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See below for background information and comments received on this draft goal concept.


Comments on themes or policy issues we have not included.

September 2014 Comments 

  • The Policy should provide for national guidance but allow for regional flexibility in implementation as all regions have different challenges and concerns. A regional approach to the policy also follows the approach provided for in the National Saltwater Action Agenda. The use of “non-commercial” as a term in the draft goals also points to the regional differentiation.
    Submitted September 12
  • Please consider the long term affects of diverting management styles. On the east coast the rebuilding of the scallop fisheries has flushed the commercial industry and their lobby with cash. While this is a good thing in theory it is creating havoc in state fisheries and the ASMFC process as this cash is financing a push for open-access and further commercial involvement in state fisheries at the expense of the more valuable recreational component.
    Submitted September 12
  • I would like to quickly comment on the Commission on Saltwater Recreational Fisheries Management's Vision for Managing Saltwater Recreational Fisheries, as presented by the Theodore Roosevelt Conservation Partnership. By any reasonable reading, it is a schizophrenic document. Much of the introductory material heralds the need for proper conservation of fisheries resources, and the role that anglers have played in achieving good conservation results. It talks about managing for abundance, rather than yield, for good population structure and reasonable numbers of large fish. All of that is good and true.

    However, its recommendations largely run counter to its aspirations. It proposes that NMFS abandon hard quotas, which is the most effective tool that can be used to restore and conserve fish stocks, with mortality-rate-based targets that do not seem to provide for express responses in the event of overfishing events. It proposes delaying rebuilding of overfished stocks, in order to provide greater short-term economic benefits to the recreational fishing industry. It proposes state ""partnerships"" that would remove fish from the federal management structure that was created by the Magnuson Act, and put them into the hands of state fisheries managers who are, too often, driven by economic and political considerations rather than by scientific reality.

    None of those proposals supports the report's aspirations with respect to conservation, stock structure, abundance, etc.

    That is not surprising when one considers that the report was essentially an industry creation, with the two Commission chairs members of the boatbuilding industry, and most of the named "contributors" being associated with trade associations such as the American Sportfishing Association, the National Marine Manufacturers Association and the Center for Coastal Conservation which, contrary to what its name suggests, is run by a board of directors dominated by fishing industry and boatbuilding industry interests.

    Once again, we have a situation where people prefer that economics, rather than science, control fisheries management decisions. It should also be noted that, in recent comments to Amendment 40 of the Gulf of Mexico Fishery Management Council's Reef Fish management plan, Bill Byrd, Chairman of the Coastal Conservation Association's national Government Relations Committee, explicitly wrote that the Gulf red snapper management situation was the primary reason that a national recreational fishery policy was proposed. It is not right that concerns of a small number of anglers, in one region of the coast, who fish for a single species, should attempt to impose a recreational fisheries policy on all of the anglers in this nation, when such policy is crafted primarily to serve their desires with respect to a particular fishery. And we should recognize that the TRCP ""Vision"" report does reflect that narrow interest group, which is probably why it seems so schizophrenic.

    To the extent that NMFS adopts a NATIONAL recreational fisheries policy, such policy should accommodate the needs of anglers on every coast of the United States. That means it must be a policy that supports the swift restoration of depleted stocks, prevents overfishing, conserves marine resources, manages for abundance rather than yield and allows fish stocks to achieve truly sustainable structure, with many age and size classes represented in the population. Such a policy, rather than what the "Vision" report actually proposes, would be of great benefit to America's anglers.
    Submitted September 12
  • The Recreational Fishing Alliance (RFA) appreciates the National Oceanic and Atmospheric Administration (NOAA) drafting and seeking comment on a National Saltwater Recreational Fisheries Policy. The recreational fishing community at large has a justified perspective that NOAA places a greater emphasis on and allocates more resources toward the commercial fisheries. This cultural attitude and bias within NOAA goes back the agency’s roots as the Bureau of Commercial Fisheries and has persisted to the current day. RFA is encouraged that NOAA has acknowledged that greater attention toward the recreation sector is needed and is undertaking the development and implementation of a recreational fisheries policy which we hope will bring better parity to the management of the recreational sector. It must be pointed out that there have been numerous attempts by NOAA over the past 20 years to achieve similar goals through different variants of policies, visions, and agendas but they have largely failed. Policy only goes so far, to truly tackle the most pressing problems facing the recreational fishing community, legislative change is needed.

    While the draft recreational fisheries policy is encouraging, it is extremely difficult for the recreational fishing community to take this endeavor seriously in light of NOAA failing to do very basic data collection improvements mandated by federal law. It is the opinion of the RFA that NOAA has only put forward a minimal effort into making meaningful data collection improvements that will certainly benefit the recreational sector and are mandated by law. Because of this, it is very difficult for the recreational sector as a whole to view NOAA’s undertaking of a recreational fishing policy as sincere, meaningful or having any authority to push the agency to improve management of recreational fisheries.

    From an enforceability standpoint, an agency level policy has no statutory authority unless it is codified through statues. The community may be very pleased with the final policy, yet, without legal teeth, the policy may simply founder within the bureaucracy without being fully enacted or implemented.

    Please find below our comments for specific sections of the national saltwater recreational fisheries policy discussion guide.

    Definition of Recreation Fishing:

    NOAA Fisheries seems to be spending a lot of time trying to define ‘recreational fishing’ despite the fact that this definition has already been clearly laid out in both regulatory and legislative terms. The U.S. Department of Commerce, through its National Marine Fisheries Service (NMFS), is currently working on a National Saltwater Recreational Fisheries Policy to help guide the agency’s future policy actions. While the term “recreational fishing” may mean different things to different people, NMFS has mostly established that recreational fishing includes non-commercial fishermen who fish from shore or on private vessels; for-hire vessels like charter and head boats; the recreational fishing industries themselves including bait and tackle manufacturers and sellers; and those who fish for subsistence. Those who fish to sell fish (no matter what they do with the profit) are NOT recreational fishermen

    Goals and Objectives

    1. How do you define recreational fisheries? Magnuson defines recreational fishing as fishing for sport or pleasure. RFA believes this is an adequate definition. RFA cautions NOAA against defining recreational fishing in alternative language as it may create legal inconsistencies with federal or state laws. RFA does not believe that activities such as fish watching should qualify as recreational fishing. A recreational fishery should include the participants, businesses, and infrastructure involved in or necessary for the act of allowing fishermen to take or attempt to take fish for sport, pleasure or personal consumption.

    2. What activities do you think constitute recreational fisheries? Activities with the intended purpose to take a marine fish regardless of the final disposition of the fish should be considered recreational fishing. RFA does not believe activities such as fish watching should be included as recreational fishing.

    3. What might be the effect of defining recreational fisheries in this way in the national policy? As stated above, Magnuson has a clear definition of recreational fishing. Any deviation from this definition in the national policy runs the risk of being inconsistent with federal or state laws.

    DRAFT GOAL #1 Foster and enhance sustainable, healthy, and diverse recreational/non-commercial fisheries and public access to them.

    1a: Management

    RFA believes that the Magnuson Act has done a good job in making sustainable and healthy fisheries. Where the law has failed is in ensuring that there is reasonable public access to those fisheries for recreational harvest and recreational opportunities. While RFA believes these goals and objectives have merit, the RFA questions why NOAA would simply not tackle the biggest and most pressing issue and which NOAA has direct oversight of; recreational data collection.

    In some fisheries, rebuilding of fish stocks and the resultant increase availability of those fish to recreational anglers can create scenario where regulations spiral downward (more restrictive) as attempts to constrain landings to a specific allocation or annual catch limit. This leads to reduced recreational opportunities and hampers new participants in the recreational fisheries. The larger and more devastating consequence is the weakening of the businesses intimately involved with or dependent upon recreational fishing. Not only does this scenario discourage the recreational sector from taking an active role in rebuilding fish stock but it defies the most basic principles and objectives of the U.S. fishery management approach. RFA views this as a huge issue that must be tackled by NOAA and the legislative branch of the U.S. government.

    RFA agrees that NOAA must give greater consideration to socio-economic information from the recreational sector when formulating management strategies and actions. To that point, NOAA must not focus solely on an absolute numerical value in terms of economic loss/gain but instead the agency must give greater consideration to the resilience and fragility of the recreational fishing industry. There is tremendous competition for water front property and for people’s leisure time and money. Restrictive management measures that aim to achieve a short-term goal, ie. annual catch limits, can cause permanent socio-economic damage to the recreational fishing businesses. For example, if shortening a particular recreational fishing season by a few weeks produces an estimated $100,000 loss yet, the shorter season results in the closing of a tackle shop, the loss of the tackle shop will have a lasting economic impact that far exceeds $100,000. NOAA must acknowledge this fact and put an equal amount of concern into the health and vitality of the recreational fishing businesses and infrastructure as it does to the fish stocks.

    It is time for NOAA to begin using alternative management approaches for the recreational sector. The limitations of the existing data collection programs should prompt managers monitor recreational landings over longer periods of time. Yet, NOAA continues to monitor the recreational sector on annual time intervals which by NOAA’s own admission, is the less accurate of the time series. In addition, NOAA should move away from managing recreational fisheries in an either wide open or completely closed manner.

    NOAA must be more receptive to the use of alternative management approaches and regulations in the recreational sector. In some cases, the best approach to reducing recreational discard mortality is to convert those dead fish into landings. NOAA needs to work with the recreational fishing community to develop these alternative management approaches and utilize the ones that have already been developed.

