What We Heard in Individual Ports

NOAA Fisheries Service’s new Northeast Regional Administrator, John Bullard, held a series of public meetings around the region.  His goal was to learn more from fishermen, scientists, environmentalists, seafood dealers and processors, the aquaculture industry and other members of the interested public about not only the challenges they are facing, but also what success looks like. Here are some of the specific comments made by stakeholders during each of the listening sessions:

Public Comments: Surf City, NJ

August 16, 2012

• Science Limitations and Funding Concerns
  • Lack of credibility with Marine Recreational Fishery Statistics Survey (MRFFs) and Marine Recreational Information Program (MRIP) due to use of extrapolated data based on a small sample size and limited phone survey
  • Things are changing within the ecosystem.  Should be allowing fishermen to fish for a diversity of species
• A lot of the management decisions being made based on bad science and fear of legal action against the agency 
• Recreational discards should be taken off the top, not assumed 100 percent mortality
• Potential impact of the Atlantic sturgeon listing on monkfish fishery
• Displaced effort from groundfish fishery into monkfish fishery
• Rhode Island should not be allowed a seat on the Mid-Atlantic Fishery Management Council
• Lack of flexibility in management to react in real time
• Groundfish fishery is a concern but equally important is to focus on a successful fishery (like scallops) and make sure that it doesn’t go by the wayside
• Department of Commerce was supposed to be about economic development – 87 percent of our seafood is coming in from outside U.S., why not have higher tariffs and use that money for science?
• Why are people who were involved in enforcement scandal not penalized?
• Concern about the potential for more consolidation in the groundfish fishery
  • Catch shares seen as resulting in winners and losers
  • Impact on marketplace and shoreside service industry
  • No opportunity for young fishermen to get into business
• Closed Areas  -- important to understand what value these areas have before they are changed
• A lot of changes happening in the marine ecosystem, where did mackerel go?  Why was this a record year for Loligo squid? 
• Want to see further support for cooperative research projects like the monkfish low profile gillnet gear study so fishemen, scientists and NOAA Fisheries could continue to work together on solutions
• Want access to the northern edge of Closed Area II for scallop fishermen
• Improve the way the Georges Bank yellowtail flounder stock is managed (e.g., reject any management advice based on the recent Georges Bank yellowtail flounder stock assessment  and apply techniques used to manage a “data-poor” fishery to set the overall  U.S./CA yellowtail TAC and apportion the TAC fairly between the two countries)

What would success look like related to fisheries in the Northeast Region?

• While the scallop fishery has been successful, NOAA Fisheries and the Council need to invest more management resources into helping ensure long term success of this fishery
• Provide real time data about the fishery’s estimated Georges Bank and Southern New England/Mid-Atlantic yellowtail catches as the  fishing year is progressing so industry can avoid exceeding  their annual catch limits

Public Comments: Boston, MA 

Seafood Dealers and Processors Meeting

August 22, 2012

• Science needs to be improved
  • NOAA continues to use outdated scientific models
  • Bigelow should be used for climate science, not fisheries – commercial fishing vessels and fishermen should be employed to collect accurate data           
  • Use acoustic sampling for herring to obtain accurate numbers
  • Get scientists out on the ocean to determine herring abundance
• Need more fish landed to keep auctions open and infrastructure working
  • Processors are eliminating local species from their sales lists because the supply is inconsistent
  • Processors’ business models are becoming increasingly centered on the distribution of foreign seafood that is flown or trucked in
• Natural cycles of distribution and abundance should be considered in fishery management decision-making
• Reduce minimum size limit on haddock to match Canada’s requirements. Otherwise, will lose market share and revenue from 2010 and 2011 year classes
• Costs of observer coverage
• Move NOAA Fisheries under Department of Agriculture for increased funding
• Seafood exporters should not have to pay fee-for-service costs for inspection services provided by the federal government. These services are over-priced and inferior
• Support aquaculture development
• Address discards as they are extremely wasteful
• Address and implement the recommendations of the Touchstone report
• Concern that the Regional Administrator has orders to downsize the fleet

