Draft Addendum XXX
Letter from JCAA to ASMFC

(from Jersey Coast Anglers Association February 2018 Newsletter)
1/4/2018 Caitlin Starks, FMP Coordinator Atlantic States Marine Fisheries Commission 1050 North Highland St., Suite 200 A-N Arlington, Va. 22201
Dear Caitlin,

The Jersey Coast Anglers Association appreciates this opportunity to comment on Draft Addendum XXX pertaining to sea bass. Our comments below reflect our stance on the various options included in the addendum.

Coast Wide versus Regional Options - We support regional management as the fisheries in the various states/regions are quite different.

Basis for Regional Allotment of the RHL - We believe that regional allocations using both exploitable biomass and historical harvest should be used to set the RHL. Including the exploitable biomass approach in management would be a refreshing change in that it addresses changes in the resource's distribution and abundance.

Regional Alignment - We realize that if the basis for regional allotment includes exploitable biomass, option b of subsection must be used. However, we support that option because New Jersey would become its own region. New Jersey is a transitional state in which its sea bass fishery doesn't really fit in with the states to its north or to its south. In fact, the fishery in southern New Jersey is quite different from that in northern New Jersey. This option would allow New Jersey to set regulations that would best suit its fishermen while allowing it to address spatial variation in size and abundance. We would also be fine with option c of subsection 3.1.22 except for the fact that this four-region approach does not allow exploitable biomass to be a factor in determining allocations.

Timeframe Used for Allocation - The timeframes of the two options in the addendum are of primary concern to us as both reduce New Jersey's historical share of the RHL. Option A of section 3.1.2 uses a ten-year timeframe from 2006-2015 while Option B uses only the five-year average from 2011-2015. The problem is that the years from 2011-2015 are the ones when New Jersey's share of the RHL was at all time historical lows. Yes, the biomass may have shifted further to the north as it expanded but the more stringent regulations that were forced upon us were also a primary reason why our historic share of the RHL was reduced. For that reason, we do not believe it is fair to include the years from 2011-2015 in determining allocations. In fact, this was pointed out at the joint ASMFC/MAFMC meeting on December 13th, 2017. A motion to have a third option to use the five- year timeframe from 2006-2010 was made at this meeting. That option would have better rounded out the other options and would have been more in line with New Jersey's and others states' historical share of the RHL. Unfortunately, though, the motion failed.

In 2011 draconian regulations were forced upon us which resulted in New Jersey harvesting their fewest sea bass during this entire century though most other states were negatively impacted as well. There was a liberalization of the regulations in 2012 at which time New Jersey was placed in the northern region. Then for 2013, NJ was forced to establish harsh regulations that resulted in us harvesting only 61% of our target quota. At the same time, New York harvested 125% of its target and Connecticut harvested 150% of their target. NJ did its part but then the following year all states in the northern region had to cut back by the same percentage. In other words, CT and NY were rewarded for going over their target quotas while NJ was penalized for under fishing theirs. Those stringent regulations that NJ set in 2013 have hurt us just about every year since as they continue to be used as the basis for liberalizing or tightening our regulations based on each year's target quota.

Further, NJ's historical share of the harvest was 47.7 % for the period from 2001 to 2010 and probably even more than that previous to those years. Going back further, and for the 20-year period from 1991 to 2010, New Jersey harvested more sea bass than any other state except in 1998 when it harvested the third most and in 1999 and 2010 when it finished second. Yet, option B proposes to use only the years from 2011-2015 when NJ finished first only once and finished fourth (its all-time lowest) in 2012. We believe it would be very unfair to base quotas on those years when New Jersey's share of the harvest was at or near its lowest and certain other states were at or near their highest levels. We would prefer an option that went back further in time and did not include the years of 2011-2015 at all. However, considering the fact that there are only two options, we support option A which uses the base years of 2006-2015. That would be the fairest to all states as it not only includes a more historical average but also accounts for the northward shift in biomass during recent years.

Process for Specification and Evaluation of Management Measures - We believe that option B of subsection 3.1.3, adjusting measures to the ACL would be an improvement from the status quo method of annually evaluating the recreational fishery based only on harvest against the RHL. This option would result in better data and reduced mortality which would in turn create more fishing opportunities for our fishermen. Educational programs to reduce mortality such as the one New Jersey has for summer flounder could be developed that would not only enhance our fishing opportunities but help maintain the sustainability of our stock.

Timeframe for the Addendum Provisions Provided our recommendations are followed we support a 3-year management program, otherwise we would prefer just the two-year plan.

Additional Comments We do not want to have even more stringent regulations forced upon us for 2018. We are urging you to leave the quota at 4.29 million pounds rather than lowering it to 3.66 million pounds. The spawning stock biomass is at 230% of the target and we need to create more fishing opportunities for these fish. Sea bass are not only competing for various forage species with other desirable species but have been devouring their young as well. Further, allowing us to harvest more sea bass would reduce the pressure we put on other species such as fluke. Also, please consider the fact that sea bass are protogynous hermaphrodites and with a 12 size limit, we are harvesting almost all males while allowing the females to continue to breed.

Sincerely, John Toth, JCAA President
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