Public Comment Process

G.U.L.F. Responsible Fisheries Management Scheme

The Public Comment Process

Audubon recognizes the value and necessity of external public stakeholder comment on the operation and development of the Program Scheme, including revisions to the documents, such as the Standard(s). The G.U.L.F. RFM Committees will consider comments based on their content and objectiveness with respect to providing improvements to the Responsible Fisheries Management Certification, consistent with the overall objectives of the Scheme.

How to Submit a Comment

The public comment period is now closed.

Stakeholders are welcome to submit comments/questions regarding the G.U.L.F. RFM Scheme to G.U.L.F. at any time. Information submitted outside the official Public Comment periods will be reviewed and forwarded to the appropriate committee(s) for consideration.

Email a Comment to John Fallon at

Procedures for Managing Stakeholder Input

Previous Public Comment Periods

On December 15, 2014 Gulf United for Lasting Fisheries (G.U.L.F.) opened a 60-day Public Comment Period on the G.U.L.F. Standard, (Issue I, V5, November 2014). G.U.L.F. accepted comments from December 15, 2014 through February 15, 2015. The initial 60-day Public Comment period is now closed.

Three submissions were received by G.U.L.F. during the Public Comment Period. Submissions were in the format of letters containing numerous comments within each. A list of comments received can be seen viewed in the Certification Comment Matrix.

On April 23, 2015, the Fisheries Technical Advisory Committee (TAC) met to review and preside over comments, where appropriate, and formulate responses. Each comment was addressed individually by the TAC during the full day session. Following the meeting, a response letter was sent to each of the three commenting organizations.

Additionally, the G.U.L.F. Standard underwent a technical review by the Irish National Accreditation Board (INAB), an International Accreditation Forum member. The TAC met on July 15, 2015 and December 12, 2015 to address the comments on the Standard received from the INAB technical review process.

At the December 12, 2015 meeting the TAC also began a detailed review of the Guidance to Assessment document, which will be released for Public Comment later in 2016. Many of the comments submitted in the initial 60-day Public Comment Period address elements of the certification contained within the Guidance to Assessment, such as scoring thresholds, outcomes and performance indicators, and these comments are being considered during the current revisions of the Guidance to Assessment document.

A finalized version of the G.U.L.F. Responsible Fisheries Management Standard (Version 1.1, March 2016) was approved by the Fisheries TAC at the  March 30, 2016 meeting.

A second round of public comment was opened for the G.U.L.F. RFM Standard Version 1.1 on April 15, 2016 and closed on May 20, 2016. Two submissions were received. Comments received from this second round have considered, where appropriate, to the Standard; however, the majority of comments received were comments that the TAC felt would be best addressed through the Guidance to Assessment and other program documents regarding governance and operations, which are planned for release in late 2016/early 2017. Comments are currently being held and  will be fully considered in 2017 during a full review of the RFM Program, including the Guidance to Assessment, Certification Requirements, and Scheme Manual in preparation for GSSI benchmarking.

On June 1, 2017 Gulf United for Lasting Fisheries (G.U.L.F.) opened a 60-day Public Comment Period on the following Standards and supporting documents:

•  The G.U.L.F. Responsible Fisheries Management Standard (Version 1.1, March 2016)

•  The G.U.L.F. RFM Guidance to Assessment (Version 1.1, September 2016)

•  The draft G.U.L.F. Chain of Custody Standard (Version 1.0, May 24, 2017)

•  The G.U.L.F. RFM Scheme Procedures #6-11. These documents define the Scheme’s procedures for Standard Setting and Maintenance (#6)Managing Stakeholder Input (#7)Complaints and Appeals (#8)Scheme Performance Monitoring and Internal Review (#9)Certification Body Performance Review (#10), and Document Control (#11).

G.U.L.F. accepted comments from June 1, 2017 through August 1, 2017. The initial 60-day Public Comment period is now closed.

One submission was received by G.U.L.F. during this Public Comment Period. The submission was in the format of a letter containing numerous comments pertaining to the G.U.L.F. RFM Standard, Guidance to Assessment and procedures. No comments were received on the G.U.L.F. Chain of Custody Standard. There were two submissions held from the previous public comment period that are also still in review. The current submission received was an update of a previous submission; therefore, two total submissions are now in consideration. A list of comments receive and a summary of how responses were addressed will be posted once all comments have gone through the review process with the appropriate G.U.L.F. RFM Technical Advisory Committees. UPDATE: the following public comment matrix contains the comments received and currently in review. This chart will be updated to include responses once the appropriate committees have finalized review and response.

Public Comment Matrix

On October 8, 2017, a final public comment period was opened for the G.U.L.F. Chain of Custody Standard. The Public Comment period for this standard was open from October 8 through November 9. No comments were received at this time.

A Public Comment period for the following documents was open for 30 days from January 18, 2018 through February 19, 2018:

The G.U.L.F. Responsible Fisheries Management Standard (Version 1.2, January 2018)

The G.U.L.F. Guidance to Assessment (Version 1.2, January 2018)

No additional comments were received during this period and comments from the prior period (June-August 2017) are still in review.

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