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Weekly fisheries news bulletin service of Fishlink - 3 September 2004

by PCFFA newsletter
Dungeness Crab Trap Limits on California Governor’s Desk; Oregon Seeks MSC Certification. PFMC TO MEET IN SAN DIEGO; GROUNDFISH ISSUES DOMINATE AGENDA OREGON CLOSES SPORT FISHERY ON POPULAR GROUNDFISH STOCKS:
A WEEKLY QUOTA OF FISHERY SHORTS CAUGHT AND LANDED BY THE INSTITUTE FOR FISHERIES RESOURCES AND THE PACIFIC COAST FEDERATION OF FISHERMEN'S ASSOCIATIONS
__________________________________________________________________________________________________
SUBLEGALS
~WE HOOK THE NEWS THAT'S FIT TO NET~
Vol. 10, No. 05
3 September 2004

Celebrating the 70th Anniversary of the West Coast Waterfront Action
__________________________________________________________________________________________________
“From the perspective of the specialist, it is a mixed blessing when the world turns its attention to your chosen area
of endeavor. You feel somehow legitimized when, if only briefly, the public shares your own intense interest in the
issues to which you have devoted your professional life. However, initial excitement quickly gives way to exasperation
as rhetoric overshadows the substantive deliberation necessary to move from knowledge to understanding.â€*â€|â€|.
John Volpe
_________________________________________________________________________________________________

IN THIS ISSUEâ€|â€|.

Dungeness Crab Trap Limits on California Governor’s Desk; Oregon Seeks MSC Certification.
10:05/01.

Science Study Finds Recreational Fishing Has Major Impact on Some Depleted Fish Stocks. 10:05/04.
Regulations Adopted for California Herring Fishery; Herring Bill Passes Legislature. 10:05/08.

Congressional Briefing Held in Eureka on Klamath Salmon Situation. 10:05/10.

California Finally Adopts Market Squid Management Plan. 10:05/11.

AND MOREâ€|â€|



10:05/01. CALIFORNIA CRAB TRAP LIMIT BILL ON GOVERNOR’S DESK;
OREGON CRABBERS SEEK MSC CERTIFICATIION: A bill to limit the number of traps used in a
portion of California’s Dungeness crab fishery passed the state legislature in the final days of its
session and is now on Governor Arnold Schwarzenegger’s desk awaiting his signature. The measure,
AB 2146, by Assemblyman Mark Leno (D-San Francisco), would limit the number of traps used in the
Dungeness crab fishery in the “southern area,â€* extending from Sonoma County south along the
California coast, to 250 per vessel for a two-year trial period. The bill was requested by the three
fishermen’s marketing associations in Fish & Game District 10 (includes the coastal waters of
Sonoma, Marin, San Francisco and San Mateo Counties), the Fishermen’s Marketing Association of
Bodega Bay, the Crab Boat Owners Association and the Half Moon Bay Fishermen’s Marketing
Association. The “southern areaâ€* is distinguished from the rest of the coast by opening and closing
two weeks earlier each year; starting the 15th of November, it typically supplies the Thanksgiving
Holiday market.



The main thrust of the bill is fleet safety; it is intended to save lives by capping the number of traps
used by each vessel in what had becomes an “arms raceâ€* as fishermen had to deploy more and
more traps, even when it wasn’t safe, just to stake some territory and remain competitive. The bill is
also intended to prevent the waste that occurs increasingly when most of the available crab is harvested
in a matter of weeks, rather than months, due to the large number of traps now being deployed. Over the
past two decades there has been a 500 percent increase in the number of Dungeness traps used in these
limited fishing grounds. In addition to making crabbing safer, the limit is expected to help crabbers
control their costs and increase the price they are paid for Dungeness. Because the trap limit will help
spread production out over a longer period of the season, it is expected to increase the value of the crab
for fishermen and processors alike and will provide consumers access to fresh, local crab over a longer
period of the year. There is expected to be an added bonus for the resource as well, since trap limits will
act to curb the amount of handling of undersized and female crabs, as well as reduce trap losses.



California already limits the number of traps used in the sport crab fishery and traps limits are
anticipated for the state’s commercial prawn trap fishery. Dungeness trap limits are already in place
in Alaska and Puget Sound, and loose limits exist for the Washington Coast.



