Recieved this from Pat Paquette of the MSBA regarding the groundfish situation

[JohnR]

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?