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I saw this on The Bunny Clark site.

For all recreational anglers (private anglers, charter fishing anglers, party boat fishing anglers), if groundfish are filleted at sea, the skin has to be on the fillet before the boat hits the dock. Once off the dock, you are free to do as you please with the fillets. This means that we won't be able to skin fish fillets at sea. After getting the letter, I called the NMFS's Sustainable Fisheries Division at 978-281-9315 and asked them about this rule. They informed me that I had interpreted Ms. Kurkul's letter correctly and that in the wording of the previous regulation, it was unclear as it applied to recreational anglers and that this new rule clarified what NMFS wanted to see. So, no skinning of fish fillets by anyone on the ride in from the fishing grounds.

This will become a real pain in the a** for everyone, the mates and customers, especially during the haddock and pollock slams. Just think, 250 - 300 fish and half of the customers want the fish skinned. If you get the fish skinned you better be tipping the mates for their efforts (and not the $5 for 30 fish as I have seen on some boats over the last few years). Can you say leaving the boat to head home at two hours after getting to the docks. Then after this is finished, the mates get the lucky job of cleaning the boat, just amazing. I will really feel for the mates and captains this year if this really holds for the '08 year.

If this interpretation holds true through the '08 season, the way of doing business for everyone will change big time. The wisdom of this new regulation is amazing when the fishery in New England has larger and more important issues to deal with. While I have only been in the area for only 7 years and started fishing again, I am sure other issues are more important.

I can't wait to see what the next thing to impact the charter boat industry will be. Limits on the food or type of food you can bring aboard or the brand of beer (Bud, Billy, Hamms)
 

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They can also skin the fish 95% of the way and leave the skin flap attached to the fillet.
When you get home, a slight tug on the skin or cut with the knife and you have a skinned fillet.
 

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I've only seen this rule come into play when there were too many fish on board (pollock slam) to cut and skin by the time the boat hits the dock. Skinning big slimey pollock filets on the kitchen counter is teh suck.
 

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Not a big Deal

Like HJ correctly stated you can leave a piece of the skin on and either rip or cut it off when you get home. Anyway, the way the reg's are shaping up we woun't have to worry much about skinning too many fillets this year anyway
. Let's pray they don't mess with the pollock reg's otherwise we will really be sh## out of luck.
 

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Apparently there is a new interpretaion of some of the language in Amendment 5 that was ment to mean one thing and is now being interpreted in a way it was never intended to be. This new view is being sent out as a point of emphasis to the CG as a new directive and
you will probably see more boardings and enforcement as a result. I have been told that a small piece of attached skin will NO LONGER be acceptable proof of compliance.

Bob
 

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I actually prefer to keep the skin on so that I can easily identify the fish when I get home. Taking the skin off is easy with a sharp filet knife. Also, I like to cook haddock with the skin on.
 

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Skin On

I received my letter in the mail today and it reads:

Amendment 5 specified that the mimimum fish size provisions apply to any part of a fish, including fillets. Amendment 5 required that all fish or fish parts must have the skin on to increase enforceability of that provision. The regulations were found to be unclear weather the requirement to land fish fillets or parts of fish with the skin still on applied to all vessels or only to commercial vessels. Therefore, NMFS has clarified that fish fillets, or parts of fish, must have the skin on while possessed on board all vessels, including private recreational or party/charter vessels. "Skin On" means the ENTIRE portion of the skin normally attached to the portion of the fish or to fish parts possessed is still attached.

Well, the way I read this is you can't just leave a small piece of the skin on, it has to be the entire portion of the skin.

Dave
 

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anyone want to set up a skinning station at the dock?

In terms of tipping the mates, tip them as you normally would, they are great people to have on a boat and usually add to the experience of fishing. Many of of us would be SOL without them!

I think you are correct, we will see more boardings this year, Captains, have your boat in order.

Is it April 1 yet?
 

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Codkiller wrote:
Dave

"mimimum fish size provisions apply to any part of a fish, including fillets"

Does this mean that the fillets have to be 23 inches long ?

Bob

If no racks are present to match up, that fillet better be of minimum length, the way I interpret the same letter, which I also got today. I guess the spirit of this may be to prevent a shorty from becoming a hacked up legal fish that was filleted by a blind mate with a dull knife.


This post edited by capndom 07:00 PM 02/09/2008
 

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BTW, there are states where it is illegal to cut/fillet any fish at sea, they must wait to get back on land before the mates can have at it. I found that out the hard way in FL....
 

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I can read as well as anyone, but they can't possibly mean that the fillet must be equal to or longer than the minimum length. This is absurd.

On a 20 inch fluke or a 23 inch cod, how many of those inches are comprised of the head and tail? A third of the total, maybe?

