October X, 2005

 

Mr. Paul Howard, Executive Director

New England Fishery Management Council

50 Water Street, Mill #2

Newburyport, Massachusetts 01950

 

Attention: Herring Amendment 1 Comments

 

Dear Mr. Howard:

 

This letter is written in strong support of Alternative 7, the Council’s preferred alternative within Draft Amendment 1 to the Fishery Management Plan (FMP) for Atlantic Herring as voted on June 21-23, 2005.  Alternative 7 demonstrates the most restrictive limited access program and establishes a “buffer zone” in Area 1A by prohibiting the use of midwater trawl gear annually from June 1 through September 30. 

 

A restrictive limited access program is necessary for a myriad of reasons including the following: to address long term fishing capacity issues; to reduce pressure for non-sustainable inshore quota levels; to reduce the race to fish; and to establish economic viability in the fishery for low value Atlantic herring.  Additionally, the restrictive limited access program acknowledges and rewards historical participants and business that depend on the herring fishery for income. 

 

Alternative 7 will prohibit the use of midwater trawl gear and pair midwater trawling in Area 1A (namely, the Gulf of Maine) from June 1 through September 30 of each fishing year.  This temporal “buffer zone” is critical in order to prevent localized resource depletion of herring and to provide adequate forage for recovering groundfish stocks, large pelagics such as bluefin tuna and several species of mammals and sharks. 

 

Midwater trawls and pair midwater trawling by vessels measuring 150’ in length are capable of holding 1,000,000 of fish per trip, introducing boats that are overly efficient and too powerful to be used in coastal waters.  The fishing pattern employed by midwater vessels aims at targeting relatively small fishing grounds with repetitive, overlapping tows until the local supply of herring is exhausted and catch rate is dismal.  Forward looking sonar allows the midwater vessels to target the remnants of schools scattered by previous trawl efforts.  This fishing pattern is not compatible with other management objectives put forth by the Council to rebuild valuable groundfish resources such as Atlantic cod. 

 

Establishing a buffer zone imparts a minimal, one-time expenditure for those in the herring fleet that opt to return to more ecosystem-friendly purse seine gear.  Purse seine gear possesses the ability to release herring as well as inadvertently captured bycatch back into the ocean alive.  Furthermore, purse seine gear targets only a portion of an assemblage of herring.  Success of the gear is shown in its ability to supply an ample amount of herring to support the baiting needs of the lobster industry of New England.

 

I strongly urge the New England Fishery Management Council to adopt and submit to the National Marine Fisheries Service for implementation Alternative 7 in Amendment 1 to the Atlantic Herring FMP.