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DEVELOPMENT AND EVOLUTION OF THE SEA SCALLOP

FISHERY MANAGEMENT PLAN

'VBWMEMr D0CUMEN1
COUECTiON

JM 4- 1924

University of Massachusetts
Oepositoiy Copy

by

David E. Pierce

Massachusetts Division of Marine Fisheries

100 Cambridge St.
Boston, MA 02202

Funded by the New England Fishery Management Council

Publication #: 13^32-75-50-5-83- C.R.

Approved by John J. Manton, state Purchasing Agent

S3 J> /% t

Digitized by the Internet Archive

in 2012 with funding from

Boston Library Consortium Member Libraries

http://archive.org/details/developmentevolOOpier

Draft Preliminary Management Plan

In December 1976 a Draft Environmental Impact Statement/
Fishery Management Plan (DEIS/FMP) , prepared by the Regional
Office and the Northeast Fisheries Center of the National
Marine Fisheries Service (NMFS) , was published for the
Atlantic Sea Scallop. As stated in the Draft,

"The purpose of the Management Plan is to manage
the sea scallop fishery off the coast of the U.S.
for optimum sustainable yield and to allocate
harvest between domestic and foreign fishermen.
The plan recommends that there be no decision on
the total allowable level of foreign (Canadian)
fishing until a U.S. -Canadian agreement is consum-
mated, and that this agreement, and the unique
joint concern for the Atlantic sea scallop resource
by the U.S. and Canada form the basis for any
future decisions".

The Draft Plan was essentially a background document
for State Department negotiations with Canada on Georges
Bank scallops. With both the U.S. and Canada extending
their jurisdictions to 200 miles thereby creating a disputed
zone of overlapping authority, joint collaboration for coop-
erative management was being pursued.

The Preliminary Management Plan (to be effective March 1,
19 77 - Fishery Conservation and Management Act implementation
date) also was necessary since, as specified by the FCMA, the
Secretary of Commerce had to prepare Plans to provide esti-
mates of optimum yields, determine total allowable levels of
foreign fishing (if any) and set permit and data reporting
requirements for foreign vessels. Moreover, there was concern
about overfishing. According to the Draft,

"...Recent declines in catch per unit effort indices
and increases in fishing mortality suggest that
abundance of Georges Bank sea scallop stocks is
declining. Landings of Georges Bank scallops during
the past two years have exceeded the 'equilibrium
level' of about 6,000 metric tons (MT) of meat
weight reached for the fishery after 1965, implying
that management measures should be enacted to reduce
overfishing and insure future favorable spawning
stock levels...., and.. it is apparent that growth
overfishing has already transpired. If present
effort levels and low cull sizes (small scallops)
continue, the prospect of stock depletion (recruit-
ment overfishing) is critical. Accordingly, future
management measures should be directed at signifi-
cantly reducing fishing effort and increasing the
age at first harvest."

A fishing mortality of approximately 6 7% (percent stock
removed each year due to fishing) , representing a most recent
(1972) estimate, was judged too high, and it was suggested
that "if fishing mortality were reduced towards 25% and the
first age of harvest increased to greater than age four to
take advantage of scallop growth and low natural mortality
of 10%, long-term yield would be increased and would decrease
the probability of recruitment failure".

Suggested Georges Bank (ICNAF Area 5Z) (Figure 1) man-
agement measures for both U.S. and Canadian fleets were:

1) limit combined U.S. and Canadian catch to approxi-
mately 6,000 MT (estimated Maximum Sustainable
Yield) ;

2) allocate the 6,000 MT between the U.S. and Canada
according to recent catch, percentages;

3) by 1982 phase in a meat count of 25 to 3Q meats per
pound;

4) consider limited entry for new vessels;

5) consider a closed season during late winter and
early spring to protect small, newly recruiting
scallops .

The Plan also suggested that regulations for sea
scallops in the Gulf of Maine (5Y) and in the mid-Atlantic
Bight (Area 6) might (emphasis added) be needed.

In addition to the suggested measures, the Plan pro-
posed a continuation of average meat per pound (meat count)
and minimum shell size restrictions implemented by the U.S.
on August 31, 1976. These restrictions were:

1) a prohibition of retention and landing of meats in
excess of an average count of 40 per pound except
that the average count in possession on board a
vessel at sea or at time of offloading could exceed
the limit by a maximum of 10%;

2) a prohibition of retention and landing of sea scal-
lops with shell sizes of less than 95 millimeters
(mm) (approximately 3 3/4 inches) except th.at 10%

of the amount retained on board a vessel or at the
time of offloading could be below the limit.

These regulations resulted from a 1972 ICNAF/Canadian
proposal later modified (10% exemptions) at a June 8-23,
1976 International Commission for the Northwest Atlantic
Fisheries (ICNAF) annual meeting.

Figure 1

Source: Anderson et al. 1979

Earliest Council efforts

In a January 14, 1977 letter of transmittal of the Pre-
liminary Management Plan (PMP) to the New England as well as Mid-
Atlantic Councils, William Gordon, then Regional Director of NMFS,
reiterated that the Plan was in support of U.S. negotiations
with Canada and noted that the Plan's fate depended on the
outcome of those negotiations which were to occur from
January 17-30, 1977. According to Mr. Gordon, the Plan had
the potential to become either "the PMP governing the
Canadian scallop fishery in undisputed U.S. waters in 1977,
or the basis for Councils to assume the task of development
of a PMP for 1978 or a subsequent year". He also stated that
time pressures prevented NMFS from discussing the PMP with
industry or Council members and he hoped that time could be
found for review and input before final actions were taken.

The New England Council initiated its discussions on
sea scallop management at its January 25 and 26, 1977 meetings.
The Regional Director reviewed the PMP and recommended that
the Council develop its own Plan based on the PMP in coopera-
tion with industry to ensure that industry needs were not
overlooked. However, he suggested the Council not proceed
with Plan development until the U.S ./Canadian negotiations
were settled. The Council agreed and postponed further dis-
cussion on the issue.

Relatively soon thereafter, at its March 9 and 10 meetings,
the Council decided to proceed with development of its own
Scallop Plan. In the Council's opinion, the NMFS Scallop
PMP was "not much concerned with the domestic fishery or the
stocks of Georges Bank." There were no regulations off
southern New England or in the Mid-Atlantic Bight; hence,
the Council did not endorse the PMP. Furthermore, the U.S./
Canadian Bilateral Agreement negotiated in March only main-
tained the status of the fishery in the disputed area
(Figure 2) .

Shortly after March meetings, at the Council's request,
services of NMFS personnel, specifically Dr. John Posgay
(NEFC) and John Linehan (New Bedford Liaison) - two indivi-
duals knowledgeable on the scallop resource and fishing in-
dustry - were offered to the Council. These individuals,
responding to directions from Spencer Apollonio, then Execu-
tive Director of the Council, began an undertaking by the
Council and its Staff to augment the biological description
of the resource and information on the nature of the fishery
in New England and mid-Atlantic areas. This effort was part
of a hoped for speedy development and implementation of a
Council Scallop Plan addressing needs and concerns of the
long established New England and rapidly growing Mid-
Atlantic scallop fishing fleets and responding to conserva-
tion of the resource along the Atlantic coast. The Council
expected to have the Plan well developed by July 1977.

Figure 2

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Scallop Plan objectives

To provide for a coordinated effort for Plan develop-
ment, a Scallop Committee was created at May 23 and 24, 1977
Council meetings. The Committee with Philip Coates, then
Assistant Director of the Massachusetts Division of Marine
Fisheries, as Chairman, was asked to quickly develop manage-
ment objectives, and the Committee obliged the Council's
request by proposing tentative objectives at July 5 and 6
Council meetings. These objectives were for the "Georges
Bank stock":

1) maintain stock size at the early 1960's level prior
to heavy Canadian effort;

2) maximize yield per recruit;
and for the "Middle Atlantic stock":

1) maximize yield per recruit;

2) spread harvest over maximum possible number of
years.

These objectives were evaluated by Council Staff to
describe practical limitations of achieving each one and
possible implications of contemplated management strategies;
e.g., closed areas and/or closed seasons, a minimum shell
size or meat count, and landing quotas.

Regarding the first "Georges Bank stock" objective, the
Staff analysis indicated it was unrealistic because, "Uncer-
tainties associated with variability in recruitment and car-
rying capacity of the environment suggest that the 196 0-196 3
biomass is not indicative of an equilibrium, sustainable
population." The Georges Bank biomass during the early 1960's
supported catches of 11,202 (1959) to 15,384 (1962) MT. His-
torical catch and effort data indicated that 6,000 MT was a
more likely sustainable biomass.

The Mid-Atlantic stock objective focused on the follow-
ing phenomenon as described by Council Staff:

"The Mid-Atlantic sea scallop fishery has histori-
cally been characterized by relatively stable, low
level harvests with periodic, high intensity fish-
ing activity occurring at about 15 year intervals
when landings may increase by an order of magnitude.
These periodic "bonanza" harvests, which probably
owe their existence to particularly favorable con-
' • ditions affecting recruitment, have typically re-
sulted from massive reallocation of fishing effort
from other species by local fishermen using bottom
trawl gear. Recently, however, there has been

significant participation by vessels from the
southern New England sea scallop fleet as well as
by the Canadians.

The philosophical basis for management of the Mid-
Atlantic sea scallop resource has focused upon the
periodic "bonanza" harvests."

This tentative Council objective sought to reduce fish-
ing mortality on these "bonanza" harvests, caused by one or
perhaps two consecutive strong year-classes, so that high
catches over a number of years could be maintained instead
of extremely high catches in a few years. In other words,
the objective was aimed at preventing a "feast or famine"
fishery.

A concern with this objective, as well as with the first
objective for the "Georges Bank stock", was that quotas
seemed logical management strategies. Scallop quotas, how-
ever, could not be based on typical stock assessments pro-
vided by scientists since data needed for assessments to
estimate stock abundance and effects of fishing mortality
(e.g. reliable measures of fishing effort and catch age com-
position) were not available for Georges Bank or Mid-Atlantic
scallops. If quotas were set, as stressed by the Staff,
their magnitudes would have to be decided solely on economic
implications to the industry. Interestingly, with respect
to the other objective for both "stocks"; i.e., to maximize
yield per recruit, the Staff emphasized that increased yield
could be achieved more effectively by increasing age (or
size) of scallops at harvest instead of decreasing fishing
mortality by perhaps imposing quotas.

Another concern with the "Mid-Atlantic" objective was
its predication on the assumption that Mid-Atlantic scallops
comprised a separate stock. The validity of this assumption
was and still is in doubt. According to Serchuk et al.
(1979) ,

"Presently no biological evidence exists that im-
plies stock differentiation within U.S.A. offshore
sea scallop populations. Although minor growth rate
differences exist between Georges Bank and Mid-
Atlantic populations, these appear to result from
differing temperature regimes rather than genetic
differences . "

Note: the Mid-Atlantic Council was apprised of the New
England Council's progress on objectives and their repre-
sentative, William Pell, was in attendance at July meetings.

8

At July meetings the tentative Committee-proposed ob-
jectives were introduced to the Council. However, none were
selected. Instead, the Council decided to accept a count of
40 meats per pound as a management objective. It was imme-
diately noted by Dr. Richard Hennemuth of NEFC that a 40 meat
count would not provide for maximum yield per recruit; con-
sequently, the Council referred its new "objective" to its
Scientific and Statistical Committee for further evaluation.

The S & S Committee responded that the adopted Council
objective was a strategy and not an objective. The Committee
would not provide any advice until real objectives were for-
mulated. It did, however, recommend that NMFS be requested
to. prepare a report on "biological relationships between
scallop catch levels, scallop sizes at harvest, and scallop
stock size to provide the Council with biological trade-offs."
The S & S Committee also cited the need for a study on eco-
nomic and social aspects of the fishery. Almost concurrently,
the Council and NMFS Regional Office Staffs began to prepare
a study of costs and earnings of different components of the
scallop fleet to be used in an assessment of economic impacts
on fishermen caused by various management strategies.

At August 2 and 3, 19 77 meetings the Council reviewed
the Committee's original recommendations for objectives and
assessed the wisdom of its 40 meats per pound "objective".
The Staff sought to have the Council reconsider its adopted
measure since it was a statement of a technique and did not
provide the flexibility needed for development of management
options. The Council agreed with the Staff's logic and in-
structed the Scallop Committee to make further recommendations

Two new objectives

The Scallop Committee, utilizing Staff suggestions,
revised its previous objectives. New suggested objectives
were :

1) Restore the Georges Bank adult stock to that level
at which relative year to year fluctuations in
stock abundance, due to variation in recruitment,
are minimized. And, increase the yield per recruit
for each component of the scallop fishery at indi-
vidual rates compatible with reasonable socioeco-
nomic impacts on the various industry and consumer
user groups (long-term objective);

2) Maximize the socio-economic net benefits from har-
vesting and utilization of the "bonanza" year class
in the Mid-Atlantic scallop fishery (short-term
objective) .

Mid-Atlantic Council representatives participated in
the development of these revised objectives, and they indi-
cated that the Mid-Atlantic Council intended to solicit in-
put from the scallop industry it represented on other possi-
ble objectives applicable to the "Mid-Atlantic stock".

At September 7 and 8, 1977 Council meetings, the
Committee's recommendations for Scallop Plan objectives were
unanimously approved.

Mid-Atlantic Council efforts

The Mid-Atlantic Council Scallop Advisory Committee met
shortly after the New England Council established its Plan
objectives. Four objectives were recommended.

1) maintain and maximize employment opportunities which
are fair, equitable, and encourage efficiency in
utilization;

2) maintain a scallop stock above the level where
survival is threatened;

3) reduce adverse environmental effects (i.e., pollu-
tion) on stock levels and utilization;

4) minimize costs of research, development, and en-
forcement associated with sea scallop management.

These objectives were to be discussed by the Mid-
Atlantic Council in September and, if approved, sent to the
New England Council for its consideration.

The Mid-Atlantic Council later rejected the first two
Committee objectives, accepted the latter two, and adopted
three additional ones. These were:

1) restore the adult stock to the level at which rela-
tive year to year fluctuations in stock abundance
due to variance in recruitment are minimized;

2) increase the yield per recruit for each areal com-
ponent of the scallop resource at individual rates
compatible with reasonable socioeconomic impacts on
the various industry and consumer user groups;

3) Maximize the socioeconomic net benefits from har-
vesting and use of the scallop resource.

Little progress

*~ '"•*•' ' '— "■ Mill— ■ I I I T-nrfWun ■/ M||||||,| || , ,

Sea scallops were not discussed at all by the Council
until its April 19 and 20, 1978 meetings. Groundfish and
sea herring management problems were of higher priority.

10

This seven month hiatus took the Council away from its ori-
ginal Plan implementation schedule. Even so, a Draft Plan
was still anticipated to be completed by July or August,
19 78. This summer completion date was expected since the
Staff in cooperation with NEFC scientists had completed the
descriptive aspects of scallop biology. Furthermore, des-
criptions of economic aspects of the New England and Mid-
Atlantic scallop industries were completed and underway,
respectively, and the NEFC stock assessment was thought to be
nearly completed (not until November, 1978) .

At these April meetings, the Regional Director expressed
his concern over increased effort in the scallop fishery. He
stated:

"If there is any fishery ripe for establishing
limits on large vessels, it's scallops. The prob-
lems of the large amount of new vessels entering
the fishery are compounded by the fact that the
fishery is being sustained by a single and ex-
tremely abundant year-class, and even further com-
pounded by the untenable position developing in
Canada regarding scallops." (Barlow, Maine Commer-
cial Fisheries May 1978) .

