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Proposed Stellwagen Bank Ecological Research Area

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Dear Mr. Nies: Regarding the proposed habitat protection measures being considered by the New England Fishery Management Council(NEFMC), i strongly oppose any changes to the Western Gulf of Maine closed area and strongly support Alternative1, No Action. Any additional closed areas for the charter/ party and recreational anglers will create an adverse effect on a sector that is already operating under rules with strict bag limits, minimum size limits, a hard TAC and a five -and-a-half month closed season on GOM cod. The type of research that the Stellwagen Bank National Marine Sanctuary wishes to conduct in the proposed 55 square mile " reference area" is unnecessary. There has been plenty of research conducted all over the world on unfished populations and the resulting fish sizes and stock structure, so there is likely very little new we will learn by closing this area to recreational bottom fishing. Furthermore, this proposed closure does not justify the future socioeconomic impact on the recreational fishing sector. As a saltwater angler, I do not personally fish for profit, though my fishing participation supports many local businesses, from tackle shops and for hire captains to owners of restaurants and lodging facilities. If SERA II and the " reference area" is put into place, anglers will be forced to transit greater distances up to 40 NM to find a few cod and haddock for the dinner table. We are already fishing 28 NM from port, which has severely restricted our angling opportunities....this latest proposal will have a devastating impact on our recreational community. I would also point out that since share catch management was implemented, a concentration of large draggers fishing 24/7 on the bank in the winter and spring has forced the charter/party and recreational anglers to fish east of Stellwagen Bank in order to locate cod and haddock. A simple analysis of the past two years of vessel trip reporting data would clearly indicate this change in fishing location, much of which is now taking place in the proposed" reference area". Our recreational sector always seems to be left out of focus when it comes to spotlighting NEFMC issues and initiatives; in reality, the socioeconomic importance of recreational fishing cannot be ignored in this critically important vote. I strongly support ALTERNATIVE 1, NO ACTION and ask that the NEFMC recognize the significance of our recreational fishing industry in supporting this winnable solution.

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