Trawl fishery comments
Here's a copy of an email i received asking for public comment on new trawl fishery regulations. They are asking for public comments. I will attach the letterhead in next post.
Today I'm reaching out to people who commented on the Gulf Trawl Management Program back in June. There's another opportunity coming up to comment on this issue, through the Environmental Impact Statement process. So far there have been 42 comments submitted, and we're fairly certain they are strongly weighted toward the trawl fleet perspective. I think its very important that the record show a balanced range of views as this issue moves through the process, so it would be great to have your comment included. The deadline is September 26.
If you want it, there is a letter outline with some possible talking points attached, and some background information below. If you use the information in the sample letter, it would be a good idea for you to put it in your words, making it personal to your fishing experience and reflective of your individual opinion. It could be similar or the same as what you submitted for the June Council meeting on this issue.
In June 2016, the North Pacific Fisheries Management Council identified a new overarching goal for a proposed bycatch management program: to minimize economic barriers for new participants and maintain opportunities for entry into the trawl groundfish fisheries by limiting the type and duration of exclusive harvest privileges that may be allocated under the proposed program. The Council decided to reopen the comment period because the scope of the EIS has been expanded to include additional types of bycatch management programs.
The bycatch management program proposes to:
· Provide incentives to manage and reduce salmon and halibut bycatch
· Promote increased use of Gulf groundfish.
· Improve stock conservation through accountability measures for bycatch and target species
· Create incentives to eliminate wasteful fishing practices;
· Provide mechanisms to control and reduce bycatch in the trawl groundfish fisheries;
· Improve operational efficiencies and safety at sea
The comment deadline is September 26, 2016. Please submit comments identified by NOAA-NMFS-2014-0150.
Electronic Submission: http://www.regulations.gov/#!docketD...NMFS-2014-0150
Mail: See letterhead on attached sample letter
Thank you for considering this,
Hannah Heimbuch | Community Fisheries Organizer
Alaska Marine Conservation Council
3734 Ben Walter's Lane | Homer, AK 99603
Cell: 907.299.4018 | AMCC Anchorage Office: 907.277.5352 |
www.akmarine.org | @AKFish4Future | fb.com/AlaskaMarine
Assistant Regional Administrator, Sustainable Fisheries Division
Alaska Region NMFS
Attn: Ellen Sebastian
P.O. Box 21668
Juneau, AK 99802-1668
RE: NOAA-NMFS-2014-0150 Gulf of Alaska Trawl Bycatch Management Program
Dear Mr. Merrill,
We/I appreciate the opportunity to comment on the EIS scoping process for the Gulf of Alaska Trawl Bycatch Management Program. [State your reason for commenting. For example, your relationship to the Gulf of Alaska as a commercial halibut fisherman, subsistence fisherman, or rural community member. Take the opportunity to personalize the letter and share your story about your connection to the fishery resource. As a coastal community member in Alaska you are a stakeholder in this process.]
[State what you are asking the Council / NOAA Fisheries to do. Example: The long-term health of coastal communities in the Gulf of Alaska depends on a fisheries management plan that protects the role of independent, community-based fishermen and minimizes the effects of the trawl fishery on other directed fisheries. The Gulf of Alaska has many communities that depend on access to a variety of State and Federal fisheries for their stability and access to these fisheries is critical for the long term health of these coastal communities. Any plan designed to manage fisheries in the Gulf should allow for community protections, viable entry opportunities, and meaningful reductions to bycatch.]
[Points to consider in your letter]
The need for meaningful bycatch reductions
● Bycatch in the trawl fisheries affects the sustainability and economic viability of other commercial, recreational, and subsistence fisheries, while also affecting the economic, social, and cultural framework of those that dependent on halibut or salmon fisheries.
● Any new management option should include bycatch reductions that go beyond status quo.
● 100% observer coverage is necessary to accurately monitor bycatch.
● Nearly 20 years of direct experience with catch share programs in Alaska demonstrates clearly how catch share programs can adversely impact fishing dependent coastal communities. The problems encountered in catch share programs in Alaska and around the world are widespread, well-documented and now predictable. These include:
● absentee ownership of quota
● fewer locally based vessels
● high leasing fees
● excessive consolidation
● lower crew pay and job loss
● out-migration of fisheries based wealth and access opportunities from communities
● Recognition that fisheries are a public resource and do not belong solely to harvesters. Coastal communities and Alaskan residents are important stakeholders and should have a voice in the management process.
● The new program must ensure that some of the economic value of Alaska's fisheries benefits local economies in rural coastal communities.
● Community Fishing Associations are a means to achieve many of these community protections.
Local fishing access
● Coastal residents depend on local fishing access to sustain their economies and culture; loss of access causes economic, cultural, and social ills.
● Commoditizing harvest privileges creates a greater economic barrier to entry for new and current participants.
● Local fishing access helps to ensure that the benefits of this public resource stay rooted in coastal communities.
● Any new management program in the Gulf must provide viable entry opportunities for the next generation of fishermen.
· The new program should minimize the creation of new wealth through individually allocated harvest privileges.
· The new program should minimize the permanence of the allocation and should include factors, such as dependence and active participation, in addition to history.
· The new program should consider other access provisions, such as set asides and community fishing associations.
Thank you for your consideration of these comments.
[State your name/organization]
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