And saving the racks to match up with the fillets is equally absurd. What a fustercluck that would be on a packed headboat.

I can live with the skin-on rule, but not the measuring of fillets.
 

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if someone does a search on the regs, you will see a minimum size on a fillet that is shorter than the full size on a whole fish.

a cod fillet was like 18 inches and a haddock was 15 inches. that is from my poor memory so don't quote me but it is there somewhere.
 

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SHIVA wrote:
if someone does a search on the regs, you will see a minimum size on a fillet that is shorter than the full size on a whole fish.

a cod fillet was like 18 inches and a haddock was 15 inches. that is from my poor memory so don't quote me but it is there somewhere.

648.89 Recreational and charter/party vessel restrictions.
(a) Recreational gear restrictions. Persons aboard charter or party vessels permitted under this part and not fishing under the DAS program, and recreational fishing vessels in the EEZ, are prohibited from fishing with more than two hooks per line, and one line per angler, and must stow all other fishing gear on board the vessel as specified under §648.23(b).

(b) Recreational minimum fish sizes ?(1) Minimum fish sizes . Unless further restricted under paragraph (b)(3) of this section, persons aboard charter or party vessels permitted under this part and not fishing under the NE multispecies DAS program, and recreational fishing vessels in or possessing fish from the EEZ, may not possess fish smaller than the minimum fish sizes, measured in total length (TL), as follows:

Minimum Fish Sizes (TL) for Charter, Party, and Private Recreational Vessels

Species Sizes
Cod 22" (58.4 cm)
Haddock 19" (48.3 cm)
Pollock 19" (48.3 cm)
Witch flounder (gray sole) 14" (35.6 cm)
Yellowtail flounder 13" (33.0 cm)
Atlantic halibut 36" (91.4 cm)
American plaice (dab) 14" (35.6 cm)
Winter flounder (blackback) 12" (30.5 cm)
Redfish 9" (22.9 cm)

(2) Exception. Vessels may possess fillets less than the minimum size specified, if the fillets are taken from legal-sized fish and are not offered or intended for sale, trade or barter.

(3) GOM cod . Private recreational vessels and charter party vessels described in paragraph (b)(1) of this section may not possess cod smaller than 24 inches (63.7 cm) in total length when fishing in the GOM Regulated Mesh Area specified under §648.80(a)(1).

(4) The minimum fish size applies to whole fish or to any part of a fish while possessed on board either a charter/party or a private recreational vessel, or at the time of landing. Fish fillets, or parts of fish, must have skin on while possessed on board a vessel and at the time of landing in order to meet minimum size requirements. ?Skin on? means the entire portion of the skin normally attached to the portion of the fish or to fish parts possessed is still attached.

(c) Cod possession restrictions ?(1) Recreational fishing vessels. (i) Unless further restricted by the Seasonal GOM Cod Possession Prohibition specified under paragraph (c)(1)(v) of this section, each person on a private recreational vessel may possess no more than 10 cod per day in, or harvested from, the EEZ.

(ii) For purposes of counting fish, fillets will be converted to whole fish at the place of landing by dividing the number of fillets by two. If fish are filleted into a single (butterfly) fillet, such fillet shall be deemed to be from one whole fish.

(iii) Cod harvested by recreational fishing vessels in or from the EEZ with more than one person aboard may be pooled in one or more containers. Compliance with the possession limit will be determined by dividing the number of fish on board by the number of persons on board. If there is a violation of the possession limit on board a vessel carrying more than one person, the violation shall be deemed to have been committed by the owner or operator of the vessel.

(iv) Cod must be stored so as to be readily available for inspection.

(v) Seasonal GOM cod possession prohibition . Persons aboard private recreational fishing vessels fishing in the GOM Regulated Mesh Area specified under §648.80(a)(1) may not fish for or possess any cod from November 1 through March 31. Private recreational vessels in possession of cod caught outside the GOM Regulated Mesh Area may transit this area, provided all bait and hooks are removed from fishing rods and any cod on board has been gutted and stored.

(2) Charter/party vessels. Charter/party vessels fishing any part of a trip in the GOM Regulated Mesh Area, as defined in §648.80(a)(1), are subject to the following possession limit restrictions:

(i) Unless further restricted by the Seasonal GOM Cod Possession Prohibition, specified under paragraph (c)(2)(v) of this section, each person on a private recreational vessel may possess no more than 10 cod per day.

(ii) For purposes of counting fish, fillets will be converted to whole fish at the place of landing by dividing the number of fillets by two. If fish are filleted into a single (butterfly) fillet, such fillet shall be deemed to be from one whole fish.

