Fate of men­haden di­rectly af­fects fu­ture of striped bass

Record Observer - - SPORTS -

The At­lantic States Ma­rine Fish­ery Com­mis­sion’s men­haden man­age­ment plan is be­ing amended, and it’s clear that the most im­por­tant fish in the sea should be man­aged us­ing Eco­log­i­cal Ref­er­ence Points with mod­els that are avail­able to­day. With the abun­dance of men­haden ris­ing and the geo­graphic range grow­ing, the time to switch from “sin­gle species” to ecosys­tem-based fish­eries man­age­ment is now.

Pub­lic hear­ings have been con­ducted through­out the At­lantic Coast states but writ­ten com­ments will be ac­cepted un­til 5 p.m. Jan­uary 4.

Writ­ten com­ments can be sent via mail, fax, and email. If you can find the time to sub­mit your thoughts, please do your part in help­ing to man­age our re­sources.

Talk­ing points are avail­able in the fol­low­ing let­ter by Stripers For­ever to the ASMFC in sup­port of ecosys­tem-based man­age­ment:

Me­gan Ware, Fish­ery Man­age­ment Plan Co­or­di­na­tor, At­lantic States Ma­rine Fish­eries Com­mis­sion

1050 North High­land Street, Suite 200A-N Ar­ling­ton, Vir­ginia 22201 To Whom It May Con­cern: On be­half of the 5,000 mem­bers of Stripers For­ever (SF) who sup­port the sus­tain­able man­age­ment of striped bass and the ecosys­tem com­po­nents that sup­port them, thank you for the op­por­tu­nity to com­ment on the Men­haden Amend­ment 3 PID.

This or­ga­ni­za­tion strongly sup­ports the use of ecosys­tem based fish­ery man­age­ment (EBFM) as the pri­mary tool for the process of pro­mot­ing long-term sus­tain­abil­ity of our ma­rine re­sources.

As out­lined in the Men­haden Amend­ment 3 PID, we will com­ment on the is­sues in or­der: IS­SUE 1: Ref­er­ence Points SF strongly sup­ports the con­cept that men­haden should be man­aged us­ing Eco­log­i­cal Ref­er­ence Points (ERP’s) with what­ever mod­els are avail­able to­day. With abun­dance of Men­haden ris­ing and the geo­graphic range grow­ing, the time to switch from “sin­gle species” to EBFM is now.

Cur­rently, Op­tion D is the best so­lu­tion. Man­ag­ing men­haden at 75% of the prein­dus­trial fish­ing stock size and re­quir­ing that the pop­u­la­tion never drops be­low 40% will al­low sus­tain­able har­vest and help men­haden con­tinue to ex­pand back into the north­ern and south­ern ex­tremes of their for­mer range. Op­tion D will en­able the pop­u­la­tion to con­tinue to grow, while in­creas­ing men­haden’s value to the recre­ational fish­ing, com­mer­cial seafood, and tourism busi­nesses that all de­pend on this im­por­tant fish, and its preda­tors. Con­ser­va­tion will ben­e­fit ev­ery­one. IS­SUE 2: Quota Al­lo­ca­tion SF feels that the ASMFC should re­vise the cur­rent al­lo­ca­tion for­mula. More fish should be al­lo­cated to the bait sec­tor, tak­ing into ac­count his­tor­i­cal catch and rec­og­niz­ing the im­por­tant role of the bait sec­tor in re­gional economies. One state or en­tity tak­ing 85% of the catch is in­equitable and is counter to re­cent NOAA guid­ance on al­lo­ca­tion.

Three op­tions have the most po­ten­tial to pro­vide a fair and eq­ui­table dis­tri­bu­tion of catch:

Op­tion B: State-spe­cific quo­tas with a fixed min­i­mum. Op­tion F: Dis­po­si­tion quo­tas with at least 30% of catch al­lo­cated to the bait sec­tor. Op­tion G: fleet ca­pac­ity quo­tas, with all fleets man­aged by a hard quota. Op­tions B, F, G strike the best bal­ance be­tween cur­rent needs and fu­ture growth.

Two op­tions should be re­moved from Amend­ment 3:

1) Op­tion C: Coast wide Quota. This will pro­duce a race to catch fish, which will be un­fair to some states, es­pe­cially in the North. 2) Op­tion E: Re­gional man­age­ment adds an un­nec­es­sary layer to an al­ready com­pli­cated fish­ery.

IS­SUE 3: Al­lo­ca­tion Time­frame

SF feels that by con­sid­er­ing only 2009-2011 or 20122016, the Board is un­fairly ex­clud­ing the sig­nif­i­cant catch his­tory of other states; es­pe­cially in the North­east where the as­sess­ment shows pro­cess­ing plants ex­isted un­til the 1980’s. Catch data from as early as 1955 should be con­sid­ered. A vari­a­tion of Op­tion C: Longer Time-Se­ries Av­er­age, go­ing back to 1985 or ear­lier would be fairer. Op­tion D (2012-2016) should be re­moved from the Amend­ment, as it is sim­ply re­flects the sta­tus quo.

Is­sue 4: Quota Trans­fers and Over­age Payback

SF sup­ports the con­cept that quota trans­fers should be un­re­stricted ONLY if com­pleted prior to a state ex­ceed­ing its quota. A state re­ceiv­ing a quota trans­fer after ex­ceed­ing its quota should be re­quired to take ac­tion to avoid the over­age in the fol­low­ing year and should not be al­lowed to ac­cept a quota trans­fer in the fol­low­ing year. IS­SUE 5: Quota Rollovers SF feels that quota rollovers should not be al­lowed. Rollovers may lead to un­in­tended con­se­quences with re­gard to lo­cal­ized de­ple­tion or quota al­lo­ca­tion on a year to year ba­sis.

IS­SUE 6: In­ci­den­tal Catch & Small Scale Fish­ery Al­lowance

SF feels that the cur­rent by­catch al­lowance is a loop­hole that al­lows mil­lions of pounds of men­haden to be caught, but not counted to­ward the quota. This ex­emp­tion was cre­ated to address a prob­lem that should be elim­i­nated un­der the al­lo­ca­tion op­tion be­ing pro­posed in this ac­tion. All har­vest MUST be counted.

IS­SUE 7: Episodic Events Set Aside

SF feels that quota rollovers should not be al­lowed. Rollovers may lead to un­in­tended con­se­quences with re­gard to lo­cal­ized de­ple­tion or quota al­lo­ca­tion on a year to year ba­sis. SF feels that the episodic events set aside is un­nec­es­sary. A fair al­lo­ca­tion and a quota trans­fer process that in­cludes ac­count­abil­ity is enough flex­i­bil­ity to man­age ex­pected fluc­tu­a­tions in lo­cal abun­dance of a sus­tain­able fish­ery.

IS­SUE 8: Ch­e­sa­peake Bay Re­duc­tion Fish­ery Cap

The Bay re­mains the pri­mary nurs­ery for the coast wide men­haden pop­u­la­tion. It is the area where the ma­jor­ity of catch is con­cen­trated. The cap should be kept in Amend­ment 3, but re­duced to 96 mil­lion pounds (closer to cur­rent levels) to pro­tect against lo­cal­ized de­ple­tion and pro­vide for the ecosys­tem ser­vices that many preda­tors de­pend on in the Bay.

IS­SUE 9: Re­search Pro­grams and Pri­or­i­ties

SF sup­ports the idea that ASMFC should pri­or­i­tize

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