Comment from John Redmond

Dear Ms. Kurkul: I am a recreational fisherman commenting on the proposed rule to modify the Gulf of Maine/Georges Bank Herring Midwater Trawl Gear Letter of Authorization (LOA) published on September 4, 2009. I suggest any LOA should require 100% observer coverage on any vessel operating in Closed Area 1, including single or pair trawl and catcher or carrier vessels. In response to the request for comment on the three “exceptions”, I feel that the fluctuations in 2009 landings from CA1 when compared with observer coverage and observed haddock by catch require that this rule must make clear that if a vessel chooses to fish in CA1 and then chooses to dump/release/slip fish from the net, transfer fish to another vessel that is not carrying a NMFS-approved observer or otherwise discard fish at sea before the fish has been made available for sampling and inspection by the observer,” then the vessel must immediately return to port, whether that choice is made because of safety concerns, mechanical issues or the amount of dogfish that appears to be in the net. I recognize the three situations are real at sea issues that must be considered and suggest the creation of one simple, easy to enforce and zero loophole rule that requires; “If fish are discarded for any reason prior to being pumped on board and inspected by the observer, then the vessel must end the trip and return to port without making additional tows.” This will go a long way to provide more accurate observation and real reports with more consistent data. Regards, John Redmond Warwick, RI.