Public comments for Draft Addendum XI to the
Summer Flounder, Scup and Black Sea Bass Fishery Management Plan.

The New York Fishing Tackle Trade Association(NYFTTA) represents over 300 member businesses in the New York Marine district. The livelihood of our members depends upon healthy stocks of many species of fish.

Our mission is not only to promote the sport of fishing, but also to do our part in preserving the resources for the future.

The members of the New York recreational fishing community are very concerned about the 2003 MRFSS Scup landings. The MRFSS data indicates an enormous increase in landings over 2002.  We do not believe that the figures are accurate, especially in light of the poor performance of the industry and the poor weather conditions in 2002.

Overall, NYFTTA member Bait and Tackle shops report average decreases of 25% in 2003. In addition, total precipitation was 17 in 2001, 22 in 2002 and 28 in
2003. A 21% increase.

With so many reports that 2003 was a poor season overall, the industry does not feel confident that the 2003 MRFSS landings data is accurate. The monitoring committee also felt that the MRFFS landings were speculative which is why they presented adjusted figures for New York back in December 2003. NYFTTA supports using these adjusted figures for the 2003 NY Scup landings.

Issue1: Regional or State Specific Management

NYFTTA supports Strategy 1: The regional management approach.

NYFTTA has been in support of this approach in the past for Summer Flounder and continues to be supportive of this approach for Scup. In the case of scup, from MA to NY, we are dealing with a species that is exploding in population and the bulk of the landings for the coast are throughout this region from the spring through the fall.  The region shares many bodies of water and anglers travel throughout this area to harvest scup.  We have always felt that there is no common sense when states have major opposing seasons, sizes or possession limits when they overlap the same body of water: such as LI Sound for NY and CT and the Block Island area for NY, CT and RI. This only causes anglers to travel to the least restrictive area  providing major inequities to each states industry and having a negative impact on the fishery.

In an effort to begin the process towards this regional management technique, we believe that it would be most effective to allow the states to initially set there own size, possession and seasons. However, we would recommend for 2004 that none of the states be permitted to go below a 10 fish or above a 50 fish bag limit in any mode.

With respect to 2004, NYFTTA supports using the Regional approach with the New York adjusted figures as outlined in Table 1 of Addendum XI.  This approach
resulted in a 31.6% reduction for each state in the region.

If this Regional approach using NY adjusted figures is not approves by the board, NYFTTA supports Strategy 4:State allocation using alternate base years. However, we have enclosed an alternate table, which is not included in the Addendum. Under our option outlined in Table 10, Scup allocation would be based on 1998-2003 landings with unadjusted New York landings.

In this approach, the percent decrease required for NY in 2004 would be 27.97%.

Strategy 4  New Option  Table 10
TABLE 10 - Scup Allocation based on 1998-2003 landings in number of fish Using NY 2003 Un-adjusted landings


       TTL Landings    %       2004    Projected       Percent
       1998-2003       Share   Allocation      2003 Landing    Decrease
CT      5,243,991.00    14.83%  622,890 1,464,991.00    42.52%
MA      6,224,896.00    35.21%  1,478,808       1,636,197.00     90.38%
NY      12,637,098.00   35.74%  1,501,057       5,367,275.00    27.97%
RI      5,028,085.00    14.22%  597,245 1,102,237.00    54.18%
               100.00% 4,200,000


Issue 2: Mode Specific Management  NYFTTA has no comment on this issue at this time.

Issue 3:  Management Process establishing conservation equivalency

NYFTTA supports option 2: Initiation of Conservation Equivalency through Management Board Action.

The trend over the last several years has been that coast wide measures are not appropriate.  Different areas  north and south  have different needs. The current process, which has gone through the burden of adopting annual conservation equivalency measures, has only resulted in bogging down the process.  It wastes time that the Board could be using to focus on other areas.  NYFTTA supports streamlining this process by giving the board the authority to adopted conservation equivalency in the same manner currently in place for Summer Flounder.  However, we do suggest that both state-by-state and regional measures be included as management tools.

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