Canadian concerns

Canada had also expressed its concerns to the U.S.
government over what it perceived to be a growing U.S.
scallop fishery on the northern edge of Georges Bank (Figure
2) / the area responsible for the majority of Canadian
Georges Bank scallop catch (disputed zone) . Canada claimed
that the U.S. fishery had expanded its effort by approxi-
mately 100% in that region since 1976 and was overfishing
the Georges Bank stock.

The Canadian assertion that U.S. effort had increased
was justified. U.S. effort on the Northern Edge and North-
east Peak of Georges Bank rose from 45 days in 1976 to 384
days in 19 77 (339 day increase) . Catch increased from 45
MT to 40 7 MT (362 MT increase) . However, Canada did not
mention, or perhaps did not realize, that its own effort in-
creased in this region, from 9,335 to 11,585 days (2,250
days) and 8,906 to 12,669 MT (3,79 3 MT) (data from Serchuk
et al. 1979) . An evaluation of percent increases in effort
and landings from 19 76-19 77 made the U.S. fishery and its
impacts on the scallop resource in the disputed zone look
much worse relative to the Canadian fishery's impacts.
Canada wanted the U.S. to implement regulations for its
scallop fisheries which theretofore were not restricted in
any way except for some industry-imposed limitations and
meat count/shell size restrictions effective and enforced
from August 1976 to February 28, 1977 (prior to FCMA imple-
mentation date) „

11

Canada felt that its interest in Georges Bank scallops
was greater than U.S. interest, and it used recent catch and
effort data to "confirm" its claim. It considered U.S. in-
creased effort as an intrusion into "Canadian" traditional

fishing grounds on the Northern Edge and Northeast Peak.

These Canadian concerns intensified in the spring of
1978 and in June, during a negotiating session on the 1978
U.S. /Canadian Reciprocal Fisheries Agreement and boundary
issues, Canada closed all its fisheries in its undisputed
waters to fishing by U.S. commercial fishermen. Canada was
dissatisfied with progress of negotiations and U.S. fishery
management efforts and would not even consider reciprocal
fishing until it was clear that a long-term agreement was in
sight.

To retaliate, the U.S. closed its undisputed waters,
too. This marked the end of a series of formal east coast
fishery agreements with Canada first established in 1973
when the U.S. and Canada agreed to allow each other's fish-
ermen to fish 3 to 12 miles from each other's coast. Both
countries had entered into a Reciprocal Fisheries Agreement
for 1977 (implemented July 26) .

Shifting shares

To appreciate reasons for both U.S. and Canadian inter-
est in control and management of sea scallops on Georges
Bank (5Ze) , sea scallop landings from 1956-1980 by both
countries are depicted in Figure 3. The U.S. fishery domi-
nated landings during the 1950 's until about 1964. After
1964 Canadian fishermen acquired the majority of landings.
This shift in percent share was attributable to:

1) development of the offshore Canadian scallop fleet
in the 1950' s;

2) decline in scallop abundance on Georges Bank;

3) more individual U.S. effort with accompanying higher
production costs needed to maintain profitable
catches on Georges Bank;

4) productive scallop beds in the mid-Atlantic found
closer to home ports particularly New Bedford,
Massachusetts, home of the long distance scallop
fleet;

finfish prices began to increase thereby providing
an incentive for fishermen to convert from scallop-
ing to dragging.

12

IS -

<5 12

»- a
o

O

Sea Sco//op Landings

Q 10

c

6

3

o

56 57 58 59 60 61 62 61 64 65 66 67 68 69 70 71 72 73 '« '5 76 77
vean

MI0- ATLANTIC
GROUNDS

:i-y.nnnnnnn

nnnnn

56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 '3 4 T. '6

FIGURE 3. Total reported United States and
Canadian sea scallop landings (metric tons, meats)
from Georges Bank and Mid-Atlantic fishing
grounds, 1956-1977. The upper lined portions of
the bars represent Canadian landings.

Figure 3

(From Serchuk, et al. 1979)

'000

■ 100
'00

SEA SCALLOPS

!967- W7 u 5 LANDINGS
MEAT W !LBS«KD:)

FIGURE 4. Geographic distribution of United
States sea scallop landings (thousands of pounds,
meats) from Georges Bank, 1967-1977.

76° W
■4T N

r~«ft

| > 1,000
100
100

SEA SCALLOPS

1966- 76 U. S. Landings

MEAT WEIGHT
(LBS x 10-3)

37* -

73*

36*

FIGURE 5. Geographic distribution of United
States sea scallop landings (thousands of pounds,
meats) from the Mid-Atlantic, 1966-1976.

13

These five factors caused a virtual abandonment of eastern
Georges Bank scallop beds by U.S. fishermen and a reduction
in the offshore fleet (New England Fishery Management Council
Sea Scallop Plan 1981) .

U.S. catches on Georges Bank have recently increased.
Catches rose from 1,760 MT in 19 76 to 4,806 MT in 19 77 and
approximated 6,000 MT from 19 78-19 80. Renewed interest in
this resource was primarily attributable to increased scallop
prices causing draggers to convert to scalloping, and the
entry of new vessels. Ex-vessel prices per pound rose from
$1.62 in 1977 to $2.47 in 1978 and $3.28 in 1979 ($4.97 in
1981) . Scallop availability was another reason for increased
effort.- The 1972 year-class (scallops produced from 1972
reproduction) was highly successful on the Bank (and else-
where) . As described in a later section, this increased U.S.
fishing caused many U.S ./Canadian squabbles and played an
important role in preventing ratification of the U.S./
Canadian Fisheries Treaty first proposed in early 19 79.

An evaluation

While the Council did not address sea scallops until
April, 19 78, the Committee, Staff and others were actively
involved in an examination of existing and needed biological
data and research activities. One such examination occurred
at a February Sea Scallop Workshop involving Northeast Fish-
eries Center and Staff of both Councils. The following
topics were discussed: sea scallop biology; needed biologi-
cal and industry data to improve assessments and economic
impact analyses; evaluation of management measures as related
to Plan objectives; and research priorities. Some of the
more important (author's view) conclusions of the workshop
were :

1) "Little is known about the factors affecting
reproduction and early life history, particu-
larly during the pelagic larval and post meta-
morphic stages, due to the difficulty associated
with mounting relevant research efforts. The
distribution of spatfall is apparently a partial
function of the prevailing current patterns,
making it unlikely that progeny will settle in
the vicinity of the parent bed. At present
there is no documented biological link between
scallops in major production areas. However,
similarities in population structure, in terms
of the relative year class strengths recently
observed between the Great South Channel and
Mid-Atlantic Bight populations, may lend sup-
port to the hypothesis that the prevailing
southwest current drift from Nantucket Shoals
along the Mid-Atlantic Bight may result in the
Mid-Atlantic beds settled by progeny from beds
"up stream".

14

Current research efforts include research^
vessel surveys (NMFS) conducted in alternate
years, periodic assessments of the abundance
and condition of the regional sea scallop
stocks, and some on-going analysis of growth
data.

2) There are three general areas where a lack of
adequate data results in an inability to apply
many of the standard assessment techniques to
an analysis of sea scallop populations. While
effort data, in terms of days fished, is avail-
able for areas 5Z and SA6 , it is not considered
adequate for measures of abundance, due to
standardization problems between vessel classes
and gear types. Effort data resulting from
trip interviews is not available for the Gulf
of Maine. To increase its usefulness, effort
data should reflect time on the bottom and/or
area dredged on a per haul basis. Secondly,
the collection of samples from the commercial
fishery for size and age composition analysis
is not adequate, particularly from the Mid-
Atlantic area. Collection of this type of data
presently relies heavily upon the voluntary
cooperation of fishermen ( "shuckers" ) in se-
curing samples. This data is critical to an
adequate estimation of standing stock and pro-
duction. Finally, there are some problems
with ageing scallops from areas where shell
structures may be indecipherable due to abra-
sion. As a result, it may be difficult to
determine age composition for analysis and
comparison among scallop stocks.

Viewing scallop assessments as a whole it is
clear that it is possible to evaluate yield per
recruit in determining the length at first cap-
ture which will maximize yield. We have avail-
able for management purposes relative estimates
of recruitment a year or two prior to entry
into the fishery and relative stock abundance
indices, both available from research vessel
surveys. Unfortunately, there are no absolute
estimates of current stock abundance or mini-
mum spawning stock size, reliable early indi-
cators of year class strength, apparent stock/
recruitment relationships or clear relation-
ships among stocks to assist the assessment
process.

3) It was generally agreed that the objectives
were reasonable; however, various difficulties

15

associated with implementing measures to
achieve certain objectives were evident.

The objective to restore the adult stock com-
ponents so as to minimize fluctuations in stock
size due to variation in recruitment is useful
only with a view toward the historical perfor-
mance of the stock, the criteria for restora-
tion and the time frame involved. With regard
to the criteria for stock restoration, workshop
participants were in agreement that restoration
in terms of numbers alone was not sufficient to
achieve objectives directed toward maximizing
yield per recruit and minimizing the impact of
variations in recruitment on stock biomass.
Rather, stock restoration in terms of increas-
ing the average age of scallops in the popula-
tion, coupled with some minimum stock biomass
constraint, better satisfied the intent of the
adopted management objectives.

The objective to increase yield per recruit
will tend to maximize yield from the scallop
fishery, and in combination with quota restric-
tions serve to restore the stock. The workshop
participants agreed that measures adopted to
maximize yield-per-recruit should apply uni-
formly over the range of the resource; however,
they noted that effective means for controlling
length at first capture have not been developed
for the sea scallop fishery.

However, major limitations were seen in imple-
menting minimum size regulations. Shucking at
sea makes it difficult to control minimum size
because of the high variability in meat weight
with respect to shell length. Research has
indicated that there is no savings gear for
scallops, and at present a practical means of
mechanically culling the catch at sea has not
been developed.

Control of fishing mortality with a view toward
maintaining a minimum spawning stock size was
suggested as having practical merit. The im-
position of catch quotas consistent with a min-
imum spawning stock (by area) constraint serves
to encourage a distribution of year classes
within the stock and may satisfy the objective
of maximizing net economic benefits if quotas
are adjusted according to some optimal time
path of exploitation. This is particularly
important where one year class is expected to
dominate the fishery.

16

In this regard it seems that research directed
toward improved assessment capabilities (com-
mercial catch analysis, ageing, recruitment
predictions, effort data) , and the imple-
mentation of management measures (i.e. ,
minimum shell size to maximize Y/R) would
best provide a basis for sound management
in the near future."

Update - mid 19 78

In a July 10 memorandum to both New England and Mid-
Atlantic Councils, Spencer Apollonio, then Executive Director
of the former Council, updated the status of FMP development,
refreshed the Council's memory on Plan objectives, commented
on the workshop, and noted the Staff's developing Economic
Impact Analysis. A Scallop FMP outline was also presented
to give the Council a feel for the Plan's contents.

Almost a year and a half had passed since implementation
of the FCMA, and a Scallop Plan to take the place of ICNAF
meat count and shell size regulations was still far from com-
pletion. Reasons for this long delay were a preoccupation
with more pressing groundfish and sea herring management
issues and a realization that scallop management objectives
and strategies were not as clear-cut as originally envisioned.

Resource status and industry views

The Scallop Committee with Daniel Arnold (Executive
Director Massachusetts Inshore Draggermen's Association and
new Council member) as Chairman met in New Bedford with in-
dustry advisors and NEFC assessment scientists to acquire
industry's views on management needs in the scallop fishery.
The most recent assessment information and its implications
for management and future of the fishery were also discussed.

A NEFC assessment scientist provided results of the 1978
U.S. and Canadian sea scallop surveys and landings (recent
and historical) . Some of this information had already been
presented at an earlier September 25 NEFC briefing held for
the New Bedford industry. Other data, particularly results
of the 19 7 8 surveys, were seen for the first time.

Importance of the strong 1972 year-class to fisheries
in the South Channel (western portion of 5Ze) and Mid-Atlantic
regions were emphasized. This year-class dominated research
vessel catches and commercial landings and was not expected
to support the fishery for much longer. The 19 73 and 19 74
year-classes in all areas were judged to be fair to poor
except on the Northern Edge and Northeast Peak of Georges
Bank where these year-classes were good. The 1975 year-
class appeared to be poor in all areas except, again, for
the Northern Edge and Northeast Peak where it was assessed
to be good. This latter revelation (1975 year-class) was

17

bad news for it had been hoped that the 19 75 year-class
would be good so that the existing high fishing effort in
the Mid-Atlantic and South Channel could continue in the near
future without a need to shift effort toward the U.S. /Canada
disputed area which included the Northeast Peak and Northern
Edge. Some industry members were visably disturbed to dis-
cover that the "motherlode" existed only on the Northern Edge
and Northeast Peak for it would mean that the future economic
health of the industry would be linked to that area currently
being contested with the Canadians. The 1976 and 1977 year-
class strengths were unknown since small scallops were not
effectively retained in survey catches.

Status of the development of the Sea Scallop Plan was
given. It was stated that no management strategies had yet
been developed by the Staff for the Council's consideration.
In response to an industry question, "Why the immediate need
for a Plan?", Spencer Apollonio noted:

1) Canada had stated that no joint management of
scallop stocks could occur until the U.S. had a
scallop plan. Therefore, the Secretaries of
Commerce and State were pressuring the Council to
formulate a Plan as soon as possible;

2) the Council voted in early 1977 to develop a Plan,
and time was passing;

3) the Mid-Atlantic Council wanted a Plan. It felt
that "stock" abundance of scallops in their area
could be stabilized if quick action was taken.

Daniel Arnold asked industry representatives to give
their views on management needs in the scallop fishery. One
fisherman stated that a meat size restriction and a prohibi-
tion of shell stocking (landing scallops in the shell rather
than shucked) would be suitable. Another fisherman suggested
a limitation on fishing days (perhaps eight fishing days with
a mandatory five days at home between trips) . Suggestions on
gear restrictions (dredge ring sizes) and spawning area
closures were also offered.

Few industry representatives realized that an optimum
yield (or quota) had to be set. When asked to verify that
regardless of the need for an OY, the Council had to deter-
mine one, Mr. Apollonio stated that while OY had to be set,
the FCMA did not specify that it could not be exceeded. He
noted, however, that Washington NMFS did not share his views.
Some fishermen were disturbed at this revelation. No one
wanted the problems occurring in the groundfish fishery to
be repeated for scallops.

Timetable and increased representation

On January 4, 1979 the Committee received a tentative
time schedule for Scallop Plan development. A final draft
of the Plan was anticipated for May 19 79 when the Council
was expected to act on Committee recommendations and the
public review process was to begin.

Council Staff was working with the NEFC to develop a
range of management strategies for Committee review, and it
was decided by the Committee that these strategies should be
reviewed with input from both the Mid-Atlantic and South
Atlantic Councils. To insure that input, the Committee de-
cided to ask a Mid-Atlantic Council member and industry ad-
visor from that region (New York to Virginia) to participate
in Committee meetings. Also, "all relevant papers were to
be sent to the South Atlantic Council for its review".

Bio-economic analysis

A "Preliminary report on the bio-economic analysis in
support of Atlantic Sea Scallop FMP Development" was pre-
sented to the Committee at its February 2 3 meeting. At the
same time, Part One of the Plan - Statement of the Problem -
was presented for review.

