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May 20, 2008
Patricia Kurkul, Regional Administrator
National Marine Fisheries Service
One Blackburn Drive
Gloucester, MA 01930
RE: Herring Amendment 4 Scoping Comments
Dear Ms. Kurkul,
I am writing to you today on behalf of the undersigned CHOIR Coalition supporters to provide scoping comments on
Amendment 4 to the Herring FMP (“amendment”). CHOIR is an industry coalition made up of commercial and recreational
fishing organizations, fishing and shore side businesses, and eco-tourism companies. CHOIR is recognized as a
stakeholder in the herring fishery and is a leading voice for the responsible management of the herring resource.
First and foremost, this amendment must be used to create and implement an effective government and/or third-party
monitoring system for 100% of the catch in the herring fishery. Furthermore, catch must be clearly defined to include the
entire contents of the net. The current system is entirely inadequate: observer coverage is far too low and erratic; there is
not enough shore-side monitoring; landings data is neither accurate nor timely; there is too much reliance on unverified
industry reporting; and loopholes in the regulations allow for partial or whole codends to be dumped at sea without being
sampled, even on observed trips (slippage).
To address these and other problems, the amendment should ensure that there is 100% catch monitoring. Everything in
the net when it is brought to the boat must be accounted for and sampled, whether it is retained or not. There are multiple
methods that could allow for this level of monitoring, including the use of more observers, electronic monitoring, a
combination of both, or other tools. While maximized retention would be ideal, if catch is dumped at sea, it must be
sampled before it is dumped. Finally, the amendment should put in place a landings system that provides for certified
offloads and actual weights, with the data reported in real time (or as close to real time as possible). There are multiple
funding solutions for these changes, including quota set-asides, application of Magnuson Stevens Reauthorization Act
herring research funds, industry funding, and increased NMFS funding.
Second, this amendment should be used to further promote the offshore herring fishery and to protect inshore herring
stocks and the predators and people that interact with and rely on them. This could be done by using inshore time and
area closures (including gear restricted areas), by prohibiting midwater trawling in Groundfish Closed Areas (including
rolling closures), and by creating new measures to pace out the fishery so as to avoid temporal and spatial forage
depletion. You should also use these tools to address the longstanding gear conflicts between inshore fishermen and the
herring fleet. For too long we have watched as the inshore areas (and those who rely on them) have been devastated by
parts of this fleet and it is time for this problem to be fully addressed.
Finally, we strongly urge that the Council does not attempt to use this amendment for allocation purposes. Until you install
an accurate monitoring system you will not have the data needed to go forward with allocation; at this time, any allocation
would likely be both difficult and wrong as it would be based on faulty data. The impact this would have on fishing
communities would be negative, both because it would possibly drive out many of the owner/operators in the fishery, while
also serving to disrupt the price and supply of bait for the lobster industry. Attempting to do allocation in this amendment
will also slow the process down and further delay the important monitoring and conservation needs that need to be
addressed as soon as possible.
We urge the Council to use this amendment to fix the many problems within the herring fishery.. The herring resource is
far too important for it to be managed with a system as inadequate as the one in place today. Time and time again this
system has shown its glaring weaknesses and the time has come to fix it, once and for all. This amendment should also
promote the offshore herring fishery we all expected by addressing the longstanding concerns regarding inshore
depletion of herring stocks, bycatch, and gear conflict. And lastly, this amendment should exclude allocation by delaying it
to a future vehicle. This region relies on herring and there is no excuse for further delaying these important changes.
Thanks for your time,
Steve Weiner, Chair
On behalf of the undersigned businesses and groups:
Massachusetts Beach Buggy Association
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