December 12, 2004
 
Honorable Richard Codey
Governor
State House
P.O. Box 001
Trenton, New Jersey 08625
 
 
Dear Governor Cody:
 
I am writing on behalf of the Garden State Seafood Association (GSSA), as you know the GSSA is comprised of commercial fishermen, shore-based processors, commercial dock facilities, seafood markets, restaurants, and various industry support businesses from New Jersey. We respectfully request that you reject the Atlantic States Marine Fisheries Commission Addendum XV to the Summer Flounder Fishery Management Plan, due to its inappropriate impacts on the State’s commercial industry.   
 
Specifically, Addendum XV, if implemented, would decrease the amount of summer flounder commercial quota received by the State of New Jersey in the year 2005 by 54,859 pounds and has further reductions in 2006. However, this can only occur if New Jersey voluntarily transfers a portion of our quota. Therefore we ask you to direct the NJDEP to oppose this Addendum and to prevent the transfer of our quota.   
 
Addendum XV was initiated for two reasons: 1) to explore the possibilities of a dedicated amount of summer flounder to be used for discards that occurs outside the directed fishery for summer flounder and; 2) to address the complaints of states with low historical landings, essentially providing for a reallocation of quota from states with high historic landings like New Jersey to other states.
 
Neither of these issues has been satisfied through Addendum XV. The management measures contained in the Addendum do not specifically set aside additional quota for discards and does not require those states who receive additional summer flounder to use it for discards. As far as the issue of reallocation of quota, those states that would receive additional quota through this Addendum did not provide any additional information that would compel the Commission to give them additional quota. Furthermore the fishery management regulations that exist in those states serve as the real impact to the historic fishermen that reside there, not low quota allocations.
 
I would also like to provide rationale for supporting our request. As stated above the Addendum is not only contrary to the intent of the original purpose but the public process was insufficient. In fact, the option voted on and approved by the Commission did not appear in the original document and was not reviewed during public meetings.
 
We also have concerns about the precedent that could be set by this Addendum. If adjustments can be made to quota allocations without regard to historical landings, than New Jersey could continue to lose historical landings in other commercial and recreational fisheries. Furthermore, this quota transfer is not a compliance measure as specified by the Fishery Management Plan and is not a biological issue. It is our opinion that if we refuse to transfer quota, the State of New Jersey will not be found out of compliance.
 
Your support is essential to a reasonable outcome for the commercial fishing industry in New Jersey. GSSA takes this strong position opposing Addendum XV after considerable discussion. Considering our position does not pose any biological threat to the recovery of the summer flounder resource we remain committed to opposing the requirements of Addendum XV.
 
We look forward to your support and are willing to answer any questions you or your staff might have regarding this issue.
 
Enclosed you will find our written comments submitted to the ASMFC.
 
Sincerely,
 
 
Gregory P. DiDomenico
Executive Director
Garden State Seafood Association
 
 
cc: MBI Gluck Shaw
      Mr. Peter Cammarano
      Commissioner Bradley Campbell