The Mid-Atlantic Fishery Management Council is holding a public comment period on an important amendment to their fishery management plans, and you need to weigh in!
I haven’t posted a blog in a while. Because, well, because I’ve been absolutely hammering the striped bass. In fact I’ve been booked solid, sometimes doing two trips a day, for a couple of weeks, and have yet to have a substandard day. Seriously man… It’s been awesome!
While I’d like to say this is due to my superpower-like guiding skills, I’m afraid it has a lot more to do with the bait. Yeah, I suppose stripers are more abundant than they were a couple of years ago, mostly because of the 2011s, but my success thus far this season is undoubtedly due to extraordinary concentrations of silversides and, yes, to some extent peanuts (juvie menhaden).
Because that bait is so unusually abundant this year, I’m able to scoot away from the meat-heads and duck into these skinny feeder creeks with my skiff and catch fish on topwater plugs and flies in just a few feet of water.
The point here though isn’t just to brag – although sure that’s part of it – It’s that THE BAIT IS IMPORTANT!
It always is. Without it, we get noth’n. And it isn’t just important to guys like me. Everyone who catches fish – for fun or for money – needs good widespread concentrations of low trophic level fish. Without that we just don’t get the “marketable” predators that guys like me need to “torture and release,” and guys like “them” need to kill.
With this in mind, back in Dec of 2014, the Mid-Atlantic Fishery Management Council initiated an “Unmanaged Forage Omnibus Amendment”. The purpose of which is to protect all those bait species that aren’t currently managed in federal waters. The intent as I understand it, is to kind of head off any unmanaged large-scale, low-value reduction fishery (e.g. for fish meal, cat food etc.) that may arise in the near future, before we have a clear understanding of what sort of effect it would have on the ocean ecosystem, and ultimately the predators fishermen currently target. This action would essentially put any new fishery of such scale off limits, until the science exists to adequately explain how much can be removed from the ecosystem without serious consequence.
To boil it down even further, the Mid-Atlantic Council action is all about protecting the bait.
Yes… I’ve written about this maybe one to many times here, but there’s a sense of urgency now as we approach the finish line. The Council just released the Public Hearing Document, and anglers need to weigh in. Because, as far as fishery management goes, this may be THE most important action the Council has undertaken in the last two decades. It could effectively ensure the future of existing fisheries, both recreational and commercial. And listen… As a small business owner and, recently, a full time Charter Boat Captain, I’ve got real skin in the game here. So do you… And so does anyone who catches marine fish. So yeah, we all need to speak up here.
Let’s move on to the public hearing document itself. Like most fishery management documents it IS NOT an effortless read, nor is it particularly easy to understand if you’re a layperson. So let me try and provide a Cliff Notes of sorts, and highlight what’s important to us anglers, and what you should be commenting on.
The first thing is the list of forage species itself. Fairly early on in the process it became clear that the Council would have a hard time with a list inclusive of everything that predators eat. Going on limited stomach contents analysis alone, we’re talking about hundreds and hundreds of species, which could have made the amendment more-or-less unmanageable.
So, the Council’s Ecosystems and Ocean Planning Committee boiled the list down to those “straight face” species with high ecological importance and/or a high potential for the development of a large-scale targeted commercial fishery.
What we ended up with is a good, reasonable list of species that includes things like sandeels, anchovies, sardines, herrings, silversides, halfbeaks, ballyhoos, pelagic mollusks (e.g. squids, cuttlefish, etc.), copepods and any other species under 1 inch as adult. Plus some deepwater fish that you’ve probably never heard of like pearlside, hatchetfish and greeneyes, which are actually quite important to the deepwater ecosystems, and currently have markets in other countries.
The issue here is that those species don’t really fall into the standard “low-trophic-level” definition of forage. In fact I’m guessing most readers would consider false albacore in particular a predator. That said, they are indeed forage once you get outside of 20 fathoms. Large pelagics absolutely eat ’em in mass quantities. And… the intent of this amendment, as mentioned above, is to prevent the development of large-scale fisheries on forage species. For sure, the schooling properties of this species, as well as their poor eating qualities, make it quite vulnerable and, in fact, a likely candidate for a large-scale, low-value, high-volume fishery for say cat food or fishmeal or something like that.