The bio-economic analysis "demonstrated the nature and
complexity of impact assessments of total allowable catch
(TAC) strategies that the Council will have to consider".
Impacts on prices, total revenues, U.S. consumption, imports,
and employment, average vessel gross stock, crew shares and
boat shares were evaluated. The analysis enabled a tracing
over time of the impacts on stock abundance and harvesting
costs of different multiple year quota strategies to deter-
mine the TAC causing the most beneficial impact.

Regarding various initial proposals for TAC's, the Staff
acknowledged that biological data limitations prevented an
analysis of multiple year TAC's similar to the analysis done
for the Sea Herring Management Plan. Impacts could only be
identified for a single year.

The Staff suggested that a reduction of annual harvests
from Georges Bank and the Mid-Atlantic from "recent high non-
sustainable levels to historic average levels of exploitation"
was most consistent with the Council's objective of spreading
catch out over time rather than to concentrate effort into a
limited time period. According to the Staff,

"In the Georges Bank resource 8,000 MT reflects
the average level of harvest over the past 20
years. Under the assumption that terms of the
current draft U. S ./Canadian Fisheries Agreement
for Scallops will prevail, the U.S. share of the

19

total scallop harvest on Georges Bank (26.4%) is
2,100 MT. In the Mid-Atlantic an annual catch of
3,500 MT represents the average annual harvest
over a 15 year period during which two unusually
strong year-classes passed through the fishery."

With an aggregate 19.79 catch of 5,600 MT (2,100 + 3,500
MT) the Staff predicted that average annual ex-vessel price
would rise by 28%; however, total gross revenues to the har-
vesting sectors were expected to drop from $79 million in
1978 to $40 million in 19 79 (49% decrease) . At the same time
with a 7,000 MT reduction in Canadian Georges Bank catch, U.S
imports from Canada were expected to fall by over 50%. New
England and Mid-Atlantic fleets were expected to experience
a 46% and 5 3% drop in total gross revenues, respectively.

The Staff defined the amount of effort in the scallop
fishery. They indicated that their review of the industry
showed over 300 vessels participating in the scallop fishery.
However, only a small percentage of these vessels showed
heavy dependence on scallops as a source of revenue. Twenty-
four vessels (dredges) operating year-round out of New Bed-
ford accounted for 52% of the 1977 U.S. 5Z catch of scallops
and approximately 33% of the U.S. Mid-Atlantic catch. For
these vessels (assuming no new entries) , the Staff's sug-
gested initial TAC strategy was expected to cause a loss in
the annual gross stock to the average vessel of over $400,000
(40%) compared to 1978. The net boat share was expected to
fall by $130,000 and annual crew share by approximately
$21,000. With new entries, returns to labor and capital
were predicted to fall even further.

Assorted suggestions and a revelation

This depressing news prompted the Committee and advisors
to discuss the need for limited entry into the scallop fish-
ery - if a TAC was necessary - to prevent possible economic
losses to vessels already in the fishery. It was decided
that limited entry was not a stopgap to overfishing since
the existing level of effort in the fishery was already high
enough to catch scallops beyond any "sensible TAC" (e.g.,
8,000 MT U.S. and Canada).

In lieu of a TAC and economic hardships it would pro-
bably impose, industry advisors suggested a management strat-
egy for the Council to consider. New Bedford advisors rec-
ommended limitations on scallops similar to self-imposed
industry restrictions; i.e., a limitation on number of days
of fishing per trip. New Bedford industry representatives
felt their own "effort restrictions" combined with a few
other controls on catch were sufficient to meet conservation
goals set by the Council.

20

At the next Committee meeting held on March 12, Mid-
Atlantic Council advisors' input, obtained at a Mid-Atlantic
Advisory Subpanel meeting, was related. The most significant
contribution of that Advisory Subpanel was a revelation that
a significant sea scallop fishery was prosecuted by North
Carolina fishermen in areas off the South Atlantic coast.
This bit of news and the need and desire of the Committee to
acquire more information about that South Atlantic effort
marked a turning point in the Committee's composition and a
need for the Committee to widen its focus to include impacts
of its future recommendations on sea scallop management over
the scallop's range along the Atlantic coast. As shall be
seen from following discussions, new South Atlantic Council
and increased Mid-Atlantic Council inputs into Committee
deliberations caused a great deal of consternation on the
part of the southern New England sea scallop industry,
notably the New Bedford industry.

Recommendations

The Committee decided to propose:

1) 1,000 lbs. /man/trip; maximum of 11,000 lbs. /trip;

2) trip limited to 8 days, 5 day layover; layover
adjustments for shorter trips;

3) dredges limited to 13 '-15* to a maximum of 26 '-30'
total;

4) ring size increased to 3 1/2" no later than 6 months
after FMP implementation;

5) meat count regulation of 30 meats/lb. (roughly
equivalent to a 4 year old scallop) ;

6) end of year break: sail before December 5, sail
after January 22.

Other recommended actions were:

1) a sea sampling/commercial observer program be esta-
blished by NMFS for the New England and Mid-Atlantic
regions to systematically monitor harvesting prac-
tices and status of stocks;

2) NOAA Counsel should be asked to comment on the
legality of establishing crew limitations.

Domestic OY is intended to be equivalent to expected
level of catch achieved by fishing in accordance with regu-
lations suggested in items 1-6. Council Staff will evaluate
level of catch which may be expected as a result of regulated
fishing activity.

21

These recommendations were presented to the Council
at its March 14 and 15, 1979 meetings, but a decision on
their acceptability was postponed until April meetings.
This was to enable the Committee to meet one more time to
provide the South Atlantic Council and Mid-Atlantic Council
with one last opportunity for review and input before a final
New England Council decision. New Bedford scallop interests
who were the prime movers of the six recommendations did not
appreciate the delay. In the opinion of some New Bedford
advisors, New Bedford had a long-standing, continuing
interest in the sea scallop resource, as demonstrated by
its history in the fishery and its self-imposed "conservation
measures"; hence, desires of Mid-Atlantic and South
Atlantic scallop interests (primarily shell stockers) that
entered the fishery only in "good times", should not be
given great weight and influence on New England Council
decisions.

A three Council confab

The next Committee meeting was held on May 7, The
meeting's purpose was for the three Council-Committee to
"propose or endorse management measures based upon their
best understanding of the status of the resource, sensitive
to the regional needs of the sea scallop industry."
Discussion covered a wide range of topics.

Council Staff presented their preliminary analysis of
the proposed 11,000 lbs. per man per trip limit to determine
if it would be restrictive. Results suggested a 20% decrease
in dredge catch although new entries would probably prevent
any decrease in total catch by the fleet.

It was related by the Chairman that approximately 150
vessels (one-third shell stockers) were fishing from New Jersey,
Virginia and North Carolina ports. A North Carolina repre-
sentative stated that 69 vessels from North Carolina landed
scallops in 1978 with approximately 60% being shell stockers.
Forty- four Virginia vessels landed scallops in 1979. Conse-
quently, it was clear to the Committee, especially New England
representatives, that both the amount and types of effort in
the Mid-Atlantic and South Atlantic regions needed to be
addressed in greater detail. For example, the large amount
of shell stocking was in conflict with one of the Plan's
objectives — to enhance yield per recruitment (to avoid
harvesting small scallops) . Shell stockers fishing with nets
caught all sized scallops and brought them to port for
shucking and processing. Need for controls on this activity
was apparent; however, the most appropriate and feasible
kinds of controls and their impacts were not clear.

A representative of shell stockers noted that a minimum
shell size would be required to prevent landing of small

22

scallops. However, a minimum size would force culling of
the catch while at sea and a need for at least one more crew
member causing a decrease in crew share. Also, mesh size
would have to be adjusted to allow escapement of smaller
scallops, yet no one knew selectivity of nets for different
sized scallops. Moreover, culling in warm weather was
expected to increase mortality of scallops sorted on deck
so undersized scallops returned to the sea would be dead.

Opinions differed, as expected, between scallop fisher-
men advisors who used dredges and those who used nets. Those
in favor of dredging felt that shell stocking should be
prohibited especially since it was not a traditional fishery
and very small scallops were caught to the detriment of the
resource. In retort, netters noted the great market demand
for small scallops, and netters were able to provide them.
It was claimed that netters could fish where dredges could
not, and this opened new fishing grounds. Also, it was
claimed that any outlawing of netters would be disastrous
to the Mid-Atlantic and South Atlantic scallop industry.

Ensuing discussions centered on meat count as a conser-
vation measure. New Bedford interests favored a 30 meat
count with the number of days fishing restriction, and
considered this strategy to be an adequate substitute for
an OY or quota. On the other hand, Mid-Atlantic scallop
interests were opposed to any limitation on days fished,
wanted some form of OY or TAC (such as OY equal to 1978
catch) , and preferred a 40 meat count restriction since it
would allow landing of smaller scallops and was comparable
with the Canadian fishery's 40 meat count restriction (with
10% tolerance) . These differences in opinions led to a
discussion on the possibility of establishing separate
Mid-Atlantic and New England management areas with different
management strategies for each area. No conclusion was
reached.

The Committee ' s choice of meat count could not be
finalized although, in the Chairman's opinion, the
Committee appeared to favor the 40 meat count with a
corresponding shell size restriction. The Chairman stated
further that if a 40 meat count was the Committee's final
choice, that count needed to be linked with a strong recom-
mendation to the Secretary of Commerce that she negotiate
with Canadians to eventually reduce the meat count for
both countries to 30 meats per pound.

The meeting ended with a South Atlantic Council
representative suggesting a great deal of additional Staff
work. His suggestion raised the hackles of some New England
scallop industry representatives who felt the suggestion
would cause a major delay in the Scallop Plan's completion
and implementation to the detriment of the resource.
Additionally, the Staff felt that before it began new

23

analyses and data gathering efforts, the Committee should
first take a position with regard to the "Statement of the
Problem" and the "Preliminary Bio-Economic Analysis" written
by the Staff in support of the Plan's development. These
documents had been distributed to the Committee in February
and March. The Staff was looking for guidance from the
Committee. This guidance was not provided.

At May 16 and 17, 19 79 Council meetings, the Council
was apprised of the divergent New England and Mid-Atlantic
views. Daniel Arnold emphasized that the Committee was
obligated to solicit all information available to insure
views of all geographic areas. He noted that strategies
would be discussed in greater detail in July.

A bit of irony

The Mid-Atlantic Council expressed its displeasure over
the slow progress of Plan development. This displeasure
sparked some negative comments from New England Council mem-
bers at June 27 and 28, 1979 Council meetings. The New
England Council had gone to great lengths to insure Mid-
Atlantic, and South Atlantic, input for the Plan's develop-
ment. This action was responsible for much of this delay.
As stated by Harvey Michelson, "It would seem to me that this
Council has the responsibility for formulating a Scallop Plan.
If this Council or the Scallop Committee had gone ahead and
formulated its position on what the Plan should be and then
submitted it to the Mid-Atlantic we would be much further
ahead. The lead group should make its position known, and
take it from there".

Not everyone shared this view, however. The Committee
Chairman in particular suggested that the Council ask the
Secretary of -Commerce to give both Council's joint management
authority for sea scallops, and he made a motion to carry out
this intent. However, this motion was later withdrawn after
the Council's collective sentiments became clear.

A majority of Council members were unwilling to relin-
quish any management authority for two reasons. First, the
issue of sea scallop management was extremely sensitive,
particularly to New Bedford interests. This had been brought
about by the proposed U. S. /Canadian Treaty and provisions thereof
with regard to scallop percent shares and management author-
ity. To delegate any more scallop management authority away
from the New England Council was considered unpalatable by
many. Secondly, the Mid-Atlantic Council had yet to properly
address the New England Council's concerns over surf clam
management. The Mid-Atlantic Council had lead authority
over the entire surf clam resource off the Atlantic coast,
and the New England Council was piqued over the continued
failure of the Mid-Atlantic Council to adequately address
concerns and needs of the New England surf clam fishing

24

interests. While this latter reason could have been consid-
ered vindictive, it nevertheless was understandable, particu-
larly considering the history of conflict between both Councils
on surf clam management. A moratorium on entry into the surf
clam fishery, which effectively stymied any development of a
New England fishery, had been especially contentious, and Mid-
Atlantic recommendations for plan amendments did not satisfy
New England interests.

Definition of issues and management unit

The Scallop Committee met on July 10 in Philadelphia to
finally address the Staff's "Draft Part I - Scallop FMP,
Statement of the Problem". Management issues approved by
the Committee were:

"In the absence of harvesting and/or effort restric-
tions in the scallop fishery, the domestic catch of
scallops in 19 79 is expected to be equal to or
greater than the 1978 catch. This expectation is
based on the assumption of continued high ex-vessel
prices suggested by strong consumer demand. This
will support continued high or increasing effort
levels.

The resource outlook presented earlier indicated
that recent years harvest levels cannot continue
in 19 79 without a decline in stock abundance and a
reduction in catch rates. Given that this is the
prospect and that future recruitment is uncertain
a main problem for management is to determine the
preferred time path for harvesting the presently
available scallop biomass. How much of the current
stock should be harvested in 19 79 and how much
should be set aside for 1980, etc?

A decision to abstain from or to restrict harvest-
ing of scallops is an investment decision. Like
other investment decisions, it requires determina-
tion of an expected return within some defined
planning period. As most fisheries the growth and
mortality parameters of the stocks as well as cur-
rent and future prices and costs determine return
on investment.. Direct and indirect effects on
employment are likely to be additional considera-
tions relative to an assessment of a social return
on the exploitation of resources. Future streams
of benefits and costs are impacted by future levels
of resource utilization and by the particular sets
of management regulations enforced in future years.
Management strategies, therefore, have to be viewed
as encompassing a time span longer than one year.
It follows that annual "optimum yields" have to be
determined for multiple years, rather than a single

25

year, recognizing that future "optimum yields"
will have to be revised as our perception of the
biological and economic decisions environment im-
proves, and as our objectives for management change

Review of the industry structure has pointed to a
pattern of historical dependency of various fleet
sectors on specific resource components. The im-
position of annual TACs for such resource compo-
nents might initiate shifts in spatial allocation
of fishing effort of various fleet sectors. A
major issue to be addressed by the Councils is,
therefore, whether the distribution of harvests
among users is to be left to the free market forces
or to the introduction of explicit systems for
distributing TACs among user-groups. In this
latter regard, it is recognized that vessel and
gear restrictions, definition of fishing areas,
and fishing periods are regulatory measures with
implications for the distribution of harvests
among user-groups.

A third management issue involves the decision of
enforcement of the overall species quota as well
as season or vessel group quotas if such alloca-
tions are made. This issue has its roots in the
pressures for exceeding the imposed TACs which
must be anticipated in periods when the expected
domestic catch in the absence of regulations
exceeds the total catch limitation imposed.

Finally the issue of limiting entry into the fish-
ery shall as a matter of Council-determined pro-
cedure be considered in the FMP for scallops. The
immediate need to address this issue in this Plan
emerges from the concern over the impact that the
expansion of fleet size and effort observed in
recent years will have on the Council's ability to
effectively manage the fishery and in particular
to enforce overall catch limitations. More funda-
mentally, however, the issue of access control
bears directly on the achievement of management
objectives, i.e. what are the impacts of continued
free entry into the fishery on the overall benefit
to users of the resource?"

The Committee also decided the management unit:

"The fishery resource addressed by this management
plan encompasses the population of sea scallops,
Placopecten magellanicus , that occur along the con-
tinental shelf of the northwest Atlantic within
the boundaries of the FCZ . The resource is found

26

found from the Northeast Peak of George's Bank
westward to the Great South Channel and along the
continental shelf of the Mid-Atlantic. It is
recognized that commercial quantities of sea
scallops also occur within the territorial waters
of the state of Maine and of Canada. These scallop
resources are outside the authority of this FMP,
and for management purposes may be assumed to
interact with those under the jurisdiction of the
FMP at the market level only.

