John Bullard
Regional Administrator
National Marine Fisheries Service
55 Great Republic Drive
Gloucester, MA, 01930
Dear Mr. Bullard;
I am extremely disappointed that the proposed bag limits voted in favor by the Recreational Advisory Panel and the NEFMC were not implemented May 1st. Discussing two options that are not much different has to be tied back to the fact that harvest to date and every day the revised bag limits were not implemented by May 1st further increases the potential for exceeding the ACL.
I am disappointed in lack of urgency to address this matter by May 1st. The planning and hard work by the Recreational Advisory Panel and the NEFMC Groundfish Analyst working together to develop measurements which charter and recreational fisherman could live without exceeding the ACL could be useless by your office not implementing the new rules at the beginning of the 2017 fishing year. Recreational Anglers should not have to have reduced bag limits of size increases in 2018 due to GARFO’s inability to meet the date of May 1st.
To come out and claim there is now a 50 percent probability of the recreational sector over harvesting the sub ACL and recommended different fall closure being the entire month of September is wrong and will place an unfair burden on recreational anglers and charter/headboat operators.
Each year we continue to hear we exceeded the ACL for both cod and haddock and members of the RAP dispute numbers such as effort in catch numbers and number of angler trips taken each wave of the season. Each year we hear it is the best available data and recreational and charter boat operators suffer the consequence due to the inability of your agency to be able to count fish relying on the outdated MIRP standards.
Many recreational anglers haul their boats out for the season in September and allowing the fishery to remain open during the early part of September will allow these vessels to have a final chance of landing fish before the October winds pick up making it nearly impossible for small boats to go twenty five miles offshore to fish for haddock.
I am requesting you implement the 2017 regulations as soon as possible as voted on and approved by the Recreational Advisory Panel and the NEFMC consisting of 12 17” haddock per person and a closed season March 1st – April 14th and September 17th through September 30th.
Thank you for your time and once again, please go with the status quo option.