Public Comment Likely Late Summer/Early Fall
The Atlantic States Marine Fisheries Commission (ASMFC) last week voted to move forward with a Public Comment Draft of Amendment 2 to the Atlantic menhaden fisheries management plan (FMP). ASMFC's official vote this past Thursday in Alexandria, VA will open the window for public comment in addressing overall bunker harvest throughout the Atlantic States in 2013.

Amendment 2 will ultimately set up a timeline for achieving the target mortality rate for menhaden by establishing certain management mechanisms in both the recreational and commercial sector. Of note to anglers, the draft addendum will not be geared towards cuts in the recreational sector because of the minimal landings from the recreational sector.

According to Capt. Adam Nowalsky, chairman of the Recreational Fishing Alliance's New Jersey chapter (RFA-NJ) and the legislative proxy to the ASMFC for New Jersey Assemblyman Nelson Albano, an update to the stock assessment will be released later this summer which is expected to incorporate the latest information about the bunker fishery, including up-to-date harvest tallies and overall status of the stock.

"The current scientific data shows that overfishing is occurring on bunker, but only by less than 1%," Nowalsky said. "The updated stock assessment coming out this summer may say that we're not overfishing, it could say that we're overfishing by more than 1%, but that presently is an unknown."

Nowalsky said this week's vote by the ASMFC will allow Draft Amendment 2 to be decided upon in October after the updates to the stock assessment have been released and once the full range of public comment is received by the ASMFC regarding the document to be released in August for review.

"ASMFC will draft a document, we'll get to review it again and then in October a vote will take place to enact the measures in the amendment," Nowalsky said, adding "the good news is that we continue to move forward in the amendment process."

It should be noted that the ASMFC vote was not about setting management measures for bunker, but about including information for public comment to be released for review sometime in August. Nowalsky noted that the complexity of fisheries management plans, particularly with regard to bunker which is targeted primarily by bait boats along the Atlantic Seaboard and the reduction fleet inside of Virginia waters including up inside the Chesapeake Bay, has spawned a lot of misinformation in Internet message boards with regard to the process.

"Much of the confusion is that folks reading the message board analysis don't understand that this can be a slow-moving process, particularly when you consider that managers are dealing with a series of numbers including thresholds and targets," explained Nowalsky. "Everything is going to be about mortality rate in the coming months, the mortality threshold by which acceptable biological fishing will be allowed over the next few years, and the overall mortality target which is more of a policy decision."

"It's important to remember that no decisions have been made yet except to move forward with crafting a document for the public for review that has a suite of options for addressing the future mortality of bunker," he added.

As an appointed delegate for the chairman of the Assembly Natural Resources Committee in New Jersey, Nowalsky said he and fellow ASMFC Commissioners from New Jersey including the Governor's Appointee Tom Fote and the proxy for the state Department of Environmental Protection, Pete Himchak, had one of the votes on the ASMFC for moving the document forward for public comment.

"New Jersey voted in favor of leaving an option in place for a 10-year timeframe for reaching a final target mortality, which is in addition to 3-year and 5-year timeframes which are also in the document," said Nowalsky. "No one voted for only a 10-year timeframe, there was simply a vote to leave this timeframe in the document for consideration and public comment along with other options."
"Steps will be taken in 2013 to achieve the threshold fishing mortality rate," Nowalsky said, adding "when the updated stock assessments come out this summer, there will be a lot more to talk about with regard to this extremely important fishery".

According to the ASMFC, a total of 22,641 comments were received as of the April 20, 2012 deadline date with regard to the initial public information document on bunker. Of those comments 104 were personalized individual comment, 18 were from organizations, and 22,519 comments were from form letters. The comments gathered by ASMFC came on the heels of 12 public hearings in 12 different states, where approximately 185 individuals were estimated to have attended the hearings combined.

As for the RFA's official position with regard to the future of menhaden management along the Atlantic Coast, one recommendation was that the bunker reduction fishery on the Chesapeake Bay be eliminated. (see www.joinrfa.org/Press/MenhadenFinalComments_042012.pdf.)

"Consistent with action taken by most states dealing with their inshore waters and bays, RFA believes a closed area for the reduction fishery should be imposed for the entire Bay and its tributaries," said Jim Donofrio in official comments to the ASFMC. "RFA believes such a closed area would result in positive ecological benefits to the Bay and species that rely on menhaden such as striped bass."

Also come up during the ASMFC bunker discussion was a reminder by the Technical Committee that they had been asked in 2010 to develop ecological reference points for menhaden which would take into account natural predation and forage issues. The problem with this particular project discussed by the ASMFC's Technical Committee was that that cost to improve the science was somewhere in the neighborhood of $300,000.
"If these environmental groups who are blanketing the Internet with form letters truly cared about helping protect bunker stocks, you'd think they would help pony up the funding to support improved science," said Donofrio. "With the war chests that Pew and Environmental Defense Fund have, you could probably find a couple of hundred thousand in cash in between the boardroom couch cushions."