November 5, 2004
Dr. Rebecca Lent
Deputy Assistant Administrator for Regulatory Programs
National Marine Fisheries Service
1315 East-West Highway
Silver Springs, Maryland 20910
Dear Dr. Lent:
We are writing on behalf of three commercial fishing trade associations all
of which have members engaged in the Loligo squid fishery. Those groups
include the Garden State Seafood Association (GSSA), Long Island Commercial
Fishing Association (LICFA) and Rhode Island Commercial Fishermen’s Association.
All three groups are comprised of commercial fishermen, shore-based processors,
commercial dock facilities, seafood markets, restaurants, and various industry
support businesses from around the Mid Atlantic and Southern New England.
We are writing to express our strong support for the timely implementation
of the 2005 Specifications for the Summer Flounder, Scup, and Black Sea
Bass Fishery Management Plan.
The Specifications for this FMP include the setting of Total Allowable Landings
(TAL) for 2005 for each species and important management measures that include
allowable gear changes and specifically a measure that would adjust the
current boundaries of the Southern Gear Restricted Area (GRA). Each year
theses specifications are published and implemented by January 1 of that
year. I realize that there was an unintentional delay in receiving the specifications
from the Mid-Atlantic Council, due to the fact this year the Council set
a Multi – Year TAL (2005-2006). However, we hope you can overcome that initial
delay using the abbreviated administrative tools available to the agency
in the rule making process.
We feel comfortable making such a request due to the fact that most of the management
measures included in the specifications for 2005 are routine. In the case
of the TAL’s for each species they are set every year and are supported
by a thorough stock analysis, and are generally supported by industry. One
particular management measure of extreme importance, which was also supported
by the industry and based on a thorough analysis, is the language that would
adjust the current boundaries of the Southern GRA. This provision was unanimously
passed by the Monitoring Committee and the Council and did not receive any
objection from the Regional Administrator. As you are aware this boundary
adjustment would retain the goals of the Southern GRA while providing access
to the historical and most productive fishing grounds for Loligo squid.
The movement of the Southern GRA boundary is being anticipated from Point Judith
and Newport in Rhode Island, to Montauk Point and Shinnecock in New York
to Point Pleasant and Cape May in New Jersey. If there is a significant
delay beyond January 1st there will be negative financial impact to many
vessels, some could be serious to vessel engaged in this fishery. Historically,
January can be a very productive month depending upon natural variations
in the Loligo behavior. It is imperative the GRA boundary is adjusted allowing
the industry access to this species as close to January 1st, 2005 as possible.
Whatever can be achieved to make this rule final effective as close to the first
of this year would be greatly appreciated. If at all possible, some advance
indication of when the rule may be effective will ease the tension of the
fishermen and allow them to prepare for the opening of the fishery. Many
vessels will plan for equipment repair and how they might schedule some
of their other business plans regarding other fisheries and cooperative
research they might be engaged in. As for the processors who rely heavily
on the Loligo squid fishery they would be able in advance to accommodate
their facilities and serve the market and customers more efficiently.
We look forward to your response and thank you in advance. We are confident
you will do what you can do to accommodate our request.
Sincerely,
Gregory P. DiDomenico
Executive Director
Garden State Seafood Association
Bonnie Brady
Executive Director
Long Island Commercial Fishing Association
Chris Brown
President
Rhode Island Commercial Fishermen’s Association