Public Comments: Gloucester, MA

August 21, 2012

• Need more review of government science by scientists outside of NOAA Fisheries
• Fishermen need to be more involved in cooperative research
• Ongoing efforts are needed to ensure continued funding for the Cooperative Research Program
• Employ an ecosystem-based approach and include people as a factor in the successful evaluation of the ocean environment
• More industry representation is needed on the New England Fishery Management Council
• Sector allocation is not an effective method of fisheries management as evidenced by the shrinking fleet
• Federal and state agencies need to work and plan ahead together to prepare for the next fishing year. Would be helpful to foresee impacts on coastal communities as well
• Regulations should be based on hold capacity, not length, so that vessels could be longer and narrower so they would ride higher in the water and use less fuel
• Catch limits need to be changed for next year to prevent fishermen from going out of business
• Sector management may have been better-received if NOAA Fisheries had allowed for more time and discussion with industry as to how a sector system would work, and for both industry and the agency to better prepare for the transition

• A successful industry would include a healthy local economy and surrounding community
  • Need robust infrastructure services to have healthy industry
  • Fleet structure, including fuel consumption and vessel efficiency, needs to be considered as a criteria for a viable industry
  • NOAA Fisheries and New England Fishery Management Council should have staff with boat engineering expertise
  • A vision of success is when people are excited to fish

 Public Comments Scituate, MA

August 24, 2012

• Been a decline in key stocks due to large vessels fishing on Stellwagen Bank
• Preserve Western Gulf of Maine Closure area to protect spawning cod, open offshore closures to get large vessels to fish offshore
• Lack of consideration for charter boats when establishing trip limits
• Distrust the Stellwagen Bank National Marine Sanctuary office due to Ecological Research Area proposal
• Should manage to reduce predators/predation
• Want input restrictions (like old daily trip limits) that make Stellwagen Bank unattractive to large vessels
• Establish the recreational daily bag limits early in the calendar year to allow fishermen to market trips, plan year
• Disaster relief should respect the unintended consequences that sectors/catch shares caused to recreational/charter fishery
• Local fishermen accepted and implemented input controls early to conserve stocks -- Instrumental in rebuilding stocks
• Early conservation resulted in current low allocation due to the catch history years selected by the New England Fishery  Management Council 
• One large boat without a trip limit can catch in one night what used to support 20 boats for days
• Although Sector 10 qualified for disaster in first year of new regime, they don’t want money, they want to be allowed to work
• Economic analyses write off $70,000/year losses. While this is a good trip for a big boat, this is an annual salary for  independent operator
• Discard assumptions are incorrect when applied to day boats fishing with input controls. They adopted measures to release fish in  good shape (e.g.,  zippers to release them before onboard). There are no dead fish around small vessels, lots after large vessels have been through
• 2013 cuts will be lethal.  Already cut crews, vessel upgrades not being done.  Additional cuts will cut into family subsistence; mortgages, groceries
• Safety is a big concern. Aging vessels and people. Northeast is now the deadliest catch fishery due to older  equipment and  fluctuating annual catch limits, inability for fishermen to develop long-term business plans, obtain bank investment. Need long-term time horizon
• Reduce costs – observers, assumed discards, quota shares
  • Will not be able to pay for monitors in 2013
• Monitoring data from at-sea monitors not being used in stock assessment, but taking funds from Northeast Fisheries Observer  Program
• Revise Magnuson-Stevens Fishery Conservation and Management Act and Marine Mammal Protection Act to make them more flexible
• Volatility in annual catch limits is unsustainable
  • Get rid of ten year rebuilding in Magnuson-Stevens Act as primary goal
  • Restrict fluctuations between years to 10 – 15%, no more
  • Finesse system to stabilize catch limits (e.g. extend rebuilding periods)
  • Result: Fishermen can make business plans, banks will have more confidence in fishing if ACLs are stable, will be more  willing to lend money
• Cooperative research partnership needs to be rebuilt
• Reinvest in this fishery, help fishermen with business plans, bank loans, long-term horizons
• Clarify role of the New England Fishery Management Council’s Science and Statistical Committee: Do they make recommendations for the Council members to consider within the big picture that includes social science, or do they dictate to the councils?
• Abandon single species management and manage and maintain the biomass of a healthier ecosystem; reduce predators and increase valuable stocks
  • Manage to reduce predation instead of just using predation estimates to reduce fishermen’s allocations
  • Develop management that allows catch of abundant species, doesn’t make poor discard mortality or bycatch assumptions
• Wind farm:
  • Reinitiate consultation on effects of wind farm to Essential Fish Habitat and fishermen
  • Request an emergency congressional hearing on effects of wind farm on fishermen
• Pilgrim Nuclear Power Plant:
  • NOAA Fisheries needs to reinitiate and do a more thorough Essential Fish Habitat and Endangered Species Assessment for Pilgrim Nuclear Power Plant to assess effects of the plant on Cape Cod Bay
  • Closed loop cooling system should be required at the plant
  • For projects affecting fishing grounds (wind farm); require fishermen be at the table early, require mitigation if adverse effects occur