    1b. Resource Conservation and Enhancement

    RFA believes the US fisheries are the best managed in the world. Yet, sustainability has not been achieved in some fisheries. In those fisheries that are not sustainable, NOAA must commit the necessary resources to achieve sustainability. Magnuson currently makes it illegal to fish unsustainably on fish stocks, therefore, fishermen may not be the cause for a stock not being achieving sustainability. Research funds and resources are needed from NOAA to determine all the variables that cause a stock to not be sustainable.

    In many fisheries, we have growing abundance – however, recreational limits are constrained due to a restrictive federal law and woeful data collection efforts by our own federal government - that in itself shows that 'abundance' without ‘access’ is not what anglers desire. Saltwater anglers and recreational fishing business owners, very much like the commercial sector, desire long-term sustainable harvest opportunities on coastal fisheries. RFA opposes NOAA incorporating a philosophical management ideology of managing for ‘abundance’ and instead supports an optimum yield approach.

    Draft Goal #2: Integrate saltwater recreational/non-commercial considerations throughout NOAA and the federal marine fisheries management system.

    As stated in our opening comments, there is a pronounced cultural bias within NOAA that favors the commercial sector. NOAA puts far less resources or concern toward the recreational fisheries under federal management compared to the commercial fisheries. A perfect example of this bias can be seen in NOAA commercial fishing marketing program and sustainability certification. Arguably, recreational fishing is by far the most sustainable fishing practice in the country and yet, NOAA does not market recreational fishing or encourage the public to take up recreational fishing as a sustainable option for obtaining seafood. Considering that over 90% of the seafood consumed in this country is imported and less than 2% of that seafood is inspected while 30% comes from illegal sources, more emphasis must be placed on U.S. recreational fishing and the need to fight for sustainable harvest by American citizens motivated by healthy, sustainable food options, which in turn drive socioeconomic benefits to our local communities.

    This intentional and glaring failure to mention recreational fishing in this agency sponsored marketing campaign illustrates this longstanding bias.

    Moreover, NOAA vastly improved commercial data collection programs by moving to electronic report for fishermen and dealers without a congressional mandate. The recreational fishing community lobbied Congress extremely hard during the last reauthorization to include provisions to improve recreational data collection and despite being passed into law. NOAA has largely ignored this mandate by Congress. Not only it is frustrating that NOAA shows such a lack of concern to really improve recreational data collection but it also has consequences for the management and assessment of marine fish.

    It is estimated that between 7 and 14 million Americans fish recreationally in marine waters each year; a more concrete number cannot be established because of inconsistencies with NMFS’ data collection deemed “fatally flawed” by the National Academy of Sciences over 8 years ago. When Congress reauthorized the Magnuson Stevens Fishery Conservation and Management Act in 2006, the law required NMFS to overhaul its system of gathering recreational fishing data by a time-certain deadline of January 1, 2009. Five years later, that deadline still has not been met. Short of legislative assistance in Congress through Magnuson reforms, NOAA Fisheries must take accountability for this delay.

    Draft Goal #3: Encourage partnership, engagement and innovation

    RFA does not believe that NOAA has the vested interest in recreational fishing to develop innovative means of management this sector. NOAA appears to view recreational fishing and its flawed data collection system as a nuisance, not as a sustainable industry that provides significant social and economic benefits to our country. For this reason, NOAA must give the resources to the stakeholders and the states to develop partnerships that tackle the most pressing problems in the fishing community and develop innovative solutions. The current approach is not realizing the maximum potential of recreational fishing. NOAA will need to turn to those with intimate knowledge and interest in the recreational fishing industry to develop new and innovative management techniques to achieve the sector’s maximum potential.

    Draft Goal #4: Enhance transparency, follow-through and continuity of action.

    With regard to transparency, follow-through and continuity of action, NOAA has failed. This failure is visible and has great consequences on the recreational fishing community. A transparent recreational fishing policy must make note of the need for transparency in council selections. To get appointment to a regional fisheries management council, a Commercial (C) representative must theoretically show permit or tax records proving stake in a commercial fishery. A Recreational (R) representative on the other hand, simply needs to show interest in fishing (perhaps having taken a trip once or twice, or even owning a rod and reel). The interests of the recreational fishing community as a whole is being jeopardized by a regional appointment process which sees ‘R’ delegates given fisheries management decisions when they may actually be considered Others (O) who are active academia or environmental interests. An improved commitment to designating true ‘R’ representatives to Councils must materialize.

    In closing, RFA appreciates the opportunity to comment on the national saltwater recreational fisheries policy discussion guide. Recreational fishing is not just a hobby, but is an element of tradition and culture along many of the coastal communities. A culture of sustainable local harvest by anglers and recreational fishing industry is deep, 400 years of history and evolution. We remain optimistic that the culture inside of NOAA will change in response to development of recreational saltwater fisheries policy. The RFA looks forward to the release of a draft policy and providing additional comments at that time.
    Submitted September 12
  • Thank you for the opportunity to provide comments on the development of the NOAA Fisheries National Saltwater Recreational Fisheries Policy. The Association of Fish & Wildlife Agencies (AFWA), an association representing the collective interest of all state fish and wildlife agencies, believes that NOAA’s approach to creating a recreational fishing policy is well thought out and timely given the importance of coastal recreational angling to the economies of many states. State fish and wildlife agencies play an integral role in the management of our coastal species and habitats, and we value NOAA’s partnership in those management efforts. Indeed, to that point, we suggest NOAA emphasize existing programs to implement the policy, including opportunities for continued engagement. We have the following specific comments for your consideration:

    Draft Goal #1: Foster and enhance sustainable, healthy, and diverse recreational/non-commercial fisheries and public access to them. We strongly encourage NOAA to acknowledge the need for a stronger joint management approach of coastal resources with the states and clearly state the importance of state-managed assets (inshore habitats and estuaries) to NOAA managed offshore fisheries. Many offshore fisheries are dependent on state management of estuarine and coastal systems so the need for close co-management is critical to include assistance in the protection and rehabilitation of these valuable resources. Our members request that policy clearly state the need for protected intact and improved habitat quality in those areas that are currently degraded, not just alluded to in other terms of the policy. We believe it is critical to have these terms in the policy to ensure increased NOAA action focused on habitat protection along with educating coastal recreational anglers about the importance of habitat to healthy fish populations. It is also critical that the needs of shore-based and inshore anglers be incorporated in, and considered with, the crafting of the policy, as they shouldn’t be overlooked in this policy.

    Draft Goal #2: Integrate saltwater recreational/non-commercial considerations throughout

    NOAA and the federal marine fisheries management system. We request that NOAA carefully consider whether or not a full-time Recreational Fisheries coordinator in each region is the best allocation of organizational resources during times of contracting budgets and organizational capacity. This is likely a decision that needs to be considered regionally as different regions of the country have different needs. We want to make sure that your agency is making the best decision when it comes to resource distribution.

    Draft Goal #4: Enhance transparency, follow-through, and continuity of action. Our member agencies request that a structured decision-making process be fully considered as a mechanism to implement this Policy. States have learned valuable lessons in resource management when engaging with necessary stakeholders through this mechanism and it would be beneficial to your agency to more frequently employ the use structured decision making strategies to better engage with and inform the public on issues that affect recreational fishing.

    Again, thank you for the opportunity for the states to have input into this Policy.
    Submitted September 12
  • The commercial fishing industry is the real problem, not the recreational fishermen. Make a mandatory stop of commercial fishing for one week in the end of August. That will save enough fish for all recreational anglers fishing in the fall.
    Submitted September 12
  • It is not the recreational fishing that is affecting the numbers of fish of certain species but the commercial fisherman. It is not right that the commercial fisherman get to keep what they want regardless of species and length. If the shoe was on the other foot and the commercial fisherman had sanctions as to what they can keep and when they can fish for certain species you can bet they would be doing something to get that changed as it would affect how they make their living. This is no different as it is affecting the lives of all the recreational fishing captains and the people that book with them. The recreational fisherman have rights too and at this point they are being violated. The laws that changed the rules for the recreational fishing need to be dropped.
    Submitted September 12
  • My wife and I among all of the recreational fisherman in this area are outraged at the decision made to close the season on Haddock and cod. It is totally unfair to let the net draggers kill everything on the ocean floor and take away our right to go catch dinner. This decision is absolutely bull. What next. Outlaw recreation fishing all together so the nets can keep depleting the fish supply. We pay our taxes and should have the right to go catch some fish. You are going to put local fisherman out of business. I don’t want to hear your excuses just make this right.
    Submitted September 12
  • To regulate the single recreational angler standing on a boat with one fishing rod and one hock, just catching the fish that bite the hock (Not thousand others unwanted like net fishing) is in my opinion a stupid decision to favor the fishing business that are the real problem, with their nets they destroy the fish and the ocean.

