RFA NC Ltr - SaltwaterCentral.Com

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CoastalCarolina
Posts: 2352
Location: Ocean Isle Beach
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Fri May 15, 2015 3:37 pm
The RFA NC sent a letter to NCMFC on the flounder situation. Hopefully, a member can put it online here in larger type than available on their Facebook page. Every rec needs to read it and support RFA. RFA NC deserves are thanks. They, along with CCANC and NCWF have sent powerful messages to NCMFC. RFA has stated the need for transparent public comment to MFC and our comments are important. All than can make it to the meeting in New bern should attend and anyone desiring a ride from the Shallotte area can contact me.  
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markc
Posts: 211
Location: Wilmington, NC
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Mon May 18, 2015 9:36 pm
sorry, been offshore the past few days and haven't been on FPT Here it is pasted as text, the tables don't show up very well this way, but you should be able to read the letter here.




Sammy Corbett, Chair
North Carolina Division of Marine Fisheries
3441 Arendell Street
Morehead City, NC 28557
RE: Southern Flounder Draft Supplemental Comments
Dear Chairman Corbett:
Please accept the following comments on behalf of the North Carolina Chapter of the Recreational Fishing Alliance (RFA-NC) in regards to pending action for the Southern Flounder fishery. The comments were developed with input gathered from members of RFA-NC who include private anglers, for-hire owners/operators, scientists and others closely involved with the fishery. In addition, the comments were prepared after careful and thorough review of the support materials provided by North Carolina Division of Marine Fisheries (NCDMF) in regards to southern flounder. Our comments reflect the chapter’s desire to see the southern flounder fishery managed in a responsible manner that also provides reasonable and equitable opportunities for the recreational fishing community to access this important fishery.
Please reference the document entitled “Draft Supplement A to Amendment 1 of the N.C. Southern Flounder Fishery Management Plan, Implement Short-Term Measures to Address Stock Concerns” dated May 4, 2015. The purpose of the referenced document is to present short term management options to remedy our depleted southern flounder stock. The N.C. Marine Fisheries Commission (MFC) will decide at its May meeting to reject the draft supplement, approve the draft supplement as presented for public comment, or modify the draft supplement and approved the modified version for public comment (p.2).
Based on the referenced supplement (p. 4) the NCDMF determined the southern flounder stock assessment could not be used to define the stock status due to mixing of the stock on a regional scale. Due to concerns of southern flounder stock status, the MFC at its February 2015 meeting decided to pursue a supplement to reduce catch of southern flounder by no less than 25% and no greater than 60%.
RFA-NC agrees with the division’s decision regarding the draft 2015 southern flounder stock assessment. However, it is recommended that the division pursue development of a valid stock assessment to determine if the stock is overfished or overfishing is occurring. The referenced supplement states that the NCDMF cannot quantify levels of sustainable harvest without a valid stock assessment; however, certain patterns in the southern flounder fishery and population are concerning and may warrant further management action (p.4). The RFA-NC concurs and requests that immediate action be taken. The supplement further states that the 2014 Southern Flounder Stock Assessment was not accepted for management use by the NCDMF due to legitimate and substantial concerns raised by three external peer reviewers, selected by the NCDMF. The RFA-NC requests that the 2014 draft stock assessment undergo additional peer review by reviewers selected by the NCDMF in collaboration with the RFA-NC and other stakeholders.

