** The following was provided by the Massachusetts Striped Bass Association (MSBA) and does not necessarily reflect the opinion of The Fisherman Magazine. When submitting public comment on fisheries management issues, it is highly recommended that all sides of the issue be considered.
Upcoming New England Hearings:
DEC 12 – MA – 5:30pm – Bourne Community Center, 239 Main St, Buzzards Bay
DEC 14 – CT – 7pm – CT DEEP Boating Education Center, 333 Ferry Rd, Old Lyme
DEC 19 – RI – 7pm – URI Corless Auditorium, South Ferry Road, Narragansett
DEC 20 – MA – 6pm – Thayer Public Library, 798 Washington St, Braintree
BACKGROUND
In May of 2015, ASMFC initiated Amendment 3 to the menhaden management plan to establish ecological management, and to review and possibly update state-by-state quota allocations.
At their annual meeting in October 2016, ASMFC’s Menhaden Management Board unanimously approved the Public Information Document (PID) for Draft Amendment 3 for public comment. The public can comment at upcoming hearings or in writing before January 4, 2017.
The PID, which precedes a draft of the actual amendment, provides the first opportunity for stakeholders to inform the Board about their own visions for the future of menhaden. These talking points don’t address every issue, but highlight key issues for menhaden conservation.
MSBA SUGGESTED COMMENTS ON ISSUES
ISSUE 1: Reference Points
PID Questions: Should the Board manage the Atlantic Menhaden stock with single-species biological reference points or multi-species ERPs? Do you support the use of simpler, readily available ERPs until menhaden –specific ERPs are developed by the BERP?
MSBA Suggested Comments: The Board should start to manage menhaden using Ecological Reference Points with whatever models are available today. With abundance of Menhaden rising and the geographic range growing, the time to switch from “single species” to “ecological” based management is now.
Issue 1, Option D is the best solution available today. Managing menhaden at 75% of the pre industrial fishing stock size and requiring the population never drops below 40 percent will allow sustainable harvest and help menhaden continue to expand back into the northern and southern extents of their former range. Conservation will benefit everyone. Option D will enable the menhaden population to continue to grow, while increasing menhaden’s value to recreational fishing, commercial seafood, and tourism businesses that all depend on this important fish, and its predators.
ISSUE 2: Quota Allocation
PID Questions: Should the Board maintain, or revise, the allocation formula currently used to manage the commercial Atlantic menhaden fishery? Which allocation option(s) provides for the fairest and most equitable distribution of coast wide total allowable catch? Which allocation option(s) strikes the best balance between current needs and future growth opportunities? Do you support the use of soft quotas for some user groups?
MSBA Suggested Comments: The board should revise the current allocation formula. More fish should be allocated to the bait sector or bait states, taking into account historical catch and recognizing the important role of the bait sector in regional economies.
One state taking 85% of the catch is inequitable & seems to contradict recent NOAA guidance on allocation.
Three options have the most potential to provide an 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, and 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.
Three options should be removed from Amendment 3: 1) Option C. Coastwide 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. 3) Option H: Allocation strategy based on TAC level. This is a dangerous option that creates incentive for risky increases in quota.
“Soft” quotas are too complicated and risk quota overages. They should not be allowed in Amendment 3.
ISSUE 3: Allocation Timeframe
PID Questions: Should the Board consider changes to the reference period on which menhaden allocation is based? Should allocation consider prior trends as well as recent changes in the fishery? What years would you recommend as the basis for allocation?
MSBA Suggested Comments: By considering only 2009-2011 or 2012-2016, 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. Option D (2012-2016) should be removed from the Amendment, as it is simply reflects the status quo option.
ISSUE 4: Quota Transfers and Overage Payback
Questions: Should the process for quota transfers be further defined or replaced by an automatic reconciliation process? Should state specific quota overages be forgiven in years when the coastwide TAC is not exceeded? When the coastwide TAC is exceeded but at least one jurisdiction has an underage, should unused quota be pooled and redistributed through a specified transfer process to states with an overage? Should states be required to contribute unused quota to a common pool or should this be voluntary? Should there be accountability measures for a state that exceeds its quota by a certain percentage or repeatedly participates in quota reconciliation?
MSBA Suggested Comments: 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 overage transfer in the following year.
ISSUE 5: Quota Rollovers
Questions: Should unused quota be rolled over into subsequent year? Should the amount rolled over be limited to a percentage of quota? Should all sectors of the fishery be allowed to roll over quota? Should rollover be mandatory of voluntary?
MSBA Suggested Comments: 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
Question: Should there be a cap on incidental landings in the Atlantic Menhaden fishery? Should incidental catch be defined as a percent composition? Should the incidental catch allowance be allocated to vessels or permit holders? Should the incidental catch provision be replaced with a small-scale fishery set aside, and if yes, what gears should be included in this sub-quota (see Table 3 in Appendix 1)? Should active and passive gears be treated differently under the incidental catch provision?
MSBA Suggested Comments: The current bycatch allowance is actually a loophole which allows several million pounds of menhaden to be caught, but not counted toward the quota. The problems this exemption was created to address should be eliminated under the allocation option being proposed in this action. All harvest must be counted.
ISSUE 7: Episodic Events Set Aside
Questions: Should a percentage of the TAC be set aside for episodic events? If yes, what percentage of the annual TAC should be set aside? Which jurisdictions should be allowed to participate in this program? Does the episodic event program need to be reconsidered as the distribution of menhaden changes? How should states demonstrate that an episodic event is occurring in state waters?
MSBA Suggested Comments: 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
Questions: Should the Chesapeake Bay Reduction Fishery Cap be maintained? Is it an important tool for the management of Atlantic menhaden?
MSBA Suggested Comments: The Bay remains the primary nursery for the coastwide menhaden population, and 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 many predators that depend on menhaden in the Bay.
ISSUE 9: Research Programs and Priorities
Questions: What are important research questions that need to be answered regarding the menhaden fishery and resource? How should research recommendations be prioritized? Should there be a RSA established for menhaden? If yes, what portion of TAC should be set aside for research purposes?
MSBA Suggested Comments: The ASMFC should prioritize fishery independent research into historical abundance, effects of localized depletion, and food web interactions of menhaden.