Improving Utilization of the Atlantic Sea Scallop Resource: An Analysis of Rotational Management of Fishing Grounds: Comment

Valderrama and Anderson (2007) presented an analysis of rotational fishing for sea scallops which unrealistically assumed high fixed price premiums for large sea scallops independent of their supply, and atypical initial conditions. These assumptions distort their results, leading them to suggest greater benefits for rotation than actually exist. This analysis was then used to criticize one aspect of current U.S. sea scallop management policy. However, their discussion ignores bycatch and possible habitat damage from scallop fishing. Including bycatch as external costs reduces the optimal fishing effort level from that which would otherwise be calculated. Finally, a number of practical difficulties in applying formal optimization to fishery management are discussed.