2-11-02

Patricia Kurkel
Regional Administrator
National Marine Fisheries Service
One Blackburn Drive
Gloucester MA 01930

RE: Recreational Fishing Access for Groundfish Litigation

Dear Patricia Kurkel,

The recent developments regarding management measures for the groundfish stocks off the coast of New England are understandably quite drastic. The New England Fishery Management Council has failed to meet the groundfish stock rebuilding targets for the Gulf of Maine stocks as dictated by the Sustainable Fisheries Act of 1996. There is no question that commercial overfishing, disastrous by-catch levels and continued destruction of essential fish habitat has contributed to the current state of groundfish stocks in the Gulf of Maine.

It has come down to private sector organizations filing a law suit against the National Marine Fisheries Service in Federal court to remove the fishery management process out of the hands of the fishery managers. The goal of this is to attempt to accomplish realistic measures to bring the recovery of the Gulf of Maine groundfish stocks back to target rebuilding levels. We feel strongly that this is a lose/lose/lose/lose situation. First, the management process loses in that they were commissioned to make the necessary decisions and elected to by-pass their responsibilities. What type of confidence can government agencies or the general public now have with this process? The fishing industry loses because of the anticipated cutbacks that litigation will surely bring. Many people will likely be forced to leave this industry and it is saddening to think of what this will do to family units as a result. The people of this country lose because of the amount of money (taxpayer money) and time that will be wasted trying to resolve this lawsuit. The final losers in this deplorable situation are the fish stocks. The goal of both sides will be to win, win at all costs. The issue is sustainable fisheries and that will surely get lost and be but a passing by-product of this process. This situation certainly is a black eye on an already bruised New England fishery management process.

Unfortunately through this whole process, the recreational sector has been sitting on the sidelines. Knowing full well that our stocks have been managed for commercial sustainability, the recreational sector has taken the approach of the quiet beachcomber, just happy to pick up a few things to take home. Everyone that is intimately involved with this process knows the figures on who has done and who is doing the damage to our stocks. The recreational sector has and will always step up to the plate when restrictions are deemed necessary and when the recreational sector is determined to be a significant factor in causing the restrictions.

Our club is over 500 members strong and is a reflective microcosm of the recreational community as a whole. We speak today on behalf of our club but we also speak for a great number of recreational anglers who don’t have an opportunity to communicate with you. We strongly feel that the recreational and sustenance angler should not have to bear the same level of restrictions to our groundfish resources as compared to the sectors that have created this unfortunate situation. As mentioned, we certainly want what is best for the resource. If we have to shoulder any restrictions, they should be in proportion to the level of mortality that the recreational sector contributes to the fishery. Also, Federal waters fishing should not be so restricted that anglers shift their efforts to in-shore, state waters. History has shown us that displacement of effort into more concentrated areas is severely detrimental to the fish stocks and ecosystems of that new area of effort.

The recreational sector currently fishes at a minimum size that is greater that the commercial minimum size (21 and 19 inches respectively). We are limited to the number of hooks (2) we can fish with and private party anglers are limited to only 10 fish per trip. With those facts, it is obvious to conclude that recreational fishing has low impact to essential fish habitat, has low catch and release mortality and is very restrictive for private anglers.

In conclusion, we, the recreational and sustenance anglers feel that if any management measures are made against our sector, that they be made in accordance to the amount of mortality that we have historically contributed to the fishery. The level of management restrictions should be proportional to those areas that have created the problem. We also should have adequate access to the resource because of the low level of mortality associated with the recreational sector.

Thank you for your time and consideration.

Sincerely,



Patrick Paquette
President, Massachusetts Striped Bass Association
On behalf of our membership

I think this does a good job of representing the thoughts of the recreational Codfish angler - whaddya think?

Exceptionally well-done, Pat. :D



It is better to have fished and lost than never to have fished at all. "me"

I believe that he represents the recreational fisherman well. While I understand that people need to earn a living, everyone needs to bear an EQUAL burden when it comes to restoration.

A rather long winded reply got lost in cyberspace ... bottom line is ... Are you for real Patrick!

Try to figure out who the winners and losers are. Is it the comms that have a ton of restrictions and are limited to 900# a day or the party boat owners who can get $100 or more per angler per trip.

A party boat that takes 40 anglers can harvest 400 cod. At say an average of 5# each ... thats 2000#. More than twice what the comm can harvest. But the owner gets $4000 or more, less expenses. So who would suffer the most??