Public Comments: Portland, ME

August 28, 2012

• Too many dogfish, seals doing a good job on winter flounder, no groundfish left in Maine
• Need an area (inshore) where small boats can fish and big boats have to stay out
• Environmental changes
  • High incidence of disease in seals is a problem
  • Increased number of harmful algal blooms
• Lack of hake allocation making it difficult for Maine fishermen to target pollock
• Catch shares are a lost opportunity because the allocations were based on catch history.  They should have been based on permits
• Lack of forage fish in the ecosystem (e.g., herring, mackerel)
• Need to pay more attention to the recreational fishing industry
• Draggers on Stellwagen Bank a problem
• Cost of at-sea monitoring
• Survey boats don’t have incentive to catch fish.  Survey boats always go to the same place.  “If I wanted to catch fish I wouldn’t go there.”
• Management measures take too long to develop, Omnibus Habitat Amendment has been eight years in the making
• In favor of maintaining the closed areas. Like the v-notch program protects lobster brood stock, closures protect brood stock for  groundfish industry
• We are bringing in bait from other parts of the world and putting pathogens in Gulf of Maine  we should have to prove it is good  before we put it into the ocean.  Ask the question does it have an impact on forage fish? 
• Don’t forget about aquaculture 

Public Comments: Ellsworth, ME

August 30, 2012

• NOAA Fisheries is still using data collection methods and technology that was used in the 18th century. Why aren’t you using hand held scanners?  “This would save me hundreds of dollars a week and then you would have instantaneous information for policy.”
• Need lobster gauge consistency across states (RI, CT southern MA, increased gauge)
• A lot of changes are happening in the ocean
  • Bottom temperature warmer in Frenchman’s Bay
  • Earlier spawning of species like elvers, blue mussels, horseshoe crabs
  • Estuaries going to be the first place really see signs of Global warming, eel grass die offs
  • Sandlance on beach in Port Clyde
  • Small groundfish in Penobscot Bay
  • Squid in Southwest Harbor in March, unusual
• Science
  • Variation in the Gulf of Maine cod assessment for 2011 -- big difference between earlier assessment
  • Cooperative Research is good.  Sentinel fishery is in its third year 
  • When fishermen aren’t catching fish, you lose valuable information for stock assessment. “We need a dedicated ecosystem study of coastal Maine waters because there is no fishery there to sample for groundfish.”
• With the opening up of the Penobscot, hopeful that the bait fish are going to come back, followed by groundfish 
• Need to have mechanisms in place for new entrants when groundfish do come back
• Small fixed gear herring fishery using stop seine shouldn’t be constrained as to when they set their nets by regulations in the  offshore big boat fishery
• Before you open up closed areas, you need to evaluate what is going on in there with a sentinel fishery. For instance, Closed Area I, northern area had greatest age structure of age 11 cod 
• Fishermen need to be able to diversify, fish for various species to survive
• Concern over having to pay monitoring costs for sector management
• Need to think seriously about aquaculture
• Have lost, through selective fishing, the large spawning cod, maturing earlier now
• To address consolidation you could apply a conservation tax. This tax could be transferred back to area banks every time a large  boat buys a small permit 

Public Comments: Point Judith, RI

September 10, 2012

This listening session was hosted by Senators Jack Reed and Sheldon Whitehouse.

Science Issues

• Need better science, particularly with respect to yellowtail flounder.  Several individuals commented that the R/V Bigelow is not the appropriate platform to survey for this species, and the survey gear currently used is not effective at catching yellowtail flounder
• We have a slow science delivery system which causes us to manage behind the curve.  Need to manage fishery closer to real time
• General support for a shift toward more cooperative research, particularly for improving the yellowtail flounder assessment
• Frustrated that money is being put into aquaculture versus improving the science.  This money should be directed towards cooperative research instead
• Can use funds from research set-aside programs to pay for cooperative surveys such as cooperative monkfish survey.  Feels fishermen should be more involved in how research funds are used (in reference to research set-aside programs in particular)
• NOAA should try to merge observational data from the fishing industry with reproducible data, but not to the detriment of the science

