February 3, 2005
 
 
Patricia A. Kurkul, Regional Administrator      
NMFS, Northeast Regional Office
One Blackburn Drive
Gloucester, MA 01930    
Sent via fax (978) –281-9135
 
Comments on Proposed Rule: Proposed specifications for the 2005-fishing year for Atlantic mackerel, squid, and butterfish (MSB). (70 Federal Register 1686-1692)
 
Dear Ms. Kurkul:
 
Please accept these comments on behalf of the Garden State Seafood Association (GSSA); GSSA is comprised of commercial fishermen, shore-based processors, commercial dock facilities, seafood markets, restaurants, and various industry support businesses from New Jersey.
 
We support all of the specifications and changes as proposed for the Loligo, Illex and butterfish fisheries but would like to take this opportunity to comment on three issues involving the specifications for the Atlantic mackerel fishery:
 

1) Loligo
 
We support the MAFMC recommendation and the NMFS decision to implement no changes to the Loligo quota or other measurements for the 2005 season.
 
2) Illex
 
We support the MAFMC recommendation and the NMFS decision to maintain the Illex specifications in 2005 at the same levels as they were for the 2004 fishing year.
 
3) Butterfish
 
We support the MAFMC recommendation and the NMFS decision to reduce IOY from 5,900 mt to 1,681 mt. In addition, we support the implementation of a 3.0-inch minimum mesh cod-end requirement for trips when vessels would possess butterfish in amounts greater then 5,000 pounds.
 
4) Atlantic Mackerel
 
a) TALFF/JVP
 
We cannot stress enough the importance of maintaining both a TALFF and JVP of zero and are convinced that any level of TALFF and JVP would impact the expansion of the US processing sector and compete directly with U.S. mackerel exports. We thank NMFS and the MAFMC in advance for maintaining a TALFF and JVP of zero.  
 
b) IOY/DAH
  
GSSA believes is fish abundance is high and the fleet experiences fair weather the U.S. industry has the capacity to harvest a DAH of 165,000 mt. and so we agree with recommendation of MAFMC. However, we believe that given the interest of foreign fleets, any mackerel that would remain “unharvested” due to any circumstances that could occur might encourage foreign fishing interests to push for direct access to this fishery.  Therefore, we support a DAH of 115,000 mt (15,000 mt recreational) for the 2005 Atlantic mackerel fishery.
 
c) In-season adjustment
 
If the mackerel fleet is able to perform to its fullest potential and capacity, in this case, the fishery should not be restrained to current estimates of production or the current setting of the DAH/IOY. NMFS could use the in-season adjustment mechanism to increase both the DAH and the IOY to the levels necessary to fully utilize the mackerel resource.
 
In order for NMFS to implement a timely in-season adjustment, they could use VTR data and Dealer Reports and landings trends from previous years to project landings for 2005. If needed NMFS could begin the in-season adjustment process and start the necessary administrative procedures when the 2005 projected catch estimates were to equal or exceed 54, 000 metric tons. NMFS could not only use landings from 2004 as a trigger for the in-season adjustment but could set some percentage of the total available 100,000 mt as a trigger.
 
We thank NMFS in advance for consideration of an in-season adjustment process that would allow for the full utilization of the Atlantic mackerel resource.
 
Thank you for the opportunity to comment.
 
Sincerely,
 
 
Gregory P. DiDomenico
Executive Director
Garden State Seafood Association
 
        
cc: Ricks Savage, Chairman, MAFMC
     Dan Furlong, Executive Director, MAFMC