[tlapinski]

Here is something I found online.

Addendum III to the Atlantic Striped Bass Interstate Management Plan was initiated in response to a multi-year, multi-jurisdictional investigation within Chesapeake Bay. This investigation resulted in $1.6 million in fines levied against 19 individuals and three corporations for more than one million pounds of illegal striped bass harvested. Some of the defendants in this case were also sent to prison. The investigation revealed that some of the control measures in place for regulating harvest were ineffective or inadequately designed to maximize compliance. The investigation also found that greater accountability of wholesalers would be difficult without uniform tags and tagging requirements. This addendum requires the Commonwealth to design and implement a conforming tagging program 60 days prior to the start of the 2014 commercial striped bass fishery. Although tagging by fishermen at point-of-harvest (POH) is generally considered the best compliance and enforcement measure and POH programs are currently being conducted by a majority of jurisdictions, the addendum allows us a choice between POH and point-of-sale (POS). Tagging Recommendations My recommendation is to implement a POS tagging program for the 2014 commercial striped bass season and to assess the program’s effectiveness with respect to agency administration, industry compliance, adaptability and practicality, enforcement, and the program’s overall ability to meet the goals of the interstate plan. Evaluation of the 2014 POS tagging program’s performance will be provided to the Marine Fisheries Advisory Commission in writing (in early 2015) as a discussion item and point of consideration for making future program improvements. Through the public comment process, both dealer representatives and fishermen voiced concern about requiring tags to be affixed to fish by buyers on their immediate receipt of the fish from commercial fishermen. They said (dealer) trucks often park near boat ramps to receive the striped bass harvest and that a new requirement for truckers to tag fish on receipt would cause time delays and thereby worsen congestion at the ramps. Some dealers recommended that we reconsider a POH program, while other dealers and a number of fishermen urged us to allow tagging to be done back at the dealer’s company location. I’m not comfortable lessening the effectiveness of a tagging program by allowing fish to travel untagged for great distances, even though the unlawful activity that occurred in the Chesapeake region leading to adoption of Addendum III involved illicit use of tags, not the trafficking of “uncounted” striped bass. Affixing tags sooner rather than later makes the most sense to achieve the multifaceted tagging goals which are to prevent unmarked fish and unaccounted for tags to leave the state, to hedge potential of “back-door” sales (in state), and to provide an effective enforcement tool to Office of Law Enforcement personnel. For these reasons, I recommend we require all striped bass to be tagged at the location where the buyer (or agent for the buyer) takes possession of the fish, and prior to transiting from one location to another. Thereby, no striped bass in possession of a dealer (or agent for a dealer) shall be untagged while in transit. As an example, if a buyer’s truck is accepting fish in a parking lot or other remote meeting place, all striped bass in their possession must be tagged before they drive away from that location. Our post-season evaluation report will include a specific summary of effectiveness (and practicality) of this part of the program. The finer details associated with this POS tagging program include the number and type of tags to be issued, information embossed on the tags, the longevity of the tags with regard to how long they remain with the fish, and dealer reporting requirements. Each detail is addressed below in summary: Tags will be lockable, single-use, tamper-evident, non-transferable, and embossed with the species, year of issue, a unique identification number traceable to the dealer issued the tags, and the minimum size limit. The Division of Marine Fisheries (MarineFisheries) will make available – prior to the start of the season and at no charge – tags to qualifying primary buyers at a number that is scaled to their past history (+20%). MarineFisheries will issue additional tags to dealers as needed at our Boston, New Bedford, and Gloucester locations, and we will make every effort to deliver tags to dealers when and if possible, but it will be the responsibility of each dealer to track his tags and request additional tags before they run out and their business is disrupted. The tags must be affixed at the place of the primary purchase and before transit by locking them to the jaw, either passing through the mouth and out the gills or by puncturing the lower jaw; only the primary buyer issued the tags (or his agents) shall affix the tags. It shall be illegal to sell, trade, loan or gift striped bass tags or to use any expired or defaced/modified tags; tags must be surrendered to MarineFisheries or the Office of Law Enforcement upon request. The tags must remain affixed to whole striped bass until the fish are processed into fillets, thereafter the tags must accompany the fillets while in possession for re-sale; tags are to remain on the premise of retail seafood dealers or food establishment until are portions are sold, thereafter the tags must be cut into two pieces and discarded. A report of used and unused tags will be required by dealers at the end of the commercial striped bass season; such reports will be due 30 days after a written request from the Director on forms provided by MarineFisheries; all unused tags shall accompany the report; failure to comply with the accounting procedures may disqualify a dealer from future participation as a primary buyer of striped bass. It shall be illegal for any person, other than the original harvester, to possess striped bass or portions thereof for the purpose of sale without the striped bass or portions thereof being tagged in accordance with the tagging requirements. Striped Bass Commercial Fishery Measures Introduction It’s my intent to begin a phased approach in 2014 to slow the commercial harvest of striped bass. An extended season would help reduce market gluts and improve ex-vessel prices paid for striped bass. A longer season would also have the potential for permit holders who fish outside of Barnstable County to have more access to the fishery. Additionally, availability of wild-caught stripers for a longer period of time during summer might increase benefits to Massachusetts consumers of fish who seek healthy, safe, and fresh seafood products caught by local fishermen. Finally, I’m seriously concerned about the impacts of intensive fishing on aggregated striped bass off Chatham. Our research tagging striped bass shows that they exhibit site fidelity. While the specific impacts on the general migratory population are unknown, we must assume that impacts on local distributions of these fish under this unique type of fishing pressure are highly negative. Under