And hey… Let’s be honest here… Albies are EXTREMELY important to the recreational fishing community. Particularly us light-tackle guides. There is a damn good opportunity to protect it here, and ensure that fishery exists into the future. Sure they are forage to a large extent, but I’d be lying if I said that their importance to the light-tackle industry wasn’t motivation for keeping them in.
Yes, there’s been some talk about taking albies, and other small tuna, out of this Amendment and dealing with them in their own fishery management plan (FMP) (e.g. a little tuna FMP)… But I don’t really get why we’d want to task an already overworked Council staff with doing a new FMP (with a stock assessment, reference points, etc.) when it can be dealt with quickly and simply right here, right now!
So… Bottom line. If you want to continue to fish on busting pods of albies… Better ask the Council that albies stay on the list.
Now let’s get to the alternatives themselves.
Alternative 1 is of course the “No Action”/status quo alternative. Of course we don’t want that.
Alternative 2A would require all forage species on the above-mentioned list (with the exception of chub mackerel – will get to that later) to be designated as an “Ecosystem Component Species”… AND… all possession of those species by commercial fishing vessels in Mid-Atlantic Federal waters would be prohibited. Alternative 2B would do that same, although allow an incidental possession limit of 1700lbs combined, or 1500lbs per species.
Now I know the knee jerk reason is to say, “no possession.” And 1500lbs of say sandeels might sound like a lot. But the reality is that this sort of cap allows for some incidental catch, but effectively prevents any sort of directed fishery from developing. Alternative 2B isn’t punitive, and it just makes sense.
So… Make a note… Support Alternative 2B in the document.
Alternative set 3 deals specifically with chub mackerel. Because during the development of this amendment, the Council became aware of a significant directed fishery, with landings as high as 5-million pounds in a year, on what many understand to be an important forage species.
Alternative 3A would simply designate chub as an ecosystem component species and use an annual landings limit to cap the catch. The intent here as I understand it, is to do this as a temporary measure, for three years or so, while the analyses necessary to determine if chub mackerel could be better managed with its own fishery management plan or as a stock in one of the Council’s existing FMPs can be completed.
Such a landings limit would be based on the landings average over 10 years, 5 years, 3 years, or… the highest catch recorded. It seems to me that if we wanted to freeze the footprint of this fishery to something resembling historical landings, we’d want to pick the 10 year average, as this fishery has undoubtedly ramped up in the last 3 to 5 years. This sort of abrupt increase in scale is exactly what we hoped to prevent with this Amendment.
There are also alternatives for whether or not we want to allow an incidental possession limit after the cap is met. And there are alternatives for what we want that incidental possession limit to look like.
Again, I don’t know if it’s reasonable to disallow the possession of incidentally caught chub. I mean, the intent here is to prohibit directing on these fish after the cap is met. A reasonable incidental possession limit would achieve that, while minimizing discards. One alternative 10k pounds, I believe is reasonable. The other – 40k pounds – is not. I mean, really, that would be directing.
Moving on, Alternative 3B would have chub mackerel just go straight to a stock in the fishery. The problem here is that you need things like a stock assessment, an over fishing limit, an “acceptable biological catch” level, etc. And really, we just don’t have that sort of science at the moment. Sure the Council could manage with proxies, but if the use of proxies in other Council-managed fisheries is any indication, management would likely revolve around caps based on average catch over a several years, which is what Alternative 3A is doing anyway.
Alternative 3C would manage chub mackerel as neither an Ecosystem Component Species nor a stock in the fishery, but through the Council’s discretionary authority. Under alternative 3C, the Council would simply implement an annual fishery-wide landings limit for chub mackerel, with or without an incidental possession limit.
This is fine I guess. But really, this would negate its inclusion in this Amendment. It makes more sense to me to designate chub as an Ecosystem Component Species… Get it included here and now. Get a reasonable cap in place while the Council does the analysis required for a possible stock-in-the-fishery designation in the near future, and allow a non-punitive incidental possession limit.
So make another note here. We should be going with Alternative 3A: designation of chub as an Ecosystem Component Species, with a cap based on a 10-year landing average, and a 10k pound incidental possession limit.