    Instead you should fight the way the commercial fishing industry is catching all they can and make 90% of it to animal food or powder that is then used to make fake processed food that is bad for the health of the people.
    Submitted September 12
  • There are eight Regional Councils established under the MSFMCA and as such each should formulate implement a strategy complementary of that region including better integration of fisheries management and conservation effort between the State(s) and associated NMFS region. Of essential consideration is not to penalize the fishing community because of multiplicative State and Federal regulations that adversely affect accessibility and bag size limits.
    Submitted September 11
  • All the bull when it comes to do with the Buoy 10 fishery we cant even keep one chinook but you can keep two north and south of here fins and all yet we have the biggest runs 80% finned fish 2 tribes don't mark a fish big natural run hanford reach= over a million chinook and still had to close the sport fishing to everything but a clipped finned coho but you can keep them everywhere I have been fishing 40 years and all the bs is so bad you have me let go dead fish to go kill another one that doesn't have a finn when every commercial fishery kills all finned fish you people that sit behind a desk and push a pencil suck I care about my resources and hate killing one to go kill another one when there all the same fish the states have been mixing them up for years and moving them around hell youngs bay fish are a invasive species that is in the grays river. theres way more but i am out of room.
    Submitted September 11
  • Higher abundance of fish is needed for a recreational fishery, due to their relative inefficiency in catch vs other fisheries. Therefore, the population levels should be above the MSY level.
    Submitted September 11
  • Grey trout have been in abundance. Time to up limit from one per person to at least six or so.
    Submitted September 11
  • In reviewing the document, I understand the final policy is designed as an internal umbrella guide. The guiding statements identify all the elements of concern, such as, foster, enhance, integrate, encourage, enhance, innovate, engage, etc. However, without the staff or funding to do much more than have this policy as a series of goals, this can become another hollow statement. If funding or (technical) staff support isn't available to support the goals the document is just another set of wishes.
    Submitted September 10
  • The NOAA needs to get out of the fisheries management business. Let the states wildlife depts. do it. The states have proven time and again they are very active in wildlife and fisheries management and have the resources for true success.

    The recreational fisherman inject billions of dollars in to local and state economies. Recreational fisherman buy licenses, boats, fuel, hotel rooms, meals at local restaurants, large amounts of tackle and gear, rent boat slips, and spend money in many other ways on a sport they love and enjoy.

    The biased science and numbers used by the NOAA and NMFS in favor of the commercial fisheries and against the recreational fisheries is killing coastal economies and hurt American families.

    The owners of the commercial boats and quota are getting rich staying at home while the fisherman working on their boats live in poverty. I know this first hand. My son works on a commercial boat. He will never earn enough money to own his own boat or be able to buy quota. He can hardly pay his bills. On his wages he will never be able to purchase a house, a new vehicle or support a family.

    The NMFS is killing the American dream of many young men who want to be able to fish for a living. The state governments need to regulate commercial fisheries also. The federal government is out of touch with the citizens of the United States has reached to far in to the lives of the American public putting regulatory agencies in place to control every aspect of our lives.
    Submitted September 10
  • Were fishermen, But your rules are B.S. it cost so much to fish at the shore i give up. No more till i see these size limits go down. I'm writing you but theres more fishermen that won't. Give us a break.
    Submitted September 10
  • There are considerable differences in view points from recreational fishermen (those that spend money to fish) and commercial fishermen (those that make money from fishing) yet NOAA and the Commissions continue to use Charter Boat Captains (those who make money from fishing) as representing recreational interest. To this point may I suggest that there then are actually at least three distinct fishing interests which should be represented: strictly recreational fishermen; strictly commercial fishermen; and supporting entities.
    Submitted September 10
  • I think a major piece of public policy missing is that in the allocation decision making processes of councils and the fishery management decisions of NOAA, allocations (fish, time, staff, opportunity, resources) to recreational fisheries will be primarily evaluated based on socio-economic data with the view of an overall optimization of the economic values of fish instead of primarily historical harvest data between commercial and recreational sectors.
    Submitted September 10
  • One strategic goal that is missing is promote understanding of the recreational fishery and recreational fisheries management practices. Both within NOAA and in the general public there is a basic lack of understanding on the nature and benefits (social, cultural and economic) of recreational fisheries. There is a need to inform the public of the significant values generated in recreational fisheries. If NOAA's own economists do not have, understand, or use the appropriate tools to define and explain the significant values associated with recreational fisheries, who does?

    Within NOAA, the councils and others responsible for fisheries management and policy development, there is often a lack of understanding of the fundamental differences between the recreational and commercial fisheries.

    Successful management of recreational fisheries differs from commercial fisheries in fundamental ways:

    1. Angler days (daily bag limits) vs. poundage (metric tons): whereas commercial fisheries maximize value by the metric ton, as measured by pounds of fish harvested and processed, recreational fisheries maximize economic and social values by optimizing the overall number of angler days sustained in a manner that provides for a reasonable expectation of harvesting fish throughout the season.

    2. Maximum sustained production (MSP) vs. maximum sustained yield (MSY): while economic value is optimized in commercial fisheries when managing for maximum sustained yield, economic and social values are optimized in recreational fisheries when managing for maximum sustainable production. More fish available in the overall ecosystem means more opportunity for the angler to catch a fish – more fish means more angler days.

    3. Predictable seasonal management vs. flexible inseason management: whereas management for MSY in commercial fisheries requires that intense, timely and flexible inseason management systems be in place, management for MSP in recreational fisheries, through a conservative approach in daily and or annual bag limits, allows for seasonal reporting predicated on minimizing the need for inseason adjustments to methods and means or bag limits.

    4. Value-added economics vs. value economics: while the economics of commercial fisheries are based upon profit generated by the metric ton, with smaller margins per fish generated from large numbers of harvested fish, the economics of recreational fisheries is the inverse, where profit is generated from angler opportunity that produces larger margins per fish on fewer numbers of harvestable fish. Whereas profits from commercial fisheries are typically realized within the seafood industry (harvesters, processors, wholesalers, retailers), profits from recreational fisheries are typically more widespread to include the tourism, retail, and real estate industries (charters, lodging, restaurants; fishing equipment such as boats, rods, reels, tackle; and secondary residences for fishing, respectively.).
    Submitted September 10
  • There is no indication in the national recreational fishing policy that the recreational and non-commercial fisheries are socially and economically valuable use of fishery resources, or that management and policy decisions will be made to foster its current and future potential.

    What steps will management and councils take to purposefully create the necessary conditions which will allow the potential social, cultural and economic benefits to be realized.

    Who is accountable to ensure that a concerted management effort will be realized and on what timetable will this occur to secure these benefits?

    How will we evaluate whether or not we are meeting the demand for quality recreational fishing experiences?
    Submitted September 10
  • First, we are and English speaking country. Get rid of the any other language on documents.

    Second, throw out any and I mean any inputs of the CCA! It is a vile self serving organization that has duped many good recreational fishermen to joining them by their misleading PR. I am a rec fisherman and ran charter boats for 20+yrs in the past. We on the outer banks are not fooled.

    Third, enforcement must obey the Constitution and especially the 4th Amendment.

    Fourth, many enforcement during the striped bass season off of VA intimidate boats by hovering helos dangerously right over the boats. They have also threatened boats outside the 3 mile line and said that they couldn't fish out there, when they were tautog fishing. No enforcement has that right!!!
    Submitted September 10
  • Comments Concerning the Proposed Recreational Policy:

    1. I do not support the development of a Rec Policy if the intent of that policy is to circumvent, or in any way weaken the requirements of the 06’ Reauthorization of MS for the rec sector or NMFS Convenience.

    2. Abundance must be clearly defined. Some in the rec sector define abundance as being able to land more fish. In reality, off of Florida, the sector is experiencing increased abundance as stocks recover under ACL’s. Red snapper, gag grouper, black seabass are all species affording the abundance the sector requests from rebuilding.

    3. The proposed policy should have as its overarching objective managing mixed (rec/com allocated) fisheries for the best benefit of the nation per the act. Economic analysis should be undertaken on all managed fisheries and mixed fisheries addressed and allocated accordingly for the best benefit of the nation.

    4. Recreational bag limit sale, as well trip expense fishing should be disallowed in all fishery FMP’s, and as a matter of NMFS Rec Policy.

    5. For hire sector should be considered a commercial enterprise and not part of the allocated recreational fishery. The for hire sector takes people fishing and /or, in pursuit of their rec bag limit. They should have no IFQ/Catch Share whatever, from the rec allocation. If they get a catch share it should derive from the commercial allocation. Policy should also mandate they cannot take a crew bag limits while fishing under charter.
    Submitted September 10
  • I wish to submit the following comments for consideration during the development of the Recreational Fishing Policy. As a Hawaii resident for almost fifty years, a retired Marine Science teacher with the State of Hawaii, a USCG licensed Captain and an individual that has been involved in ocean related recreation for seventy years, I submit the following items to be considered while developing the Recreational Fishing Policy.

    1. The policy must NOT be a one size fits all policy but MUST take into account the customs, needs and values of different regions. This could be done by aligning the regions with the Magnuson-Stevens Act.

    2. Each region would control the management of their own marine resources via a board, panel and use a bottom up method of developing management rules. Members of the board would be selected by a non-governmental group of individuals and use selection based on knowledge and experience in marine related fields. Terms would be for a minimum of four years to provide continuity and members could serve more than one term.

    3. The over-all goal(s) of the board should be to develop a sound management policy for their region and see that those policies are enforced by the State, County, District law enforcement authorities be they police, sheriff, game management, or any other law enforcement entity.
    Submitted September 9
  • The very general themes should be kept that way to accommodate significant regional differences and give flexibility. Consider adding a theme that focuses on enhancing social and cultural as well as economic research on and our understanding of the fishing experience, the flow of fish (post-harvest distribution food security), and angler attitudes. Consider the recommendations in the RFWG white paper in terms of whether the themes are general enough to accommodate all, or whether some regions could/should have separate policy statements.
    Submitted September 9
  • Including some measurable goals is an essential part of a management/conservation/public access plan. There needs to be concrete plans with measurable goals addressing the "Garbage Patch" issue. Thanks you for this opportunity to comment on this important issue.
    Submitted September 9
  • Thanks for the opportunity to comment on the proposed National Saltwater Recreational Fisheries Policy. The new Policy is a great time to strengthen the agency’s work on recfish-related science, connections to habitat conservation programs, and joint efforts such as the National Fish Habitat Partnership.

