October 27, 2011
Atlantic States Marine Fisheries Commission
1050 N. Highland St., Suite 200 A-N, Arlington, VA 22201
Dear Ms Kerns:
Subject: Menhaden Draft Addendum V
I am writing you in behalf of the Jersey Coast Anglers Association (JCAA) with our comments on Addendum V to Amendment I to the Atlantic Menhaden Fishing Management Plan (FMP). These comments pertain to the biological reference points for menhaden as well as possible management measures that could be used in order to control the harvest, if they should become needed. JCAA makes these in light of the 2010 stock assessment's Peer Review Panel's statement "that menhaden population abundance had declined steadily and recruitment had been low since the last peak observed in the early 1980's."
The existing biological reference points of the target fishing mortality (F target) when applied to the most recent benchmark stock \assessment and its terminal year (2008) resulted in about only 8% of the stocks maximum spawning potential (MSP) being achieved. As a result, the Peer Review Panel recommended that other reference points be considered that would provide greater protection for the coastwide menhaden spawning stock biomass. In addition, given the current overfishing definition in the Menhaden FMP, overfishing has occurred some 60% of the time over the last 54 years. As you point out in your draft document, recruitment of menhaden to the coastwide stock does not appear to totally depend upon the number of spawning fish but to an important degree upon environmental factors, especially for the production of large year-classes. Further, as you point out, it is very likely that menhaden could be able to take greater advantage of favorable environmental conditions if a larger percent of spawning fish exist in the population.
While all of us benefit to some degree in the use of commercial menhaden meal as feed for chickens, turkeys, hogs and aquaculture production, and its oil via omega 3 fatty acid; as well as the direct use of menhaden as bait, JCAA feels strongly that the most important role for menhaden is it ecological one as a forage base for predatory fishes and other aquatic animals. We believe that it could be to everyone's advantage, the general public, as well as commercial fishermen and recreational fishermen, to work to increase the menhaden stock, especially spawning fish, to a higher level than now exists.
JCAA's specific comments are as follows:
Biological Reference Points - (2.3)
Unfortunately the ASMFC provides just two choices for an F threshold; status quo (option 1) and (option 2) a 15% maximum spawning potential. We feel neither of these accomplishes what is needed to allow the menhaden stock to fulfill its important ecological role in the sea. JCAA believes this species needs to be placed with the other important forage fishes and receive the needed status it deserves.
We recommend option 4, 40% MSP with it corresponding F target and F threshold, the target guideline recommended by the Federal National Standard 1. These reference points would reflect menhaden's ecological importance, yet still provide for a commercial and recreational fishery.
Proposed Management Tools (2.3.2)
Recreational Fishery - (22.214.171.124)
Since the data pertaining to the recreational fishery is so poor (no menhaden taken for bait along the entire coast in 2009 is an example of just how unreliable those data are. Figure 2 in Draft Document), it is recommended that an alternative data collection be explored.
If recreational action is needed in the future, we feel that size limits are of no practical use. However, either daily bag limits or some time limits, i.e., seasons may prove useful.
Commercial Fishery - 126.96.36.199)
Continue the harvest cap in Chesapeake Bay, at least through 2013. If other actions are needed, the use of trip limits, gear restrictions, season closures, area closures, quotas, effort controls and limited entry should be included in the FMP, if only to have a broad range of possible options for the future.
One final item: In the late 1970's as the ASMFC began discussing the need for a menhaden FMP, a proposal was put forward to provide a 1 mile-wide corridor along the entire coast during the fall where no reduction fishing for young of year menhaden would occur. At that time, these small juveniles are migrating in mass close along the coast and were being targeted by reduction boats for fishmeal. It was agreed by most everyone, biologist and fishermen alike, that harvesting menhaden at this stage of life was wasteful. The harvest of the juveniles at that time was between 300 million and 1.5 billion fish annually. It would be to everyone's benefit to let these fish live another few years to grow larger. Unfortunately, all but a single processor agreed, but it would take the entire industry to agree to this on a voluntary basis for it to be implemented. Unfortunately this plan was not put in place because of this single objection.
At the present time, no one is directly fishing on young of year menhaden. A prohibition of a reduction fishery for these juvenile fish would not pose any hardship on fishermen, yet would have a great benefit to the stock in the future.
We ask that the Menhaden Board consider this request to prohibit any future reduction fishing on young of year menhaden.
Eileen Smith President of JCAA
Frank Virgilio President of NJSFSC