Three resource components within the FCZ may be
generally defined. These consist of the northern
edge and northeast peak of George's Bank, the
Great South Channel, and the Mid-Atlantic Bight.
Although there is little biological evidence,
particularly reproductive, that could serve as
a basis for stock separation within the bounds
of the resource described, the three resource
components will be treated as independent stocks
for management purposes based upon their geographic
separation, historic trends in recruitment, and
levels of production, and proximity to user groups.

It is recognized that management authority over
the George's Bank sea scallop resource is an
issue currently being resolved between the U.S.
and Canada. Pending ratification of the draft
U. S. /Canadian Atlantic Fisheries Agreement, this
FMP will be generated under the assumption that
the negotiated terms of access and entitlement
will stand."

August 1 and 2, 1979 Council meetings marked the accep-
tance of the "Statement of the Problem" part of the FMP.
It was related that the Mid-Atlantic Council also concurred
with the "Statement" at its July meetings. The Mid-Atlantic
Council also accepted the New England Council's timetable
for the Plan's development which indicated an expected
November completion date for the Draft Plan.

Additionally, a July 31 letter (received by the New
England Council on August 3) to the New England Council
from the Mid-Atlantic Council indicated that Council ' s
request to the Secretary of Commerce that she "declare
the scallop fishery a conditional fishery in the Mid-Atlantic
region, if not throughout its entire range." A conditional
fishery designation for scallops would have caused NMFS to re-
strict use of financial assistance programs to prevent additional
vessels from entering the fishery. Mid-Atlantic concerns over
the scallop resource and fishery were mounting and that Council
had gone so far as to state it would prepare its own Plan if
the New England Council did not speed up development of its

27

Plan. The Mid-Atlantic Council later backed away from this
position after it was led to believe that November was the
expected Draft completion date. However, the request to
make scallops a conditional fishery still stood firm.

Strategies develop

In October, progress was made on strategies to achieve
the Council's Plan objectives. Council Staff, with assis-
tance from NMFS Staff, identified a range of strategies
that could be pursued. However, before a detailed Staff
analysis of biological and economic impacts of each of its
proposed strategies could be performed, Committee policy
decisions had to be made. Three issues were:

1) desirability of quotas in New England and Mid-
Atlantic areas;

2) establishment of regional shares of quotas
for each geographic area;

3) limited entry

These policies were discussed at an October 12 Committee
meeting which began on a sour note. Mid-Atlantic Council
members present felt they could not make any determination
of management strategies for the Mid-Atlantic Council. This
was ironic to some Committee members since the Mid-Atlantic
Council was on record as wanting a Scallop Plan in place as
soon as possible, yet its representatives were not willing
to express any policy preferences for the Mid-Atlantic.

The question of TAC * s for the scallop resource was
debated and it was decided that the Staff would analyze a
number of strategies to result in biologically justifiable
and non-biologically justifiable levels of allowable catch.
The Committee was to then review these catch levels to
decide if it wished to opt for a TAC or an expected catch
(implied TAC) . The difference between these two classifica-
tions was not completely clear; however, as explained by
the Staff, a TAC was a cap which could not be exceeded
while an expected catch (implied TAC) could be exceeded if,
for example, scallops were more abundant than originally
assessed.

The meeting concluded with further requests for Staff
analyses of regional shares and no regional shares of the
resource and general aspects of management proposals
offered by New Bedford scallop interests in March. The
Committee voted to formally adopt a 3 0 meat count management
measure and again suggested that the Secretary of Commerce

28

negotiate with the Canadians to achieve a complimentary meat
count. Significantly it also voted to have no overall catch
limitation on the sea scallop fishery; i.e., it decided to
adopt an implied TAC. OY was to be the expected level of catch
resulting from fishing under the eventual management system
which was to include the 30 meat count,
count.

The Committee shied away from TAC's since TAC's were
bound to have significant adverse impacts on the U.S.
fishery. For example, assuming the Council eventually
decided to adopt a 9,000 MT quota for Georqe ' s Bank (reason-
able estimate of MSY - mean annual landings since 196 0) and
the U.S. /Canadian Fisheries Treaty was eventually ratified
giving the U.S. only a 26.65% share of George's Bank scallops,
the U.S. scallop TAC under the Council Plan would only be
approximately 2,400 MT. With the scientists' prediction
that abundance of scallops was decreasing everywhere except
for the Northern Edge and Northeast Peak of George's Bank,
the hesitancy of the Committee to use quotas was under-
standable.

November discussions

Staff analyses were revealed at a November 19 Committee
meeting. Since a strong relationship between fishing effort
(standard U.S. days fished) and fishing mortality was found
to exist in the Georges Bank sea scallop fishery, the Staff
used effort data to determine long-term sustainable levels of
effort which would not have unacceptable biological impacts.
The Staff equated historical average effort levels (U.S. and
Canadian) of 2,320 days fished to be acceptable biological
impact. The historical maximum (4,226 days) was equated to
marginally acceptable biological impact with higher levels
being unacceptable.

Under all examined scenarios involving different New
England and Mid-Atlantic shares of the Georges Bank and
Southern New England resource, management solely by meat
count was predicted to cause an unacceptable biological im-
pact. Only when days fished was reduced by 50% or greater
did the biological impact become acceptable. This "needed"
overall cut in fishing effort combined with the proposed
U.S. /Canadian Fisheries Treaty U.S. percent share caused the
Committee to drift farther from TAC or effort management.

While the Committee was divorcing itself from quota or
effort management, some industry advisors were leaning the
other way. Advisors were noting decreases in average catches
of scallop per vessel, an absence of small scallops

29

on the fishing grounds (needed to sustain future high
catches and effort), and increased effort on George's Bank.
They felt a need for more restrictions than just a 30 meat
count. Indeed, Guy Marchesseault of the Council Staff, added
that a 30 meat count in 1980 would not limit the New England
scallop fishery since the average size of landed scallops
(primarily 1972 year-class) would result in an even smaller
count (e.g. 20 count). Note: the larger the meat or scallop,
the smaller the count. Also, as it was later learned from
a NEFC assessment, the 1979 NEFC scallop survey indicated
that "as a result of heavy fishing pressure applied over the
last few years, the 1972 year-class no longer held its
position of prominence, and abundance has subsequently
decreased in all areas. As in 1978, there was no evidence
of improved recruitment which might have alleviated the
trend of decreasing abundance."

The Mid-Atlantic viewpoint was provided by Barbara
Stevenson. She stated that the Mid-Atlantic Council would
accept a 30 meat count, was opposed to separate management
regimes, and wanted a TAC equal to historical high landings.
A South-Atlantic Council opinion was given by Michael Street.
In contrast, he stated the South-Atlantic Council would
support some effort controls including possible limited
entry, wanted separate management regimes for each stock,
and opposed a 30 meat count. As stated above, the Committee
did not savor effort limitations; however, somewhat incon-
gruously, it decided to accept a Staff proposal that a re-
duction in fishing effort was needed and that the Staff and
Committee should attempt to reach an acceptable reduction in
effort throughout the entire fishery. The Committee did not
bend on its position regarding quotas. The Committee agreed
"that the management system would establish measures aimed
at achieving acceptable levels of economic benefits while at
the same time reflecting biologically acceptable levels of
resource exploitation. As such, the expected level of catch
resulting from fishing under a management system would de-
fine the OY, although this level would not serve as a measure
constraining overall catch." Mid-Atlantic Council represen-
tatives did not support this position.

Divergent opinions

At December 12 and 13, 19 79, Council meetings, divergent
opinions of the three Councils were related. According to
the Committee Chairman, Daniel Arnold, "The Committee is
currently facing complex political and resource problems
which must be resolved before the FMP can be finalized.
There are representatives from the Mid-Atlantic and South
Atlantic Councils representing significant scallop interests
who are advocating management systems which are not in har-
mony with the New England industry's articulated needs and
preferences". Council member Harvey Mickelson was outspoken

30

on this issue. His views were, as described by Barlow
(Maine Commercial Fisheries, January 1980):

"Stating that delays in the preparation of the
Scallop FMP had been caused by 'the unnecessary
introduction of comment, directions and require-
ments of people who are not voting and not respon-
sible for this Plan' , Harvey Michelson again expressed
his frustration with the time-consuming process of FMP
development. As he further elaborated on the situation
from his perspective, he described a situation in which
the work of the Scallop Oversight Committee was being
hampered by efforts to accomodate the interests of
scallopers from the Mid-Atlantic and South Atlantic areas
Based on lead Council status conferred on the New
England Council by the Secretary of Commerce and the
request by the New England sector of the industry to get
a plan in place, Michelson believed that the proper proce-
dure to follow was for the Scallop Committee and the
New England Council to prepare the Plan and then 'let
the other Councils do what they may after we have done
our work ' . "

Daniel Arnold noted that the Committee was to meet
before the end of the year to hopefully agree on means of
reducing fishing effort and also to discuss an industry sug-
gestion of a meeting between Canadian scallop industry rep-
resentatives and government officials, U.S. industry repre-
sentatives, and Council members "to explore the possibility
of joint agreement on matters relating to sea scallop manage-
ment. "

Strategies are adopted

On December 20, 19 79, the Committee met again and
formally adopted a management program for sea scallops.
Three Committee members, other New England Council repre-
sentatives, South Atlantic and Mid-Atlantic Council members,
industry advisors, and Staffs of NEFC, the Regional Office
and the Council were in attendance.

In spite of another South Atlantic Council request that
the Committee reverse its position on the 30 meat count and
increase it to 40 meats per pound, the Committee reaffirmed
its October vote to proceed with 30. The feeling was that
with a 40 meat count "more stringent effort controls may be
necessary. "

The Committee agreed that vessels should be required to
obtain a permit or license (with a minimum amount before
which none would be needed) ; vessels had to furnish NMFS with
specific statistical data; designation of the fishery as
"conditional" should not be considered as part of the plan;
and, the Council should commit itself to formulate some

31

additional measures of effort control (no deadline was set) .
Mid-Atlantic and South Atlantic representatives were asked
to acquire their Council's views on these issues as soon as
possible.

Other questions raised but not answered were:

1) Should there be regional allocations or shares
of the resource?

2) Should the Council adopt a limited entry-
program? Council staff recommended a limit on
the number of vessels which could participate
in the scallop fishery.

The Committee was also reminded that:

1) it had decided to recommend that the Plan have
an "implied" OY;

2) the relationship of a 30 meat count to Canadian
scallop regulations and imports of Canadian-caught
scallops into the U.S. needed to be addressed;

3) the Committee should look to NMFS for a complete
explanation of possible impacts of declaring the
scallop fishery "conditional". Council staff
recommended this declaration in order to dis-
courage new investment in sea scallop vessels.

The Committee had been guided in part by conclusions
drawn by the Staff in its analyses of sea scallop management
strategies. Those conclusions were:

1) The current levels of effort in the sea scallop
fishery, if maintained, can be expected to re-
sult in a lower average level of long-term pro-
duction from the resource than would be expected
at lower average levels of applied effort.

2) The recent high levels of effort in the sea
scallop fishery substantially increase the
level of biological risk to the resource. This
relatively high level of risk translates into
a) wide fluctuations in abundance, b) increased
chance of recruitment failure, and c) unexpected
or unpredictable behavior in stock dynamics.

For any or all of these reasons, increased risk
may negatively impact on the resource's ability
to support an economically viable fishery in
the future .

32

3) Historically, effort has been directed away
from the fishery as abundance has declined.
Thus^ despite the record, high ex-vessel
price levels of recent years, it is ex-
pected that there will be a net reduction in
fishing effort because of substantially de-
creased abundance over the next several years.
However, the current and forecasted high prices
can be expected to slow the rate of exit rela-
tive to historic observations.

4) At this time, given the conclusions in (3), it
cannot be scientifically demonstrated that
relatively modest reductions in effort (to
1978 levels for example) , imposed as man-
agement measures within the FMP, would

result in any measurable biological or economic
benefits in the future.

5) In the absence of a management system control-
ling effort through 1980, it is forecast that
key dredge vessels participating in the fishery
will experience a reduction in real income
during 19 80, and this trend is expected to be
maintained through 1981.

Results of the December Committee meeting and an
informal U.S. /Canadian industry meeting were related at
January 16 and 17, 19 80, Council meetings. According to
Dan Arnold,

"We did vote on three items. First a 30 meat count,
second the requirement that any vessel must obtain
a permit to participate in the scallop fishery, and
third, that there be some recordkeeping. There was
a lot of discussion on the general subject of
effort control. This has been a great problem.
The staff felt there was insufficient data at this
time to design any kind of effort control in the
plan. We settled on a statement that there would
be effort control. As the data base improves we
can develop an effort control system that will fit
the fishery. The Mid- Atlantic representatives took
this package back to the Mid-Atlantic Council and
the first three items they agreed to. The fourth
item of effort control they have problems with.
One thing was that we said we would have an effort
control system in place by a certain date, without
definition of what the effort control system would
be. They felt they could not agree with that. I
feel we are pretty close. We need some proper
lanauaae , before that fourth item will be included.

About a week ago I accompanied Mr. Costakes and

Mr. Enoksen to Halifax, N.S. for a discussion with the

33

Halifax Scallop Fishery members, and informed them
of our intent to have a 30 meat count. They were
not too receptive. We hoped we could get agreement
without going through the governmental process to
get this. Rejection means we will have to go
through the Secretary of Commerce to get prohibi-
tion on Canadian scallops larger than a 30 meat
count. Strong feeling that we want to prevent
small scallops from coming across the border., I do
not know at this time if we should recommend that,
(see newspaper account describing Canadian 1979
fishery and a fishermen's viewpoint on U.S. effort)

Council members raised three issues - was the 30 meat
count appropriate for Gulf of Maine scallops; why did the
Committee decide not to declare the fishery "conditional";
and, when would a final decision be made on the need for
and kinds of effort controls? Regarding the first question,
the Committee was charged to look at the Gulf of Maine scal-
lops and to return with recommendations at a later date. On
the need for a "conditional fishery" designation, it was re-
lated that the cons simply outweighed the pros and the
Regional Director felt that the designation, if wished by
the Council, should not be an integral part of the FMP.
With respect to effort control, Daniel Arnold stated:

"We have expressed in Committee that this item is
not dead. In fact, we have every intention of
continuing the investigation into effort control.
It is our intention that, at some time in the
future, an effort control system would be outlined,
developed, and included in the Plan. It may pos-
sibly be a future plan amendment."

On a nine to four vote the Council approved the 30 meat
per pound restriction, the need for vessel permits, and the
requirement that all vessels had to provide NMFS with speci-
fic statistical data.

A significant meeting

To provide operating guidelines for determination of
compliance with the 30 meat count restriction, the Committee
met on March 6, 19 80, and discussed a series of options pro-
vided by the Staff. The Council unanimously approved a
strategy whereby an average meat count of 10 one-pound-bag
samples drawn randomly had to be less than or equal to 30
meats per pound and that no single one-pound sample could
exceed a meat count of 40_. The latter stipulation was to
discourage fishing predominantly on small scallops.

The Committee also decided to include in the draft FMP
two options for public hearing comment on a minimum shell
size restriction - either a minimum size of 3.4" with some
percent tolerance or an average shell size of approximately 3,5".