Disaster Funds

• Disaster funds should go towards 1) people put out of business, 2) those that had to sell business due to lack of sufficient groundfish allocation, and 3) those severely impacted by the sector program
• Industry does not need disaster funds.  Just need more fish and government needs to get out of the way.  They do not want a bail-out or a buyout

Fishery Management Issues

• We are always operating in crisis mode, and nothing is going to change
• Have lost faith in process.  Catch shares are putting small boats out of business and leading to over-consolidation of the fleet.
• The collateral damage associated with catch shares is immense.  Feels needed to have a ¾ referendum to introduce sector program.  Some have managed to survive, but hyper consolidation of the fishery is real
• Have a hard time understanding why it takes rulemaking so long
• Concern expressed that fishermen do not have good representation on the Council
• Need to move away from single species management to ecosystem management
• Problem is not as simple as fish and fishermen.  It is really an issue of biology; commercially harvested versus non-commercially important species.  Communities are also very complex
• The saying, “too few fish being chased by too many fishermen” is untrue 
• It is difficult to get picture on what is happening under the water.  Would like to see a 1 mile square area that is not fishable to make a sanctuary that can be used for monitoring purposes
• Need to find ways to target healthier stocks such as Georges Bank haddock and redfish
• Need to revisit the Magnuson-Stevens Act with an eye towards flexibility
• Need to manage short-lived species, such as squid, differently 
• Loligo squid is critical to Rhode Island and butterfish is a choke species for this fishery
• Discontent regarding summer 2012 squid fishery closure when there appeared to be plenty of squid out there
• Frustration expressed regarding poor notification regarding summer 2012 squid closure, especially how it cost several industry members a lot of money
• Too much dogfish out there and they should be the basis of the disaster declaration.  Cod and yellowtail will not come back until dogfish population is controlled
• Looming cuts will lead to displaced effort moving to Rhode Island.  This is going to affect local species
• More dependent on Mid-Atlantic species in Rhode Island, but the state does not have a seat on the Mid-Atlantic Council.  Mentioned that Representative Langevin’s office introduced legislation to get seat on Mid-Atlantic Council
• Frustrated with Regional Office bureaucracy.  Often told by NOAA staff that they have at least 30 days to XYZ.  This is a minimum performance standard
• Need people to simply get things done.  Provided data issue with monkfish amendment as an example.  Industry asked for allocation information, but agency said it could not be provided until some decisions were made (about what allocation criteria might be). 
• Feels NOAA policy analysts do not go out on fishing boats and should.  They should be developing ties with fishermen.
• Steps to empower the fishing industry are needed
• Need healthy fishermen and resource and healthy ecosystem
• Not many day boat scallopers left in Rhode Island.  They were told they were catching a large amount of yellowtail flounder, but now sorting that out through observers and cooperative research project, which “saved their butts”
• Federal lobster fishery off Rhode Island is managed under the Atlantic States Marine Fisheries Commission and that process works, but there is no Federal representation.  More fish are being landed in the offshore fishery, but there is no talk about lobster.
• Need better information on offshore lobster fishery to improve stock assessment for this species.  Northeast Fisheries Science Center trawl survey does not work. Would like to have a lobster study fleet (like groundfish study fleet)
• Need to put money and science into lobster fishery, especially offshore
• Need more staff in Regional Office working on lobster issues
• The Atlantic Offshore Lobsterman’s Association is paying for own observers to collect this information.  They have also established voluntary conservation efforts such as reducing their own traps by 50% and industry buyout
• There is no mandatory Federal reporting in the lobster fishery.  Vessel Trip Report is a groundfish form and need a form that works for lobster 

Other Issues

• Sturgeon listing:  Industry hired a consultant (Dadswell) who put together a 30-page paper to rebut the listing determination.  Cost industry $12,000 and involved 4 industry groups
• Raised concern over Pioneer Array (National Science Foundation project) off the southern New England coast.  It was noted that NSF planned to place this array in one of the more prolific fishing grounds without consulting industry.  As a result, the Atlantic Offshore Lobstermen’s Association facilitated workshops to discuss location of moorings for this array.  Asked about NOAA’s role in this.
• Asked about NOAA’s role with respect to windfam proposals being coordinated by the Bureau of Ocean Energy Management (BOEM).  Asked about NOAA’s role in this process
• Concerned about impacts of wind farms on fisheries in area.  Feel noise, etc. will impact resource availability (i.e., pile driving will scare away fish).  Also concerned about fishing industry being displaced and industry does not have a say in the process