In addition, the RFA-NC requests that the MFC take immediate action to prevent further depletion of the southern flounder stock. Thus, the RFA-NC recommends that the MFC approve to modify the draft supplement and approve the modified version for public comment. The importance of allowing a public process to move forward cannot be over emphasized. Further, consideration of all public comment by the MFC for its August 19-21 meeting is extremely important in this case. Public comments would greatly assist the MFC in its selection of the preferred management option and final approval of the supplement. The RFA-NC overwhelmingly supports a public transparent process whereby the public is provided an opportunity to comment on a modified draft supplement. Our recommendations on this document are provided below. Please note that many recreational fisherman and RFA members work during the day or live far from New Bern and will not be able to attend the MFC May meeting. Thus, providing those fishermen an opportunity to comment on southern flounder, including our recommended options, is even more important.
The RFA-NC also concurs with resolutions to support the NC DMF use of the supplement process to implement reduction of southern flounder harvest recently adopted by Alamance County, Lenoir County, Town of Wallace, and Wayne County (see Directors report).
Since approximately 1989, the recreational sector has been subject to increased restrictions on southern flounder that have included increased minimum size limits and decreased bag limits. The recreational sector has endured six size limit increases from 13” in 1989 to the current 15” and two bag limit decreases from unlimited to the current bag limit of 6 fish per person/day (p.47). The commercial sector has and is allowed to catch an unlimited amount (i.e. no quota or Total Allowable Catch (TAC)) of flounder 11 months a year with a minimum size limit of 14” (p.48-51). Based on Table 1 (p.9) and Table 2 (p.11), the total recreational and commercial catch for 2011-2013 was 2,148,822 lbs as shown in Table 1 below. Of this total, the recreational industry caught 21.4% (459,177 lbs of the total 2,148,822 lbs) and the commercial industry caught 78.6% (1,689,645 lbs of the total 2,148,822lbs). The inequity in flounder harvest between recreational and commercial fishing is astounding. Further reductions to the recreational flounder catch would not be equitable, reasonable, or fair. The RFA-NC firmly believes that flounder reduction must be taken from the 79% side of the equation.
Table 1. Total landings (lbs) 2011-2013*
Sector
Landings (lbs)
Reference
Percent of Total Commercial 1,689,645 Table 2, p.11 78.6
Recreational
459,177
Table 1, p.9
21.4 Total 2,148,822 100
*based on Table 1(p.9) and Table 2 (p.11) of draft supplement.
The referenced supplement provides five management options for MFC consideration which would be made available for public comment (p.1). These include:
1. Implement a season closure;
2. Increase the minimum size limit;
3. Decrease the recreational bag limit;
4. Implement a season closure and also increase the minimum size limit;
5. Implement a season closure, increase the minimum size limit, and decrease the recreational bag limit.

Our comments on each of these options, as presented in the referenced document, are as follows:
1. Season Closure (p.17). This option considers season closures of both commercial and recreational fisheries. NCDMF tagging data clearly indicate that southern flounder begin spawning migration to ocean waters in fall months. This time period is critical for spawning flounder. Should this option be selected, the RFA-NC recommends a commercial seasonal closure from October 1-December 31 resulting in an estimated reduction of 50% (see Table 4, p.19) which would reduce the minimum catch reduction as requested by the MFC. If option 1 is approved, RFA-NC suggests the development of effort controls to prevent a reattribution of commercial effort to which could potential negate or reduce the estimated 50% reduction. The RFA-NC strongly opposes any recreational closure from May through November in any year since it would adversely affect the ability of the for-hire industry to work within the tourism season and allow recreational fisherman to enjoy the fall fishing season.
2. Minimum Size Increase (p.23). Increasing the minimum size limit is a management tool that has always been used by the NCDMF to help end overfishing. Data provided in the referenced document and other NCDMF documents clearly indicate this management measure applied to the recreational industry is not successful (Table A1.1, p.47). However, the referenced document (p. 26 and Table 11) states that “increasing the minimum size limit to 16” would reduce commercial catch by an estimated 32% which would reduce the minimum catch reduction as requested by the MFC (p.28). The RFA-NC therefore recommends that the commercial minimum size limit be increased to 16”. The recreational minimum size limit must remain at 15”.
3. Decrease the recreational bag limit (p.31). According to the referenced document the hook and line recreational fishery contributed the most to reductions from recreational bag limit decreases because of the greater harvest from this gear. Based on estimated catch reductions shown in Table 17 (p.32), the reduction from decreasing to a one-fish recreational bag limit is less than 23% and does not meet the minimum catch reduction requested by the MFC. Therefore, the RFA-NC does not support this option. Moreover, we feel that increasing the recreational bag limit to 8 fish per person/day would not adversely impact the southern flounder stock.
4. Season closure and increase the minimum size limit (p.32). This option proposes to combine a season closure with a minimum size limit increase. For reasons described above, the RFA-NC supports a commercial fishing season closure from November 16-December 31and increasing the commercial minimum size limit to 16” resulting in a commercial reduction by 36% to meet the minimum catch reduction as requested by the MFC (Table 18, p.33). Consistent with RFA-NC’s comment in regards to Option 1, effort controls should be developed to prevent redistribution of commercial effort in response to a seasonal closure. As stated above, we cannot support any recreational closure or recreational minimum size limit reduction. This is the preferred option of the RFA-NC.
5. Season closure, increase the minimum size limit, and decrease the recreational bag limit (p.37). As stated above, the recreational industry has taken the biggest reduction in southern flounder since 1989. The RFA-NC cannot support any further reductions in bag limits in order to allow the commercial industry to harvest more southern flounder. We request that this option be eliminated from further consideration.
The RFA-NC recommends the MFC approve the draft supplement with modifications that would help prevent further depletion of the stock in a fair and equitable manner. It is highly recommended that the MFC approve a modified supplement that allows public comment on the

