by Ed Cherry
(from Jersey Coast Anglers Association February 2004 Newsletter)
The National Coalition for Marine Conservation has prepared a recommendation to amend the Atlantic Menhaden Fishery Management Plan. The paper is too long to include in our newspaper in its entirety. I have prepared a summary that is included in this newspaper. If you are interested in this topic, the entire document is posted at http://www.jcaa.org/JCNL0402/NCMCMenhaden.htm .
A Recommendation to Amend the Atlantic Menhaden Fishery Management Plan To Protect and Preserve Menhaden’s Ecological Role in Chesapeake Bay and Throughout its Range
Presented to the Atlantic States Marine Fisheries Commission by December 17, 2003 by the National Coalition for Marine Conservation
“In the long run, I look forward to the day when fishery conservation and management are carried out with full knowledge of the interactions between the managed species and the living and nonliving components of their environment. I believe we are making steady progress toward the goal of an ecosystem approach to management.
“In recent years, we have begun to move away from single species concepts of management, like maximum sustainable yield, and toward the multispecies concept of optimum yield. Optimum yield encourages the consideration of ecological factors in devising management strategies, as well as economic and social factors. Within a few years, I expect that most fishery management plans prepared by the Regional Fishery Management Councils will be multispecies plans, which will take into account predator-prey relationships in particular. Not too long after that, I hope we will use an ecosystem approach to fishery management.”
This statement was part of the keynote remarks by then-NOAA Administrator Richard Frank at a Striped Bass Symposium sponsored by the National Coalition for Marine Conservation in March 1980.
In spite of Dr. Frank’s optimism, we’ve only begun to take the first tentative steps toward an ecosystem approach to managing marine fisheries during the last several years, primarily due to the recommendations of the 1999 Report to Congress of the Ecosystems Principles Advisory Panel. In many respects, we are today only marginally closer to making ecosystem-based fishery management a reality than we were 23 years ago.
The National Coalition for Marine Conservation respectfully urges the Atlantic Menhaden Management Board to initiate the process of amending the Interstate Fishery Management Plan for Atlantic Menhaden to address concerns about the diminished ecological role of menhaden, on a regional as well as coastwide basis, with the goal of incorporating, as necessary, new objectives, reference points and management measures designed to protect and preserve the sustainability of the menhaden resource and associated species and the fisheries that depend on them.
Clear and Compelling Signs of Trouble
In Chesapeake Bay, predator demand is reaching unprecedented highs while available prey is at an all-time low.
A growing number of conservationists and biologists believe the continued high level of menhaden harvest in the Bay, if not curtailed, could jeopardize the hard-earned recovery of striped bass and other species, while hindering efforts to clean up the Bay environment. The situation practically cries out for an ecosystem-based approach to management but, although well-intentioned moves are being made in this direction, the system moves without urgency while we continue to manage without caution.
The evidence of an existing or pending ecological crisis in Chesapeake Bay and beyond is circumstantial but nonetheless compelling.
· The harvest of Atlantic menhaden, a stock found from Maine to Florida, has become more and more concentrated within Chesapeake Bay. Since 1997, 58% of the entire East Coast catch (by weight; nearly 70% by numbers of fish) has been taken from waters of the Bay.
· The Chesapeake is the striped bass’ main spawning ground. Possibly as much as 90% of the coastal migratory population breeds there.
· The spatial consolidation of the menhaden reduction fishery in the Bay has coincided with the return of striped bass, a key predator, and beginning in 1990.
· The numbers of striped bass and other consumers of menhaden (bluefish and gray trout, as well several species of water birds among them) have increased dramatically as a result of concerted efforts to rebuild previously depleted populations. As a result, total demand for prey is now at a level not experienced for decades, and growing.
· The number of adult striped Bass is still on the rise, desirably so, as we seek a more stable age-structure in the population. For large adult striped bass, the most prolific egg-producers and thus the key to a sustainable fishery for the future, immature menhaden are the preferred prey. The diet of mature bass typically consists of 70-80% menhaden, primarily sub-adult fish (< than age 3).
· Nearly 9 of 10 menhaden harvested by the purse seine (reduction) fishery are of prime forage size. Last year, for example, 73% of the menhaden catch in Chesapeake Bay was sub-adult fish (age 0-2).
· Juvenile menhaden abundance has been in decline since 1990 and is currently at an all-time low.
· Chesapeake Bay historically has produced nearly half (47%) of each new generation of menhaden for the coastwide stock. Indices of juvenile abundance are poorest in the Bay.
· The number of loons, osprey and other water birds nesting in the Bay or stopping there during their coastal migrations is down from a decade ago. Some scientists speculate the reason for the decline may be a lack of small menhaden.
· The catch of underweight or “skinny” rockfish has been commonplace since the early days of the comeback in the mid-1990s. Samples collected from the Bay have confirmed that on average bass carry only 10-25% of the body fat typically found in healthy fish.
