[Mr. Sandman]

"the Southern New England/Mid-Atlantic stock is at 9 percent of the target biomass (over-fished) with overfishing occurring and that the Gulf of Maine stock is likely to be over fished with overfishing likely to be occurring. "


1) Winter flounder is hardly fished by recs in southern NE anymore. (when was the last time you saw a whole bunch of boats out there in April pounding the winter flounder?) I don't even know anyone who even goes anymore.

2) Clearly we didn't get to 9% overnight. This problem has been going on for and getting worse for years in spite of the "expert" management we have.

Let me make a couple of suggestions.

a) Your problem is most likely the endless INSHORE DRAGGING and unreported (by) catches.

b) Fisheries Management should not negotiate with commercial (or recs) on the rules. Do what is right and FIX IT ASAP! Shut it down if need be. Just FIX IT and quit #^&#^&#^&#^&ing around for decades.

c) there might be another cause that should be looked into. Perhaps the SB ( or seals or some predators) are eating them because of lack of other forage fish. IMO this is a root cause on why the lobster population in southern NE is low as well (not the shell disease) ). I find it hard to believe that it was overfishing by recs that did this...there are simply too few fishermen who target winter flounder to make this happen. Maybe in NJ and in some bays in NY but not in Southern NE. Before saying things like that they should untie the the boats from the dock and go out (every day during the season) and actually count the boats fishing winter flounder, instead of relying on bogus models that have a ridiculously high error.

My only written comment will be that they should request a bail out from Obama, issue themselves a big bonus then retire. Really, I would pay these guys to leave.


One more thing...what is WAVE? I don't see it defined in the .pdf