34

35

NEFC scientists had noted that overall for Georges Bank and
the Mid-Atlantic a 30 meat per pound scallop equalled approxi-
mately 3.9" with a lower 95% confidence interval of approxi-
mately 3.4"; i.e., it was quite safe to assume that a 30 meat
count scallop would seldom have a shell size less than 3.4".

Unfortunately for the Committee, their best laid plans
were to be disrupted by a problem presented by Gulf of Maine
scallops. According to Maine industry representatives and a
Maine DMR scientist, the Maine sea scallop resource exhibited
slower growth rates than scallops from other areas. This
belief was the primary basis for an argument to exempt the
developing Maine FCZ scallop fishery from the meat count
measure. A Council Staff member, Guy Marchesseault ; however,
countered that "available evidence indicated that the termi-
nal size of Maine scallops was well in excess of a 30 meat
count and therefore the measure would not be discriminatory".

The meeting ended with a Committee request that Maine
collect biological data on the Gulf of Maine FCZ resource to
help resolve the question of a need for a possible Gulf of
Maine exemption, and with a discussion on kinds of data required
from permit holders.

A projected timetable

At March 25 and 26, 19 80, meetings it was noted that a comple-
ted draft Plan was expected for April meetings with tentative
June hearings and a July submission of the Plan to Washington.
The Plan was already twelve months behind schedule and some
lamented this delay because small scallops were being landed
especially by shell stockers operating in the Gulf of Maine.
Mid-Atlantic vessels, in particular, had switched to more
northern ports due to an extremely poor fishery in the Mid-
Atlantic area. Of note, efforts of these and local vessels
prompted the State of Massachusetts to enact a 3" minimum
shell size with a 10% tolerance (same as existing Maine size)
to prevent shellstocking of small scallops into Massachusetts
ports such as Gloucester. This practice had increased due to
availability of small scallops in the Gulf of Maine and
was frowned upon by most Massachusetts scallop fishermen who
wanted the small scallops to reach a size where they would
produce a greater yield.

Timetable revision

The timetable had to be revised; i.e., the Plan would
not be ready for Council review until the end of May, and
this revision prompted at April 30/May 1 Council meetings
discussion on the slowness of the Plan's development. Daniel
Arnold stated, "A number of times I have inquired as to how
the work has been going, and there have been continuing
emergency priorities on groundfish that set us back. I know

36

I have never insisted that scallops be put ahead. ! I am dis-
tressed that there have to be priorities. I feel that per-
haps I am getting criticism because the Scallop Plan has not
progressed fast enough." Douglas Marshall, Council Executive
Director, noted, "There has been a lot of pressure to get
some sort of document to NMFS in Washington, and there may
be some concern on the part of some Council members that we
should not proceed quite as fast".

These comments typified contrasting views of many Council
members; i.e., some wanted to complete the long overdue Plan
immediately and some wanted to spend more time on its devel- •
opment to insure its thoroughness.

State of Maine objections

On May 15, the Scallop Committee received a memorandum
from Spencer Apollonio, Commissioner of Maine DMR, describing
the newly developed offshore Gulf of Maine sea scallop fish-
ery (see memorandum and newspaper article) , and recommending that
Maine's exisiting 3" minimum size limit be adopted for the Gulf
of Maine scallops. He cited economic reasons for a 3" Gulf of
Maine restriction and stated rationale for his belief that pro-
posed Council regulations for the Gulf of Maine offshore stock
were not justified. He began a still continuing State of Maine
resistance to application of the proposed Council regulation
for the Gulf of Maine (see July 16 memorandum) .

Reaffirmation

On May 20, 1980, the Scallop Committee reaffirmed its
position that there be "no management induced regional shares
to the scallop resource components" meaning that the FMP
"would not attempt to preserve current or traditional regional
fishing practices of the scallop industries". The Committee
also reaffirmed the requirement that all vessels "which take
and land sea scallops in any quantity need a permit" and
decided that the permit was to be completely separate from
enforcement; i.e., a permit should not be forfeitted for
violations of sea scallop regulations.

At May 28 and 29, 19 80, Council meetings the full
Council unanimously approved the "no regional shares" and
"a need for a permit" part of the Committee's recommendations;
however, the issue of permit revocation was not as easily
resolved. After length debate, the Council reversed the
Committee's decision thus making it clear in the FMP that
violators could lose their permits. A statement by Philip
Coates, Director of Massachusetts Division of Marine Fish-
eries, reflected the view leading to this latter vote. That

statement was " fishermen have always operated with the

understanding that their permit is subject to revocation.
Establishing a provision whereby under no circumstances would
a permit be revoked is unacceptable from my standpoint."

37

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3

National Fisherman May 1980

39

Booming Me. Scallop Fishery
May Suffer From Overfishing

The Gulf Of Maine has become a small
bright spot in a generally Weak New
England scallop fishery.

The offshore areas of the gulf, carrying
distinctive names like Tilles, Three Dory
Ridge, Fippennies Ledge and Lubes
Ground, have always supported tome
scalloping activity.

But it wasn't until late last year that tome
of the larger scallopers from down the
Atlantic Coast and some convened Maine
bottom trawlers began massing on the
grounds, seeking an alternative to the
heavily fished beds off southern New
England. '

Approximately 20 offshore scauopen are
fishing regularly, each with crews of eight
to 12. The effort is keeping 200 to 300
shoreside workers in jobs that didn't exist
before the recent boom. Ex-vessel prices of
over $4 per lb. and landings averaging up to
40,000 lbs. per week along the coast have
combined to make a significant contribu-
tion to the economies of coastal com-
munities from Gloucester, Mass., to
Rockland. Me.

New Bedford, Mass., ot course, nuiw
its position as the top scalloping port,
reporting landings from Nantucket Shoals
and western Georges Bank that are up to •
five times greater than those in the Gulf of
Maine. But the smaller northern fishery is
still important though it has already become
controversial and its future remains unccrv
tain.

Most of the boats involved in the fishery
are "shell stocking," a fishing method
which some say is destructive because the
scallop shells are brought ashore for shuck-
ing rather than being shucked on the spot
and cast overboard.

The problems with this.-xrrdes say. are
twofold. First, the absence of shells in the
beds reduces the chances of scallop spat, or.
spawn, surviving because they have nothing
to attach themselves to for protection. And,
secondly, not stopping to shuck at sea gives
the fishermen more time to fish, leading to
a more rapid depletion of the stocks.

Countering these claims are fishermen
who say they see very little spat attached to
shells and also think -the shell stocking
creates jobs ashore which help distribute
-the wealth from the fishery.

. The issue of conservation is also in ques-
tion, with some saying the small scallops be?
ing harvested should be allowed to grow,
Morrill says. - -

Counts of scallop meats per pound range
from about 45 to 60, depending on who is
' shucking and how careful they are about
removing the meats.

If the scallop management plan as cur-
rently proposed by the New England
Fishery Management Council's scallop
committee were in effect today there would
be no Gulf of Maine fishery because the
committee is proposing a 30-meat count.

"Some people say they're too small and
some say they're just smaller scallops than
what you see down South," Morrill says.
* There is also the "cycle" theory, which
contends that the scallops are abundant
now and will die off if not harvested, an
idea undoubtedly being helped along by the
increased pressures from more and more
vessels bearing of the gulf boom and mov-
ing in to get their share.
*" "No one-I've- talked with thinks this is a
major new discovery," Morrill says, adding
that estimates of the economic life of the
beds range from a few months to a year.

There has been pressure from the smaller
vessels who have survived in the fishery very
quietly for years to exclude the bigger
vessds they fear will eliminate their fishery
in no time. In the absence of any federal
management scheme, however, this is
almost impossible.

Maine has a six-month residency require-
ment for the license necessary to land
scallops at the state's wharves, but this rule
has been easily circumvented by hiring a
Maine fisherman and putting the permit in
his name.

New Hampshire - and Massachusetts,
meanwhile, have no such rules and are as
close to most of the grounds as the Maine
pons.

T'Wait 'til this summer," says one
scaUoper out of Gloucester who has quietly
made a living off the gulf fishery for several
years. "They'll wipe us right out with all
those boats from down South . . . then
they'll go away and we'U be left with our lit-
tle boats and nowhere to fish."

— T. Sullivan

40

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41

Finally, in an effort to resolve the discrepancy between the
30 meat count proposed in the Scallop Plan and the Canadian
40 meat count, the Council voted to "request the Secretary
of Commerce, at the appropriate time, to use all possible
influence to seek resolution to the discrepancy over sea
scallop meat size". This vote occurred in spite of a Regional
Director suggestion that the Council could better address
this discrepancy in a more direct manner by way of a "posses-
sion" regulation set by the Plan. Council Staff had noted
that "developing a possession restriction was a difficult
issue and one that could possibly slow things down". Hence,
the Council took no position on a possession limit at these
meetings.

FMP Completion

At a June 24, 19 80, Committee meeting Council Staff
provided a memorandum reviewing Council action on the sea
scallop FMP which was judged by the Staff to be complete with
a few exceptions. This review is included here.

The Committee, using this review, "hastily" approved
the Plan in order to submit it to the Council the following
day. The meeting did not begin until very late in the after-
noon since a quorum was not established until then.

During the next two days the Council reviewed the Plan
and approved it for submission to NMFS Washington, but sub-
ject to a final review and approval of the completed docu-
ment by the Scallop Oversight Committee. This was necessary
since some sections of the Draft were "reserved"; e.g., con-
tinuing fishery management program, and needed to be written.
The purpose of Council approval before the Draft was finalized
was to save a month's time; i.e., to submit the Draft to NMFS
to begin the formal review process and to submit reserved
portions later on. It was expected that the accompanying
DEIS would be completed at the end of July then submitted to
EPA as a "Draft Discussion Paper" to start the clock on that
public review process leading to mid-August public hearings.

The Draft was approved in spite of the hesitancy of
some members who did not like voting on Plan which was not
complete. Assurances that all reserved sections would be
reviewed by the Committee prior to submission to Washington
assuaged these individuals' concerns.

The Council also decided that "possession of scallops
of a count greater than the Plan-recommended size be pro-
hibited at the level of first transaction in the U.S.".

42

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44

Continuing review

The Committee met on July 21 to review the reserved
portions of the Scallop FMP which were to be submitted to
Washington sometime in August. At this meeting and at July
30 and 31, 19 80 Council meetings some additional insight
into the review process was provided by the Executive Direc-
tor who stated that once in Washington the FMP/EIS would be
reviewed by the NOAA Office" of Environment and Conservation
before being filed with EPA. After filing with EPA public
hearings would be scheduled at the end of September or early
October. The Plan was also forwarded to the Regional Office
of NMFS for its internal review.

Comments received

On October 20, 1980, the Council received results of a
critique of the Draft EIS/ Discussion Paper by Washington
and the Regional Office. Revisions were requested to address
three principal concerns: the EIS did not contain all nec-
essary information in required format; the identification
and discussion of issues and alternatives needed to be ex-
panded; and some discussions needed to be broadened to
clarify content.

The "long" review period and nature of some of the
comments disturbed many Council members. The central Council
concern appeared to be the requirement that every FMP be sub-
mitted with a DEIS and a Regulatory Analysis (required by
Executive Order 12044) . This concern led to a long discus-
sion on results of an October Council Chairmen/Executive
Directors meeting.

Council Chairman Robert Jones stated,

"There was a rather long discussion of the plan
development process at the meeting. One of the
questions involved the so-called 'fish policy
group' which a number of people had made reference
to as the faceless bureaucracy that FMPs go through.
There was a concern not unlike what was expressed
here yesterday as to, "who are these people that
review the plans?" Mr. Leitzell addressed this
matter to some degree indicating that this group
consisted of himself, Dick Frank's Deputy in NOAA,
NOAA General Counsel, and Chief of the Office of
Planning and Policy. It is this senior policy-
making group in NOAA/NMFS which in fact has the
final say in regard to approval of plans and amend-
ments. To date there has been no backing-down from
the judgement by this policy group.

45

There was some discussion about Regulatory Analyses
and Environmental Impact Statements. I think one
of the things that became clear was that nobody
really likes these two ancillary aspects of the Plan,
development process. However, it was clear that it
was going to be necessary to prepare the regulatory
analysis and in particular the environmental impact
statements with the same standards that we prepare
the fishery managment plan. There was concern ex-
pressed that most of the Councils weren't really
doing them in the way that NEPA or the Executive
Order had indicated. The point being that these
analyses should be done in concert with the plan
development rather than sitting down after the
fact and developing the Environmental Impact State-
ment or Regulatory Analyses. I am sure we will be
seeing some additional guidelines in that regard.

There was some discussion of the relationship be-
tween the Regional Offices and the Washington of-
fice and the Councils. Terry Leitzell said that
it was his policy that in fact the Regional Offices
had a significant level of authority in the review
and approval process of plans. At least two out
of the three Regional Directors that were present
seemed quite surprised at the statement. It is
pretty clear that there is not a general under-
standing of just exactly what the policy is in this
regard. I think the point was made very clearly
that all the Councils felt there should be substan-
tial additional involvement in this whole process
by their respective regions and that most of the
problems seem to center around the Washington of-
fice i I suspect we may be seeing some changes in
this regard, and I suspect they will be favorable
from our standpoint."

Jacob Dykstra added,

"I want to make a few comments on the EIS situation
As I understand it, the primary responsibility con-
cerning EISs rests with people at the Environmental
Protection Agency and CEQ. These people are pri-
marily supposed to be the watch dogs of the en-
vironment. The representatives of the Councils I
heard speak at the San Juan meeting said that it
was their understanding that there have been prac-
tically no problems with these agencies on any of
these EISs. FMPs go to them with the EIS and they
sign off on them practically automatically, but the
guidelines in NMFS/NOAA are far stricter than those
of EPA. It gives the impression at least to me
that NMFS/NOAA has decided to be the busy-bodies in

46

this particular area. They have just assumed the
authority that, look, we are the ones that are
going to nit-pik the environmental impact state-
ments and make sure that everybody does everything
all right and follows the law just the way the
guidelines say. If this indeed is the case, I
think this is one area that is very important to
look at. We have to look at whether we want to
get some legislation which says NEPA does not
apply. Perhaps we can keep certain pieces which
may be good. It just seems to me that this NEPA
business and the interpretation of NOAA is some-
thing that is really screwing up the works."

Robert Hanks, then Deputy Director of NMFS Regional
Office countered:

"I would just like to comment that this is not just
a dabbling on the part of NOAA/NMFS in the process.
It is a parallel review process. NEPA takes a
path and the FMP takes a path. This more intensive
look at the quality of the EIS.S results from CEQ
looking at the problem nationally. They have told
us very clearly that they will not accept EIS's any
longer that do not meet certain standards. There-
fore, if we are going to proceed with the develop-
ment of plans and get them through the system, they
are going to have to be of a better quality than
they have in the past."

Jack Dunnigan agreed with Mr. Dykstra and stated,

'"I think Jake is absolutely correct when he says
that NOAA would like to hold its actions to very
high standards of environmental review. It isn't
really accurate to say that CEQ and EPA are the
agencies that are in control of this process....

I think NOAA does try to set some very high stan-
dards for environmental review. It believes it is
an environmental agency, and therefore, does have
to hold its own actions to some very strict scru-
tiny. It is true, as Bob says, that there has been
some criticism leveled as NOAA very recently by the
Council on Environmental Quality with respect to
the overall quality of its EIS's. That has resulted
in a general tightening up of NOAA's approach to
EIS's coming out of the agency."