Dungeness crab in California, like the rest of the west coast, is under a limited entry system, but the
program limits only the number of vessels in the fishery, not the number of traps. Under AB 2146, the
250-trap limit will be in place for two years unless the California Fish & Game Commission acts to change
it or extend it. The number was a compromise reached between large and small boat operators and is
based on the average number of traps that can be “runâ€* in a day under normal sea conditions.
Although all vessels would have the same limit, larger vessels retain the advantage of being able to
handle more gear, hold more crab and operate in worse weather. Commenting on AB 2146, a veteran
Eureka crabber with over 40 years of experience, chuckled, “now we’ll find out who the good
fishermen are.â€*



Governor Schwarzenegger has until the end of September to decide the fate of AB 2146. “In the
movies, the Governor was known as ‘The Terminator,’ but in real life I don’t think he wants
to waste any crab fishermen,â€* said San Francisco fisherman Larry Collins, Vice-president of the Crab
Boat Owners Association. “He can be a real champion to the fleet by signing this bill.â€*



To the north, the Oregon Dungeness Crab Commission, together with ShoreBank Enterprise Pacific,
have contacted the Marine Stewardship Council (MSC) seeking certification of the state’s Dungeness
fishery as sustainable. They have also contracted with Scientific Certification Systems of Emeryville,
California to conduct the assessment of the fishery for purposes of certification. If successful, this
would be the first crab fishery certified on the Pacific Coast. Alaskan salmon have been certified and
currently California salmon, Baja lobster, and longline blackcod and Pacific halibut fisheries are seeking
MSC certification. The Oregon Dungeness crab assessment is being made possible by an $80,000 grant
from the Sustainable Fisheries Fund of the Resource Legacy Fund. The fishery is under the direct
management of the Oregon Department of Fish & Wildlife.



"The Commission is working hard to support our local fishermen and ensure the long-term
sustainability of our industry," said Nick Furman, Executive Director of the Oregon Dungeness Crab
Commission. "MSC certification will legitimize efforts underway for decades and allow us to connect
with consumers demanding environmentally sensitive products."



For more information on AB 2146, contact Assemblyman Leno’s office at (916) 319-2013, or go
to the California Legislature’s website at: http://www.leginfo.ca.gov/index.html. For more
information on MSC certification of Oregon’s Dungeness crab fishery, contact Karen Tarica at (206)
369-0855 or e-mail: Karen.Tarica at msc.org.



10:05/02. PFMC TO MEET IN SAN DIEGO; GROUNDFISH ISSUES DOMINATE
AGENDA: The Pacific Fishery Management Council will meet, 12-17 September, at the Hyatt Regency
Islandia, 1441 Quivira Road in San Diego, California, Tel: (619) 224-1234. Groundfish will be the main
issue on the agenda of a full week of meetings and four days of Council sessions. On Tuesday, groundfish
and salmon are on tap. Wednesday it’ll be marine protected areas (MPAs), halibut and groundfish.
Thursday, it’s habitat, highly migratory species, coastal pelagics and groundfish. On Friday, it’s
groundfish again. For a copy of the agenda/meeting schedule, go to:
http://www.pcouncil.org/events/2004/0904pfmc.pdf.



10:05/03. OREGON CLOSES SPORT FISHERY ON POPULAR GROUNDFISH STOCKS:
Oregon Fish & Wildlife officials announced on 30 August that they would halt Oregon sportfishing for
rockfish, lingcod and greenling for the first time, reported the 31 August Oregonian. The closure will
be in effect until the end of the year. A larger than expected catch of black rockfish during the week
before – approximately 24 tons – put the state on the verge of exceeding its 377-ton yearly sport
limit for this species. The commercial fishery is under separate catch limits. For more see the 31
Oregonian article at:
http://www.oregonlive.com/news/oregonian/index.ssf?/base/news/109395390159060.xml.



10:05/04. SCIENCE STUDY FINDS MAJOR RECREATIONAL FISHING IMPACT ON
IMPORTANT FISH SPECIES: A study published in the 27 August issue of the journal Science, finds
that sportfishing has a much greater affect on declining fish species than previously thought.



