April 13, 2012 – The Atlantic State Marine Fisheries Commission is proposing to create Addendum II to the Atlantic Menhaden Fishery Management Plan, which would create new, more conservative reference points for management of this important forage fish. This is the Public Information Document (PID) phase, which is the start of the process. The ASMFC will use the information generated here to create the Draft Addendum sometime this summer.
A sample letter is available for your convenience that you may use to send your comments to ASMFC.
Subject line: PID Menhaden Management
I believe that restoring the menhaden resource to historic levels of abundance must be the primary management objective of the Amendment. Fisheries that can operate without depleting the overall abundance of the menhaden resource or fishing on immature fish, and which avoid concentrating effort in relatively small, ecologically important areas such as the Chesapeake Bay, must be governed by adequate monitoring and enforcement measures. Fisheries which cannot meet such basic criteria should be prohibited.
Menhaden management is at a critical juncture – overfishing is occurring, even under the old reference points, and must be addressed immediately. Menhaden abundance is at the lowest level in the 50-plus year time series, which, in my view, is a serious management problem.
I believe management measures must be put in place to reach the current fishing mortality threshold and end overfishing in 2013, and that management measures must be in place to meet the current fishing mortality target no later than 3 years later, in 2016, with a 75 percent probability of success.
Putting in place these basic fishery management measures, which are common to virtually all managed stocks, will, at the very least halt, the decline in menhaden abundance and increase spawning stock biomass.
I support putting in place the full suite of commercial management measures, with the exception of limited entry, but question the need for recreational management measures, which comprises less than 1 percent of the harvest.
I sincerely appreciate the opportunity to comment on proposed menhaden management measures.
Analysis: The petition says that "overfishing [of menhaden] is occurring, even under the old reference points, and must be addressed immediately."
According to the Atlantic States Marine Fisheries Commission's (ASMFC) 2010 stock assessment, overfishing did occur in 2008, the last year covered in the assessment. However, this was the only year in the last ten years that overfishing had occurred. And while the stock had experienced overfishing (meaning that the number of fish caught exceeded the level set by the ASMFC), the stock was not overfished (meaning that the population is still producing enough eggs to replace itself).
The petition also does not account for the fact that environmental factors, rather than fishing, are the biggest determinant of the size of the menhaden population. National Oceanic and Atmospheric Association’s Chesapeake Bay Office stating on its website, “menhaden recruitment appears to be independent of fishing mortality and spawning stock biomass, indicating environmental factors may be the defining factor in the production of good year classes.”