(10/27/2011) Following a full month of public hearings and debate, the deadline for public comment to the Atlantic States Marine Fisheries Commission (ASMFC) with regard to the Atlantic Menhaden Draft Addendum V is quickly coming to a close on Wednesday, November 2, 2011.
After careful deliberation following comprehensive analysis of the draft, the Recreational Fishing Alliance (RFA) has prepared their final comments for submission to the ASFMC, which are now posted at the RFA homepage at www.joinrfa.org.
"RFA has been in close contact with its members along the Atlantic Coast, individuals and business involved with the menhaden bait fishery, and other organizations that have an interest in responsible menhaden management," writes RFA executive director Jim Donofrio in the opening comments to the letter to ASMFC's Toni Kerns, outlining RFA's official position. Calling ASMFC's current management measures for Atlantic menhaden a "failure," RFA said annual harvest reductions are necessary in the menhaden fishery, while saying that reductions need to be directed specifically at the reduction fishery.
"Harvest reductions in concert with revised management measures geared toward the reduction fishery, have the highest likelihood of achieving the existing or revised management goals in the coming fishing seasons," Donofrio said.
"It is without question that fishing mortality which is driven primarily by the reduction fishery landings exceeded the fishing mortality target in every single year except once in the past 52 years," Donofrio said, adding "Reduction landings from the most recent year, 2010 report a 27% increase from 2009."
"A sensible response from any resource management body would be to address this problem in a responsible manner through the implementation of management measures," he added.
In recent days, numerous advocacy groups have come out with one- and two-page policy positions calling for newer and more restrictive fishing mortality thresholds which RFA openly supports. However, Donofrio points out in his letter that without management measures being revised through an amendment process, any revisions to biological reference points as proposed in the ASMFC's Addendum V draft will be meaningless."
"RFA supports Option 2 for fishing mortality thresholds," Donofrio said, explaining that a new threshold would result in an almost immediate 23% reduction in overall menhaden landings. "In a general sense, RFA supports a threshold associated with higher maximum spawning potential ratio because it would ensure a greater percentage of menhaden available for forage."
The RFA goes on to explain that "a harvest reduction is necessary," while also adding that they are "extremely concerned that option as written does not include a mechanism to prevent landings from increasing as the stock responds to management objectives."
RFA's comprehensive six-page policy position addresses each of the options included in the ASMFC draft, and tackles important considerations such as gear restrictions, season and area closures, mortality targets, along with cap and effort controls within both the bait and reduction industry.
"What the ASMFC has given the public to review does not reflect reality," Donofrio said this week in preparing final comments. "ASMFC is trying to make the pain of harvest reduction go across the board equally when the real culprit is Omega Protein out of Reedville on the Chesapeake and the displaced herring fleet in federal waters. Given that harvest occurs in both federal and state waters, the best answer that's not on the document would be for menhaden to be jointly managed by both ASMFC and the regional fishery management council."
RFA has summarized their full comments into a one-page document for RFA members and advocates to submit their own comments if interested. Those supporting RFA's more comprehensive position can download, print, sign and fax a similar position to Toni Kerns, Senior Fishery Management Plan Coordinator for Management, at 703-842-0741.
Click here for RFA's full comments to ASMFC:
http://www.joinrfa.org/press/RFA_MenhadenFinalComments102411.pdf
Click here to download, print, sign and fax your own version:
http://www.joinrfa.org/press/MenhadenComments_110211.pdf