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Public comments on Addendum VIII for the Recreational Fluke Payback Proposal are due in by April 30th. They can be faxed or mailed.

Here's mine, you can used it as a template for yours if you agree with it or taylor it to your needs.

Sent Via Fax (202) 289-6051

Micheal Lewis
Fishery Management Plan Coordinator
Atlantic States Marine Fisheries Commission
1444 Eye Street NW, 6th Floor
Washington, DC 20005

Dear Mr Lewis:

This letter is being submitted concerning Addendum VIII to the Summer Flounder, Scup and Black Sea Bass Fishery Management Plan.

Of all the species of finfish found on the Mid-Atlantic coast, none is more valuable to anglers and the recreational fishing industry than the summer flounder. The money spent pursuing summer flounder is a major driving force for businesses that provide goods and services that anglers utilize in every state on the east coast. The economic benefit to states and regional economies derived from this recreational fishery is enormous, in the billions of dollars annually. The social benefits accrued by individuals and families that spend time together fishing for them are beyond valuation.

The ability to catch and keep summer flounder for consumption is critical to participation in the fishery. Now, with the stocks approaching levels not seen in 25 years, instead of benefiting from their past sacrifices, anglers are facing with even greater restrictions by the ASFMC.

Addendum VIII

Issue 1: Calculation of State Specific Recreational Allocation

I support Option 1, Status Quo.

I agree with the Technical Committee that 1998 is the most appropriate base year since it was the last year regulations among the various states, were consistent.

Issue 2: Quota Overage Repayment

I STRONGLY support Option 1 - Status Quo.

The entire premise of the Board's proposed recreational payback system is based on the idea that the "perceived" overages by the recreational community are hurting the recovery of the summer flounder stocks. That simply has not been shown to be true. In fact the exact opposite has been shown. All of the lastest survey statistics indicate a sharp rise in summer flounder stocks as well as the spawning biomass. So much so, that the overfished designation was removed last year.

How can that be the case? Simple, the MRFSS surveys are not accurate enough to provide us with a true account of the recreational catch. The NMFS themselves have stated in the past that the MRFSS surveys were never intended to be used for what the ASMFC is proposing. They are intended to be used to show trends in the fishery, not actual numbers. They are in no way accurate enough to be used as a "hard" count like the commercial landings report.

When summer flounder regulations were first put into place recreational anglers fell far short of their quota yet no one proposed to allow anglers to carry over their surplus. The surplus was dismissed as inaccurate surveys.

The fishing public has suffered enough under the ASMFC summer rebuilding program. The ASMFC continually puts the value of commercial harvest over the greater economic benefits derived from recreational pursuit. We are not the ones who destroyed the fishery with offshore dragging, we also should not be made to suffer more just so the commercial sector can fill their quota, a little faster.

Has anyone on the board tried to catch a legal summer flounder in the surf or bay in the last few years! Current regulations have virtually eliminated that fishery and now you want more.

If the ASMFC wants to impose a hard quota system for recreational anglers then they must also come up with the funding for an accurate system to get those numbers from. Until then, the board can not justify the system.

Issue 3: Quota/Harvest Limit Underage Rollover

Assuming there is no overage penalty system from Issue 2, I support Option 1 - Status Quo.

I do wonder why this was never proposed in the early years of the summer flounder management plan.

Issue 4: Change in Allocation of Quota Based on Recreational Overages

I STRONGLY support Option 1 - Status Quo.

I have to wonder if the Board is seriously considering actually basing, an already unfair allocation split, on the highly inaccurate MRFSS surveys. This would take the complete disregard of the public's share of our resources to a new level for the board.



Town, State Zip

(This post edited by BobECT on 04/18/2003)
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