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State of New Jersey Office of the Governor 125 West State Street PO Box 001 Trenton NJ 08625-0001 Jon S. Corzine, Governor August 8, 2007 W. Peter Jensen, Chairman Mid-Atlantic Fishery Management Council Room 2115 Federal Building300 South New Street Dover, Delaware 19904-6790 Dr. William T. Hogarth, Director National Marine Fisheries Service National Oceanic and Atmospheric Administration 1315 East-West Highway Silver Spring, Maryland 20910
Dear Chairman Jensen and Dr. Hogarth: I am writing to you regarding the management of summer flounder, with particular attention to the quota for the 2008 fishing year. As you know, just seven months ago, the Atlantic States Marine Fisheries Commission (ASMFC), the Mid-Atlantic Fishery Management Council (MAFMC), and National Marine Fisheries Service (NMFS) set the 2007 summer flounder quota and projected a 2008 quota of 19.6 million pounds if the rebuilding schedule was extended. In addition, in January, Congress reauthorized the Magnuson-Stevens Fishery Conservation and Management Act, which includes a provision to extend the summer flounder rebuilding schedule for three years. It has come to my attention, however, that the recommendation to the MAFMC is for a 2008 summer flounder quota between 11.64 and 12.9 million pounds, 34 to 40% below the original projection. I am very concerned that, even with the rebuilding schedule extension, summer flounder quotas continue to drop. These concerns have led many to call into question the accuracy and validity of the science upon which management is based. I would therefore request that all available data, assessment methodology, and results, including the biological reference points, be thoroughly reviewed by an independent panel of experts. The ASMFC Summer Flounder, Scup, and Black Sea Bass Management Board made this very recommendation during their December 2006 meeting in New York City. Although the management agencies have policies in place for stock assessment peer review, I recommend that the summer flounder assessment be reviewed through the National Research Council (NRC) of the National Academy of Sciences. An NRC review would be entirely independent of all management agencies and would follow the precedent of the NRC review of the summer flounder stock assessment in 2000. In addition, a truly independent review will go a long way toward restoring the public’s faith in the summer flounder management process. Summer flounder is an extremely important contributor to New Jersey’s $2 billion a year marine fishing industry. Commercially, summer flounder ranks first in terms of economic value for all finfish species landed in New Jersey, while recreationally it ranks first both in terms of harvest and number of directed trips. Diminishing quotas place an undue hardship on the numerous businesses directly and indirectly linked to these key New Jersey fisheries, particularly when you consider that the summer flounder resource is at the highest biomass level on record. Coastwide, summer flounder resource users have borne the burden of stock rebuilding long enough. It is important for them to have access to accurate, reliable science in order to maximize the potential of this valuable resource. Thank you for your attention in this matter. Sincerely, Jon S. Corzine Governor c. V. O'Shea, ASMFC Executive Director D. Furlong, MAFMC Executive Director |
Mid-Atlantic Fishery Management Council Room 2115 Federal Building 300 South New Street Dover, Delaware 19904-6790 Tel 302-674-2331 Toll Free 877-446-2362 Fax 302-674-5399 W. Peter Jensen Chairman Daniel T. Furlong Executive Director Dr. Gene Kray Vice Chairman August 24, 2007 The Honorable Jon Corzine The Governor of New Jersey PO Box 001 Trenton, NJ 08625 Dear Governor Corzine: Thank you for your letter of August 8 regarding the management of summer flounder and your expressed concern regarding the likely quota for summer flounder in 2008. At the moment, our Council and the Atlantic States Marine Fisheries Commission have jointly recommended to the National Marine Fisheries Service a quota of 15,770,000 pounds for 2008. That recommendation represents a decrease of 1,340,000 pounds from the current year quota and is the lowest quota level we have ever recommended in the history of summer flounder despite the greatest abundance of summer flounder in the past twenty five years. Moreover, despite overfishing as it is currently defined under the terms of the Magnuson - Stevens Act, the abundance of summer flounder has more than doubled its biomass and tripled its spawning stock biomass since 1993 when the current summer flounder allocation system was implemented. We are well aware of and genuinely appreciate the extremely important contribution the summer flounder fishery is to the State of New Jersey both as a commercial fishery as well as your state's most important recreational fishery. We share