During the implementation period, the U.S. State Department will likely further revise its guidelines to permit complainants to show they use A comparable methods to protect sea turtles from shrimp trawling, such as through limiting the time or area in which trawlers may operate.45 Revised guidelines should also offer foreign governments greater A due process rights, including the right to challenge A preliminary State Department findings before they become definitive, in particular concerning the local A condition of endangered sea turtles and the comparability of their shrimp trawling requirements.