The Fisheries Survival Fund has sent a letter to John Pappalardo, chairman of the New England Fisheries Management Council, outlining FSF's positions regarding the upcoming reconsideration of Scallop Framework 21.
The letter makes six major points:
1. The buffer between Acceptable Biological Catch ("ABC") and the target landings level is overly precautionary.
2. The scallop fishery was not subject to overfishing in 2009.
3 . The under-estimation of open area catch rates that led to F(target) being exceeded in 2008 and 2009 has been corrected.
4. The SSC's ABC of 65 million pounds conforms with the National Standard 1 Guidelines' advice for precautionary management; a target F of 0.24 for 2010 presents a virtually nonexistent chance of overfishing.
5. The virtually imperceptible economic advantages of the F=0.20 approach are highly uncertain and do not outweigh short-term economic impacts.
6. The differences in projected yellowtail flounder by-catch cannot justify the F=0.20 strategy.