(iii) Cod harvested by charter/party vessels with more than one person aboard may be pooled in one or more containers. Compliance with the possession limits will be determined by dividing the number of fish on board by the number of persons on board. If there is a violation of the possession limits on board a vessel carrying more than one person, the violation shall be deemed to have been committed by the owner or operator of the vessel.

(iv) Cod must be stored so as to be readily available for inspection.

(v) Seasonal GOM cod possession prohibition . Persons aboard charter/party fishing vessels fishing in the GOM Regulated Mesh Area specified under §648.80(a)(1) may not fish for or possess any cod from November 1 through March 31. Charter/party vessels in possession of cod caught outside the GOM Regulated Mesh Area may transit this area, provided all bait and hooks are removed from fishing rods and any cod on board has been gutted and stored.

(3) Atlantic halibut. Charter and party vessels permitted under this part, and recreational fishing vessels fishing in the EEZ, may not possess, on board, more than one Atlantic halibut.

(4) Accounting of daily trip limit. For the purposes of determining the per day trip limit for cod for recreational fishing vessels and party/charter vessels, any trip in excess of 15 hours and covering 2 consecutive calendar days will be considered more than 1 day. Similarly, any trip in excess of 39 hours and covering 3 consecutive calendar days will be considered more than 2 days and, so on, in a similar fashion.

(d) Restrictions on sale. It is unlawful to sell, barter, trade, or otherwise transfer for a commercial purpose, or to attempt to sell, barter, trade, or otherwise transfer for a commercial purpose, NE multispecies caught or landed by charter or party vessels permitted under this part not fishing under a DAS or recreational fishing vessels fishing in the EEZ.

(e) Charter/party vessel restrictions on fishing in GOM closed areas and the Nantucket Lightship Closed Area ?(1) GOM Closed Areas. A vessel fishing under charter/party regulations may not fish in the GOM closed areas specified in §648.81(d)(1) through (f)(1) during the time periods specified in those paragraphs, unless the vessel has on board a letter of authorization issued by the Regional Administrator pursuant to §648.81(f)(2)(iii) and paragraph (e)(3) of this section. The letter of authorization is required for a minimum of 3 months, if the vessel intends to fish in the seasonal GOM closure areas, or is required for the rest of the fishing year, beginning with the start of the participation period of the letter of authorization, if the vessel intends to fish in the year-round GOM closure areas.

(2) Nantucket Lightship Closed Area. A vessel fishing under charter/party regulations may not fish in the Nantucket Lightship Closed Area specified in §648.81(c)(1) unless the vessel has on board a letter of authorization issued by the Regional Administrator pursuant to §648.81(c)(2)(iii) and paragraph (e)(3) of this section.

(3) Letters of authorization. To obtain either of the letters of authorization specified in paragraphs (e)(1) and (2) of this section, a vessel owner must request a letter from the Northeast Regional Office of NMFS, either in writing or by phone (see Table 1 to 50 CFR 600.502). As a condition of these letters of authorization, the vessel owner must agree to the following:

(i) The letter of authorization must be carried on board the vessel during the period of participation;

(ii) With the exception of tuna, fish harvested or possessed by the vessel may not be sold or intended for trade, barter or sale, regardless of where the regulated species are caught;

(iii) The vessel has no gear other than rod and reel or handline gear on board; and

(iv) For the GOM charter/party closed area exemption only, the vessel may not use any NE multispecies DAS during the period of participation.

[69 FR 22984, Apr. 27, 2004, as amended at 71 FR 62196, Oct. 23, 2006; 72 FR 73281, Dec. 27, 2007] [end]

Further,under CFR 648.83 there is a provision which states that sub legal measurement fillets may be retained, provided it can be proved they came from a legal fish. Point being no rack, no proof in "my" interpretation.

Difficult to enforce? YES...Impossible to enforce? Not even close.....

All it would take would be a count of total fillets and whole fish, then a look in the plie of racks to see if there is a short. Not enough racks to match up to the fillets and the boat could be in trouble if the officers don't think the fillets came from legal fish....

This post edited by capndom 08:35 PM 02/09/2008
 

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SHIVA wrote:
capndom
thanks for posting that as it shows that i was wrong.
i did say though i had poor memory!

I had to think about it myself, and do a bit of research...I seem to vaguely remember something to that effect like you mentioned, but I thought it might be a state reg? My memory aint so good all the time either!

The wording in most of the CFR's leaves alot to be desired, and leaves "interpretation" issues open for the dreaded lawyers....


This post edited by capndom 08:59 PM 02/09/2008
 

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I don't do any cod charters on my boats, but I would have to look into that "letter of authorization" they mention for fishing the closure if I did????

Anyone of you cod capts know a bit more about that? Dave?

This post edited by capndom 09:04 PM 02/09/2008
 
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