Comment from Jon Savage

My comment today will refer to the coomon pool regulations and the effects of tri-mesters and percentages on the small vessel fishing fleet (vessels less than 30 feet in length) whether it be handgear or gillnet fishing. The current 2011 fishing year has been a success by allowing all common pool vessels to fish the entire season with trip limits at the 300-500 pound range. The 2011 data should be studied and compared to the 2012 suggested time frames and percentages landed. Had 2011 been divided into tri-mesters, the 1st trimester would have landed 60% of the quota with all boats having access to the quota in seasonably calm waters.The first tri-mester in 2012 which starts May 1st is set at 27%, with a stop fishing in place when 90% of this quota is reached. When cod fishing limits are scaled back vessels will target dogfish and end up discarding cod. My main concern is that small vessels will lose access fishing when the fall winds pick up and the ocean becomes rough which almost happens to the day on Labor Day in September (which is the start of the second tri-mester). This scenario leaves larger common pool vessels with access to over 70% of the quota alloted since their vessels can handle the weather. I would like to see the percentage allocation revisted for the tri-mesters so all fish are landed and all vessels are given fair access to the quota. Once again, fishing year 2011 seemed to work well and the information is there to back it up.