    The American Fisheries Society, founded in 1870, is the oldest and largest professional society representing fisheries science, management, and policy. AFS promotes scientific research and enlightened management of aquatic resources for optimum use and public enjoyment. That mission intersects nicely with recreational fishing, and prompts the following comments to NOAA/NMFS as you develop and then implement your new Policy:

    1. Use best available social and natural sciences across disciplines to encourage broader approaches to traditional challenges
    - Recognize the value of programs that might not have a clear focus on recreational fish or fishing (programs that focus on general issues such as fisheries management or habitat conservation often have direct benefits to recreational fish issues)
    - Document to social value of those broader approaches as the ecological returns are likely to surpass the socio-economic investments.
    - Advance the scientific analysis of the ecological and economic value of seasonal and permanent marine protected areas or closures.

    2. Address the long-standing challenge of evaluating the ecological value of artificial or created habitats (SAV beds, fishing reefs) or facilities (fish passage structures) compared to natural habitats
    - Evaluate existing literature to determine the relative value of various protection and restoration techniques, including created habitats such as artificial reefs and engineered plots like salt marshes or SAV beds.
    - Include the artificial reef, restoration, and engineering sectors in such work to gain from their expertise.
    - Identify data needs (by topic or geography) and pursue creative solutions to filling priority gaps, e.g., partnerships with NOAA’s Sea Grant Program or academic partners to encourage academic research.

    3. Increase attention on monitoring, assessment, and management of the entire recfish sector
    - Create a special committee under the Marine Fish Advisory Committee (MAFAC), a FACA-exempt advisory body, or another alternative to focus attention on the need to evaluate existing sector approaches.
    - Include the recreational fishing sector in selecting the preferred approach and then in design and implementation.
    - Partner with the US FWS and states to increase consistency on monitoring, management, etc.

    4. Advance consideration of habitat threats as an immediate mechanism to decrease environmental mortality and thereby increase the number, size, and weight of fish pursued by anglers
    - Add environmental mortality to fishing mortality in all management discussions.
    - Consider such an approach as a viable means to increase overall yield and the relative share to the recfish sector.

    5. Engage in efforts to reverse trends in coastal wetland loss, thereby improving one of the more important habitats for juvenile and adult species pursued by sport fishers
    - Partner with state and federal agencies to document the effects of coastal wetland loss to the recfish sector.
    - Identify specific actions the recfish community can take to improve wetland health, e.g., harbor management plans, bilge/wastewater/fuel handling, anchoring strategies.

    6. Investigate ecological interactions of recreational fisheries with marine mammals
    - Increase attention on connections of some growing marine mammal populations (perhaps like grey seals off Cape Cod) that might affect striped bass but to the benefit of species like great white sharks. Are any changes to the Marine Mammal Protection Act warranted?

    The American Fisheries Society would appreciate the opportunity to discuss these comments as the Policy is finalized and then as NMFS implements its new plan.
    Submitted September 9
  • These 5 items are already very much part of NOAA's job. No comment should be required. It's as if a deckhand on my partyboat were appalled that he had to cut bait: "I have to do that??"

    I'm very disappointed in a system that jams catch estimates no one believes straight into formulaic management regimes: no matter how badly they affect science, management and create economic suffering among users, NOAA forces all of management to use them - "It's the best available data."

    You'll recall MRFSS estimated NJ Shore anglers took 74K tog in the spring of 2010 – That was made a laughing stock because shore-bound NJ tog anglers in Mar/April probably catch fewer than 500 tog.

    MRIP steamrolls in with it's repair: "No!! Those Anglers Took One-Hundred & Seventy Four Thousand Tog In Mar/Apr!" 100,000 more..

    That's just stupid. One of MRFSS worst-ever made incredibly more worse by MRIP's "repair."

    Then MRIP writes about that estimate in a press-release: "..With these improvements in place, we can say with confidence that we have enhanced the quality of our estimates. In fact, the cases you cite are good examples for demonstrating exactly what we mean by that."

    Hey, that's the same language as in the "Is this what NOAA should do?" comment period.

    Does anyone in management believe NJ and NY private boats took more sea bass than ever before with their smallest creel limits in history during the summer of 2013? That they out-fished the entire Atlantic Coast's For-Hire AND Commercial Trap Fisheries?? Anyone who does believe that has no idea the fishery – none.

    Yet:
    Those Estimates Are EXACTLY why I'll be shut down in a couple weeks.
    Those Estimates Are EXACTLY why I will not be able to target sea bass in Jan/Feb.
    Those Estimates Are EXACTLY why science has been bound and gagged; why the stock withers despite researchers being ga-ga over warming's habitat expansion..
    Want to know what drives recreational fisheries? Fish! ..and access to them.
    Want to know what's destroying recreational fisheries?

    Management focused on bad data -- estimates they should scarcely even consider are running the whole show. Overarching methods of Making More Fish: Habitat, Habitat Fidelity In Quota Management and Managing For Maximized Spawning Stock Potential Are Not Even A Consideration.

    Nary a thought for rec-fish other than, "Did they exceed quota?"

    True Statement: Never in history has so much knowledge and skill been brought to fishery management. NOAA is wasting that talent by demanding adherence to MRIP/MRFSS catch estimates.

    If You're Unsure Of How I Actually Feel About Recreational Catch Estimates' Influence On Restoration – see Jim Cramer at 2:00 minutes http://www.youtube.com/watch?v=rOVXh4xM-Ww

    Not only can habitat ecology/population biology not get a foot in the door, its practitioners are AFRAID to say anything that might go against the "We Know What You Caught" charade of present-day NOAA insistence.

    You have no idea how far off course NOAA has steered restoration by treating MRFSS/MRIP as if it offered a scientific gold standard. What a waste!

    I think management's early years enjoyed instant success via ANY restriction. Now NOAA is squandering early gains by bringing no other science to the table, by insistence that the dream of Camelot can be made true in ever-tightening catch restriction. Reef? What Reef?

    Age at Maturity? What effect could that possibly have.
    Warning Will Robinson!! Warning!! Overfishing!!
    Kayaks are wiping out swordfish! Man the regulatory cannons!
    There are ways to check MRIP.

    First you'll have to admit you need to check at all.
    Submitted September 8
  • Stripers Forever, a conservation and recreational advocacy organization focused on striped bass along the East Coast offers the following comments on NOAA recreational fishing policy.

    NOAA must stand up in the fishery management process for recreational fishing. On a local basis it is very difficult for recreational fishing to get the consideration it is due because commercial fishing has historically been seen as the more important use of the resource. Politicians are very slow to take new and forward thinking positions that they do not thoroughly understand, and these politicians control the appointment process for all aspects of local fishery management.

    The federal government often has a different view of wildlife management than the states because it is not as easily controlled by small segments of the public. The history of waterfowl management provides one of the clearest examples of how the influence of the federal government was needed to change the fishery management practices within the states. Action by the federal government could now be very important in improving recreational fishing opportunities, and this would overall be very beneficial.

    There are a number of strong justifications for giving a great deal more consideration to recreational fishing than it currently receives.

    I. Issues that justify greater allocations and management consideration for recreational fishing.
    A. Personal Use Allocations - SF sees recreational fishing as members of the public directly accessing for their own personal use and enjoyment a resource that all citizens have an equal right to. The precedents are clear in wildlife management that this individual right has the highest primacy when compared to other harvesting.

    In many cases today we see commercial fishing quotas taking such a bite out of a scarce resource that a reasonable personal use harvest is not possible, and this is simply wrong. NMFS should stand up for the rights of individual citizens to have a fair harvest allocation before commercial fishing harvests the surplus – if in fact there is any surplus.

    B. Conservation - Because of the comparatively inefficient and non-invasive equipment used by recreational fishers they do not take large percentages of a fish population from a defined area at any one time. Recreational equipment also tends to be far less harmful to the environment than commercial gathering techniques such as bottom dragging, nor does it cause ghost fishing issues that take place with the use of gill nets. Also, because there is no profit motive fishing will generally not occur beyond taking the bag limit. The greater conservation values in recreational fishing activity when compared to commercial fishing should be recognized and supported. If, for instance, a fishery or a fishing location cannot support commercial fishing activity recreational activities should not be automatically banned just because commercial fishing activities are not appropriate.

    C. Economics - In most or perhaps all fisheries that are participated in by recreational anglers the public benefits by receiving a greater amount of economic activity than if the same fish were taken by commercial fishing. There is no justification for harvesting the fish commercially if it generates less economic activity than would be available through recreational fishing. In spite of rhetoric about providing seafood for people, all commercial harvest does when confronted with a limited resource is to take fish away from those willing to harvest their own and sell them to someone else. No additional seafood can be created, and less economic activity and jobs are produced in the process.

    D. Social Benefits - The great American conservationist Gifford Pinchot said: “Conservation is the foresighted utilization, preservation and/or renewal of forests, waters, lands and minerals, for the greatest good of the greatest number for the longest time.” Surely our continued management of fish to fulfill the desires of the small number of people within the commercial fishing industry provides benefits for less people than a recreational fishery with many times the participants. For those fish enjoyed by recreational fishing it is obvious that the greatest social benefits can be achieved by optimizing the populations of those species to get the most public participation in the fishery.

