SEE THE PETITION BELOW- READ IT AND IF YOU AGREE AND WANT TO SIGN ON,
USE THE FORM AT THE BOTTOM TO ADD YOUR SIGNATURE.
Your
personal
information
will
be
kept
confidential
and
will
only be
supplied to the DMF and MFC
THE PETITION
Page 1
Cape
and Islands Inshore Fishermen’s
Association
P.O. Box 2008
Cotuit
MA. 02635
To:
MASSACHUSETTS DMF / MFC
We are petitioning to amend the landing limit for hook gear in
the directed period
II summer flounder
fishery.
We request to amend Massachusetts 322CMR 622 (2)
D-2 ii; effective opening day of the
directed
summer flounder fishery period II (June 10) 2010, to read as
follows:
" ii. It is unlawful for any commercial fishermen
to possess or land more than 300 lbs. of summer flounder."
Striking:" and for any commercial fishermen using hooks to possess or land more than 200 lbs. of summer flounder."
We also request that the commission
set this item for the public hearings in March. DMF is already
brining management options for fluke fishing to public hearing in
March, this could be attached to any proposals as a public petition.
Our Position
13 years years
ago the DMF/MFC was
similarly (and successfully) petitioned by the trawl fishermen to
reduce the
landing limit for the hook fishery. The argument from trawl fishermen
was that
the state had allowed more permits to be issued than the amount of
quota there
was to divide could support and that the majority of hook fishers were
newer
entrants to the fishery and that the majority of the hook participants
were not full-time. The trawlers also contended that the
quota we
had was based on landings that they claimed to be almost exclusively
their own.
At the time the landings were made, landing report requirements were,
as we
have all learned too well, woefully inadequate. Many
or
all
of
the
landings
for
hook
caught
fluke
were
improperly
or
not documented at all. This reporting problem resulted in initially
low
quotas for other species such as scup and sea bass too. While it was
true that
a large percentage of the newer permit holders were new to the fishery
and
weren’t “full time” fishermen, there was and still are a reasonable
number who
are full time and fish income dependent. Fluke permits have been
limited
entry for 13 years and the overall number of permits has
decreased.
Coastwide
summer flounder quotas are increasing , Ma. summer flounder
quota will be higher
this year and according to Dr. Pierce's comments at the January MFC
meeting in Harwich, be increased substantially in 2011. At this
juncture we feel that the issue of who is allowed to participate to
what extent in this fishery is overdue for review. This an
excellent time to provide added opportunities for the hook fishery,
this would help fishermen who are at a loss from the last ten years of
shrinking access in other fisheries.
The
trawl
fishermen
have
always
been
at
an
advantage
in
the
fluke fishery, they are
able to land larger size fish than the hook fishermen and fish more
weather.
The trawl fishery has some by-catch, some of which may
be retained and sold, including scup and conch. By
regulatory
advantage,
the
less
discriminate gear type is afforded a better opportunity. In contrast, the hook fishery
has less environmental impact than
the trawl
fishery and by-catch (and mortality) is almost non-existent and pound
for pound landed uses less fuel per day, which helps our
environment.
Ma. Fisheries management has a history of
favoring fisheries that had less negative impact on the natural
resources, but
this regulatory difference in landing limits contradicts this. DMF
should
be
giving far more credit to a gear type with less by-catch and negative
environmental impact and not giving more quota to a gear type who needs
to
catch more just because their operating expenses are higher. The
commercial hook
fishermen in Massachusetts should have the same economic opportunity
afforded
to them as the trawlers.
The many
regulatory restrictions to different fisheries have most fishermen
participating in several
different fisheries throughout the year. These last few years with so
little access to sea bass and scup and without several years of good
inshore squid runs have left little besides fluke to fish for for some
fishermen and that isn't enough at 200 pounds a day for someone trying
to earn a living, as short as the season is. The increased daily
landings should be low, most hook boats aren't able to catch 200 pounds
now, so very few would likely get 300 on any regular basis. There are a
number of hook
fishermen that depend on summer flounder as an important part of their
fishing
income.
See attached sheet/s for signatures