Public Comments: Portsmouth, NH

September 12, 2012

Pending Closure to Protect Harbor Porpoise

• NOAA Fisheries and fishermen should work together to develop more effective pingers - technology exists to get down to zero by- catch levels
• Upcoming harbor porpoise closures could reduce groundfish landings sufficiently to put the only remaining Co-op left in New Hampshire (the Yankee Co-op) out of business. If the Co-op closes, the New Hampshire fishing fleet will have no shore side support
• Pinger testing gun and the observer process don’t work to determine compliance
• In consequence closure area, fish mortality will not decrease as mobile gear will come in and take those fish
• Small vessels cannot make up the lost revenue from these closures in other months, captains will not be able to afford their crew
• Consequence closure is being implemented based on a faulty methodology and ratio
• Local fishermen make money during the proposed closure months and simply cover costs the rest of the year. The economic 
• consequence for industry is much more severe in October/November than in February/March
• How are fishermen supposed to detect pingers when they emit a high frequency sound that is not detectable to human ear?
• Why can't you just keep the fishery open and have observers come down to the docks with guns to make sure all the pingers are working so fishermen can go fish?
• How do you explain when the fisherman knows the pinger is working and both the observer and the fisherman hear it, but the gun says it isn't working?
• Why are you punishing fishermen who are compliant along with those who aren't?  This closure isn't fair
• Concerns about the methodology and the way that the bycatch trigger that prompted the closure was calculated 
• It is not easy for fishermen who fish inshore to fish around these areas
• Commit to change at the highest levels of NOAA Fisheries leadership to safeguard a successful future for industry
• Need additional financial resources to keep the groundfish industry afloat
• Roll back minimum size of Bluefin tuna to be able to catch the full quota

 Public Comments: New Bedford, MA

September 18, 2012

Problems with the Science

• Need to integrate School of Marine Science and Technology (SMAST) data on groundfish into NOAA data.  Why give data to SEAMAS?
• When you do the surveys, don’t use the Bigelow and Albatross.  Should use side-by-side tows with fishing vessel to catch fish.
  • Hard to believe science when you have cases like pollock, depleted and then biomass increased six fold
• Waters are too warm for cod fish, but they are out there, but we don’t know where they are
• Bigelow tows nets that are too small, won’t touch the bottom and aren’t designed to catch flatfish
• Should be surveying for cod at night
• Would have confidence in the survey if you used NEMAP, which annually costs around$20,000 vs. Bigelow which costs $1 million for one cruise
• We don’t have real time data
• The Science and Statistical Committee data shouldn’t be accepted because independent scientists are not allowed to do their own survey work
• NOAA shouldn’t be doing survey work at static sites.  Ocean is a dynamic environment 
• NOAA can’t do any analysis on how Climate Change affects fisheries

Closed Area Access

• Not a good idea to open up closed areas  Just going to provide opportunity for fishermen to catch their allocation quicker and cheaper.  Not really beneficial to fishermen to have access because you are constrained by bycatch of other species.  It is not just a case of going out there and catching haddock

Catch Shares

• Abolish catch shares and go back to Days-at-Sea and trip limits
• Concerns over Caps on Ownership in the Fishery 
• Catch shares are not humane, they destroy community and jobs and only benefit those few individuals
• Question posed: Do you think it was an error to move ahead with catch shares without cap?

Problems with Minimum Size Differences between US/CA

• 2010 year class of haddock is out there and Canada is catching them – they are 16-21 inches in length but our regulations  are 21 inches
• Canada is going to be the most upset when we open up the closed areas because they are reaping the benefits of the closed areas now
• What if you shifted closed area boundaries so you can fish (Kendall highway) near the Hague Line
• Problem is that lobstermen catch their lobster within five miles from the line.  But there is a belief that both fishing sectors will reach a compromise to identify times of year when each sector can fish

Gillnet Closure to Protect Harbor Porpoise

• Disappointed about agency decision to close in October/November to protect harbor porpoise.   "I think you didn’t look into this.  Did it too fast."
• Don’t understand how agency came up with 41 percent noncompliance – "It is unfair that if you have to use hundreds of pingers and you are missing only one or one isn’t working you are noncompliant."