    E. Right Thing To Do - It is obvious to all thinking individuals that we should not destroy our populations of ocean fish, yet that is exactly what we have done. Commercial fishing interests have been able to leverage local politicians and on up the political ladder to have the greatest influence of any user group on the fishery management process. The result has been the essential destruction of our marine fish populations. Clearly these practices have to end and we need to rebuild our fishery populations. It will not be possible to do this and manage them allowing as much commercial harvest as we have in the past. NOAA has the ability to greatly influence the fishery management process for the better by adopting and promoting policies that recognize the rights of recreational anglers and the benefits of recreational salt water angling. Typically local fishery management has no guiding policies of any kind, and NOAA’s policies will become the benchmark.

    II. Additional issues that must be addressed to improve recreational fishing experiences and enjoy the associated benefits.

    1. “Willingness to Pay (WTP)” must be replaced with some other more practical allocation metric – one that the managers can understand and apply today. The fact that each individual recreational participant is a citizen with equal rights to all others must be recognized.

    2. Minimum standards for recreational fisheries must be established – a hard catch per unit effort (CPUE) should be set where possible to ensure an acceptable probability of catching a fish.

    3. Abundance must be evaluated in terms of the minimum catch per unit effort established for a “successful” recreational fishery in recognition of the fact that it takes more fish to have a successful recreational fishery. For fisheries participated in by recreational anglers it must be formally recognized that maximum sustainable yield (MSY) is not an appropriate concept.

    4. Better effort data must be continuously collected for the recreational fishery. MRFSS and MRIP have been relied on for years, not because they provided the best data but because they were easiest to implement.

    5. Recreational participation in the management process at the council and commission level must be increased. These venues are traditionally saturated by commercial interests. For many jurisdictions, there is essentially very little recreational representation at the ASMFC.

    6. We need to stop hiding behind phrases like “fair and equitable,” and words like “reasonable” that are poorly defined in the context of fisheries. The federal recreational fisheries policy should either stop using these terms or give them some teeth in practical terms that can influence policies. When the law says that allocation policies shall “Not permit a particular individual, corporation, or other entity to acquire an excessive share of fishing privileges,” what does the word “excessive” mean?
    Submitted September 8
  • I would like to comment that I support the findings and goals that the Commission on Saltwater Recreational Fisheries Management has put forward in their Vision for Managing Saltwater Recreational Fisheries. On the policy scope I feel that the meaning of recreational fishing means just that it is the act of fishing for recreational purposes and nothing else. It means fishing within the ethics set for the fishery in bag limits and closures. There is a need to include recreational spearfishing and FL lobster and tropical fish collection as recreational also, the need to end backdoor fish sales. Draft Goal #2 is important to the recreational anglers in the FL Keys waters due to the fact that we are in a National Marine Sanctuary under NOOA. In which there are areas set aside that anglers view as no take areas, it seems to anglers that we are looked upon to supply other areas without a clear voice in the fishery management councils both of which we are covered under in which we should have our own sector to be covered under on (Possible Policy Goals in Detail as Fishery Management Within and Outside of Sanctuary's Boundaries). The need to fund enforcement for they have been cut to the bone on funds, the areas they have to enforce seems to ever grow and they are doing a great job just think of the enforcement they could do with proper funding. For in the FL Keys National Marine Sanctuary we have found out that you can write all the rules that you want but without enforcement they are just that rules which are looked upon as such with out enforcement to back them up.
    Submitted September 8
  • Leave it to the individual states to establish a policy for their own waters.
    Submitted September 5
  • If you want equal access to the fishery, pass Amendment 40 with Action 1. Preferred Alternative 2. This will allow everyone the ability to go fishing. Not just those who can afford to buy a boat, store it and maintain it year after year just to fish one or two times a year. Some people may fish once every other year.
    Submitted September 4
  • How about a national saltwater fishing license. I have a drivers license valid in all states, why not a saltwater fishing license.
    Submitted September 4
  • As long as commercial fishing vessels have debts and fishing represents the only recognized option for the owners to earn a living and to meet their debt obligations, the temptation to circumvent limits on days, weights, species and areas created by laws and regulations will not only continue to exist but will also be given into. This is not to say that recreational anglers are not so tempted but their ability to negatively impact fish stocks is of a magnitude less.

    Laws and regulations should exist for both groups but special considerations are required in creating options for those whose livelihood is at stake and whose vision is limited by the financial situations they find themselves in. While governmental purchase of vessels represents to many an extreme step, anything less will not eliminate the perceived need to land enough biomass to cover the existing debts and assuage the needs of those in the industry. Such a program in and of itself is insufficient and must be coupled with programs to prepare and promote those negatively impacted for alternative employment. Aggressive enforcement of existing and proposed laws and regulations in an impartial manner is also a requirement of success and an additional expense laid upon government.

    Currently the fees for recreational fishermen do not represent sufficient monies to cover the enforcement of existing laws and
    regulations and should therefore be gradually increased until they do so.

    Limits have been set in the past through debate and compromise with many interested parties. While the knowledge base of academics is not perfect, these scientists have the best base for proposing a sound basis for the long term successful management of our shared natural resources. Political courage of the highest and best kind is required going forward?
    Submitted September 4
  • Sport and Commercial representation on FMCs needs to be equal. Also, such representation needs to be a real interest (for example don't want a sport fishing representative that also has commercial fishing interest). Need to have strong staff support in each NMFS region with a focus on recreational fisheries interests.
    Submitted September 4
  • Hundreds of salmons are caught and put back in the water as illegal not fin clipped fed to the birds and seals. I don't think this is the way to save the salmon. Apparently seals and birds are more important than people. This I don't understand.
    Submitted September 3
  • I believe that Sector Separation will improve the fairness, catch accuracy, and accountability of the Gulf Fishery. One reason that this issue has met resistance from some fishermen is the rally from non permitted charter boat operators who profit from the increased state seasons and short federal seasons. Many customers who would normally fish on federally permitted charter boats are being forced to fish for Red Snapper in state waters on small non-federally permitted boats. These non-permitted boats don't want a balanced fishery or accountability and seek to financially benefit from the loss of the federally permitted boats who are being forced out of the fishery by the status quo and Amendment 30.
    Submitted September 3
  • I as a fishing guide for the last 36 years In the state of Alaska would like to see a fair distribution of sport and commercial use of halibut. Why 29 vs 32 for instance or are we catering to the commercial sector.
    Submitted September 3
  • Where to start. Well first and for most it is a great idea to find out how many people are actively fishing. But at the same  time no one knows how much is taken and from where. I feel that YOU NMFS need to start. I have been filling out a log books for years, and when more pounds of bait were used to catch a lesser weight in fish it is hard to understand the logic. Now when other boats go and catch why can't we make them report. Here's my idea. Make a app where people can go and report what they caught, how big, how many and where. But nothing will be done, how about some new reefs closer to shore. Or maybe we should be allowed to keep nothing.  Close the ocean. There is nothing to save all that's left is salt.
    Submitted September 3
  • This rec fishery policy misses the boat in that recreational fisheries are about opportunity not simply yield. Magnuson mandates that our fishery models are designed to obtain maximum or optimum yield. Recreational fisheries do not simply desire the most yield. Hence the metric which our assessment models are mandated to optimize will not necessarily maintain desirable recreational fisheries and clearly will not optimize for them. They are mandated and designed to maximize yield, only. The solution is a redesign of Magnuson to allow for optimizing some desired metric other than yield and to redesign the models to solve for metrics other than simply maximum or optimum yield. So what should be asked of rec fishers are what kinds of metrics are most important- the most yield, the most opportunity, the highest catch rates, etc. All of these things can be optimized for but currently we only operate on yield.
    Submitted September 3
  • I believe that you are doing our fisheries a disservice by segregating stakeholders into individual user groups. I feel that NOAA’s priority should be clearly focused on the protection of our fishery resources.

    When there are a lot of fish in the sea, everyone, all users are pleased. When there is a shortage of fish, Fisheries Managers are blamed for failing to provide adequate regulation and enforcement.

    Fisheries management by species is totally inadequate. You can try to protect a species while allowing decimation of that species forage base and/or habitat. We need to focus more on the health of our waters to provide a balanced aquatic ecosystem.

    When you can achieve that everyone will be pleased.
    Submitted September 3
  • I don't think you have missed anything…I know that you are well-aware of the Morris-Deal report. A number of very influential industry leaders have spent a lot of time, energy and money on trying to separate / identify discrepancies between Commercial vs. Recreational Fishing. The crux of the Report is so Recreational Fishing is considered and recognized on its own merits, and not merely lumped-in with Commercial Fishing management. I believe NOAA Fisheries is moving forward at great lengths to address this core concern. If and when NOAA Fisheries mandates a unique and separate National Recreational Fisheries Policy - which it is my understanding you guys are doing just this very thing, then that will be significant in the hearts and minds of Recreational Anglers.

    Selfishly, I think that NOAA Fisheries and FishAlerts/Great Outdoors Mobile needs to be collaborating on more significant and deeper levels of engagement. We have the technology - we just need more support! Thank you for your time, consideration and support in helping Recreational Fishing, Fisheries Management and putting more people to work, on behalf of our oceans and marine ecosystems.
    Submitted September 3
  • One: Council Representation: As a stakeholder I deserve equal representation on the council or any other future council designed to regulate the Saltwater Recreational Fishery.

