August 25, 2004
Mr. Vince O’Shea, Executive Director
Atlantic States Marine Fisheries Commission
1444 Eye Street, N.W. Sixth Floor
Washington, D.C. 20005
Dear Mr. O’Shea:
On behalf of the Garden State Seafood Association I am compelled to express
our concerns regarding the summary that was provided to the Summer Flounder,
Scup and Black Sea Bass Management Board during the discussion of the Summer
Flounder Reallocation Petition at the August Commission meeting. We believe
that the summary is inaccurate and does not reflect the discussion and conclusions
of the Committee. Considering it is a draft document and the Petition will
be discussed in detail during the joint Council and Commission Meeting that
will be held in October, it was premature and unnecessary to provide a summary
at this time. We are requesting the summary be edited so it accurately reflects
the feelings of the Technical Committee and that it is completed in time
for the October Meeting.
The document I am referring to is a summary of the Technical Committee’s discussion
of the Summer Flounder Petition during their meeting on April 21, 2004 in
Baltimore, MD. I attended the Technical Committee Meeting because of its
importance to the outcome of the Petition and was satisfied with the discussion
that took place. I was not surprised that the Committee agreed that the
years used for the allocation equation were not “perfect”, as your summary
states. I was encouraged when the Committee agreed that the years selected
to calculate the allocation had the most accurate landings data for both
the recreational and commercial user groups. This crucial point expressed
by the Committee is not reflected in your summary.
As you know I requested this summary via e-mail, shortly after the Committee
meeting and on several occasions asked for it by personal communication
with your staff. Due to its importance, I was eager to receive it as soon
as possible. I received the summary on June 21, 2004 and personally communicated
my concerns regarding its content to Ms. Toni Kearns when I saw her on July
26th. Since no changes were made to the summary I thought it best to voice
my concerns to you. Considering it was a draft I was also surprised to find
out that it would be provided during the August Commission meeting.
In closing I believe the Technical Committee summary needs to be edited to reflect
the conclusions expressed during the meeting specifically that the years
used in the current allocation equation considers the best available landings
data. Additionally, I would request that this edited summary be provided
to the Council and Commission in advance of the discussion on the Petition
to reallocate summer flounder quota.
On behalf of the Garden State Seafood Association, I appreciate and look forward
to your response to this important matter.
Sincerely,
Gregory P. DiDomenico
Executive Director
Garden State Seafood Association
cc: Dan Furlong, MAFMC
Chris Moore, MAFMC
Dave Simpson, Connecticut DMF