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Paul Haertel, president of the Jersey Coast Anglers Association, sent the following comments on proposed ASAMFC Summer Flounder Fisheries Management Plan FMP Coordinator Kirby Rootes-Murdy. January 19th, 2015 Mr. Kirby Rootes-MurdyFMP CoordinatorAtlantic States Marine Fisheries Commission1050 North Highland St.Suite 200 A-NArlington, VA 22201 Kirby, For many years fluke were managed by state-by-state measures with conservation equivalency. Each state was given its own quota while being allowed to set their own regulations. In 2013 we still had state-by-state quotas but additionally, the ASMFC allowed the projected coastwide underage of fluke to be utilized. Ultimately New Jersey and New York shared this quota. It worked out well in that New Jersey was able to add additional days to its season while New York was able to reduce its size limit. However, in 2014 regionalization was forced upon us against the will of the vast majority of our fishermen, fishing groups and those who represented NJ on the commission. New Jersey's anglers wanted to stay with state-by-state measures or be made its own region. However, despite that the ASMFC, via a conference call, made exceptions for Massachusetts and Rhode Island allowing them to be their own regions even though that option was not in the addendum. Why were they allowed to do that when NJ was not? New Jersey was forced into a region with Connecticut and New York. In part this was done because the fluke biomass has shifted further northward. However, even with New York's size limit being reduced to 18" from 19" while New Jersey's was increased from 17 1/2" to 18", New Jersey still caught far more fluke than New York. New Jersey has the most fluke, the most fluke fishermen and the highest percentage of fluke trips to overall fishing trips and yet regulations were adjusted so that New Jersey's projected harvest was lower than some of its past quotas. It certainly seems that NJ should be allowed to be its own region. Another reason NJ was forced into regionalization was due to a disparity in the regulations in the Raritan Bay area where the commission deemed it was unfair for NJ anglers to have a 2" lower size limit than anglers from NY who were fishing in essentially the same waters. However, instead of correcting the problem all the commission did was to transfer the problem to Delaware Bay. In 2014 NJ anglers had to abide by an 18" size limit while DE anglers fishing the bay were allowed to keep fluke that were just 16". This was unfair to the anglers of southern NJ and many of our fishing businesses there lost revenue as people opted to fish out of DE instead. While you can say that with regionalization in 2014, we had a projected harvest for each state as opposed to quotas or target quotas, it certainly appears to be a reallocation of quota. It seems that a portion of New Jersey's quota was reallocated to New York. Additionally though, fish from other states were also reallocated to our region. The projected harvest was substantially increased for Connecticut and New York while at the same time New Jersey's projected harvest was decreased. Then low and behold the MRIP numbers came out and showed that New Jersey over fished its projected harvest but since Connecticut and New York under fished theirs, our region is Ok. The data also showed that the coastwide quota was slightly exceeded but that may be neutralized by a slight coastwide quota increase for 2015. Now, it appears that NJ is being forced to stay in the regionalization plan or face significant cuts under state-by-state measures. Still, it initially seemed that even with regionalization, NJ would come out of this OK as our region underfished its projected harvest. One would think that therefore, we would at least have very similar regulations to what we had in 2014. However, there are several options that would change the structure of the regions and rumor has it that New York is pushing for a 18.5" size limit so that our region's season could be extended to 153 days, 25 days more than last year. An increase of the size limit to more than 18" will not be tolerated by the vast majority of anglers in NJ. In fact the majority of anglers in NJ may prefer returning to a 17 ½" size limit. JCAA is on record as favoring state-by state measures with conservation equivalency. However, for 2015 we will only favor that option if it can be done without forcing us to have significantly stricter regulations. More specifically, we do not want a higher size limit, smaller bag limit or shorter season than we had in 2014. Therefore of the various regionalization plans, we favor Option 5A. It is the fairest option not only to NJ but to other states as well. This option would have Delaware Bay as its own region and it could act as a transitional area between regions to the north and south of it. Perhaps Delaware Bay could have a 17" size limit while the region to its south could have a 16" size limit and the region to the north of it could have an 18" size limit. A 1" difference between any regions is far more acceptable than a 2" difference. Having a neighboring region with any more than a 1" less restrictive size limit is totally unacceptable. Further having Delaware Bay as its own region should have minimal impact on the other regions. For example, if the option to split NJ in half were chosen, there would likely again be a 2" gap between the regions. This would pit northern NJ anglers against those in southern NJ. Northern NJ as well as other states within that region would then likely have to sacrifice fish to accommodate southern NJ. In closing we would like to urge the ASMFC to thoroughly review the pros and cons of each option and be as fair as possible to all the states. Lastly, we would like to thank you for allowing us to comment on this matter. There are some controversial decisions to be made on the plan. Those who agree with the JCAA letter can forward it to krootes-murdy@asmfc.org  -- or send their own comments. This must be done quickly -- by 5 p.m. Jan. 23.

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