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Maine Lobstermen’s Association
MLA urges NMFS to focus on development of a comprehensive, holistic approach to management. The goal should be to achieve effective protection for whales without inflicting unnecessary economic harm to individual businesses and communities. …
At a minimum, NMFS must make a preliminary assessment of the efficacy of the sinking line rule and other existing management rules in order to inform how to best approach vertical line risk management. Among other things, it is critical to understand whether the sinking line rule, or the recently implemented ship strike rule, have had any effect on potential biological removal (PBR), the level of serious injury and mortality (SI & M), or on the scarification rates of whales. Given the hardship experienced by the lobster industry under the sinking line rule, it is important to demonstrate that their efforts have actually contributed to protecting whales.
With respect to potential management measures, MLA preliminarily suggests the following:
1. Implement the most aggressive management measures in areas where data indicates whales and fishing gear are most likely to occur and risk is highest, such as in areas outside the 50-fathom curve or the 12-nautical mile line.
2. Do not implement additional measures in Maine state waters.
3. Allow for gear modifications to reduce risk of severe entanglement, such as modifying lobster gear by fishing a weaker rope on the top portion of the buoy line.
4. Allow for a second endline for trawls larger than five traps; two endlines must be allowed for trawls of six or more traps.
5. Allow a short amount of float rope off the lead trap for management scenarios requiring gear to be fished as trawls.
6. Explore options for both enhanced gear marking and reporting to improve the information available to guide the management process.
a. NMFS should consult with the disentanglement teams to determine which section of the vertical line is most likely to be documented, and add a second mark to this area. This could be done through high resolution photographs and/or gear retrieved from a whale.
b. NMFS must work closely with the disentanglement teams on techniques to carefully document the gear that the whale first encounters when it becomes entangled versus subsequent gear picked up after primary entanglement.
7. Remove the federal high flyer requirement for lobster gear fished outside of 12 miles in Area 1.
8. Eliminate the allowance of float rope at the surface between buoy and high flyer or between more than one buoy in the surface system.
9. Create incentives to minimize the amount of rope deployed throughout the gear system, to lighten the weight of gear and to reduce the breaking strength of rope, whenever possible.
10. Investigate the potential risk of trawling up gear by making the gear heavier, and strategies to make subcomponents of the gear safer if encountered.
Department of Marine Resources, Maine
DMR encourages and supports a method of regulating areas of risk, depending on the level of co-occurrence in different areas within the Gulf of Maine. DMR does not support any vertical line risk reduction measures being implemented in areas of low to no co-occurrence. These areas include most of state waters, with some exceptions in Lobster Management zones A and G, as well as some significant areas in federal waters off Zone D. DMR does not support seasonal or year round closures as a risk reduction strategy.
DMR supports an area based approach to reducing the risk of vertical lines to large whales in Maine. …During meetings across the State of Maine, DMR head broad support for a triples minimum in federal waters for most of the state, including all zones from 3-12 miles…. DMR does not support the use of only one vertical line on trawls greater than five. …
DMR heard broad support for changes to the gear marking strategy from industry members coast-wide. There was agreement within the industry to get at least a unique marking color for the State of Maine, separate from nearby critical habitats in Massachusetts and other areas. …
Another challenge that Maine faces is the diversity of our fishery. Trawling up thresholds, vessel size, safety and fishing efficiency must be considered. Management options must be operationally feasible and not impose an undue economic burden on fishermen.
Cape Cod Hook Fishermen’s Association
… it does not appear that the most recent data regarding the status of right, humpback and minke whale populations is being employed or is even being identified as a crucial data need. Furthermore, there has been no obvious effort to quantify the impact of several recent management actions in key commercial fisheries which, while not targeted at reducing whale interactions, have almost certainly resulted in fewer vertical lines in the water…
We and other industry groups are very concerned by the ongoing development of conservation measures intended to reduce the risk of serious injury and mortality of large whales due to entanglements without current and comprehensive information regarding the known impacts of this fishing gear on each whale population. …
As currently proceeding, this effort lacks appropriate and data-driven targets and risks unnecessary negative impacts to commercial fishing operations. …Because of these existing shortcomings, we strongly support the ‘status quo’ management alternative.
Georges Bank Fixed Gear Sector
The analysis provided in the document is based on severely outdated information. The “co-occurrence” model that is used to “predict” where fishing effort and whales overlap uses baseline data from 2008 in its analysis. A number of fisheries, namely the Northeast Multispecies Fishery, have undergone significant revisions since that time and are operating much differently today. It is outright false to assume that fishing effort in 2008 in any way attempts to represent fishing effort in 2011. …
Finally, as it is, there is no direct correlation that can be made between a reduction in vertical lines and the resulting reduction in whale entanglements. The National Marine Fisheries Service is “guessing” at what the results of this plan will be. …
Furthermore, any level of “serious injury and mortality” (SI&M) includes incidents from Canadian waters. Therefore, U.S. fishermen are paying the price for injuries that occur outside of our jurisdiction. … Knowingly making decisions using outdated information and guesswork is irresponsible and jeopardizes this plan and any fishery using vertical lines….
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