NOAA’s John Bullard to NEFMC on GOM Cod, GOM Haddock, SNE/MA Winter Flounder and Carryover Provisions

We are bound by what the law says, not what it does not say and§ 305(c) is clear on its face that interim rules are limited to no more than 366 days. It continues to be our position, therefore, that to be consistent with the plain meaning of relevant provisions in the MSA, and in light of the clear mandate of the MSA to end overfishing, a second year of interim measures in the case of GOM cod is not justified unless a change in circumstances has created a new emergency situation that would permit such action. At this time there are no new circumstances that would give rise to a new set of interim measures. Read the letter