47

Addressing the problems

To address NMFS/NOAA problems with the EIS/FMP, a meet-
ing of Washington and Regional Office people with the Scallop
Committee and Council Staff was set for November 10, 19 80,
and reported on at December 3 and 4, 19 80, Council meetings.

According to Daniel Arnold, there were no serious
problems with the necessary modifications of the EIS and FMP,
and the rewrite was to begin in mid-December. Douglas
Marshall noted that the majority of changes were in the EIS
and were principally format or presentational changes. There
were a few changes in the text of the Plan but none were
substantive; i.e., none would change any strategies or policy
decisions on measures involved and included in the plan.

The Committee was given the go-ahead to resubmit the
DEIS/FMP when the revisions were made. Council approval
was not considered necessary.

Resource status

In December the NEFC presented, its stock status report.
That report read,

"Sea scallops (Placopecten magellanicus) occur along
the continental shelf of North America from the
Straight of Belle Isle south to Cape Hatteras,
North Carolina. Sexual maturity may occur as early
as age 2, but scallops less than 4 years old proba-
bly contribute little to total egg production be-
cause of low fecundity. Spawning occurs in late
summer or early fall, varying slightly between
years and areas. Sea scallops may live to approxi-
mately age 20.

The 1979 total U.S. sea scallop catch of 14,256
metric tons (MT) was about 2% lower than the 19 78
catch of 14,482 MT. USA Georges Bank landings in
1979 were 6,666 MT, a 19% increase from the 1978
catch of 5,598 MT. The 19 79 USA Middle Atlantic
catch of 7,156 MT was 17% lower than the 8,6 41 MT
landed in 19 78. Canadian catches on Georges Bank-
Middle Atlantic area were 2 3,64 3 MT, 11% less than
the 26,671 MT caught in 1978.

The 19 79 NMFS sea scallop survey indicated that,
as a result of the heavy fishing pressures applied
over the last few years, the 1972 year class no
longer held its position of prominence, and abun-
dance had subsequently decreased in all areas. As
in 1978, there was no evidence of improved recruit-
ment which might have alleviated the trend of
declining abundance.

48

As anticipated early in 1979, decreased abundance
in the South Channel and New York Bight areas has
resulted in a shift of more U.S. effort to the
Northern Edge and Peak of Georges Bank which, in
conjunction with sustained pressure from the
Canadians, appears to have significantly reduced
the abundance in that area. Without significantly
improved recruitment, abundance will continue to
decline unless fishing effort (and mortality) is
reduced. "

Hearings

A series of public hearings were held from Maine to
North Carolina to solicit comments on the DEIS/FMP. As ex-
pected views were diverse particularly on appropriateness of
the 30 meat count and shell size restriction and wisdom of shell
stocking. Regarding meat count, most commenters felt that
it was more sensible to begin the Plan with a 40 rather
than a 30 meat count. This position was emphasized by
James Costakes, General Manager of the New Bedford
Seafood Producers Association, who .believed that the
best opportunity to reconcile differences between
Council and Canadian meat counts was by beginning the
Council Plan at 40 count (with a 10% tolerance) with the
expectation that the count could be reduced "when it
makes sense for the fishery and the industry". He noted
that the existing Canadian Plan had a 40 meat count
provision with a 25% tolerance effectively bringing the
average count for any trip up to 50 . He was also ada-
mant that, "the immediate imposition of a 30 meat count
would result in very significant short-term losses (to
the industry) and could have severe long-term conse-
quences". • His entire testimony is included here.

Many felt that shellstocking should be prohibited.
James Costakes noted that this prohibition would be a
strong conservation measure. In Maine, however, while
it was conceded by some that shellstocking was less
desirable than shucking, the practice was still consid-
ered to be of great importance to some ports, especially
Portland. Of note, Portland shellstockers not only
defended their way of harvesting but argued that a shell
size restriction larger than 3" would put them out of
business. They suggested that the FMP adopt Maine's 3"
minimum shell size.

The proposed possession limit was not as contro-
versial. As stated by Daniel Arnold at May 26 and 27,
1981, Council meetings, "the possession issue surfaced
in every hearing. Everybody was in favor of the inclu-
sion of the possession mechanism in the Plan. My own
feeling is that we should go for it as strongly as
possible. "

49

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52

Committee considerations

At a June 18, 19 81, Committee meeting, the Staff drew
five conclusions based on the public hearings and suggested
options for Plan modifications. The conclusions were:

1) The industry supports the use of meat count as

a measure in the FMP, but believes that the meat
count adopted should not place U.S. harvesters
at any disadvantage relative to imported scal-
lops from Canada. Various resource and industry
concerns were expressed in opposition to a 30
count U.S. standard. This opposition stems
from (1) a current scarcity of 30 count scal-
lops and (2) fear of being disadvantaged by im-
ports of small scallops from Canada.

2) There was broad support for an initial minimum
size of 40 meats per pound. However, when
asked, industry members generally favored even-
tual decreases in the meat count, but only on
the condition that such changes be reflected

in Canadian regulations. .In any event, there
was general support for having the ability to
make timely changes in the meat count standards
as the Council perceived changes to be appro-
priate.

3) The industry generally supports a tolerance on
the meat count standard. Most prefer the 10%
tolerance value included in the Canadian regu-
lation.

4) Representatives of the shellstocking sector of
the fishery (principally from. Maine and North
Carolina) prefer that the shell size equivalent
of the meat count measure be in terms of a
minimum size. Some shellstocking representa-
tives also called for a tolerance on the number
of shells that could be landed below the mini-
mum size.

5) The industry strongly supports the concept of
a prohibition on the possession of scallops of
a meat count higher than that allowed by the
plan at the point of first transaction in the
U.S. Such a prohibition would apply to both
domestically landed and imported scallops.

The Commitee recommended for Council consideration:

- 40 meat count average for vessels shucking sea
scallops at sea effective upon initial implementa-
tion of the FMP; 30 meat count average for

53

shucked scallops effective one year after imple-
mentation and thereafter until otherwise amended.

- 3 1/4" minimum shell height for sea scallops

landed in the shell effective upon initial imple-
mentation of FMP; 3 1/2" minimum shell height for
sea scallops landed in the shell effective one
year after implementation and thereafter until
otherwise amended;

- standard for recreational fishing same as for
commercial vessels landing scallops in the shell;

(The recommended minimum shell height is expected to result
in the corresponding average meat count when the scallops
are shucked.)

- a 10% tolerance would be applied to the meats per
pound measure;

- a 10% tolerance would be applied to the minimum
size measure in both commercial and recreational
fisheries;

(Procedures for sampling the catch to monitor compliance
with the provisions of the Plan will be specified in the
regulations. )

The Committee recommends "possession at the point .
of first transaction in the U.S." be adopted in the
FMP as the basis for monitoring compliance with
the meat count/shell height management measures.

This language clarifies the intent of the Council
regarding the implementation of the Plan's control measures.
It eliminates uncertainty in monitoring compliance by clari-
fying the shared responsibility of the parties involved in
the transaction and expanding the time frame for enforcement.
In doing so, it enhances the effectiveness of the meat count/
shell height control measure for achieving Council objectives
and conserving the resource. It is noted that the Committee
recommends that the Council Staff work with the NMFS Regional
Office and Regional NOAA General Counsel Staffs to develop
appropriate language for implementing the Council's intent
regarding possession, particularly in view of possible im-
plications for imported sea scallops.

A significant, review

On June 15, 1981, the Council received the NMFS review
of the DEIS/FMP (see letter) which focused on five critical
issues "upon which plan approval is contingent". The FMP
did not:

54

UNITED STATES DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric Administration

NATIONAL MARINE FISHERIES SERVICE

Northeast Regional Office

14 Elm Street

Gloucester, Massachusetts.

<$

gpfl M/fl^s

,^v* RECEIVED "S/fy

V

June 12, 1981

Mr. Robert Jones

Chairman

Mew England Fishery Management Council

Suntaug Office Park

Saugus, Massachusetts 01906

Dear Bob:

JUN15 if;-£1

This Is to advise you of the completion of the National Marine Fisheries
Service review of the New England Fishery Management Council's draft Fishery
Managment Plan for the Atlantic Sea Scallop Fishery, and to provide you with
our comments.

The scallop plan is the victim of changed circumstances, which is unfortunate,
since all of us are aware of the considerable time and effort, over a period
now of several years, devoted by the Council, Industry advisors, the Council
staff, and the National Marine Fisheries Service. The changed circumstances
will force us not only to extend our thinking, but to improve the plan and the
management approach. This should result in a more flexible plan which Is both
able to account for changing circumstances and which is more versatile and
efficient for managing an extremely Important fishery resource.

The results of public review of the plan are clear and suggest major
modification of the plan. Unless we are able to determlr ■ and demonstrate
that the proposed thirty meat count measure will not seriously impair the
viability of large segments of the industry in the immediate future, a less
stringent initial specification is indicated. I believe we should begin with
a meat count which provides some resource conservation benefit, and build into
the plan flexibility under established criteria which will permit changes in
that meat count specification as permitted by changes in resource availabilty
so that we can work towards an optimum conservation measure. Most of the
enclosed comments discuss methods and requirements of such a flexible
approach.

My staff and the staff of the Northeast Fisheries Center are available to
cooperate with and assist the Council In developing a flexible management
program. If you or the staff have any questions, or need further
clarification of our comments, please contact Bruce Nicholls, the plan
coordinator.

Sincerely,

Allen E. Peterson, Jr.
Regional Director

Enclosure

55

1) discuss resource condition and fishery during
the past year;

2) establish a management framework versatile
enough to recognize or adjust for changes in
the fishery similar to those recently experi-
enced;

3) address consequences of Canadian activities on
the fishery and on attainment of plan objectives;

4) state clearly how each management alternative
related to plan objectives. It was especially
deficient in its analyses of immediate and
short-term impacts of a 30 meat count;

5) provide a concise statement of rationale for
the decision to select the preferred alterna-
tive.

Many other "deficiencies" were noted. The upshot of
this review was that the timetable for getting the plan back
to Washington was considerably delayed.

Extensive debate and varied opinions

At June 30 and July 1, 19 81 meetings, the Council acted
on Committee recommendations for Plan revisions. The first
consideration was the meat count provision, and this raised
many eyebrows. Some individuals, such as Jacob Dykstra,
were concerned that the proposed action was totally inflexi-
ble in that the meat count automatically would decrease to
30 one year after plan implementation. Others, notably Nancy
Goell of the Mid-Atlantic Council, argued that the 30 meat
count should be implemented immediately for stock conservation
and that the proposed 10% tolerance with a 40 meat count
would effectively result in a too high 44 count. A New
Bedford scallop industry representative, Roy Enoksen, count-
ered that Canadians were fishing the small scallops; there-
fore, conservation was already being prevented.

To address the issue of flexibility, after extensive
debate, the Council eventually voted to modify and accept a
Staff suggestion provided in a June 12 memorandum. It de-
cided to require:

40 meat count average for vessels shucking sea
scallops at sea effective upon initial implemen-
tation of the FMP; 30 meat count average for
shucked scallops effective one year after imple-
mentation except that the Council, upon a finding
of fact that conditions warrant, may authorize the
Regional Director to change the size limit. Such

56

changes would be based on pre-set criteria for a
range of 40 to 30 meat count in increments of not
more than 5 units at a time with a frequency of
not more often than once every 12 months .

The record is clear that the Committee and then the
Council were unsure of their intent regarding whether they
wished to go to 30 meat count one year after plan implementa-
tion or to make the change optional, and whether they wanted
the Council or the Regional Director to have the authority
to make changes. The vote only indicated that the Council
had agreed in principal with the strategy of beginning at
40 and going to 30 after a one year period. According to
some Council members and the Staff, "There is nothing in the
motion that now requires the Council to move from 40 to 30
meat count within any defined time period". This position
was subsequently debated further at a July 17 Committee meet-
ing and taken up again by the Council at its July 28 and 29,
19 81 meetings.

Other positions taken at the June 30 and July 1, 19 81
meeting were that:

1) the 10% tolerance for the meat per pound re-
striction be eliminated;

2) the 10% tolerance would apply to the minimum
shell size measures in commercial and recrea-
tional fisheries.

3) no attempts be made to find means to accomodate
state territorial and inland waters statutes
relative, to size limits and possession;

4) perhaps most importantly, the Council agreed
that possession up to and including the point
of first transaction in the U.S. be adopted
as the basis for monitoring compliance with

the meat count/shell height management measures,
and the possession measure was an inseparable
part of the Plan.

Meetings for clarifications

At its July 17 meeting the Committee decided that the
move from 40 to 30 meats per pound with corresponding shell
size changes (3 1/4" to 3 1/2") should be automatic after
one year of plan implementation and that the flexibility in
the measure should be exercised thereafter based upon a
.finding of facts by the Regional Director and concurrence by
the New England Council and in consultation with the Mid-
Atlantic Council. The meat count (shell size) was to remain
at 30 (3 1/2") for at least one year. The frequency and meat

57

count interval remained the same as previously decided.
Changes in the meat count restriction by the Regional Direc-
tor would occur automatically unless changes were specifi-
cally disapproved by the New England Council.

This intent was conveyed at July 28 and 29 Council
meetings, and immediately this met with resistance. Harvey
Mickelson sought to delete the automatic move to 30 meats per
pound one year after the Plan was in place. He wished all
changes in meat count to be optional; however, his efforts
were in vain. Many Council members believed that if left
optional, the count would remain at 40 one year after the
plan was in effect particularly if industry did not favor
the decrease in meat count.

The reader is referred to June and July, 19 81, Council
minutes for detailed accounts of deliberations (author can-
not do it justice) .

A few changes before submission

December 8 and 9, 1981 Council, meetings involved discus-
sions and changes in the procedure for in-season adjustments
in the meat count and minimum size. Utilizing Committee rec-
commendations, the Council approved the following judgement
criteria:

"The decision to alter the management measure
specification rests on a determination that the
objectives of the Fishery Management Plan would
be achieved more readily, or would be better
served through an adjustment to the current meat
count or minimum size. Specification may not be
altered unless at least one of the following condi-
tions exists in the resource, fishery or industry,
subject to the condition that in no case would such
an alteration result in a reduction in expected
catch over the following year by more than 5% from
that which would have been expected under the
existing management measure specification.

1) International inconsistencies exist in the
management measures applied to sea scallop
stocks in areas harvested by both domestic and
foreign fishermen, and such inconsistencies
provide foreign fishermen with an advantage
over domestic fishermen that can be demon-
strated to adversely affect the domestic fish-
erman;

2) Analysis of the size distribution of sea scal-
lops shows that more than 50% of the harvest-
able sea scallop biomass is at sizes smaller

58

than those consistent with the prevailing
management measure specification and that a
temporary relaxation of the specification
would not jeopardize future recruitment to
the fishery.

Along with discussions on the appropriateness of these
criteria was the reoccurring complaint that the Plan should
not require an immediate move to 30 meat count one year
after the Plan's implementation. James Costakes, in particu-
lar, chastised the Council for this mandatory action.

In defense of the Council's decision, Guy Marches seault
stated,

"I can only respond to the extent that we have in
the short-term analysis had an opportunity to take
a look at what the resource is expected to look
like in the next two years. This summer, the 19 81
assessment has provided us with a good basis for
projecting ahead for 1982 and 1983. It demonstrates
to us that a move to a 30 meat count would not
result in a significant impact. Moving to 30 is
generating less than a two million dollar impact.
We feel that whatever action it is will be insig-
nificant and will not generally affect vessels
shucking scallops."

