Comment from Gregory DiDomenico

GSSA maintains our original position as stated in our November 25, 2011 comment letter. We support the original Council recommendation and the NMFS proposal contained in the Proposed Rule (76 Federal Register 66260-66267) that would set the butterfish ABC/ACL at 3,622 mt, the ACT at 3,260 mt, the DAH and DAP at 1,087 mt, and the butterfish mortality cap on the longfin squid fishery at 2,445 mt. The Agency has the added benefit of the 2011 Fall NEFSC Trawl survey data which is "best available science" and is additional justification for the increase of the 2012 butterfish ABC. Furthermore the fall data indicates a continued increasing trend in kilograms per tow and numbers of butterfish per tow, in 2011 both were approximately the highest in 16 years. The increasing trends clearly indicates that adequate fish numbers survive to maintain the reproductive potential of the stock. The most recent stock assessment of butterfish (SARC 49) found that the F rate of butterfish was less than 0.02. This F rate is so low it has almost no effect on butterfish abundance. In addition the current buffer between the ABC and ACT is adequate to account for management uncertainty given the closure of the directed fishery when the cap reaches %80 and the significant restraints on the directed fishery. The original quota recommendation will not lead to overfishing and is supported by "best available science".