Do you remember federal reports of over 40 thousand pounds of dumped Haddock and film of Striped Bass that allegedly came from Mid Water Trawlers operating in Ground Fish Closed Areas last October & November? Right Now the National Marine Fisheries Service is seeking public input on a proposal to require 100% federal observer coverage on Mid Water Trawlers operating in Ground Fish Closed Area 1. In addition, NMFS is attempting to write a rule to prevent dumping of by catch prior to observers doing their job. The Massachusetts Striped Bass Association urges all recreational fishermen to copy or modify the following sample letter and submit comments via one of the ways explained below prior to September 21, 2009. Protect these fish today, do not wait until the Sept 21 deadline. Please reference 0688-AX93
Fax letter to: Patricia Kurkul, NMFS Regional Administrator Fax #(978) 281-9135
Submit comments via the Federal e-Rulemaking Portal
Regulations.gov
Mail to:
Pat Kurkul, Regional Administrator NOAA/NMFS Northeast Region 55 Great Republic Drive Gloucester, MA 01930
Dear Ms. Kurkul:
I am a recreational fisherman commenting on the proposed rule to modify the Gulf of Maine/Georges Bank Herring Midwater Trawl Gear Letter of Authorization (LOA) published on September 4, 2009.
I suggest any LOA should require 100% observer coverage on any vessel operating in Closed Area 1, including single or pair trawl and catcher or carrier vessels.
In response to the request for comment on the three “exceptions”, I feel that the fluctuations in 2009 landings from CA1 when compared with observer coverage and observed haddock by catch require that this rule must make clear that if a vessel chooses to fish in CA1 and then chooses to dump/release/slip fish from the net, transfer fish to another vessel that is not carrying a NMFS-approved observer or otherwise discard fish at sea before the fish has been made available for sampling and inspection by the observer,” then the vessel must immediately return to port, whether that choice is made because of safety concerns, mechanical issues or the amount of dogfish that appears to be in the net. I recognize the three situations are real at sea issues that must be considered and suggest the creation of one simple, easy to enforce and zero loophole rule that requires; “If fish are discarded for any reason prior to being pumped on board and inspected by the observer, then the vessel must end the trip and return to port without making additional tows.”
Thank You
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