Menhaden Comment Letter to ASMFC
The Atlantic States Marine Fisheries Commission (ASMFC) is developing an amendment to revise the Interstate Fishery Management Plan for Atlantic Menhaden. The Commission, under the Atlantic Coastal Fisheries Cooperative Management Act, is charged with developing fishery management plans for Atlantic menhaden which are based on the best available science and promote the conservation of the stock throughout its range. The states of Maine through Florida participate in the management of this species via the Commission’s Atlantic Menhaden Management Board. The following is an abbreviated version of the Fishermen's Association's comment letter to ASMFC.
Recent cuts in the menhaden quota, as well as favorable environmental conditions, resulted in a rebound in the Atlantic menhaden population for the 2016 and 2017 fishing years. However, extremely low catch between 2009 and 2011 (the period used for reference in calculating historical catch) caused Maine to receive just 0.04% of the coastwide total allowable catch (TAC) . This quota was far too low to accurately reflect the amount of menhaden historically caught in Maine throughout the 20th century, and an “episodic event” had to be declared in order for Maine fishermen to catch the menhaden that entered state waters. We strongly believe that a sensible, responsive management strategy must be put in place that will eliminate the need for such last-minute patchwork fixes year after year. Below I have enumerated our recommendations for each issue in Draft Amendment 3.
Reference Points: The Fishermen’s Association supports Option E, which allows for the interim use of a fishing mortality rate which uses a 75% target and a 40% threshold until menhaden-specific ecological reference points (ERPs) are developed by the BERP Workgroup. The Fishermen’s Association believes that the creation of ERPs will provide the best structure for good management in the future, since menhaden are an extremely important forage species and this should be factored into their stock assessment and other measurements. Additionally, menhaden are biologically distinct from other forage fish, and having custom reference points will help to create optimal management. In the interim, aiming for a 75% target unfished biomass and keeping a 40% unfished biomass as a “floor” threshold is the best strategy to prevent overfishing of this stock, which is critical in order to enable this migratory species to make it to Maine’s waters.
Quota Allocation: The Fishermen’s Association supports Option C, sub-option 3 (Jurisdictional (state-by-state) Allocation with a 2% Minimum Base Allocation). Implementing a 2% fixed minimum base allocation will allow the menhaden fishery in Maine and other states along the Atlantic seaboard to recover and build a stable foundation without having to count on episodic event allowances.
Allocation Time Frame: The Fishermen’s Association supports Option B (2012-2016). If a timeline is to be supported, Option B (status quo) more evenly distributes the quota throughout the coast, although this is not a preferred alternative for MCFA.
Quota Rollovers: The Fishermen’s Association does not support Option D (50% unused rollover). This amount of rollover is far too high, and could lead to overfishing especially if large amounts of juvenile fish are caught. A smaller rollover may be appropriate but we have found in other fisheries that allowing rollover causes problems in years when quota may be adjusted down. While a rollover initially makes sense, upon deeper reflection it may disrupt sound management based upon the best available science.
Incidental Catch: The Fishermen’s Association strongly believes in accountability in all fisheries. Therefore, we prefer an option from the second set (D, E, or F) which will include incidental and small-scale menhaden catch in the TAC. Out of those three, we support Option D (2% set-aside). This allows for fishermen who catch menhaden incidentally in small amounts to continue fishing, while making sure that this catch is accounted for.
Episodic Events: The Fishermen’s Association supports Option B. The Episodic Events program has allowed Maine to have a menhaden fishery. If a more generous distribution of allocation is chosen in this process, the Episodic Events program could stay at status quo of 1% or be done away with, but under status quo this is an important tool to ensure fishermen throughout the range of this species have access.
Chesapeake Bay Reduction Fishery Cap: The Fishermen’s Association supports Option B, sub-option B for a smaller cap of 51,000 metric tons and zero rollover. This would shrink the cap to the level currently fished in the Chesapeake Bay for the reduction fishery. We do not believe that rollover is appropriate in the sensitive environment of a nursery for juvenile fish. We know that the nursery population must be protected in order for the stock to thrive and reach Maine, the northernmost extent of its range. Therefore, we believe that the Chesapeake Bay reduction fishery must be capped appropriately and prevented from fishing more than its current level.