options below. As stated above, public comment on all options would greatly help the MFC with its selection of a preferred southern flounder management option.
1. Total closure of commercial gill nets (used for southern flounder). According to the referenced document, page 10, gill nets are used in most estuarine waters where regulations allow. Based on Table 2 (p.11) and Table 1 (p.9), Gill nets accounted for roughly 55.2% (932,792 lbs/1,689,6451lbs) of the commercial harvest and 43.4% (932,792/2,148,822) of the total recreational and commercial fishery harvest. This single option would fully meet the catch reduction as requested by the MFC. The RFA-NC recommends this option be given serious consideration in the modified supplement.
2. Prohibition of the issuance of future pound net permits. This motion failed to be approved at the February 2015 MFC meeting. Since that time, there have been numerous pound net permit applications submitted, as expected. Therefore, the RFA-NC recommends that issuance of new pound permits be immediately prohibited until southern flounder management decisions based on a new flounder stock assessment can be made.
3. A quota based fishery management option must be implemented for southern flounder similar to that used for summer flounder. Several issues regarding equal opportunity to land summer flounder and dealer reporting frequencies need to be resolved. The RFA-NC recommends the NCDMF pursue commercial and recreational quotas for southern flounder using a public process that includes an advisory panel. In the absence of the valid stock assessment and amended FMP, it is recommended the NCDMF immediately implement a total cap for commercial fishing of southern flounder. It is recommended that a commercial flounder harvest cap of 40% of the 2011-2013 commercial landings (see Table 2, p.11) be used until a science based commercial and recreational quota can be determined. The recommended cap on commercial landings that the NCDMF should consider are as follows:
Table 2. Proposed caps on commercial landings for southern flounder (40% reduction).*
Gear
2011-2013 landings (lbs)*
Proposed Landings Cap (lbs) Gill Net 932,792 559,675
Pound Net
614,899
368,939 Gig 127,413 76,454
*based on Table 2, p.11 of draft supplement.
4. A valid southern flounder assessment is essential to ensuring sustainable southern flounder stocks. The RFA-NC requests that the 2014 stock assessment undergo additional peer review by reviewers selected by the NCDMF in collaboration with the RFA-NC and other stakeholders.
5. Recreational Commercial Gear Licenses (RCGL) holders are allowed to use limited amounts of commercial gears such as gill nets, trawls, pots and seines. The RFA-NC recommends a moratorium on all gear permitted by RCGL’s.
6. Develop and implement species specific reporting for all commercial fisherman and dealers in the southern flounder and summer flounder fisheries. RFA-NC suggest that this program should be implemented over 2 fishing seasons with NCDMF providing mandatory workshops on proper species identification. A forthcoming southern flounder stock assessment will require highquality fisheries dependent information to properly assess the stock. NCMFC should move away from using the location of commercial fishing activity as the determining factor for flounder species identification and instead rely on using accepted identifying features to distinguish between the two species.
5
RECREATIONAL FISHING ALLIANCE
PO Box 98263 Washington, DC 20090
888 JOINRFA, www.joinrfa.org
Thank you for reading our comments. To iterate, the RFA-NC recommends that the MFC approve to modify the draft supplement and approve the modified version for public comment. The RFA-NC overwhelmingly supports a public process whereby the public is provided an opportunity to comment on a modified draft supplement for southern flounder.
Sincerely,
Capt. Robert Schoonmaker
RFA-NC Chairman
cc: Ms. Anna Beckwith, MFC
Mr. Mikey Daniels, MFC
Mr. Kelly Darden, MFC
Mr. Mark Gorges, MFC
Mr. Chuck Laughridge, MFC
Mr. Joe Shute, MFC
Mr. Mike Wicker, MFC
Ms. Alison Willis, MFC
Mr. Donald van der Vaart, NC DENR
  
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bill62
Posts: 85
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Wed May 20, 2015 3:14 pm
thanks to the members who drafted the response.  
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RFA NC Ltr - SaltwaterCentral.Com