other circumstances, for instance if these fish were aggregating to conduct spawning activities, I would consider an area closure. Since this is not the case, in fact most fish caught in the area are likely post-spawning migrants from the mid-Atlantic region, it warrants a more moderate management approach than a commercial fishing closure. Reduced number of weekly commercial fishing days with a lower daily bag limit is a sensible first step. Likewise, starting the commercial fishing season earlier in June rather than mid-July should help increase access beyond the water’s of Chatham, assuming striper aggregation hasn’t peaked there in June. Limiting entry to the fishery was cited numerous times at public hearings as the way to control shorter seasons and market gluts. Limiting entry to the fishery is not on the table at this time. I’m willing to discuss how it might be a useful tool to manage the fishery in the future, provided we do so with open eyes. Keep in mind that over the past several years we have issued an average of 3,822 permits annually; 68% of these permits were not fished. Another 20% of these permits have striped bass sales averaging 250 pounds a year contributing to about 17% of the annual quota. In summary, we could eliminate 88% of current permit holders (about 3,350 people) without gaining more than 17% of the annual quota. We could stand to lose a substantial amount of marine economy in the form of bait and tackle and other related purchases currently being made by these individuals. Management Recommendations I recommend we open the commercial season on June 16, a Monday. Beginning earlier in June might provide better access to those fishing outside of the Chatham aggregation. Additionally, I recommend we eliminate commercial fishing on Sundays and reduce the open days to two days per week, Mondays and Thursdays. This season start and these fishing days provide a sufficient buffer around the July 4 holiday, which falls on a Friday this year. According to public comments, Mondays and Thursdays accommodate both interstate shipping schedules and availability at local markets. Some felt Sundays provided the best opportunity to benefit from the fishery because it afforded some fun time with family and friends or it was the only time they had away from a fulltime job. While I understand those concerns, Sunday fishing is by far a day spent on recreation while weekdays are common working times. Considering that striped bass are sold whole or in-the-round, not gutted, often caught on warm summer days, and perhaps not properly iced, commercial fishing on Sundays is not conducive to providing a high quality seafood product to consumers because markets are closed and fish caught on these days do not get into commerce quickly. I recommend a 15-fish bag limit for the Monday and Thursday fishery. Consider that currently, with fishing on Sunday and three weekdays, we had a 16-day season in 2012 and 2013. In 2013, the 16-day season amounted to six Sundays and 10 weekdays of fishing which results in a maximum of about 6,600 pounds of fish per permit per season (based on 30 fish from the Sundays and 300 fish from the weekdays, averaging about 20-pounds per fish). If the 2014 season increases even slightly and price per pound increases, not only would access be afforded to more permit holders, but a majority will earn more while fishing a similar number of days that they fished in past years. It’s true that the fishery’s highliners would have to work additional days to maintain or increase earnings over the past two seasons, but they represent less than four percent of permit holders who sell fish. Therefore these measures stand to benefit more than 96% of those permit holders who sell fish. The 15-fish bag limit recommendation is for those fishery participants possessing a Boat or Coastal Lobster Permit (with a striped bass permit endorsement). I further recommend that we restrict fishery participants with an Individual or Rod & Reel Permit (with a striped bass endorsement) to two fish per day. I continue to believe that those intending to earn a living from this fishery should be expected to have a boat. Many in attendance at the public hearings commented that we ought to define and restrict this fishery to “real commercial fishermen.” This is a step in that direction. The lower limit will also deter under-capitalized fishermen from engaging in the fishery, thereby freeing up some quota for more invested harvesters. Moreover, Individual and Rod & Reel permits are often used as a tool to sell fish in excess of the possession limit; limiting their harvest to two fish will drastically disincentivize this illegal practice. I am also recommending that primary buyers be prohibited from purchasing more than one daily limit from a commercial fisherman regardless of the number of permits in possession to address this problem. Lastly, I am not swayed by some harvesters’ comments that they prefer fishing alone from their boats under the authority of an Individual or Rod & Reel Permit so as to reduce expenses; the difference between a resident Boat Permit (0-59 feet) and resident Individual Permit is $65, an amount that can be covered by the sale of a single striped bass. I also recommend we eliminate the sale of striped bass harvested by the clients of for-hire vessel operators when conducting a striped bass charter or party trip. For-hire captains who are properly permitted will be free to commercially fish for striped bass and sell their harvest when not engaged in for-hire fishing. The arguments to allow this type of commercial fishing are weak, basically being that it continues a long-standing tradition of the fishery and that for-hire captains should be allowed to work a second job like carpenters and firemen who also work as fishermen. I am usually one who upholds traditions, but this type of commercial activity has nearly all been abandoned in other quota managed fisheries in the Commonwealth, it disrupts our ability to estimate the “recreational” striped bass harvest, and it weakens the ability of law enforcement officials to track compliance. I don’t feel we are prohibiting anyone from working a second occupation to earn additional income, but this situation substantially differs from the examples provided in public testimony. Carpenters and firemen are not building homes and putting out fires when they are out fishing. Lastly, I recommend adopting March 6, 2008 as a control date for the striped bass commercial fishery and moving the permit application/renewal date to February 28/29 beginning in 2015. Whether we choose to limit entry to the fishery or not, a control date will be a beneficial tool for managing this fishery in the future. Adopting a more contemporary date to address effort that has entered the fishery because of the Chatham aggregation won’t help us moving forward if that aggregation continues; but the 2008 period coincides with that date which applies to all other commercial rod and reel fisheries in Massachusetts. Likewise, the end of February coincides with the permit renewal deadline for our limited-entry fisheries; a consistent date will avoid unnecessary confusion.