Titled, “The Impact of United States Recreational Fisheries on Marine Fish Populations,â€* by
Felicia C. Coleman, William F. Figueira, Jeffrey S. Ueland, and Larry B. Crowder, the study was released
26 August online in Science at http://www.sciencemag.org/cgi/content/abstract/1100397 (Science
subscribers only). An accompanying article, “Sportfishers [sic] on the Hook for Dwindling U.S. Fish
Stocksâ€* appeared in the 27 August issue of the journal Science (Vol. 305, No. 5688, p.1235); that
report is online from Science at: http://www.sciencemag.org/cgi/content/full/305/5688/1235. The
study evaluated commercial and recreational fishery landings over the past 22 years, first at the national
level, second for populations of concern (those that are overfished or experiencing overfishing), and
finally by region. The research shows that recreational landings in 2002 accounted for 4 percent of total
marine fish landed in the U.S. With large industrial fisheries (e.g., menhaden, squid) excluded, the
recreational component rose to 10 percent. Among populations of concern, recreational landings in
2002 accounted for 23 percent of the total nationwide, rising to 38 percent in the South Atlantic and 64
percent in the Gulf of Mexico. The study found sportfishing affected many of the most valued but
overfished species, including red drum, bocaccio, and red snapper, all of which are taken primarily in the
recreational fishery. The researchers said recreational fishing takes 59 percent of the red snapper in the
Gulf of Mexico, 93 percent of red drum in the South Atlantic and 87 percent of bocaccio on the Pacific
coast.



For more information, see the accompanying press articles that appeared on the 27th, including the
Reuters report at: http://www.planetark.com/dailynewsstory.cfm/newsid/26816/story.htm;
Newsday at:
http://www.newsday.com/news/local/longisland/ny-lifish2708,0,5418030,print.story?coll=ny-li-big-pix;
CNN at: http://www.cnn.com/2004/TECH/science/08/27/environment.fishing.reut/index.html; and
National Geographic at:
http://news.nationalgeographic.com/news/2004/08/0826_040826_fishing.html#main.



10:05/05. BILL GIVING STATE CONTROL OVER NON-FEDERAL TRAWL FISHERIES
PASSES CALIFORNIA LEGISLATURE: SB 1459, by California State Senator Dede Alpert (D-San
Diego), to give the state control over all non-federal trawl fisheries occurring offshore California passed
in the final day of the legislative session and is now on Governor Arnold Schwarzenegger’s desk.
Some of the original language in the bill banning trawling in the Halibut Trawl Grounds (in the Santa
Barbara Channel) and for pink shrimp in state waters was deleted following negotiations between the
bill’s proponents with PCFFA and the Southern California Trawlers Association (SCTA). In return
the State Fish & Game Commission will evaluate and determine within 3 years whether those fisheries are
adversely affecting bottom habitats. The negotiations between the bill sponsors with the commercial
fishing groups were made possible when Assembly members Patty Berg (D-Eureka) and Hannah-Beth
Jackson (D-Santa Barbara) intervened asking that the legitimate concerns of the commercial fishing
industry be dealt with, and Senator Alpert agreed. Senator Alpert is a California Commissioner on the
Pacific States Marine Fisheries Commission (PSMFC) and a member of the Legislature’s Joint
Committee on Fisheries & Aquaculture. In addition to California halibut and pink shrimp, the state also
regulates the sea cucumber trawl fishery. For more information on SB 1459, contact Senator
Alpert’s office at (916) 445-3952 or go to: http://www.leginfo.ca.gov/index.html.

10:05/06. PSMFC ANNUAL MEETING IN SEATTLE: The 57th annual meeting of the Pacific
States Marine Fisheries Commission (PSMFC) will be held 19-22 September at the Grant Hyatt, 721 Pine
Street in Seattle, Washington. For more information, call (503) 595-3100 or go to:
http://www.psmfc.org.

10:05/07. COMPETITION TO DESIGN FISHING GEAR AIMED AT REDUCING
BYCATCH: The National Oceanic & Atmospheric Administration (NOAA), along with a group of
aquariums, universities and conservation organizations is sponsoring “The Smart Gear
Competition,â€* a contest to develop designs for “practical, cost-effective solutions that reduce the
incidental catch of sea turtles, cetaceans, fish bycatch and other non-target species in either fixed gear or
nets. One winner will be selected for the grand prize of $25,000 to take their design from the
drawing-board stage to prototype development, testing, and initial manufacture. The two runners-up
will receive $5,000 each.â€* For more detailed information, see the Smart Gear Competition’s
website at: http://www.smartgear.org.



