Comment from Joseph Spampinato

September 22, 2009 Pat Kurkul, RA NMFS NERO 55 Great Republic Drive Gloucester, MA 01930 Re: Public Comment on Proposed Rule #0688-AX93 Dear Administrator Kurkul, I’m writing to emphatically support NMFS’ Proposed Rule published on 9/4/09 outlining new monitoring requirements for herring vessels that wish to access groundfish Closed Area I (CA1). Please implement this proposed rule in full as quickly as possible. For these important new rules to have any effect this year they must be in place very soon because herring vessels are already fishing in CA1. I would like to comment on a few specifics: • I support the requirement to abide by the restrictions on dumping fish even when fishing outside CA1, for any trip that may fish in CA1. Otherwise observers will have no way of determining which tows are subject to the new requirements. • I support NMFS intention to prohibit access to CAI when there is no observer. NMFS has drawn a sensible distinction between a 100% observer coverage requirement (which is what the Council requested) and a 100% observer coverage target. • Trip termination is a safe and sensible way to prevent unnecessary dumping or dumping designed to hide bycatch. Other disincentives like having to leave CA1 will not work. They may prevent additional dumping in CA1, but not dumping in the first place. • I support the suggested measures to allow dumping of tows with a significant percentage (50%) of dogfish. NMFS biologists have indicated that tows with 50% dogfish can be pumped, and that NMFS observers can quantify the catch composition based on pumping of a portion of the net contents. Thanks for reviewing my input on this Proposed Rule. Please put these necessary, sensible and long-overdue monitoring standards in place as quickly as possible. Sincerely, Joseph Spampinato