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John K. Bullard, Regional Administrator
National Marine Fisheries Service
Northeast Regional Office
55 Great Republic Drive
Gloucester, MA 01930
Re: Comments on Recreational Omnibus Amendment ~ NOAA-NMFS-2013-0108
Dear Mr. Bullard,
I am writing in support of the Recreational Accountability Measures Omnibus Amendment, which was developed by the Council to modify the accountability measures for the Atlantic mackerel, Atlantic bluefish, summer flounder, scup, and black sea bass recreational fisheries.
I agree that in-season closure and a pound-for-pound “payback” for alleged “overfishing” are not the most effective Accountability Measures (AMs) for the indicated recreational fisheries, and applaud the Council’s apparent recognition that catch estimates produced by the MRIP program produce results that are not reliable or scientifically accurate. Describing these results as “uncertainty in recreational catch estimates” is an understatement. I do not support the Amendment insofar as it proposes to maintain the existing ACT process which is flawed and produces highly inaccurate results.
I also support the Amendment insofar as it proposes to remove the in-season closure authority for recreational fisheries.
Concerning the Amendment’s proposal to use the 3-year moving average of the lower bound of the confidence interval of the recreational catch estimate to determine if an ACL has been exceeded, it is a good first step. Describing MRIP results as having a “confidence level” is misleading at best. While averaging bad data may ameliorate some of the harmful results of MRIP, the fact remains that averaging bad or inaccurate data only produces “average bad data” instead of accurate data. The Magnuson Act requires use of the best science available, and I submit to you that MRIP is not scientifically supportable.
In this regard, the Council’s determination “that the necessary information and resources to support that type of reevaluation [of MRIP] does not currently exist” should be reconsidered. The Magnuson Act is a Congressional mandate to do so.
While the Amendment does not adequately address all the issues in a manner that I find acceptable, it is an improvement over current regulations and a step in the right direction. Therefore, I support it with reservations.
Instead of focusing on catch limitations, the Council should consider dedicating more resources to habitat restoration. In the long run, this will produce better results than the past efforts to restore fish populations via recreational catch limitations.
Thanks for taking the time to consider my comments.
Very truly yours,