Comment by Joseph Gordon on RIN 0648-XC84

RIN 0648-XC84 Attn: Patricia A. Kurkul Regional Administrator NMFS, Northeast Regional Office One Blackburn Drive Gloucester, MA 01930 Subject: Flawed 2008 Summer Flounder Quota Must Comply With the Magnuson- Stevens Act by Following Scientific Recommendations to End Overfishing Dear Administrator Kurkul, Fisheries are collapsing in America's oceans and around the world. In the United States, summer flounder illustrates the problem of mismanagement. After 20 years of allowing overfishing of summer flounder, MAFMC and NMFS continue to reject the best available science in setting catch limits and ignore evidence of overfishing. Today, summer flounder populations have only recovered to around 47 percent of healthy levels and, by law, must be fully recovered by 2013. The Mid-Atlantic Council?s Monitoring Committee (made up of academic and government fishery scientists) recommended a quota for 2008 of between 11.64 and 12.9 million pounds in order to have a 50 to 75 percent chance of success. The Committee?s modeling approach has been peer reviewed by independent scientists 16 times in the last 23 years. Despite this, MAFMC and NMFS have ignored the best available science and recommended a quota of 15.77 million pounds which has less than a 50% chance of success, endangering the recovery of this damaged population. Last year, Congress reauthorized the Magnuson- Stevens Act largely to prevent the kinds of actions the MAFMC and NMFS have proposed. By proposing an annual catch limit that exceeds scientists? recommendations, the council and the agency have failed the first true test for complying with new conservation measures in the recently revised Magnuson-Stevens Fishery Conservation and Management Act, our nation?s primary federal fisheries law. After decades of overfishing and mismanagement, NMFS and MAFMC must follow the legal mandate to follow scientific recommendations and issue a final 2008 quota of 11.64 million pounds. Thank you for your work. Please consider this an official comment for the proposed summer flounder quota for 2008. Sincerely, Joseph Gordon