Dockside monitoring/Observers

• Shouldn’t use disaster money for this, won’t be enough – thinks costs of observers are inflated
• Video too expensive for monitoring
• Can’t identify the fish so cameras aren’t effective
• Mixed results in London on video usage to monitor catch  (need to monitor at-sea, not dockside to monitor discards)

Opportunity for Young People to get into Fishing

• Very concerned about access.  Worried about consolidation being inevitable.   Alaska done some positive things to protect owner operators 
• Most owner operators can’t afford to pay their crew fairly
• Quotas being bought for very high prices

Public Comments: East Setauket, NY - Marine Resources Advisory Council Meeting

September 18, 2012

Ideas/Proposals

• NOAA Fisheries should reduce ant target their mailings to save money.  Perhaps when renewing permits, fishermen could choose areas of interest
• Fishermen who only use rod and reel should be exempt from vessel upgrade restrictions if they give up their rights forever to using any other gear type.  Effectively limits their potential effort, making upgrade restrictions unnecessary

Concerns/Issues 

• NY needs better representation at regional fishery management meetings
• Inequality between mid-Atlantic state allocations of commercial catch quota, particularly now that fish stocks are shifting north with warming waters 
• State boundaries used in Mid Atlantic allocation decisions don’t make sense for fish; instead consider regional distribution. 
• Allocations based on historical commercial harvest makes no sense for recreational fishing industry
• Need more timely information for management at the more agile state level
• State allocations are set using 25 year old effort and distribution data, when stocks were declining.  This is disconnected from current fishery demographics, fish abundance, and distribution during a time when water temps are changing and stocks are moving north.
• Fishery management a constant lurching from crisis to crisis; needs more efficient and stable planning  
• Bluefish FMP is an example of adaptive management because the plan allows transfer between recreational and commercial sectors
• Shellfish aquaculture and its contribution to improving water quality should receive funding priority 
• Waters off NY are full of fish (no disaster) but we don’t know how to regulate rebuilt fisheries.  Current measures restrain access to plentiful stocks
•  Management has been successful in the Mid Atlantic, but is too restrictive and is too cumbersome so cannot quickly respond to changes in abundance and distribution 
• Fishermen in the Mid-Atlantic need to get recognition for making tough decisions a decade ago that have paid off in rebuilt fish stocks.
• Mid Atlantic fishermen accepted hard quota a decade ago to rebuild stocks; New England’s soft targets and restrictions perpetuated their overfishing problems
• Worried about New England groundfish boats being displaced into the Mid-Atlantic
• Question the science.  For example;  observations that stocks are rebuilt are frequently followed by cautious allocations blamed on low spawning stock biomass levels  
• Feel major changes in science needed; appreciates that John is not a scientist
• Attributes stock assessment problems to the Bigelow calibration issues 
• Science and statistics are 5 years behind the actual conditions on the ocean. Surveys say high abundance while he sees stocks declining.  Eg. fluke and scup stocks may be high, but they are dropping down from recent  years
• Black sea bass management results in short seasons despite healthy  fish stock
• To see how off the science is, look at dogfish: 15 year predicted for rebuilding; rebuilt in 5
• Uncertainty is the major stumbling block for commercial fishing industry.  Allocations relying on imperfect science are wrong; delays and fluctuations in setting limits make it impossible for fishermen to plan 
• The Act now requires the science to dictate the management to an extent that the current science cannot address.  More funds/resources need to be devoted to the science to allow it to reach that level 
• Social science assessments should be completed before management actions are taken.  Fishermen are not just numbers so decisions affect people’s lives and livelihoods
• Concerned that large companies like Omega will cause menhaden to be fished out and cause food chain problems 
• Tautog rebuilding compels improved marking and monitoring requirements
• Marine recreational fishing data questions.  The Marine Recreational Fisheries Statistics Survey (MRFSS) was reviewed, and improvements identified. The newer Marine Recreational Information Program (MRIP) has not fixed the problems so should not be used to estimate effort and landings
• Recreational fishermen feel that they do not get sufficient attention, relative to commercial fishermen

