MCFA Public Comments on the NGOM Scallop Amendment 21
Issues Amendment 21 will address
Measures related to the Northern Gulf of Maine (NGOM) Management Area.
Limited Access General Category (LAGC) individual fishing quota (IFQ) possession limits.
Ability of Limited Access vessels with LAGC IFQ to transfer quota to LAGC IFQ only vessels.
For issues pertaining to the Northern Gulf of Maine Management Area:
The Council is planning to develop measures that will support a growing directed scallop fishery in federal waters in the NGOM. To do so, the action will consider measures that would:
Prevent unrestrained removals from the NGOM management area
Allow for orderly access to the scallop resource in this area by the LAGC and LA components.
Establish mechanisms to set allowable catches and accurately monitor catch and bycatch
Working with NGOM Scallop fishermen, the Maine Coast Fishermen’s Association has developed the following responses to the issues proposed to be addressed in this document.
Range of Alternatives: Top issues as identified by Maine GOM fishermen
An allocation split between the Limited Access and General Category:
MCFA supports status quo (70,000lbs and a 50/50 split of remainder of the allowed catch dedicated to general category fishing in the NGOM)
We believe that status quo is working and the simplest way to move this amendment forward in a timely manner is to continue to support the allocation split as developed by the council through a framework process last year.
Consistent Gear Restrictions:
MCFA support a consistent gear restriction within the sensitive inshore habitat of the Northern Gulf of Maine area
MCFA supports consistent gear restrictions in the Gulf of Maine to ensure that this unique area is protected and that we have a fair and equitable management system on the water. The Gulf of Maine is rebuilding, and we have limited science on scallops in federal waters. We believe that a consistent gear throughout the area will limit the impact on bottom and the resource.
Should the Council limit the ability to turn incidental permits and Gen Cat permits into NGOM permits?
MCFA supports a review of the current regulations this and potentially limit the movement of permits in and out of this management area.
MCFA supports the Council developing alternatives to limit large increases in effort in the Northern Gulf of Maine. The biomass in this area is low right now and a large influx of new permits could undermine the sustainability of the fishery.
Spread the availability of catch throughout the year (trimester TACs)
MCFA does not support the creation of trimester TACs until the biomass and allocation is large enough to support that change.
We have additional concerns related to gear conflict that may take place if catch is pushed to different times of the year. We support an analysis of gear conflict in any alternatives for trimester TACs.
MCFA is not opposed to trimester TACs, but currently the biomass is too small to support a redistribution. If the council would like to explore trimester TACs, we would ask that analysis be conducted that establish a biomass at which point trimester allocations could be triggered. Additionally, we have heard significant concerns from fishermen about gear conflict that could take place if the catch was moved to a different time of year. This may be putting scallop boats onto some of the most crowded fishing grounds at other times of year which would create safety concerns and gear conflict.
Develop set-asides to support research and monitoring
MCFA supports the creation of a research and monitoring set-aside
MCFA strongly supports creating a research set-aside for research and monitoring as it is essential to have good science and accountability to ensure a sustainable and profitable fishery in the Gulf of Maine. We need more surveys within the data-poor area Gulf of and an accountable fishery to ensure the resource is managed effectively.
Change of the NGOM boundary
MCFA does not support a change to the NGOM boundary
MCFA does not support moving the NGOM line. There needs to be a good reason to revisit a line that was drawn over 10 years ago and if we are going to move the line whenever there is a change in biomass distribution, we will be consistently drawing new lines in the ocean. If the council wants to explore this issue, we suggest that biology and the best available science is used to determine and justify changes.”
Allocate portions of the catch across sub-regions of the NGOM.
We would encourage the council to allow these types of allocations once more and better data is available for this fishery.
There is significant value in creating opportunities in different areas of the Gulf of Maine by spreading portions of the catch across different areas. Unfortunately, we don’t currently have good enough science to make these decisions. If the council could create an option to do this in the future through a framework, this could be really valuable, but we are not ready for that change presently.