    The gulf council is currently made up of the following: 5 commercial, 2 charter boats, 2 recreational, and 2 others. Not sure what an other is??

    As a private recreational saltwater fisherman, I want someone who actually fishing offshore in the saltwater, not a plant paid by the charter or commercial. Voting council spot are very political and the Private Recreational fisherman get very little representation on the council.

    Two: Move Private Recreational saltwater management out of the Gulf Council:

    The fishery Council were never intended to manage recreational fishery. It was designed and the laws written to manage the commercial fishery. Therefore, I propose to set the Gulf Council and other council manage the commercial fishery and for hire industry.

    Why does this make sense?? All for hire vessels should be required to have VMS systems and electronic log books. IE charter boats are a business and should be treated as such. Every passenger should be tracked for safety reason if a boat is lost at sea and for telephone surveys to make sure the charter boats are reporting correctly.

    Since VMS is required on Commercial vessels, charter and commercial vessels should be managed by the same organization, same regulators and same law enforcement.

    Saltwater Private recreational fishery should be regulated by the States in conjunction with the Gulf States Marine Council.
    Three: All Private recreational fishery vessels fishing for a Federal managed species should be required to have a species vessels permit regardless if they fish Federal waters or State waters.

    IE Red Snapper vessel permit, amberjack permit, grouper permit and etc.

    Four: Free daily fishing vessel permits must be obtained to harvest, not catch but harvest any federal managed species.
    Example: if you want to harvest Red Snapper, you must fish from a boat that has a red snapper permit and then you must get a free daily permit using that boats permit number. Daily permits could be obtained via, the internet, on line, telephone or smart phone and then a daily permit number issued to that boat along with a copy to the State of registry.

    If stopped by the marine patrol, you will give them your daily permit number so that it can be verified or show them a print out.
    catch data is the problem and this needs to be resolved before any other issue is adopted.
    Submitted September 3
  • We would like to see a more comprehensive policy with more emphasis on the economic affects that management has on businesses that depend on local resources for revenues, jobs, and tax revenue to local, state, and federal governments.  This comprehensive policy must be included in the Magnuson Act to strengthen the importance of recreational fishing as a valuable economic resource with minimal negative environmental impacts.
    Submitted September 3
  • OK. To all the people saying the small business guy with a boat and com. license is the issue. So for instance- If the limit on draggers is 9k and it scoops 13k. 4k of that goes back into the ocean dead. Transferring it to another boat is not an option.

    Now I ask- If each one of the small boat captions went out with their single line rod and reel fisher/people, how long and how many trips would it take to equal the amount of dead fish thrown away by a dragger in one day (P.S. this goes on every single day of the year!!)

    How many years does it take one person to catch 4k lbs of fish on a single rod and reel? How about you. Have you in a lifetime caught this amount.. I don't think any of you have, I know I certainly have not. So the real issue is NOT small boat captains trying to make a living but it is the draggers over getting their limits and throwing perfectly good food back dead and also undersized.

    Now lets talk about that..UNDERSIZED CATCH- How do you control what goes into a net that scoops everything in its path up to the surface? FACT- YOU DON'T ! you are taking everything in its path and not able to control what you are catching. Unless you do it with a rod and reel you have no control. So is the fishing industry turning a blind eye...YUP.

    Where is the guy with the badge boarding their boat checking their holds for undersized...? They don't get fined because the industry knows it can not control that aspect of it, so what do you do. You people blame the ONLY ones that are actually controlling the size of fish that are coming up and into a boat. Your blaming the single line rod and reel small boat captions making a living actually caring about the industry and ecological system as a whole. Please stop being idiots and talking about things you have no clue about. Start getting on a band wagon you actually can speak first hand from. Otherwise like this industry you are just catching the wrong people and throwing back the dead without ever knowing or caring about the consequences...
    Submitted September 3
  • Fire everyone of you from Spud Woodward on down. You all cannot manage. Establish a 100 mile boundary and keep the foreign commercial boats away. Leave the inshore fisheries alone and it will take care of itself.
    Submitted September 3
  • We would like to comment on the proposed National Saltwater Recreational Fisheries Policy. We are Columbia River commercial fishers with well over fifty years of experience in commercial salmon fishing on the Columbia, Willapa Bay, Southeast Alaska and Bristol Bay. We have experienced first-hand the devastation that can be wrought on commercial fishers and their communities by implementing policies similar to the new proposal. We have attached a 2014 update of the 2005 Social Snapshot of the Columbia River Gillnet Fishery that indicates the devastating social effects of the Oregon/Washington implementation of a Columbia River recreational fisheries priority on commercial fishing counties. We have also included an electronic copy of the 2005 Social Snapshot.

    One of the fundamental assumptions under the proposed National Saltwater Recreational Fisheries Policy (and others like it) is that stability can be achieved in recreational fisheries. Natural-resource-based fisheries, including those based on hatchery stocks, are inherently unstable, and fluctuate according to weather, food production, ocean cycles, natural and man-made disasters and a myriad of other phenomena. One of the key points made under Draft Goal 1, Management, in the Policy Discussion Guide is that NOAA Fisheries should "better understand and manage for angler satisfaction.” The Policy does not identify what “angler satisfaction” might be, and is basically an issue of perception. One would assume, however, that catching one or more fish would be part of that satisfaction standard. The potential for conflict arises when there are not enough fish, or there is the perception there are not enough, in the recreational allocation to fulfill that requirement. Fish populations fluctuate and in times of low abundance fulfilling a mandate regarding “angler satisfaction” may not be feasible.

    We have also noticed in our years of fishing that a year of high abundance does not necessarily satisfy anglers. Instead, we have seen in numerous meetings that there is an expectation that next year will be better. Every year of high returns brings with it the expectation that the following year will meet or even exceed the preceding year’s abundance. This may be a perception more suited to a corporate board trying to satisfy its stockholders, but for the reasons stated above, it does not apply to a continually fluctuating natural resource.

    The draft Policy also includes under Goal 1, Management, that NOAA Fisheries must "ensure equitable distribution of fishing opportunities to and within the saltwater recreational/non-commercial fishing community, including periodic review of catch allocations.” Discussions and supporting documents indicate that  periodic review is to take place every five years. In essence, management will be required to “manage for angler satisfaction” by reviewing allocations to commercial fisheries and possibly shifting them to recreational fisheries to “ensure equitable distribution of fishing opportunities” to the recreational fishery sector. There is no mention of equitability for the consumer who purchases fish to eat nor of consumer satisfaction. There is also no mention as to how this policy might work in a time of low abundance, when conceivably there would not be enough fish to achieve “angler satisfaction.” Would commercial fisheries be forced to shut down, and consumers not be allowed to access fish to purchase? The draft Policy is a very thinly veiled sport fishing priority policy, at consumers’ and taxpayers’ expense. It is a formula for perpetual allocation battles. It also could be construed as an attempt to shift any conservation burden to the commercial fishery, in favor of recreational angling.

    While these battles continue, how do commercial fishers decide to make long-term investments in a climate of short-term (every five year) reviews? The Policy takes any stability out of the commercial fishery in order to enhance recreational fisheries. Moreover, there may be substantial tax implications involved in the continuing cycle of allocation reviews, especially if large numbers of fish are suddenly allocated out of the commercial sector and into the recreational sector. A perusal of the IRS website, www.irs.gov indicates various depreciation and amortization schedules: a fishing vessel may be depreciated over 7 years; a tender or floating processor over 10 years; a permit may be amortized over 15 years. Fishermen may also set aside money over a period of years in a Capital Construction Fund for vessel purchase or construction. These are clearly long-term investments, as already recognized by the federal government in its tax laws and policies, and should not be subjected to short-term thinking and policies by another federal agency.

    Moreover, this is an expensive policy for the taxpayers. One of the suggestions under Draft Goal 2 encourages NOAA Fisheries to “establish a full-time regional recreational coordinator in each NOAA Fisheries region and Atlantic HMS.” Our understanding of this requirement is that there are 45 such offices, each of which would either hire or appoint a full-time staff member to “coordinate” recreational fisheries, conduct planning, and, presumably, carry out this policy. At a time of serous fiscal issues at the federal level, this strikes us as an expensive way to pursue a hobby. We recognize that there is an industry associated with recreational fishing that brings in revenue to some business owners. But recreational fishing is still a recreational pastime, a hobby, and we wonder why so much federal tax money should go into ensuring its participants achieve “angler satisfaction.” We haven’t noticed stamp collectors pursuing a “National Stamp Collectors’ Policy” with the U.S. Postal Service.

    On a larger scale, some of the ideas put forward in the Draft Policy would make sense for both recreational and commercial fishers, and we wonder why they are being confined solely to recreational fisheries. For example, “cooperative scientific research and analysis in partnership with fishermen,” and “partnership on conservation and enhancement projects,” should not be limited to just recreational fishers. There are a number of other areas where the two sectors (recreational and commercial) could and should be working together, but this Policy appears to us to be divisive and actively excluding commercial/recreational sharing rather than fostering better partnerships between the two sectors.

