Comment from Marc Stettner

Document ID: NOAA-NMFS-2009-0186-0045
Document Type: Public Submission
Agency: National Oceanic And Atmospheric Administration
Received Date: January 18 2010, at 01:31 PM Eastern Standard Time
Date Posted: January 27 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: December 31 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: January 20 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80a7f26f
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0648–AW72 NORTHEAST HOOK FISHERMEN’S ASSOCIATION COMMENT A16 The members (39) of the Northeast Hook Fisherman’s Association (NEHFA) don't agree with the sections of the document that implements a zero (0) retention limit on Atlantic wolffish for both the recreational and commercial fisheries. Per the latest stock survey by the NMFS "unless Atlantic wolffish catches greatly increase and wolffish reproduction fails considerably, the population does not require the protections offered by a listing under the Endangered Species Act in order to persist.” The NEHFA recommends that instead of the zero possession limit, a less restrictive (buts still conservative) measure such as a 1 fish per vessel possession limit be implemented. This would eliminate any directed fishery. A one fish limit would also continue to provide valuable catch data that can be used to determine the status of the stock. Without any catch data, the stock status will not be as reliable as landing trends will not continue. Current trawl surveys conducted do not provide reliable stock status due to the habitat that wolffish live in (holes, rock, ledges). Until better stock survey methods are developed for wolffish, the zero posession limit is not warrented. There is little info on this species and it is believed that there are landings and discards made in the lobster fishery which should be included in the stock assessments. Wolffish prey included significant quantities of lobster and many enter lobster traps to feed. It does not make sense that there is more restrictive measures proposed in this document for wolffish than Halibut.

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