Public Comments:  Chatham, MA

October 4, 2012

• Use an Emergency action to open the Barndoor skate fishery  - would be a great benefit to the small boat fleet
• Reserve near shore areas for Limited Access General Category Scallop (LAGC) vessels to preserve viability of small boats.  Eliminate 600 lb. daily trip limit for LAGC scallop boats
• To preserve fish populations, keep closed areas closed and reduce the numbers of predators, i.e. dogfish and seals
• Cod populations will crash if closed areas are opened to fishing.  Need drastic cuts to have a chance at saving cod
• The Marine Mammal Protection Act (MMPA) needs provisions for what to do when seal populations are re-built and how to control their population numbers at that point
• Need to protect food sources (herring) for fish stocks and look holistically at the fisheries. Predation needs to be controlled
• To respond to increased data demands, need more timely assessments and should employ a third party technical service.  NMFS could do more for less money if third party were used
• Large seal populations threaten the health of the community and beaches
• The groundfish monitoring program is poor – fishermen cannot afford to pay for monitors. NMFS needs to work with the Councils to devise a way to fund monitoring
• In order for electronic monitoring to work, full retention of catch is necessary
• NMFS should oversee third party data collection and analysis for greater timeliness and accuracy
• Reduce costs of observers by placing them only on groundfish vessels versus requiring them for skate and dogfish trips
• Need increased funding for restoration activities, particularly oyster restoration.  Should also look at opportunities to increase section 6 funding through Massachusetts Division of Marine Fisheries to get better handle on sea turtle numbers in Massachusetts waters and causes of sea turtle strandings
• Enhanced coordination at the state and federal levels is needed to support habitat restoration
• Observers are too costly and unnecessary on dogfish trips
• The Northeast Regional Office, Science Center and Office of Law Enforcement need to work better together

Public Comments:  Manteo, NC

February 11, 2013

• New England fishermen begin catching their bluefin tuna quota on June 1 and by December the majority of the quota has been caught by fishermen in the northern states. By the time the Bluefin have migrated to North Carolina in December, there is very little quota remaining for the North Carolina fishermen. Recommend that the quota be set on a monthly basis, allowing portions of the quota to be available to NC during the Dec-Apr months
• Sturgeon and turtles are endangered, but they are coming back in large numbers. New rules are being established to protect these animals that force fishermen to fish in limited areas and at certain times of the year, which handicaps fishermen’s abilities to fully harvest their fish quotas. There is no history indicating that a large presence of sturgeon existed
• Since NOAA Fisheries has no vested financial interest in the fisheries, its science and policies can be poor with no repercussions to staff
• Amendment 5 will ruin the valuable shark fishery – not many boats will be able to survive fishing for only four months
• Need to bring the bait back to bring the cod back
• Putting sturgeon, cod, and herring on an endangered species list will not save them – need to protect their habitats
•  NOAA Fisheries does not have sufficient data to establish policies. Need more studies, not on-board cameras and observers, to get that data
• Fishermen should be keeping everything in their catch and not waste parts of it
• Oregon inlet jetty issues needs to be resolved
• Our government should be looking at job creation
• Let’s put more local seafood on our plates

Public Comments: Hampton Rhodes, VA

February 12, 2013

• In the recreational fishery, black sea bass estimates are inaccurate – need to deduce reasonable percentage of standard error
• Harbor porpoise closure was larger than originally thought by the State of Virginia and local fishermen. It includes the eastern boundary of Chesapeake Bay, needlessly impact gillnet fishermen – need to follow up on exemption that was previously requested
• Fleet should be allowed to keep 100% of their catch to fully utilize the resource
• Need better science – genetically selecting slower, smaller fish
• Regulations were implemented before North Carolina had a vote on the Council
• Can scallop vessels harvest unused quota from previous years in different areas instead of having to try to fish in closed areas?
• Scallop fleet should have access to areas within Closed Areas 1 and 2 where there is no scientific reason for them not to fish there – need habitat  amendment
• NOAA Fisheries should consider a zero retention plan for scallopers for the yellow tail fishery to remove financial incentive for landing them.  Survivability for yellowtail caught in dredges is low but even if a small percentage survives it provides benefits for fishermen
• The open areas DAS counting disadvantages scallop vessels that are returning to their homeport in Hampton Roads, VA. With VMS vessels should be able to declared the trip ended and be able to return to their port without losing revenue (DAS)
• Closed Area 2 boundary is arbitrary and needs to be reviewed
• The scallop industry is a multi-million dollar industry – why is the yellow tail fishery being prioritized over it?
• Yellow tail stock assessment process needs review – it needs to involve more fishermen to increase accuracy and buy-in
• Dogfish fishery needs attention – too many of them
• Gulf of Maine cod has underutilized recreational quota that should be harvested – need emergency action to open this fishery in April
• Belief that some data sets were not used in the ESA listing of Atlantic Sturgeon