    We would appreciate a revision of this Policy to include the possibilities of cooperation rather than conflict, and enhanced fisheries for both the commercial and recreational sectors, as well as a very clear analysis of how this Policy might affect fish consumption in the U.S. For the past several years NOAA Fisheries’ website indicates we are importing approximately 90% of the seafood consumed in the U.S. Will this policy further contribute to this unbalanced statistic? Or is there a way to increase the amount of American-caught seafood so that American consumers, who pay for its management, can purchase it in the market? The draft policy nowhere addresses this important issue. There is also no cost/benefit analysis that shows what the costs associated with this policy might be, nor how it will benefit recreational fishers, commercial fishers, and consumers.

    We would appreciate your attention to these issues regarding the draft National Saltwater Recreational Fisheries Policy. We believe there are significant fiscal, social and community issues involved that have not been addressed. We also see major conflicts with current federal policy, including tax implications and job and business conflicts. But in our view, the biggest flaw is that the Policy does not foster cooperation in working for conservation of fisheries resources, but pits people who rely on the same resource against each other. NOAA Fisheries should not be endorsing or putting forward any such policy that will work to the detriment of the same resources it is charged with protecting.
    Submitted September 1
  • Eliminate draggers or reduce where they can fish. Draggers have excessive by catch that is wasted. They also destroy the ocean bottom ecosystem. We should consider commercial long lines for fish like cod/haddock that would only take market size fish of the targeted species and leave juvenile and non targeted fish to grow and spawn for future generations. I realize this would increase the cost of fishing, but what's the point of fishing it nothing is left.
    Submitted September 1
  • I speak only for the Northeast striper fishery. After an amazing comeback in the 90s, the striper fishery appears to have or is beginning to collapse once again. As a recreational angler, I would support stricter regulations, specifically a slot limit that would protect the big reproducing females. I believe the sooner this is done, the faster the fishery will recover. I think we can all afford to skip a few years of trophy fishing in order to restore the fishery. The slot limit would satisfy those that need to harvest a few fish.
    Submitted September 1
  • I find the themes comprehensive - Thank you! I do have concerns on commercial fishing and it's impact on my recreational. For example herring harvests and the dependance of striped bass stocks on herring. I hope commercial interests are kept sufficiently in check to achieve overall goals.

    Also, as we become increasingly aware that fish swim and use a geographically broad and somewhat diverse habitat, our management strategies should be equally geographically broad and diverse to achieve the desired goals.

    Thank you for all you do!
    Submitted September 1

August 2014 Comments

  • Further restrictions of commercial fishing. Restrict recreational catch to one per day and increase size limit. Also consider slot limits on size.
    Submitted August 31
  • The headboat/charter fishery needs to be looked at with a large reduction implemented. The boats take charters out up to 3 times a day with 3-5 sports on board who are killing 2 fish each. That means they are killing 20+ fish a day. All recreational fisherman should be limited to 1 fish per day especially the charter boats as they are fishing 100+/- days a year which means they are killing thousands of fish every year.
    Submitted August 29
  • I have fished recreationally and scuba dived the waters from the Danvers River to Marblehead to Cape Ann for more than 30 years.
    In recent years we have more striped bass than anything else. If they have declined recently it is because they have eaten every other juvenile ground fish or eel available in shore and have moved off shore. Let them be caught in greater numbers (smaller size, greater daily limit) so we can restore some balance.
    Submitted August 29
  • My opinion on how to improve the striped bass fishery:

    1. Please start a slot limit that only mid sized fish say 28" to 35" fish can be harvested.

    2. If harvesting of larger bass is ever allowed again, I suggest issuing a tag (like a deer tag) for one trophy sized striped bass. Have it difficult to get and very limited. We need to protect the big breeders.

    3. Please limit one bass per 2 men on a boats. One fillet is more than enough for each man to bring home a taste. There is no need for each man to have to keep a whole bass. That is too destructive. Filling the coolers in boats is out of control. I know for a fact that too much frozen bass filets end up just going to the dump and never even cooked and eaten.

    4. Targeting and harvesting of breeder striped bass should be closed completely in the upper Hudson River and Chesapeake Bay. It upsets me so much to see 55 gallon drums of fish waste including massive scanes full of eggs being thrown out to the dump. These eggs could allow for a very healthy population. The amount of bass that is being filleted during breeding season is a sin.

    5. Very large fines or 24 hours in jail should be put in place on poachers caught with under sized bass. Seeing Asian and Hispanic fishermen keeping 12" and even 8" bass along the Hudson is horrible. I've caught then filling the bottom of their large tackle boxes with tiny panfish sized striped bass. We have reported some which have been fined and brought to court but the fines need to be increased substantially.

    6. Please open hunting seasons on Gray seals to save all the inshore fish populations including striped bass. They are wiping everything out.
    Submitted August 29
  • There should be one saltwater fishing license (per angler) needed that allows fishing in any saltwater surrounding the United States. Each angler should have a maximum of two fishing poles with one hook or lure per pole. There should be a requirement that all boat operators take the boat safety classes.
    Submitted August 29
  • Ban and strictly enforce dragger boats from fishing within 5 miles of shore. I have seen them fishing with in a couple hundred yards of shore in Plymouth Duxbury and Manomet. The shoreline needs time to reestablish its ecosystem...it's been decimated by commercial fishing!
    Submitted August 28
  • I'm a fly fisherman primarily, I generally don't keep fish especially striped bass. Its seems the bait available for the bass has decreased significantly in the last 20 years, and so has my catch . We should further reduce quotas for such fish i.e. bunker.
    Submitted August 28
  • I think the policy of requiring a fee for fishing is wrong. Fishing for relaxation, recreation or bonding has been a long standing practice for centuries (forever) You are about to drive this activity away from those who cannot afford it. Think it through!
    Submitted August 28
  • My 'home waters' of Buzzards Bay, Mass seem devoid this season of the familiar striped bass and bluefish chasing menhaden.

    I suspect this may be due to the massive commercial harvest of menhaden in the Chesapeake and offshore. I would hope your organization could address this issue, in spite of the powerful interests of the menhaden industry. They have destroyed my sport and an important sports fishing industry around Cape Cod.
    Submitted August 28
  • Where is the link to comment on Striped Bass?
    Submitted August 28
  • What I have noticed related to spawning striper bass and the declining # of salt water bass noted in this area:our limit is and was 2 fish maximum minimum of 32"L in recent years (since about 1996 or so when it was 36"L for a keeper)

    What purpose does this serve when neighboring states are KEEPING what we are told need to spawn for the count to healthily flourish? Maine's was (?still is) 44" and also could keep 24" stripers. I was told it was a different size limit on Cape Cod as well though 32" was MA law. This does NOT add up to me.
    Submitted August 28
  • Prioritize measures that will assure recovery of striped bass stock, especially commercial fishing. Bowing to demands of commercial fishing industry based on effect on wages and profits is a ridiculously short sighted policy. i.e. The latter will inevitably lead to extinction of the striped bass population and PERMANENT LOSS of those wages and profits. Recreational fisherman, a huge lobby, have taken note of those politicians who pander to the commercial fishing industry.
    Submitted August 28
  • Input from longtime fisherman who have observed changes first hand!
    Submitted August 28
  • I know budgets are tight everywhere. But the problem is people taking fish under 28". I see pictures on Facebook with fish under 28" being taken home. Police boat launches? I fished from the rocks at plum island 8 times and caught 2 fish-26' and 22. Didn't see many other people catching much either. I follow all the rules and I think I'm in the minority. I hope you find an answer, because this was the worst bass summer I can remember. In 10 years I don't think there will be any striped bass or tuna.
    Submitted August 28
  • There is clearly a decline in my recreational catch this year in Mass and CT. I think all commercial activities should be stopped until stocks improve This view is shared by my commercial friends as well.
    Submitted August 28
  • You should support having One Federal Recreational fishing license per boat, that covers who is on the boat with you. Having a State license per individual is just not practical when people come to visit and just want to fish a few times. However, I feel the State of Mass will never give up this new revenue stream. At the end of the day all this new Licensing is all about control and creating a revenue.
    Submitted August 28
  • The thing I find with most of our fishery management is that by the time something is done its usually to late. I glad to see there is a concern because I have seen a decline in the last few years. Do something before it gets worst. Bring the size limit back up limit the catch. Keep our fishery healthy so we all can enjoy what we like to do catching fish. Thanks.
    Submitted August 28
  • First, I would like to comment that the entire process involved in reading the proposals and sending comments is at best confusing and at worst appears to be the work of real bureaucratic jingoese, no offense intended. I am a college grad and have a graduate degree, but I do not have the patience to try to make sense of these scientific proposals. How about something simpler? For my two cents worth, I think that commercial striped bass fishing should be stopped. If there is any doubt about the future of the fish, err on the side of caution. I know this will never happen in MA because of the commercial lobby, which is a shame.
    Submitted August 28
  • The rules and regulations that the lay fisherperson are required to follow should be very clear and easy to understand. I still have to re-read the reg. every time I go tuna fishing to figure out what size I can keep...this year. As for things like stripers, why don't you have a unilateral slot size for keepers that targets males, in every state, rather than allowing the culling of larger females? These are things I have always found to be a bit confounding.
    Submitted August 28
  • The decline in Bass stocks has been in direct proportion to the increase in seal populations. Start to investigate this relationship by harvesting some seals to determine what they are eating and then drop the protection of this species. No fishermen, no tourists due the Great Whites feeding on seals near the shore equals no tourists and a collapsed economy in the Cape. I cancelled my $500 charter this year, for the first time, due to poor catches in early July.
    Submitted August 28
  • There are some of us that cannot afford a boat especially when you can't keep nothing. I am all for management but full closure is insane. Red snapper are extremely abundant. 1-2 per person but zero for a full year. That is not management that is communism. I like to go on overnight trips to the middle grounds, in fact, I have a trip booked for Oct 24th, but now with you extreme rules I will have to cancel. I simply will not be able to spend $500 to release just about all I catch. What you guys are doing is creating a situation where anglers will probably increase their poaching were as they would normally abide by the rules. Closing the big 4 offshore fish gag, red grouper, amberjack, and red snapper at the same time. Come on give us a little. You must be hurting the boat sales with this. I cant believe someone would spend 100 grand +especially in the gulf region to not be able to keep 1 fish. In closing I wish to thank all you jerks for destroying any chance I had to enjoy a nice fishing trip..happy poaching...
    Submitted August 25
  • The council has failed to provide a valid reason for the current red snapper fishing regulations. Your quotas and population statistics are not only inaccurate,  but due to the severity of the disturbance these regulations have caused, it should be considered criminally fraudulent. The status of the red snapper fishery in the gulf of Mexico fishery is stellar, and whether the cause is misrepresentation or ignorance or greed, recreational fisherman deserve better reason for the harsh regulations set forth. Also, it should be recognized that recreational fisherman are on the front line's of conservation, it is only a step backwards to continue penalizing those that truly value our beautiful and plentiful resources.
    Submitted August 16
  • Thank you for the opportunity to provide comments to the development of the NOAA Fisheries National Saltwater Recreational Fisheries Policy. As Board chair of the National Fish Habitat Partnership (the Partnership), I believe the underlining tenets of the Partnership are consistent with NOAA Fisheries approach to habitat conservation. The Partnership seeks to protect, restore, and enhance the nation’s fish and aquatic communities through partnerships that foster fish habitat conservation and improve the quality of life for the American people.

