JCAA Position Statement on Addendum XVII To The Summer Flounder, Scup And Black Sea Bass Fishery Management Plan

 The Jersey Coast Anglers Association is a group of 75 fishing clubs who fish in New Jersey.  We have reviewed Draft Addendum XVIII to the Summer Flounder Fishery Management Plan:  Summer Flounder Recreational Fishery Management and find it to be totally lacking of merit.

The only option which should be considered is Status Quo for the following reasons.

1)           In 2001, 2002 and early in 2003 the states of Maryland, Delaware, Virginia and New Jersey had gone over quota.  The reaction of the council and the states of New York and Connecticut was totally without compassion.  There was no sympathy, no consideration of how they could help their neighboring states out of this problem.  In fact, what New York pushed for was recreational paybacks if a state went over their quota.  Luckily for New York that motion did not pass or they would be in an even more serious situation than they are now.

2)           Is it proper or reasonable to penalize states that take a more conservative approach when they set their seasons and size and bag limits?  The states do that so they would insure that they would not exceed their quota.  The prime example of that is New Jersey.  Based on the information and tables that were presented in 2004 for the 2005 season, New Jersey could have elected to go to a smaller size or a longer season.  The fisheries managers in New Jersey with the support of recreational organizations took the more conservative approach and elected to stay with the larger size limit and approximately the same length of season.  The fear is that we never know what NMFS’ next move will be.  This conservative approach is much to the dismay of anglers who had hoped for some relief from the onerous regulations they have been living with for years.  The result of this conservative approach was that New Jersey was 30% under their quota.  How should New Jersey anglers be rewarded for their conservation?  By giving it to New York?  That is neither reasonable nor ethical.

3)           At the recent ASMFC meeting in Atlantic City New York and Connecticut were the states that pushed for a 2006 quota of 23.59 million pounds instead of taking the hard stance and insisting that the quota be 26 million pounds.  This addendum rewards NY and CT for that effort.  No thank you.  The anglers of New Jersey will not help those who will not help themselves.

4)           This proposed Management Plan is not a solution.  It is not even a quick fix to the management of Summer Flounder.  The ASMFC must address the bigger problem of how to deal with recovering stocks in a reasonable manner.

5)           A better method of determining the number of fish caught by recreational anglers must be developed.  To base management decisions on data from the MRFS survey is nonsensical.  We can never rely on NMFS and MRFS to show consistency from one year to another.  Data from party and charter boat logbooks are a far better indication of the number of fish caught recreationally and yet that scientific data is ignored.  Yes, it is scientific data.  Any data that is measured, recorded and signed is scientific data by definition.

6)           We believe we cannot trust the models NMFS uses.  In 2004, using 75% probability, ASMFC and Mid-Atlantic Fisheries Management Council were told by NMFS that we could set quotas of 30,000,000 pounds for 2005 and 33,000,000 for 2006.  Instead we wind up with a quota of 23,600,000 pounds.  ASMFC did not stand by its decisions and acquiesced to NMFS again.  Uncertainty generates fear and distrust.  The states have gotten so paranoid about going over that have gone very conservative.  New Jersey underfished its recreational target by 30% and its commercial fishery by over 500,000 pounds.  If anything is to be done with the difference between what we caught and our target it should be used to reward the recreational and commercial industry of the state where the lost opportunity to harvest fish took place.

7)           If we are not going to reward that the state that was responsible for the savings then let savings be savings.  These types of transfers should only be made when the states that are affected can all agree.  The state that did the realized the savings might want it to go to rebuilding the stocks faster and that should be allowed.  Are we going to do the same with the commercial quotas?  New Jersey and NC are going to be way under their commercial quota.  Are we going to transfer that to states that went over their targets?

In conclusion, JCAA has been very supportive of New York’s situation of recreational overages in the last couple of years.  New Jersey commissioners and JCAA fought against NY recreational reduction in 2003 and 2004.  JCAA and New Jersey commissioners supported the 26 million pound quota for 2006 that would have little impact on New Jersey’s recreational fishery but would have greatly helped New York’s recreational fishery.  New York and Connecticut commissioners voted against the 26,000,000 and support the 23,600,000.  New York will need to live with that decision.

Bruce B. Smith,

President

Jersey Coast Anglers Assoc.

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