10:05/08. 2004-2005 CALIFORNIA HERRING REGULATIONS APPROVED;
LEGISLATURE PASSES BILL TO MAKE PERMIT TRANSFERS EASIER: At its 27 August
meeting in Morro Bay (see Sublegals, 10:03/11), the California Fish & Game Commission approved the
regulations for the 2004-2005 herring roe fishery. Most of the fishery occurs within San Francisco Bay,
with smaller fisheries occurring to the north in Tomales Bay, Humboldt Bay and Crescent City. The total
quota for the roe herring gillnet fishery for San Francisco Bay will be 3,440 tons (based on 10 percent of
the previous year’s estimated spawning biomass), up from last season’s 2,200 ton quota (see
Sublegals, 8:21/09). The “DHâ€* gillnet platoon begins fishing 5 December and continues until 23
December or until its quota is reached, whichever comes first. The “Oddâ€* and “Evenâ€*
platoons begin fishing 2 January and continue until 11 March or until their quotas are reached,
whichever comes first. Each platoon fishes alternate weeks. The Commission at its Bridgeport,
California meeting voted to evaluate the use of 2 inch mesh (currently 2â…? inches) for the San
Francisco Bay fishery (successfully used in Tomales Bay) to target more of the younger fish, to increase
the percentage of older fish in the population. That issue will be taken up at the October Commission
meeting.



In Tomales Bay, the “baseâ€* quota has been increased to 400 tons, over last year’s 300-ton
starting amount. If escapement goal of 4,000 tons is exceeded for Tomales Bay, the quota may be
increased to 500 tons on 15 February. The Tomales Bay fishery begins 26 December, closes 31
December, and opens again 2 January and extends until 25 February or when the quota is reached,
whichever occurs first. The quotas for Humboldt Bay and Crescent City are again 60 and 30 tons
respectively. For more information, call the California Department of Fish & Game’s (CDFG)
Herring Hotline at (650) 631-6784, or go to: http://www.dfg.ca.gov/fg_comm/2004/163164ntc.pdf.



The same day the Commission was approving the upcoming herring season regulations, the California
Legislature was passing AB 2519 by Assemblywoman Patty Berg (D-Eureka), authorizing the
Commission to adjust herring permit transfer measures and take other steps to facilitate the easier
transfer of roe herring permits. That measure, which also allows the Commercial Salmon Stamp
Committee to authorize salmon stamp funds for the recovery of ESA [Endangered Species Act] listed
salmon runs, had been held-up over an amendment clarifying state prevailing wage laws in regard to past
salmon restoration programs. It is now on Governor Schwarzenegger’s desk awaiting his approval.
For more information on AB 2519, contact Assemblywoman Berg’s office at (916) 319-2001, or go
to: http://www.leginfo.ca.gov/index.html.



10:05/09. NMFS RELEASES US PLAN FOR ADDRESSING FISHING OVERCAPACITY:
At the September 2002 World Summit on Sustainable Development (WSSD), held in Johannesburg,
South Africa, one of the goals set out for fisheries, in addition to an end of all illegal fishing by 2004, was
for nations to have in place plans for the control of fishing fleet capacity by 2005 (for more on this see
Pietro Parravano’s speech, “A Fisherman’s Perspective on Sustainable Development and the
Global Oceans Agenda,â€* given in Paris, November 2003, and available on the PCFFA website at:
http://www.pcffa.org). In August of this year, the National Marine Fisheries Service (NMFS) issued its
“Final National Plan of Action for the Management of Fishing Capacity (NPOA/Capacity), consistent
with an international obligationâ€* to the United Nations’ Food & Agriculture Organization (FAO).
According to NMFS, the “plan addresses a fundamental and widely debated problem in many
federally managed fisheries: overcapacity in the harvesting sector. The NPOA/Capacity announces, for
the first time, a national governmental policy: ‘to use its authorities to help the Councils and industry
manage capacity with the major objective of bringing about a reasonable balance between harvesting
capacity and available resources.’ Over the long term, the NPOA/Capacity proposes the elimination
or significant reduction of overcapacity in 25 percent of federally managed fisheries by 2009, and in a
substantial majority of fisheries in the following decade.â€*



