Dear Mr. Waine and Mr. Beal:
We are writing to express concern regarding Draft Addendum XXV to the Summer Flounder, Scup and Black Sea Bass Fishery Management Plan (FMP) being considered by the Atlantic States Marine Fisheries Commission (Commission). The Draft Addendum XXV includes a proposal to replace the current summer flounder management plan with one that would require states to combine their quotas in regional groups of states, known as regionalization. This is a sweeping change that requires careful consideration and analysis before any action to adopt it is taken.
While we are sensitive to the fact that Addendum XXV is an attempt to address concerns that the current summer flounder management measures are inadequate, we believe that it is in the best interest of all fishermen that the Commission ensures there is a fully inclusive process which allows for carefully developed public input. Furthermore, we believe that the Commission should first commit to more fully evaluating the impacts that the proposed changes will have on state regulations and whether there are better alternatives that will still address the concerns that have been raised.
The Commission has cited reliance upon recreational harvest estimates from the year 1998 as the basis for individual state targets as a reason to move to regionalization. Yet, we have not yet seen any formal explanation as to why regionalization is the best response. Addendum XXV states that regionalization would "allow states the flexibility to mitigate potential disproportionate impacts" and "pursue more equitable harvest opportunities," but does not explain what those specific impacts are or why regionalization is the most effective and fair method for improving management. There may be a need to reconsider the state-by-state allocations, but there must be a careful consideration of how this would be accomplished and why any option would be the best course of action for the states.
In addition, the Commission first proposed Addendum XXV at the December meeting, then began meetings to hear public comment this month and plans on considering its adoption at next month's meeting. This is hardly enough time for all constituent groups and interested parties to analyze the consequences of such a radical departure from current management measures or for the Commission to make a fully informed decision. As such, we are concerned that the process is being rushed.
Furthermore, there are alternatives available that will allow states to combine quota while the Commission engages in a full review of the best options and allows for an inclusive process. The current FMP allows states to voluntarily combine their quotas with neighboring states. Making regionalization mandatory at this time, while perhaps addressing the concerns of some states, would be inequitable in its application for the majority of affected states.
We understand that at a public hearing on Addendum XXV in New Jersey there was unanimous opposition to the proposal to mandate regionalization next year. In light of this opposition and the concerns we have laid out above, we urge you to take all appropriate action to ensure that further public input and evaluation of alternative management plans is carried out before regionalization of quota is considered for adoption.