Comment from Bonnie Spinazzola

As I know you are aware, the offshore lobster industry is highly dependent on skate as a primary bait source; therefore, the Atlantic Offshore Lobstermen's Association remains extremely interested in the protection and the management of the skate species. Previous committee and management discussions have focused on sustained availability of skate throughout each fishing year. Interim TACs were to be used in anticipation of historical allocations within the fishery. We believe this is still the most practical and viable option. Variance in the direction toward an historical bait skate fishery with historical allocation for each operation, will affect both the skate and lobster industries, and create double economic impacts throughout both fisheries. While it is the offshore lobster fishery that depends heavily on the bait skate fishery, interruptions in bait for the offshore has the ramifications to affect the entire lobster fishery, as herring would then become the bait of choice for all, creating scarcities throughout the range of the lobster resource. Management must move toward history based allocations in as quickly a manner as possible - for sustainability of the resource, and the fishermen.