MLA letter to Mike Pentony, NMFS

In late December, the MLA drafted a letter to National Marine Fisheries commenting on the herring specifications for 2019 and on the need for another herring assessment. Having received such a dramatic cut in quota, it is important that the allowances in area 1A match the recent catch ratios and also allow Maine fishermen access to local herring as opposed to paying extra for herring landed in say, Virginia and trucked to Maine. Below is the letter that was submitted.

To :Michael Pentony, Regional Administrator, Greater Atlantic Region Fisheries Office

National Marine Fisheries Service, 55 Great Republic Drive, Gloucester, MA  01930

December 31, 2018

Dear Mr. Pentony:

The Maine Lobstermen’s Association (MLA) is commenting in strong support of NMFS’ Proposed Rule (NOAA– NMFS–2018–0131) for an in-season adjustment to the Atlantic herring specifications for 2019 to prevent overfishing of the herring resource while minimizing negative social and economic impacts of reduced catch limits. However, with regard to area sub-allocations, the MLA recommends that NMFS use the percentages from 2018 to mirror proportion of landings by area in recent years rather than carrying forward the area sub-allocation scheme from the previous specification package.

The MLA is Maine’s oldest and largest fishing industry association dedicated to sustaining the lobster resource and the fishermen and communities that depend on it. Maine’s lobster industry has long been an integral part of Maine’s culture and economy supporting tens of thousands of jobs and hundreds of ancillary businesses. Atlantic herring is the most important bait fish for Maine’s lobster fishery which generated more than $433 million in ex-vessel revenue and was valued at nearly $2 billion in 2017. Maine lobster represents more than 80% of the value of Maine’s commercial fisheries. Successful management of Atlantic herring has been fundamental to the success of the Maine lobster industry.

In recent years, Maine lobstermen have struggled to cope with locating a predictable and affordable supply of bait. Since 2013, herring landings have decreased by nearly 50% and bait prices for Maine lobstermen have increased by as much as 75% in various harbors along the coast. The lobster industry has weathered this challenge as Maine’s bait dealers diversified the bait supply and added additional storage facilities. However, the resulting high cost of bait remains a huge issue of concern and threatens the economic viability of many of Maine’s lobstering businesses.

The MLA has been extremely disappointed with the New England Fishery Management Council’s vote for full adoption of Amendment 8 after the results of the Benchmark herring assessment were understood. While the MLA appreciates the significant amount of time and energy that went into developing the amendment, the fact remains that the Council did not analyze the significant negative economic impacts that Amendment 8 would have on the lobster fishery. All of its analyses assumed the new ABC control rule would be implemented during a time of high biomass. The wide-ranging negative impacts that will actually be experienced by Maine lobstermen are far more dire than anything contemplated under this management action.

The combined impacts of Amendment 8 and the latest Benchmark Herring Assessment create an extremely challenging situation for Maine’s lobster industry. The MLA weighed the options for herring specifications carefully since both the Council and NMFS proposed scenarios will create certain hardship and an acute shortage of fresh herring during peak lobster fishing season. Under the Council’s recommendation, the lobster industry must absorb a 70% reduction in herring in 2019 and an even larger 80% reduction the following year, compared to 2018. Under the NMFS proposal, the lobster industry must absorb 51% reduction in 2019 and a much larger 87% reduction in 2020 when compared to 2018. Maine’s lobster industry will need time to adjust to the magnitude of cuts in herring landings contemplated under these management scenarios.

The MLA supports the NMFS proposal because it gives the industry an extra year before deeper cuts in herring quota are realized. This will allow the industry time necessary to identify alternative sources of bait, coordinate bait distribution and grow infrastructure and storage capacity, thereby minimizing the economic impacts. The MLA also carefully weighed the impact of landing more herring in 2019 on the health of the herring stock. We find NMFS’ approach to be extremely conservative when compared to the management approach utilized in recent years.

The MLA remains concerned about the proposed recommendation for the area sub-allocations. An important strategy to minimize the economic impacts of the herring quota reductions on the lobster industry is to ensure that all of the available herring quota is landed and available for use by the lobster industry. The MLA urges NMFS to adopt the sub-ACLs put in place for the adjusted 2018 quota. This more closely reflects the proportion of herring landed by area in recent years, rather than simply carrying forward the percentages from the last specification package. Under MLA’s proposed recommendation, Area 1A would be allocated 55.6%, Area 1B 5.3%, Area 2 16.4%, and Area 3 22.7%. The Area 1A herring fishery directly supplies bait to the lobster fishery and matches herring landings with the lobster fishery’s time of peak demand. Having the greatest proportion of the 2019 quota landed from Area 1A would be one way to address some of the needs of the bait market and help lobstermen cope with the drastic quota reductions proposed for 2019.

Finally, the MLA strongly supports moving the herring assessment up a year to 2020 in the hopes that the many reports of juvenile herring observed by the commercial fishing fleets in inshore areas may be properly accounted for in the updated assessment.

In closing, any of the alternatives for herring specifications over the next three years will create hardship for the lobster industry. However, the MLA strongly supports NMFS’s proposal to provide more quota in 2019, with larger reductions in the following years to give the lobster industry time to respond to the full brunt of the quota cuts required by the new ABC control rule. The MLA strongly urges NMFS to reconsider the area sub-allocations and provide more herring quota to Area 1A to reflect recent proportions of landings and in doing so, ensure that all of the 2019 quota is landed and available as bait for the lobster industry.

Thank you for your consideration.

Sincerely,

Patrice McCarron, Executive Director

Senator Collins

Senator King

Representative Pingree

Representative Poliquin

Commissioner Patrick Keliher

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