with a cost-effective, targeted approach. Expanding the program outside of at-risk species makes little tactical sense and even less fiscal sense.

John Connelly

President, National Fisheries Institute