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Write Public Comment to The Ma. DMF by 03/05/21

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jason colby

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Among the most outrageous moves the DMF can make!
First, they recognize there is an issue with ripping apart the fish when they move inshore and congregate to spawn and then they CONSTANTLY ignore their own findings and allow the decimation to continue.
I was under the impression that things would get better (I was assured by someone on this email) with the change from Pierce to McKiernan. I know this is not a "done deal" as of yet but looking at the past, 100% of the time this has come up for public comment the comments were overwhelmingly against the proposal and yet The DMF lifted the closure anyway. THIS CLOSURE "SHOULD" encompass ALL STATE WATERS and "SHOULD BE" for March and April.
Mr. McKiernan, consider this my "public comment" opposing the lifting of the closure and please show me you are different.
Thank you!
Captain Jason Colby
Little Sister Charters

From: marine.fish@public.govdelivery.com
To: fishinglsister@aol.com
Sent: 2/19/2021 5:55:37 AM Pacific Standard Time
Subject: Public Comment Sought on Proposed Action to Temporarily Lift the State-Waters Groundfish Closure for April 2021

Public Comment Sought on Proposed Action to Temporarily Lift the State-Waters Groundfish Closure for April 2021

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DMF Advisory #2 v3

February 19, 2021

Public Comment Sought on Proposed Action to Temporarily Lift the State-Waters Groundfish Closure for April 2021

DMF is seeking public comment on lifting the conditional April groundfish closure for 2021. This annual closure was developed in 2019 to address allocative concerns that landings from the state waters-only groundfish fishery may impact access to federal groundfish quotas. By regulation, those state waters between 42°00’N (Plymouth) and 42°30’N (Marblehead) west of 70°30’ W are closed to commercial groundfish fishing in April. However, the closure may be lifted on an annual basis if DMF projects the action will not result in an exceedance of the annual federally allocated state-waters subcomponent for regulated groundfish stocks or will not compromise federal conservation objectives.

DMF has analyzed landings data for the current fishing year (May 1 – April 30) and intends to  lift the conditional April groundfish closure this year. Landings for the current fishing year are well below the federally allocated sub-components, likely driven by COVID related impacts on fishery effort last spring and summer. Accordingly, it is unlikely that an April opening will result in an exceedance of the state waters sub-components or of overall annual catch limits. Further information on this analysis may be found in DMF’s February 12, 2021 memorandum to the Marine Fisheries Advisory Commission.

DMF will accept written public comment on this proposal through 5PM on Friday, March 5, 2021. Written comment may be submitted to by e-mail to marine.fish@mass.gov or by post sent to 251 Causeway Street, Suite 400, Boston, MA 02114. The Marine Fisheries Advisory Commission will consider adopting this action at their March 18, 2021 business meeting.  

For more information regarding the management of marine fisheries in the Commonwealth please visit our website: www.mass.gov/marinefisheries


groundfish closure
Massachusetts State Seal

Massachusetts Division of Marine Fisheries

251 Causeway Street, Suite 400, Boston, MA 02114

(617) 626-1520  |  Contact Us  |  Find a Location

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2 mins ago, ermghoti said:

Which species are affected? Are there links to cite that these species are congregating to spawn?

Well first of all, GOM cod should not be targeted at all (but I digress), that leaves haddock and flounder.  The haddock fishing is good everywhere so there is no need to fish inshore and the intent of the closures is to protect breeding cod and as a benefit to that, flounder get protected as well. Having cut flatfish professionally for over 25 years, I can tell you without a doubt that winter flounder in Massachusetts State waters are spawning in March and April.

Not only are they packed full of roe but they are amassing in specific areas that the draggers know all too well. Further, they are harvesting a very significant percentage of the biomass of breeding flounder that eventually make their way into Boston Harbor and the surrounding bays and estuaries to feed by late April/early May.  

For the years leading up to the cod collapse that was declared at the end of the 2012 season, the flounder fishing in Boston Harbor and the surrounding area was getting better and better each and every year. Also, the fish were getting bigger and bigger because they were not getting pounded by commercial over exploitation while the draggers were busy decimating the cod. At the end of 2012, the commercial fisheries in and around state and federal waters of The GOM cut commercial cod by 77%.

What they did after that was what brought us to where we are today with 90% LESS FLOUNDER than 2012. They doubled the daily flounder quota for Ma. State Waters and cranked up the federal annual TAC's for The GOM to over triple what they were prior. 

To put it in "plain and simple terms": The recreational harvest was not impeding the population of flounder from growing AND the increased commercial pressure had a very rapid effect on the flounder population. WINTER FLOUNDER NEED SOME PROTECTION FROM DRAGGERS and when they are spawning is a excellent time to give them that protection.

An argument that a (pro commercial) fishery  biologist gave me once was that "a dead fish is a dead fish no matter what time of year you kill it". I BEG TO DIFFER! You don't burn your field just as your crop is ready to harvest. 

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  • 2 weeks later...

I'm a bit disheartened at how few said they sent in their comments. We (rec fishermen) have so little say in management that we should jump at the chance when one is presented to us. I assure you that the other major allocation group (the commercial sector) has large lobby power in every aspect of the process and they are well represented by our government. It is not a fair comparison when you measure how few rec voices are heard.

When (not if) the Mass DMF says they are going to lift the April closure and they publish the public comments, you will plainly see (I'm going by history here) that the comments to not lift the closure far outweigh the ones, if any, that support the lift. So the question begs to be asked: "Why have a public comment if they are not going to consider what is said anyway"?

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You can still send your comments.  The rules just state that DMF does not have to consider comments sent after the deadline.


Additionally, one could argue that such a change requires a public hearing and that, without one, the DMF's decision is invalid.  


I would encourage people to provide comments this summer if they notice the fishery has declined.   

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