To carry this out NMFS is promising to “hold national workshops, prepare reports, and assist in
the implementation of capacity management programs.â€* NMFS “will work closely with the
Fishery Management Councils in the implementation and administration of exclusive quota programs,
such as individual fishing quotas, community quotas, and fishing cooperatives.â€*



The troubling aspect of NMFS’s announcement of the plan is its claim that development of
individual fishing quotas is required by “relevant law.â€* On close analysis there is no “relevant
lawâ€* promoting IFQs; even where regional fishery councils have adopted them, those are only
recommendations to NMFS. So it appears the agency is advancing an agenda here, claiming a legal
mandate when none exists. The federal fishery agency goes on to say it “ will assist in the design and
administration of permit and vessel buyout programs to ensure their compatibility with federal law,â€*
including section 3129(b)-(e) of the Magnuson-Stevens Fishery Conservation & Management Act. To
keep the program on target NMFS says it will conduct a formal review of the plan at least very four
years, beginning in 2008. For a pdf copy of the NPOA/Capacity plan, go to:
http://www.nmfs.noaa.gov/sfa/reg_svcs/npoa.capacity.8.4.04.pdf.



10:05/10. THOMPSON HOLDS COASTAL BRIEFING ON KLAMATH SALMON
SITUATION: U.S. Representative Mike Thompson (D-CA) held a Congressional briefing on 30 August
in Eureka, California (see Sublegals 10/03/05) to hear from the Bureau of Reclamation (BOR), state
and federal fishery officials, Tribes, commercial and recreational fishermen and local elected officials
regarding the status of Klamath salmon stocks this year, actions aimed at resolving the on-going conflict
between fisheries and agriculture, and the potential impacts to the river and ocean fisheries in 2005 due
to the 2002 fish kill (see Sublegals, 10:03/05; 10:01/01; 9:11/01; 6:15/01; 6:14/01; 6:13/01; 6:12/07;
5:18/01; 5:17/02; 5:14/02; 5:13/02). The Congress has held hearings in Klamath Falls, Oregon and
within the Upper Klamath Basin over the years to hear from irrigators, but never came to the coast to
learn the impacts of the basin’s diversions on coastal fishing communities. Thompson aimed to
change that even if he was the only Congressman present.



Yurok Tribal leader Troy Fletcher described the water bank that was in place on the river as
“welfareâ€* for the farmers there and said the Tribes would be suing to force more water down the
river. Growers meanwhile, represented by the Klamath User Water Association (KUWA) said they
wanted to find a solution but reducing water diversions in the basin was “not on the table.â€* PCFFA
Executive Director Zeke Grader said fixing the Klamath problem was not “rocket science,â€* but did
require leadership, chiding the federal administration for its failure to recognize the plight of the
fisheries. Three immediate steps he proposed were reducing agricultural demand in the basin (e.g.,
through willing seller buy-outs), removal of the three lower dams on the Klamath (see Sublegals,
10:01/05), and resolving the problems plaguing the Shasta and Scott river tributaries. PCFFA
Vice-President Dave Bitts explained to the more than 120 present at the Eureka City Council Chambers
what the impact of the 2002 fish kill could be on the 2005 fishery and the need to have a plan to address
it, warning “the 2002 fish kill could result in so few adults returning to the Klamath in 2005 that
fishing seasons would have to be shut down off most of California and Oregon.â€* Bitts, a member of the
Klamath Fishery Management Council, said he was willing work with the growers in the basin on a
long-term solution but said they had to realize the compromising by the fishing groups has already
happened, they’ve got nothing left to compromise.



At the end of the briefing, Thompson admonished many of the agency representatives there saying the
situation has to be fixed. "I hope I never have to bring 500 pounds of dead salmon to Washington again,"
said the Congressman who in 2002 dumped a load of rotting fish, which died in the Klamath late that
summer because of the lack of flows, on the Department of Interior’s doorstep. For more
information, see the 31 August Eureka Times-Standard article by John Driscoll, “Klamath’s
conundrumâ€* at:
http://www.times-standard.com/cda/article/print/0,1674,127%257E2896%257E2370796,00.html,
and the Associated Press article by Jeff Barnard at: http://www.katu.com/printstory.asp?ID=70610.