· The reduced length-to-weight ratio strongly suggests poor nutritional health among the Bay’s striped bass population. There are indications bass are feeding more on alternative and less nutritious prey, namely bay anchovy and blue crab, which are themselves at historical low supplies.
· Up to half the Bay’s striped bass are infected with mycobacterium, a chronic wasting disease that scientists believe is stress-related and could be linked to malnutrition and/or poor water quality. The disease, rare in wild fish, first appeared in 1997 and has been increasing in frequency and severity ever since. It now has been detected in the coastal population as well.
· Oxygen-sucking, fish-killing algae blooms are turning more and more of Chesapeake Bay into dead zones, devoid of life. The number and size of such areas in the Bay has reached alarming levels. Excess nutrients, mainly nitrogen and phosphorous in run-off from farmland and inadequate wastewater treatment plants, produce the blooms that cut off life-giving light to seagrasses on the bottom then suck the oxygen out of the water when they decompose. Fish and crabs either go elsewhere or die.
· Menhaden are a principal filter feeder of the Bay’s waters, second only to oysters, which are virtually extinct. Menhaden control nutrient levels through grazing and transfer into fish tissue and make energy available for consumption by predators. Scientists recognize the potential to control water quality by regulating removals of menhaden.
The present menhaden management program does not accommodate consideration of these and other concerns. It features no process for assimilating this information into the stock assessment or informing management decisions.
Needed: A Precautionary Approach
To this end, the National Coalition for Marine Conservation urges the Atlantic States Marine Fisheries Commission to amend the Interstate Fishery Management Plan for Atlantic Menhaden in four ways:
1. Make preservation of an adequate supply of menhaden as forage for predators and as a critical filter feeder of coastal waters, on a coastwide and regional (e.g., Bay-wide) basis, the primary plan objective.
2. Expand the FMP’s information base to more fully describe and comprehend the links among associated species, incorporating all available information on ecosystem health and integrity.
3. Add a definition of “ecosystem overfishing” as an alternative to traditional overfishing criteria.
4. Establish a conservative, precautionary total allowable catch (TAC) that provides a suitable buffer against ecosystem overfishing, with appropriate measures to control the harvest of immature menhaden and disperse effort away from nursery areas.
The ASMFC, by choosing not to regulate the harvest of menhaden, has neglected the ecological consequences of overfishing. In turn, it has relegated management responsibility for menhaden to the individual states. In the absence of interstate guidance, a number of states have been forced to act unilaterally, without benefit of a coherent and cohesive coastwide plan. Adoption of such a plan, as recommended above, will require a restructuring of the fishery and of the current regulatory system.
Interstate management measures adopted under the Menhaden FMP should:
1. Substantially reduce the overall catch of menhaden;
2. Disperse effort throughout the range of the fish as befits a coastwide stock; and,
3. Strictly limit the harvest of sub-adult menhaden (age 0-2), with emphasis on protecting the forage base within Chesapeake Bay.
The amendment process should examine, and submit for public review and comment, a wide range of options for achieving these management objectives, including seasonal or year-round closure of menhaden nursery areas.
The board wanted to make sure the recreational catch did not significantly increase its percentage.
Those are understandable reasons. But in reality, what is actually accomplished with the new tables? Under the previous amendment in order to accomplish the required reduction, states north of New Jersey implemented a 16-inch size limit with no bag limit. That fulfilled their requirements under the previous amendment. The table now says if you have a 16-inch size limit you must have a 10 fish bag limit. But if you look at the MRSS, in the states that have a 16-inch size limit, no one is catching 10 fish. So on paper this looks like a reduction, but it isn’t. I will accept this part of the plan even though it has no immediate impact. Under the previous plan, New Jersey, Delaware and Pennsylvania were able to meet our reduction with a 14-inch size limit and a 14 fish bag limit.
What happens to us with the new tables? The new tables allowed for 9 fish at 14 inches. This was a true reduction since many anglers were already catching at the old bag limit. We lost 5 fish at 14 inches, a big reduction. ASMFC pretended to do us a favor by allowing 9 fish since the tables were actually lower at 14 inches. Under the previous amendment, states that wanted to fish at 12 inches were required to have a 4 fish bag limit. Under the new amendment, these states needed to go from an 18% reduction to a 32 % reduction. I would imagine that would require a smaller bag limit. I was taught old math. According to ASMFC’s new math, to get a reduction you need to catch more fish. These states are now allowed 12-inch fish with a 7 fish bag limit, an increase of 3 fish. Again, the only states that actually face a reduction are New Jersey, Pennsylvania and Delaware.
I will be working with the Governor’s Office to try to find a solution to the striped bass situation with ASMFC. In the meantime, you should send letters to Governor McGreevey asking him to stand firm and pursue any action necessary to keep the anglers of New Jersey from being discriminated against. You need to state your support for a lawsuit as a last resort. Thank the Governor, Commissioner Campbell and Director McHugh for their continued support in resolving this issue.
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