The Coastal Conservation Association (CCA) is a marine fishery conservation organization. With chapters spanning from Maine to Texas, CCA has more than 7 5,000 direct members dedicated to the conservation and enhancement of marine fishery resources.

Summer flounder are one of the most sought after fish on the Atlantic Coast, both commercially and recreationally. As the population of summer flounder recovered, anglers responded in what we know now to be an entirely predictable response - increasing their effort nearly exponentially. A stock has to have a relatively high biomass to be successfully exploited by recreational fishermen. But, once biomass reaches a high enough level, recreational catches soar.

Anglers have accepted their fair share of the burden in making this recovery a reality, taking real reductions in bag and season limits promulgated under an unfair allocation scheme. Anglers stayed within their total allowable landings (TAL) until 1996. A s the stock grew in range and abundance, overages began to occur in succeeding years. C oastwide management measures proved inadequate to properly manage the recreational summer flounder fishery, and demonstrated the need for a management plan that took the nature of local fisheries into account.

CCA fully understands the principles of stock recovery and are aware the danger continued overages place on the summer flounder stock. To bring the recreational harvest back to acceptable levels in 2001, w e support the management measures , outlined below .

In doing so, we note that s ome have questioned the reliability of the data generated from the Marine Recreational Fishing Statistics Survey (MRFSS). While we acknowledge that MRFSS was never intended to be used for quota management, we also recognize that it provides the best available information. We thus agree we must be guided by it today, but we also maintain that it is necessary to find ways to make MRFSS a better measure of recreational catch and effort in the future.  

CCA supports the following summer flounder measures: 

1.  Implement an equitable management structure.

We believe coastwide management measures are inherently unfair, due to their unacceptable, disparate impact on the several states participating in the recreational summer flounder fishery. Thus, we do not support using a single coastwide management measure. We support using the 1998 landings by state to determine the reductions necessary for each state to achieve the 2001 harvest limit. This is only fair to those states that have already implemented effective management measures. 

2.  Make the concept of conservation equivalency a part of the plan.

We support the continued use of conservation equivalency to allow states flexibility to set their own harvest reduction strategies. We urge the Mid-Atlantic Fisheries Management Council (the Council) to put Framework 2 into place as soon as possible so conservation equivalence will be readily available to the states.

3.  Implement similar regulations in state and federal waters.

We are concerned there may be widely differing regulations in the exclusive economic zone and state waters due to the different TAL adopted by the Council and the Atlantic States Marine Fisheries Commission (the Commission). We ask the Council and Commission to work together to develop similar management measures so that summer flounder regulations can be effective and enforceable. If the regulations are significantly different, they cannot be effectively enforced and the summer flounder resource will suffer.

4.  Improve the data collection system.

Many states on the Atlantic Coast conduct the bare minimum number of interviews and intercepts required for the coastwide MRFSS data collection system. The resulting date is inadequate for regional or state-by-state management measures. While the proportional standard error of the estimates are within acceptable limits (most less than 10%), more coverage, intercepts and interviews would provide fishery managers with better data, and enable them to better regulate the fishery. We ask the National Marine Fisheries Service (NMFS) to determine the sampling levels required for more accurate data collections within the states. We would gladly help NMFS pursue federal funding for these surveys if necessary.  

5.  Divide the TAL equally between the commercial and recreational sectors.

We believe the allocation of this important resource is incorrect. While the estimate of the recreational harvest before 1981 is not reliable, all evidence suggests that it was substantial and, at least, equal to the commercial harvest. The time period used to calculate the current allocation was a period when commercial landings were at an all time high and recreational landings were declining. That time period does not reflect the historical relationship between the fisheries that, despite all regulations, is inevitably reasserting itself today. While we understand this issue is not under consideration at this meeting, we respectfully request that the Council consider changing the allocation to a more equitable 50:50. Such a change would help ease the landings problem and maximize the economic return to the states. If changes were made and the flounder population (and thus the TAL) continued to expand, the actual poundage landed by the commercial fishery would not change significantly. Further, if the allocation was revised, we would support a limited entry system in the summer flounder fishery to protect the fishermen already participating.

In closing, CCA supports management measures that will ensure the continued recovery of this important stock. We believe the Council and Commission must find a fair and enforceable regulatory mechanism that will keep the recreational fishery within its total allowable landings. Recreational fishermen have been and must continue to be willing to do their part for summer flounder conservation. At the same time, they must not be asked to pay a disproportionate cost for the species’ recovery.