Comment from David Allan

As a 20+ year veteran commercial fisherman in the Central California nearshore groundfish fishery, I submit the following recommendation. I am one of the last three remaining skiff fishermen on the Big Sur Coast. We fish in the old traditional way, by launching from the beach, through the surf, and catching our fish using hook and line. I catch and sell my fish, including rockfish, cabezon, greenling, and lingcod to small markets, restaurants, and the end user. I want to recommend that the 2-month closure of the nearshore rockfish fishery for March-April be eliminated. This closure no longer serves a purpose, as the trip limits, designated by poundage allowed to be caught during bi-monthly periods have effectively controlled the take amounts, and served to ensure a stable and sustainable nearshore fishery. The unnecessary 2-month closure now only causes an economic problem for both the fishermen and the markets, by creating a "lurch" in the market availability of fish, and the income for both the fishermen and the marketers. The economic demand for the fish, combined with the closure only shifts the demand to other available fish on the market, which means that the restaurants, markets must replace the sustainable nearshore fish with foreign, unsustainably-caught fish that are imported to replace our product. The local West Coast groundfish fishery is one of the most regulated and sustainable fisheries in the world. The two-month closure goes against this by "punishing the sustainable/regulated nearshore fishery with a market interruption, and gives favor to the unsustainable foreign fisheries that replace it during March and April. Having a year-round open nearshore fishery will "smooth out" the economic market and fill the market demand with local, sustainable fish. The trip limits of allowable poundage can be easily adjusted to allow for the fishery catch during March/April. I look at this from not only economic sense, but also international sustainability.