Final FMP submission

On January 11, 19 82 the final FMP was sent to William
Gordon, Assistant Administrator for Fisheries (see letter) .
Draft regulations were to follow, and these were reviewed by
the Committee at a January 25 meeting and approved by the
Council during January 26 and 27, 19 82 meetings.

Approval expected

On February 24 and 25, 1982 meetings Douglas Marshall
reported,

"The Scallop Plan was reviewed on Friday, February 19,
19 82. The reviewers decided that the Scallops Plan is
approvable, and there is every expectation that it will
be approved. The region has recommended that the Scal-
lop Plan be implemented on an emergency basis. The
argument is that the 19 79 year class coming up is very
large. The scallops would be very vulnerable on Georges
Bank. There is some additional work the staff has to do
The revisions are on the supporting documents, not on
the Plan. We are looking at the end of next week for
completion. The target date for implementation is the
middle of May. "

59

NEW ENGLAND FISHERY MANAGEMENT COUNCIL

SUNTAUG OFFICE PARK. 5 BROADWAY (ROUTE 1)

SAUGUS. MASSACHUSETTS 01906

AUGUS 617-231-0422 January 11, 1982 FTS 6-223-3822

Mr. William G. Gordon

Assistant Administrator for Fisheries, NOAA

National Marine Fisheries Service

Page 2 Building

3300 Whitehaven Street, N.W.

Washington, D.C., 20235

Dear Mr. Gordon:

Enclosed for your review and approval under the Magnuson Fishery Conservation
and Management Act is the Atlantic Sea Scallop Fishery Management Plan. Fifty
additional copies are being sent to your office under separate cover.

This final version of the FMP has been carefully revised to address the issues
raised by NMFS on the March, 1981 draft (Peterson letter dated June 12, 1981).
Further, various modifications have been made to the FMP reflecting the concerns
raised at the series of public hearings held on the draft FMP/EIS in April of
1981. In particular, the Council has chosen to specify the meat count management
measure at 40 meats per pound for the first year of plan implementation, to be
followed immediately by a reduction in meat count to 30 meats per pound, with the
provision that the meat count specification may be adjusted thereafter, within
limitations, by the Regional Director. The Council believes that this revision to
the plan is responsive to prevailing resource conditions, provides for meaningful
resource conservation in the context of a continuing management program, ang
accomodates the need for a flexible and responsive management system.

Bound with this FMP is a comoined Final Environmental Impact Statement and
Regulatory Impact Review. The latter concludes that implementation of the Sea
Scallop FMP is a "non-major" action for the purposes of Executive Order 12291.
Specific sections of the EIS/RIR that support this conclusion have been highlighted
in the document. We expect to be submitting draft proposed regulations shortly.

We have worked closely with the various offices of the National Marine
Fisheries Service in the development of this FMP. We would like to thank you,
Allen Peterson, and Bob Edwards for the cooperation and careful attention given the
Council in connection with the informal review and final drafting of these
documents. We look forward to early approval of the FMP so that meaningful
conservation and management of this important fishery resource may proceed in a
timely manner.

Sincerely,

New England Fishery Management Council
Jacoo J. Dykstra

by: Douglas Gj? Marshall
Executive Director

GM/lg

cc: Allen E. Peterson
Council Members

60

An accomodation for Canada

At an April 20, 1982 Council meeting, the Regional
Director reported,

"The Scallop Plan is waiting for final signature.
We expect that the emergency regulations will be
agreed to and will be implemented around May 15,
19 82. There have been ongoing discussions with
the Canadians. We have tentatively agreed to
accept certified Canadian products. We expect the
Canadians to prepare a proposal, and we will then
develop a memorandum of understanding. There has
been no response received yet from the Canadians.
If they don't respond, then the regulations would
apply to Canadian scallops the same as they apply
to American scallops. We made it clear to the
Undersecretary that their regulations would have
to be consistent with our regulations. We recog-
nize that someone would have to go first and that
there would be a time delay. We have, however,
managed to move closer to a common goal of scallop
management. "

A Canadian scallop export certification program was
prepared by Canada. This program, acceptable to the Regional
Director, was as follows:

1) Every scallop shipment for export from Canada
will be accompanied by a serially numbered
Government of Canada Certificate of Origin.

2) The Certificate shall include, as a minimum
requirement, the following information:

a) Shipper and/or packer

b) Actual destination in the importing country

c) Date of shipment

d) Details respecting the amounts and product
forms

3) In the event the shipment includes bagged scal-
lops, which are not normally marked, the
Certificate shall be certified by the Department
of Fisheries and Oceans Officer to the effect
that the scallops in the shipment were caught

by Canadian fishermen subject to Canadian scal-
lop management regulations.

4) For bagged scallops, a self-locking, serial-
ized, single-use, tamperproof Government of
Canada tag will be affixed by the shipper in a
manner that will necessarily destroy the bag

61

or the tag after the initial and intended use.
A description of the process and of the tags
will be provided as soon as they are developed.

5) In the case of processed product (e.g., frozen,
breaded) , the Certificate will include all the
details noted above except the certificate will
not be signed. Note: the existing Fish In-
spection Regulations presently in force require
that processed products be labelled with the
following information, requested by NMFS , i.e.,

a) Name and address of shipper

b) Product and weight

c) Product of Canada label

In addition to the above, there is also a
regulatory requirement for all master cartons
to be coded to identify the fish processing
establishment, as well as the day, month, and
year of processing.

6) In the event a shipment is to be delivered to
more than one location, a separate Certificate
will accompany each portion of the load.

A need to address Canadian concerns about the Sea Scallop
Plan had been clear. Canadian fears were repeatedly expressed
in their news media (see newspaper articles 9/17/81, 2/15/82,
and 3/11/82). Additionally, poor Canadian landings and de-
clining prices (see 6/15/82 news article) had especially
fomented Canadian agitation over the Plan. Fortunately,
the Certification Program appeared to dispel some Canadian
criticism (7/1/82) .

Declining stocks

Canadian (and U.S.) fishermen's observations on declining
abundance of Georges Bank sea scallops were substantiated by
NEFC assessments (see Serchuk, et al. 1982) which indicated,

"Despite recent increases in landings and total
revenues, analysis of both commercial and re-
search survey data indicate that resource abundance
in almost all fishing areas had begun to decline."

and,

"The mean size of scallops sampled in 1981 from
USA landings was the smallest in the 1965-1981
time series implying a significant reduction in
cull size (size retained for market) in the com-
mercial fishery."

62

Saturday, October 17, 1981 THE CHRONICLE-HERALD THE MAIL-STAR

Proposal could harm
scallop market in U.S.

By MARILYN MacDONALD
Staff Reporter .

A proposal by the Now England
Fisheries Management Council for man-
agement of the scallop fishery could en-
danger the Canadian scallop market in
the UniUd States. v

Roger Stirling, executive director of
the Seafood Producers Association of
Nova Scotia (SPANS), said U. S. mar-

-kets for the inshore scallop fishery could
be wiped out, and the offshore scallop
fishery's U. S. markets cut. if a proposal
for scallop management is enacted Into

*l»w.

Responding to a Canadian request
fcf some type of management regula-
tions in the American scallop fishery, the
New England Fisheries Council proposed
implementing a meat count of 40 scallops
per pound caught. That is similar to Ca-
nadian regulations, but the problem oc-
curs when the Americans insist upon im-
posing that meat count to scallops being
exported to U. 8. customers.

V Mr. Stirling said that while Canadian
scallop fishermen must have an average
ef 40 scallops per pound when they are
landed, the scallops are then graded by
size to acrommodate demands of cus-
tomers.

Some customers require smaller

"scallops so some package* exported to
the United States may contain as many
as 50 scallops per pound. The American
regulation includes border checks to en-
sure there are no more than 40 scallops
per pound in a package-

This "possession limit," as It Is

'eased, would effectively cut out some ex-
ports from the offshore scallop fishery

: fj>4 practically all exports by the inshore

fishery, such as in the Bay of Fundy.
where the scollops never grow large
enough for a meat count of 40, Mr. Stirl-
ing said.

"What they are doing in response to
the Canadian initiative to ask for man-
agement measures is putting In manage-
ment measures that hurt us."

He noted that what Canada initially
asked the United States to do was limit
entry to the scallop fishery, but that was
turned down immediately. Setting a
meat count similar to Canada's would re-
duce the amount of scallops the Ameri-
can scallop fishermen are taking from
Georges Bank, putting Canada on an
equal footing. But if they extend that
management to border cheeks, it defeats
the entire purpose. Mr. Stirling said.

The Canadian industry concerns
were put to American industry officials
last weak during a meeting between the
two groups m Boston. While nothing was
settled during the discussion, the Ameri-
cans were at least made aware of the
Canadian concerns. Mr. Stirling said.

He added that the meeting was held
only to discuss the scallop management
proposals and nothing was discussed con-
cerning an interim agreement on the
Georges Bank fishery. Mr. Stirling said
that while an interim agreement binding
until the boundary dispute is settled is
favoured by the Canadian fishing indus-
try, it appears impossible.

"The American contingent at last
week's meeting said they did not want to
discuss an interim agreement," he said.

Mr. Stirling predicts that if Canada
agrees to send the boundary dispute is-
sue to the International Courts at the
Hague, it could be three to five years be-
fore a daeiaton is rendered.

63

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66

— THE SOU'WESTER, Yarmouth, N.S., Thursday, July 1, 1982

Canadian scallop sales resume
on normal basis to U.S. market

It's now business as usual for Canadian scallop pro-
cessors and their U.S. clients.

DFO Minister Romeo LeBlanc announced in Ottawa
recently that the U.S. market for Canadian scallops
had been re-opened.

An American conservation plan called for a size limit
of 40 meats per count on all scallops landed in the U.S.
the restriction also applied to Canadian-caught
scallops imported into the United Stales.

The meat count regulation was being applied at the .
U S -Canadian border, and Nova Scotian processors
felt this was a non-tariff barrier which prevented ex-
porters from filling specific orders in the U.S.

All this has changed and now all scallop shipments
will be accepted in the U.S. as long as they carry cer-
tificates showing they were landed legally in Canada

"We're naturally very pleased that the United States
has adopted regulations to conserve this stock." DFO
Minister Romeo LeBlanc said. "This is an important
step in saving the very lucractive scallop fishery."

Canada exports more than SO percent of its scallop
catch to the United States and sold 10.454 metric tons
with a value of close to $100 million to that country in
ISM.

According to Kent Sweeney of Sweeney Fisheries in
Yarmouth, the regulation change won't have too much
effect on the Yarmouth and Saulnierville offshore
fleets.

"We basically stick to the 40 meats count, but the
western shore fleet should benefit because they carry
larger crews and need more scallops to make fishing
trips worthwhile," he said.

The agreement struck between Canada and the U.S.
re-sea scallops looks like this: From June IS to July IS
• 40 meat count with a 15% tolerance and after July IS.
40 meats with normal enforcement discretions.

Canada agreed to continue its trip and catch quotas
and license limits.

The deal has some U.S. scallopers feeling that Cana-
dian scallops smaller than the 40 meats regulation will
be imported into the U.S. and they are right, at least
until July 15.

The agreement won't be discontinued until, both
countries have been consulted about problems.

The new scallop regulations have run into some dif-
ficulties, especially in Maine. As reported to the Com-
mercial Fishing News, a group of fishermen operating

near Grand Manan are Finding that while the scallepe
they harvest are of or over the legal shell size of 3 v4 in-
ches, these scallops shell out a meat count as high as SO
per pound.

Over forty scallopers from the Jonesport, Maine,
area are affected by the 40 meats ruling and recently
met with Maine members of the New England fishery
Management Council.

The New England Council plans to further reduce the
meat count to 30 next year in a move to protect East
Coast scallop stocks, a move which Neva Scotiaa
scallopers have been hollering for for a long time

Pat Amirault, executive director of the scallop sec-
tor of the Nova Scotia Fishermen's Association is a bit
peeved at the price members of his association are
receiving for scallops.

Up until recently, Yarmouth and Saulnierville
scallopers were getting basically what New Bedford,
Mass. fishermen were receiving. But of late New Bed-
ford prices have soared while prices here have remain-
ed the same.

Fishermen in New Bedford receive C 50 to S3.S0 a
pound, U.S., while southwestern Nova Scotian
scallopers are still receiving $3.10.

67

WOODS HOLE LABORATORY REFERENCE DOCUMENT NO. 82-06

Review and Assessment of the Georges Bank, Mid-Atlantic and Gu)f, of..^^
Atlantic Sea Scallop (Placopecten maqellanicusr^tesaurcjes

Fredric M. Serchuk, Paul W. Wood, Jr., and Robert S. Rak

Summary

The USA Atlantic sea scallop fishery is one of the most important commercial
fisheries along the eastern coast of the United States. Total annual USA landings
during 1977-1981 from the Georges Bank, Mid-Atlantic, and Gulf of Maine resources
attained record levels, averaging 12,800 metric tons of meats, the highest for any
five-year period. In 1980 (latest data available), USA scallop landings generated
110.4 million dollars in ex-vessel revenues, an all time record. Despite recent
increases in landings and total revenues, analyses of both commercial and research
survey data indicate that resource abundance in almost all fishery areas has begun
to decline. This report reviews recent fishery and resource conditions within each
principal fishery region and provides an evaluation of these conditions relative to
historical patterns and likely future events.

Georges Bank

Total international (USA and Canada) commercial landings in 1981 were 16,200
tons, 49% higher than in 1980, and the third highest annual catch ever. USA 1981
landings were 8,200 tons, an increase of 46% from 1980, and the highest yearly
harvest in 18 years. Canadian 1981 landings totalled 8,000 tons, 53% greater than
in 1980. More than 80% of the combined 1981 catch was derived from the Northern
Edge and Peak region of Georges Bank. USA 1981 landings from this region were
4,306 tons, the highest since 1962, and accounted for 62% of the USA Georges Bank
landings, nearly twice the proportional representation in the 1980 landings (34.5%).
All of the 1981 Canadian catch was taken from the- Northern Edge and Peak. Research
vessel survey and commercial data indicate that exceptional recruitment of the 1977
year class, localized principally on the Northern Edge region, sustained the 1981
fishery. This year class was heavily exploited upon recruitment as evinced by the
rapid rise and decline of commercial catch rates during January-September 1981 and
the prevalence of smaller sized scallops throughout this period in both USA and
Canadian catch samples. The mean size of scallops sampled in 1981 from USA landings
was the smallest in the 1965-1981 time series, implying a significant reduction
in cull size in the commercial fishery.

Total effort in the Georges Bank fishery during 1980 was the highest ever.
Preliminary effort statistics for 1981 suggest that effort has remainea high. Com-
mercial catch per unit of effort (CPUE) of both fleets, however, declined by about
50% between 1977 and 1980; the 1980 USA CPUE index was the third lowest value in
37 years. Both USA and Canadian CPUE declines indicate that, prior to recruitment
of the 1977 year class in 1981, resource abundance had sharply diminished as a con-
sequence of high fishing mortality rates. Fishing mortality is thought to have
continued at high levels during 1981 in spite of exceptional recruitment from the
1977 cohort.

USA and Canadian research survey total catch per tow indices declined in all
areas on Georges Bank between 1980 and 1981. Survey indices from the South Channel
and Southeast Part regions of the Bank declined by over 50%; the 1981 total eaten
per tow value for each of these regions was the lowest in the 1975-1981 time series.
Pre-recruit indices in both areas were also relatively low. On the Northern Edge
and Peak, the 1981 survey data indicate that the 1978 year class is above-average
1n strength and will provide significant recruitment to the Northern Edge fishery
1n 1982. However, the 1978 cohort is believed to be only half as large as the
1977 year class and hence, under current fishing practices, will not sustain the
level of landings supported by the 1977 year class.

