Dear Mr. Rootes-Murdy

     In regards to the proposed  reductions for summer flounder for 2017, the New York Sportfishing Federation is in favor of “status quo” for the upcoming season.  We support this option until a new, updated benchmark stock assessment for summer flounder is completed with justifiable data.  The fishing community has asked NMFS to conduct a new benchmark assessment for summer flounder to avoid unwarranted, drastic reductions in allocation resulting from the current flawed data.  This was supposed to be completed but the request simply was ignored.

     We strongly believe that the data collected on the trawl surveys that were done by NMFS on their vessel “Bigelow” are grossly inaccurate.  Their trawl survey vessel is improperly equipped and their gear type and methods for harvesting summer flounder are inadequate, thus rendering this data useless for management purposes.

     Also, our confidence in the accuracy of the MRIP data collection program, which is still in its infancy, is low at best.  Recent MRIP data on summer flounder show high variability between the measure and the performance numbers. Which respectively, are calculated and estimated, therefore rendering MRIP data inconclusive and non-credible.  Implementing such unreliable data into a management model would be futile and cause the conclusions to be erroneous.

     The New York Sportfishing Federation recommends that a new model, such as the Summer Flounder Sex-Specific Population Model, developed by Dr. Sullivan from Cornell University, be adopted incorporating the data collected from a new benchmark assessment.

     Until such time whereas these recommended approaches can be completed and implemented, we support an option of “status quo” for summer flounder.  We are supporting Senator Schumer’s  decision to instruct the Secretary of Commerce to force NMFS and ASMFC to postpone implementing any reductions in summer flounder allocations until a new, proper benchmark assessment is completed in order to avoid the certain economic hardships that the fishing community will incur.  Thank you.
Sincerely,

Capt. Joe Paradiso

President-NYSF

 NY Marine Resource Advisory Council