your concern regarding the science upon which our management is based. Nonetheless, as a federal Regional Fishery Management Council created by the Magnuson-Stevens Act (MSA) we are charged by that law to meet its National Standards and its rebuilding timelines. The confounding aspect of the Magnuson-Steven Act as it relates to summer flounder is that we have an inflexible timeline (rebuild by January 1, 2013) to achieve a scientifically established spawning stock biomass target of 197,000 pounds. These twin pinchers leave little flexibility for us in our quota setting process. Hence, to meet the letter of the law we are required to recommend lower quotas despite the large biomass of summer flounder. We cannot honor your recommendation that the summer flounder assessment be reviewed through the National Research Council of the National Academy of Science as we do not have the financial where-with-all to undertake such a review. However, we do not object to such a review and understand that the National Marine Fisheries Service (already in receipt of such a request from Congressman Pallone) is considering whether or not such a review will be financed by that organization. You should be aware that over the last 25 years summer flounder stock assessments have been peer reviewed 16 times and the summer flounder species is undoubtedly the most frequently, independently peer reviewed stock for which we have a management responsibility. Moreover, we are aware that the National Marine Fisheries Service is committed to a June 2008 benchmark stock assessment for summer flounder. That process will include a Stock Assessment Workshop (SAW) where all the data regarding surveys and landings are reviewed for their completeness and accuracy, and following this, there is a Stock Assessment Review Committee which evaluates the model's applicability to the stock assessment estimates and related forecasts for appropriateness. This independent peer review will be conducted by a board of three experts who are assigned to this specific task by the University of Miami's Center for Independent Expertise. We, along with all the other interested parties involved with summer flounder management, are looking forward to the outcome of next year's benchmark stock assessment. By way of additional background, when the rebuilding target for summer flounder was established it was based on information since 1982 and represents the stock's behavior over the past 25 years. Now, after many years of management there is no clear answer to the question of whether the biomass target can be achieved to meet the Magnuson - Stevens Act’s requirement to rebuild stocks as quickly as possible, but not to exceed 10 years (extended in the 2007 reauthorization by three years to January 1, 2013). Yet, even with the three year extension it is difficult to predict, project and measure - over the short term - the outcome of management measures in a diverse and variable ocean ecosystem within the mandated time period. This uncertainty has resulted in increasingly restrictive measures as a means of achieving the biomass target within the mandated time period. Our Council has heard repeatedly from fishermen and others about the hardships they are facing year after year as these measures have been implemented. In closing, please allow me to offer a personal perspective as a long time participant in fisheries management that pre-dates passage of the Magnuson - Stevens Act. I believe it is important that Congress give the Councils as much flexibility as possible in making decisions that balance the needs of our fisheries with sustainable fish stocks. The unique character of the Council membership as a forum to blend scientific advice with the reality of how our diverse fisheries are conducted and the social and economic consequences of management are central to good decision making and frequently call for judgment in addition to considering the science. This gives rise to controversy as is frequently the case when there is uncertainty in the short term, particularly with a deadline to meet. It is my belief that the original intent of the Magnuson Act that created this unique form of government was a sound idea that needs the continued support of Congress to allow the Council system to work as intended. Sustainable fisheries can be achieved over the long term of many decades without arbitrary deadlines. As we work toward the long term sustainability we must also pay attention to the short term economic and social consequences of regulation. Rebuilding deadlines and natural events can undermine the fishing communities that look to the Council for relief. Without more options to provide some relief when justified we face the prospect of conserving fish stocks but damaging the very fisheries that we want to be economically healthy. Very truly yours, W. Peter Jensen Chairman CC: Bill Hogarth, NMFS Vince O'Shea, ASMFC Daniel Furlong, MAFMC |