Comment from Hilary Goodwin, Consortium for Ocean Leadership

I think it is troubling that NMFS is considering raising the quota for spiny dogfish. I read the Spiny Dogfish Technical Committee Report (2007) by the ASMFC and the 1st and 2nd proposed Alternatives in the Federal Register do not follow the report at all. While Alternative 3 is the closest to the Technical Committee's recommendations, it is the status quo. How can a population be considered "not overfished" when the average size of females is declining, the number of pups is declining, and the ratio of male to female is severely skewed (4:1)? Furthermore, the long gestation time period of the spiny dogfish is among the longest of any in the world-22 to 24 months. I think the spiny dogfish needs more time to recover before we jump to conclusions and try and overfish spiny dogfish to the brink of extinction. We started fishing dogfish when cod collapsed and one would think we would learn from that disaster, but it seems history is destined to repeat itself. I think Alternative 3 should be followed or the Technical Committee's recommendation of a 6 million lb quota and a 600 lb trip limit.