10:05/11. AFTER SIX YEARS, CALIFORNIA APPROVES SQUID MANAGEMENT
PLAN: The California Fish & Game Commission at its 27 August meeting in Morro Bay adopted its
Market Squid Management Plan, or most of it anyway. Among the major elements of the plan was the
adoption of a 118,000 ton annual total catch limit, allowing a northern California experimental fishery
and establishment of a limited entry program. The development of the plan is pursuant to SB 364 by
Senator Byron Sher (D-Palo Alto) passed by the Legislature in 1997 (go to:
http://www.leginfo.ca.gov/cgi-bin/statquery).



The most controversial aspect of the plan was the Commission’s decision to adopt a total
allowable catch in the plan for 118,000 tons, which is based on the three highest catch years on record.
Conservation groups, specifically Natural Resources Defense Council and The Ocean Conservancy,
recommended an initial 80,000-ton limit, which would be revised every year depending on the status of
the stocks. A compromise was suggested by some of the fishing groups for a 100,000-ton cap, also
revised yearly. A number of veteran squid fishermen have been skeptical about a total catch limit, since
the squid are so short-lived -- 6 months to a year -- and proposed, instead, days of the week and area
closures allowing the squid to spawn without disturbance. One proposal did recommend a four-day a
week fishery for Fish & Game Districts 10 and 16. The Commission rejected these proposals and went
with the Department recommendation. It did differ from the Department in allowing for an
experimental squid fishery for the north coast (something PCFFA had pushed for), and allowed fishing
north of Pillar Point, but prohibited the use of lights for fishing within the current Gulf of the Farallones
National Marine Sanctuary boundary (includes the Farallon Islands and the waters around Point Reyes)
to protect sea birds. The Commission adopted a limited entry program, partially, leaving the decision on
the qualifications for the non-transferable “grandfatherâ€* permits to their October meeting. There
were also questions about what areas were open and what were closed around the Channel Islands. What
seems clear is that although a management plan has been adopted, there are still more discussions to
come regarding the regulation of California’s largest fishery. For more information, contact Marija
Vojkovich at: (805) 568-1246, or go to: the Department of Fish & Game website at:
http://www.dfg.ca.gov.



10:05/12. PFMC PELAGIC SPECIES MEETING: The Pacific Fishery Management Council’s
(PFMC) Coastal Pelagic Species Advisory Subpanel will meet 28-29 September the National Marine
Fisheries Service, Southwest Region’s Conference Room 3300 at the federal building, 501 West
Ocean Boulevard in Long Beach, California beginning at 0900 HRS on the 28th. The meeting is for the
purpose of developing alternatives for annual allocation of the Pacific sardine harvest guideline, as well
as to review the 2004 Pacific sardine stock assessment and harvest guideline recommendation for the
2005 season. The PFMC’s Coastal Pelagic Species Management Team will meet the 30th, following
the Subpanel meeting, also in Long Beach. This meeting is to review the Pacific sardine stock assessment
and harvest guideline recommendation, and receive a briefing on the allocation alternatives being
developed by the Subpanel. For information on the meetings, contact Dan Waldeck at (503) 820-2280,
or go to the PFMC website at: http://www.pcouncil.org/events/2004/cpsmtap0904.html.



10:05/13. NEW AFS TEXT ON MPAS: The American Fisheries Society (AFS) has announced the
third volume in the AFS–Sea Grant symposia intended to develop new approaches to fisheries
management; this proceedings examines the topic of marine protected areas. The text, Aquatic
Protected Areas as Fisheries Management Tools, J. Brook Shipley, editor, (301 pages, August 2004)) is
available for $60 (AFS member price: $42) Stock # 540.42P, from AFS, Attn: Orders Dept, 1650
Bluegrass Parkway, Alpharetta, GA 30004, Tel: (678) 366-1411, or online at: http://www.fisheries.org
(click on "Bookstore").


YOUR NEWS, COMMENTS, CORRECTIONS: Submit your news items, comments or any
corrections to Editor at: sublegals [at] ifrfish.org, or call the IFR/PCFFA office with the news and a source
at either: (415) 561-FISH (Southwest Office) or (541) 689-2000 (Northwest Office). Sublegals is a
weekly fisheries news bulletin service of Fishlink. To find out more about Fishlink, list information can
be viewed and you can subscribe automatically at:
http://straylight.primelogic.com/mailman/listinfo/fishlink. If you have any trouble subscribing or
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