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Jersey Coast Anglers Association
Subject: Draft Addendum XXII to the Summer Flounder Scup and Black Sea Bass Fishery Management Plan for Public comment (January 2012) The Jersey Coast Anglers Association represents 75 fishing clubs and individual members who fish the waters off New Jersey. Our member clubs have reviewed the draft addendum and provide the following comments. The JCAA feels that the ASMFC has completely mishandled the management of the sea bass fishery. The public comments submitted last year on Addendum XXI were not even considered when the quotas were set. In fact the commission members did not even see the comments until late in the day of the meeting. Massachusetts made a motion for a plan that was not even sent out for public comment. This proposal was rushed through the process since it was the last agenda item on the last day of the meeting and everyone was ready to leave. So this important issue was not given its fair time and was approved so people could leave. New Jersey was severely penalized in this total abuse of the management process. The setting of last year’s quota was totally arbitrary and capricious and the anglers of New Jersey were shortchanged. Specifically, the ASMFC voted to base the 2011 quotas for each state based on their 2010 landings. They chose not to base the quotas on landings from multiple years, which would have resulted in fairer and more precise quotas for each state. This year’s Addendum does not clearly state what the problem is that they are trying to solve. Sea Bass have been managed on a coast wide basis and they do recognize that may not be the best way to manage a localized fishery. So this Addendum allows for states to develop their own measures to set seasons and limit to achieve their allotted quota. It does offer four options and does allow New Jersey to liberalize its regulations. Option 1 would continue the same regulations as last year for each state except North Carolina. This would not be good for New Jersey as we had a shortened season that resulted in us significantly under fishing our quota. Option 2 would allow each state to adopt regulations. New Jersey regulations would include a 100% liberalization. Option 3 would allow the northern states including New Jersey to each develop regulations with a 57% liberalization. Option 4 would allow the four states north of us to each develop regulations with a 44% liberalization. New Jersey would be allowed to liberalize 100%. The JCAA supports and recommends either Option 2 or option 4 which allow New Jersey to develop proposals that allow for an increase of up to 100% of the estimated 2011 landings. As stated in the section entitled Stock Status the stock of Sea Bass is not over fished and over fishing is not occurring… It further states that the total biomass remains above the biomass maximum sustainable yield. The spawning stock biomass is 30.7 million pounds, which is 111% of the target. It is further estimated that the average recruitment (age one) in 2010 (2009 cohort) was 26.8 million fish. With this level of biomass and this many fish it does not make sense that the harvest limit is reduced from 1.78 million pounds down to 1.32 million pounds. This means that the harvest level for 2011 will be 4.2% of the spawning stock biomass. Was there a mistake in the calculations? It is incomprehensible that the harvest numbers in Table 1 in section 5.0 are correct. The fluctuation in harvest in the years 1996 – 2008 don’t pass the common sense test. The high harvest in the range was in 1997 with a harvest off 4.3 million pounds in 1997 then the next year it drops to a low for the series at 1.2 million pounds. Could it be the MRFS data is wrong? The season was cut drastically in 2010 and 2011 so it is reasonable that the harvest would be less than previous years. A precipitous drop in harvest from 2010 (2.98 million pounds) to 2011 (0.99 million pounds) would indicate that something dramatic has happened; yet this is not addressed in the document. The same can be said of the years 1997 and 1998 when a similar drop in the harvest numbers occurred. Could it be that the MRFS data is wrong? In reading the section Statement of the Problem it is difficult to determine what the perceived problem is. The problem is that the Harvest Quota is unrealistic and should be revisited and increased to a level consistent with the historical information provided in this document. What is happening with this fishery? Certainly the data must be reexamined to determine the root cause of the problem. Could it be that the MRFS data is wrong? There is another misconception in the document. On page 5 under the Note: in section 4.0 Proposed Management Program it states: “The MRFSS data used to set state by state specific conservation equivalent measures produces more variable results when used on a state-by-state basis. As the coverage area increases the variability of the data decreases; therefore, adopting regional or coast wide approaches will give more precision to the data.” This statement makes the incorrect assumption that the sample size has increased as the coverage area increase. Increasing the coverage area introduces additional variables such as different weather patterns and fish availability therefore the samples are separate entities and cannot be combined. Therefore the data in each individual area must be examined separately. Combining areas cannot be used as a justification that the variability decreases. What it does show is that the sample size in each individual state is totally inadequate. In regard to landings as shown in table 3 of Addendum XXII New Jersey's percentage of the total coastal landings dropped from 38% in 2009, to 29% in 2010 and to 19% in 2011. If historical landings are used to set future quotas on a state-by-state basis then the landings from 2009 before the season was drastically changed should be used as the base year.
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