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Atlantic Menhaden
Draft Amendment 3 Comments

JCAA, October 18, 2017
(from Jersey Coast Anglers Association November 2017 Newsletter)
Jersey Coast Angers Association Comments on Amendment 3
Dear ASMFC Commissioners,

The Jersey Coast Anglers Association (JCAA) is an association of more than 75 saltwater fishing clubs that represents the position of marine sport anglers, champions their causes and protects their rights in matters pertaining to fishing, fisheries, and environmental quality.

Professor Bruce Franklin, from Rutgers University, detailed the value of menhaden to the ocean’s eco-system and its commercial value in his book “The Most Important Fish in the Sea”. This fish filters the ocean’s waters and whales, bluefish, striped bass and other fish depend on menhaden as an important food source. It has many commercial uses such as paint etc., but it is extremely important to us recreational anglers since we know that when menhaden are not around, neither are other fish that we seek such as stripers and bluefish. “No bunker – no bass,” is a phrase we are very familiar with. The importance of menhaden for the ocean’s eco-system and for the fishing opportunities it presents to anglers cannot be understated! The stocks of this fish must be conserved and enhanced. The current approach that ASMFC uses for setting catch limits does not effectively meet this goal. The following comments addresses specific points in this amendment and are offered in the spirit of protecting the stocks of this important fish.

Issue: Reference Points

Ecological management is right for menhaden, so Option E is the best solution now. Menhaden must be managed conservatively to 75% of virgin biomass.

The current management system risks huge increases in catch which could have a direct impact on the striped bass recreational fishery and potentially many other fisheries.

Issue: Quota Allocation

Tier 1: Option C, Jurisdictional Allocation with a Fixed Minimum, Sub-option 3 allocating a fixed minimum of 2%, is the best option on the table, but an even larger reallocation is appropriate.

The current quota allocation for menhaden gives more than 85% of the fishery to Virginia, leaving the remainder of the states to split the rest. This is inherently unfair and must be fixed.

Reduction fishing has been banned in every state on the E. Coast, except Virginia, so it makes no sense that the one state that still allows it gets 85%.

At the same time, commercial bait harvesters outside of VA are begging to catch more fish.

If option C is not possible, a reasonable alternative is a 70/30 split for reduction/bait coastwide, and no increase in catch.

Issue: Quota Transfers

Quota transfers encourage horse trading of fish and they should not be allowed.

Issue: Quota Rollovers

Option A - No quota rollovers – is the most appropriate option.

Issues: Incidental Catch and Small Scale Fisheries

Option F - All catch to be included in cap.

Issue: TAC set aside

Option C is the best option with a 0% of TAC set aside

Issue: Chesapeake Bay

The Chesapeake Bay is an important nursery for menhaden that eventually migrate across the coast. Option B-Reducing the cap and set at 51,000 MT for the Chesapeake – should be adopted along with Option B- No rollover of unused cap. Over the preceding years, catch in the bay has fallen drastically. This option is an opportunity to further protect the nursery.

Thank you again for doing what you did back in 2012. We have all seen what can happen when the bunker are given just a little chance to recover. As fishermen and concerned citizens, we thank you in advance for voting in favor of the above conservation options in November!

John Toth, President, JCAA cc: Governor Christie, NJ Commissioner Bob Martin, Asst. NJ Commissioner Rich Boornazian, Larry Herrighty, Director, NJ Fish & Wildlife
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