    As the Policy is being crafted and implemented, we encourage NOAA Fisheries to take into consideration existing programs to which it currently provides a support or leadership role, making connections where appropriate. In particular, we draw your attention to programs under the NOAA Habitat Blueprint such as the Habitat Focus Areas, and the National Fish Habitat Partnership, both of which can play an important role in implementing habitat components of the National Saltwater Recreational Fisheries Policy.

    Under Draft Goal #3: Encourage Partnership, Engagement and Innovation, we encourage NOAA to incorporate the suggested “Partnership on conservation and enhancement projects (e.g. habitat restoration) to further fishery management goals.”  And support an additional action item/principal: “seek collaboration with existing partnership groups that are currently working to protect, restore, and enhance habitats benefiting recreational fisheries.”  

    I am also forwarding the attached comment letter on behalf of the Coastal Fish Habitat Partnerships. These Fish Habitat Partnerships are successfully addressing marine and coastal issues, and can be an avenue through which to take action to achieve NOAA’s Saltwater Recreational Fishing Policy goals.
    Submitted August 15
  • I think you missed the most important theme which is to return control of maintaining Gulf of Mexico fisheries back to the states and you monitor state policies only. I firmly believe that the states are in the best position to oversee, monitor and enforce compliance of maintaining the Gulf Coast Fisheries. The states can do stock assessment that are more current and make quicker decision on ways to maintain and grow the fisheries.
    Submitted August 13
  • NMFS and ASMFC have reduced the Long Island Sound to a desert. The food web has been destroyed by your MSY management of the Atlantic herring and the Atlantic menhaden. Your Assessment Models have collapsed the fisheries of the east coast.... Yet still you refuse to change your view and behavior. Why have our fisheries collapsed under you highly touted Assessment Models? The models are modeling nothing. Are you scientists? How much bad news do you need until you scrape this gibberish? I imagine you have a limitless appetite for failure as "nobody ever get fired". Your future employment should be based on the health of our fisheries..... You should go. If you were managing an asset in the private market place as you have managed this ecosystem you would all be on the unemployment line. Where  are the biologists hiding? You are not leaving anywhere near enough fish in the water! You seem to blind, deaf and dumb! Please resign or retire..... anything...... just leave the playing field and get some new blood to fix this mess you made.
    Submitted August 10

July 2014 Comments

  • I fail to see how any for-hire or headboat operations can be considered "recreational". While these outlets provide recreational anglers fishing opportunities they might otherwise not have, the cost / benefit equation begs scrutiny.

    1) Most charge $100 to $200 per person for a half day of fishing
    2) Most don't require passengers to have state or federal fishing licenses
    3) Most operators have commercial fishing permits which allow them to overharvest popular fish such as striped bass

    I take pride in being educated on both sides of issues that affect me personally, which is why I support the Coastal Conservation Association and the Center for Sustainable Fisheries, but also subscribe to National Fisherman. One simply cannot appreciate the reasoning, methodology, and goals of disparate groups without becoming familiar with what they read and believe. What I have learned over the years is that commercial fishermen don't believe government regulation of their industry is needed. They continually overfish one species until it becomes commercially non-viable, then target another, from the top to the bottom of the food chain. Only 15 years ago, no one in the industry would have predicted that commercial fisherman would be targeting pollack, ling, dogfish, and skate instead of cod, haddock, and flounder.

    I would love to see the amount of attention and advocacy for recreational fishermen properly reflect the billions of dollars they spend annually on boats, equipment, fuel, bait, licenses and fees, and fishing vacations.
    Submitted July 30
  • I recommend that all Regional Fisheries Councils should be encouraged to seek appropriate representation of recreational fishing interests throughout the Council. It should be discouraged to have majority representation of commercial interests, for example, in a region where the vast majority of fishers are recreational, or where recreational fishing's economic impact is greater than that of the commercial fishing sector. A change to greater representativeness could enhance the probability that council-generated management measures would be adopted by the states or territories.
    Submitted July 30
  • I support non-biased proper scientific evaluation of fish stocks. This is the only possible way we can have a sustainable fishery for our country.  I believe that the condition of most saltwater fish stocks is strong and that recreational fishermen are being unjustly limited. For example, the stocks of Red Snapper off the East Coast of Florida are stronger than they have ever been. Despite this we have only been allowed 8 days to recreational fish for Red Snapper with a limit of ONE snapper per person per day. This is not logical.

    Recreational fishing should be defined as fishing for sport, pleasure and for the families food. No recreational fish should ever be sold to off-set expenses. Ecotourist who do not fish should not be part of the Recreational fishery discussion.

    I strongly suggest that the ""Greatest Economic Value for all Citizens of the USA and for each community individually"" be considered when fishery management decisions are made.

    For Example: The value of a pound of Grouper sold commercially is easily quantified by the market price and normally around $10.00 a pound. The overall value of the same grouper captured by a recreational fishermen is harder to determine, but almost certainly higher when you consider their purchase of tackle, boats, gas, etc. That same grouper could easily be worth more than $500 a pound to the US Economy. The jobs that are generated and the families that are supported by recreational fishermen are very valuable to the economy.

    Subsistence fishing should be limited to that what a family can catch for their own needs. To the extent that good science dictates, families should be permitted to fish using recreational fishing methods for their food. This should be counted as a recreational fishery.

    Thank you very much for asking our opinions.
    Submitted July 28
  • The Atlantic menhaden stock has been overfished down to less than one percent of its unfished biomass. This fish is a critical part of our east coast food web. The food web has been ruptured and our fisheries on the east coast are dwindling due to loss of menhaden from Florida to the Gulf of Maine.  A new policy for NMFS....  Identify stocks that are critical food fish such as mackerel, the herrings and menhaden and insure these stock are protected and are maintained at 80% of it unfished biomass. Short of this, we are going to see more of the same failing fisheries. Also, depriving whales of their historic food source violates the Marine mammal Protection Act. What manner of biologists are you to sit around and watch these stocks being destroyed? Are you all asleep?  
    Submitted July 24
  • It seems you have left out Alaska, as the Public Town Hall in Alaska is scheduled in October, after the end of the comment period in September.  
    Submitted July 8

June 2014 Comments

  • I hear and read all these new themes, partnerships and etc. The biggest problem I see are the rules and regulations become very complicated as to seasons, bag limits and place to allow fishing. Example: The Florida Keys has state and federal regulations in one place area. Then add the national preservation areas. Everything becomes very confusing, and I have noticed that the enforcement hardly exists, furthermore the enforcement officers county, state and federal are not familiar with the rules and regulations. Only a few officers actually know the rules. I find it amazing a college degree is required for the job and hardly anyone studies, reads or keeps themselves updated on the ever changing information.

    My honest opinion is to come up with some basic rules and regulations concerning seasons and bag limits. Have officers in the field well aware of these rules and enforce the rules with strong penalties.

    Also Charter Fishing should be considered a commercial venture. These businesses should be filling out trip tickets. They are fishing for money and they are depleting a natural resource without any accountability. As for the catch and release guides they should also be handing in information concerning their catches and releases.

    We live in an information world. The more data we can acquire the better information we will have to improve our fish stocks. Face it almost everyone has a smartphone. Lets start collecting better data.
    Submitted June 30
  • Do your job! Protect our resources from selfishness in either the commercial or recreational side of the equation. Manage all of the programs, themes and whatever you would like to call it, but take a big picture approach and save the resource for our children and grandchildren! Don't make todays program tomorrow's regret.
    Submitted June 27
  • What formal mechanisms will be put in place to insure appropriate representation of user groups? How will recreational and commercial  fishermen and other groups participate in the policy development and implementation process?
    Submitted June 18