MakingWaves Waves Winter Summer 2016 Making 2016
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thing more in line with a 70% to 80% reduction surveys, mesh sizes, historic trends and someby way of lost business stemming from decreased times arbitrary reference points. angler interest and effort. So, are you happy with our federal government? Not to mention the cost and expense to the priDo you trust the data? Think one more cutback in vate angler, paying $50 for a tank of gas, bait, ice the recreational harvest of summer flounder will and the tackle required for the opportunity to be the last? Remember those days when they bring home just two fish (three if you’re lucky pledged, “sacrifice today, rebuild the fluke and enough to get your weakfish bag limit too) – the sea bass fishery, and in a few years you’ll have American public is essentially being denied acthe best regulations you ever had”? Sounds more cess to a natural public resource based on trawl like a campaign pledge, doesn’t it?
RFA LETTER TO MAFMC/ASMFC ON SUMMER FLOUNDER QUOTA REDUCTION RE: 2017 and 2018 Summer Flounder Specifications The Recreational Fishing Alliance (RFA) respectfully submits the following comments in regards to the 2017 summer flounder specifications. RFA acknowledges the Magnuson Stevens Fishery Conservation and Management Act (MSA) 16 U.S.C. 1852, § 302(h)(6) which mandates that the regional fishery management councils may not develop annual catch limits that exceed the recommendation of its scientific and statistical committee (SSC). Noting that guidance, the MidAtlantic Fishery Management Council (MAFMC) put forward a 2017 acceptable biological catch (ABC) for summer flounder of 11.30 million pounds for 2017 and 13.23 million pounds for 2018 consistent with their respective SSC’s recommendation. However, NOAA, in its final approval of the 2017 specifications, is not bound by this section of MSA. Therefore, the agency has the ability to set the 2017 and 2018 ABC’s at but not exceeding the overfishing limit (OFL) set by the 2017 assessment update. Such action, if taken by NOAA represents the maximum allowed by law and legal precedence. With that in mind, the RFA requests that NOAA sets the 2017 and 2018 ABC’s for summer flounder at the 2016 ABC of 16.26 million pounds for each year. This
number is below the 2017 and 2018 overfishing limits of 16.76 million pounds and 18.69 million pounds respectively. As you are aware, the departure of the SSC ABC recommendation of 11.30 million pounds from the OFL 16.76 million pounds is a product of the Council risk policy that mandates a reduction of available quota based on uncertainty. Specifically, section §648.21(b)(2) that deals with a fishery not under a rebuilding plan with a typical life history. RFA must assume that when this section of the policy was adopted that few could foresee the pending implications. The RFA does not support the principle of above section as it applies to rebuilt fisheries. Specifically, the application of the risk policy language to the summer flounder fishery in concert with MSA § 302 (h)(6) is extremely problematic. With a stock that has a long management history with NOAA and which has undergone significant rebuilding success, it is not in the best interest of the Council or the fishing industry to defer all authority to manage risk to the SSC. Summer flounder was rebuilt in 2010, continues to be extremely robust and will have stronger year classes moving into the fishery beginning in coming years. In addition, RFA believes the 2013 benchmark assessment produced an extremely conservative OFL due to an as-