Comment from Gregory DiDomenico

Comments on: ANPR for Control Date To Limit Excessive Accumulation of Control, Qualifying Landings History, and Referendum Eligibility in the Monkfish Fishery (FR 77, pages 27175-27176) Dear Mr. Morris: Please accept these comments on behalf of the Garden State Seafood Association (GSSA). GSSA is comprised of commercial fishermen, shore-based processors, commercial dock facilities, seafood markets, restaurants, and various industry support businesses from New Jersey. We also provide these comments on behalf of the Monkfish Defense Fund (MDF). The MDF is an ad hoc group of concerned directed monkfish fishermen and seafood dealers. Our two comments on the ANPR are as follows. First, we support the implementation of a May 9, 2012 as a firm “control date” for future management actions in the monkfish fishery. The development of FMP Amendment 6 has precipitated a noticeable redistribution of fishing effort, an increase in directed effort, and changes in fishing practices that appear to be based upon speculation of future quota-based management actions. These are not beneficial activities for the majority of the fishing industry or the resource and adoption of such a control date will hopefully discourage this behavior. Second, we also request NOAA/NMFS address the issue of requiring a two-thirds majority referendum in each management area for all permitted fishermen as a prerequisite for adoption of an individual, quota-based management alternative. We support a formal referendum requirement and request it apply to the application of any individual (or group)-based catch share-type system be it termed a LAPP, catch share, sector, exempted fishing permit, community or association-based quota system, as well as any similar RFMC action pursuant to MSA Section 302. We feel a referendum vote for fully-informed, permitted fishermen with monkfish landings in 3 of the 5 years preceding the control date is the best way to reflect the true needs of the fishery participants.