Yahoo! Mail Fw: Annual Catch Limits Thursday, July 22, 2010 7:46 PM From: "Miguel Rolon" To: "Graciela Garcia-Moliner" , "Bill Arnold" , "Joe Kimmel" Cc: "Diana Martino" Thank you for your comments. These will be forwarded to SERO and CFMC staff for the records. ----- Forwarded Message ---- *From:* "Olsen41@aol.com" *To:* JMagras@srmedicalcenter.org; Bill.Arnold@noaa.gov; Joe.Kimmel@noaa.gov; miguel_rolon_cfmc@yahoo.com *Cc:* cbryan@legvi.org; winstonledee@yahoo.com *Sent:* Thu, July 22, 2010 12:53:54 PM *Subject:* Re: Annual Catch Limits A couple of other points: 1. It must be clearly stated that the ACL's being set are for the commercial landings only. If recreational landings become known, either the overall ACL should be adjusted or a separate allocation provided. There should be no possibility that recreational landings could lead to an over run of the commercial ACL. 2. The relationship between the Caribbean-wide ACL and the separate island ACLs must be clearer. There should be no possibility that over runs in Puerto Rico or St. Croix will lead to accountability measures in St. Thomas/St. John, and vice versa. 3. You need to do something about this data proposal-it is doomed from the start. The port sampling side is probably OK but the fisherman catch reports portion is a total failure. You are going to generate less accurate data than you are currently getting and that is bad. In fact, all of these ACLs are based upon fiction. If you test reliability by looking for agreement with port sampling or look for known seasonal trends, you won't find any. 4. We're never going to accept that you can't provide landing results on a bi-monthly or quarterly basis. I did and there is no excuse for you all not being able to. 5. Personally, I think you are being extremely cowardly in the way you are addressing the situation in St. Croix. I think that you're opening yourselves up for lawsuits. 6. What you need to do is sit down with us and work out an approach that we can support both to the data and the ACLs. If you do, you can quiet down the opposition and have support instead of acrimony and opposition. David A. Olsen, Ph.D. Chief Scientist, St. Thomas Fishermen's Association 8168 Crown Bay Marina, Ste. 310, PMB 379 St. Thomas, VI 00802 (340) 998-2798 www.stfavi.org In a message dated 7/22/2010 12:40:24 P.M. SA Western Standard Time, JMagras@srmedicalcenter.org writes: Good afternoon; Below you will find concerns that the STFA had with the presentation last night. 1. It must be made clear in writing as part of the document that islands will be separated in Sectors for setting the ACL’s. (STT/STJ, STX & PR) Once this has been done the STFA wants 85% of it’s landings as the ACL due to the level averages running the same over 3 decades with very little to no change. 2. Action 2 (b) Queen Conch Complex. There is another problem here where as in STT there is a virgin stock conch fishery. So use our current landings would be a problem. What the STAF would like to see is the 50,000 lb quota that was put in place in 2007 by DFW be the quota. If a fishery develops then we would request the quota to be revisited. 3. Action 4 (b) Recreational Bag Limit-Alternative 7. There is a problem here because a charter boat can take 10 people out and everyone would be able to catch 10 of each reef fish. They should only be allowed 10 total fish per angler sine it’s for personal consumption. 4. Action 5 (a) Triggering Accountability Measures Alternative 3 & (c). The problem with this is that the mandate by the reauthorization of the act doesn’t go into effect until January 1, 2011. So all of these dates in this document referring to any rules must be changed to at least January 1, 2010. If the process is longer than expected then it needs to be changed then to the effective date of implementation. 5. Action 5 (b) Applying Accountability Measures Alternative 2. Another problem here with the wording SEASON. The STFA will not except a season reduction for over runs but would except a reduction of over runs by poundage. The problem here is that NMFSC needs to be held accountable for processing the data on a monthly basis or quarterly basis so the stakeholders can see what’s going on and if they need to scale back or if they are on target. Fishermen will not accept anymore failures from NMFSC. This federally funded department must step up. If the fishermen have requirements to turn their reports by the 15 of the following month then NMFSC must be held accountable also. No Accountability Measures should be enforced until NMFSC has done their job. Julian Magras Chairman of the Board STFA PS: I am open for discussion. ------------------------------------------------------------------------