Given the disparity in scallop abundance between the Northern Edge region
and all other areas on Georges Bank, it is likely that both USA and Canadian fleets
will continue to concentrate their fishing activities during 1982 in this area of
Georges Bank. Under 1981 culling practices, this would result in meat counts
in the 1982 fishery as high as those observed in 1981, although the implementation
of a USA sea scallop fishery management plan in May 1982 is aimed at ameliorating
this situation by constraining the harvest of small scallops through meat count
and shell size restrictions. Continuation of fishing strategies focused upon
incoming recruitment will result in losses in both yield per recruit and reproductive
potential, increasing the losses associated with growth overfishing and elevating
the probability of recruitment overfishing.

68

Gulf of Maine

Commercial Gulf of Maine sea scallop landings in 1981 were 1,100 tons, 537
tons less than in 1980, but still the second highest annual catch ever. As in 1980,
most of the landings (-70S) were derived from offshore, FCZ waters from newly dis-
covered beds. However, landings in 1981 were taken from beds much further north-
eastward then those exploited in 1980. This shift in areal distribution of land-
ings connotes that fishery mortality in 1980 resulted in a rapid diminution of
standing stock biomass in the areas exploited. Commercial effort in 19S0 and 1981
attained record levels, primarily due to increased activity Qy Class 3 and 4
vessels. During 1965-1979, these vessel classes accounted for less than 10" of
the annual Gulf of Maine landings; in 1980, however, combined class 3 and 4 land-
ings comprised more than 605 of the annual catch. Preliminary 1981 data suggest
a similar pattern as in 1980. Reliance of the Gulf of Maine fishery on offshore
populations is a recent phenomenon. Before 1950, all landings were derived from
inshore, territorial waters. Ouring 1970-1978, inshore landings accounted far
more than 87S of the Gulf of Maine commercial sea scallop catch.

In1 1980, commercial size frequency sampling data indicated that the offshore
fishery was sustained primarily by recruitment of the 1975 year class. Although
1981 data show a substantial increase in the average size of scallop landed, it is
likely that this increase is apparent rather than real due to low sampling intensity.

USA spring and autumn offshore bottom trawl survey relative abundance indices
indicate differential scallop abundance in waters between 30-60 fin and 61-100 fm.
In the former depth zone, catch per tow indices have been relatively stable since
1974. The 1980 and 1981 surveys indicate that the 1975 and 1976 year classes
dominate the population. Most of the 1980-1981 offshore exploitation is thought
to have occurred in depths between 30-60 fm since the 1975 and 1976 year classes
were predominant in commercial size frequency samples obtained in these two years.

In the 61-100 fm region, survey catch per tow indices in 1980 and 1981 mark-
edly increased from former years. Survey size frequency data indicate that abundance
has improved due to a successful 1974 year class. ' Recruitment of the 1975 and 1976
year classes also appear to be above average.

Although the long-term productivity of scallop populations in the 51-100 fm
region is unknown at present, the extremely high 1980-1981 survey indices suggest
that current densities may be sufficient to suoport .development of commercial
exploitation. Given that recent offshore landings have been largely supported by
one or two year classes, and have been achieved by significant increases in fishing
mortality, it appears unlikely that current catch levels can be sustained unless
additional high density beds are located.

M1d-At1 antic

Total commercial 1981 Mid-Atlantic sea scallop landings were 2,100 tons, 59"
less than in 1980, and the lowest annual harvest since 1975. Commercial CPUE in

1980 was 34S lower than in 1979, 64X lower than the peak 1977 index, and the third
lowest value in the 1965-1980 USA time series. Oespite the sequential annual decline
In commercial catch rates since 1977, effort in the Mid-Atlantic has continued to
increase reaching a record high in 1980. During 1981, Mid-Atlantic catch rates
declined further precipitating a transfer of vessel operations to the Georges Bank
fishery.

Commercial size frequency sampling data indicate a continued dependence in the
fishery on larger-sized scallops (>110 mm shell height), reflecting the lack of any
significant recruitment of the magnitude that sustained record landings during
1976-1980. Concomitantly, the extremely low 1981 commercial catch rates suggest
that population abundance has substantially been reduced as a result of high fishing
mortality rates during the past four years.

Research survey catch per tow indices during 1980 and 1981 exhibited similar
trends. In the Delmarva and Virginia-North Carolina regions, survey values have
sequentially declined; the 1981 indices for both areas were the lowest in the 1975-

1981 time series. Recruitment of the 1977 and 1978 year classes is relatively low

1n Delmarva and poor off Virginia-North Carolina. No evidence of successful recruit-
ment of the 1979 year class was observed in survey tows in either area. Survey total
catch per tow indices 1 rr the New York Bight region in 1980 and 1981 were about
half of the 1975 index, and among the lowest values in the survey series. Pre-
recruit indices in both years suggest low to moderate recruitment from the 1977 and
1978 year classes. Recruitment of the 1979 year class may be better than these
preceding cohorts since scallops from this year class were taken in the 1981 survey.
Normally, two-year-old scallops are rarely captured with the survey gear.

The absence of significant recent recruitment throughout the Mid-Atlantic area,
in conjunction with high effort levels in the Mid-Atlantic fishery, will continue
to impede improvement of resource abundance in the near future. Unless reductions
in fishing effort are effected, overall scallop abundance is expected to further
decline.

69

70

The issue of "overfishing" had long been a U.S. /Cana-
dian bone of contention with Canadian fishermen claiming
U.S. "uncontrolled fishing" and "American total destruction
of Georges Bank year-classes", and U.S. fishermen claiming
that Canadian fishermen had overfished their own grounds
(see October, 1980 newspaper article) . Interestingly, one
Canadian fishermen was quoted as saying, "What went on last
year (1981) was horrible. Scallops the size of nickels were
kept. We were just killing our harvest for the next three
years." Regardless of which country's fishermen were to
blame, the resource declined.

Emergency implementation

In a May 10 correspondence, the Council was informed
by the Regional Director, that the Scallop Plan would be
implemented on an emergency basis on May 15 (see letter) .
Sea scallop fishermen were informed of the implementation
date by way of a May 13 correspondence (see letter) .

Scallop Plan summary

The Sea Scallop Plan was implemented on an emergency basis ef-
fective May 15 to regulate sea scallop harvest throughout the range
of the resource from Maine to North Carolina. Realizing that this
range included several states' territorial and internal waters, the
Plan encouraged states to adopt complimentary regulations to insure
effectiveness of the Council's management program. Regulations imple-
menting the Plan were to be in place until June 28, and to be renewed
for another 45 days until mid- August after which final, permanent
regulations were to be issued.

Rationale for Emergency Implementation:

As stated by the Federal Register Announcement (50 CRF Part 650)

"Implementation of the FMP is time critical. In the spring of
1981 a very large year-class of scallops (a large number of ma-
turing individuals) became available for harvest on Georges Bank,
the center of sea scallop production. At that time, the scallops
were extremely small, averaging 50-60 meats per pound. Many scal-
lops were taken that spring by fishermen from both the U.S. and
Canada, before they had an opportunity either to spawn or to grow
to a size at which their meat yield approached its potential.
Another large year-class is expected to be available this spring
on the portion of Georges Bank which currently sustains the bulk
of the fishery. Without implementation of the FMP, these immature
scallops will be harvested this spring. These regulations are
being implemented on an emergency basis to protect these scallops
immediately, to allow them to grow to a size at which their yield
can contribute to the fishery and to enable them to enhance the
fishery by spawning before being harvested.".

71

May 13, 1982

Dear Federal Flatteries Permit Holder:

UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration

NATIONAL MARINE FISHERIES SERVICE

Northeast Region

14 Elm Street

Gloucester^+aWj^te^ts 01930

MAY 1 4 1982

The Fishery Management Plan for the Atlantic Sea Scallop Fishery was approved
by the Assistant Administrator for Fisheries on April 26, 1982, and will be
Implemented by emergency regulations effective May 15, 1982. The plan was
developed by the New England Fishery Management Council in consultation with
the Mid-Atlantic and South Atlantic Councils, and will regulate the harvest of
sea scallops, Placppectgn magellanlcus, wherever taken throughout their range,
from Maine through North Carolina.

Ttte emergency regulations will continue in effect for 45 Kays, and may be
renewed for an additional 45 days, after which final, permanent regulations
will be Issued. Comments on the regulations will be accepted through June 28,
1982, and should be directed to this address, marked "Sea Scallop Comments" on
the outside of the envelope. Copies of the regulations will be forwarded to
you on request, and to anyone who applies for a sea scallop permit.

The regulations implement a management program which relies on a single
conservation measure. The measure Is a restriction on the size at harvest of
sea scallops. For the first year of plan implementation, scallops must meet a
standard of 40 meat count (average 40 meats per pound), or a corresponding 3-
1/4 Inch (83mm) shell height. After that first year, the standard will rise
to 30 meat count (average 30 meats per pound), or 'a corresponding 3-1/2 Inch
(89mm) shell height Thereafter, the standard will remain at 30 meat count,
except that the Regional Director may, under certain circumstances, adjust the
standard within a range of from 40 to 25 neat count, in increments of five
meat count, on a temporary basis.

Enforcement of the meat count standard will apply to sea scallops landed
shucked and sold Co a dealer up to the poiat in the U.S. where they are nixed,
sorted, or processed. Sea scallops landed and sold in che shell must comply
with the shell height standard up to the point in the U.S. where they are
shucked. Sea scallops taken in Canada under regulations which are
substantially consistent with U.S. regulations, will be admitted to the U.S.
if they are properly labeled and accompanied by a certificate of compliance
issued by the Government of Canada.

All vessels harvesting sea scallops in quantities greater than five bushels or
25 pounds of meats per trip must obtain and carry on board a federal fisheries
permit with an endorsement for the sea scallop fishery. Applications for the
permit may be obtained in writing from P.O. Box 1109, Gloucester,
Massachusetts 01930, or by calling the Analytical Services Branch at (617)
281-3600. There are no standards of eligibility for a permit, apart from
providing routine Information about your vessel and gear.

▲ voluntary fishery Information collection program will be used to obtain
information from flsharaen for the purpose of managing the fishery. Most aea
scallop fishermen currently provide the interview and weighout information
requested under the program. The program will be fully Implemented in the
near future mm an action apart from the sea scallop management plan.

▲ grace period of fifteen days, until June 1, 1982, will be granted so that
fishermen can restrict their harvests to scallops which meet the meat count or
•hall height standards. A grace period of sixty days, until July 15, 1982,
will be granted to fishermen so that they can apply for, and receive, their
fishery permits. Anyone landing sea scallops which fail to meet the standards
after June 1,1982, or fishing for sea scallops without a valid permit on board
after July 13, 1982, will be subject to enforcement action.

If you have any questions about the management plan, the regulations, or any
other aspect of the fishery, please call the Sea Scallop Management
Coordinator, Bruce Nicholls at (617) 281-3600.

Thanh yon for your attention and cooperation.
Sine

^ Allen E. Peterson, jk.
Regional Director

72

Reasons for a Plan:

"Historically, landings from Georges Bank and the Mid- Atlantic
areas have fluctuated. It is believed that high rates of exploita-
tion may increase these fluctuations in the stocks, and in fact high
rates of exploitation have typically preceded sharp declines in abun-
dance.

The ability of these resources to support the current level
of effort is questionable. Over the last several years the
high abundance of sea scallops in all areas, coupled with
increasing market value, have supported significant in-
creases in fishing effort. In 1978 total removals (U.S. and
Canadian) from the overall resource surpassed all historic
levels. Data for 1979 and 1980 indicate declines in catch
in spite of increases in overall effort.

Over-exploitation is a danger, in light of anticipated in-
creases in demand. Consumer demand may be expected to support
high ex-vessel prices, and thus, maintain an environment which
encourages overexploitation" .

Objectives:

The Plan has one overall objective with four sub-objectives.
These are:

To maximize over time joint social and economic benefits from
the harvesting and use of the sea scallop resource.

To reduce year-to-year fluctuations in stock abundance
caused by variation in recruitment.

To enhance yield per recruit for each stock.

To evaluate the impact of Plan provisions on research,
Plan development, and enforcement costs.

To minimize adverse environmental impacts on stock levels
and utilization.

Optimum Yield:

Optimum yield has been defined as that amount of annual domestic
sea scallop catch that results from implementation of the sea scallop
fishery management program.

Management strategies:

The Plan relies on one basic conservation and management
measure to achieve these objectives; that is, a meat count/
shell size restriction - maximum of 40 meats per pound (average
value per trip) and minimum 3 1/4" shell height (with a 10%
tolerance by number) . This meat count: ana sneil size is to be
enforced, as provided by the Plan, through a comprehensive pro-
hibition of non-conforming sea scallops up to and including the
point of first transaction in the U.S..

73

Scallops are required to meet these standards unless they are
certified to have been taken under a management system that is found
to be "substantially consistent" with the standards and conservation
objectives of the FMP. Procedures for certification are to be esta-
blished by the Regional Director and he is to make the finding as to
"substantial consistency" required for certification. The need for a
certification process originated from discussions between the U.S. and
Canada and is a means to address Canadian scallop export concerns.

After the Plan is in place for one year, the meat count restric-
tion will be automatically increased to 30 meats per pound with a cor-
responding shell height of 3 1/2". Thereafter, the Regional Director
has the authority to change the meat count and shell size standard upon
a finding of fact according to four criteria (below) and consultation
with the Councils.

Criteria are:

1) The objective of the FMP would be achieved more readily
or would be better served through an adjustment of the
prevailing standards;

2) The recommended alteration in the standards would not
reduce expected catch over the following year by more
than 5% from that which would have been expected under the
prevailing standard;

3) The recommended standards for meat count and shell height
are consistent with each other; and,

4) Inconsistencies exist in the management measures applied
to sea scallop stocks in areas harvested by both domestic
and foreign fishermen, and those inconsistencies can be
demonstrated to adversely affect the domestic fishery;
or, analysis of the size distribution of sea scallops
shows that more than 50% of the harvestable sea scallop
biomass is at sizes smaller than those consistent with
the prevailing standards and that a temporary relaxation
of the standards would not jeopardize future recruitment
to the fishery.

The fact finding process can be originated either at the Regional
Director's initiation or upon a request from the New England Council.
Changes can only be made within a range of 2 5-4 0 meats per pound
with corresponding shell sizes. This process allows changes in the
standards without a formal, time consuming Plan Amendment. Action to
alter the standard is subject to public review at a hearing scheduled
for the same day as the Council meeting on which the recommendation is
discussed.

Any vessel of the U.S. harvesting sea scallops in quantities
greater than five bushels or 25 pounds per trip must have a permit
on board the vessel.

74

A voluntary fishery information collection system will be
used to obtain information from fishermen for the purpose of managing
the fishery (Three-Tier System) . Dealer and processor data will
also be collected as part of the system.

75

LITERATURE CITED

Anderson, E. D. , F. E. Lux, and F. P. Almeida. 1979.

The silver hake stocks and fishery off northeastern
United States. NEFC , Woods Hole Lab. Ref. Doc.
No. 79-28. 25 pp.

Serchuk, F. M. , P. W. Wood, J. A. Posgay, and B. E. Brown.
1979. Assessment and status of sea scallop
(Placopecten magellanicus) populations off the
northeast coast .of the United States. Proceedings of
the National Shellf isheries Association. Vol. 69:
161-191.