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JCAA Draft Position Paper on Amendment 1 of ASMFC Winter Flounder Plan
Prepared by JCAA Winter Flounder Committee
(from Jersey Coast Anglers Association January 2005 Newsletter)
This is a Draft Position paper that will be distributed to the JCAA clubs and put in our newspaper so a discussion and vote will take place at our December 28 meeting. Changes could be made at the JCAA meeting.
JCAA fully agrees with the concept that the Winter Flounder stock is in need of some regulation. The only place where a somewhat healthy coastal and inshore stock of winter flounder appears to exist is the New York Bight. New Jersey did not cause or contribute to the very low New England winter flounder stocks, and it is highly unlikely that our localized stock is capable of any regeneration of the New England stock to healthy levels. There is some tagging study evidence to suggest the New Jersey stock may be a somewhat localized stock, the greatest percentage of which stays in the New Jersey-New York bight area year round, with only minor northern migrations. Within the proposed plan the following statement says it all.
“The Technical Committee noted that the recreational sector of the winter flounder fishery accounts for a small percentage of winter flounder landings (~20% of the landings from the SNE/MA stock in recent years) and that reductions in fishing mortality achieved in the recreational sector may have a negligible effect on the recovery rate of the SNE/MA stock.
The Technical Committee also noted that NEFMC Amendment 13 focuses on the commercial fishery in the EEZ and did not implement any regulation on the recreational fishery. Amendment 1 to the ASMFC plan is the only available mechanism for regulating the recreational fishery.”
Presently, New Jersey has 11 inch minimum size, no bag limit, and open fishery from March through May and September 15 through December 31. At a recent Management Board meeting, it was determined that a final public hearing will be held to solicit comments and a decision made by the Board at its February meeting. The only items that may be commented on are the recreational and commercial winter flounder options! There are two preferred options being considered by the management board. They are as follows:
1. 12 inch minimum size, a 6 fish bag limit, and a closure of March and April.
2. 12 inch minimum size, a 2 fish bag limit with the existing closed season of January and February and from June 1 through September 14. March and April are open to fishing!
It has been determined that if Option 1 is to be implemented in New Jersey it will result in a 45% reduction in the fishery. Option 2 if implemented would result more than a 60% reduction in the recreational catch.
An increase of only the size limit from 11" to 12" will result in about a 17% reduction in the catch by it self.
There is a target for a 48 % reduction on a coast wide basis mentioned as guiding the recreational options. Also, if the severe recreational restrictions are implemented (basically shutting a viable recreational fishery down), then equally severe restrictions (48%) should be placed on the commercial sector (which catches ~80% of all winter flounder caught) on a coast wide basis, otherwise it appears to be a very discriminatory and arbitrary restriction. The change in gear size and reduction in days fishing placed on the commercial fleet does not in itself create or guarantee any target of a percentage of reduction. Again, any target finite percentage reduction placed on the recreational fishery should be placed as a finite target reduction on the commercial fisheries.
JCAA does not have a real problem with supporting a 12” size limit provided New Jersey be given the option of choosing to close the fall or spring season if a closed season is indicated. Remember, an increase in the size limit from 11" to 12" does result in about a 17% reduction in the catch.
More troubling is that ASMFC appears to have absolutely no concern as to the real economic impact the proposed regulation will have on local tackle stores, bait stores, charter and party boats, boat liveries and local municipalities that depend upon the spring season. For most of these it simply is “the only game in town” during the first 3 ˝ months of the year. The fall season allows for multiple fisheries to be active and viable other than winter flounder. A closure of the fall season would have a far less impact on the above economies. The NJ recreational fishery mainly takes place in back bays and rivers. Recreational boat fishermen are also regulated by weather to a very high degree during the two most important waves. We simply can’t go out every day during a season, there are too many weather variables in play at all times.
JCAA feels that because of the relatively healthy local stock, if any severe regulation is indicated, it be phased in over a three year time period to ease the economic impact on New Jersey.
It appears that 27% of the total coastal recreational catch occurs during (Wave 2) the Spring Season. Within the same (Table 3, these are 5 year totals rather than individual yearly totals) chart, the fall season (Wave 6) results in a 25+ % of the total coastal recreational catch. It would appear since it is MRFFS data that is used, the percentages would appear to be statistically the same. Table 4 (these are 5 year totals rather than individual yearly totals) indicates the number of fish caught in New Jersey during wave 2 and wave 6 to be nearly identical (1.6 million vs. 1.5 million fish).
A provision for conservation equivalency must be written into the plan by ASMFC. There does not appear to be a provision for one currently in the 6 recreational options presented. New Jersey should then have the right to examine the % reduction sought, and through conservation equivalency adjust size, season and creel limits to comply with the goals of the plan. The entire inshore winter flounder fishery is mainly of a recreational nature in New Jersey and regulated by seasons and weather conditions. States should have the rights to govern their own inshore waters.
The NJ commercial winter flounder fishery should not be regulated in general terms as if it were a cod or haddock fishery.
The issue of fyke net and pound fisheries (the main NJ inshore commercial fisheries) that are in operation in the same areas where the recreational sectors are being closed and/or severely impacted has not been adequately addressed.
It is the New England commercial fishery that has driven the overall stock towards collapse, and it and it alone must be held responsible. JCAA is sure that if it were economically feasible for the NE commercial fishery to fish the NY-NJ Bight, they would have fished it to extinction as well.