Maine Lobstermen’s Association letter to ASMFC reiterates its call to delay any gauge increase
Atlantic States Marine Fisheries Commission
Caitlin Starks
1050 N Highland St, Suite 200 A-N
Arlington, VA 22201
Transmitted Via email
June 3, 2024
Dear Ms. Starks:
The Maine Lobstermen’s Association (MLA) strongly supports the Atlantic States Marine Fisheries Commission’s (ASMFC) recommendation to NOAA Fisheries proposed in Addendum XXX “that as changes to the minimum gauge size in LCMA 1 are required by Addendum XXVII, the smallest minimum size for foreign imports would match the smallest minimum size in effect for the US industry.”
MLA has raised concern with ASMFC through previous comments and letters that the lack of clarity in Addendum XXVII regarding the import of undersize lobster from Canada smaller than the minimum possession size has created significant confusion and angst amongst Maine lobstermen who worry that the import these lobsters would have a significant negative impact on the U.S. boat price.
Maine lobstermen remain very concerned that Downeast lobstermen will be forced to throw back lobsters that could then be caught and landed by Canadian lobstermen fishing in shared waters only to be sold back to the U.S.
The MLA also reiterates its position that the need for Addendum XXX would be eliminated if ASMFC delayed the schedule of gauge increases for LMA 1. The MLA does not believe that a gauge increase is necessary at this time for several reasons which were described indetail in our April 2024 letter:
*The reference period of 2016-2018 and the percent trigger decline are overly precautionary.
*The three-year average for the trigger is too short to smooth out extremes coming off historic highs and unexpectedly triggered the schedule of gauge increases with the addition of only one year of data. The decline of 23% jumped to 39% decline compared to a 23% with the addition of 2022 data.
*Lobstermen continue to report observing high numbers of undersize lobster and eggers in their traps and survey data show the number of eggers and v-notch lobsters remain stable at historic highs.
*The ventless trap survey index has not exceeded the trigger index and the results of Maine’s 2023 lobster surveys show improvement.
*Lobstermen remain concerned that lobster surveys may be underestimating settlement and juvenile lobsters due to a shift in lobster distribution.
The MLA continues to urge ASMFC to delay increasing the LMA 1 gauge to allow the time necessary to address the concerns raised by the MLA and for ASMFC to work with Canada to resolve trade impacts if the U.S. minimum gauge is increased. If and when the scheduled gauge increases are required, the MLA supports ASMFC’s recommendation to NOAA described in Addendum XXX that lobster smaller than the minimum possession size in effect under the Commission’s FMP for American lobster continue to be illegal for import to the U.S.
Thank you for your consideration.
Patrice McCarron
Acting Chief Operating Officer
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