Sure, the party boats make out great, not that many get $100 smackers per angler, but they make a living. I feel that it's the recreational guy that is going to suffer here unjustly and that's what Pat is trying to bring up. Whether it's Party boat, shore bound, or the few that actually run their own boats in the winter, the rec angler has done nothing of any significance to deplete the stock. And for the vast majority of people cod fishing - sport, sustinence, or a combination of the two, it's those party boats providing the vehicle to get out there...

The comms may be limited to 900#s per day now because they were previously allowed (legally) to harvest HUGE amounts with more people getting into the game with better and better technology. Meanwhile, the rec gut has done nearly zero to cause the damage to these stocks.... Why should the Rec guy be penalized???

Mike - I agree with a lot of stuff you put up but I gotta disagree on this... Just my opinion....

John,
Certainly everyone is entitled to thier own opinion. I'm certainly not saying I'm right ... there is much that I'm unaware of I'm sure.

Many of my views concerning comms changed when I started talking to my nextdoor neighbor in Eastham who happens to be a comm rod & reel cod fisherman.

I'm pretty sure all comms are not created equal. He is not thrilled with the miles of gillnets that are placed on most of the good bottom far offshore. If a storm comes up and they can't get out for several days ... well the fish rot in the nets.

Most of the small guys aren't effected by the size limits ... more by the size of their boats. Much more than 900# and he couldn't get back in.

Funny a year or so ago when I was at a S-B hearing at MA Maritime the recs and comms all seemed to be in favor of higher size limits. But the party boat owners got up there and p & m-ed about how they couldn't compete with other states with lower size limits. So the limit went from 30" to 28". I believe that the party boats that targeted stripers were responsible for this size reduction, since they appeared to be the only ones in favor of it.

Besides the PB's hammer the cod and haddock as previously closed areas are opened to them. You take a fish outta the eco-system, whether it be by comm or PB rec ... and its gone ... period.

There seem to be a lot more PB's going out of Plymouth Harbor these days than draggers.

Funny the cod stocks are way down but they are hammering them 1/2 off the beach on the outer cape. Not many comms fishing for them because the price has been so low since 9-11.

I'd say everyone may have to sacrifice to get the stocks up to the levels where you could catch 20#ers at night in the spring right in the harbors. Success will require the same teamwork that the Pats employed to win a Super Bowl. Will it happen??? What do you think!!

Your friend (actually many of the comm guys out of that area) is not what caused the problem. Rod & reel guys won't wipe out a fishery and I don't think they should be punnished for it either but they are more the exception than the rule. Unfortunately, they are just as likely if not more likely to get screwed by this than the recs. It's the draggers and massive nets fished too hard & too often by too many boats that did it. And for the most part, they did it legally, even though everyone knew it was coming...

I agree with you about the party boats re S-B too. Do you recall if they are still allowed to sell the extra catch when bass comm season is open? Or did that get stopped too?

While I'm not against the recs taking a small hit to help in recovery of the cod like adding a couple inches to the minimum lenght or dropping to 8 per day, it's not fair to exclude the recs because the recs didn't screw up the fishery in the first place... You think it's bad around the cape - it's far worse codfishing in Rhody, NY, & NJ waters compared to what was available 20 years ago...

I'd say everyone may have to sacrifice to get the stocks up to the levels where you could catch 20#ers at night in the spring right in the harbors. Success will require the same teamwork that the Pats employed to win a Super Bowl. Will it happen??? What do you think!! Everyone should pitch in & sacrafice, but the ones responsible for the most damage need the most sever penalty (which they are in right now). The ones that didn't cause that damage shouldn't need to bear the burden too. Will a Pat's style success be possible? Probably not. The current NEFMC "team" not only couldn't play together, the forfeited the game last month when they folded their cards. Now leagues office gets to pick the winner & loser...

Damn - didn't see the time - gotta run....

I think there are some key differences between any rod & reel fishery and the netters.

1. Catch and Release

Any fish caught on rod & reel stands a better chance of survival upon release. So undersized fish go back alive. The idiotic thing about size limits and nets... what good does it do to release a dead undersized cod.

2. Bycatch

see above. You can release an unintended victim more often than not. Again, what good does it do to release a dead juvenile striper or whatever else they may catch. I can't claim to know what bycatch comes along with cod netting, but this really goes beyond groundfish.

3. Habitat destruction

Draggers that dredge the bottom do a heck of alot more damage than just catching the fish. It disrupts the whole ecosystem.

That being said, it sounds like a party boat can claim a hefty toll on the fish too. I know that the total poundage is divided up between a bunch of individual anglers, but if 30 anglers limit out, your still taking alot of fish... albeit doing less damage overall.

I really don't know the overall numbers... tonnage, quotas, etc., but the focus of the fight shouldn't be protecting rec interests versus comm interests... it should be protecting the fish.

Yes, I realize that is idealistic.