Alternative set 4 are alternatives for the development new fisheries and/or expansion of existing fisheries.
Now remember that what we’re ultimately trying to do here is not to prevent any new fisheries from developing, but to ensure that any new fisheries on unmanaged forage are properly vetted for ecosystem sustainability BEFORE they ramp up.
Alternative 4C does this by requiring an Exempted Fishery Permit (EFP) prior to development of a new or expansion of existing fisheries for species on the list. An EFP is a permit issued by NOAA that authorizes fishing activity that is otherwise prohibited under the regulations. Some limited, closely monitored fishing under this permit would allow for a first step in data gathering and analysis of such a fishery. Alternative 4Cii, goes a step further, having the Council develop a new policy for Council review of EFP applications. In my view this is imperative as the NOAA EFP process isn’t designed to account for forage/ecosystem considerations. All this should be a prerequisite to Alternative 4D, which requires the Council to formalize management before allowing fishing on any of these species – that’s what it means for a species to be a “stock in the fishery.” Formal management requires them to do a full evaluation of the status of the stock and set catch limits based on what the stock can handle.
So again… Make a note. For development of new fisheries, or expansion of existing ones, Alternative 4Cii (EFP requirement, with Council review of applications) combined with Alternative 4D seems to fit the Council’s intent best.
Alternative Set 5 are administrative alternatives. They are all pretty good, “no-brainer” things, and I don’t expect much push back on them. Alternative 5B is an important one though. It would require all vessels with any retained species on the ecosystem component species list in federal waters to have a federal fishing permit. What this will do is prevent state permitted vessels from landing these Ecosystem Component Species caught in Mid-Atlantic Federal Waters. It would also prevent large scale landings in say New England.
So make a note. Support Alternative 5B.
Alternative 5Di and 5Dii are worth noting also. They deal with jurisdictional boundaries. Pretty much from the onset, the Council’s intent was to limit the management unit of the amendment to Mid-Atlantic Federal waters. So, the Council is considering two alternative ways of defining the boundaries of Mid-Atlantic Federal waters. 5Di defines the southern boundary as the NC/VA state line (out 3 miles), while 5Dii defines it at Cape Hatteras. The greater the area the better as far as I’m concerned. So I’d recommend supporting 5Dii. Make a note!
Okay… So here’s the deal. The Mid-Atlantic Council will hold seven public hearings in May and June to solicit public input on this Amendment. You can find the schedule here: Unmanaged Forage Amendment Public Hearings: May 17 – June 8.
The Council is also soliciting written comments through Friday, June 17, 2016. Email them to Julia Beaty, at firstname.lastname@example.org, and be sure to include “unmanaged forage public hearing comments” in the subject line. You can also submit comments through the online portal.
For help commenting, here’s short summary of the above.
- Support the Council’s list of Ecosystem Component Species as listed in the document, but emphasize the continued inclusion of false albacore, frigate and bullet mackerel.
- Support Alternative 2B: Designate unmanaged forage as Ecosystem Component Species and implement an incidental possession limit, with a 1700 pound total cap and a 1500 pound cap on individual species.
- Re: chub mackerel alternatives, support 3Aii, Manage chub mackerel as an Ecosystem Component Species, and enforce an incidental possession limit after an annual fishery-wide landings limit is met. The landing limit should be based on a 10-year average of landings. The incidental limit should not exceed 10k pounds.
- Re: Alternative set 4 and the development new fisheries and/or expansion of existing fisheries. Support Alternative 4Cii, having the Council develop a new policy for Council review of EFP applications, and 4D, Consideration of stock in the fishery designation prior to development of new or expansion of existing fisheries for ECs.
- Re: permitting support Alternative 5B requiring commercial fishing vessels to obtain a commercial fishing permit from GARFO in order to possess any species designated as Ecosystem Component Species in the amendment.
- Re: jurisdictional boundaries, support alternative 5Dii, defining the southern boundary at Cape Hatteras.
It would be awesome if you could come to a public hearing in your state. But at the very least, take a few minutes to submit comments. Like I said, this is really important.
Do it now!